# Georgia's State Implementation Plan
for the
Atlanta 8-Hour Ozone Nonattainment Area

September 8, 2009

Prepared by:

Georgia Department of Natural Resources
Environmental Protection Division
Air Protection BranchThis page is left intentionally blankThe Atlanta Eight-Hour Ozone Attainment Demonstration



## PREFACE

This document contains Georgia's modeling de monstration that the metro Atlanta region
8-hour ozone nonattainment area will meet th e National Ambient Air Quality Standard for 8-hour ozone by June 15, 2010. This area in cludes the entire c ounties of Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb, Co weta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Henry, Newton, Paul ding, Rockdale, Spalding, and Walton.

3The Atlanta Eight-Hour Ozone Attainment Demonstration



## EXECUTIVE SUMMARY

INTRODUCTION
Ozone, a strong chemical oxidant, adversel y impacts human health through effects on respiratory function and can also damage forests and crops. Ozone is not emitted directly but instead is formed in the lower atmosphe re (the troposphere) by a complex series of chemical reactions involving nitrogen oxides (NOx) and reac tive volatile organic compounds (VOCs). NOx emissions are the re sult of combustion pr ocesses at electric utilities, industrial sources, motor vehicles , and other non-road and area sources. VOCs include many industrial solvents as well as the various hydrocarbons (HC) that are evaporated from the gasoline used by moto r vehicles or emitted through the tailpipe following combustion. Additionally, VOCs are emitted by natural sources such as trees and crops.

Ozone formation is promoted by strong sunlig ht, warm temperatures and light winds. High concentrations tend to be a problem in the eastern Unite d States only during the hot summer months when these conditions freq uently occur. Therefore, the U.S. Environmental Protection Ag ency (USEPA) mandates seasonal monitoring of ambient ozone concentrations in Georgia from Ma rch 1 through October 31 (40 CFR 58 App. D, Table D-3).

NATIONAL AMBIENT AIR Q UALITY STANDARD (NAAQS)
The Clean Air Act (CAA) establishes a pro cess for air quality management through the National Ambient Air Quality Standards (NAAQS ). Area designations are required after promulgation of a new or revised NAAQS. In 1979, EPA promulgated the 0.12 parts per million (ppm) 1-hour ozone standard (44 FR 8202, February 8, 1979) . On July 18, 1997, EPA promulgated a revised ozone standard of 0.08 ppm, measured over an 8-hour period, i.e., the 8-hour standard (62 FR 38856). The 1997 NAAQS rule was challenged by numerous litigants and the legal cha llenges were resolved by March of 2002.

A violation of the NAAQS occurs when the average of the annual fourth highest daily
maximum 8-hour ozone values over three consec utive years is equal to or greater than 0.085 ppm. This three-year aver age is termed the design va lue for the monitor. The design value for a nonattainment area is the highest monitor's desi gn value in the area.

4The Atlanta Eight-Hour Ozone Attainment Demonstration

REGULATORY HISTORY OF OZONE PROBLEM IN ATLANTA, GEORGIA

Pursuant to the Clean Air Act Amendmen ts of 1990 (CAAA), the Atlanta area was designated as nonattainment for the pollutant ozone by U.S. EPA and was classified as a
serious 1-hour ozone nonattainment ar ea on November 6, 1991. The 1-hour ozone nonattainment area (NAA) was at that time ge ographically defined as the following 13 Georgia counties: Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, and Rockdale. Because Atlanta failed to attain the 1- hour ozone NAAQS by November 15, 1999, EPA issued a final rulemaking action in the September 26, 2003, Federal Register (68 FR 55469) determining that, by operation of law, the Atlanta area was being reclassified as a "severe" ozone nonattainment area effective January 1, 2004. In addition to having been required to submit state implementation plan (SIP) revisions meeti ng requirements for marginal, moderate, and
serious ozone nonattainment ar eas, Georgia was required to submit plans meeting the additional requirements for areas classified as severe. As a result of EPA's implementation of the original federal Clean Air Act of 1970, the Clean Air Act Amendments of 1977, and the Clean Air Act Amendments of 1990, EPD has completed, and EPA has approved (67 FR 30574), SIP re visions to address the Atlanta one hour
ozone nonattainment area.

On February 1, 2005, EPD requested that the Atlanta area be redesignated from nonattainment to attainment with respect to the 1-hour ozone NAAQS in accordance with section 107(d) of the Clean Air Act. This request was base d on three years, 2002 through 2004, of ambient monitoring data at all 11 oz one monitors in the Atlanta NAA showing no violation of the 1-hour ozone NAAQS; the implementation of permanent and enforceable reductions in ozone precursor emissions; compliance with all applicable requirements; and the Atlanta Maintenance Plan with projections demonstrating that the 2002 emission levels in this area will not be exceeded through at least the year 2015. EPD also petitioned EPA to make a determinat ion that the Atlanta area was eligible for application of EPA's Clean Data Policy, base d on the Atlanta area's attainment of the 1- hour ozone NAAQS. EPA approved the plan a nd redesignation reque st effective June 14, 2005 (70 FR 34660).

Ozone design-values (DV; three year average of the 4th highest reading per year) for the 2001-2003 period, which was used in desi gnating the Atlanta 20 county area as nonattainment, show that 10 out of the 11 sites exceed the 8-hour ozone NAAQS (0.08 ppm). The highest design value for these 11 sites was 0.091 ppm. Therefore, on April 30, 2004, EPA designated 20 metropolitan Atlanta counties as a "marginal" nonattainment
area under the 8-hour ozone standard. Th e eight-hour ozone nonattainment area encompasses the 13 counties of the former 1-hour ozone nonattainment area plus seven additional "ring" counties: Barrow, Bartow, Carroll, Hall, Newton, Spalding, and
Walton. With an attainment deadline of J une 15, 2007, marginal areas were required to attain the National Ambient Air Quality St andard (NAAQS) by the 2006 ozone season.

Because monitoring data from the 2006 ozone season indicates that Atlanta has not attained the NAAQS, the area was reclassified to a higher classification (i.e., "moderate"). On October 16, 2007, EPA propos ed to find that the Atlanta, Georgia

5The Atlanta Eight-Hour Ozone Attainment Demonstration

"marginal" 8-hour nonattainment ozone area ha d failed to attainment the 8-hour ozone NAAQS by June 15, 2007, and to reclassify the Atlanta, Georgia nonattainment area as a
“moderate” 8-hour ozone nonattainment area. This finding and reclassification was finalized on March 6, 2008 [ 73 FR 12013-12017]. The "moderate" area attainment date for the Atlanta, Georgia area would then be "a s expeditiously as pract icable," but no later than June 15, 2010. As part of this recla ssification, EPA required the submittal of an 8-
hour ozone SIP revision to be submitted "as expeditiously as practicable" but not later than December 31, 2008.

This submittal represents an attainment demonstration (40 CFR 51.908) for the Atlanta
metro 8-hour ozone nonattainment area that consists of the following counties: Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb, Co weta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, Pi ckens, Rockdale, Spalding, and Walton
counties.

CONTROLS APPLIED
Attaining the federal 8-hour oz one NAAQS will require the involvement of all sectors of Georgia's economy and populati on. Significant reductions in man-made sources of VOC
and NOx were achieved via state and federa l regulatory and voluntary control measures for attainment of the 1-hour ozone NAAQS. This set of existing requirements and voluntary efforts serve as the basis for consid ering further control measures. Since the metro Atlanta region is also designated nona ttainment for the federal PM2.5 standards, control strategies for PM2.5 and the 8-hour ozone NAAQS will be integrated and harmonized to the extent possible.

Control measures already in place or bei ng implemented over the next few years will reduce stationary point, highway mobile, a nd nonroad mobile sources emissions. The expected Federal and State control measures were modeled for the attainment year of
2009.

The Federal control measures that were mode led included the Clean Air Interstate Rule, Federal Ozone Measures (CAA Section 183( e)), motor vehicle emission and fuel standards (e.g., Tier 0, 1, and 2 emission sta ndards; gasoline volatili ty requirements; and fuel sulfur requirements), and nonroad engine s and vehicles emission standards. The State control measures that were modeled include the vehicle emissions inspection and maintenance program; Georgia's 45-county Gasoline Marketing Rule, 391-3-1- .02(2)(bbb); existing VOC and NOx RACT measures; and new Georgia Rule 391-3-1- .02(2)(sss) Multipollutant Control for Electric Utility Generating Units which establishes a schedule for the installation and operation of NOx and sulfur dioxide pollution control systems on many of the coal-fired power plan ts in and around the Atlanta metro area.

6The Atlanta Eight-Hour Ozone Attainment Demonstration

ATTAINMENT RESULTS
Georgia EPD conducted an attainment demonstr ation in accordance with the US EPA's September 2006 draft final Guidance On The Use Of Models And Other Analyses for Demonstrating Attainment of Air Qualit y Goals for Ozone, PM2.5, and Regional Haze (" Attainment Guidance "). Section 3.0 of the Attainment Guidance recommends applying
both a modeled attainment test and a subse quent unmonitored area analysis to the air quality modeling results to determine if the 8-hour ozone NAAQS will be met.
Additional technical or corroboratory analyses may also be used as part of a "weight of evidence" determination to supplement the modeled attainment test and to further support a demonstration of attainment of the NAAQS.

The EPD has evaluated future ozone design va lues using a combination of two methods for calculating modeling baseline design va lues (DVBs) (2001-2003 and weighted 2000- 2004), and two methods for calculating the rela tive response factors (RRFs) ("maximum in array" and "monitor grid ce ll"). A summary of future de sign values (DVFs) based on these four test configurations is given in Table E-1. DVFs for ten out of the eleven
monitors show attainment of the 8-hour ozone NAAQS using the 2000-04 DVB and "maximum in array" method. However, all el even sites show attainment of the NAAQS when using the "monitor grid cell" ap proach or when using the 2001-03 DVB.

Table E-1: Atlanta attainment test resul ts for 2009 based on four different test configurations.

Bold red numbers indicate DVF at or a bove 85 ppb; Bold, underlined green numbers indicate DVF below 85 ppb but within wei ght-of-evidence range; Standard-font green numbers indicate DVF below 82 ppb.

Site name AIRS ID 2000-04 DVB;
"max in array" 2000-04 DVB;
"monitor grid cell" 2001-03 DVB;
"max in array" 2001-03 DVB;
"monitor grid cell"

Conf. Ave. 13-121-0055 86 84 83 82
McDonough 13-151-0002 80 80 77 77
Douglasville 13-097-0004 80 80 80 80

Kennesaw 13-067-0003 81 81 80 80

Tucker 13-089-3001 82 82 81 80

Conyers 13-247-0001 79 79 77 77

S. DeKalb 13-089-0002 82 80 80 78

Newnan 13-077-0002 77 76 76 74

Lawrenceville 13-135-0002 79 79 76 77

Yorkville 13-223-0003 75 75 76 76
Fayetteville 13-113-0001 75 75 73 73

7The Atlanta Eight-Hour Ozone Attainment Demonstration

The modeled attainment demonstration perfor med according to EPA guidance results in a single monitor in the Atlanta NAA exceedin g the 8-hour ozone NAAQS (DVF of 86 ppb at the Confederate Avenue monitoring site). However, the weight of evidence analysis
demonstrated in Section 6.2 of this document provides strong evidence that the Atlanta 8-
Hour Ozone NAA will demonstrate attain ment of the ozon e NAAQS by 2009. The attainment demonstration with the weight of evidence analysis is effective since the unmonitored area analysis showed no mo deling grid cell greater than 86 ppb. Furthermore, the additional emission control or reduction measures identified in Section 5.3 of this document as well as those contingency measures that will be implemented, regardless of attainment st atus, will provide additional emission reductions beyond those quantified and modeled for this attainment demonstration. Therefore Georgia EPD concludes that this document provides an adeq uate demonstration of compliance with the 8-Hour Ozone NAAQS for the Atlanta 8-Hour Ozone NAA by the year 2009.

8The Atlanta Eight-Hour Ozone Attainment Demonstration

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9The Atlanta Eight-Hour Ozone Attainment Demonstration

TABLE OF CONTENTS

PREFACE .......................................................................................................................... 3

EXECUTIVE SUMMARY .............................................................................................. 4

INTRODUCTION .............................................................................................................. 4

NATIONAL AMBIENT AIR QU ALITY STANDARD (NAAQS) ................................... 4

REGULATORY HISTORY OF OZONE PROBLEM IN ATLANTA, GEORGIA ......... 5

CONTROLS APPLIED ..................................................................................................... 6

ATTAINMENT RESULTS ................................................................................................ 7

1.0 INTRODUCTION ............................................................................................... 20

1.1 Ozone as an Air Pollutant................................................................................. 20

1.2 Ozone as a National Ambient Air Quality Standard ......................................... 22

1.3 Regulatory History of Atlanta's Smog Problem ................................................ 23

1.4 Nonattainment Area Designation for 8-Hour Ozone in Atlanta ....................... 23

1.5 8-Hour Ozone Design Values in Atlanta .......................................................... 27

1.6 SIP Requirements for Moderate Nonattainment Areas .................................... 28

2.0 CONCEPTUAL DESCRIPTION OF 8-HOUR OZONE LEVELS IN
ATLANTA AND GEORGIA ......................................................................................... 34

2.1 Conditions Leading to Elevated Ozone in the Atlanta Area ............................. 40 2.1.1 Analysis of PAMS data in Atlanta using Ozone M.A.P.P.E.R................. 43

2.2 Weekday/weekend trends in ozone concentrations ........................................... 46

2.3 Conclusions ....................................................................................................... 47

3.0 ATTAINMENT DEMONSTRATION METHODS AND INPUTS ............... 49

3.1 Analysis Method ................................................................................................ 49

3.2 Model Selection ................................................................................................. 50
3.2.1 Selection of Photochemical Grid Model ................................................... 50
3.2.2 Selection of Meteorological Model .......................................................... 51

10The Atlanta Eight-Hour Ozone Attainment Demonstration

3.2.3 Selection of Emissions Processing System ............................................... 54

3.3 Episode Selection .............................................................................................. 55
3.3.1 Overview of U.S.EPA Guidance on Ozone.............................................. 55

3.3.2 Episode Selection ...................................................................................... 56

3.4 Modeling Domains............................................................................................ 56
3.4.1 Horizontal Modeling Domain ................................................................... 56
3.4.2 Vertical Modeling Domain ....................................................................... 58

3.5 Emission Inventory ............................................................................................ 59
3.5.1 Types of Emission Inventories .................................................................. 59
3.5.2 Emission Inventory Source Classification ................................................ 60
3.5.3 Stationary Point Sources ........................................................................... 64
3.5.4 Stationary Area Sources ............................................................................ 66
3.5.5 Off-Road Mobile Sources ......................................................................... 67
3.5.6 Highway Mobile Sources .......................................................................... 67
3.5.7 Biogenic Emission Sources ....................................................................... 68
3.5.8 Emission Inventory Summary fo r Atlanta Nonattainment Area ............... 69

4.0 MODEL PERFORMANCE EVALUATION ................................................... 72

4.1 MM5 Model Performance Evaluation ................................................................... 72

4.2 CMAQ Air Quality Model Performance Evaluation ............................................. 78 4.2.1 Air Quality Modeling Evaluation Methodology.............................................. 78 4.2.2 Air Quality Modeling Evaluation Results ....................................................... 81

5.0 CONTROLS APPLIED .................................................................................... 103

5.1 Control Measures Analyses for Stationary Point and Area Sources .............. 104

5.2 Control Measures Analyses for On-Road Mobile Sources ............................. 111

5.3 Control Measures Analyses for Off-Road Mobile Sources ............................. 114

5.4 Action Plan for Reducing Emissions with Voluntary Control Measures ........ 120
5.4.1 Emission Reductions from Transportation Measures ............................. 121
5.4.2 Retrofits/Use of Alternative Fuels .......................................................... 124 5.4.3 Energy Demand Reduction..................................................................... 126
5.4.4 Activities at Hartsfield-Jackson Atlanta International Airport ............... 128

6.0 ATTAINMENT DEMONSTRATION ............................................................ 130

6.1 Modeled Attainment Test ................................................................................ 130

6.2 Weight of Evidence ......................................................................................... 132
6.2.1 Use of Monitor Grid to Calculate RRFs ................................................. 133
6.2.2 Use of Alternative DVB to Calculate DVF ............................................ 134

6.3 Local Measures not Modeled .......................................................................... 136

6.4 Unmonitored Area Analysis ............................................................................ 136

11The Atlanta Eight-Hour Ozone Attainment Demonstration

6.5 Summary ......................................................................................................... 141

6.6 Attainment Conclusion .................................................................................... 142

7.0 SENSITIVITY OF OZONE IN ATLANTA TO NOx AND VOC
EMISSIONS .................................................................................................................. 143

7.1 Cases Modeled ................................................................................................ 143

7.2 Results ............................................................................................................. 144

7.3 Discussion ....................................................................................................... 146

8.0 OTHER CLEAN AIR ACT REQUIREMENTS ........................................... 147

8.1 RACT/RACM Requirements ............................................................................ 147

8.2 Reasonable Further Progress ......................................................................... 147

8.3 Actual Emissions Inventory............................................................................. 147

8.4 Emissions Inventory Statement ....................................................................... 148

8.5 Periodic Emissions Inventory ......................................................................... 148

8.6 Permit Program Requirements ....................................................................... 148

8.7 Inspection and Maintenance Program ............................................................ 148

8.8 Other Measures ............................................................................................... 149

8.9 Compliance with Section 110(a)(2) ................................................................ 149

8.10 Equivalent Techniques .................................................................................... 149

8.11 Contingency .................................................................................................... 149 8.11.1 Contingency Overview ........................................................................... 149

8.11.2 Contingency Measures ............................................................................ 149
8.11.3 Contingency Emission Reductions for Failure to Attain ........................ 150

9.0 MOTOR VEHICLE EMISSIONS BUDGETS .............................................. 152

9.1 Background ..................................................................................................... 152

9.2 Establishment of 2009 Motor Vehicle Emi ssions Budgets for the Atlanta 8-Hour
Ozone Nonattainment Area ......................................................................................... 152

10.0 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT)
ANALYSIS .................................................................................................................... 155

11.0 INFRASTRUCTURE SIP ELEMENTS ......................................................... 196

12.0 REFERENCES .................................................................................................. 207

12The Atlanta Eight-Hour Ozone Attainment Demonstration

LIST OF FIGURES

Figure 1-1: Diagram Illu strating Ozone Formation ................................................... 21

Figure 1-2: Location of ozone monitors within the Atlanta 20-county nonattainment

area ........................................................................................................................... 26

Figure 2-1: (a) Area-average and (b) si ngle-site area-maximum ozone DVs for 2001-

2006........................................................................................................................... 37

Figure 2-2: (a) Area-average and (b ) single-site area-maximum number of

exceedances of the ozone NAAQS leve l (expressed as 85 ppb) in 2001-2006. ... 38

Figure 2-3: Inter-a nnual trends in NO
x emissions (total Georgia EGU and 13-county

Atlanta on-road mobile-source emissions) and count of "ozone conducive days"

for 1996-2005. .......................................................................................................... 40

Figure 2-4: Average diurnal pattern in exte nt of reaction for th e four PAMS sites

for 1997-2005 ........................................................................................................... 44

Figure 2-5: Average diurnal pattern in extent of reaction for 1997-2005 binned by

the daily maximum 8-hour ozone concentration (<65ppb, 65-85ppb, 85-105ppb,

>105ppb) for (a) Yorkville, (b) Tucker, (c) South-DeKalb, and (d) Conyers. ... 45

Figure 2-6: Weekdays/weekend differences in ozone concentrations at the

Confederate Avenue site and the four Atlanta PAMS sites for (a) 1997-2005, (b)

1997-1999, (c) 2000-2002, and (d) 2003-2005. ....................................................... 47

Figure 3-1: The MM5 horizontal domain is the outer most, blue grid, with the

CMAQ 36-km domain nested in the MM5 domain. ............................................ 57

Figure 3-2: A more detailed view of th e 12-km grid over the VISTAS region. ......... 58

Figure 3-3: Ozone season daily NO X and VOC emissions by source categories for 20

counties in Atlanta. ................................................................................................. 70

Figure 3-4: Ozone season daily NO X and VOC Emissions by source categories and

metro Atlanta 8-hour ozone nonattainment counties. ......................................... 71

Figure 4-1: Monthly average d Bias statistics for 2-m temperature and humidity ... 76

Figure 4-2(a): Mean Normalized Bias for 1-ho ur and 8-hour ozone concentrations of

CMAQ 12 km simulation at 11 monitor sites in 20 counties around Atlanta. .. 85

13The Atlanta Eight-Hour Ozone Attainment Demonstration

Figure 4-2(b): Mean Normalized Gross Error for 1-hour and 8-hour ozone

concentrations of CMAQ 12 km simulati on at 11 monitor sites in 20 counties

around Atlanta. ....................................................................................................... 86

Figure 4-3: Daily Mean Normalized Bi as over 20 counties around Atlanta for

observed 1-hour O 3 > 60 ppb. ................................................................................ 87

Figure 4-4: Daily Mean Normalized Gross Error over 20 counties around Atlanta

for observed 1-hour O 3 > 60 ppb. .......................................................................... 88

Figure 4-5: Daily Mean Normalized Bi as over 20 counties around Atlanta for

observed 8-hour O 3 > 60 ppb. ................................................................................ 89

Figure 4-6: Daily Mean Normalized Gro ss Error over 20 counties around Atlanta

for observed 8-hour O 3 > 60 ppb. .......................................................................... 90

Figure 4-7(a): Mean Normalized Bias for daily maximum 1-hour and 8-hour ozone

concentrations of CMAQ 12 km simulati on at 11 monitor sites in 20 counties

around Atlanta. ....................................................................................................... 91

Figure 4-7(b): Mean Normalized Gross E rror for daily maximum 1-hour and 8-

hour ozone concentrations of CMAQ 12 km simulation at 11 monitor sites in 20

counties around Atlanta. ........................................................................................ 92

Figure 4-8: Daily Mean Normalized Bias over 20 counties around Atlanta for daily

maximum 1-hour O 3 (paired in space). ................................................................. 93

Figure 4-9: Daily Mean Normalized Gro ss Error over 20 counties around Atlanta

for daily maximum 1-hour O 3 (paired in space). ................................................. 94

Figure 4-10: Daily Mean Normalized Bias over 20 counties around Atlanta for daily

maximum 8-hour O 3 (paired in space). ................................................................. 95

Figure 4-11: Daily Mean Normalized Gro ss Error over 20 counties around Atlanta

for daily maximum 8-hour O 3 (paired in space). ................................................. 96

Figure 4-12: Tile plot of daily 8-hour maximum ozone concentrations on June 12,

2002........................................................................................................................... 97

Figure 4-13(a): Bar plots for daily maxi mum concentrations of 8-hour ozone. ........ 98

Figure 4-13(b): Bar plots for daily maxi mum concentrations of 1-hour ozone. ....... 99

Figure 4-13(c): Bar plots for daily maximu m concentrations of nitrogen dioxides. 100

14The Atlanta Eight-Hour Ozone Attainment Demonstration

Figure 4-14: Weekly time series plot for hourly ozone concentration at the

Confederate Avenue site. ...................................................................................... 101

Figure 4-15: Scatter plot of 8-hour ozone concentrations at the Confederate Avenue

site. .......................................................................................................................... 103

Data points are from observed and mode led 8-hour concentrations in June 2002. 103

Figure 6-1: Demonstration of EPD's MATS operation. ............................................ 138

Figure 6-2: Results of MATS when 21 days were used for spatial gradient

calculations. ........................................................................................................... 139

Figure 6-3: Detail visualization of MA TS outputs when 21 days were used. ......... 140

Figure 6-4: Detail visualization of MATS outputs when 153 days were used. ........ 141

Figure 7-1: Modeled 2009 daily maximum 8- hr ozone at the Confederate Avenue

site, .......................................................................................................................... 145

Figure 7-2: Modeled 2009 daily maximum 8-hr ozone at the Confederate Avenue 146

15The Atlanta Eight-Hour Ozone Attainment Demonstration

LIST OF TABLES

Table E-1: Atlanta attainment test resul ts for 2009 based on four different test

configurations. ....................................................................................................................... 7

Table 1-1: Subpart 2 Classifi cations and Attainment Dates .................................................. 22

Table 1-2: Georgia Counties Considered in this Analysis ....................................................... 24

Table 1-3: 2001-2003 ozone design values for Atlanta nonattainment area sites ................. 28

Table 1-4: SIP Infrastructure Elements .................................................................................. 28

Table 1-5: SIP Requirements fo r Moderate Nonattainment Areas ...................................... 29

Table 2-1: Yearly 4 th highest 8-hour ozone concentr ations (ppm) at the 11 Atlanta

nonattainment area sites during 1996-2006. ..................................................................... 34

Table 2-2: Number of exceedances of the oz one NAAQS at the 11 Atlanta nonattainment

area sites during 1996-2006. ............................................................................................... 35

Table 2-3: Ending year 8-ho ur ozone design-values (ppm) .................................................... 35

Table 2-4: Concentrations of NO
x , VOCs and meteorological co nditions associated with

various ozone levels at the Tucker PAMS site .................................................................. 41

Table 2-5: Concentrations of NO
x , VOCs and meteorological co nditions associated with

various ozone levels at the South-DeKalb PAMS site ...................................................... 41

Table 2-6: Concentrations of NO
x , VOCs and meteorological conditions ............................. 42

Table 2-7: Concentrations of NO
x , VOCs and meteorological condition .............................. 42

Table 2-8: Interpretation of Extent of Reaction ....................................................................... 43

Table 2-9: Weekday/weekend diff erences in daytime (6am-7pm) NO
x and VOC (TNMOC)

concentrations at the four Atlanta PAMS sites during 1997-2005 ................................. 46

Table 3-1: Vertical Layer Definition For MM5 and CMAQ .................................................. 59

Table 3-2: Summary of ozone season daily NOX emissions in 2002 and 2009 by source

categories for 20 counties in Atlanta. ................................................................................ 62

Table 3-3: Summary of ozone season daily VOC emissions in 2002 and 2009 by source

categories for 20 counties in Atlanta. ................................................................................ 63

Table 3-4: Summary of ozone season daily NO X emissions (tons/day) in 2002 and 2009 for

major EGU point sources in and aro und the Atlanta nonattainment counties ............ 65

16The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 3-5: Major non-EGU point sources in the Atlanta nonattainment counties with NOx

emissions larger than 100 tons/year .................................................................................. 66

Table 3-6: Summary of ozone season daily NO X and VOC emissions (tons/day) in 2002 and

2009 by onroad mobile sources in Atlanta 20 counties .................................................... 68

Table 4-1: Mathematical Formul ation of Statistical Metrics Used for Evaluating Mesoscale

Meteorological Model Performance .................................................................................. 74

Table 4-2: Statistical Benchmarks for Mesoscale Meteorological Models ............................ 74

Table 4-3: Monthly averaged stat istics for the region of the 12-km modeling domain in and

around Georgia. .................................................................................................................. 77

Table 4-4: Performance Statistics .............................................................................................. 80

Table 4-5: Mean Normalized Bias and Mean Normalized Gross Error for 8-hour ozone

from CMAQ 12km simulations temporally averaged from May 1, 2002 to September

30, 2002 (8-hour O 3 > 0 ppb and 8-hour O 3 > 60 ppb). .................................................... 82

Table 4-6: Mean Normalized Bias and Mean Normalized Gross Error for 1-hour ozone

from CMAQ 12km simulations temporally averaged from May 1, 2002 to September

30, 2002 (O 3 > 0 ppb and O 3 > 60 ppb). ............................................................................. 83

Table 4-7: Mean Normalized Bias and Mean No rmalized Gross Error of daily maximum 1-

hour ozone from CMAQ 12km simulations temporally averaged from May 1, 2002 to

September 30, 2002 (1-hour O 3 > 60 ppb and 8-hour O 3 > 60 ppb). .............................. 83

Table 4-8: Mean Observation (MO), Mean Predic tion (MP), Ratio of the Means (RATIO),

Mean Bias (BIAS), Normalized Mean Bias (NMB), Mean Fractional Bias (FBIAS),

Mean Error (ERR), Normalized Mean E rror (NME), Mean Fractional Error

(FERROR), and Correlation Coefficient (r ) of 8-hour ozone from CMAQ 12km

simulation temporally averaged from M ay 1, 2002 to September 30, 2002 (8-hour O 3 >

60 ppb).

............................................................................................................................... .. 84

Table 5-1: NOx Emissions for 20 Co unty Nonattainment Area – Part 1 ............................ 103

Table 5-2: NOx Emissions for 20 Co unty Nonattainment Area – Part 2 ........................... 103

Table 5-3: VOC Emissi ons for 20 County Nonattainment Area – Part 1 ........................... 104

Table 5-4: VOC Emission s from for 20 County Nonattainment Area – Part 2 ................. 104

Table 5-5: Georgia Rule 391-3-1-.02(2) Stat ionary Source VOC Standards for Point, Area,

and Mobile Sources ........................................................................................................... 105

17The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 5-6: Georgia Rule 391-3-1-.02(2) St ationary Source NOx Standards for Point and

Area Sources ...................................................................................................................... 107

Table 5-7: Specific Large Point Source Cont rol Measure – Lafarge Building Materials,

Inc.

............................................................................................................................... ....... 108

Table 5-8: Specific Large Point Source Co ntrol Measure – Transco Compressor Station

120....................................................................................................................................... 108

Table 5-9: Specific Large Point Source Control Measure – Caraustar Industries, Inc. ... 109

Table 5-10: Federal Control Measu res for On-Road Mobile Sources ................................ 111

Table 5-11: State Authority to Implement Federal Control Measures for On-Road Mobile

Sources ............................................................................................................................... 112

Table 5-12: Federal Control Measu res for On-Road Mobile Sources ................................ 114

Table 5-13: Clean Air Campai gn in Metro Atlanta Region ................................................. 123

Table 6-1: Atlanta attainment test results for 2009, using the maximum value in the 3x3

array surrounding each site ............................................................................................. 132

Table 6-2: Atlanta attainment test results for 2009 using the monitor grid cell value. ...... 134

Table 6-3: Atlanta attainme nt test results for 2009, usin g a three-year DVB and the

maximum value in the 3x3 array surrounding each site ............................................... 135

Table 6-4: Atlanta attainment test results for 2009 using a three-year DVB and the monitor

grid cell value. .................................................................................................................... 135

Table 6-5: Atlanta attain ment test results for 2009 ............................................................... 142

Table 7-1: Summary of sensitiv ity analysis results for the At lanta Confederate Avenue site

(AIRS ID 13-121-0055) ..................................................................................................... 145

Table 8-1: Multipollutant Control Re quirements for Certain Coal-Fired Boilers ............ 151

Table 9-1: Total 20-County 2009 Mo tor Vehicle Emissions Budgets.................................. 154

Table 9-2: 2009 20-County Atlanta Nona ttainment Area Projected Emissions ................ 154

Table 10-1: Source Categories Covered S ection 182(b)(2)(A) of the Clean Air Act .......... 159

Table 10-2: Source Categories Covered S ection 182(b)(2)(B) of the Clean Air Act .......... 166

Table 10-3: Source Categories Covered S ection 182(b)(2)(C) of the Clean Air Act .......... 172

Table 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or

Exceed 100 tons per year.................................................................................................. 174

18The Atlanta Eight-Hour Ozone Attainment Demonstration



## LIST OF APPENDICES

Appendix Title

A County-Level Emission Summary Tables for Georgia

B Observed and Modeled Spatial Distribution of Daily 8-Hour
Maximum Ozone

C Daily Maximum 8-Hour Ozone, 1-Hour Ozone, NO, and NO2 Barplots

D Scatter Plots of Hourly 8-Hour Ozone, 1-Hour Ozone, NO, and

NO2

E Time Series Plots of Hourly 8-Hour Ozone, 1-Hour Ozone, and Precursor Species

F Sensitivity of Ozone in Atlanta to Reductions in NO

x and VOC
Emissions

G Clean Air Markets - EGU NOx Data

H Sensitivity of Ozone in Macon to Reductions in NO

x Emissions from Various Sources in Georgia

I Protocol for Annual MM5 Modeling in Support of VISTAS

J MM5 2002 Modeling in Support of VISTAS

K Documentation of VISTAS Inventories and Georgia 2002 CERR Inventory

L Guidance on the Use of Models and Other Analysis for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze

M Comments on Guidance on the Use of Models and Other Analysis for Demonstrating Attainment of Air Quality Goals for Ozone,

PM 2.5 , and Regional Haze

N Modeling Protocol for the Atlanta, GA
8-hour Ozone Nonattainment Area

O VISTAS CEM Emission Rate Memo

P Quality Assurance Project Plan (Draft) For Association for Southeastern Integrated Planning (ASIP) Q Hartsfield-Jackson Atlanta Intern ational Airport, Reduction in
Emissions of Ozone Precursors

R Georgia MM5 Meteorological Model Performance Evaluation

S.1 May 11, 2006 Letter to EPA Requesting Concurrence of I/M Applicability

S.2 May 31, 2006 Letter from EPA Concurring

T Voluntary Reduction of Emissions from Railyards in Metro Atlanta Region

U Mobile Source Emissions Modeling
for Atlanta Ozone Attainment Demonstration Motor Vehicle Emissions Budgets

V MATS Input/Output Files

19The Atlanta Eight-Hour Ozone Attainment Demonstration



## 1.0 INTRODUCTION

This document, entitled Georgia's State Implementation Plan for the Atlanta 8-Hour
Ozone Nonattainment Area , presents the Georgia Enviro nmental Protection Division’s (EPD) plan for attaining th e 8-hour ozone standard by June 15, 2010 in the Atlanta metropolitan area. This document presents Georgia EPD’s regulatory requirements and supporting information in accordance with section 110 of th e 1990 Clean Air Act Amendments (CAAA) and Title 1 Subpart D of the CAAA.

1.1 Ozone as an Air Pollutant
Ozone is a colorless gas. Ground level oz one, unlike the other gaseous air pollutants (such as oxides of nitrogen, sulfur dioxide, carbon monoxide) is not a primary pollutant. This means that ozone is not directly em itted by any sources, mobile or stationary. Ozone forms through a complex series of ch emical reactions, which take place in the presence of strong sunlight ( photochemical reactions). For th ese reactions to take place, certain ingredients (precursors) must be availa ble. Since the reactions must take place in the presence of strong sunli ght, ozone concentrations ha ve a strong diurnal pattern.

As shown in Figure 1-1, the precursors to oz one formation are oxides of nitrogen (NOx) and reactive organic substances (sometimes referred to as volatile organic compounds (VOCs) or hydrocarbons. Examples of su ch reactive organic substances include hydrocarbons found in automobile exhaust (l ike benzene and propa ne), vapors from cleaning solvents (like toluene), and biogeni c emissions (like terpenes). Ozone, when mixed with particles and ot her pollutants, such as NO 2 forms smog, a brownish, acrid mixture. This type of pollution first ga ined attention in the 1940's as Los Angeles photochemical "smog." Since then, photochemi cal smog has been observed frequently in many other cities.

20The Atlanta Eight-Hour Ozone Attainment Demonstration

Figure 1-1: Diagram Illu strating Ozone Formation

Historically, the official “ozone season” is Georgia is March 1 through October 31 for each calendar year for ambient monitoring requirements. Implementation of some ozone control measures are required May 1 through September 30 for each calendar year. The reason for the shorter season is that long periods of strong sunlight and warm temperatures are needed for ozone formation. Most urban areas expe rience high levels of ground level ozone during the summer months (generally May through September for Georgia). With that in mind, ozone is predominantly a summertime air pollutant. Changing weather patterns contribute to yearly differences in ozone concentrations from region to region. Ozone and the pollutants that form ozone also can be transported into an area from pollution sources found hundred of miles upwind.

Breathing ozone can trigger a variety of h ealth problems including chest pain, coughing, throat irritation, and congesti on. It can worsen bronchiti s, emphysema, and asthma. Ground-level ozone can also reduce lung functio n and inflame the linings of the lungs. Repeated exposure may permanently scar lung tissue.

Ground-level ozone also damages vegetation and ecosystems. Ground-level ozone is absorbed by the leaves of plants, where it can 1) interfere with th e ability of sensitive plants to store and produce food (which can lead to reduced growth, biomass production and/or yields), 2) make sensitive plants more susceptible to certain diseases, insects, or harsh weather, other pollutants, and competition, 3) reduce or change the diversity of plant species (which can lead to damage to ecosystems dependent on those species, 4) visibly injure the leaves of plants, affec ting the appearance of vegetation in national parks, recreation areas, and cities.

21The Atlanta Eight-Hour Ozone Attainment Demonstration

1.2 Ozone as a National Ambi ent Air Quality Standard
The Clean Air Act (CAA) establishes a pro cess for air quality management through the National Ambient Air Quality Standards (NAAQS ). Area designations are required after promulgation of a new or re vised NAAQS. In 1979, the U.S. Environmental Protection Agency (EPA) promulgated the 0.12 parts per million (ppm) 1-hour ozone standard (44 FR 8202, February 8, 1979). On July 18, 1997, EPA promulgated a revised ozone standard of 0.08 ppm, measured over an 8-hour period, i.e., the 8-hour standard (62 FR 38856). The 1997 NAAQS rule was challenged by numerous litigants and in May 1999, the U.S. Court of Appeals for the D.C. Circuit issued a deci sion remanding, but not vacating, the 8-hour ozone standard. Among ot her things, the Court recognized that the U.S. EPA is required to designate areas fo r any new or revised NAAQS in accordance with the CAA. The U.S. EPA sought review of two aspects of that decision in the U.S. Supreme Court. In February 2001, the Suprem e Court upheld EPA's authority to set the NAAQS and remanded the case back to the D. C. Circuit for disposition of issues the
Court did not address in its initial decision. The Suprem e Court also remanded the 8- hour implementation strategy to EPA. In March 2002, the D.C. Circuit rejected all remaining challenges to the 8-hour ozone standard.

The process of designations following promul gation of a NAAQS is c ontained in section 107(d) of the CAA. For the 8-hour ozone NAAQS, the Transportation Equity Act for the

21 st Century (TEA-21) extended by 1 year the ti me for EPA to designate areas for the 8- hour ozone NAAQS. Thus, EPA was required to designate areas for the 8-hour NAAQS by July 2000. However, U.S. House Bill HR3645 (EPA's appropriation bill in 2000) restricted EPA's authority to spend money to designate areas until June 2001 or the date of the Supreme Court ruling on the standard, whichever came first. As noted earlier, the Supreme Court decision was issued in Fe bruary 2001. In 2003, several environmental groups filed suit in district court claimi ng the U.S. EPA had not met its statutory obligation to designate areas for the 8-hour ozone NAAQS. The U.S. EPA entered into a consent decree, which required EPA to issue designations by April 15, 2004.

EPA promulgated designations on Ap ril 30, 2004 (69 FR 23858 through 23951), and
EPA created six classifications of nonattainment for the 8-hour ozone standard as specified in Table 1-1.

Table 1-1: Subpart 2 Classifi cations and Attainment Dates

Classification Ozone Design Value Range (ppm) Attainment Date

Marginal 0.085 up to 0.092 June 15, 2007

Moderate 0.092 up to 0.107 June 15, 2010

Serious 0.107 up to 0.120 June 15, 2013

Severe 15 0.120 up to 0.127 June 15, 2019

Severe 17 0.127 up to 0.187 June 15, 2021

Extreme 0.187 and above June 15, 2024

22The Atlanta Eight-Hour Ozone Attainment Demonstration

1.3 Regulatory History of Atlanta's Smog Problem

Pursuant to the Clean Air Act Amendmen ts of 1990 (CAAA), the Atlanta area was designated as nonattainment for the 1- hour ozone NAAQS by U.S. EPA and was
classified as a serious nonattainment ar ea on November 6, 1991. The nonattainment area (NAA) was at that time geogr aphically defined as the foll owing 13 Georgia counties: Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, and Rockdale. Because Atlanta failed to attain the 1-hour ozone NAAQS by November 15, 1999, EPA issued a fi nal rulemaking action in the September 26, 2003, Federal Register (68 FR 55469) determining that, by operation of law, the Atlanta area was being reclassified as a "severe" ozone nonattainment area effective January 1, 2004. In addition to having been required to submit state implementation plan (SIP) revisions meeting requirements for marginal, moderate, and serious ozone nonattainment areas, Georgia was required to submit plans meeting the additional requirements for areas classified as severe. As a result of EPA's implementation of the original federal Clean Air Act of 1970, the Clean Air Act Amendments of 1977, and the Clean Air Act Amendments of 1990, EPD ha s completed, and EPA has approved (67 FR 30574), SIP revisions to address the 1-hour ozone Atlanta NAA.

On February 1, 2005, EPD requested under the CA AA of 1990 that the Atlanta area be redesignated from nonattainment to attainment with respect to the 1-hour ozone NAAQS. This request was based on three years, 2002 through 2004, of ambient monitoring data at
all 11 ozone monitors in the Atlanta NAA showing no violation of the 1-hour ozone NAAQS; the implementation of permanent and enforceable reductions in ozone precursor emissions; compliance with all applicable requirements; and the Atlanta Maintenance Plan with projections demonstr ating that the 2002 emission levels in this area will not be exceeded through at least the year 2015. EPD also petitioned EPA to make a determination that the Atlanta area was elig ible for application of EPA's Clean Data Policy, based on the Atlanta area's attainme nt of the 1-hour ozone NAAQS. EPA approved the plan and redesignation reque st effective June 14, 2005 (70 FR 34660).

1.4 Nonattainment Area Designation for 8-Hour Ozone in Atlanta
The process for designations following prom ulgation of a NAAQS is contained in CAA Section 107(d)(1). This secti on of the Act provides each State Governor an opportunity
to recommend attainment/unclassifiable or nonattainment designations including appropriate boundaries to EPA a nd for EPA to make modificati ons to these designations and boundaries as it deems necessary. EPD reviewed guidance provided by the EPA as well as pertinent, available data to deve lop criteria for assigni ng area designations and boundaries. The EPA's March 28, 2000, memorandum "Boundary Guidance on Air Quality Designations for the 8-Hour Ozone National Ambient Air Quality Standard (NAAQS)" delineates the EPA's position that any monitored violation of the standard within a Metropolitan St atistical Area (MSA) 1 should, as an initial presumption, cause
that entire MSA to be considered for designation as nonattainment.

1 (based on Census 1990, http://www.census.gov/population/estimates/metro-city/99mfips.txt )

23The Atlanta Eight-Hour Ozone Attainment Demonstration

The CAA defines a nonattainment area as any ar ea that does not meet (or that contributes to ambient air quality in a nearby area that does not meet) the primary or secondary NAAQS. EPA guidance indicates that Georgia should use the larger of the MSA or the 1-hour ozone NAA as the presumptive boundary for the 8-hour ozone NAAQS. Table 1- 2 specifies the Georgia counties considered in this analysis. Figure 1-2 illustrates the
location of ozone ambient monitors w ithin the Atlanta nonattainment area.

Table 1-2: Georgia Counties Considered in this Analysis

County Atlanta
MSA? 1-hour Ozone
NAA Contributing to
1-hour ozone
NAA Considered for
8-hour Ozone
NAA?

Banks No No Yes Yes

Barrow Yes No Yes Yes

Bartow Yes No Yes Yes

Butts No No Yes Yes

Carroll Yes No Yes Yes Chattooga No No Yes Yes

Cherokee Yes Yes Yes Yes

Clarke No No No Yes Clayton Yes Yes NA Yes

Cobb Yes Yes NA Yes

Coweta Yes Yes NA Yes

Dawson No No Yes Yes

DeKalb Yes Yes NA Yes Douglas Yes Yes NA Yes Fayette Yes Yes NA Yes Floyd No No Yes Yes Forsyth Yes Yes NA Yes

Fulton Yes Yes NA Yes

Gordon No No Yes Yes

Gwinnett Yes Yes NA Yes

Hall No No Yes Yes

Haralson No No Yes Yes

Heard No No Yes Yes Henry Yes Yes NA Yes

Jackson No No Yes Yes Jasper No No Yes Yes

Jones No No Yes Yes

Lamar No No Yes Yes Lumpkin No No Yes Yes

Madison No No Yes Yes

Meriwether No No Yes Yes Morgan No No Yes Yes

Monroe No No Yes Yes

24The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 1-2: Georgia Counties Considered in this Analysis

County Atlanta
MSA? 1-hour Ozone
NAA Contributing to
1-hour ozone
NAA Considered for
8-hour Ozone
NAA?

Newton Yes No Yes Yes

Oconee No No Yes Yes Paulding Yes Yes NA Yes

Pickens Yes No Yes Yes

Pike No No Yes Yes

Polk No No Yes Yes

Putnam No No Yes Yes

Rockdale Yes Yes NA Yes Spalding Yes No Yes Yes Troup No No Yes Yes Upson No No Yes Yes

Walton Yes No Yes Yes

25The Atlanta Eight-Hour Ozone Attainment Demonstration

Cherokee

13-121-0055 (Conf. Ave) 13-089-3001 (Tucker)

13-089-0002 (S.DeKalb) 13-223-0003 (Yorkville) 13-067-0003 (Kennesaw)

13-247-0001 (Conyers)

13-077-0002

(Newnan) 13-113-0001 (Fayetville ) 13-151-0002 (McDonough ) 13-097-0004 (Douglasville) 13-135-0002 (Lawrenceville )

13-121-0055 (Conf. Ave) 13-089-3001 (Tucker)

13-089-0002 (S.DeKalb) 13-223-0003 (Yorkville) 13-067-0003 (Kennesaw)

13-247-0001 (Conyers)

13-077-0002

(Newnan) 13-113-0001 (Fayetville ) 13-151-0002 (McDonough ) 13-097-0004 (Douglasville) 13-135-0002 (Lawrenceville )

13-121-0055 (Conf. Ave) 13-089-3001 (Tucker)

13-089-0002 (S.DeKalb) 13-223-0003 (Yorkville) 13-067-0003 (Kennesaw)

13-247-0001 (Conyers)

13-077-0002

(Newnan) 13-113-0001 (Fayetville ) 13-151-0002 (McDonough ) 13-097-0004 (Douglasville) 13-135-0002 (Lawrenceville ) Cherokee

Figure 1-2: Location of ozone monitors within the Atlanta 20-county nonattainment

area

Georgia EPD utilized existing EPA guidance (as specified in EPA's March 28, 2000 memorandum) to exclude, or include, countie s in the presumptive nonattainment area, i.e., the MSA. Georgia's methodology used to arrive at their recommendations was based
on a set of criteria based on EPA's 11 f actors (as specified in EPA's March 28 memorandum) and input received from other State agencies. The process of specifying the nonattainment boundary for Atlanta was explai ned in detail in Georgia EPD's letter of July 17, 2003 in which EPD supplied additi onal information regarding the selection methodology used to arrive at the June 15, 2003, recommendations. The screening criteria were: (1) projected 2007 populati on density exceeding the minimum value that corresponds to a monitored viol ation within an MSA; (2) Projected 2007 nitrogen oxides

26The Atlanta Eight-Hour Ozone Attainment Demonstration

(NOx) or volatile organic compounds (VOC ) emissions density exceeding the minimum value that corresponds to a known monitore d violation within an MSA; (3) Daily commuting trips (year 2000) basis from a count y into the nonattainment area exceeding the minimum number of daily in-commutes fo r an existing nonattainment county; and (4) Summer daily non-interstate vehicle mile s traveled (VMT) exceeding the minimum summer daily non-interstate VMT for an existing nonattainment county (year 2001 basis).

Georgia EPD submitted its nonattainment ar ea designation recommendations under the 8-
hour ozone standard to EP A on July 15, 2003. Georgia recommended the following counties be designated nonattain ment for the 8-hour ozone standard: Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Henry, Newton, Paulding, Ro ckdale, Spalding, and Walton. Georgia recommended that Pickens County be exclud ed from the nonattainme nt designation even though the county is part of the Atlanta MSA. Georgia based this exclusion, in part, on the fact that the county did not exceed any of the State's criteria for inclusion into a nonattainment area. Other pa rameters used in the anal ysis included the county's population and annual NOx and VOC emissi ons. EPA concurred with Georgia's recommendations in a letter dated December 3, 2003.

On April 30, 2004, EPA designated 20 metropo litan Atlanta counties as a "marginal"
nonattainment area under the 8-hour ozone standard. The eight-hour ozone nonattainment area encompasses the 13 co unties of the former 1-hour ozone nonattainment area plus seven additional "ring" counties: Barrow, Bartow, Carroll, Hall, Newton, Spalding, and Walton. With an attain ment deadline of June 15, 2007, marginal areas were required to attain the National Ambient Air Quality Standard (NAAQS) by the 2006 ozone season. On October 16, 2007, the U.S.EPA published a rulemaking proposing its determination that the Atlanta Area did not attain the 8-hour ozone NAAQS by June 15, 2007, the applicable attainment date for margin al nonattainment areas. The proposed finding was based on ambient air quality data from years 2004, 2005, and 2006. The U.S.EPA explained that, consistent w ith Section 181(b)(2) of the Clean Air Act (CAA), when EPA finalizes its determination th at the Atlanta Area failed to attain, and that requirement becomes effective, the A tlanta Area would be reclassified by operation of law to the next highest classification, or “moderate” nonattainment. The U.S.EPA further proposed that the State submit the SIP revisions meeting the new moderate area requirements as expeditiously as practi cable, but no later th an June 15, 2010. The
U.S.EPA finalized this findi ng on March 6, 2008 [73FR 12013-12017].

1.5 8-Hour Ozone Design Values in Atlanta
Ozone design-values (DV; three year average of the 4 th highest reading per year) for the 2001-2003 period, which was used in design ating the Atlanta 20 county area as nonattainment, show that 10 out of the 11 sites exceed the 8- hour ozone NAAQS (0.08 ppm) (Table 1-3). Due to EPA's rounding and truncation conven tion, any DV less than or equal to 0.084 ppm is considered attaini ng the NAAQS while any DV greater than or equal to 0.085 ppm is considered not attaining the NAAQS.

27The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 1-3 : 2001-2003 ozone design values for At lanta nonattainment area sites

Site name AIRS ID 2001-2003 DV (ppm)

Confederate Ave. 13-121-0055 0.091 Conyers 13-247-0001 0.089 Douglasville 13-097-0004 0.091 Fayetteville 13-113-0001 0.083

Kennesaw 13-067-0003 0.090

Lawrenceville 13-135-0002 0.085 McDonough 13-151-0002 0.089

Newnan 13-077-0002 0.087

South-DeKalb 13-089-0002 0.087

Tucker 13-089-3001 0.089

Yorkville 13-223-0003 0.089

1.6 SIP Requirements for Moderate Nonattainment Areas
Section 110(a) of the CAA requires states to submit an implementation plan to the U.SEPA that provides for implementation, ma intenance, and enforcement of NAAQS. Section 110(a)(2) lists the elements that ar e to comprise the implementation plan. Several of the elements in section 110(a)(2) specifically address the need for state to demonstrate the ability to implement, mainta in, and enforce the air quality standards.
These elements are sometimes referen ced as “infrastructure” elements.

The elements of section 110(a)(2) are lis ted below:

Table 1-4: SIP Infrastructure Elements

Federal CAA Description Found Where in Plan?

110(a)(2)(A) Enforceable emission limitations
and other control measures Chapters 5, 10, and 11

110(a)(2)(B) Air quality monitoring, compilation, data analysis, and reporting Chapter 11

110(a)(2)(C) Enforcement and Stationary Source Permitting Chapter 11

110(a)(2)(D) Interstate Transport Chapter 11 110(a)(2)(E) Resources, conflict of interest, and emergency backstop Chapter 11

110(a)(2)(F) Stationary source emissions monitoring and reporting Chapter 11

110(a)(2)(G) Emergency powers and contingency plans Chapter 11

110(a)(2)(H) SIP revision for revised air quality standards or new
attainment methods Chapter 11

110(a)(2)(I) SIP revisions for new
nonattainment areas See Table 1.5

110(a)(2)(J) Consultation and public Chapter 11

28The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 1-4: SIP Infrastructure Elements

notification 110(a)(2)(K) Air quality modeling and reporting Chapters 2, 3, 4, 6, and 7

110(a)(2)(L) Major stationary source permitting fees Chapter 11

110(a)(2)(M) Consultation with local entities Chapter 11

Section 110(a)(2)(I) of the CAA pertains to a required SIP revision for an area designated as a nonattainment area and this section required that the SIP revision meet the applicable requirements of part D of the CAA as it rela tes to nonattainment ar eas. The applicable requirements of part D of the CAA, in this case, are specified in sections 172(c), 182(a), and 182(b). The applicable part D re quirements are specified in Table 1-5.

Table 1-5: SIP Requirements fo r Moderate Nonattainment Areas

Requirements Federal
CAA Description Found Where in Plan?

172(c)(1) Provide for the implementation of RACM as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obta ined through the adoption, at a minimum, of RACT) and shall provide for attainment of the primary NAAQS Chapter 10

172(c)(2) Provide for Reasonable Further Progress Chapter 8.2

172(c)(3) Provisions shall include a comprehensive current inventory of
actual emissions from all sources of the relevant pollutant or pollutants in such area, including periods revisions as determined necessary. Chapter 8.3

172(c)(4) Plan shall expressly identify and quantify the emissions of any such pollutant(s) which will be allowed in accordance from section 172(a)(1)(B) from the construction and operation of major new or modified stationary
sources in each such area. Emissions quantified for this purpose will be
consistent with the achievement of
RFP and will not interfere with attainment of the applicable NAAQS. Chapter 8.6 and 11 Nonattainment Area (NAA)
Plan: General Requirements

172(c)(5) Plan shall require permits for the construction of new or modified major stationary sources as applicable. Chapters 8.6 and 11

29The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 1-5: SIP Requirements fo r Moderate Nonattainment Areas

Requirements Federal
CAA Description Found Where in Plan?

172(c)(6) Plan shall include enforceable
emission limitations and such other control measures, means or techniques
as well as schedules and timetables for compliance as deemed necessary to provide for attainment of the applicable NAAQS. Chapters 5 and 10

172(c)(7) Shall meet the applicable provisions of section 110(a)(2). Chapters 8.9 and 11

172(c)(8) Administrator may allow the use of equivalent modeling, emission inventory, and planning procedures. Chapter 8.10

172(c)(9) Plan shall provide for the implementation of specific measures
to be undertaken if the area fails to make RFP or to attain the applicable NAAQS. Such measures shall be included in the plan revision as contingency measures to take effect in any such case without further action by the State/Administrator. Chapter 8.11

182(a)(1) Within 2 years after the date of enactment of the 1990 CAAA, (in this case designation)the plan shall provide for a comprehensive current inventory
of actual emissions from all sources as described in section 172(c)(3). Chapter 8.3 [see 6/15/2006 letter]

182(a)(2)(A) Plan shall pr ovide corrections to the state implementation plan to correct requirements in (or add requirements to) the plan for reasonable available control technology (RACT) as required under section 172(b) as in effect immediately before the date of enactment of the CAAA’s of 1990) as interpreted in guidance issued by the
Administrator under section 108
before the date of enactment of the
CAAA’s of 1990. Chapter 10

182(a)(2)(B) Plan shall provide corrections to the state implementation plan to include a savings clause implementation of a vehicle emission control inspection and maintenance (I/M) program no less stringent that that already included I the plan. Chapter 8.7 NAA Plan: Marginal Area Requirements

182(a)(2)(C) Plan shall provide for a permit program in accordance with sections 172(c)(5) and 173. Chapters 8.6 and 11

30The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 1-5: SIP Requirements fo r Moderate Nonattainment Areas

Requirements Federal
CAA Description Found Where in Plan?

182(a)(3) Plan shall provide for a general periodic emissions inventory every three years until area is redesignated to attainment. Plan shall also provide for an annual emissions inventory for sources 25 tpy or greater of VOC or
NOx. Chapter 8.5

NAA Plan:
Moderate Area Requirements 182(b)(1) Mandates a 15% VOC emission reduction, accounting for growth, in the first 6 years after the baseline year (2002) for moderate and above ozone

NAAs. Chapter 8.2

31The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 1-5: SIP Requirements fo r Moderate Nonattainment Areas

Requirements Federal
CAA Description Found Where in Plan?

182(b)(2)

(A)

(B)

(C) The State shall submit a revision to the applicable implementation plan to include provisions to require the implementation of RACT under section 172(c)(1) with respect to each of the following: (A), (B) and (C).

Each category of VOC sources in the area covered by a CTG document issued by the Administrator between
the date of the enactment of the
CAAA’s of 1990 and the date of
attainment. Each revision described in subparagraph (A) shall be submitted within the period set forth by the Administrator in issuing the relevant
CTG document.

All VOC sources in the area covered by any CTG issued before the date of
the enactment of th e CAAA’s of 1990. The revision with respect to sources described in subparagraph (B) shall be submitted by 2 years after the date of enactment of the CAAA’s of 1990, and shall provide for the implementation of the required measures as expeditiously as practicable but no later than May 31,
1995.

All other major stationary sources of
VOCs that are located in the area. The revision with respect to sources described in subparagraph (C) shall be submitted by 2 years after the date of enactment of the CAAA’s of 1990, and shall provide for the implementation of the required measures as expeditiously as practicable but no later than May 31,
1995. Chapter 5 and Chapter 10

32The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 1-5: SIP Requirements fo r Moderate Nonattainment Areas

Requirements Federal
CAA Description Found Where in Plan?

182(b)(3) Plan shall provide requirements for applicable owners/operators of gasoline dispensing systems to install and operate a system for gasoline vapor recovery of emissions from the fueling of motor vehicles. Not required for moderate
ozone nonattainment areas as per section 202(a)(6).

182(b)(4) Plan shall provide for a vehicle inspection and maintenance program (I/M) as required by section 182(a)(2)(B). Chapter 8.7

182(b)(5) The emission o ffset requirements are
the ratio of total emission reductions
of VOCs to total increase of emissions
of VOCs shall be at least 1.15 to 1. 8.6

33The Atlanta Eight-Hour Ozone Attainment Demonstration



## 2.0 CONCEPTUAL DESCRIPTION OF 8-HOUR OZONE
LEVELS IN ATLANTA AND GEORGIA

To analyze the spatial patterns in ozone concentrations throughout the Atlanta nonattainment area, the yearly 4 th highest 8-hour ozone concentration and number of exceedances of the NAAQS from 1996-2006 were investigated (Table 2-1, 2-2). These data indicate that peak 8-hour ozone concentrations typicall y occur at the center (urban core) of the nonattainment area, represented he re by the Confederat e Avenue site. This site exhibited the highest ozone concentration (4 th highest value) in six out of the eleven years analyzed, and recorded the highest num ber of exceedances in seven out of the eleven years. Other sites in which peak c oncentrations and number of exceedances were recorded are the Conyers, Douglasville, Lawrencevill e, and McDonough sites, all representing suburban sites, downwind of peak precursor emissions. Analyzing ozone DVs (three year average of the 4 th highest reading per year) (T able 2-3), also indicates
that the Confederate Avenue site consiste ntly exhibits the highest DV within the nonattainment area. However, despite most violations o ccurring at the Confederate
Avenue site near downtown Atlant a, it is important to note that all of the 11 sites within the nonattainment area continuously record vi olations of the ozone NAAQS, hence the problem is not limited to a specific site or s ubset of sites within the nonattainment area.

Table 2-1 : Yearly 4 th highest 8-hour ozone concentr ations (ppm) at the 11 Atlanta nonattainment area sites during 1996-2006. Bold red numbers indicate maximum per year.

Site name 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006

Conf. Ave. 0.110 0.104 0.126 0.124 0.113 0.084 0.100 0.091 0.089 0.092 0.092 Conyers 0.098 0.110 0.113 0.123 0.099 0.091 0.099 0.078 0.087 0.088 0.099 Douglasville N/A 0.090 0.110 0.105 0.097 0.092 0.098 0.085 0.080 0.089 0.095 Fayetteville N/A N/A 0.111 0.113 0.100 0. 084 0.088 0.077 0.084 0.086 0.090

Kennesaw N/A N/A N/A 0.095 0.107 0.088 0.100 0.084 0.073 0.081 0.093

Lawrenceville 0.089 0.086 0.111 0.103 0.100 0.080 0.089 0.088 0.092 0.082 0.096 McDonough N/A N/A N/A 0.126 0.111 0.086 0.099 0.082 0.085 0.089 0.095

Newnan N/A N/A N/A 0.108 0.096 0. 085 0.099 0.077 0.083 0.078 0.086

South DeKalb 0.102 0.092 0.112 0.112 0.107 0.085 0.095 0.083 0.084 0.087 0.096

Tucker 0.100 0.085 0.111 0.111 0.107 0.088 0.090 0.091 0.088 0.084 0.094
Yorkville 0.092 0.086 0.104 0.103 0.088 0.085 0.099 0.083 0.073 0.082 0.084

34The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 2-2: Number of exceedances of the ozone NAAQS at the 11 Atlanta nonattainment area sites during 1996-2006. Bold red numbers indicate maximum per year.

Site name 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006

Conf. Ave. 21 24 41 54 22 3 15 4 7 7 11 Conyers 15 24 38 43 11 6 12 1 6 4 10 Douglasville N/A 9 36 37 13 6 21 4 1 8 8 Fayetteville N/A N/A 34 30 9 3 6 0 3 4 6

Kennesaw N/A N/A N/A 8 17 5 12 3 0 2 11

Lawrenceville 9 6 27 16 12 2 7 6 4 1 8 McDonough N/A N/A N/A 34 22 4 11 0 5 6 9

Newnan N/A N/A N/A 33 11 4 9 0 2 0 4

South DeKalb 15 8 21 28 16 4 10 2 3 7 10

Tucker 15 4 19 27 16 7 11 5 4 3 8
Yorkville 10 5 26 23 6 4 11 2 0 2 3

Table 2-3: Ending year 8-ho ur ozone design-values (ppm) for the 11 Atlanta nonattainment area sites during 1998-2006 (e.g., the 1998 DV is based on data from 1996-1998). Bold red numbers indicate maximum p er year. Bold black (and red) numbers
indicate an exceedance of th e NAAQS (expresses as 0.084 ppm).

Site name 1998 1999 2000 2001 2002 2003 2004 2005 2006

Conf. Ave. 0.113 0.118 0.121 0.107 0.099 0.091 0.093 0.090 0.091 Conyers 0.107 0.115 0.111 0.104 0.096 0.089 0.088 0.084 0.091 Douglasville N/A 0.101 0.104 0.098 0.095 0.091 0.087 0.084 0.088 Fayetteville N/A N/A 0.108 0.099 0.090 0.083 0.083 0.082 0.086

Kennesaw N/A N/A N/A 0.096 0.098 0.090 0.085 0.079 0.082

Lawrenceville 0.095 0.100 0.104 0.094 0.089 0.085 0.089 0.087 0.090 McDonough N/A N/A N/A 0.107 0.098 0.089 0.088 0.085 0.089

Newnan N/A N/A N/A 0.096 0.093 0.087 0.086 0.079 0.082

South DeKalb 0.102 0.105 0.110 0.101 0.095 0.087 0.087 0.084 0.089

Tucker 0.098 0.102 0.109 0.102 0.095 0.089 0.089 0.087 0.088

Yorkville 0.094 0.097 0.098 0.092 0.090 0.089 0.085 0.079 0.079

Spatial patterns in ozone DVs outside of the Atlanta nonattainment area were also investigated, to assess whether ozone levels are impacted by regional factors (such as emissions, meteorology), or exhibit a local phenomenon to Atlanta. For this purpose, 1999-2006 ozone DVs from all monitoring-sites throughout Georgia we re grouped to the following regions (only sites with conti nuous ozone records for 1999-2006 were used):

35The Atlanta Eight-Hour Ozone Attainment Demonstration

1. Atlanta : 11 sites listed in Table 1-3

2. Macon : Macon south-east monitor (AIRS ID 13-021-0012)

3. Columbus : Columbus Airport (13-215-0008) and Columbus Crime lab (13-215- 1003) monitors

4. Augusta : Augusta 13-245-0091 monitor
5. Athens : Athens 13-059-00002 monitor

6. Savannah : Savannah 12-051-0021 monitor

7. South Coastal Georgia : Brunswick monitor (12-127-0006)

8. South Central Georgia : Leslie monitor (13-261-1001)

9. North Georgia Mountains : Fort mountain (13-213-0003) and Dawsonville (13- 085-0001) monitors

The area-average and area-maximum (singl e site) DVs for the period of 2001-2006 are shown in Figure 2-1. Area-average and area- maximum (single site) count of daily exceedances of the NAAQS (expressed as 85 ppb) are shown in Figure 2-2. These data seem to exhibit both regional and local patt erns in ozone levels in Georgia. A sharp
decline in both ozone levels and the number of exceedances are observed at all areas from 2001 to 2005, followed by a slight increas e in the 2006 DV. In addition to this regional pattern, a local one is evident in Atla nta, as expressed by hi gher ozone levels and more frequent exceedances compared to any other area of the state. The relatively minor
differences in ozone levels between Atlanta and Macon as observed in Figure 2-1(a) are due to the comparison between an average of 11 monitor for the Atlanta area and a single site in Macon. However, when the maximu m DV and number of exceedances in the Atlanta area are compared to the Macon m onitor, larger differences are observed. The increment in ozone levels in Atlanta, comp ared to other areas in the state, can be interpreted as a local contribution caused by em issions of ozone precu rsors in the Atlanta area. In fact, previous work has demonstrat ed that emissions of ozone precursors in
Atlanta also contribute to ozone formati on at Macon and other regions of the state (Appendix H).

36The Atlanta Eight-Hour Ozone Attainment Demonstration

60.0 65.0 70.0 75.0 80.0 85.0 90.0 95.0 100.0

Atl

an

t a Maco n

C ol

u m

b

u s

A ug

u st

a At h

e

n s
Sa v an

n a h

S.

Co a s ta

l GA

S.

Ce n tra

l G

A

N.

G

A

M

o

u n ta

in

sAverage O3 DV per geographical area (ppb)

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

60.0 70.0 80.0 90.0 100.0 110.0

Atla n ta
M a con Co l umbus Au g us

t a At hen s Savannah S. Coastal GA S. Central GA

N.

GA M

ountainsHighest O3 DV per geographical area (ppb)

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006 (a)

(b)

Figure 2-1: (a) Area-average and (b) si ngle-site area-maximum ozone DVs for 2001-
2006.

37The Atlanta Eight-Hour Ozone Attainment Demonstration

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0

Atl

a nt

a Maco n

C

o lu

m

bus

A ug

u st

a Athens
Sa

v an

n a h

S.

Co a st

a l GA

S. Central GA

N.

G

A

M

o

u n ta

in

sDays per year in which max 8-hr O3 >= 85ppb(average per area)

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

0.0 5.0 10.0 15.0 20.0 25.0 30.0

Atlanta
M a con Columb u s Au g us

t a Ath e

ns Savannah S. Coas t al GA

S.

Ce n tra

l G

A

N.

GA M

ountainsDays per year in which max 8-hr O3 >= 85ppb(maximum in single site per area)

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006 (a)

(b)

Figure 2-2: (a) Area-average and (b) single-si te area-maximum number of exceedances of the ozone NAAQS level (expressed as 85 ppb) in 2001-2006.

38The Atlanta Eight-Hour Ozone Attainment Demonstration

The strong (generally) downward trend in ozone DVs throughout the st ate is of interest, and is likely due to a combination of both a decrease in emissions and variations in meteorological conditions leading to ozone fo rmation. This can be inferred from Figure 2-3, in which variations in NO

x emissions (both EGU and mobile-sources) and in the number of "ozone conducive days" are presented for 1996-2005 ( 2006 meteorological
and vehicle miles traveled data were not available at the time of this analysis). State total

EGU NO
x emissions were obtained from the Clean Air Markets Division (CAMD) website ( http://www.epa.gov/airmarkets/ ; see also Appendix G). Approximate 13-county highway mobile source emissi ons inventories were calculated by EPD using a modified
draft version of EPA's Na tional Mobile Inventory Model (NMIM20050311) into which "historic" 1994 through 2004 average annual da ily vehicle miles traveled (VMT) from Georgia Department of Transportation we re imported. The 2005 VMT were projected through linear regression. The MOBILE6.2.0 3 emission factors produced by NMIM reflect default MOBILE6 speed distributions . Trends in meteorology were quantified
based on the count of "ozone conducive da ys" per ozone season. An "ozone conducive day" was defined here as a day in which the maximum daily temperature was above the
75 th percentile, and both the av erage relative-humidity and average wind-speed were
below the 50 th percentile for the period studied (1996-2005, using data from the National weather Service station in Atlanta). Thes e parameters were chosen to represent meteorological conditions conducive to ozone formation, i.e. hot, dry and stagnant conditions. The use of relative (p ercentile based) ra ther than absolute thresholds (e.g., temperature above 90 ° F) allows for an easy inter-annual comparison incorporating several meteorological parameters. Different th resholds were investigated, resulting in a change in the actual number of ozone conducive days per ye ar, but this had little effect on
the observed trend. Emissions data show a strong decline in EGU NO

x emissions in Georgia (60% decrease from 1998 to 2005) due to the installation of Selective Catalytic Reduction (SCR) devices at several power plants (Bowen Units 1-4, Hammond Unit 4, and Wansley Units 1-2) and other controls (suc h as the use of Powder River Basin coal at Scherer Units 1-4, co-firing of natural gas at Plant McDonough and Plant Yates, over-fire air at several other units, and low-NOx burne rs on almost all units). On-road mobile
source emissions also exhibit a downward trend (32% decrease from 1998 to 2005), mainly due to fleet turnover. In addition, there seems to be a substantial amount of variability in the meteorological condition betw een years, with an overall decrease in the count of "ozone conducive days" in the last several ozone seasons. The combination of
these reductions in emissions and more-favor able meteorology in th e last several years can help in explaining the downwar d trend in ozone design values.

39The Atlanta Eight-Hour Ozone Attainment Demonstration

0 100 200 300 400 500 600 700

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005NOx emissions (TPD)

0 5 10 15 20 25 30 35Number of "ozone conducive" days

EGU NOx (TPD) Mobile-source NOx (TPD) Count of "O3 conducive" days

Figure 2-3: Inter-a nnual trends in NO
x emissions (total Georgia EGU and 13-county Atlanta on-road mobile-source emissions) a nd count of "ozone conducive days" for
1996-2005.

2.1 Conditions Leading to Elevated Ozone in the Atlanta Area
To further study the factors contributing to ozone formation in Atlanta and to the
occurrence of exceedances of the ozone NAAQS, data from the Photochemical Assessment Monitoring Stations (PAMS) netw ork was used. The A tlanta PAMS network
consists of four sites: Yo rkville (type 1, upwind/backgr ound site), Tucker (type 2, maximum precursor location), South-DeKalb (type 2, maximum precursor location) and Conyers (type 3, maximum ozone site). Data from the four PAMS sites were binned, according to the daily maximum 8-hour ozone concentration, into the following bins: <65 ppb, 65-85 ppb, 85-105 ppb, and >105 ppb. Parameters investigated were morning (6- 10am), midday (10am-4pm), and evening (4-7pm) NO

x and VOC (sum of 56 PAMS VOC species) concentrations, previous day ozone concentrations, and meteorological conditions (maximum daily temperature, average daytime wind speed and relative humidity). Data from 1997-2003 were analy zed, for days in which the above-mentioned parameters were available (Tables 2-4, 2-5, 2-6, and 2-7). Elevated ozone at both the 'type 2' sites (Tucker and South-DeKalb) and the 'type 3' site (Conyers) are associated with elevated previous day ozone, indica ting a buildup of ozone during episodes. As expected, elevated ozone is also associated with elevated temperatures, low wind speeds and low relative humidity, as these meteorol ogical conditions are known to be conducive
of ozone formation.

40The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 2-4: Concentrations of NO
x , VOCs and meteorologica l conditions associated
with various ozone levels at the Tucker PAMS site (ozone concentrations reported as daily maximum 8-hour ozone; VOC reported are

the sum of 56 PAMS target species; morning refers to 6-10am; midday refers to 10am-4pm; evening refers to 4-7pm; daytime referred to as 6am-7pm)

Parameter O 3 <65ppb 65ppb ≤ O 3 < 85ppb 85ppb ≤ O 3 < 105ppb O 3 ≥ 105ppb Number of days 155 112 36 13

O 3 (ppb) 48.3 73.1 90.8 116.2 Previous day O 3 (ppb) 54.7 70.8 79.4 85.2 Morning NO

x (ppb) 17.7 20.9 34.0 32.7 Mid-day NO

x (ppb) 7.5 6.0 8.0 10.7 Evening NO

x (ppb) 11.5 10.7 13.5 15.9 Morning VOC (ppbC) 58.8 70.9 95.6 107.0 Midday VOC (ppbC) 35.5 34.0 36.6 47.0 Evening VOC (ppbC) 49.5 45.9 59.8 63.1 Morning VOC/NO

x (ppbC/ppb) 4.6 4.2 5.3 3.6 Midday VOC/NO

x (ppbC/ppb) 7.6 8.0 5.1 5.4 Evening VOC/NO

x (ppbC/ppb) 5.4 5.3 4.5 4.7 Daytime wind speed (m/s) 1.52 1.44 1.21 1.15 Max. Temperature ( ° C) 28.5 31.1 32.2 33.1 Daytime relative humidity (%) 73.5 58.7 53.9 48.5

Table 2-5: Concentrations of NO
x , VOCs and meteorologica l conditions associated
with various ozone levels at the South-DeKalb PAMS site (ozone concentrations reported as daily maximum 8-hour ozone; VOC reported are

the sum of 56 PAMS target species; morning refers to 6-10am; midday refers to 10am-4pm; evening refers to 4-7pm; daytime referred to as 6am-7pm)

Parameter O 3 <65ppb 65ppb ≤ O 3 < 85ppb 85ppb ≤ O 3 < 105ppb O 3 ≥ 105ppb Number of days 272 146 43 15

O 3 (ppb) 45.5 73.3 91.9 113.7 Previous day O 3 (ppb) 51.7 69.0 80.0 88.2 Morning NO

x (ppb) 26.4 45.3 71.5 75.4 Mid-day NO

x (ppb) 5.7 5.2 5.1 6.5 Evening NO

x (ppb) 10.5 14.1 13.8 16.8 Morning VOC (ppbC) 52.0 83.9 117.7 108.7 Midday VOC (ppbC) 25.6 25.5 28.8 34.0 Evening VOC (ppbC) 40.4 43.4 47.6 55.6 Morning VOC/NO

x (ppbC/ppb) 3.9 2.9 2.0 1.9 Midday VOC/NO

x (ppbC/ppb) 7.9 8.2 8.3 7.4 Evening VOC/NO

x (ppbC/ppb) 9.0 7.2 7.5 7.8 Daytime wind speed (m/s) 1.44 1.26 1.12 1.07 Max. Temperature ( ° C) 29.3 31.7 32.9 34.8 Daytime relative humidity (%) 74.4 61.2 58.2 54.6

41The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 2-6: Concentrations of NO
x , VOCs and meteorological conditions
associated with various ozone levels at th e Conyers PAMS site (ozone concentrations

reported as daily maximum 8-hour ozone; VOC reported are the sum of 56 PAMS

target species; morning refers to 6- 10am; midday refers to 10am-4pm; evening refers to 4-7pm; daytime referred to as 6am-7pm)

Parameter O 3 <65ppb 65ppb ≤ O 3 < 85ppb 85ppb ≤ O 3 < 105ppb O 3 ≥ 105ppb Number of days 146 64 29 11

O 3 (ppb) 47.4 72.9 91.9 110.0 Previous day O 3 (ppb) 52.5 69.6 78.8 98.9 Morning NO

x (ppb) 6.7 10.7 17.1 25.4 Mid-day NO

x (ppb) 2.5 3.4 4.6 5.9 Evening NO

x (ppb) 3.0 3.5 5.6 6.9 Morning VOC (ppbC) 27.8 44.6 56.2 100.8 Midday VOC (ppbC) 17.6 22.7 27.5 31.6 Evening VOC (ppbC) 24.9 32.8 37.3 52.8 Morning VOC/NO

x (ppbC/ppb) 6.6 6.0 4.8 4.5 Midday VOC/NO

x (ppbC/ppb) 10.1 10.5 9.7 8.2 Evening VOC/NO

x (ppbC/ppb) 13.2 16.5 12.2 13.0 Daytime wind speed (m/s) 1.21 1.39 1.43 1.03 Max. Temperature ( ° C) 29.2 31.1 32.8 33.2 Daytime relative humidity (%) 73.5 62.0 59.4 60.7

Table 2-7: Concentrations of NO
x , VOCs and meteorological condition
associated with various ozone levels at the Yorkville PAMS site (ozone concentrations reported as daily maximu m 8-hour ozone; VOC reported are the sum of 56 PAMS target sp ecies; morning refers to 6- 10am; midday refers to 10am4pm; evening refers to 4-7pm; da ytime referred to as 6am-7pm)

Parameter O 3 <65ppb 65ppb ≤ O 3 < 85ppb 85ppb ≤ O 3 < 105ppb O 3 ≥ 105ppb Number of days 58 39 2 0

O 3 (ppb) 48.6 73.7 86.0
- Previous day O 3 (ppb) 50.4 66.3 71.0
- Morning NO

x (ppb) 2.0 2.4 2.0
- Mid-day NO

x (ppb) 1.4 1.5 1.0
- Evening NO

x (ppb) 1.8 1.9 1.2
- Morning VOC (ppbC) 16.7 19.8 14.3
- Midday VOC (ppbC) 16.7 14.1 12.2
- Evening VOC (ppbC) 21.0 25.0 26.4
- Morning VOC/NO

x (ppbC/ppb) 11.0 13.0 6.9
- Midday VOC/NO

x (ppbC/ppb) 14.5 11.8 12.2
- Evening VOC/NO

x (ppbC/ppb) 15.9 19.7 24.3
- Daytime wind speed (m/s) 2.65 2.38 3.13
- Max. Temperature ( ° C) 28.4 30.0 31.4

- Daytime relative humidity (%) 77.3 63.7 73.0
-

42The Atlanta Eight-Hour Ozone Attainment Demonstration

To examine the relative importa nce of precursors of ozone (NO

x and VOCs) to ozoneformations, trends in these precursors were analyzed. Elevated ozone at the SouthDeKalb, Tucker and Conyers are typically a ssociated with elevated levels of both NO

x and VOCs. However, lo wer ratios of VOC/NO

x are typically associated with elevated ozone, possibly indicating 'NO

x -limited' conditions (ozone formation is limited by the
amount of available NO

x ). However, this analysis is a de scriptive one, and it is difficult to conclude on the relative importance on NO

x or VOC based on these data alone.



### 2.1.1 Analysis of PAMS data in Atlanta using Ozone M.A.P.P.E.R.

To further examine the relative importance of NO

x and VOC to ozone formation, EPD used the Ozone M.A.P.P.E.R. program (Blanchard et al. , 1995, 1996). Ozone M.A.P.P.E.R. (Measurement-based Analysis of Preferences in Planned Emission Reductions) is a Windows-based program that analyzes ozone and other air-quality measurements to determine if ground-level oz one formation is limited by the availability of the pre-cursor pollutants: VOCs or NOx. Ozone M.A.P.P.E.R. can be used to: (1) qualitatively assess the preferential effectiv eness of controlling VOC or NOx emissions, (2) compare control strategy assessments obtai ned from the application of grid-based photochemical air quality models, and (3) evalua te trends in the rela tive effectiveness of
VOC vs. NOx controls. The calculations are ca rried out according to the equations of the Integrated Empirical Rate (IER) model or the Smog Production (SP) algorithm (Blanchard et al. , 1995, 1996). These equations use measurements of ozone, nitric oxide (NO), and either NOx (NO + NO 2 ) or NO y (the sum of all oxidi zed nitrogen species) to compute the extent of reaction. The extent of reaction is a dimensionless parameter ranging from zero to one. As the extent of reaction approaches one, ozone production ceases because virtually all of the NOx has reacted. Table 2-8 contains a summary of
how the extent of reaction is typically interpreted.

Table 2-8: Interpretation of Extent of Reaction

Extent of Reaction Interpretation

0.0 – 0.6 Strongly indicative of VOC limitation

0.6 – 0.9 Transitional to NO

x limitation

0.9 – 1.0 Strongly indicative of NO

x limitation

Ozone M.A.P.P.E.R. should be used as a quali tative indicator of control preferences, rather than quantitatively as an estimator of control requirements because: (1) the computational algorithms are simple repres entations of ozone formation in smog chambers and do not incorporate many physical processes that are important in affecting ozone concentrations in the ambient environment, and (2) bias and imprecision of measurements typically result in uncertainties on the order of 0.1 in the extent of reaction.

43The Atlanta Eight-Hour Ozone Attainment Demonstration

2.1.1.1 Application to Atlanta

PAMS data was available for four PAMS s ites in Atlanta for the ozone seasons (MaySeptember) of 1997-2005. Ozone M.A.P.P.E.R. wa s applied to each of these PAMS sites using the Smog Production (SP) algorithm. The Smog Production algorithm was chosen over the Integrated Empirical Ra te (IER) model to calculate extent of reaction because it is considered to be more advanced and comprehensive.

NO
x data were available at all four PAMS sites (along with ozone and NO), however

NO y data were only partially available (for 2000-2005 at South DeKalb and Tucker, 1998 at Conyers, not available for Yorkville). For consistency across sites and years, NO

x data (rather than NO y ) were used in the analysis.

2.1.1.2 Summary of Ozone M.A.P.P.E.R. Results

Average diurnal patterns in the extent of r eaction (EOR) for the four PAMS sites for the period of 1997-2005 are shown in Figure 2-4. Th e extent of reaction clearly follows a diurnal pattern similar to ozone, with p eak values in the afternoon and values approaching zero during the nighttime. Base d on the average diurnal patterns of the EOR, formation of ozone during the afternoon (peak ozone) hours is in the 'transitional' range (EOR in the range of 0.6-0.9), indicatin g that both NO

x and VOC controls may be efficient for reducing ozone levels. Also evid ent is that the Yorkv ille and Conyers sites

are more NO
x -limited compared to the two 'type 2' (maximum precursor) sites, Tucker
and South-DeKalb.

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23

Time of dayExtent of reaction

Conyers South-DeKalb Tucker Yorkville

Figure 2-4: Average diurnal pattern in extent of reaction for the four PAMS sites for
1997-2005

To further analyze the relative importance of NO

x and VOCs to the formation of ozone, EOR results were binned according to daily maximum 8-hour ozone concentrations (in the ranges of <65 ppb, 65-85 ppb, 85-105 pp b, and >105 ppb). The average diurnal patterns associated with each bin at each s ite were calculated, and are presented in

44The Atlanta Eight-Hour Ozone Attainment Demonstration

Figures 2-5. These figures clearly demonstr ate that ozone formation becomes more NO

x limited with elevated daily maximum 8-hour ozone concen trations. This is of special importance, as the 8-hour ozone NAAQS is a percentile/maximum based standard (4 highest concentration per year), hence in order to bring the region into attainment of the NAAQS, controls that are most efficient in reducing peak oz one concentrations should be adopted and implemented. While the data in Figure 2-4 seem to indicate that Atlanta
ozone is 'transitional' to NO

x -limitation, data in Figures 2-5 cl early indicate that days of high-ozone are NO

x -limited. Hence, NO

x controls are likely to be substantially more efficient than VOC controls in reducing maximum 8-hour ozone concentrations. The apparent discrepancy between the trends in Figure 2-4 and 2-5 are due to the distribution of days between the four ozone bins. In all four PAMS sites, the vast majority of days (72%-75%) are categorized in the low oz one bin (<65 ppb), while only 4.4%-8.6% of days are categorized in the top two bins (>85 ppb).

a) Yorkville

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Time of dayExtent of reaction

O3<65ppb 65ppb<O3<85ppb
85ppb<O3<105ppb O3>105ppb b) Tucker

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Time of dayExtent of reaction

O3<65ppb 65ppb<O3<85ppb
85ppb<O3<105ppb O3>105ppb c) South-DeKalb

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Time of dayExtent of reaction

O3<65ppb 65ppb<O3<85ppb
85ppb<O3<105ppb O3>105ppb d) Conyers

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Time of dayExtent of reaction

O3<65ppb 65ppb<O3<85ppb
85ppb<O3<105ppb O3>105ppb

Figure 2-5: Average diurnal pattern in extent of reaction for 1997-2005 binned by the daily maximum 8-hour ozone con centration (<65ppb, 65-85ppb, 85-105ppb, >105ppb) for (a) Yorkville, (b) Tucker, (c) South-DeKalb, and (d) Conyers.

2.1.1.3 Ozone M.A.P.P.E.R. Conclusions

The application of Ozone M.A.P.P.E.R. to the four PAMS sites in Atlanta clearly
indicates that the control of NOx emissions is preferred to VOC emission controls. This is especially true for the days of elevated 8-hour ozone concentra tions. These results are consistent with results from an air-quality model based sensitivity analysis (Appendix F),

45The Atlanta Eight-Hour Ozone Attainment Demonstration

showing a much greater sensitivity of el evated 8-hour ozone concentrations to NO

x controls than VOC controls, both at core-urban and suburban/rural sites.

2.2 Weekday/weekend trends in ozone concentrations

The weekly cycles of ozone ar e of interest because they provide information about the response of ozone to changes in anthropogeni c emissions from weekdays to weekends.
While it is not feasible to conduct ambient experiments with long-term changes in precursor emissions, the respons e of ozone to changes in pr ecursor emissions that occur
on weekends has ramifications toward its re sponse to long-term strategies to control ozone through reductions in precursor emi ssions. During weekends, the emissions of anthropogenic precursors are lower compared to weekdays, because major sources of ozone precursors, such as mobile sources and industrial sources , are less active on
weekends. Data collected at the four Atlant a PAMS sites (Table 2-9) indicate that NO

x concentrations are substantially lower on weekends relative to weekdays, while differences in VOC concentrations (exp ressed here as tota l non-methane organic compounds, TMNOC) are less pronounced. This is due to the fact that some major VOC sources, such as biogenic emissions and fuel evaporation, remain cons tant irrespective of the day of the week. For both precursors, the weekend/weekday differences are more evident at the maximum precursor sites (Tuc ker and South-DeKalb) than at the upwind (Yorkville) and downwind (Conyers) sites.

Table 2-9: Weekday/weekend diff erences in daytime (6am-7pm) NO
x and VOC (TNMOC) concentrations at the four Atlanta PAMS sites during 1997-2005 (only days in which both NOx and TNMOC measurements were available are included)

NO
x (ppb) VOC (TNMOC, ppbC) Site Weekday Weekend % change Weekday Weekend % change

South

- DeKalb 18.9 10.6 -43.8 65.1 49.3 -24.2

Tucker 15.4 7.6 -50.5 72.6 51.6 -28.9 Conyers 6.2 4.1 -34.7 34.5 31.3 -9.3

Yorkville 3.1 2.1 -31.3 24.5 24.6 0.3

Changes in weekdays/weekend daily maximum 8-hour ozone concentrations are presented in Figure 2-6, for all four Atla nta PAMS sites, as well as the Atlanta Confederate Avenue site, for the period of 1997-2005, as well as for 3-year periods within that range. The Confed erate Avenue site is of special interest as its DV has consistently been the highest of all the Atlanta monitors throughout the 1998-2005 period, and due to its location in the cente r of the nonattainment area (about 2 miles south-east of downtown Atlanta) . These results indicate that ozone in Atlanta is typically lower on the weekends compared to weekdays, which can serve as an additional indication to Atlanta ozone being NO

x -limited. Of the five sites investigated, Confederate
Avenue and South-DeKalb seem the least NO

x -limited, which is expected given their
location in the middle of the core urban ar ea (Confederate Avenue) and adjacent to a major highway (South-DeKalb, located about 0.8 miles away from I-285). Splitting the
dataset of ozone concentr ations into three 3-year periods (1997-1999, 2000-2002, 2002-

46The Atlanta Eight-Hour Ozone Attainment Demonstration

2005) seems to indicate that Atlanta oz one may have shifted from being VOClimited/NO

x -inhibited in the earlie r period (1997-1999), as e xpressed by higher ozone concentrations during the weekends (especia lly in the Confederate Avenue and SouthDeKalb sites) to NO

x -limited in the latter period ( 2003-2005), as expressed by lower ozone concentrations during the weekends. Thes e results are consistent with the overall
trend of reduction in NO

x emissions in the region (Figure 2-3), and hence the decline in availability of NO

x for ozone formation.

b) 1997-1999

52.0 54.0 56.0 58.0 60.0 62.0 64.0 66.0 68.0 70.0 72.0

Conf.

Ave. SouthDeKalb Tucker Conyers YorkvilleAverage of max 8-hr O3(ppb) Weekdays Weekend

d) 2003-2005

44.0 46.0 48.0 50.0 52.0 54.0 56.0

Conf.

Ave. SouthDeKalb Tucker Conyers YorkvilleAverage of max 8-hr O3(ppb) Weekdays Weekend a) 1997-2005

51.0 52.0 53.0 54.0 55.0 56.0 57.0 58.0 59.0 60.0 61.0

Conf.

Ave. SouthDeKalb Tucker Conyers YorkvilleAverage of max 8-hr O3(ppb) Weekdays Weekend

c) 2000-2002

48.0 50.0 52.0 54.0 56.0 58.0 60.0

Conf.

Ave. SouthDeKalb Tucker Conyers YorkvilleAverage of max 8-hr O3(ppb) Weekdays Weekend

Figure 2-6: Weekdays/weekend di fferences in ozone concentrations at the Confederate
Avenue site and the four Atlanta PAMS sites for (a) 1997-2005, (b) 1997-1999, (c) 2000- 2002, and (d) 2003-2005.

2.3 Conclusions
Various analyses presented in this section suggest that desp ite a regional trend in ozone levels throughout the state of Georgia, there is a local pattern of ozone formation in the
Atlanta area and that reducti ons in emissions of ozone precursors in the Atlanta nonattainment area are likely to introduce a change in (local ) ozone concentrations. In addition, it has been shown that the A tlanta nonattainment area is generally NO

x -limited, though may be VOC-limited or transitional in so me cases. Analysis of data collected at the four PAMS sites throughout Atla nta indicates that lower VOC/NO

x ratios are associated with elevated daily maximum 8-hour ozone concentrations. Analysis of ozone,
NO and NO

x data using the ozone M.A.P.P.E.R. pr ogram indicated that ozone formation in Atlanta is generally transitional to NO

x -limited, but when the results were binned according to the daily maximum 8-hour oz one, ozone formation seemed strongly NO

x limited on days of elevated ozone. An analysis of weekend/weekday differences in ozone

47The Atlanta Eight-Hour Ozone Attainment Demonstration

concentration also indicate a generally NO

x -limited regime, with ozone formation becoming more NO

x -limited in recent years compared to the late 1990's.

These findings are generally in agreement with several studies of the trends and limiting
factors for ozone formation in Atlanta. Pun et al. (2003) investigated the weekly patterns
of ozone in Atlanta and found elevated midweek concentrations compared to weekends, with stronger weekly pa tterns in later years (1995- 1999 compared to 1986-1990), concluding that the availability of NO

x drives the weekly ozone cycle in Atlanta. Analyzing various aircraft m easurements, Sillman et al. (1997) conclude that Atlanta ozone is mostly NO

x -limited, using various indicator ratios.

The findings presented here are also consistent with results from an air-quality model based sensitivity analysis (Appendix F). The integration of these various analyses support the control of NO

x emissions as part of a state strategy for reducing ozone levels
in the Atlanta area.

48The Atlanta Eight-Hour Ozone Attainment Demonstration

49 

## 3.0 ATTAINMENT DEMONSTRATION METHODS AND
INPUTS

The attainment modeling for the Atlant a nonattainment area was performed in conjunction with the regional haze mode ling being done by the Southeast Regional Planning Organization, Visibi lity Improvement State and Tribal Association of the Southeast (VISTAS) and the fine particul ate matter (PM2.5) and ozone modeling being done by the Association of Southeastern Inte grated Planning (ASIP). VISTAS and ASIP are run by the ten Southeast states (Alaba ma, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Vi rginia and West Virginia). Since the regional haze and PM2.5 modeling uses annual simulations and includes an intermediate year that is the attainment year required for the Atlanta nonattainment area, the EPD
decided to use the this mode ling for its attainment demonstration. The sections below outline the methods and inputs used by VISTAS/ASIP for the regional modeling.

3.1 Analysis Method

The modeling analysis is a complex technical evaluation that begins by selection of the modeling system. VISTAS decided to use the following modeling system:

• Meteorological Model: The Pennsylvania State University/National Center for Atmospheric Research ( PSU/NCAR ) Mesoscale Meteorological Model ( MM5 ) is a nonhydrostatic, prognostic meteorological model routinely used for urban- and regional-scale photochemical, fine particul ate matter, and regional haze regulatory modeling studies.

• Emissions Model: The Sparse Matr ix Operator Kernel Emissions ( SMOKE ) modeling system is an emissions modeli ng system that generates hourly gridded speciated emission inputs of mobile, nonroad mobile, area, point, fire and biogenic emission sources for photochemical grid models.

• Air Quality Model: USEPA's Models -3/ Community Multiscale Air Quality (CMAQ) modeling system is an 'One -Atmosphere' photochemical grid model capable of addressing ozone, particul ate matter (PM), visibility and acid deposition at regional scale for periods up to one year.

Additionally, a historical year is selected to model that represent typical meteorological conditions in the Southeast when high oz one, PM2.5 and poor visibility are observed throughout the Region. Once the hi storical year is selected , meteorological inputs are developed using the meteorological model. Emission inventories are also developed for the historical year and processed through the emissions model. These inputs are used in the air quality model to predict ozone, PM2.5 an d visibility, with the results compared to the historic data. The model performan ce is evaluated by comparing the modeled predicted data to the hi storic air quality data.The Atlanta Eight-Hour Ozone Attainment Demonstration

50 Once model performance is deemed adequate, ty pical baseline and future year emissions are processed through the emissions model. For this demonstrati on, the baseline year was 2002, which corresponds with the same year as the historic meteorology used in the modeling. The attainment future year EPD is using for this demonstration is 2009, since the mandatory attainment date for Atlanta as a moderate nonattainment area is June 15, 2010. The attainment date is set prior to the completion of the 2010 ozone season, therefore the attainment of the NAAQS woul d have to be met by the end of the 2009 ozone season. These emissions are proces sed through the air quality model with the meteorological inputs. The ai r quality modeling re sults are used to determine a relative reduction in future ozone, whic h is used in the attainment demonstration. The complete modeling protocol and the quality assurance pr oject plan used for this analysis can be found in Appendix N and Appendix P, respectively.

3.2 Model Selection

To ensure that a modeling study is defensible, care must be taken in the selection of the models to be used. The models selected must be scientifically appropriate for the intended application and be freely accessible to all stakeholders. Scientifically appropriate means that the models address important physical and chemical phenomena in sufficient detail, using peer-reviewed me thods. Freely accessible means that model formulations and coding are freely available fo r review and that the models are available to stakeholders, and their consultants, for execution and verification at no or low cost.

The following sections outline the criteria for selecting a modeling system that is both defensible and capable of meeting the study's goa ls. These criteria we re used in selecting the modeling system used for this modeling attainment demonstration.



### 3.2.1 Selection of Phot ochemical Grid Model

Criteria

For a photochemical grid model to qualify as a candidate for use in an attainment demonstration of the 8-hour ozone NAAQS, a St ate needs to show that it meets several general criteria:

• The model has received a scientific peer review

• The model can be demonstrated applicable to the problem on a theoretical basis

• Data bases needed to perform the analysis are available and adequate

• Available past appropriate performance ev aluations have show n the model is not
biased toward underestimates or overestimates

• A protocol on methods and procedures to be followed has been establishedThe Atlanta Eight-Hour Ozone Attainment Demonstration

51 • The developer of the model must be willing to make the source code available to users for free or for a reasonable cost, and the model cannot otherwise be proprietary.

Overview of CMAQ

The photochemical model selected for this st udy was CMAQ version 4.5. For more than a decade, the U.S.EPA has been developing the Models-3 CMAQ modeling system with the overarching aim of producing a 'One-A tmosphere' air quality modeling system capable of addressing ozone, fine particulate matter, visibility and acid deposition within a common platform. The original justifica tion for the Models-3 development emerged from the challenges posed by the 1990 CAAA and the USEPA's desire to develop an advanced modeling framework for 'holistic' environmental modeling utilizing state-ofscience representations of atmospheric pr ocesses in a high performance computing environment. The U.S.EPA completed the in itial stage of development with Models-3 and released the CMAQ model in mid 1999 as the initial operati ng science model under the Models-3 framework. The most recent rendition is CMAQ version 4.5, which was
released in October 2004.

Another reason for choosing CMAQ as the atmo spheric model is the ability to do oneatmospheric modeling. Since EPD will be us ing the same modeling exercise for the
ozone and PM 2.5 attainment demonstrations SIPs, as well as the regional haze SIP, having a model that can handle both ozone and partic ulate matter is essential. A number of features in CMAQ's theoretical formula tion and technical implementation make the model well suited for annual PM modeling.

The configuration used for this modeling de monstration, as well as a more detailed description of the CMAQ model, can be found in the Modeling Protocol (Appendix N).



### 3.2.2 Selection of Meteorological Model

Criteria

Meteorological models, either through objec tive, diagnostic, or prognostic analysis,
extend available information about the state of the atmosphere to the grid upon which photochemical grid modeling is to be ca rried out. The crite ria for selecting a meteorological model are based on both the model's ability to accurately replicate important meteorological phenomena in the re gion of study, and the model's ability to
interface with the rest of the modeling systems -- par ticularly the photochemical grid model. With these issues in mind, the fo llowing criteria were established for the meteorological model to be used in this study:

• Non-Hydrostatic Formulation

• Reasonably current, peer reviewed formulation

• Simulates Cloud PhysicsThe Atlanta Eight-Hour Ozone Attainment Demonstration

52 • Publicly available at no or low cost

• Output available in I/O API format

• Supports Four Dimensional Data Assimilation (FDDA)

• Enhanced treatment of Planetary Bo undary Layer heights for AQ modeling

Overview of MM5

The non-hydrostatic MM5 model is a three-di mensional, limited-area, primitive equation, prognostic model that has been us ed widely in regional air quality model applications.
The basic model has been under continuous de velopment, improvement , testing and open peer-review for more than 20 years and has been used worldwide by hundreds of scientists for a variety of mesoscale studies.

MM5 uses a terrain-following non-dimensiona lized pressure, or "sigma," vertical
coordinate similar to that used in many operational and re search models. In the nonhydrostatic MM5, the sigma levels are define d according to the initial hydrostaticallybalanced reference state so that the sigma le vels are also time-invariant. The gridded meteorological fields produced by MM5 ar e directly compatible with the input requirements of "one atmosphere" air-quality models using this coor dinate. MM5 fields can be easily used in other re gional air quality mode ls with different coordinate systems by performing a vertical inte rpolation, followed by a mass-conservation re-adjustment.

Distinct planetary boundary layer ( PBL ) parameterizations are available for air-quality applications, both of which repr esent sub-grid-scale turbulent fluxes of heat, moisture and
momentum. One scheme uses a first-order eddy diffusivity formulation for stable and neutral environments and a modified first-order scheme for unstable regimes. The other scheme uses a prognostic equation for the s econd-order turbulent kinetic energy, while diagnosing the other key boundary layer terms.

Initial and lateral boundary condi tions are specified for real -data cases from mesoscale three-dimensional analyses performed at 12- hour intervals on the outermost grid mesh selected by the user. Surface fields are analyzed at three- hour intervals. A Cressmanbased technique is used to analyze standard surface and radiosonde observations, using the National Meteorological Center's spectral analysis, as a first guess. The lateral boundary data are introduced us ing a relaxation technique a pplied in the outermost five rows and columns of the coarsest grid domain.

Results of detailed performance evaluations of the MM5 modeling system in regulatory air quality application studies have been widely reported in the literature (e.g., Emery et al., 1999; Tesche et al., 2000, 2003) and many have involved comparisons with other prognostic models such as the Regi onal Atmospheric Modeling System ( RAMS ) and the Systems Application International Mesoscal e Model. The MM5 enjoys a far richer application history in regulator y modeling studies compared with RAMS or other models. Furthermore, in evaluations of these models in over 60 recent regional scale air qualityThe Atlanta Eight-Hour Ozone Attainment Demonstration

53 application studies since 1995, it has generally been found th at the MM5 model tends to produce somewhat better photochemical m odel inputs than a lternative models.

The configuration used for this modeling de monstration, as well as a more detailed description of the MM5 model, can be f ound in the Modeling Pr otocol (Appendix N).The Atlanta Eight-Hour Ozone Attainment Demonstration

54 

### 3.2.3 Selection of Emissions Processing System

Criteria

The principal criterion for an emissions proces sing system is that it accurately prepares
emissions files in a format suitable for the photochemical grid model being used. The following list includes clarification of this cr iterion and additional desirable criteria for effective use of the system.

• File System Compatibility with the I/O API

• File Portability

• Ability to grid emissions on a Lambert Conformal projection

• Report Capability

• Graphical Analysis Capability

• MOBILE6 Mobile Source Emissions

• Biogenic Emissions Inventory System version 2 (BEIS-3)

• Ability to process emissions for the proposed domain in a reasonable amount of
time.

• Ability to process control strategies

• No or low cost for acquisition and maintenance

• Expandable to support other species and mechanisms

Overview of SMOKE

The SMOKE Emissions Processing System Pr ototype was originally developed at the Micro-computing Center of North Carolina. As with most "emissions models," SMOKE is principally an emission processing system and not a true emissions modeling system in
which emissions estimates are simulated from "f irst principles." This means that, with the exception of mobile and biogenic sources , its purpose is to provide an efficient, modern tool for converting emissions invent ory data into the formatted emission files required by an air quality simulation model. For mobile sources, SMOKE actually simulates emissions rates based on input m obile-source activity data, emission factors and outputs from transportation travel-dema nd models. SMOKE was originally designed to allow emissions data processing met hods to utilize emergent high-performancecomputing as applied to sparse-matrix al gorithms. Indeed, SMOKE is the fastest emissions processing tool currently availabl e to the air quality m odeling community. The sparse matrix approach utilized throughout SMOKE permits both rapid and flexible processing of emissions data. The processing is rapid because SMOKE utilizes a series
of matrix calculations instead of less efficien t algorithms used in previous systems. The processing is flexible because the processi ng steps of temporal projection, controls, chemical speciation, temporal allocation, and spatial allocati on have been separated intoThe Atlanta Eight-Hour Ozone Attainment Demonstration

55 independent operations wherever possible. The results from these steps are merged together at a final stage of processing.

SMOKE contains a number of ma jor features that make it an attractive component of the modeling system. The model supports a variet y of input formats from other emissions processing systems and models. It supports both gridded and county total land use scheme for biogenic emissions modeling. SMOKE can accommodate emissions files from up to 10 countries and any pollutant can be processed by the system.

For additional information about the SMOKE model please refer to Georgia EPD’s Modeling Protocol found in Appendix N.

3.3 Episode Selection

A crucial step to SIP modeling is the selection of episodes to model. Several considerations need to be weighed before settling on not only which days to model, but how many days for each episode. This section details the guidance and process by which episodes were selected for the 8-hour Ozone SIP modeling package. The time frame for
the ozone season considered in this episode selection is May through September even though the ambient monitoring for ozone is required from March through October.



### 3.3.1 Overview of U.S.EPA Guidance on Ozone

The USEPA's September 2006 draft final guidance (referred to as Attainment Guidance ), Guidance on the Use of Models and Other Anal yses for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze (see Appendix L) , sets out specific criteria for the selection of episodes to model for attainment of the 8-hour ozone NAAQS. First, episodes should include days encompassing a variet y of meteorological conditions, including varyin g wind directions, for da ys exceeding 0.084 ppm. Additionally, episodes should be selected that contain days close (within ± 0.010 ppm) to the current design value ( DVC ). Episodes should also be chosen around days for which there are extensive air quality and meteor ology measurements, incl uding measurements aloft, measurements of indicator species and/or precursor measurements. Finally, a sufficient number of days should be selected to ensure robust attainme nt tests at violating monitoring sites.

In addition to these primary cr iteria, the U.S.EPA also suggest s a set of secondary criteria that may be used in the selection of episodes. This set of criteria allows states to give preference to previously modele d episodes. This is a very valuable consideration, as the U.S.EPA points out, since it can save modeling resources and effort. Additional
considerations include sele cting episodes maximizing the number of days and sites observing a violation, selecti ng episodes which include weekends, and the selection of episodes meeting primary and secondary crit eria in other nonattainment areas, when participating in regional mode ling. Using these criteria laid out by the U.S.EPA, the data available was systematically examined to determine the best episodes for modeling.The Atlanta Eight-Hour Ozone Attainment Demonstration

56 

### 3.3.2 Episode Selection

With the advances in computing and st orage technologies, and aided by regional modeling efforts, EPD will use modeling for the 2002 ozone season (May through September) for the 8-hour ozone attainment de monstration SIP. By modeling this season, several criteria are covered, in cluding the modeling of weekends and a sufficient number of days to ensure a robust modeled attainme nt test. Modeling the 2002 ozone season will also accomplish the goal of encompassing a myriad of meteorologi cal conditions that
influence ozone concentrations. Details of the episode selection process can be found in Appendix N.

3.4 Modeling Domains



### 3.4.1 Horizontal Modeling Domain

The CMAQ model was run in one-way nested gr id mode. This allowed the larger outer
domains to feed concentration data to the inner nested domain. One-way nesting is believed to be appropriate for the generally stagnant conditions experienced during Georgia ozone episodes. Two-way nesting was not considered due to numerical and computational uncertainty asso ciated with the technique.

The horizontal coarse grid modeling domain boundaries were determined through a national effort to develop a common grid projection and b oundary. Since this national modeling domain was used in the VISTAS regional haze modeling, it was used for the
attainment demonstration as well. A sma ller 12-km grid, modeling domain was selected in an attempt to balance location of areas of interest, such as ozone and fine particulate matter nonattainment areas, as well as Class I and wilderness areas for regional haze. Processing time was also a factor in c hoosing a smaller 12-km grid, modeling domain.

The coarse 36-km horizontal grid domain covers the continental United States. This
domain was used as the outer grid domain for MM5 modeling with the CMAQ domain nested within the MM5 domain. Figure 3- 1 shows the MM5 horizontal domain as the outer most, blue grid with the CMAQ 36- km domain nested in the MM5 domain.The Atlanta Eight-Hour Ozone Attainment Demonstration

Figure 3-1: The MM5 horizontal domain is th e outer most, blue grid, with the CMAQ 36-
km domain nested in the MM5 domain.

To achieve finer spatial resolution in th e VISTAS states, a one-way nested high resolution (12-km grid resolution) was used. Figure 3- 2 shows the 12-km grid, modeling domain for the VISTAS region. This is the modeling domain on which the attainment
test results are based. The North Carolina Division of Air Quality (NCDAQ) did a study (Arunachalam et al ., 2006) to determine if using a fine r grid resolution provided different modeling results. Since the USEPA's attainment test uses the modeling results to
determine the relative reductions in ozone betw een the base year and the future year, the NCDAQ determined that effectively the same attainment test results are obtained from 12-km grid modeling or 4-km grid mode ling. Since 4-km grid modeling takes significantly more time and resources to run, the EPD decided to use the VISTAS 12-km grid modeling results for this attainment demonstration.

57The Atlanta Eight-Hour Ozone Attainment Demonstration

Figure 3-2: A more detailed view of the 12-km grid over the VISTAS region.



### 3.4.2 Vertical Modeling Domain

The CMAQ vertical structure is primarily defined by the vert ical grid used in the MM5 modeling. The MM5 model employed a terrain following coordinate system defined by pressure, using 34 layers that extend from th e surface to the 100 mb. Table 3-1 lists the layer definitions for both MM5 and for CMAQ. A layer-averaging scheme is adopted for CMAQ to reduce the computational cost of th e CMAQ simulations. The effects of layer averaging were evaluated in conjunction wi th the VISTAS modeling effort and was found to have a relatively mi nor effect on the model perf ormance metrics when both the 34 layer and a 19 layer CMAQ models were compared to ambient monitoring data.

58The Atlanta Eight-Hour Ozone Attainment Demonstration

59 Table 3-1: Vertical Layer Definition For MM5 and CMAQ

MM5 Simulation CMAQ 19 Layers Layer Sigma Pressure (mb) Height (m) Depth (m) Layer Sigma Pressure (mb) Height (m) Depth (m)
34 0.000 100 14662 1841 19 0.000 100 14662 6536

33 0.050 145 12822 1466 0.050 145

32 0.100 190 11356 1228 0.100 190

31 0.150 235 10127 1062 0.150 235

30 0.200 280 9066 939 0.200 280

29 0.250 325 8127 843 18 0.250 325 8127 2966

28 0.300 370 7284 767 0.300 370

27 0.350 415 6517 704 0.350 415

26 0.400 460 5812 652 0.400 460

25 0.450 505 5160 607 17 0.450 505 5160 1712

24 0.500 550 4553 569 0.500 550

23 0.550 595 3984 536 0.550 595

22 0.600 640 3448 506 16 0.600 640 3448 986

21 0.650 685 2942 480 0.650 685

20 0.700 730 2462 367 15 0.700 730 2462 633

19 0.740 766 2095 266 0.740 766

18 0.770 793 1828 259 14 0.770 793 1828 428

17 0.800 820 1569 169 0.800 820

16 0.820 838 1400 166 13 0.820 838 1400 329

15 0.840 856 1235 163 0.840 856

14 0.860 874 1071 160 12 0.860 874 1071 160

13 0.880 892 911 158 11 0.880 892 911 158

12 0.900 910 753 78 10 0.900 910 753 155

11 0.910 919 675 77 0.910 919

10 0.920 928 598 77 9 0.920 928 598 153

9 0.930 937 521 76 0.930 937

8 0.940 946 445 76 8 0.940 946 445 76

7 0.950 955 369 75 7 0.950 955 369 75

6 0.960 964 294 74 6 0.960 964 294 74

5 0.970 973 220 74 5 0.970 973 220 74

4 0.980 982 146 37 4 0.980 982 146 37

3 0.985 986.5 109 37 3 0.985 986.5 109 37

2 0.990 991 73 36 2 0.990 991 73 36

1 0.995 995.5 36 36 1 0.995 995.5 36 36

0 1.000 1000 0 0 0 1.000 1000 0 0

3.5 Emission Inventory



### 3.5.1 Types of Emission Inventories

In addition to the various sour ce classifications, there are al so various types of emission inventories. The first is the "actual" base ye ar inventory. This inve ntory is the base year emissions that correspond to the meteorologica l data, for this modeling effort is 2002. These emissions are used for evaluating the air quality model performance.The Atlanta Eight-Hour Ozone Attainment Demonstration

60 The second type of inventory is the "typical" base year i nventory. This inventory is similar to the actual base year, however for sources that may have significant changes from year-to-year, a more typical emission valu e is used. In this modeling effort, typical emissions were developed for the electric ge nerating units (EGUs) and the wildland fire emissions. The air quality modeling results using these emissions are used in calculating the relative response factors used in the attainment demonstration test.

The “future” year base inventory is an i nventory developed for some future year for
which attainment of the ozone standard is n eeded. For this modeling project, the future year inventory will be 2009, the last complete year for which the standard must be
attained. It is the future ba se year inventory that control strategies and sensitivities are applied to determine what controls beyond thos e measures already included in the future year base inventory, to which s ource classifications must be made in order to attain and
maintain the ozone standard.

Lastly, ozone season averages were com puted based on emissions from May through September which makes up a portion of the ozone season of March through October.



### 3.5.2 Emission Inventory Source Classification
There are five different emission inventory source classifications, stationary point and area sources, off-road and on -road mobile sources, and bi ogenic sources. Stationary point sources are those sources that emit greater than a specified tonnage per year and the data is provided at the facility level. EP A has established certain minimum point source thresholds for both pollutant nonattainment area s and attainment areas. According to the Consolidated Emissions Reporting Rule (CERR) , States are required to report data for larger point sources, or Type A point sources, on an annual ba sis. Type B sources refer to all point sources, including Type A sour ces. The reporting frequency for Type B sources has been established as once every 3 years. Area (or nonpoint sources) are sources that do not qualify as point sources under the releva nt emissions cutoffs. Area sources encompass more widespread sources th at may be abundant, but that, individually, release small amounts of a given pollutant and collectively could be significant. Examples of area sources include dry clean ers, residential wood heating, autobody painting, fires, and consumer solvent use. These types of emissions are estimated on the county level.The Atlanta Eight-Hour Ozone Attainment Demonstration

61 Georgia EPD used the 2002 CERR, in part, to build its 2002 base year inventory for this analysis. Stationary sources located in the 13-county metro Atlanta area [1-hour ozone nonattainment area] in 2002 were located in a “serious” nonattainment area and the annual reporting threshold for such sources wa s 50 tons per year for VOC and NOx. In the additional seven additional counties that make up the 20-county metro Atlanta ozone
nonattainment area in 2002 were located in an attainment area and the annual reporting threshold for such sources was 100 tons per year for VOC and NOx. Off-road mobile sources include equipment th at can move, but do not use the roadways, i.e., lawn mowers, construction equipment, railroad locomotives, aircraft, etc. The emissions from these sources, like stationary area sources, are estimated on the county level. On-road mobile sources are automobiles, trucks, and motorcycles that use the roadway system.
The emissions from these sources are estimat ed by vehicle type a nd road type and are summed to the county level. Biogenic sour ces are the natural sources like trees, crops, grasses and natural decay of pl ants. The emissions from th ese sources are estimated on a county level.

In the sections that follow, a synopsis of the inventories used for each source
classifications are discussed. The detailed discussions of the emissions inventory development can be found in Appendix K. Emission summaries by county for the
Atlanta nonattainment area can be found in Tables 3-2 and 3-3, and the state-wide emission summaries are in Appendix A.The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 3-2: Summary of ozone season daily NOX emissions in2002 and 2009 by source categories for 20 counties in Atlanta.PointAreaOn-RoadNon-RoadCountiesFIPs20022009Diff%20022009Diff%20022009Diff%20022009Diff%Barrow Co0130130.060.070.019.420.450.460.012.525.694.69-1.00-17.511.411.18-0.23-16.12Bartow Co01301569.9217.60-52.32-74.831.301.350.054.0315.7611.46-4.29-27.263.893.30-0.60-15.31Carroll Co0130450.060.070.0110.491.301.350.053.8810.917.92-2.99-27.442.391.96-0.43-17.89Cherokee Co0130570.200.220.028.730.720.760.045.0910.256.77-3.49-34.003.593.01-0.58-16.13Clayton Co0130630.300.350.0517.361.081.120.043.5319.9611.64-8.31-41.6619.2120.981.779.20Cobb Co01306712.6211.54-1.08-8.574.124.260.143.4250.6629.03-21.62-42.6812.6710.93-1.74-13.71Coweta Co01307723.0831.067.9834.570.890.920.033.827.865.11-2.74-34.903.302.89-0.41-12.40DeKalb Co0130890.490.530.047.924.064.190.143.3763.3336.25-27.09-42.779.988.42-1.55-15.58Douglas Co0130970.060.060.018.870.480.500.024.069.706.35-3.35-34.521.871.60-0.27-14.62Fayette Co013113----0.770.800.034.335.203.18-2.02-38.802.181.83-0.36-16.31Forsyth Co0131170.120.120.000.820.840.880.044.638.416.16-2.25-26.723.112.59-0.52-16.66Fulton Co0131215.464.19-1.27-23.286.596.790.203.0991.4252.06-39.37-43.0620.0217.20-2.82-14.07Gwinnett Co0131350.090.090.001.304.554.700.163.4849.2630.32-18.94-38.4515.3612.87-2.50-16.25Hall Co0131390.290.290.000.292.792.890.103.6115.1210.89-4.23-27.983.803.11-0.68-18.04Henry Co0131516.442.78-3.67-56.890.600.630.035.3113.408.48-4.92-36.704.684.08-0.59-12.68Newton Co0132170.000.000.005.430.790.800.011.426.724.99-1.73-25.761.951.57-0.38-19.67Paulding Co013223----0.260.310.0517.634.763.33-1.43-30.012.662.37-0.29-10.79Rockdale Co0132470.080.090.016.941.001.040.044.495.703.49-2.21-38.811.591.26-0.32-20.41Spalding Co0132550.000.010.009.140.790.820.033.855.253.96-1.29-24.550.870.67-0.20-22.69Walton Co0132970.010.400.393589.330.470.46-0.01-1.195.724.35-1.37-23.951.701.41-0.28-16.74Total119.3169.47-49.84-41.7733.8535.071.213.59405.06250.43-154.63-38.17116.23103.25-12.98-11.1762The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 3-3: Summary of ozone season daily VOC emissions in2002 and 2009 by source categories for 20 counties in Atlanta.PointAreaOn-RoadNon-RoadCountiesFIPs20022009Diff%20022009Diff%20022009Diff%20022009Diff%Barrow Co0130130.020.01-0.02-71.593.743.57-0.17-4.544.303.65-0.65-15.040.750.52-0.23-31.09Bartow Co0130151.311.410.107.878.057.39-0.66-8.2210.568.00-2.56-24.272.542.10-0.44-17.32Carroll Co0130450.850.910.067.499.549.20-0.34-3.608.105.89-2.21-27.271.871.64-0.23-12.08Cherokee Co0130570.130.140.016.816.305.71-0.58-9.275.173.92-1.25-24.195.304.14-1.16-21.83Clayton Co0130631.291.14-0.15-11.929.538.49-1.04-10.929.906.53-3.37-34.033.833.10-0.73-19.04Cobb Co0130670.890.910.032.8828.1825.91-2.27-8.0626.8417.46-9.38-34.9418.8213.39-5.43-28.85Coweta Co0130770.620.52-0.10-16.393.943.53-0.41-10.343.752.70-1.04-27.842.491.61-0.89-35.58DeKalb Co0130894.663.88-0.78-16.7444.6739.56-22.34-15.6331.2120.56-10.65-34.1316.7611.75-5.01-29.88Douglas Co0130970.080.090.0111.713.933.52-0.41-10.364.543.46-1.08-23.751.260.87-0.39-31.24Fayette Co013113----4.694.31-0.37-7.922.841.93-0.92-32.211.911.27-0.64-33.66Forsyth Co0131170.480.510.036.204.824.43-0.39-8.144.283.61-0.67-15.635.363.50-1.87-34.79Fulton Co0131215.424.32-1.10-20.3649.4746.45-3.02-6.1046.1030.33-15.77-34.2117.1913.85-3.34-19.43Gwinnett Co0131350.130.170.0428.2932.0229.74-2.28-7.1225.2017.72-7.48-29.6923.8515.19-8.67-36.33Hall Co0131390.690.45-0.24-34.8913.6913.20-0.49-3.6111.598.48-3.11-26.826.475.43-1.04-16.02Henry Co0131511.341.440.118.155.264.81-0.45-8.596.404.73-1.67-26.072.752.19-0.56-20.38Newton Co0132172.012.570.5527.405.215.03-0.17-3.344.953.71-1.25-25.201.290.87-0.42-32.56Paulding Co013223----3.513.17-0.34-9.752.572.04-0.53-20.571.430.97-0.46-31.89Rockdale Co0132470.440.530.0920.054.284.06-0.22-5.132.881.99-0.89-30.881.420.94-0.49-34.21Spalding Co0132550.180.17-0.01-7.065.955.90-0.05-0.854.143.10-1.04-25.081.211.16-0.04-3.49Walton Co0132970.320.25-0.07-20.824.924.72-0.20-4.144.663.52-1.14-24.501.530.98-0.55-35.80Total20.8619.41-1.45-6.95251.69232.7-18.99-7.54219.98153.33-66.65-30.30118.0385.46-32.57-27.5963The Atlanta Eight-Hour Ozone Attainment Demonstration

64 

### 3.5.3 Stationary Point Sources

Point source emissions are emissions from individual sources having a fixed location. Generally, these sources must have permits to operate and their emissions are inventoried on a regular schedule. Point source emissions data can be grouped into the EGU sources and the other point sources, i.e., non-EGUs. Stationary point NOx emissions comprise approximately 17.7% of total NOx emissions in the metro Atlanta nonattainment area for 2002. Stationary point VOC emissions comp rise approximately 3.4% of total VOC
emission in the metro Atlanta nonattainment area for 2002.

Electric Generating Units

The actual base year inventory for the EGU sources used 2002 continuous emissions monitoring (CEM) data reporte d to the USEPA's Acid Ra in program or 2002 hourly emissions data provided by stakeholders. Th is data provides hourly emissions profiles that can be used in the modeling of these la rge sources of NOx and helps to provide more accurate modeling of these sources (Appendix O).

Since the NOx emissions from EGU sources are a signifi cant part of the emissions inventory, a typical base year emissions i nventory was developed for these sources to
avoid anomalies in emissions due to vari ability in meteorology, economic and outage
factors in 2002. This approach is consistent with th e USEPA's modeling guidance. To develop a typical year 2002 emissions inve ntory for EGU sources, for each unit the average CEM heat input for 2000 through 2004 wa s divided by the 2002 actual heat input to generate a unit specific normalizing factor. This normalizing factor was then multiplied by the 2002 actual emissions. The heat inputs for the period 2000 through 2004 were used since the modeling current desi gn values use monitoring data from this same 5-year period. If a unit was shutdow n for an entire year during the 2000 through 2004 period, the average of the years the unit was operational was used. If a unit was shutdown in 2002, but not permanently shutdown, the emissions and heat inputs for 2001 (or 2000) were used in the normalizing calculations.

As part of the VISTAS modeling, VIST AS and the Midwest Regional Planning Organization contracted with ICF Resources, L.L.C., to generate future year emission inventory for the electric generating sector of the contiguous United States using the Integrated Planning Model ( IPM) . IPM is a dynamic linear optimization model that can be used to examine air pollution control policies for various pollutants throughout the contiguous United States for th e entire electric power system . The dynamic nature of IPM enables the projection of the behavior of the power system over a specified future period. The optimization logic determines th e least-cost means of meeting electric generation and capacity requirements while complying with specified constraints including air pollution regulations, tran smission bottlenecks, and plant-specific operational constraints. The ve rsatility of IPM allows users to specify which constraints to exercise and populate IPM with their own datasets.The Atlanta Eight-Hour Ozone Attainment Demonstration

65 The IPM modeling runs took into consideration the USEPA's Clean Air Interstate Rule ( CAIR ) implementation and Clean Air Mercury Rule (CAMR) and North Carolina's Clean Smokestacks Act compliance plan s for Duke Power and Progress Energy.

Table 3-4 lists EGU point so urces in and near the Atla nta nonattainment area and the average daily ozone season NOx emissions.

Table 3-4: Summary of ozone season daily NO X emissions (tons/day) in 2002 and

2009 for major EGU point sources in and around the Atlanta nonattainment
counties

County FIPS Plant ID Pl ant Name 2002 2009
Electrical Generating Units (EGU)

Bartow 013015 01500011 GEORGIA POWER COMPANY, PLANT BOWEN 69.24 16.92

Cobb 013067 06700003 GEORGIA POWER COMPANY, PLANT
MCDONOUGH 11.28 10.21

Coweta 013077 07700001 GEORGIA POWER COMPANY, PLANT YATES 22.93 30.89

Monroe 013207 20700008 GEORGIA POWER COMPANY, PLANT SCHERER 77.41 52.55

Putnam 013237 23700008 GEORGIA POWER COMPANY, PLANT BRANCH 62.59 58.31

Heard 013149 14900001 GEORGIA POWER COMPANY, PLANT WANSLEY 44.59 10.24
Floyd 013115 11500003 GEORGIA POWER COMPANY, PLANT HAMMOND 22.77 17.81

NOx Emissions - Other Point Sources

For the non-EGU sources, the same inventory wi ll be used for both the actual and typical base year emissions inventories. The non- EGU category will use annual emissions as reported for the Consolidated Emissions Reporting Rule (CERR) for the year 2002. These emissions were temporally allocated to month, day, and hour using source category code ( SCC ) based allocation factors using the SMOKE emissions model.

The general approach for assembling future y ear data was to use recently updated growth
and control data cons istent with USEPA's CAIR analyses. This data was supplemented with state specific growth factors and stakeholder input on growth assumptions.

Table 3-5 lists non-EGU point sources in the Atlanta nonattainment counties with NOx emissions larger th an 100 tons/year.The Atlanta Eight-Hour Ozone Attainment Demonstration

66 Table 3-5: Major non-EGU point sources in the Atlanta nonattainment counties with NOx emissions larger than 100 tons/year

County FIPS Plant ID Plant Name 2002 2009

Henry 013151 15100025 TRANSCONTINENTAL GAS PIPE LINE - STATION 6.43 2.76

Fulton 013121 12100020 OWENS-BROCKWAY GLASS CONTAINER INC. 1.93 2.11

Fulton 013121 12100021 OWENS CORNING - FAIRBURN PLANT 1.65 1.81

Fulton 013121 12100401 LAFARGE BUILDING MATERIALS 1.63 0.00

Cobb 013067 06700022 CARAUSTAR MILL GROUP, INC. 1.00 0.80

Bartow 013015 0 1500061 ANHEUSER-BUSCH IN C - CARTERSVILLE 0.41 0.41

Hall 013139 13900002 CARGILL INC 0.29 0.29
Clayton 013063 06300105 DELTA AIR LINES, INC. TOC 0.28 0.33



### 3.5.4 Stationary Area Sources
Stationary area sources include sources whos e emissions are relatively small but due to the large number of these sources, the coll ective emissions could be significant (i.e., combustion of fuels for heating, structure fire s, service stations, et c.). Emissions are estimated by multiplying an emission factor by some known indicator of collective activity, such as fuel usage, number of house holds, or population. St ationary area source emissions are estimated on the county level. A portion of the area source 2002 base year inventory for Georgia was developed by th e EPD and provided to the VISTAS/ASIP
contractor. The VISTAS/ASIP contractor cal culated the remaining portion of the area source inventory. The sources es timated by the contractor include emissions from animal husbandry, wildland fires, and particulate matte r from paved and unpaved roads. For the
other states within the mode ling domain, the state supplied data or the CERR data for
2002 was used.

The actual base year inventory will serve as th e typical base year inventory for all area source categories except for wildland fires. For this source category, development of a typical year fire inventory provided the capabil ity of using a comparable data set for both the base year and future years. Thus, fire emissions would remain the same for air quality modeling in both the base and any fu ture years. The VISTAS Fire Special Interest Work Group was consulte d and decided to use State le vel ratios of acres over a longer term record (thr ee or more years) developed for ea ch fire type relative to 2002. The 2002 acreage was then scaled up or down based on these ratios to develop a typical year inventory.

For categories other than wildland fires, the VISTAS/ASIP contractor generated the future base year emissions inventory used in the attainment demonstration modeling. Growth factors supplied from the states or the USEPA's CAIR emission projections were applied to project the controlled emissions to the appropriate year. In some cases, the USEPA's Economic Growth and Analysis System Version 5 growth factors were used if no growth factor was available from either the states or the CAIR growth factor files.The Atlanta Eight-Hour Ozone Attainment Demonstration

67 Area source NOx emissions comprise approxima tely 5.0% of total NOx emissions in the
metro Atlanta nonattainment area in 2002. Area source VOC emissions comprise approximately 41.2% of total VOC emissions in the metro Atlanta nonattainment area in

2002.

Appendix K provides a detailed discussion of the area source inventory. Appendix A provides emission summaries by county for average ozone season day area source
emissions.



### 3.5.5 Off-Road Mobile Sources
Non-road mobile sources include equipment that can move, but do not use the roadways, such as construction equipment, aircraft , railroad locomotives, lawn and garden equipment, etc. For the majo rity of the non-road mobile sources, the emissions were estimated using the USEPA's NONROAD2005c m odel. For the three source categories not included in the NONROAD model, i.e., ai rcraft engines, railroad locomotives and commercial marine, more traditional methods of estimating the emissions were used. The same inventory will be used for both th e actual and typical base year emissions
inventories for the non-road mobile sources. For the source categories estimated using the USEPA's NONROAD model, the model was used to create a future base year inventory. The NONROAD model take s into consideration rules that are in effect that could impact the emissions from these sour ce categories. The FAA's Terminal Area Forecast was used to project growth in aircraft emissions. For the commercial marine, railroad locomotives and the remaining airp ort emissions, the VISTAS/ASIP contractor calculated the future base year emissions usin g detailed inventory da ta (both before and after controls) for 1996 and 2010 obtained from the USEPA's Clean Air Interstate Rule Technical Support Document. When available, state specific growth factors were used.

Off-road NOx emissions comprise approxima tely 17.2% of total NOx emissions in the
metro Atlanta nonattainment area in 2002. Off-road VOC emissions comprise approximately 19.4% of total VOC emissions in the metro Atlanta nonattainment area in

2002.

Appendix K provides a detailed discussion of the non-road mobile source inventory. Appendix A provides emission summaries by county for average ozone season day nonroad emissions.



### 3.5.6 Highway Mobile Sources
In order to accurately model the mobile source emissions in the Atlanta nonattainment area, the newest version of the MOBILE m odel, MOBILE6.2, was used. Key inputs for the MOBILE model include information on the ag e of vehicles on the roads, the average speed on the roads, the mix of vehicles on the roads, any control technologies in place in
an area to reduce emissions for motor vehi cles (e.g., emissions inspection programs), and
temperature.

The MOBILE model takes into consideration ru les that are in effect that impact the emissions from this source sector. For highw ay mobile sources, the actual and typical year emissions were the same and the MOBI LE model was run using input data reflectiveThe Atlanta Eight-Hour Ozone Attainment Demonstration

68 of 2002. The same model then is run for the future year emissions inventory using input data reflective of 2009. Area-specific vehicl e age distributions were modeled. For the Atlanta nonattainment area, 2002 and 2009 vehicle miles travel ed (VMT) and speeds data from the Atlanta Regional Commission's travel demand model were used. Elsewhere in the state, emissions were modeled us ing 2002 VMT obtained from the Georgia Department of Transportation (GDOT) with emission factors base d on MOBILE6 default speeds. For 2009 emissions modeling, 2009 VMT were projected by the VISTAS contractors based on linear gr owth as derived from the VMT data assembled by the U.S. EPA for their most recent heavy-duty diesel rulemaking. MOBILE6 default speeds were used for 2009 emissions modeling outsid e the Atlanta nonattainment area.

For a detailed discussion about the mobile source inventory development used in the attainment demonstration modeling, please re fer to Appendix K. Emission summaries by county for the mobile source sector can be f ound in Appendix A. Table 3-6 summarizes onroad mobile source emissions in the Atlanta area. On-road NOx emissions comprise approximately 60% of total NOx emissions in the metro Atlanta nonattainment area in 2002. On-road VOC emissions comprise approxi mately 36% of total VOC emissions in
the metro Atlanta nonattainment area in 2002.

Table 3-6: Summary of ozone season daily NO X and VOC emissions (tons/day) in 2002 and 2009 by onroad mobile sources in Atlanta 20 counties

NOX VOC Category 2002 2009 2002 2009 Heavy duty diesel vehicles 213.79 121.25 8.58 6.39 Light duty diesel trucks 0.61 0.25 0.35 0.14 Light duty diesel vehicles 0.20 0.04 0.09 0.02 Heavy-Duty Gas Vehicles 29.98 16.02 7.73 4.93 Light-Duty Gas Trucks 1 & 2 55.21 52.35 78.58 70.65 Light-Duty Gas Trucks 3 & 4 24.36 22.57 21.73 18.04 Light-Duty Gas Vehicles 80.01 37.01 100.81 51.00 Light-Duty Gas Motorcycles 0.90 0.94 2.11 2.17

Total 405.06 250.43 219.98 153.33



### 3.5.7 Biogenic Emission Sources
Biogenic sources are natural (i.e., non-anth ropogenic) emissions sources. Biogenic sources are biological s ources of ozone precursor emission s such as trees, agricultural crops, or microbial activity in soils or water. Biogenic emissions were prepared with the SMOKE-BEIS3 (Biogenic Emission Inventory System 3 version 0.9) preprocessor. SMOKE-BEIS3 is basically the Urban Airs hed Model (UAM)-BEIS3 model, but also includes modifications to use MM5 data, grid ded land use data, and science updates. The
emission factors that are used in SMOKE-BEIS3 are the same as the emission factors in

UAM-BEIS3.

The basis for the gridded land use data used by BEIS3 is the county land use data in the Biogenic Emissions Landcover Database vers ion 3 (BELD3) provide d by the U.S.EPA. A separate land classification scheme, ba sed upon satellite (AVHRR, 1 km spatialThe Atlanta Eight-Hour Ozone Attainment Demonstration

69 resolution) and census information, aided in defining the forest, ag riculture and urban portions of each county. This emission inventory source sector introduces VOC emissions in a magnitude that exceeds all of the other categories combined.



### 3.5.8 Emission Inventory Summary for Atlanta Nonattainment Area
Daily NOx and VOC emissions during ozone s easons (May-September) are averaged to calculate ozone season daily emissions. In the 20 Atlanta nonattainment counties during 2002, NOx emissions from on-road mobile sour ces are the largest contributing 57% of total NOx emissions, followed by non-road m obile source (19%), point source (19%) and area source (5%) (Figure 3- 3). From 2002 to 2009, NOx emissions from point and onroad mobile sources are reduced by 42% and 33% respectively, leading to a 29% reduction in total NOx emissions. Emissions by source categories in each Atlanta County during both 2002 and 2009 are listed in Figur e 3-3. NOx emissions from mobile source are highest in Fulton, DeKalb, Cobb, and Gwi nnett counties, and such emissions from point source are highest in Bartow, Coweta , and Cobb counties (each of which contain Electric Generating Units). NOx emissions from major point sources in the 20 Atlanta nonattainment counties, including both EGU and non-EGU are listed in Table 3-4 for both 2002 and 2009. The NOx emission from Georgia Power, Bowen Plant is reduced the most by 76% among all facilities. Heavy-duty di esel vehicles and light-duty gas vehicles
contribute 76% of NOx emissions from on -road mobile source category, and their emissions have been reduced by 34% and 50%, respectively, from 2002 to 2009.

VOC emissions from biogenic sources are the largest (contributing 62% of the total VOC emissions) in the 20 Atlanta nonattainment c ounties, followed by area source, on-road and non-road mobile source and point sour ce. VOC emissions are high in DeKalb, Fulton, Gwinnett, and Cobb counties. Total anthropogenic VOC emissions are reduced by 20% in the 20 counties from 2002 to 2009, mainly contributed by emission reduction in on-road and non-road mobile source (29% of reduction) and area sources (10% of reduction). Light-duty gas vehicles have the largest emissions and such emissions have
been controlled the most from 2002 to 2009.The Atlanta Eight-Hour Ozone Attainment Demonstration

NOx Ozone Season Daily Emissions

0 50 100 150 200 250 300 350 400 450

point area onroad nonroad

SourcesEmissions (tpd) 2002 2009

VOC Ozone Season Daily Emissions

0 200 400 600 800 1000 1200 1400

biog point area onroad nonroad

SourcesEmissions (tpd) 2002 2009

Figure 3-3: Ozone season daily NO X and VOC emissions by source categories for 20
counties in Atlanta.

70The Atlanta Eight-Hour Ozone Attainment DemonstrationNOx Ozone Season Daily Emissions140020406080100120Barrow Bartow Carroll Cherokee Clayton Cobb Coweta DeKalb Douglas Fayette Forsyth Fulton Gwinnett Hall Henry Newton Paulding Rockdale Spalding Walton

Emissions (tpd )nonroadonroadareapointVOC Ozone Season Daily Emissions04080120160200Barrow Bartow Carroll Cherokee Clayton Cobb Coweta DeKalb Douglas Fayette Forsyth Fulton Gwinnett Hall Henry Newton Paulding Rockdale Spalding Walton

Emissions (tpd )nonroadonroadareapointFigure 3-4:Ozone season daily NOXand VOC Emissions by source categories andmetro Atlanta 8-hour ozone nonattainmentcounties.71The Atlanta Eight-Hour Ozone Attainment Demonstration

72 

## 4.0 MODEL PERFORMANCE EVALUATION

The performance evaluation of the MM5 me teorological model and CMAQ air quality model is critical for determining if the modeli ng system can be used to accurately predict
future ozone concentrations. The follo wing section describes these evaluations.

4.1 MM5 Model Performance Evaluation

U.S. EPA guidance (EPA, 2007) recognizes the complexity and importance of evaluating meteorological modeling results for air quality applications. Since MM5 algorithms and modules have undergone signifi cant peer review and testing, an “operational” evaluation of the modeling system is sufficient to serve as the basis of evaluating if the system is operating with sufficient reliabi lity to be used in support of SIP development. An operational evaluation can be defined as the process of evaluating how accurately a modeling simulation estimates observed qua ntities. In the case of a prognostic meteorological model, this amounts to a stat istical analysis of model predictions and
surface observations.

The 2002 annual MM5 simulation us ed in this attainment de monstration was performed by VISTAS. The VISTAS MM5 modeling prot ocol and the VISTAS model performance evaluation are contained in Appendix I and Appendix J, respectivel y. Additional model performance evaluations were performed by GA EPD to look at the model performance at Georgia sites. GA EPD used the software package METSTAT developed by ENVIRON corporation for ca lculating model performa nce statistics. METSTAT computes domain wide surface statistics fo r temperature, wind sp eed and direction, and humidity. The metrics include: Bias Error (B ), Gross Error (E) and Root Mean Square Error (RMSE), Systematic Root Mean Square Error (RMSE
s ), Unsystematic Root Mean Square Error (RMSE
u ) and Index Of Agreement (IOA). Mathematical formulation of these variables is provided in Table 4-1. The surface meteorological data for this analysis
was obtained from http://dss.ucar.edu/datasets/ds472.0

.

While reviewing statistics, the reader is cautioned that summary statistics are useful in making only a general assessment about the ad equacy of meteorological fields. For example, daily-mean performance statistics ar e likely to conceal important hour-to-hour variations. Also, summary st atistics depend upon the numbe r of observation-prediction pairs and generally improve with larger sampling sizes and longe r averaging periods. This is because the probability of statistics being affected by extreme values is high in smaller sample sizes. These and other concer ns have lead U.S. EPA to recommend that benchmarks proposed in Table 4-2 (Emery et al ., 2001) should not be used in a “pass/fail” model, but only as a means of a ssessing general confiden ce in meteorological model output.The Atlanta Eight-Hour Ozone Attainment Demonstration

73 A graphical summary of the da ily and hourly mean performan ce statistics for the 12-km grid resolution modeling simu lation is provided in Appe ndix R. Monthly averaged statistics have also been provided in Fi gure 4-1 and Table 4-3. Statistics have been computed at monitoring stations that are located in and around Georgia.The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 4-1: Mathematical Formulation of Statis tical Metrics Used for Evaluating Mesoscale Meteorological Model Performance

Metrics Formulation

Bias 

# ( ) ∑∑

= = − = J

j I

i i j i j OP IJ B

1 1 1

Gross Error 

## ∑∑

= = − = J

j I

i i j i j OP IJ E

1 1 1

Root Mean Square Error 

# ( ) 2/1

1 1 2 1 ⎥ ⎦ ⎤ ⎢ ⎣ ⎡

− = 

## ∑∑

= = J

j I

i i j i j OP IJ RMSE

Systematic Root Mean Square Error 

# ( ) 2/1

1 1 2 ˆ 1 ⎥ ⎦ ⎤ ⎢ ⎣ ⎡

− = 

## ∑∑

= = J

j I

i i j i j S OP IJ RMSE

Unsystematic Root Mean Square Error 

# ( ) 2/1

1 1 2 ˆ 1 ⎥ ⎦ ⎤ ⎢ ⎣ ⎡

− = 

## ∑∑

= = J

j I

i i j i j u PP IJ RMSE

Index of Agreement ⎥ ⎥ ⎥ ⎥

⎦ ⎤

⎢ ⎢ ⎢ ⎢

⎣ ⎡

−+− −= 

## ∑∑

= = J

j I

i o i jo i j MOMP

RMSEIJ IOA

1 1 2

. 1

Table 4-2: Statistical Benchmarks for Mesoscale Meteorological Models

Statistical Measure Benchmark Wind Speed Bias (m/s) < ± 0.5 Wind Speed Total RMSE (m/s) 2.0 Wind Speed Index of Agreement 0.6 Wind Direction Gross Error (degree) 30.0 Wind Direction Bias (degree) < ± 10.0 Temperature Bias (Kelvin) < ± 0.5 Temperature Gross Error (degree) 2.0 Temperature Index of Agreement 0.8 Humidity Bias (g/kg) < ± 1.0 Humidity Gross Error (g/kg) 2.0 Humidity Index of Agreement 0.6

Overall, the simulation is able to captur e meteorological conditions observed during the study period with the adequate level of accur acy. Performance statistics for most days are within the benchmarks proposed by Emery (2001). Monthly average statistics reveal under prediction in humidity from May thro ugh November, and an over prediction in temperature during the summer months (May through September). The simulation tends to over predict day-time and night-time temper ature, and consistently over-predicts nighttime wind speed. However, the magnitude of these under/over predictions remains small. Deficiencies in physical parameterization (p lanetary boundary layer, surface heat, and

74The Atlanta Eight-Hour Ozone Attainment Demonstration

75 moisture budgets) at smaller scales, together w ith the issue of da ta scarcity and representatives might produce verification scor es that do not adequately represent the quality of meteorological mode ling simulation (Mass, 2002). It should also be pointed out that air quality model performance evaluatio n serves as an additional check on how accurately the meteorological model was ab le to capture the observed atmospheric dynamics during a particular time period. In an unlikely event of an unusually poor air quality model performance, it is reasonable to further investigate the performance of meteorological model.

A more detailed description of the meteorol ogical model performance can be found in Appendix R.The Atlanta Eight-Hour Ozone Attainment Demonstration

Monthly Average Temperature Bias

-0.80 -0.60 -0.40 -0.20 0.00 0.20 0.40 0.60

January Feburary Ma r c h Apr il Ma y J u

ne July August September

O

c tober

N

ovem be

r

D

ec

em

berBias (degree K)

Monthly Average Humidity Bias

-1.00 -0.80 -0.60 -0.40 -0.20 0.00 0.20 0.40

J

anu ary

Fe

burary Ma rc

h April Ma y Ju ne July Au gust

S

e p t e mber

O ctober Nov emb er

DecemberBias (g/kg)

Figure 4-1: Monthly average d Bias statistics for 2-m temperature and humidity

76The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 4-3:Monthly averaged statistics for the region of the 12-km modeling domain in and around Georgia.77The Atlanta Eight-Hour Ozone Attainment Demonstration

78 4.2 CMAQ Air Quality M odel Performance Evaluation

The model performance methodology outlined in EPA's modeling guidance (EPA, 2007) is used as a guide for evaluating air quality model performance. EPD has evaluated the model performance of 1-hr and 8-hr averag e ozone concentrations as well as other important precursor concentrations. It shoul d be noted that model performance evaluated against observational data recorded at the finest temporal resolution at which air quality predictions are available (i.e., 1-hour averag e concentrations) provides a more stringent test of the model's ability to replicate polluta nt concentrations comp ared to an evaluation that uses temporal averages (e.g., 8-hour aver age concentrations). EPD believes that the comparison of observed and predicted concentrat ion from the grid cell that "contains" the monitoring station is a more rigorous test (i.e., finest sp atial resolution at which air quality concentrations ar e available) than a test that utilizes predicte d concentrations from "nearby" grid cells. Therefor e, all statistics described below utilize the predicted concentration from the grid cell that "conta ins" the monitoring station. In addition, the model performance evaluation presented here will focuses on the model's ability to capture pollutant dynamics during the episod e. The following sections describe the methodology used in evaluating the adequacy of the air quality model results for regulatory purposes and the results of the model performance evaluation. Summary of evaluation results are presented here for the purpose of brevity and the full model performance statistics and graphics for the 1-hour and 8-hour metric have been provided in Appendix B, C, D, and E. The spatial co verage of the performance evaluation contains
monitors in the 20 nonattainment counties ar ound Atlanta. The te mporal coverage is from May 1, 2002 to September 30, 2002 EST. Since our modeling started April 27, 2002 UTC, our evaluation excluded 3 days and 5 hours in the m odeling outputs as the spin-up periods.



### 4.2.1 Air Quality Modeling Evaluation Methodology

The traditional statistical performance metric s are the Mean Normalized Bias (MNB) and Mean Normalized Gross Error (MNGE). Th ese statistics were estimated for hourly ozone, 8-hour averaged ozone, daily peak hourly ozone, and daily peak 8-hour ozone predictions at the monitoring station. In a ddition, we adopted 10 other statistical metrics for hourly observation-prediction pairs sugge sted by the EPA modeling guidance. The
mathematical formulation of these metric s is provided in Table 4-4. As the EPA modeling guidance recommends, two observa tion based cut-off values (0 ppb and 60 ppb) were used for 1-hr and 8-hr MNB and MNGE. For the 60 ppb cut-off case,
whenever the observation is smaller than the cut-off value, the prediction-observation pair is excluded from the calculation. Fo r daily peak hourly ozone MNB and MNGE, daily peak 8-hour ozone MNB and MNGE, and the 10 additional metrics that were looked at, only a 60 ppb cut-off was used. All metrics were estimated for daily averages over 11 monitoring stations in the 20 counties near Atlanta. Also, the daily MNB and MNGE averaged over the entire evaluation peri od were calculated at each monitor. The EPA guidance recommends no "bright line" perf ormance goals and encourages states to use a "Weight of Evidence" approach to assess the validity of a specific model application and to compare their evaluation re sults with the results from similar modelingThe Atlanta Eight-Hour Ozone Attainment Demonstration

79 exercises. Since the modeling guidance ha s only two evaluation result examples for ozone modeling in its reference modeling exer cises, EPD used the previous 1-hour ozone performance criteria as a reference: ± 5-15% for MNB and 30-35% for MNGE.

The above-mentioned statistical analysis is followed by graphical analyses of daily 8-
hour maximum ozone concentrations to visu alize the predicted ozone fields against observations. Spatial performance analysis was conducted with a series of PAVE tile plots with observations overlaid. This he lps to understand the dynamics of pollutant plumes in the region and helps to diagnose performance issues related to individual monitors. For example, poor model performan ce at a monitoring station might be related to the displacement of a plume due to an error in wind direct ion. In this analysis, the spatial coverage included all monitors in Georgia and some mon itors in neighboring

states.

In addition to the spatial analysis, graphica l analyses were performed at each monitor site. Graphical measures include daily peak concentration bar pl ots of predicted and observed hourly concentrations, time series plot s, and scatter plots. These analyses help to evaluate how well the model replicates th e observed hourly concentration at the same
time and location as the observed value. Pr oblems with diurnal variation in predicted concentrations are readily apparent in a time se ries plot. In these graphical analyses, we extended our spatial coverage to all Georgia m onitors to include monitors outside of the Atlanta 20 county nonattainment area. Since an accurate prediction of ozone precursor species is as important as ozone itself, model performance for nitrogen monoxide (NO), nitrogen dioxide (NO 2 ), carbon monoxide (CO) and sele cted VOC species including isoprene was also conducted. The CB-IV ch emical mechanism used in the modeling, lumps individual VOCs species into modeled VOC species. Often, it is very difficult to properly evaluate the modeled VOCs species because one lumped VOC species represent several individual VOC species. Therefore, this evaluation focuses on explicit species plus some proxy species. Following is th e list of VOCs that were examined: ISOP (isoprene), ETH (ethylene), FORM (forma ldehyde), OLE (double bonds in hydrocarbon), TOL (toluene), XYL (xylen e), CO (carbon monoxide).The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 4-4: Performance Statistics

Metrics Formulation

Mean Normalized Bias (%) 

## ( ) %100 1

1 × − 

# ∑

= N

i Obs Obs Model

N

Mean Normalized Gross Error (%) %100 1

1 × − 

# ∑

= N

i Obs Obs Model

N

Mean Observation (ppb) 

# ∑

= N

i Obs N 1 1

Mean Prediction (ppb) 

# ∑

= N

i Model N 1 1

Ratio of the Means 

# ∑

= N

i Obs Model

N 1 1

Mean Bias (ppb) 

# ∑

= − N

i Obs Model N 1 ) ( 1

Normalized Mean Bias (%) %100 ) (

1 1 × −


# ∑ ∑

=

=
N

i N

i

Obs Obs Model

Mean Fractional Bias (%) %100 ) ( ) (2

1 × ⎟ ⎟ ⎠ ⎞ ⎜ ⎜ ⎝ ⎛

+ − 

# ∑

= N

i Obs Model Obs Model

N

Mean Error (ppb) 

# ∑

= − N

i Obs Model N 1 1

Normalized Mean Error (%) %100

1 1 × −


# ∑ ∑

=

=
N

i N

i

Obs Obs Model

Mean Fractional Error (%) %100 ) ( 2

1 × ⎟ ⎟ ⎠ ⎞ ⎜ ⎜ ⎝ ⎛

+ − 

# ∑

= N

i Obs Model Obs Model

N

Correlation Coefficient 

# ∑ ∑ ∑

= =

=

− − −

−

N

i N

i N

i

ObsObs Model Model ObsObsModel

Model

1 1 2 2 1

)() ( ) )( (

80The Atlanta Eight-Hour Ozone Attainment Demonstration

81 

### 4.2.2 Air Quality Modeling Evaluation Results

A total of 11 monitors ar e located within the 20 c ounties around Atlanta and the maximum number of observation-prediction pa irs to estimate statistical performance measures was 3672 pairs per monitor. The percentage of valid 1-hour ozone observation out of this maximum possible number of pa irs was over 97 % for all monitors and EPD
believes this should be sufficient to make the statistical/graphical ev aluation meaningful.

MNB and MNGE for 8-hour ozone and 1-hou r ozone with 0 ppb and 60 ppb cutoff are
shown in Table 4-5 and Table 4- 6. For quick graphical exam ination, these metrics with a 60 ppb cutoff are also depicted in Figure 4- 2. Time series of daily MNB and MNGE (60 ppb cutoff) averaged over the 11 Atlanta mo nitors are shown in Figure 4-3 through Figure 4-6. During the modeli ng period, the model showed good performance with most days showing MNB less than ± 15% and MNGE less than 30%. Days with poor performance were typically days with low ozone concentrations.

The daily maximum 1-hour and 8-hour ozone is captured reasonably well by the model. As shown in Table 4-7, Figure 4-7(a), and Figure 7(b), th e MNB for the daily maximum 1-hour and daily maximum 8-hour ozone range from [–4.9% to + 5.1%] and [–2.5% to +10.7%] across the 11 Atlanta monitors. The MNGE for daily maximum 1-hour and daily maximum 8-hour ozone range from [ 10.4% to 12.2%] and [ 8.6% to 13.1%] across
the 11 Atlanta monitors. Time series of spatially averaged MNB and MNGE for daily peak 1-hour and 8-hour ozone concentrations are shown in Figure 4-8 through Figure 4- 11. Overall, the model captures daily peak oz one concentrations reasonably well except for a few low ozone days.

Table 4-8 summarizes the additi onal 10 statistical metrics fo r observation-prediction pairs
with observed 8-hour ozone concentrations over 60 ppb. In terms of these additional metrics, the model showed reasonable performa nce at each monitor sites. For example, FBIAS ranged from [-5.3% to 10.6%] and FERROR ranged from [9.9% to 14.5%] across
the 11 Atlanta monitors. Since the Confeder ate Avenue monitor (GA-Fulton-0055) is of particular concern, additional metrics were examined. For example, the RATIO (1.07) and BIAS (-3.3 ppb) is considered to be good model performance. Other metrics were
also close to values found at the other monitors.

All the graphical measures that were examined are included in Appendi x B, C, D, and E. A brief summary of the findings is presen ted here. Since the Confederate Avenue monitor had the highest 2002 design value, th e site-specific summary will focus on this
site.

Figure 4-12 contains an exampl e plot showing the spatial di stribution of modeled ozone
concentrations with observations overlaid. Th is particular day was chosen since June 12, 2002 was the day when the Confederate Ave nue monitor showed its highest ozone
concentrations in 2002. As shown in the fi gure, the simulation captures the high ozone
concentration distribution around Atlanta reasonably well.The Atlanta Eight-Hour Ozone Attainment Demonstration

82 Figure 4-13 is an example of the daily pe ak concentration analyses. Daily peak
concentrations of 8-hour ozone, 1-hour ozone, and NO 2 are listed from top to bottom of Figure 4-13. The x-axis contains monitor site s and all monitors are sorted from west to east to capture any geographical biases in our simulation. The simulation showed good performance at monitors in counties near Atla nta while it showed a noticeably low bias in
ozone at monitors downwind of Fulton and DeKalb counties.

Figure 4-14 is an example of a weekly time se ries plot for hourly ozone concentration at the Confederate Avenue site. In general, the simulation replicat ed the diurnal ozone pattern reasonably well. However, there were hours when the model showed high biases, especially during the nighttime hours. To ex amine possible precursor biases associated with these nighttime ozone biases, we created additiona l time series analyses for precursors species at sites near the Confederate Avenue site.

Figure 4-15 is an example of a monthly scatter plot for 8-hour ozone c oncentrations at the Confederate Avenue site. This plot show s that the model pred icted the higher 8-hour
ozone concentrations in June 2002 reasonably well. The lowe r ozone concentr ations tend to be over-predicted, but these predictions typically occur during the nighttime hours.

Based on the statistics and graphics presen ted in this document and the Appendix, EPD has concluded that the CMAQ modeling used in the attainment demonstration is able to captures the peak 8-hour ozone concentrations and is acceptable for regulatory purposes.

Table 4-5: Mean Normalized Bias and Mean Normalized Gross Error for 8-hour ozone from CMAQ 12km simulations temporally averaged from May 1, 2002 to September 30, 2002 (8-hour O 3 > 0 ppb and 8-hour O 3 > 60 ppb).

8-hour O 3 > 0 ppb 8-hour O 3 > 60 ppb

SITE MNB MNGE Number of
observationprediction pairs used MNB MNGE Number of
observationprediction pairs used

GA-Fulton-0055 95.2 102.6 3636 -4.2 11.0 428

GA-Rockdale-0001 126.8 129.4 3558 -2.3 9.8 419 GA-Douglas-0004 52.8 57.6 3672 -2.6 11.0 559 GA-Fayette-0001 167.5 168.1 3672 12.5 16.1 263

GA-Cobb-0003 97.0 102.5 3672 -2.5 12.9 463

GA-Gwinnett-0002 128.0 132.1 3666 -3.0 10.1 406 GA-Henry-0002 111.1 113.5 3666 -0.2 11.5 373

GA-Coweta-0002 135.1 136.7 3666 0.7 11.7 335

GA-DeKalb-0002 187.4 190.4 3627 0.3 11.1 328

GA-DeKalb-3001 64.0 72.0 3672 -3.1 12.3 436 GA-Paulding-0003 28.7 34.4 3651 -2.1 11.6 576The Atlanta Eight-Hour Ozone Attainment Demonstration

83 Table 4-6: Mean Normalized Bias and Mean Normalized Gross Error for 1-hour ozone from CMAQ 12km simulations temporally averaged from May 1, 2002 to September 30, 2002 (O 3 > 0 ppb and O 3 > 60 ppb).

1-hour O 3 > 0 ppb 1-hour O 3 > 60 ppb

SITE MNB MNGE Number of
observationprediction pairs used MNB MNGE Number of
observationprediction pairs used

GA-Fulton-0055 185.7 200.0 3619 -5.1 14.3 591

GA-Rockdale-0001 247.7 252.6 3549 -4.1 12.4 559 GA-Douglas-0004 99.2 107.1 3641 -3.0 13.6 656 GA-Fayette-0001 300.5 302.4 3643 7.2 13.9 405

GA-Cobb-0003 187.2 196.7 3646 -2.0 15.1 619

GA-Gwinnett-0002 243.4 250.9 3643 -2.5 11.9 616 GA-Henry-0002 225.0 229.6 3641 -1.8 12.4 522

GA-Coweta-0002 261.3 264.6 3645 -0.7 12.7 507

GA-DeKalb-0002 349.2 356.9 3597 -1.0 13.3 501

GA-DeKalb-3001 122.3 136.7 3645 -2.1 14.2 616 GA-Paulding-0003 38.7 46.7 3625 -3.3 13.4 643

Table 4-7: Mean Normalized Bias and Mean Normalized Gross Error of daily maximum 1-hour ozone from CMAQ 12km simulations temporally averaged from May 1, 2002 to September 30, 2002 (1-hour O 3 > 60 ppb and 8-hour O 3 > 60 ppb).

1-hour O 3 > 60 ppb 8-hour O 3 > 60 ppb

SITE MNB MNGE MNB MNGE

GA-Fulton-0055 -1.8 11.4 -2.5 9.1

GA-Rockdale-0001 -4.6 11.6 -2.4 9.2 GA-Douglas-0004 -2.0 12.1 0.2 9.4 GA-Fayette-0001 5.6 11.0 10.7 13.1

GA-Cobb-0003 0.2 11.7 0.7 11.0

GA-Gwinnett-0002 0.7 10.5 -0.6 8.6 GA-Henry-0002 -2.9 10.9 0.0 10.0

GA-Coweta-0002 -0.4 12.2 2.0 11.6

GA-DeKalb-0002 0.5 10.4 1.9 9.4

GA-DeKalb-3001 -0.4 10.4 1.1 9.9 GA-Paulding-0003 -4.9 11.6 -1.1 9.4The Atlanta Eight-Hour Ozone Attainment Demonstration

84 Table 4-8: Mean Observation (MO), Mean Prediction (MP), Ratio of the Means (RATIO), Mean Bias (BIAS), Normalized Mean Bias (NMB), Mean Fractional Bias

(FBIAS), Mean Error (ERR), Normalized Mean Error (NME), Mean Fractional Error (FERROR), and Correlation Coeffici ent (r) of 8-hour ozone from CMAQ 12km simulation temporally averaged from May 1, 2002 to September 30, 2002 (8-
hour O 3 > 60 ppb).

SITE MO MP RATIO BIAS NMB FBIAS ERR NME FERROR r

GA-Fulton-0055 73.2 70.0 1.07 -3.3 -4.5 -5.3 8.0 11.0 11.6 0.48

GA-Rockdale-0001 72.7 70.7 1.04 -2.0 -2.8 -3.0 7.1 9.8 9.9 0.49 GA-Douglas-0004 73.7 71.4 1.05 -2.2 -3.0 -3.6 8.1 11.0 11.3 0.37 GA-Fayette-0001 70.3 79.0 0.91 8.8 12.5 10.6 11.3 16.1 14.5 0.43

GA-Cobb-0003 72.7 70.6 1.05 -2.2 -3.0 -3.9 9.2 12.7 13.2 0.31

GA-Gwinnett-0002 69.9 67.6 1.05 -2.3 -3.3 -3.8 7.0 10.0 10.4 0.30 GA-Henry-0002 72.9 72.5 1.02 -0.4 -0.6 -1.3 8.4 11.5 11.6 0.50

GA-Coweta-0002 71.7 71.5 1.01 -0.2 -0.2 -0.3 8.4 11.8 11.6 0.22

GA-DeKalb-0002 71.8 71.9 1.02 0.1 0.1 -0.7 7.8 10.9 11.0 0.43

GA-DeKalb-3001 71.6 69.1 1.06 -2.5 -3.5 -4.5 8.8 12.2 12.8 0.27 GA-Paulding-0003 72.6 70.6 1.05 -2.0 -2.7 -3.3 8.5 11.6 12.0 0.30The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-2(a):Mean Normalized Bias for 1-hour and 8-hour ozone concentrations of CMAQ 12 km simulation at 11 monitor sites in 20counties around Atlanta.85The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-2(b): Mean Normalized Gross Errorfor 1-hour and 8-hour ozone concentrations of CMAQ 12 km simulation at 11 monitor sites in20 counties around Atlanta.86The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-3: Daily Mean Normalized Bias over 20 counties around Atlanta for observed 1-hour O3> 60 ppb.MO stands for mean observation. Red dashline indicates performance reference,±15 %.87The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-4: Daily Mean Normalized Gross Error over 20 counties around Atlanta for observed 1-hour O3> 60 ppb.MO stands for mean observation. Red dashline indicates performance reference,±35 %.88The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-5: Daily Mean Normalized Bias over 20 counties around Atlanta for observed 8-hour O3> 60 ppb.MO stands for mean observation.89The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-6: Daily Mean Normalized Gross Error over 20 counties around Atlanta for observed 8-hour O3> 60 ppb.MO stands for mean observation.90The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-7(a): Mean Normalized Bias for dailymaximum 1-hour and 8-hour ozone concentrations of CMAQ 12 km simulation at 11 monitorsites in 20 counties around Atlanta.91The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-7(b): Mean Normalized Gross Error for daily maximum 1-hour and 8-hour ozoneconcentrations of CMAQ 12 km simulation at11monitor sites in 20 counties around Atlanta.92The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-8: Daily Mean NormalizedBias over 20 counties around Atlanta for daily maximum 1-hour O3(paired in space).MO stands for mean observation.93The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-9: Daily Mean NormalizedGross Error over 20 counties aroundAtlanta for daily maximum 1-hour O3(paired in space).MO stands for mean observation.94The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-10: Daily Mean Normalized Bias over 20counties around Atlanta for daily maximum 8-hour O3(paired in space).MO stands for mean observation.95The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-11: Daily Mean Normalized Gross Error over20 counties around Atlanta for daily maximum 8-hour O3(paired in space).MO stands for mean observation.96The Atlanta Eight-Hour Ozone Attainment Demonstration

Confederate

Avenue
Monitor

Figure 4-12: Tile plot of daily 8-hour ma ximum ozone concentrations on June 12, 2002.

97The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-13(a): Bar plots for daily maximum concentrations of 8-hour ozone.All monitors were sorted from west to east to capture any spatial biases. Red bars indicate observed concentrations and blue barsindicate predicted concentrations. Data points for this figure were sampled from 6 AM to 5 PM on June 12, 2002.98The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-13(b): Bar plots for daily maximum concentrations of 1-hour ozone.All monitors were sorted from west to east to capture any spatial biases. Red bars indicate observed concentrations and blue barsindicate predicted concentrations. Data points for this figure were sampled from 6 AM to 5 PM on June 12, 2002.99The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-13(c): Bar plots for daily maximumconcentrations of nitrogen dioxides.All monitors were sorted from west to east to capture any spatial biases. Red bars indicate observed concentrations and blue barsindicate predicted concentrations. Data points for this figure were sampled from 6 AM to 5 PM on June 12, 2002.100The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 4-14: Weekly time series plot for hourly ozone concentration at the Confederate Avenue site.The red line represent observed ozone concentrations and the blue line representsthe modeled ozone concentrations. The x-axisshows hours from midnight of June 10, 2002 (Monday) to midnight of June 17, 2002 (Monday).101The Atlanta Eight-Hour Ozone Attainment Demonstration

Figure 4-15: Scatter plot of 8- hour ozone concentrations at the Confederate Avenue site. Data points are from observed and modele d 8-hour concentra tions in June 2002.

102The Atlanta Eight-Hour Ozone Attainment Demonstration

103 

## 5.0 CONTROLS APPLIED

This chapter presents an analysis of NOx and VOC emissions control measures
considered in this atta inment demonstration. As discusse d in Chapter 3, ozone precursors of VOC and NOx can come from man-made (a nthropogenic) sources as well as naturally occurring sources. Significan t reductions in man-made sources of VOC and NOx were achieved via state and federal regulatory and vol untary control measures for attainment of the 1-hour ozone NAAQS. This set of existin g requirements and voluntary efforts served as the basis for considering further control measures.

Since the metro Atlanta region is also de signated nonattainment for the federal PM2.5 standards, control strategies for PM2.5 a nd the 8-hour ozone NAAQS will be integrated and harmonized to the extent possible.

Attaining the federal 8-hour oz one NAAQS will require the involvement of all sectors of Georgia's economy and populati on. Tables 5-1 and 5-2 su mmarize NOx emissions for the 20 county nonattainment area for the ba se year of 2002 and future year 2009.

Table 5-1: NOx Emissions for 20 Count y Nonattainment Area – Part 1

2002 2009 Inventory Category tpd % of total tpd % of total

Point 119.31 17.7 69.47 15.2

Area 33.85 5.0 35.07 7.7

On-Road 405.06 60.1 250.43 54.7

Non-Road 116.23 17.3 103.25 22.5

Table 5-2: NOx Emissions for 20 Co unty Nonattainment Area – Part 2

2002 (tpd) 2009 (tpd) Inventory Category SubCategory

(See table 3-6 for acronyms) Category Contributions
from subcategory Category Contributions
from subcategory
On-Road 405.06 250.43

HDDV 213.79 121.25

LDGV 80.01 37.01

LDGT 1&2 55.21 52.35

HDGV 29.98 16.02

LDGT 3&4 24.36 22.57

LDGM 0.90 0.94

LDDT 0.61 0.25

LDDV 0.20 0.04

Point 119.31 69.47

EGUs 104.13 58.02

Non-EGUs 15.18 11.45The Atlanta Eight-Hour Ozone Attainment Demonstration

104 Tables 5-3 and 5-4 summarize anthropoge nic VOC emissions for the 20 county nonattainment area for the base year of 2002 and future year 2009.

Table 5-3: VOC Emissi ons for 20 County Nonattainment Area – Part 1

2002 2009 Inventory Category tpd % of total Tpd % of total

Point 20.86 3.4 19.41 4

Area 251.69 41.2 232.7 47

On-Road 219.98 36.0 153.33 31

Non-Road 118.03 19.4 85.46 18

Table 5-4: VOC Emissions from for 20 County Nonattainment Area – Part 2

2002 (tpd) 2009 (tpd) Inventory Category SubCategory

(See table 3-6 for acronyms) Category Contribution
from subcategory Category Contribution
from subcategory
Area 251.69 232.7

On-Road 219.98 153.33

LD Gas Veh 100.81 51.00

LDGT 1 &2 78.58 70.65

LDGT 3&4 21.73 18.04

HDDV 8.58 6.39

HDGV 7.73 4.93

LDGM 2.11 2.17

LDDT 0.35 0.14

LDDV 0.09 0.02

This control measures analysis focuses on id entifying possible modifications to existing control measures (i.e., 2002 ba se year emissions) in order to help the metro Atlanta area attain the ozone standard by June 15, 2010. This analysis draws heavily on the RACT analysis described in Chapter 10.

5.1 Control Measures Analyses for St ationary Point and Area Sources
The federal government has promulgated regulations, in accordance with Clean Air Act requirements, to reduce emissions of NOx and VOC from stati onary point and area sources. In most cases Georgia EPD has been granted delegation of authority to implement and enforce such regulations for stationary sources.

The legal authority to regulate NOx and VOC emissions from stationary point and area sources comes from sections 111, 112, 172(c), 1 82(a), 182(b)(2), and 18 2(f) of the CAA.
Section 111 emission standards are referred to as New Source Performance Standards [NSPSs] and Georgia EPD has been delegated au thority to implement and enforce such standards per Georgia Rule 391-3-1-.02(8). The NSPSs specify emission standards and/or work practice standards from e quipment whose date of construction (or manufacture) meets the specific timelines for most criteria air pol lutants including VOC
and NOx. Section 112 es tablishes, in part, National Emission Standards for HazardousThe Atlanta Eight-Hour Ozone Attainment Demonstration

105 Air Pollutants [NESHAPs] and Georgia EPD has been dele gated authority to implement and enforce such standards per Georgia Ru le 391-3-1-.02(9) for major sources of hazardous air pollutants [HAPs]. EPA has promulgated NESHAPs for area sources. Georgia EPD has taken delegation of some of these standards. Decisions are still pending as to who, Georgia EPD or U.S. EPA, will implement and enforce the remaining
standards. The Section 112 standards c over HAPs and many VOCs are also HAPs.

Sections 172(c), 182(a), 182(b)(2), and 182( f) require implementation of control measures that satisfy Reasonably Available Control Measures [RACM] and Reasonably Available Control Technology requirements for VOC and NOx emissions. Control measures for VOC and NOx emissions that satisfy these requirements are promulgated in Georgia Rule 391-3-1-.02(2). Chapter 10 provides a detailed discussion of the relationship between provisions in Georgia Rule 391-3-1-.02(2) an d sections 172(c), 182(a), 182(b)(2), and 182(f).

VOC emission limitation and standard provisi ons in Georgia Rule 391-3-1-.02(2) are
established for various indus try sectors and consist of emission limits, work practice standards, compliant coating limits, and/or air pollution control requirements. The majority of these provisions apply stat ewide based on county-specific VOC emission thresholds. The VOC provisions that do not a pply statewide apply in the 20 counties that make up the metro Atlanta non-attainment area. These VOC provisions apply yearround.

Table 5-5: Georgia Rule 391-3-1-.02(2) Stationary Source VOC Standards for Point, Area, and Mobile Sources

Subparagraph Category Industry Sector Is this sector
included in 2002

Base Year Inventory? (t) Surface Coating Automobile and LightDuty Truck Mfg Yes – Point

(u) Surface Coating Can Coating Yes – Point

Yes-Area (v) Surface Coating Coil Coating Yes – Point

Yes-Area (w) Surface Coating Paper Coating Yes – Point

Yes-Area (x) Surface Coating Fabric Vinyl Coating Yes – Point (y) Surface Coating Metal Furniture Coating Yes – Point

Yes-Area (z) Surface Coating Large Appliance Surface Coating Yes-Area

(aa) Surface Coating Wire Coating No (bb) Petroleum Liquid Storage Yes – Point

Yes-Area (cc) Bulk Gasoline Terminals Yes-Area (dd) Cutback Asphalt NoThe Atlanta Eight-Hour Ozone Attainment Demonstration

106 Subparagraph Category Industry Sector Is this sector
included in 2002

Base Year Inventory? (ee) Refinery Petroleum Refinery No (ff) Degreasing Solvent Metal Cleaning Yes – Point

Yes-Area (hh) Refinery Petroleum Refinery Equipment Leaks No

(ii) Surface Coating Miscellaneous Metal Parts
and Products Yes – Point

(jj) Surface Coating Flat Wood Paneling No (kk) Pharmaceutical Synthesized Pharmaceutical Mfg Yes-Area

(ll) Surface Coating Manufacture of Pneumatic
Rubber Tires Yes – Point

(mm) Printing Graphic Arts Systems Yes – Point

Yes-Area (nn) Storage Tanks External Floating Roof
Tanks Yes – Point

(pp) Bulk Terminals Bulk Gasoline Plants No (qq) Dry Cleaning Large Petroleum Dry
Cleaners Yes-Area

(rr) Gasoline Dispensing Gasoline Dispensing Facility – Stage I Yes-Area

(ss) Gasoline Transport Gasoline Transport Vehicles and Vapor Collection Systems Yes – Point

(tt) NA Case-by-Case for Major

Sources No

(vv) Breathing Losses Volatile Organic Liquid Handling and Storage Yes – Point

(zz) Gasoline Dispensing Gasoline Dispensing Facilities – Stage II Yes – Point

(aaa) Windshield Wiper
Fluid Consumer and Commercial
Products No

(bbb) Gasoline Marketing No (ccc) General-Industry Bulk Mixing Tanks No (ddd) Printing Offset Lithography Yes – Point (eee) Polystyrene
Production Expanded Polystyrene Products Mfg Yes – Point

(hhh) Surface Coating Wood Furniture Finishing and Cleaning Operations Yes-Area

(kkk) Surface Coating Aerospace Mfg and
Rework Facilities Yes – PointThe Atlanta Eight-Hour Ozone Attainment Demonstration

107 NOx emission limitation and standard provis ions in Georgia Rule 391-3-1-.02(2) are
established for various external and internal combustion devices and consist of emission standards and work practice re quirements. All of these pr ovisions, except for Rules 391- 3-1-.02(2)(yy) and (rrr) already applied to th e 20-county 8-hour ozone metro Atlanta area in 2002. Applicability of Rules (yy) and (r rr) were expanded from 19 (all but Barrow County) to all 20 nonattainment counties in 2008. Coal-fired external combustion devices that generate steam for electricity generation are regulated under Georgia Rule 391-3-1-.02(2)(jjj) for NOx emissions. These de vices are also classified as “affected units” under regional control measur es discussed later in this ch apter. Georgia Rule (jjj) establishes a more stringent NOx emissi on standard beginning May 1, 2003. Georgia
EPD estimated that NOx emissions from point sources would be reduced by approximately 42% as a whole between 2002 and 2009. As illustrated earlier, the majority of NOx emissions from point s ources comes from coal-fired external combustion devices that generate steam for el ectricity generation. There are three such plants in the 20-county metro Atla nta area under analysis and 4 su ch plants near this area. The plant in Cobb County [i.e., Georgia Po wer Plant McDonough] will be converted to a natural gas combined-cycle plant which will re sult in a major decrease in NOx emissions.

Table 5-6: Georgia Rule 391-3-1-.02(2) Stationary Source NOx Standards for Point
and Area Sources

Subparagraph Category Industry Sector Is this sector
included in 2002

Base Year Inventory? (yy) Case-by-Case RACT for Major Sources No

(jjj) Electricity
Generation Electric Utility Steam Generating Units Yes-Point

(lll) Fuel-Burning Fuel-Bur ning Equipment Yes-Point

Yes-Area (mmm) Electricity
Generation Stationary Gas Turbines and Stationary Engines
Used to Generate Electricity Yes – Point

Yes - Area

(nnn) Electricity
Generation Large Stationary Gas
Turbines Yes-Point

(rrr) Fuel-Burning Small Fuel-Burning Equipment Yes - Area

EPD had determined that several large point sources were signifi cant contributors and
that additional controls and NOx reductions were deemed available. The negotiated controls and associated NOx reductions are sp ecified for the following facilities in their Title V air quality permits.The Atlanta Eight-Hour Ozone Attainment Demonstration

108 Table 5-7: Specific Large Point Source Control Measure – Lafarge Building Materials, Inc.

Plant Name and Location AIRS No.

Lafarge Building Materials, Inc. – Atlanta Plant (formerly Blue Circle Cement) Atlanta (Fulton County) 04-13-121-00401

Effective May 1, 2003, in addition to any existing emission limits which apply to Rotary Kiln No. 1 (Source Code EU303), the Pe rmittee shall comply with the limits on emissions of nitrogen oxides (NOx) in th e following table during the period May 1 through September 30 of each year:

NOx Emission Limit During Which No Clinker is Produced for Special Products (tires continuously injected into kiln) = 235 lb/hr rollin g 30-day average

NOx Emission Limit During Which Clinker is Produced for Special Products (no tires injected into kiln) = 268 lb /hr rolling 30-day average

The averaging periods shall consist of thirty consecutive operating days.

CONDITION: Effective May 1, 2003, during th e period May 1 through September 30 of each year:

• Except as provided below, the Permittee shall burn tires, as supplemental fuel, in kiln
No. 1 at all times that th e kiln is in operation.

• While the kiln is in operation, periods duri ng which tires are not burned in kiln No. 1 shall not exceed 10 days per 30-day averaging period. The averaging periods shall consist of thirty cons ecutive operating days.

Lafarge Building Materials has ceased to operate as of December 31, 2006 and is reflected in the 2009 inventory.

Table 5-8: Specific Large Point Sou rce Control Measure – Transco Compressor
Station 120

Plant Name and Location AIRS No.

Transco Compressor Station 120 Stockbridge (Henry County) 04-13-151-00025

Their Title V Permit specifies an ozone season NOx limit, effective May 1, 2003, of 6.0 grams per horsepower-hour for all fifteen of its mainline internal combustion engines (Source Codes: ML01, ML02, ML03, ML04, ML05, ML06, ML07, ML08, ML09, ML10, ML11, ML12, ML13, ML14, and ML15).The Atlanta Eight-Hour Ozone Attainment Demonstration

109 Table 5-9: Specific Large Point Source Control Measure – Caraustar Industries,

Inc.

Plant Name and Location AIRS No.

Caraustar Industries, Inc. (formerly Austell Box Board) Austell (Cobb County) 04-13-067-00022

CONDITION: The Permittee shall not disc harge or cause the discharge into the atmosphere from the Coal-Fired Boiler (S ource Code: CB01), any gases which contain NOx emissions in excess of the following:

• 0.38 pounds NOx per million BTU heat input during the period from May 1 through September 30 of each year, determined on a thirty day rolling average.

• Compliance date was as early as 1999.

NOx emissions have been reduced because the Acid Rain Program set NOx emission standards for certain coal-fired utility boile rs across the U.S., incl uding Georgia. The Acid Rain NOx program was implemented in two phases, beginning in 1996 and 2000. Phase I of the NOx program began on January 1, 1996 and applied to two types of boilers (which were already targeted for Phase I SO 2 reductions): dry-bot tom wall-fired boilers and tangentially fired boilers. Dry-bottom wall-fired boilers had to meet a limitation of 0.50 pounds of NOx per million BTU averaged over the year, and tangentially fired
boilers had to achieve a limitation of 0.45 pounds of NOx per million BTU, again, averaged over the year.

Phase II of the NOx program began in 2000. These regulations:

• Set lower emission limits for Group 1 boilers first subject to an acid rain emissions limitation in Phase II, and

• Established initial NOx emission limitati ons for Group 2 boilers, which include boilers applying cell-burner technology, cy clone boilers, wet bottom boilers, and other types of co al-fired boilers.

Most of the affected units in Georgia were also subject to a state NOx emission standard (Georgia Rule 391-3-1-.02(2)(jjj)) which in some cases imposed a more stringent NOx emission standard during the same time frame.

Regional transport of NOx and VOC emissions (and ozone) contribute to a certain degree to the ozone problem in the metro Atlanta area. Regional transport [a.k.a. interstate transport] is covered under section 110(a)(2)(D) of the CA A. The NOx SIP Call is a NOx budget trading program using a market-b ased cap and trade program created to reduce emissions of nitrogen oxides (NOx) from power plants and other large combustion
sources in the eastern United States in an e ffort to mitigate significant transport of NO

x from those affected facilities that contribute to ozone nonattain ment areas in other states. EPA has promulgated these control measures to address ozone season NOx emissions in 40 CFR Part 96 Subpart A through I. The NOx SI P Call control measures aided states in addressing interstate transpor t under the 1-hour ozone NAAQS. Georgia is not subject to the NOx SIP Call; however, upwind areas outside of the state are subject to these controlThe Atlanta Eight-Hour Ozone Attainment Demonstration

110 measures. Georgia EPD included NOx SIP Call control measures in upwind areas (located out of the stat e) in its ozone modeling.

EPA adopted the Clean Air Interstate Rule (CAIR) in order to reduce interstate transport of ozone and PM2.5 precursors from states th at significantly contri buted to downwind 8-
hour ozone and PM2.5 nonattainment areas. CAIR is a market-based cap and trade program that consisted of both a seasonal NO x program (for states that significantly
contributed to downwind 8-hour ozone nonatt ainment areas) and annual NOx and SO2 program (for states that significantly contributed to PM2.5 nonattainment areas. The seasonal NOx program replaced the NOx SIP Call. EPA promulgated CAIR control
measures to address annual NOx emissions in 40 CFR Part 96. EPA required that Georgia submit a CAA Section 110 (a)(2)(D)(i) [referred to as "interstate transport"] SIP
revision to address its need to eliminate significant contribution to North Carolina and other applicable downwind states [and/or its need to eliminate interference] as it relates to the new PM2.5 NAAQS. EPD submitted this SIP revision to EP A on March 30, 2007, and in this SIP revision EPD adopted by refe renced (with allowed flexibility) the CAIR Rule (40 CFR Part 96 Subparts AA-II for NOx Program and 40 CFR Parts 96 Subparts
AAA-III for SO 2 Program) as the control strategy for eliminating significant contribution to applicable downwind states as it relates to the PM2.5 NAAQS. One aspect of this control strategy is the need to meet a stat e annual NOx allowance via a nation-wide capand-trade program.

The CAIR Rule will require certain stat es, whose ozone season NOx emissions are
considered to significantly contribute to the 8-hour ozone attainment problem in Atlanta,
to reduce their ozone season NOx emissions. Georgia is not subject to the seasonal NOx program, but compliance by affected units in Georgia with the annual NOx allowance for the PM2.5 NAAQS should also co ntribute to reductions in lo cal emissions of NOx during
the ozone season.

The CAIR applies to (1) any stationary, fossil- fuel-fired boiler or st ationary, fossil-fuelfired combustion turbine servi ng at any time, since the st art-up of a unit's combustion chamber, a generator with a nameplate capacity of more than 25 MWe producing electricity for sale and (2) for a unit that qualifies as a cogenera tion unit during the 12- month period starting on the date that the un it first produces electrici ty and continues to qualify as a cogeneration unit, a cogeneration unit serving at any time a generator with nameplate capacity of more than 25 MWe a nd supplying in any calendar year more than one-third of the unit's potential electric output capacity of 219,000 MWh, whichever is greater, to any utility power distribution system for sale.

This rule provide annual state caps for NOx a nd SO2 in two phases, with the Phase I caps for NOx and SO2 starting in 2009 and 2010, respectively. Phase II caps become effective in 2015. The U.S.EPA is allowing th e caps to be met through a cap and trade program if a state so chooses to participate in the program.

Georgia EPD included local and upwind CAIR control measures in its ozone modeling. Georgia EPD implements the CAIR rule in Georgia Rules 391-3-1-.02(12) and 391-3-1- .02(13).The Atlanta Eight-Hour Ozone Attainment Demonstration

111 5.2 Control Measures Analyses for On-Road Mobile Sources

On-road mobile sources in the metro Atlant a account for the larges t percent of NOx and anthropogenic VOC emissions. Air pollution fr om cars and light-duty trucks comes from by-products of the combustion process (exhaust) and from evaporation of the fuel itself. Hydrocarbon pollutants escape into the air through fuel evaporation. With today’s
efficient exhaust emission controls and toda y’s gasoline formulations, evaporative losses can account for a majority of the total hydrocarbon pollution from current model cars on hot days when ozone levels are highest. Evaporative emissions occur several ways:

• Diurnal: Gasoline evaporation increases as the temperature rises during the day, heating the fuel tank and venting gasoline vapors.

• Running Losses: The hot engine and exha ust system can vaporize gasoline when the car is running.

• Hot Soak: The engine remains hot for a period of time after the car is turned off, and gasoline evaporation continues when the car is parked.

• Refueling: Gasoline vapors are always present in fuel tanks. These vapors are forced out when the tank is filled with liquid fuel.

The federal government has promulgated regulations, in accordance with Clean Air Act requirements, to reduce emissions of NOx and VOC from on-road mobile sources. States (other than California) are pre-empted from implementing and enforcing these regulation. In addition, this preemption also prevents st ates from implementing and enforcing more stringent standards or regulating the operation of on-road sources.

The 1990 Clean Air Act Amendments further reduce vehicle emissions. Mobile source provisions include even tighter tailpipe standards, increas ed durability, improved control of evaporative emissions, and computerized diagnostic systems that identify malfunctioning emission controls.

Table 5-10: Federal Control Measu res for On-Road Mobile Sources

Statutory Requirement Federal Regulation Description of Control

Measure
Sections 182(b)(3) and 202(a)(6) 40 CFR Part 86 New Vehicle On-Board Vapor Recovery System

Title II Part A – Sections 202 through 219 that pertain
to on-road mobile sources. Includes certain portions of
40 CFR Parts 85 and 86. Motor Vehicle Emission
and Fuel Standards:

Includes Tier 0, 1, and 2
emission standards. Tier 2 standards begin 2004.

Includes RVP requirements;

Includes fuel sulfur content requirementsThe Atlanta Eight-Hour Ozone Attainment Demonstration

112 Table 5-10: Federal Control Measu res for On-Road Mobile Sources

Statutory Requirement Federal Regulation Description of Control

Measure

Includes lead substitute gasoline additives

Section 211(l) 40 CFR Part 86 S ubpart G Regulation of Fuels – Detergents.

Table 5-11: State Authorit y to Implement Federal Control Measures for On-Road
Mobile Sources

Statutory Requirement State Rule Description of Control

Measure

Title II Part A 391-3-20 Rules for Enhanced Inspection and Maintenance

Title II Part A 391-3-22 Cl ean Fuel Fleet Program

Title II Part A 391-3-1-.02(2) Heavy-Duty Diesel Engine Requirements

Tighter Tailpipe Standards: Tighter tailpipe standard s for total hydrocarbons, carbon monoxide and NOx were phased in by the 1996 model year fleet. U.S. EPA determined
that lower standards were warranted in 1999 and the U.S. EPA further tightened the tailpipe standards beginning with the 2004 model year vehicl es. Because of continued growth in the number of vehicles and miles traveled, tailpipe emissions from conventional gasoline engines will eventually begin to increase despite improvements in emission control systems, unless EPA adopts tig hter tailpipe standards for future model

years.

Evaporating Gasoline: As a complement to stricter tailpipe standards, the U.S.EPA has introduced programs to minimize air pollution from evaporating gasoline. Evaporative emissions are a major source of the hydro carbon compounds that form ground-level
ozone. To that end the U.S.EPA has esta blished more stringent limits on gasoline volatility and the control of hydrocarbon vapor s that evaporate during vehicle refueling.

For example, Section 182(b)(3) of the CAA requires moderate areas to implement Stage II gasoline vapor recovery systems unless and until the U.S.EPA promulgates an onboard

vapor recovery system regulation. On January 24, 1994 EPA promulgated the onboard rule. As section 202(a)(6) of the CAA provi des that once the rule is promulgated, moderate areas are no longer required to implement Stage II. Thus, the Stage II vapor recovery requirement is not an appli cable requirement for the Atlanta ozone nonattainment area. This measure required the installation of onboard refueling emissions controls for new passenger cars a nd light trucks beginning in the 1998 model year. The onboard refueling vapor recovery (ORVR) system was required for new passenger cars and light trucks beginning in model year 1998.The Atlanta Eight-Hour Ozone Attainment Demonstration

113 Gasoline Deposit Control Program: The accumulation of deposits in the engine and fuel supply systems of gasoline motor vehicles can significantly increase emissions of NOx, hydrocarbons, and carbon monoxide. Pursuant to the requirements of Section 211(l) of the CAA, EPA implemented a gasoline deposi t control program which requires that all gasoline sold for use in motor vehicles in th e US contain additives that are effective in limiting the formation of such deposits. Spec ifically, EPA requires that deposit control additives be certified for their ability to c ontrol fuel injector deposits and intake valve deposits in EPA-specified test procedures. Section 211(l) of the CAA requires that, by January 1, 1995, all gasoline must contain detergent additives to prevent the accumulation of deposits in motor vehicle engi nes and fuel supply systems. This CAA section also requires EPA to promulgate sp ecifications for the detergent additives. Detergent additives prevent the accumulation of engine and fuel supply system deposits
that have adverse effects on vehicle emissions as well as on fuel economy and drivability.

In response to section 211(l)'s requirements, EPA published a Notice of Proposed Rulemaking (NPRM) on December 6, 1993 (59 FR 64213) proposing a detergent additives regulatory program. The detergent program was finalized in two parts. Final regulations for the interim detergent program, requiring the use of de tergent additives in gasoline but not mandating spec ific detergent efficiency testing,, were published on October 14, 1994 (59 FR 54678). Final regula tions for the detergent certification program, mandating the use of certified deterg ents with specified detergent efficiency testing, were published on July 5, 1996 (61 FR 3 5310) with an effectiv e date of August 1,
1997.

Reformulated Gasoline: By 1995, all gasoline sold in the country’s wo rst ozone areas were required to meet reformulation spec ifications. EPA estimated that using reformulated gasoline would result in reduct ions in hydrocarbon and air toxic emissions
as well as NOx emissions. Reformulated gasoline is currently not required for the
Atlanta ozone nonattainment area.

Inspection and Maintenance: Georgia EPD is implementing an Enhanced Motor Vehicle Inspection and Maintenance Program in acco rdance with Georgia Rule 391-3-20 in the 13 counties that make up the former 1-hour ozone Atlanta nonattainment area. This action is being taken under section 110 of the CAA and section 348 of the National Highway Systems Designation Act. Georgi a’s 13-county Inspection and Maintenance Program satisfies the Inspection and Mainte nance requirement for the 20-county ozone
nonattainment area.

Clean Fuel Fleet Program: Georgia EPD is implementing this program in accordance with the Clean Air Act; however, this pr ogram no longer provides emission reductions
because the current fleets in use must meet stricter tailpipe standards via 40 CFR Part 86.

Heavy-Duty Diesel Engine Requirements: These specifications are established in Georgia Rule 391-3-1-.02(2)(ooo). This rule requires heavy duty dies el engines (vehicle weight of 14001 lbs or more) to meet the Californi a Air Resources Board (CARB) emissions standards by 2005. These standa rds are essentially the same as the federal heavy duty engine standards (40 CFR 86, Subpart A) described in th e federal control measuresThe Atlanta Eight-Hour Ozone Attainment Demonstration

114 section. The CARB heavy duty diesel engine st andards were adopted to ensure that the
emission reductions would be achieved in the event that U.S. EPA relaxed the federal requirements and did not require 2005 and 2006 model year engines to meet the Not-ToExceed (NTE) test requirements. The CARB standards and Georgia’s rule (ooo) were promulgated prior to the federal standards. The rule was expected to reduce NOx by 13 tons per day statewide and 8 tons per day in the 45 county Atlanta oz one control area in
2005. These emissions benefits would potentially have doubled in 2006 if the
manufacturers continued to not meet the N TE test requirements. Manufacturers were required federally to begin testing the engi nes to the NTE requirements with the 2007 model year. Georgia has kept the CARB standard s in place to prevent a delay in the state receiving cleaner engines in the event that EP A were to relax or delay the federal 2007 or 2010 engine standards. Also, the CARB engine requirements differ from EPA’s in that CARB requires a 5 minute idle shutdown or th e use of a clean-idle engine beginning with the 2008 model year. The benefit of this 5-mi nute idle limit has not been quantified for Georgia. However, it is expected to reduce NOx and PM emissions.

5.3 Control Measures Analyses for Off-Road Mobile Sources
The off-road (or nonroad) category covers a diverse collection of engines, equipment, vehicles, and vessels. Examples of o ff-road equipment include outdoor power equipment, recreational vehicles, farm an d construction machinery, lawn and garden equipment, marine vessels, and locomotives . Until the mid-1990s, emissions from these engines were largely uncontrolled according to the U.S.EPA. The 1990 amendments to
the Clean Air Act directed the U.S.EPA to study the contribution of nonroad engines to urban air pollution, and regulate them if they contributed to air quality problems. In 1991, the U.S.EPA published a report showing that nonroad equipment emitted large amounts of NOx, hydrocarbons, carbon monoxide and particulate matter. In general, the U.S.EPA noted that nonroad engines had to tal emissions almost as high as highway motor vehicles. In addition, di esel particulate matter emissi ons were significantly higher from nonroad equipment than from highway emissions. In response, the U.S.EPA adopted emissions standards for most categor ies of new nonroad engines, and these are specified in Table 5-12.

The federal government has promulgated regulations, in accordance with Clean Air Act requirements, to reduce emissions of NOx and VOC from off-road mobile sources. States (other than California) are pre-em pted from implementing and enforcing these regulations. In addition, this pre-emption also prevents states from implementing and enforcing more stringent standards or regul ate the operation of off-road sources.

Table 5-12: Federal Control Measu res for On-Road Mobile Sources

Statutory Requirement Federal Regulation Description of Control

Measure

Section 231 40 CFR Part 87 Ai rcraft Engine Standards Effective 1974 through
2005

Section 213 40 CFR Part 89 Non-Road Diesel En g inesThe Atlanta Eight-Hour Ozone Attainment Demonstration

115 Table 5-12: Federal Control Measu res for On-Road Mobile Sources

Statutory Requirement Federal Regulation Description of Control

Measure
(Land Based)

Tier 2 Standards – Effective 2001 through 2006

Tier 3 Standards – Effective 2006 through 2008

Section 213 40 CFR Part 90 Land-Based Spark Ignition Engines

Phase II – Effective date depends on engine class and model year. Model years
covered in Phase II are 2001 through 2007 depending on engine class.

Section 213 40 CFR Part 91 Marine Spark Ignition Engines – Effective date depends on engine class and model year. Model years covered are 1998 through 2006 depending on engine
class.

Section 213 40 CFR Part 92 Locomotive and Engines – Effective date depends on original manufacture date
and date of remanufacture. Effective dates for original manufacture range from
1973 to 2005.

Tier 1: 2002 through 2004

Tier 2: 2005 and after

Section 213 40 CFR Part 94 Diesel Marine Engines

Tier 1 – 2004 Model Year
and after.

Tier 2 – Model Years 2004 through 2009.

Section 213 40 CFR Part 1039 Nonroad Diesel EnginesThe Atlanta Eight-Hour Ozone Attainment Demonstration

116 Table 5-12: Federal Control Measu res for On-Road Mobile Sources

Statutory Requirement Federal Regulation Description of Control

Measure
Model year beginning in
2008 with other effective
dates of 2011 and 2012.

Section 213 40 CFR Part 1048 Large Spark Ignition Engines

January 1, 2004

Section 213 40 CFR Part 1051 Recreational Vehicles – Model year 2006 with certain exceptions

Land-Based Diesel Engines: Equipment included in this category includes: diesel engines up to 750 horsepower (hp) used in agriculture, c onstruction, and industry. Equipment examples include: asphalt pavers , rollers, scrapers, r ubber-tired dozers, agricultural tractors, combines, balers, harves ters, and backhoes. Diesel-fueled engines in aircrafts, marine vessels, and locomotives are not included in this category. Federal regulation 40 CFR Part 89 specifies, in part, NOx emission standards from these engines. Federal regulation 40 CFR Part 1039 specifies, in part, fuel sulfur content requirements for diesel fuel used in these engines.

The federal engine NOx exhaus t standards were first promul gated in 1994 and again in
1998. The 1994 NOx exhaust standards are refere nced as “Tier 1” standards and these standards were phased in years 1996 thr ough 2000. The 1998 NOx exhaust standards
revised “Tier 1” standards and introduced “Tie r 2” and “Tier 3” standards. NOx exhaust standards for applicable diesel engines less than 50 hp were phased in from 1999 through 2006. NOx exhaust standards for applicable diesel engines equal to or greater than 50 hp (and less than 750 hp) were phased in from 2001 through 2008. The U.S.EPA estimated that nationwide NOx reductions from implem entation of Part 89 would be approximately
60%.

The federal government introduced fuel sulfur standards for this type of equipment on June 29, 2004 in new federal regulation 40 CFR Part 1039. Part 1039 covers large nonroad diesel engines, such as those used in construction, agricultural, and industrial equipment, to be phased in between 2008 and 2014. The nonroad diesel rule also reduces the allowable sulfur in nonroad diesel fuel by over 99%. Nonroad diesel fuel currently averages about 3,400 ppm sulfur. The rule limits nonroad diesel sulfur content to 500 ppm in 2006 and 25 ppm in 2010.

Land-Based Spark-Ignition Engines: The U.S.EPA divided land-based spark-ignition engines into three board categories – (1) small engines typically used for lawn and garden applications, (2) large engines used in indus trial applications, and (3) specialty engines used in recreational applications.The Atlanta Eight-Hour Ozone Attainment Demonstration

117 Small SI Engines: This category is covered in 40 CF R Parts 90. Nonroad spark-ignition engines below 19 kW (25 horsepower), which usually run on gasoline, are primarily in lawn and garden equipment. The U.S.EP A defines lawn and garden equipment as handheld and non-handheld. Examples of applicable lawn and garden equipment include lawnmowers, string trimmers, leaf blowers, ch ain saws, commercial turf equipment, and lawn and garden tractors fall within this category, but engines used for marine propulsion, recreational ve hicles, or hobby applications (such as remote-control airplanes) are treated separately.

Under Phase 1 regulations, new small SI engines have been meeting exhaust engine standards for HC, CO, and NOx emissions si nce 1997. According to the U.S.EPA, these Phase 1 standards have resulted in a 32 per cent reduction in nationwide HC levels from these engines.

The U.S.EPA adopted Phase 2 standards for small SI engines in two separate rulemakings. The U.S.EPA adopted new e xhaust standards for non-handheld lawn and garden equipment in March 1999 that were phased in between 2001 and 2007. The U.S.EPA adopted new exhaust standards for ha ndheld lawn and garden equipment (such as trimmers, leaf blowers a nd chainsaws) in Ap ril 2000 that were pha sed in between 2002
and 2007.

Standards requiring control of evaporative emissions do not yet apply to Small SI engines.

Large SI Engines: This category is covered in 40 CFR Part 1048. Nonroad SI engines above 19 kW (25 hp), which are usually car a nd truck engines insta lled in industrial equipment, are used in many different applic ations, including forklifts, airport service equipment, generators, compressors, welders, aerial lifts, and ice-grooming machines. These engines – which may operate on liquefied petroleum gas, gasoline, or natural gas – currently contribute about 2 percent of NOx emissions, a nd 3 percent of HC and CO emissions from mobile sources nationwide in 2003 according to EPA.

EPA has adopted emission standards for Large SI engines that take e ffect for new engines starting in 2004. Manufacturers will rely on emission-control technologies from automotive engines, including three-way catalysts and electronic fueling systems, to meet these emissions standards. Starting in 2007, manufacturers have need to use optimized engines, including new diagnostic systems, to meet more stringent standards calling for a 90-percent reduction in NOx, HC, and CO emissions.

Recreational Vehicles: This category is covered in 40 CFR Part 1051. This category includes off-highway motorcycle s, all-terrain vehicles, and snowmobiles that operate on gasoline. According to EPA, this category may also include some motorized scooters, mini-bikes, and mopeds. EPA noted that in 2003 this category contributed about 5 percent of HC emissions and 2 percent of CO emissions from mobile sources nationwide. In November 2002, EPA adopted emission standa rds for new recreational vehicles that was phased in starting in 2006. Those standard s were estimated to reduce HC emissions from these vehicles by 67 percent and CO emissions by 28 percent nationwide.The Atlanta Eight-Hour Ozone Attainment Demonstration

118 Gasoline Marine Engines (40 CFR Part 91): The U.S.EPA promulgated emission control requirements for gasoline marine engines unde r Part 91. Examples of gasoline marine engines includes gasoline outboards, personal watercraft engines and jet boat engines.
The effective date for the introduction of su ch exhaust standards was July 1996 and Part 91 imposes increasingly stringent standards fo r new engines for model years beginning in 1998 through 2006. The U.S.EPA projected a nationwide reduction of 75 percent for hydrocarbons over the cour se of 1996 through 1998.

Diesel Marine Engines (40 CFR Part 94): The U.S.EPA promulgated emission control requirements for diesel marine engines unde r Part 94. Examples of diesel engines includes recreational yachts, fishing boats, tu g and towboats, dredgers, and coastal and ocean-going vessels. Internationally, emissions from marine diesel engines are controlled by Annex VI of the International Convention for the Prevention of Pollution from Ships (known as the MARPOL convention). The NOx limits, contained in Regulation 13 of Annex VI apply to marine diesel engine s rated above 130 kW and are similar in stringency to the first tier of emission st andards adopted for land-based nonroad diesel engines. The Regulation 13 standards are also triggered if an engi ne is substantially modified on or after January 1, 2000. The international standards went into effect in
2005.

In 2003, EPA adopted requirements to make the Regulation 13 sta ndards enforceable beginning January 2004 for engines above 2.5 liters per cylinder in stalled on vessels flagged in the U.S. EPA has also adopted more stringent national standards for certain categories of marine diesel engines installed on vessels flagged in the U.S. The levels of the standards and their applic ation dates vary depending on e ngine size. (Note that EPA
has not finalized Tier 2 sta ndards for engines greater than or equal to 30.0 liters per cylinder but is required to do so on or before December 17, 2009, in accordance with federal regulations.)

40 CFR Part 87: Aircra ft Engine Standards : Section 231 of the CAA directs the EPA
Administrator to issue proposed emission standards appl icable to the emissions of any air pollutant from any class or classes of aircraft or aircraft engines which in his judgment causes, or contributes to, air pol lution which may reasonably endanger public health or welfare. Under this authority EPA has conducted several rulemakings establishing emission standards and related requirements for several classes (commercial and general aviation engines) of aircraft and aircraft engines.

3⁄4 1973: EPA promulgated emission regulations for vented fuel, smoke and exhaust emissions (HC, NOx, and CO) [ see 38 FR 19088, July 17, 1973] 3⁄4 1976: EPA promulgated standards fo r supersonic aircraft engines. [ see 41 FR 34722, August 16, 1976] 3⁄4 1980: EPA rescinded all gaseous emissi on requirements for piston engines and auxiliary power units. [ see 45 FR 1419, January 7, 1980] 3⁄4 1981: The International Civil Aviation Organization (ICAO) issued its first
international standards and recommended practices covering aircraft engine emissions. These provisions applied to many of the same classes of engines to which the U.S. standards in force at the time applied.The Atlanta Eight-Hour Ozone Attainment Demonstration

119 3⁄4 1982: EPA withdrew HC, CO, NOx, and smoke emission standards for various aircraft (and engine) categories. 3⁄4 1993: ICAO issued an amen dment to existing NOx emission standards and test procedures for aircraft engine emissions. These standards took effect in the year 1996 through 2000 and represented a 20 per cent reduction over the 1981 ICAO NOx
standards. 3⁄4 1997: EPA adopted the ICAO's 1993 amen dments, ICAO's existing NOx and CO
emission standards issued in 1981 and other technical amendments to further align EPA and ICAO requirements. These stan dards and test procedures apply to commercial aircraft engines; no general aviation or military engines are covered in
this rule.

EPA noted that in 1997, aircraft engines cont ributed about 2 percen t of the total U.S.
mobile source NOx and CO emissions. In addi tion, EPA noted that in some U.S. airport areas, aircraft can contribute up to 4 percent of mobile so urce NOx emissions. Emissions of NOx from aircraft are increasing (due in pa rt to an increase in LTOs) and this growth is occurring at a time when ot her significant mobile and sta tionary sources are drastically reducing emissions, thereby accentuating th e growth in aircraft emissions.

Under the authority of Section 231 of the CAA, EPA adopted standards equivalent to ICAO's February 1999 NOx standards and March 1997 test procedure amendments [ see 70 FR 69664-69687]. These standards only apply to certain commercia l aircraft engines
whose date of manufacture of the first in dividual production model was after December 31, 2003. The effective date of this rule is December 19, 2005.

40 CFR Part 92: Railroad Engine Standards : Locomotives contribute about 7 percent of NOx emissions and 5 percent of diesel PM emissions from mobile sources nationwide according to the U.S.EPA in 2003. These engines are usually larger than any land-based nonroad diesel engines in displacement volume and total power and may last for 40 years or longer. The U.S.EPA adopted three separa te sets of emission standards, with the standards taking effect depending on the da te a locomotive is first manufactured.

Tier 0 Standards: These first set of standards apply to locomotives and locomotive engines originally manufactured from 1973 through 2001 any time they are manufactured or remanufactured. Locomotives are generall y remanufactured five to ten times during their total service lives of 40 years or more according to the U.S. EPA in 2003.

Tier 1 Standards: This set of standards apply to locomotives and locomotive engines originally manufactured from 2002 through 2004. These locomotives and locomotive engines must meet the Tier 1 standards at th e time of original ma nufacture and at each subsequent remanufacture.

Tier 2 Standards: This set of standards apply to locomotives and locomotive engines originally manufactured in 2005 and later. These locomotives and locomotive engines
must meet the Tier 2 standards at the time of original manufacture and at each subsequent
remanufacture.The Atlanta Eight-Hour Ozone Attainment Demonstration

120 Tier 3 Standards: This set of standards apply to locomotives and locomotive engines originally manufactured in 2009 and later. These locomotives and locomotive engines
must meet the Tier 3 standards at the time of original manufacture and at each subsequent
remanufacture.

Tier 4 Standards: This set of standards apply to locomotives and locomotive engines originally manufactured in 2015 and later. These locomotives and locomotive engines
must meet the Tier 4 standards at the time of original manufacture and at each subsequent
remanufacture.

5.4 Action Plan for Reducing Em issions with Voluntary Control
Measures
Georgia EPD recognizes that every sector, from the public thr ough all levels of government, business, and industry, must reduc e emissions in order to bring the metro
Atlanta area into attainment with the 8-hour ozone standard. The Atlanta 1-hour ozone plans contained aggressive regulatory components that have resulted in substantial reductions in ozone precursors, but EPD rec ognizes that regulations alone cannot bring about all the reductions that are necessary to reach attainment. Stationary sources are already heavily controlled, and although reduc tions from additional stationary source controls, to be installed in accordance with Georgi a Rule 391-3-1-.02(2)(sss), 2 will reduce future ozone formation, those controls won't be in place before the attainment date. Similarly, more stringent tail-pipe standards for new vehicles will not produce emissions reductions until the old engines are replaced with cleaner new engines.

EPD, through its participation in The Clean Air Campaign, actively promotes emission reductions from voluntary programs, and also supports the development and implementation of innovative programs that pa rtner with local juri sdictions, businesses and private citizens to implement emission-re ducing behaviors at the local level.

Inclusion of the following programs in the control measures portion of this attainment plan is not intended to create an enfor ceable commitment by EPD to implement the programs or to achieve any sp ecific emission reductions projected as a result of implementation of the programs, and EPD do es not make any such commitment. In addition, EPD does not rely on any emission reductions projected as a result of implementation of these programs to dem onstrate attainment. While the emission reduction from these programs is potentially su bstantial, leading to significant regional air quality benefits, actual air quality benef its are uncertain and the reductions are not federally enforceable. Consequently, projec ted emission reductions from these programs are not included in the emission inventory, the attainment modeling, the reasonable further progress calculation, or any other area of the SIP where specific projected
emission reductions are identified.

2 see Section 8.12.3The Atlanta Eight-Hour Ozone Attainment Demonstration

121 

### 5.4.1 Emission Reductions from Transportation Measures
Substantial funding commitments have come from State and local agencies and private employers for promotion of strategies to reduce on-road mobile emissions. Examples of these measures include idling reduction; ridesh aring; teleworking; transit use; vehicle replacement and retrofit measures; and bicycle and pedestrian programs.

These programs are working to reduce emissions from mobile sources , and they play an important role in the transportation sector 's contribution to clea ner air. EPD is not including their effects in this SIP, but a ny emission reductions projected as a result of implementing these directionally correct programs could be us ed outside of the SIP for transportation planning purposes if needed.

The following are descriptions of selected em ission reduction strategi es and organizations that promote these strategies in Georgia.

The Clean Air Campaign

When air quality in Georgia becomes unhealt hy, elevated pollution levels pose significant health and economic impacts to its citizens. Traffic congestion is a major problem in the Atlanta region, where individuals waste hundreds of hours every year stuck in traffic on congested roadways. The traffic congestio n contributes to ai r quality problems;
numerous studies have demonstrated that reducing ground level em issions of NOx and
VOC from mobile sources such as cars and trucks is advant ageous in addressing smog problems.

Reduced commuter road miles decrease ai r polluting vehicle emissions, gasoline consumption, traffic congestion, and highway maintenance cost s for Georgia's citizens. With 4.2 million people in the metro Atlanta region today, and another 2.5 million expected in the next 25 years, Georgia must take action now to address these traffic and air quality challenges.

The Clean Air Campaign (CAC) is a 501(c)3 nonprofit corporation that works collaboratively with a number of organizatio ns as part of a regi onal, and increasingly statewide, public-private partnership. Th is partnership uses transportation demand management activities – such as carpool an d transit programs – to reduce traffic congestion and improve air quality. The mission of the Clean Air Campaign is to motivate Georgians to take action to improve air quality and reduce traffic congestion. The Clean Air Campaign motivates individuals to change their commuting habits and live a clean air lifestyle; it also partners with employers to promote clean commuting in the workplace and works with schools to empower children to get involved in cleaning the
air. Some of the recent resu lts of the efforts of the Cl ean Air Campaign are noted in
Table 5.10.The Atlanta Eight-Hour Ozone Attainment Demonstration

122 Transportation Demand Management (TDM) in Atlanta

The rapid population increase in the Atlanta re gion in recent years has caused community
leaders to address concerns over increased traffi c congestion and poor air quality. As a result, Atlanta's Transportation Demand Ma nagement (TDM) community continues to expand its efforts in three major progr am areas: media campaigns, employer and individual outreach services, and regional supporting programs and services. In addition to The Clean Air Campaign, TDM practitioners and Transportation Management Associations (TMAs) in the Atlanta region aim to cha nge individual and employer
attitudes and behaviors about th e voluntary use of alternative forms of transportation in an effort to reduce traffic congestion a nd improve air quality. The participating organizations include but are not limited to the following: 3⁄4 Atlanta Regional Commission's 187RIDEFIND program 3⁄4 Buckhead Area TMA (BATMA) 3⁄4 Central Atlanta Progress/Downtown Atlanta TMA 3⁄4 The Clean Air Campaign 3⁄4 Clifton Corridor TMA (CCTMA) 3⁄4 CobbRides TMA (CobbRides) 3⁄4 Commuter Club (formerly Cumberla nd Transportation Network TMA) 3⁄4 Hartsfield Area TMA (HATMA) 3⁄4 Midtown Transportation Solutions TMA (MTS) 3⁄4 Perimeter Transportation Coalition TMA (PTC)

Other supporting partners and programs in clude but are not limited to the following: Metropolitan Atlanta Rapid Tr ansit Authority (MARTA), Douglas County Rideshare, Georgia Regional Transportation Aut hority (GRTA), GDOT, EPD, Georgia
Environmental Facilities Authority, and MetroVanpool.The Atlanta Eight-Hour Ozone Attainment Demonstration

123 Table 5-13: Clean Air Campai gn in Metro Atlanta Region Employer Services

• Provides one-on-one assistance to 500 employers and property management companies. In 2006, these employers started 870 new programs, such as teleworking and carpooling.

• Outreach team provides approximately 30,000 hours of consulting time to employers across the region

• Partners represent more than 300,000 employees.

Incentives for Commuters & Employers

• In 2006, 21,000 commuters participated
in Commuter Rewards , an innovative regional incentive program.

• Cash for Commuters, which rewards new users of commute alternatives, has
eliminated 62 million miles since its 2002
launch. Sixty-four percent of participants are still clean commuting nine months to one year after the incentive
ends.

• The 2006 Metro Atlanta Walk There! Challenge succeeded in getting 6,100 participants to walk more and drive less.

• Almost 3,500 new teleworkers have started working from home because of the Telework Leadership Initiative. Fifty employers have started or greatly expanded telework programs with the help of this
initiative. Regionally, 72 new vanpools hit the road in 2006 using the Vanpool Incentive Program, reducing 4.4 million vehicle miles. Overall, the region's 349 vanpools reduced 40 million miles from our roadways. Public Education & Awareness

• Radio spots supporting a call to "Give Your Car a Day Off," espousing the financial and quality of life benefits to

commuters.

• Radio spots featuring representations of UPS, Cox Enterprises, GE Energy and the State of Georgia tout the business benefits of commute alternative programs.

• Public relations raised awareness and program participation through more than 475 news stories in 2006, including national exposure for innovative programs by the Associated Press, The New York Times, Good Morning America, and XM
Radio

.

• In 2006, The Clean Air Campaign Web site averaged 6,500 unique visitors each month.

Better Air Schools

• Eighteen elementary and middle schools in metro Atlanta participate as Better Air Schools, helping reach more than 17,000 children and 2,000 staff members.

• Ride There! helped schools realize increases in bus ridership of six to 11
percent.

• BAIR, the Better Air Bear, performs at more than 70 schools, events and organizations each year, teaching children about air quality and its solutions.

• In 2006, The Clean Air Campaign's air quality lesson plans were downloaded more than 25,000 times

.

Pedestrian Walkways and Bikeways Projects A number of communities are creating walkways and bikeways in order to provide safe pathways for pedestrians and bicyclists to move about busy traffic areas. These types of projects provide safe alternatives to driv ing in the city. For example, the Atlanta Regional Commission has produced bicycle su itability maps for every county in the Atlanta region as well as the City of Atla nta to assist the cycling community in determining the safest and most logical pa ths. The maps identify existing on –road bicycle facilities, off-road path s, transit stations, bus routes, and various points of interest.The Atlanta Eight-Hour Ozone Attainment Demonstration

124 Traffic Signal System Retiming A goal of traffic signal system retiming is to improve the flow of traffic through a corridor or system and thereby reduce emi ssions of NOx and VOC. There are numerous studies underway by the various metro Atlant a Transportation Management Associations to analyze existing and proposed intersections to determine the need for traffic signal installation or upgrades to existing signals as well upgrades to existing traffic signalsinterconnect-signal coordination plans.

High Occupancy Vehicle (HOV) Lanes High Occupancy Vehicle (HOV) lanes were introduced to metro Atlanta on December 14, 1994, along an 18-mile section of I-20, east of I-75/85. An addi tional 60 lane miles opened on I-75 and I-85 inside I-285 in 1996. Th ey are an integral part of the Georgia

NAVI GA TOR system, designed to help reduce air pollution, improve traffic congestion and ensure a substantial time savings fo r commuters who rideshare (two or more occupants per vehicle).

HOV lanes, identified by diamond-shaped pa vement markings and overhead signs, are located on I-20, I-75, and I-85. They are desi gnated only for vehicles carrying two or more occupants, certified alternative fuel vehicles, motorcycles and emergency vehicles.

HOV lanes have been extended in the metro Atlanta region since January 1, 2003, as
follows: 3⁄4 Approximately 11.8 miles on I-85 nor thbound and southbound from ChambleeTucker Road to State Route 316. As part of this project, the Georgia NAVI GA TOR System has also been expanded along I-85 to State Route 316 with the installation of cameras, fiber optic cable and changeable message signs.

Income Tax Credits for Teleworking

In January 2008 the Georgia Department of Revenue announced that 135 employers have been approved to take tax credits in 2008 fo r creating and expanding telework programs. These credits will provide in part fewer cars on Atlanta’s roads during the work week. Georgia Code O.C.G.A. §48-7- 29.11 provides authority for this program and Georgia is the first in the nation to offer a tax credit of this kind [Atlanta Journal Constitution February 26, 2008]. In 2008, th e Georgia General Assembly extended this tax credit through 2011.



### 5.4.2 Retrofits/Use of Alternative Fuels
Georgia Adopt-A-School Bus ProgramThe Atlanta Eight-Hour Ozone Attainment Demonstration

125 Georgia EPD has initiated a school bus retrof it program, also referre d to as the Adopt-ASchool Bus Program. It focuses on retrof itting school buses w ith diesel oxidation catalysts, diesel particulate filters, catalyzed wire-mesh filters, and crank case filters and using cleaner fuels such as ultra low sulf ur diesel. Georgia EPD has established agreements with seven school systems, which has resulted in 699 school buses retrofitted. In addition, another 360 school bus retrofits have been completed by school systems seeking funding directly. EPA and CMAQ grants and supplemental environmental projects have provided the bulk of the funding for these projects. At this time, additional CMAQ funds are available for retrofitting sch ool buses and other diesel vehicles and equipment. The CMAQ funds require a 20% match from the school systems or other project partners. The Georgia Regional Tr ansportation Authority has stepped up as a project partner and is c ontributing $40,000 to leverage up to $160,000 in federal CMAQ funds for the Adopt-A-School Bus Program.

Georgia Diesel Working Group The Georgia Diesel Working Group, with memb ers from EPD, U.S. EPA, and public and private entities throughout Georgia, formed in 2004 to develop mechanisms and solutions
to address and reduce the contri bution of diesel engines to Ge orgia's air quality problems.

Ultra-Low Sulfur Diesel Fuel (ULSD) The federal ULSD fuel program, when fully implemented and combined with heavy-duty diesel engine controls pha sed in through 2010, is expected to reduce PM and NOx emissions by 90% and 95%, respectively. Geor gia EPD established a statewide contract in 2005 through which state and local agencies could purchase ULSD over a year sooner
than it would otherwise be available under th e federal program. Several agencies are utilizing this contract, including GRTA's Xpress regional express commuter coach
system.

Low Emission Vehicle Certification Program The Low Emissions Vehicle Certification Program allows for tax credits for the purchase
of dedicated alternative fuel low emission vehicles, for electric vehicle chargers purchased by businesses, for the purchase of zero emission vehicles, and for the
conversion of conventional fueled vehicles to low emission alternative fueled vehicles.

Georgia Diesel Emissions Reduction Technology Tax Credit The State of Georgia offers a 10% tax cr edit diesel particulat e emissions reduction equipment, including equipment for altern ative power during idling. The tax credit applies to 10% of the total cost of equipment and installation costs (Georgia Code 48-7- 40.16).

Congestion Mitigation and Air Quality Impr ovement Program (CMAQ) Retrofit Projects A total of $2.5 million (2005$) in federal CMAQ funds were programmed for fiscal years
2005 and 2006 in the Atlanta Tr ansportation Improvement Progr am for retrofitting school
buses in the area with emissions control de vices. Another $4.7 million were programmed for the same period to help offset the increm ental costs of ultra-lo w sulfur diesel fuel
which must be used for some diesel retrofit technologies. Georgia EPD is the sponsor of these two projects.The Atlanta Eight-Hour Ozone Attainment Demonstration

126 Truck Stop Electrification (TSE) Historically truck drivers idle their engines about eight hours a day, or as much as 1,800 hours annually. Under federal la w, truckers must rest 8 hours for every 10 hours of driving. During this rest pe riod, truck drivers often idle their engines to operate air conditioning or heat in their sl eeper cabs, or on-board applia nces such as television or microwave. Idling also keeps engine s and fuel warm in cold weather.

Truck Stop Electrification (TSE) is a tec hnology solution with two ways to reduce extended truck idling: on-boa rd and off-board. On-board TSE combines battery storage on the truck with recharging at truck stops to power truck electric appliances. These applications include electric heaters and air conditioning units. Off-board technologies provide heating and air conditioning infrastructure at truck stops. An overhead unit supplies cool or warm air to the truck cab by a hose connection. In addition to basic heating and cooling services, TSE users can purchase Internet access, movies, and satellite programming. Both on-board and off- board technologies allow the trucks to turn off their engines, thus saving fuel and re ducing air pollution (emi ssions of both NOx and VOC). TSE is taking place in the following counties:

• Bartow County: 72 spaces at a truck stop in Cartersville were converted with IdleAire technology.

• Butts County: 63 spaces at a truck stop in Jackson were converted with IdleAire technology

• Coweta County: 51 spaces at a truck stop in Newnan were converted with IdleAire technology.

• Fulton County: 96 spaces at a truck stop in Atlanta were convert ed with IdleAire technology.



### 5.4.3 Energy Demand Reduction
Georgia relies on a variety of energy sources . Petroleum products provide energy for transportation; natural gas, coal and other el ectricity fuels are used for heating, cooling, lighting and industrial production. This energy use affects the quality of life of all Georgians, creating jobs, providing mobility and sustaining the state’s prosperity. However, by-products of energy use and high en ergy costs can erode this quality of life. Without reducing demand as the population an d economic activity increase, Georgians may face more price volatility, supply constr aints, security threats and health and
environmental stress. The Governor’s Ener gy Policy Council addressed the topic of energy demand as part of their State Energy Strategy (December 14, 2006). As part of this Strategy, the Council explored opportun ities to treat energy efficiency as a “resource” equal in value to new energy supplies. The Council noted “Energy efficiency is one of the most cost effective and rapidl y deployable resources available to Georgians, and has the added benefit of reducing the health and environmental impact of energy consumption.

Policies and strategies to sust ain Georgia’s quality of life and productivity while reducing the state’s energy consumption through conser vation and efficiency are documented asThe Atlanta Eight-Hour Ozone Attainment Demonstration

127 part of Chapter 3 of the Strategy. Chapte r 3 of the Strategy is organized around six policy objectives, which are programs or policies intended to move Georgia toward affordable, reliable and environmentally re sponsible energy. Each policy objective is followed by associated implementation strate gies, which are designed to achieve or implement the policy. The following table highlights the Council’s recommendations regarding energy demand reduction.

Sector Policy Objective Implementation Strategy

Reduce Energy Demand in Transportation Increase the Use of Technologies that Make the
Vehicle-Based Transportation System
More Fuel Efficient 3.1: Create incentives to increase the adoption of
efficient vehicles and vehicle technologies.

3.2: Establish purchasing
criteria for the State to
increase the use of efficient
vehicles in its fleet.

3.3: Use and support idle reduction technologies.

3.4: Increase the use of
“smart” traffic control technologies and practices. Support Transportation Demand Management
Efforts 3.5: Maximize the use of
telecommunicationtechnology and egovernment to provide government services to the public.

3.6: Encourage continued or expanded funding for proven TDM programs. Increase the Availability of
and Access to Public Transportation and Transit Options 3.7: Continued support and funding for public transit
systems.

Reduce Energy Demand for Electricity and Natural Gas Support the Use of Efficient Building Technologies and
Practices 3.8: Create incentives to increase the adoption of efficient building technologies and practices.

3.9: Establish energy reduction goals for public
facilities.The Atlanta Eight-Hour Ozone Attainment Demonstration

128 Sector Policy Objective Implementation Strategy

3.10: Encourage the use of energy savings performance contracting to finance energy efficiency projects.

3.11: Develop more effective building energy
code enforcement strategies.

Increase the Use of Efficient Appliances and Equipment 3.12: Continue incentives to increase the adoption of efficient appliances and products.

3.13: Establish minimum energy performance criteria for all appliance and equipment purchases by the

State. Support the Increased
Involvement of Electric and
Natural Gas Utilities in Promoting and Implementing Energy Efficiency 3.14: Encourage achievement of a voluntary energy efficiency target for electric and natural gas
utilities.

3.15: Consider alternative utility regulation strategies
that allow utilities to
recover investments in energy efficiency.



### 5.4.4 Activities at Hartsfield-Jac kson Atlanta International Airport

The Hartsfield-Jackson Atlanta Internationa l Airport (HJAIA) is one of the world's busiest airports, and a source of emissions of ozone precursors in the Atlanta metro area. HJAIA has taken numerous steps to minimize em issions of ozone prec ursors in light of the fact that the activity generating the emissi ons is not expected to decrease. Georgia EPD does not have authority to impose eq uipment-specific emission standards or operational standards due to federal preemp tion law. Therefore, minimization of emissions at HJAIA must take place on a voluntar y basis as well as be an inherent portion of future HJAIA facility management plans.The Atlanta Eight-Hour Ozone Attainment Demonstration

129 Sources of emissions of ozone precursors in clude aircraft, auxiliar y power units (APUs), ground support equipment (GSE), passenge r-related motor vehicles, construction, deicing, aircraft refueling, engi ne testing, fire training, boiler s, generators, fuel storage tanks, and emergency generators.

HJAIA has undertaken the follo wing projects to either reduce negative environmental effects associated with operating the airport or to enhance customer service and provide
an environmental benefit. Further discussi on of HJAIA efforts to minimize air emissions is located in Appendix Q.

• Reduced Traffic to and from Airport: This category of projects includes: MARTA rail access to airport; Delta Ai r Line Ticket Counters in MARTA terminal; the City of Atlanta Department of Aviation provides real time airport status and parking lot availability via radio station and web s ite; local and intercity bus service; and activities coordinated by the Hartsfield Airport Transportation Management
Association.

• Reduced Idling Emissions: This category of projects includes: Expansion of Concourse E to eliminate (or reduce) the ne ed for remote parking of planes; taxiway and intersection upgrades; expediting of criti cal airfield construction; use of super tugs; upgrading of some portion of the ground service equipment population from traditional diesel engine to electric engine ; and equipping a majority of the gates with fueling carts.

• Miscellaneous: This category of projects includes: Use of light colors on surfaces of
new construction to reduce heat island e ffects; and commissioning of a compressed natural gas fueling station.

The following projects are either under cons truction or are anticipated to be under
construction in the near future.

• Reduced Traffic to and from Airport: This category of future projects includes the Consolidated Rental Car Facility equipped with automatic people mover.

• Reducing Idling Emissions: This category of future projects includes: Taxiway, runway and intersection upgrades; parking pa y-on-foot option; use of two departure headings; optimize fleet mixes; expand the number of ramp charging stations for electric ground service equipm ent; use of single engine ta xi; use of automated billing system for various users of the Ground Transportation Center (GTC) that use
automatic vehicle identification to track the number of times the GTC is accessed as well as the amount of time spent at the GTC; and the addition of more gates to
Concourse E to reduce the occurren ce of remote parking of planes.The Atlanta Eight-Hour Ozone Attainment Demonstration

130 

## 6.0 ATTAINMENT DEMONSTRATION

This section summarizes the procedures that were used to demonstrate attainment of the 8-hour ozone National Ambient Air Qua lity Standard (NAAQS) in this State Implementation Plan (SIP) package. As de scribed in the US Environmental Protection Agency's (USEPA's) September 2006 draft final Guidance On The Use Of Models And Other Analyses for Demonstrating Attainme nt of Air Quality Goals for Ozone, PM2.5, and Regional Haze (" Attainment Guidance "), an attainment demons tration consists of (a) analyses which estimate whether selected emissions reductions will result in ambient concentrations that meet the NAAQS, and (b) an identified set of co ntrol measures which will result in the required emissions reductions. The necessary emission reductions for
both of these attainment demonstration co mponents may be determined by relying on
results obtained with air quality models.

Section 3.0 of the Attainment Guidance recommends applying both a modeled attainment test and a subsequent screening test to the air quality modeling results to determine if the 8-hour ozone NAAQS will be met. Additiona l technical or corroboratory analyses may also be used as part of a "weight of evid ence" determination to supplement the modeled attainment test and to further support a de monstration of attainment of the NAAQS.

6.1 Modeled Attainment Test

The modeled attainment test is the practice of using an air quality model to simulate baseline (i.e., current) and future air quali ty. For the 8-hour ozone NAAQS, the baseline
and future model estimates are used in a "r elative" rather than "absolute" sense. Specifically, the ratio of the air quality model's future to baseline predictions is calculated at each ozone monitoring site. These mon itoring site-specific ratios are called relative response factors (RRF). Future ozone design values (DVF) are then estimated at each monitor by multiplying the monitor-specific baseline ozone design value (DVB) by the modeled relative response factor for each monitor. If the resulting predicted site-specific DVFs are < 82 parts per billion (ppb), a clear demonstration of predicted attainment is shown. If the predicted DVFs is > 82 ppb and < 87 ppb, then a weight of evidence (WOE) demonstration must be submitted that supports a demonstration of attainment. For DVFs > 87 ppb, the Attainment Guidance states that more qualitative results are less likely to support a conclusion differing from th e outcome of the modeled attainment test. Equation 4-1 presents the modeled attainment test, applied at monitoring site "x" as
described in Section 4.0 of the Attainment Guidance

.

(DVF) = (RRF) x (DVB) Equation 6-1

Where (DVB) = the baseline design va lue monitored at site "x," ppb = the average (of the three) design value periods which include the baseline inventory year (i.e. the average of the 2000-2002, 2001-2003, and 2002-2004 design value periods for the 2002 baseline inventory year).The Atlanta Eight-Hour Ozone Attainment Demonstration

131 (RRF) = the ratio of the future 8-hr daily maximum concentration predicted "nearby" a monitor (averaged over each day of the episode) to the current 8-hr daily maximum con centration predicted "nearby" the monitor (averaged over each day of the episode). (DVF) = the estimated future design value, ppb.

The Attainment Guidance recommends considering an arra y of cells "nearby" a monitor rather than focusing on the in dividual cell containing the mon itor, in order to allow for variations in the model perfor mance where the peak ozone may not occur in the grid cell
that contains the monitor but rather ne arby the monitor. Since the attainment demonstration modeling was performed using a 12-kilometer grid resolution, the size of the array for "nearby" cells was 3x3. Accord ing to the recommended procedure, the maximum value within the 3x3 matrix is used for RRF calculations, for both the future and baseline cases, even if these occur in different cells.

Section 14.1.1 of USEPA's Attainment Guidance outlines the process for determining which days are used in the RRF calculati on. The day selection process starts by identifying all the days in the baseline m odeling that has a modeled daily maximum 8- hour average ozone equal to or greater than 85 ppb. If there are 10 or more days greater than 85 ppb, then 85 ppb is us ed as the cutoff with thos e days used in the RRF
calculation. If there are fewer than 10 da ys with a modeled daily maximum 8-hour average ozone equal to or greater than 85 ppb, then the threshold is reduced by 1 ppb until there are at least 10 days identified for use. If there are fewer than 10 days with a modeled daily maximum 8-hour average ozone e qual to greater than 70 ppb, then all days at 70 ppb and higher are used in the RRF calculation and consid eration of modeling another episode should be explored.

The DVB, for purposes of the modeled at tainment test, is defined in the Attainment
Guidance by one of four methods:

1. The design value period (i.e. the averag e 4th highest value for the 3-yr period used to designate an area "nonattai nment," here the period from 2001 to 2003).

2. The average 4th highest value for the 3-yr period straddling the baseline inventory year (e.g., the 2001-2003 design value pe riod for the 2002 baseline inventory year).

3. The highest of the three design value peri ods which include the baseline inventory year (e.g., the 2000-2002, 2001-2003, 2002-2004 de sign value periods for a 2002 baseline inventory year).

4. The average of the three design valu e periods which straddle the baseline inventory year (e.g., the averag e of the 2000-2002, 2001-2003, and 2002-2004 design value periods for a 2002 baseline inventory year).

The U.S.EPA recommends the fourth method (average of the three design value periods straddling the baseline year), which is the method presented in this section. Attainment
test results for all monitors within the Atlanta nonattainment area are shown in Table 6-1.The Atlanta Eight-Hour Ozone Attainment Demonstration

132 The bold italicized DVFs are values that fall within the range where additional WOE is needed to demonstrate attainment. Eight out of the eleven monitors in the Atlanta nonattainment area have predicted DVFs that fa ll below 82 ppb, and the remaining three monitors (Confederate Avenue, Tucker, and South-DeKalb) fall within the WOE range (82 to 87 ppb), with Confederate Avenue be ing the only site with a DVF above 85 ppb.

Table 6-1 : Atlanta attainment test results fo r 2009, using the maximum value in the 3x3 array surrounding each site

Site name AIRS ID DVB (ppb) Number of Days
used in

RRF Ozone

Threshold (ppb) RRF DVF (ppb)

Confederate Ave. 13-121-0055 94.6 21 85 0.913 86
McDonough 13-151-0002 92.1 23 85 0.872 80
Douglasville 13-097-0004 91.6 33 85 0.875 80

Kennesaw 13-067-0003 91.5 25 85 0.891 81

Tucker 13-089-3001 91.4 22 85 0.905 82

Conyers 13-247-0001 91.2 19 85 0.872 79

South-DeKalb 13-089-0002 90.2 21 85 0.913 82

Newnan 13-077-0002 88.8 21 85 0.874 77

Lawrenceville 13-135-0002 88.3 17 85 0.897 79

Yorkville 13-223-0003 88.2 25 85 0.858 75
Fayetteville 13-113-0001 85.5 28 85 0.886 75

6.2 Weight of Evidence

The Attainment Guidance recommends the use of the predicted or modeled 8-hour daily maximum concentration within the 3x3 matrix for all relevant days used in the RRF calculations, for both the future and baseline cases, even if these occur in different cells. The guidance also recommends the use of the average of the three design value periods which straddle the baseline inventory ye ar (e.g., the averag e of the 2000-2002, 2001- 2003, and 2002-2004 design value periods for a 2002 ba seline inventory year). However, EPD believes it is more appropriate to use th e grid-cell in which each monitor is located
instead of the maximum value within the 3x3 matrix. EPD has also looked at the resulting DVFs based on the first two me thods for defining the DVB listed in the
Attainment Guidance (the average 4th highest value for the 3-yr period used to designate an area "nonattainment" and the average 4th highest value for the 3-yr period straddling the baseline inventory year). In both these cases, the DVB will be based on the 2001- 2003 design value period. EPD thinks that th e third method listed by EPA (highest of the three design value periods which include the baseline inventory year) would be a "worst
case scenario" and considered t oo conservative since major NO

x emission controls were implemented between 2000 and 2002.The Atlanta Eight-Hour Ozone Attainment Demonstration

133 

### 6.2.1 Use of Monitor Grid to Calculate RRFs
EPD previously commented to EPA (Appendix M) that the use of the maximum value
within the 3x3 matrix for th e RRF calculations might not be the best approach for determining the impact of precursor emissi on reductions on ozone concentrations. EPD believes and that analyzing the modeling results for the actual grid-cell where the monitor is located would be a better approach.

The Attainment Guidance describes the use of cells "near" a monitor rather than the cell containing the monitor in the modeled attain ment test. Although three reasons are listed why this is appropriate, EPD f eels that the use of the cell c ontaining the monitor is more appropriate and will lead to more realisti c future DVFs at the monitor locations. EPD finds it hard to justify using unmonitored grid cells near the monitor to describe what is happening at the monitor. Model performance evaluations (MPE) are only conducted for the grid cells containing monitors ; therefore, we feel that th e model attainment test should remain consistent with the MPE and only use these grid cells. In addition, calculating RRFs based on nearby cells that change loca tions between the baseline simulation and future simulation (not paired in space) can lead to erroneous and misleading conclusions.

To address any potential issues arising from predicted p eak "migration," EPD proposes that the cells "near" the monitor undergo th e "unmonitored area analysis" described in
Attainment Guidance . Although these grid cells will no t be used in the actual modeled attainment test to project future design values , they could still be examined along with the
other unmonitored areas.

Uncertainty in the formulation of the model and the model inputs is not a good reason to use an array of nearby grid cells instead of th e cell containing the monitor. There can be very large (and very real) differences in precursor emissions, pollutant formation/deposition processes, and resu lting pollutant conc entrations between neighboring grid cells within the array. Arbitrarily ta king the maximum value or the average value is not an accurate way to characterize the changes occurring at the monitor. If the model performance at the grid cell w ith the monitor is extremely poor on a specific day, consideration should be given to removing this day from the RRF calculation.

The use of nearby grid cells is especially ina ppropriate in situations where there are major emission reductions from large point sources or significant area/mobile sources located within the array of nearby cells. For example, if the model simulates the installation of SCRs at a large utility located one grid cells to the west of the monitor, the model might predict lower future ozone concentrations in the array even when the wind is blowing perpendicular or even in the complete ly opposite direction from the monitor.

As part of EPD's weight of evidence demonstration, RRFs and DVFs have been calculated based on the grid-cell in which each monitor is located (Table 6-2). This approach results in DVFs for all sites th at are below 85 ppb and only two monitors (Confederate Avenue and Tucker) that would fall within the WOE range.The Atlanta Eight-Hour Ozone Attainment Demonstration

134 Table 6-2: Atlanta attainment test results for 2009 using the monitor grid cell value.

Site name AIRS ID DVB (ppb) Number of Days
used in

RRF Ozone

Threshold (ppb) RRF DVF (ppb)

Confederate Ave. 13-121-0055 94.6 12 85 0.895 84
McDonough 13-151-0002 92.1 12 85 0.871 80
Douglasville 13-097-0004 91.6 22 85 0.873 80

Kennesaw 13-067-0003 91.5 15 85 0.886 81

Tucker 13-089-3001 91.4 10 84 0.901 82
Conyers 13-247-0001 91.2 14 85 0.872 79

South-DeKalb 13-089-0002 90.2 12 85 0.895 80

Newnan 13-077-0002 88.8 10 85 0.860 76

Lawrenceville 13-135-0002 88.3 10 79 0.899 79

Yorkville 13-223-0003 88.2 12 85 0.859 75
Fayetteville 13-113-0001 85.5 16 85 0.881 75



### 6.2.2 Use of Alternative DVB to Calculate DVF
EPD has also looked at the resulting DVFs based on the first two methods for defining
the DVB listed in the Attainment Guidance (the average 4th highest value for the 3-yr period used to designate an area "nonattain ment" and the average 4th highest value for the 3-yr period straddling the baseline inventor y year). In both these cases, the DVB will be based on the 2001-2003 design value period, resulting in area-maximum DVB of 91.6 ppb (at Confederate Avenue). As part of EP D's weight of evidence demonstration, DVFs
have been calculated based on these revise d DVB using the maximum value within the 3x3 matrix and the actual grid-cell containing the monitor for the RRF calculations (Tables 6-3 and 6-4). This ap proach results in DVFs for a ll sites that are below 85 ppb, with the Confederate Avenue's DVF being the only one within WOE range (83 ppb based on the "maximum in array" method; 82 ppb based on the "monitor grid cell" method).The Atlanta Eight-Hour Ozone Attainment Demonstration

135 Table 6-3 : Atlanta attainment test results for 2009, using a three-year DVB and the maximum value in the 3x3 array surrounding each site

Site name AIRS ID DVB (ppb) Number of Days
used in

RRF Ozone

Threshold (ppb) RRF DVF (ppb)

Confederate Ave. 13-121-0055 91.6 21 85 0.913 83
McDonough 13-151-0002 89.0 23 85 0.872 77
Douglasville 13-097-0004 91.6 33 85 0.875 80

Kennesaw 13-067-0003 90.6 25 85 0.891 80

Tucker 13-089-3001 89.6 22 85 0.905 81

Conyers 13-247-0001 89.3 19 85 0.872 77

South-DeKalb 13-089-0002 87.6 21 85 0.913 80

Newnan 13-077-0002 87.0 21 85 0.874 76

Lawrenceville 13-135-0002 85.6 17 85 0.897 76

Yorkville 13-223-0003 89.0 25 85 0.858 76
Fayetteville 13-113-0001 83.0 28 85 0.886 73

Table 6-4: Atlanta attainme nt test results for 2009 using a three-year DVB and the monitor grid cell value.

Site name AIRS ID DVB (ppb) Number of Days
used in

RRF Ozone

Threshold (ppb) RRF DVF (ppb)

Confederate Ave. 13-121-0055 91.6 12 85 0.895 82
McDonough 13-151-0002 89.0 12 85 0.871 77
Douglasville 13-097-0004 91.6 22 85 0.873 80

Kennesaw 13-067-0003 90.6 15 85 0.886 80

Tucker 13-089-3001 89.6 10 84 0.901 80

Conyers 13-247-0001 89.3 14 85 0.872 77

South-DeKalb 13-089-0002 87.6 12 85 0.895 78

Newnan 13-077-0002 87.0 10 85 0.860 74

Lawrenceville 13-135-0002 85.6 10 79 0.899 77

Yorkville 13-223-0003 89.0 12 85 0.859 76
Fayetteville 13-113-0001 83.0 16 85 0.881 73The Atlanta Eight-Hour Ozone Attainment Demonstration

136 6.3 Local Measures not Modeled

The metro Atlanta area has a number of groups that ar e working towards decreasing emissions. These measures are voluntary meas ures that, although may not result in large emission reductions, are directionally correct . A few of the known measures that are under way in the metro Atlanta area include : The Clean Air Campaign, truck stop electrification, traffic signa l system retiming, High Occupancy Vehicle (HOV) lanes, pedestrian walkways and bike ways projects, idle reduction policies, biodiesel use and diesel retrofit projects. Discussions of these measures can be found in Section 5.3.

6.4 Unmonitored Area Analysis

The modeled attainment test does not address fu ture air quality at locations where there is not an ozone monitor nearby. To guard against the possibility that ai r quality levels could exceed the standard in areas with limited monitoring, Section 3.4 of the Attainment
Guidance suggest that additional review is "necessary, particularly in nonattainment areas
where the ozone or PM 2.5 monitoring network just meets or minimally exceeds the size of the network required to report data to Air Quality System (AQS)." This review is intended to ensure that a control strategy lead s to reductions in oz one at other locations that could have baseline (and future) desi gn values exceeding the NAAQS if a monitor was deployed there. The te st is called an "unmonitore d area analysis" (UAA). The purpose of the analysis is to use a combin ation of model output and ambient data to identify areas that might exceed the NAAQS if monitors were located there.

For UAA, EPD adopted the Modeled Attainment Test Software (MAT S) tool that was developed by the U.S.EPA to spatially interpol ate data, adjust the spatial fields based on model output gradients, and multiply the fields by model calculated RRFs for analysis of
unmonitored areas. The version of MATS th at EPD used is 1.1.2 (Build 123) and it can
be found on EPA's MATS website: http://www.epa.gov/scram001/modelingapps_mats.htm

Details of EPD's MATS operations are dem onstrated in Figure 6-1. It shows the operational choices that EPD made for the UAA by capturing computer screens of MATS operations. These four steps are mandatory to get DVFs. Of the required input parameters needed to run MATS , the number of days used to calculate spatial gradients from the modeling outputs is one of the most critical inputs. As shown in Table 6-1, the number of days EPD included in the RRF calculation for the Confederate Avenue monitor was 21 days. Given that the Confed erate Avenue monitor observed high ozone concentrations and the CMAQ 12km modeling predicted similar trends, EPD chose to use 21 days for the UAA. In addition, EPD used 153 days to analyze "average" ozone seasonal gradient of predicted daily maximu m 8-hour ozone concentration fields. Input and output files used in the application of MA TS are located in Appendix V. The results of UAA from MATS are shown in Figure 6-2 through Figure 6-4. Circles denote monitors and squares represen t model grid cells in the CMAQ 12 km modeling domain. Red symbols indicate DVF values greater th an or equal to 85 ppb. Orange and yellow symbols are for DVF of 80-84 ppb and 75-79 ppb, respectively. White symbols depict
locations where the DVF is less than or equal to 74 ppb. Figure 6-3 and Figure 6-4 shows details of the MATS outputs around A tlanta areas when 21 days and 153 days were used for the UAA. No modeling grid cells showed DVFs greater than 86 ppb when 21 days were used. If 153 day were used, all modeling cells showed DVFs less than 85The Atlanta Eight-Hour Ozone Attainment Demonstration

137 ppb. In general, all Georgia modeling grid ce lls showed predicted DVFs close to or equal to those of the nearby monitors.The Atlanta Eight-Hour Ozone Attainment DemonstrationFigure 6-1: Demonstrationof EPD's MATS operation.138The Atlanta Eight-Hour Ozone Attainment Demonstration

Figure 6-2: Results of MATS when 21 days we re used for spatial gradient calculations.

Circles denote monitors and squares repr esent model grid cells in the CMAQ 12 km modeling domain. Red symbols indicate DVF values greater than or equal to 85 ppb.

Orange and yellow symbols are for DVF of 80-84 ppb and 75-79 ppb, respectively. White symbols depict locations where th e DVF is less than or equal to 74 ppb.

139The Atlanta Eight-Hour Ozone Attainment Demonstration

Figure 6-3: Detail visualization of MA TS outputs when 21 days were used.
The first line of labels indicates AIRS ID and the second line of labels are DVF at
each monitor. Numbers in red colored cel ls show DVFs. Other color schemes are the same as Figure 6-2.

140The Atlanta Eight-Hour Ozone Attainment Demonstration

Figure 6-4: Detail visualization of MATS outputs when 153 days were used.
The first line of labels indi cates AIRS ID and the second line of labels are DVF at each
monitor. Numbers in red colo red cells show DVFs. Other co lor schemes are the same as Figure 6-2.

6.5 Summary
The EPD has evaluated future ozone design va lues using a combination of two methods for calculating baseline DVBs (2001-2003 a nd weighted 2000-2004), and two methods for calculating RRFs ("maximum in array" and "monitor grid cell"). A summary of DVFs
based on these four test conf igurations is given in Tabl e 6-5. DVFs for ten out of the
eleven monitors show attainment of the 8-hour ozone NAAQS using the 2000-04 DVB and "maximum in array" method. However, all eleven sites show attainment of the NAAQS when using the "monitor grid cell" approach or when using the 2001-03 DVB.

141The Atlanta Eight-Hour Ozone Attainment Demonstration

142 Table 6-5: Atlanta attainme nt test results for 2009 based on four different test configurations. Bold red numbers indicate DVF above

85 ppb; Bold, underlined green numbers indicate DVF below 85 ppb but within weight-of-evidence range; Standard-font green numbers indicate DVF below 82 ppb.

Site name AIRS ID 2000-04 DVB;
"max in array" 2000-04 DVB;
"monitor grid cell" 2001-03 DVB;
"max in array" 2001-03 DVB;
"monitor grid cell"

Conf. Ave. 13-121-0055 86 84 83 82
McDonough 13-151-0002 80 80 77 77
Douglasville 13-097-0004 80 80 80 80

Kennesaw 13-067-0003 81 81 80 80

Tucker 13-089-3001 82 82 81 80

Conyers 13-247-0001 79 79 77 77

S. DeKalb 13-089-0002 82 80 80 78

Newnan 13-077-0002 77 76 76 74

Lawrencevill 13-135-0002 79 79 76 77

Yorkville 13-223-0003 75 75 76 76
Fayetteville 13-113-0001 75 75 73 73

6.6 Attainment Conclusion

The modeled attainment demonstration perfor med according to EPA guidance results in a single monitor in the Atlanta NAA exceedin g the 8-hour ozone NAAQS (DVF of 86 ppb at the Confederate Avenue monitoring site). However, the weight of evidence analysis demonstrated in Section 6.2 provides strong evidence that the Atlanta 8-Hour Ozone NAA will demonstrate attainment of the ozone NAAQS by 2009. The attainment demonstration with the weight of evidence analysis is effective since the unmonitored area analysis showed EPD's modeling showed no modeling grid grea ter than 86 ppb. Additionally, the additional emi ssion control or reduction meas ures identified in Section 5.3 as well as those contingency measures th at will be implemented, regardless of attainment status, will pr ovide additional emission reduc tions beyond those quantified
and modeled for this attainment demonstrati on. Therefore Georgia EPD concludes that this document provides an ad equate demonstration of comp liance with the 8-Hour Ozone NAAQS for the Atlanta 8-Hour Ozone NAA by the year 2009.The Atlanta Eight-Hour Ozone Attainment Demonstration

143 

## 7.0 SENSITIVITY OF OZONE IN ATLANTA TO NOx AND
VOC EMISSIONS

EPD performed an analysis of the sensitivity of ozone concentra tions in the Atlanta
nonattainment area to reductions in em issions of both nitrogen oxides (NO

x ) and volatile organic compounds (VOCs). The analysis was based off of the Visibility Improvement
State and Tribal Association of the South east (VISTAS) modeling, using the emissions inventories for both 2002 and 2009, and CMAQ version 4.5 with the CB-IV chemical mechanism. The entire "ozone season" was modeled (May 1 – September 30), using a 12- km modeling grid, covering the state of Ge orgia and parts of the neighboring states (boundary conditions were obtained from simulations using a larger domain). Given the relatively flat terrain of the Atlanta area and the distance from the coastline, a 12-km modeling grid should be sufficient for char acterizing the spatial patterns in ozone response to control measures. This is also s upported in Cohan et al. (2006), in which the effect of grid resolution of sensitivity analyses results was investigated.

7.1 Cases Modeled

Sensitivities were modeled relative to 2009 em issions, to evaluate the efficiency of various control strategies to be implemented by the start of the 2009 ozone season. Sensitivities to both ground-level emissions (e.g., mobile, area) and elevated emissions (e.g., major power plants) were modeled. Fi ve ground-level cases and five major pointsources were modeled. Note that Plant Bowen, Plant Wansley, and Plant Hammond Unit
4 were not included in the anal ysis since they currently have selective catalytic reduction devices installed on all their major units. The following is a detailed list of the 10 cases
that were modeled:

1. 10% Atlanta ground-level NO
x : a reduction of 10% in anthropogenic groundlevel NO

x emissions in the Atlanta 20 c ounty nonattainment area (average reduction of 37.1 tons-per-day compared to 2009 emissions).

2. 10% Atlanta ground-level VOC : a reduction of 10% in anthropogenic groundlevel VOC emissions in the Atlanta 20 county nonattainment area (average reduction of 52.1 tons-per-day compared to 2009 emissions)

.

3. 10% Atlanta on-road NO
x : a reduction of 10% in anthropogenic ground-level
on-road NO

x emissions in the Atlanta 20 co unty nonattainment area (average reduction of 23.2 tons-per-day compared to 2009 emissions).

4. 10% Atlanta non-road NO
x : a reduction of 10% in anthropogenic ground-level
non-road NO

x emissions in the Atlanta 20 co unty nonattainment area (average reduction of 8.9 tons-per-day compared to 2009 emissions).

5. 10% Atlanta area NO
x : a reduction of 10% in anthropogenic ground-level areasource NO
x emissions in the At lanta 20 county nonattainment area (average reduction of 3.8 tons-per-day compared to 2009 emissions).The Atlanta Eight-Hour Ozone Attainment Demonstration

144 6. SCRs at Branch : Installation of selective catalytic reduction devices (SCRs) onPlant Branch units 1-4 (average reduction of 50.9 tons-per-day compared to preinstallation emissions; assuming a decr ease in emissions rate from 0.42 lb/MMBtu to 0.07 lb/MMBtu).

7. SCRs at Hammond : Installation of selective catalytic reduction devices (SCRs) on Plant Hammond units 1-3 (average reducti on of 11.8 tons-per-day compared to pre-installation emissions; assuming a decrease in emissions rate from 0.20 lb/MMBtu to 0.07 lb/MMBtu).

8. SCRs at McDonough : Installation of selective catalytic reduction devices (SCRs) on Plant McDonough units 1-2 (average reduction of 7.5 tons-per-day compared to pre-installation emissions; assuming a decrease in emissions rate from 0.23 lb/MMBtu to 0.07 lb/MMBtu).

9. SCRs at Scherer : Installation of sel ective catalytic reduc tion devices (SCRs) onPlant Scherer units 1-4 (average reduction of 26.8 tons-per-day compared to preinstallation emissions; assuming a decr ease in emissions rate from 0.14 lb/MMBtu to 0.07 lb/MMBtu).

10. SCRs at Yates : Installation of selective catal ytic reduction devices (SCRs) on Plant Yates units 1-7 (average reducti on of 24.0 tons-per-day compared to preinstallation emissions; assuming a decr ease in emissions rate from 0.21 lb/MMBtu to 0.07 lb/MMBtu).

7.2 Results
The results of the sensitivity analysis are reported in terms of the average reduction in daily maximum 8-hour ozone at model grid-ce lls corresponding to monitoring sites, for days in which the 2002 base-case modele d daily maximum 8-hour ozone was above 85 ppb (or a minimum of 10 days, using a lo wer threshold), following the approach recommended in the EPA modeling guidance (EPA, 2007). Both absolute reductions (ppb) and reductions normalized per ton-per- day of precursor controlled (ppt/TPD) are reported. Modeled reductions at each site were scaled by the 2002 5-year ozone design value (DV) used for attainment demonstrations.

Sensitivity analysis results for the Confederate Avenue site in Atlanta are reported in Table 7-1, and Figures 7-1 and 7-2. This site was chosen since its DV is the highest of all
the Atlanta nonattainment area sites. Sensitivit y results for other sites in the Atlanta nonattainment area are reported in Appendix F, and generally show similar patterns.The Atlanta Eight-Hour Ozone Attainment Demonstration

Table 7-1 : Summary of sensitivity analysis results for the Atlanta Confederate Avenue site (AIRS ID 13-121-0055)

Sensitivity TPD
reduction Average 1

Reduction in
O 3 (ppb) Normalized average 1

reduction in O 3 (ppt/TPD) 10% Atlanta ground-level NO

x 37.1 1.41 38.1 10% Atlanta ground-level VOC 52.1 0.09 1.7

10% Atlanta on-road NO

x 23.2 0.92 39.5

10% Atlanta non-road NO

x 8.9 0.28 31.7

10% Atlanta area NO

x 3.8 0.14 36.5

SCRs at Branch 50.9 0.22 4.4

SCRs at Hammond 11.8 0.04 3.4 SCRs at McDonough 7.5 0.27 35.7

SCRs at Scherer 26.8 0.17 6.2

SCRs at Yates 24.0 0.21 9.0

1 Using modeled days in which the 2002 mode led 8-hr ozone concentration was above 85 ppb.

-1.50 -1.00 -0.50 0.00 0.50 1.00 1.50 2.00 2.50

6/1 6/8 6/15 6 / 22 6 / 29 7 /6 7/ 1 3 7/ 2 0 7/27 8 /3 8/ 10 8/ 1 7 8/ 2 4 8/31 9/ 7Reduction in max 8-hr ozone (ppb)

30.0 40.0 50.0 60.0 70.0 80.0 90.0 100.0 110.0Daily max 8-hr ozone (ppb)

10% NOx 10% VOC 2009 base-case
Figure 7-1: Modeled 2009 daily maximum 8-hr ozone at the Confederate Avenue site, along with the modeled reductions in ozone for a 10% control of ground level, anthropogenic, non-EGU NO

x and VOC emissions. Red diamonds denote days in which

the 2002 model results were above 85 ppb, and su ch days were included calculation of the average reductions reported in Table 7-1.

145The Atlanta Eight-Hour Ozone Attainment Demonstration

-0.50 0.00 0.50 1.00 1.50 2.00 2.506/16/86/156/226/297/67/137/207/278/38/108/178/248/319/7Reduction in max 8-hr ozone (ppb)

0.0 20.0 40.0 60.0 80.0 100.0 120.0

Branch Hammond McDonough Scherer Yates 2009 base-case
Figure 7-2: Modeled 2009 daily maximum 8- hr ozone at the Confederate Avenue site, along with the modeled redu ctions in ozone associated w ith the installation of SCRs at plants Bowen, Hammond, McDonough, Scherer and Yates. Red diamonds denote days
in which the 2002 model results were a bove 85 ppb, and such days were included calculation of the average reduc tions reported in Table 7-1.

7.3 Discussion

Results from the sensitivity an alysis clearly indicate that NO

x controls are substantially more efficient in reducing peak ozone concentrations compared to VOC controls (38.1 vs. 1.7 ppt/TPD, respectively), indicating to NO

x limited conditions. Relatively minor differences in control efficiency ar e observed for the various ground-level NO

x sources (39.5, 31.7, 36.5 ppt/TPD for on-ro ad, non-road and area NO

x , respectively), likely due to both atmospheric turbulence resulting in mixing of emissions prior to peak ozone and to "artificial" dilution of emissions using in model grids.

NO
x controls at Plant McDonough are more effici ent in controlling ozone than at other power plants in Georgia ( 35.7 vs. 3.4-9.0 ppt/TPD, respectiv ely), due to its location within the Atlanta nonattainment area, but its abso lute reduction is fairly similar to that of plants Branch, Scherer and Yate s (0.27, 0.22, 0.17, 0.19 ppb, respectively).

Results for other sites within the nonattain ment area (shown in Appendix F) typically show a similar pattern, w ith a tendency to increased efficiency of ground-level NO

x controls over VOC controls outside of the core urban area (as represented here by the Confederate Avenue site).

146The Atlanta Eight-Hour Ozone Attainment Demonstration

147 

## 8.0 OTHER CLEAN AIR ACT REQUIREMENTS

Sections 172(c), 182(a) and 182( b) of the CAA, as amended, contain the requirements for ozone nonattainment areas. As a subpart 2 moderate ozone nonattainment area, the Atlanta area must meet the requirements for both a marginal and moderate area, as well as the general requirements contained in S ection 172(c). These requirements were listed
in Table 1-4.

8.1 RACT/RACM Requirements
Section 172(c)(1) of the CAA requires SIPs to provide for the implementation of all reasonably available control measures (R ACM) to demonstrate attainment as expeditiously as practicable. A subset of RACM is RACT, which relates specifically to stationary point sources. All available RACM measures that are not considered RACT have been exhausted through nearly three decades of ozone nonattainment planning for Atlanta and have been included in previous SIPs. Section 182(b)(2) of the CAA, for
areas classified as moderate nonattainment status for ozone, requires RACT rules to be adopted for all point sources of VOC and NOx emissions with potential to emit at least 100 tons per year or greater. As a portion of the 8-hour ozone metro Atlanta region is subject to RACT rules for the 1-hour ozone maintenance plan, RACT requirements apply
for some sources of VOC and NOx emissions which have lower emission thresholds.

Georgia’s RACT demonstration is contai ned in Chapter 10 of this document.

8.2 Reasonable Further Progress
Section 182(b)(1) of the CAA mandates a 15 percent VOC em ission reduction, accounting for growth, in the first 6 years afte r the baseline year (2002) for moderate and
above ozone nonattainment areas. Thus for the metro Atlanta nonattainment area, a reasonable further progress (RFP) anal ysis between 2002 and 2008 is required.

Georgia EPD is submitting an RFP SIP under separate cover.

8.3 Actual Emissions Inventory
Section 182(a)(1) and Section 172(c)(3) require the developm ent of a comprehensive, accurate current inventory of actual emissions from all sources of VOC and NOx in the nonattainment area. Such inventory was due two years after designation of the 8-hour ozone nonattainment areas, or by June 15, 2006. The Georgia EPD met this requirement through the submittal of the 2002 emission inve ntories under the Consolidated Emission Reporting Rule (CERR) for the metro Atla nta counties in this nonattainment area.

The final 2002 emission inventories used in the attainment demons tration will go through the public hearing process with the full attainment demonstration, which will include any updates or revisions that are ne cessary since the CERR submittal.The Atlanta Eight-Hour Ozone Attainment Demonstration

148 8.4 Emissions Inventory Statement
Section 182(a)(3)(B) requires the SIP to contai n a requirement for all owners or operators of stationary sources located in the nonattainment area and that emit either VOC or NOx
to submit a statement of actual emissions a nnually. The State may waive the requirement
for sources that emit less than 25 tons per year of NOx or VOC emissions. The requirement for such emissions statements was previously required by Rule 391-3-1- .02(6)(a)4 for the original 13 c ounties for stationary sources, defined as those which emit more than 25 tons per year of NOx or VOC emissions subject to the previous old 1-hour
ozone nonattainment SIP. Emission statement fo r stationary sources that emit more than 25 tons per year of NOx or VOC emissions we re required by an amendment to that same rule effective March 12, 2007 for the additional 7 counties.

8.5 Periodic Emissions Inventory
Section 172(c)(3) and 182(a)(3)(A) require periodic inventory submittals. Specifically, Section 182(a)(3)(A) requires the inventory be submitted every three years until the area is redesignated to attainment. The Georgi a EPD met this requirement by submitting the CERR inventory to EPA on June 1, 2007.

8.6 Permit Program Requirements
Sections 172(c)(5) and 182(a)(2)(C) require a permit program consistent with the requirements of Section 173. Additionally , Section 182(b)(5) requires an offset requirement of 1.15 to 1. Georgia EPD updated rules for nonattainment new source review (NNSR) effective July 25, 2007, including updating the new offset requirement. The Georgia EPD has met the permit program requirements for a moderate nonattainment

area.

8.7 Inspection and Maintenance Program
Section 182(b)(4) requires moderate and above ozone nonattainment areas to implement a vehicle inspection and maintenance (I/M) prog ram. To meet this requirement for the Atlanta 1-hour ozone nonattainment area, a d ecentralized idle test was implemented as part of the previous Atlanta 1-hour ozone SIP. In the 13 counties 3 of the former Atlanta
1-hour ozone nonattainment area there is an an nual enhanced I/M program, with onboard diagnostics system checks on 1996 and newer m odel year cars and light trucks; 2-mode ASM tests on 25-year-old through 1995 mode l year vehicles; a check for catalytic converter tampering on 25-year-o ld through 1995 model year ve hicles; a gas cap pressure test on all subject vehicles; and technician training and certification. The existing 13- county I/M program has been determined to be sufficient to meet the requirements of section 182(b)(4) for the 20-county nonatta inment area (see Appendix S).

3 Cherokee (13057), Clayton (13063), Cobb (13067), Coweta (13077), DeKalb (13089), Douglas (13097), Fayette (13113), Forsyth (13117), Fulton (13121), Gwinnett (13135), Henry (13151), Paulding (13223), and Rockdale (13247)The Atlanta Eight-Hour Ozone Attainment Demonstration

149 8.8 Other Measures
Section 172(c)(6) requires the nonattainment SIPs to include enforceable limitation and other control measures, along with schedules for compliance as needed to demonstrate attainment. Chapters 5 and 10 provide a discussion of state and federal control measures that help the metro Atlanta area make pr ogress in attaining the ozone standard.

8.9 Compliance with Section 110(a)(2)
Section 172(c)(7) requires nonattainment SIPs to meet the applicable provisions of Section 110(a)(2). The Georgia EPD has revi ewed the requirements of Section 110(a)(2) and has concluded that, except for the prov isions of 110(a)(2)(G), the prior rule submittals, along with this attainment demonstration plan address the relevant requirements. On March 27, 2008, EPA published a finding that the state of Georgia has failed to submit a SIP addressing the emerge ncy episode plan requirements of section 110(a)(2)(g). EPD intends to comply with the requirements published in this Federal Register notice in order correct this deficiency.

8.10 Equivalent Techniques
The Georgia EPD believes that the procedur es for modeling, emissions inventory and planning follow the USEPA guidance and is not requesting approval for equivalent techniques, as envisione d under Section 172(c)(8).

8.11 Contingency



### 8.11.1 Contingency Overview
The Clean Air Act requires States containi ng nonattainment areas to adopt contingency
measures that will take effect without further action by the State or USEPA upon a determination by the USEPA that an area failed to demonstrate Reasonable Further Progress (RFP) or to timely attain the a pplicable NAAQS, as described in section 172(c)(9).



### 8.11.2 Contingency Measures

Section 172(c)(9) of the Clean Ai r Act requires states to identify and include contingency
measures in their attainment demonstration plans. Contingency measures must take effect without significant further action by the State or USEPA upon a determination by
EPA that an area has either failed to dem onstrate Reasonable Further Progress (RFP)
toward attainment or attainment of the applicable NAAQS. Contingency measures are additional control measures to be implemented in the event that an area fails to meet RFP or fails to attain the standards by its attain ment date. These contingency measures must be fully adopted rules or control measures that are ready to be implemented quickly upon
failure to meet RFP or failure of the area to meet the standard by its attainment date.
These measures should consist of other contro l measures for the area that are not included in the control strategy for the SIP.”The Atlanta Eight-Hour Ozone Attainment Demonstration

150 

### 8.11.3 Contingency Emission Redu ctions for Failure to Attain
The Clean Air Act requires nonattainment area s to implement control measures necessary to meet the federal air quality standard s. Through analysis and modeling a state demonstrates attainment based in the implem entation of a State Implementation Plan. If
a nonattainment area does not attain the fede ral standard by the pr escribed attainment
date then the nonattainment ar ea is required to implement c ontingency measures within a year of a federal register notice that the ar ea did not meet its at tainment date. The contingency measures, if needed, must be meas ures that will take effect without further action by the State or the Administrator.

The attainment date for Atlanta as a mode rate nonattainment area is June 15, 2010, under the 8-hour ozone NAAQS. However, attainment of the standard is based on the threeyear design value that averages the ozone seasons of 2007, 2008 a nd 2009. Therefore, the 2009 design value is the mark er by which attainment will be judged. States will be notified if they did not meet the 8-hour ozone NAAQS in 2010 based on a review of the 2009 design value. One year from the date of notification the identified contingency measures must be fully implemented. This means that contingency measure must provide emission reductions in the 2011 timefra me to meet the contingency requirements.

The attainment contingency requirements can be met by demonstrating that significant emission reduction will occur from specific measures implemented after 2009.

Georgia's state only contingency measures fo r this attainment demonstration SIP are as
follows:

• NOx controls on Coal-Fired Power Plants;

• Voluntary Initiative to Reduce Railyard Emissions;

Except for the voluntary initiative to redu ce railyard emissions, these measures are
controls that are either cu rrently required by an adopted state rule or are currently undergoing the rulemaking process to be adop ted at a later date , but prior to the attainment date required of this SIP re vision. The measures and their scheduled implementation dates are described in the following paragraphs.

NOx Controls on Coal-Fired Power Plants Georgia Rule 391-3-1-.02(2)(sss), Multipollu tant Control for El ectric Utility Steam Generating Units, requires owners/operators of specific coal-f ired electric steam generating units to install addi tional controls for one or more pollutants. The units are required to be equipped with NO

x controls after May 1, 2009. At this time the owners/operators anticipate using selective catalytic reduction for emission reductions of NOx. The affected units and the required in stallation dates are specified in Table 8.1. Because these controls are required by an ex isting Georgia rule, they will take effect without further action by Georgia or EPA.

While the table below demonstrates that state rule requires NOx reductions to be implemented in the near future, only Georgi a Power Plant Scherer Unit 3 and Georgia Power Plant McDonough Unit 2 may specifically qualify to be a contingency measure in the requisite time period.The Atlanta Eight-Hour Ozone Attainment Demonstration

151 Table 8-1: Multipollutant Control Requi rements for Certain Coal-Fired Boilers

AIRS No. Plant/Unit County Capacity (MW) Fuel Type Deadline for
Installation and Operation of
NOx Control

04-13-207-00008 Georgia Power Plant
Scherer Unit 3 Monroe 891 Subbitumino
us Coal 12/31/2011

04-13-067-00003 Georgia Power Plant McDonough Unit 2 Cobb 299 Bituminous
Coal 12/31/2011

04-13-067-00003 Georgia Power Plant McDonough Unit 1 Cobb 299 Bituminous
Coal 4/30/2012

04-13-207-00008 Georgia Power Plant
Scherer Unit 4 Monroe 891 Subbitumino
us Coal 12/31/2012

04-13-237-00008 Georgia Power Plant
Branch Unit 3 Putnam 544 Bituminous
Coal 12/31/2013

04-13-207-00008 Georgia Power Plant
Scherer Unit 2 Monroe 891 Subbitumino
us Coal 12/31/2013

04-13-237-00008 Georgia Power Plant
Branch Unit 4 Putnam 544 Bituminous
Coal 06/01/2014

04-13-237-00008 Georgia Power Plant
Branch Unit 1 Putnam 299 Bituminous
Coal 12/31/2014

04-13-237-00008 Georgia Power Plant
Branch Unit 2 Putnam 359 Bituminous
Coal 12/31/2014

04-13-207-00008 Georgia Power Plant
Scherer Unit 1 Monroe 891 Subbitumino
us Coal 12/31/2014

04-13-077-00001 Georgia Power Plant
Yates Unit 6 Coweta 403 Bituminous
Coal 06/01/2015

04-13-077-00001 Georgia Power Plant
Yates Unit 7 Coweta 403 Bituminous
Coal 06/01/2015

Voluntary Reduction of Emissions from Railyards in the Metro Atlanta Region Railroad-related emissions of NOx are a majo r contributor to ozone concentrations in many of Georgia's nonattainment counties. Cost-effective options are available to significantly reduce NOx emissions from locomotive engines, however federal regulations do not currently require or allow states to require their use. In addition, recent federal regulations for these engines w ould not significantly reduce their emissions to the level possible for many years. EPD is pursuing a voluntary emissions reduction program and has been awarded a $36,200,000 gr ant from Georgia Department of Transportation under the Congestion Mitigation and Air Quality improvement program (CMAQ) to negotiate the use of emission re duction technologies and techniques with railroad companies operating in the Atlanta area. EPD anticipates emission reductions based on this contingency measure after 2010. A detailed discussion of voluntary
emission reduction measures is discussed furt her in Appendix T. EPD will amend this SIP upon completion of the contra ctual obligation with the Class I railroads that operate
in the Atlanta NAA.The Atlanta Eight-Hour Ozone Attainment Demonstration

152 

## 9.0 MOTOR VEHICLE EMISSIONS BUDGETS

9.1 Background
Attainment demonstrations are control strategy SIP revisions. As such, they establish motor vehicle emissions budgets (MVEBs). A motor vehicle emissions budget is described in EPA's transportation conformity rule 4 as "...the implementation plan's estimate of future [motor vehicle] emissi ons." Such budgets establish caps on motor vehicle emissions; projected emissions from transportation plans and programs must be equal to or less than these caps for a positive conformity determination to be made.

9.2 Establishment of 2009 Motor Ve hicle Emissions Budgets for the Atlanta 8-Hour Ozone Nonattainment Area
Note that the motor vehicle emissions budgets being established w ith this Attainment
Demonstration are esse ntially the 2009 mobile 5 source emission inventories for the
Atlanta nonattainment area and do not include emissions from outsi de the nonattainment

area.

In preparation for establishing budgets with this Attainment Demonstration, EPD worked closely with the Atlanta Re gional Commission (ARC) to develop the best possible
estimates of mobile source emissions for th e 20-county Atlanta nonattainment area, using
the MOBILE6 emission factor model 6 and ARC's link-based emissions estimation procedure. The projected mobile source emissi ons inventories reflect all federal and state mobile source control rules, including federal tailpipe standards, low-sulfur and low-Reid vapor pressure (RVP) gasoline, 7 and, in the 13 counties of the former 1-hour ozone standard nonattainment area, enhanced I/M and Stage II refu eling vapor recovery. See Appendix U for details of the mobile s ource emissions modeling used for MVEB development.

One adjustment had to be made to the calcu lated tons per day emi ssions inventories to
arrive at the final motor vehicle emissions i nventories. This adjustment accounts for the
loss of credit from a state rule allowi ng exemption from vehicle inspection and maintenance (I/M) for cars 10 years old or older driven fewer than 5,000 miles per year and owned by persons 65 years old or older. It was estimated that this senior I/M exemption increased VOC and NOx emissions by 0.05 and 0.03 tons per day, respectively, in 2002. This senior I/M exemption emissions debit for 2002 is conservatively high and was al so added to the 2 009 budget year inventories. See "Effect of Senior Exemption on 2002 Highway M obile Source Emissions" in Appendix U, Exhibit 6, for details of the senior exemption credit loss calculations.

4 40 CFR Part 93.124(a)

5 The term "mobile" is used to describe emissions from on-road motor vehicles. The term "nonroad" is
used to describe emissions from off-road equipment and vehicles.

6 http://www.epa.gov/otaq/m6.htm#m60

7 The MVEB inventories reflect a later planning assumption than do the air quality modeling inventories: a 100% market share of 10% ethanol-blend gasoline (E10) is assumed, with a volatility waiver that, per Georgia's Gasoline Marketing Rule, allows RVP for E10 allows to rise from 7.0 to 8.0 pounds per square
inch.The Atlanta Eight-Hour Ozone Attainment Demonstration

153 As noted above, the 2009 mobile source VOC and NOx emissions inventories were developed using the ARC's link-based emissions estimation procedure (see Appendix U).
These inventories reflect the most recent planning assumptions and emission factor
model 8 available, and the use of updated trav el demand and emissions calculation models. The methodology used to calculate the highway mobile source emissions on which the updated 2009 MVEBs are based is di scussed below and, in greater detail, in Appendix U.

The MOBILE6.2 motor vehicle emission factor model was used to calculate 2009 VOC
and NOx emission factors with all 2009 mobile s ource control rules in place. Two sets of emission factors were produced to properl y reflect different fleet characteristics 9 and
mobile source emissions controls in the 13- county and 7-county parts of the 20-county
nonattainment area.

The 13-county controls includ e: annual enhanced I/M with onboard diagnostics system checks on 1996 and newer model year vehicles; 2-mode ASM tests on 25-model-year-old through 1995 vehicles; a check for catalytic converter tamp ering on 25-model-year-old through 1995 vehicles; a gas cap pr essure test on all subject vehicles; low-sulfur and lowRVP gasoline; Stage II gasoline refueling vapor recovery; the Federal Motor Vehicle Control Program (FMVCP), including Tier 1 and (beginning with 2004 models) Tier 2 tailpipe standards; the National Low Emi ssion Vehicle (NLEV) program; and technician training and certification.

For the 7-county part of the nonattainment ar ea, the emission factors reflect Georgia's low-sulfur/low-RVP gasoline and all fede ral controls (e.g., FMVCP, NLEV).

The emission factors resulting from the sepa rate MOBILE6.2 runs for the 13-county and 7-county parts of the 20-count y nonattainment area were used with ARC's link-based emissions estimation procedure to calculate 2009 tons per day emissions in the following

manner:

• For each of four times of day (a.m. peak, midday, p.m. peak, and night), the HPMSadjusted 10 and summer-adjusted 2009 VMT and speeds from each link in ARC's travel demand model were multiplied by the 2009 MOBILE6.2 emission factor at the average speed closest to the c ongested-flow speed on that link.

• Emissions from all the links and all four time periods were summed together to get grams per day inventories, which were divided by 907,180 to convert from grams per day to tons per day.

These mobile source inventories reflect the most up-to-date mobile modeling assumptions, including 2009 VMT projected from a state-of-the-art travel demand model

8 MOBILE6.2.03

9 Separate registration distributions by age were modeled for the 13-county and 7-county parts of the 20- county nonattainment area.

10 The VMT from the travel demand model were adjusted based on the VMT estimates that GDOT develops for the Highway Performance Monitoring System (HPMS).The Atlanta Eight-Hour Ozone Attainment Demonstration

154 for the 20 counties and July 2009 emission factors from EPA's latest mobile source emission factor model, MOBILE6.2.03.

Details of the mobile source emissi ons modeling methodology used for MVEB development, along with the MOBILE6.2 inpu t files and other doc umentation, are in Appendix U (Mobile Source Emissions M odeling for Atlanta Ozone Attainment Demonstration Motor Vehicle Emissions Budgets).

Table 9-1 sums the calculated mobile sour ce emissions inventories for the 20-county
Atlanta ozone nonattainment area and th e 13-county senior exemption emissions
increases.

Table 9-1: Total 20-County 2009 Mo tor Vehicle Emissions Budgets VOC (tons/da y ) NOx (tons/day)

2009 Mobile Emissions Subtot al (MOBILE6.2 results) 163.82 252.24 Senior I/M Exemption Increases + 0.05 + 0.03 Total 2009 Motor Vehicle Emissions Budgets 163.87 252.27

This Attainment Demonstration hereby esta blishes 2009 motor vehi cle emissions budgets of 163.87 and 252.27 tons per day, VOC and NOx, respectively, for the 20-county
Atlanta 8-hour ozone nonattainment area. Interagency consultation among the relevant agencies occurred during the development of these MVEBs and prior to the submittal of this Attainment Demonstration. Full implementation plan documentation was provided to EPA, and EPA's stated concerns have been addressed.

The MVEBs established by this Attainment De monstration are based on new estimates of VMT and speeds from an updated, state-of-t he-art travel demand model; on the latest version of EPA's motor vehicle emission factor model (MOBILE6.2.03); and on registration distributions by age developed using registration data 11 obtained from R.L. Polk & Company.

To show the MVEB "together with all other emissions sources 12 ," point, area, and nonroad emissions from 2009 modeling inve ntories developed by the VISTAS/ASIP
contractors were used. 13 Table 9-2 below shows the 2009 nonattainment area emissions
inventories for all sectors:

Table 9-2: 2009 20-County Atlanta Nona ttainment Area Projected Emissions

Point Area Nonroad Mobile Total VOC (tons/summer day) 19.41 313.72 85.46 163.87 582.46 NOx (tons/summer day) 69.47 35.07 103.25 252.27 460.06

11 Registration data was from R. L. Polk & Co.'s National Vehicle Population Profile ® current as of October 2002 and from R. L. Polk & Co.'s TIPNet ® current as of March 2003. See Appendix U, Exhibit 2, for more details on the registration distribution by age.

12 Section 93.118(e)(4)(iv) of the transportation conformi ty rule requires that the "motor vehicle emissions budget(s), when considered together with all other emissions sources, is consistent with applicable requirements for...attainment...."

13 See Tables 3-2 and 3-3.The Atlanta Eight-Hour Ozone Attainment Demonstration

155 

## 10.0 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) ANALYSIS

10.1 Introduction Under the former 1-hr ozone NAAQS, the 13-county Atlanta non-attainment area, consisting of Cherokee, Clayton, Cobb, Cowe ta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding and Rockdale Counties, was classified as a severe non-attainment area. Georgia EPD implemen ted RACT for ozone precursors VOC and NOx in accordance with applicable provisions of the CAA. These RACT provisions are still in place as part of the 1-hour ozone metro Atlanta mainte nance plan. The 1997 eight-hour ozone NAAQS classifi es the 20-county Atlanta non- attainment area consisting of Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, He nry, Newton, Paulding, Rockdale, Spalding and Walton, as a moderate nonattainment area. According to the EPA’s Final Rule to Implement the 8-Hour Ozone NAAQS – Phase 2 (40 CFR§51.912, November 29, 2005), for each subpart 2 are classified moderate or above, the State shall submit a SIP revision that meets the VOC and NOx RACT requirement s in sections 182(b)(2) and 182(f) of the CAA, respectively. The deadline for submittal of a SIP revision fulfilling the requirements of 40 CFR Part 51.912 is December 31, 2008. In addition, the State shall provide for implementation of RACT as expeditiously as practicable but no later than the first ozone season or portion thereof which o ccurs 30 months after the RACT SIP is due.

10.1.1 RACT
RACT is defined as the lowest emissions lim itation, that a particular source is capable of meeting, by the application of control technology that is reasonably available considering technological and economical feasib ility (44 FR 53762; September 17, 1979 )

. Documents useful in establishing RACT incl ude Control Techniques Guidelines (CTGs), Alternative Control Technique guidance (ACT), Maximum Achievable Control Technology (MACT) standards, New Source Performance Standards (NSPS), and Best Available Control Technology (BACT) standard s. RACT requirements are included in the CAA to assure that significant source cate gories at major sources of ozone precursor
emissions are controlled to a “reasonable” ex tent, but not necessarily to best available control technology (BACT) levels expected of new major sources major modifications to existing major sources or to maximum ach ievable control technology (MACT) required for major sources of hazardous air pollutants.

10.1.2 Clean Air Act Section 182(b)(2) Requirements Section 182(b)(2) requir es that areas classified as moderate for ozone nonattainment include provisions to requi re the implementation of Reasonably Available Control Technology under section 172(c)(1) with respect to three VOC categories. Section 182(b)(2)(A) covers the VOC CTG categories u pdated or created between November 15, 1990 and the particular date of attainment . Section 182(b)(2)(B) covers the VOC CTG categories for which a CTG was issued prior to November 15, 1990. Section 182(b)(2)(C) covers all other major stationary sources of VOCs that are located in the area [metro Atlanta eight-hour ozone non-attainment area].The Atlanta Eight-Hour Ozone Attainment Demonstration

156 The abbreviation CTG stands for Control Te chniques Guidelines and sections 108 and 183 of the CAA provide more b ackground into the role CTGs pl ay in helping States meet section 182(b)(2) requirements as they rela te to VOC emissions. The EPA has issued CTG documents defining presumptive RACT levels for existing facilities that emit large amounts of air pollutant s The CAA [section 183(e)] requir es the EPA to revise RACT, update existing CTG documents, or develop new documents, on a frequent basis to provide states and local agencies with the mo st current technical information and assist them in determining RACT. The EPA has issued updates to existing CTG documents and CTGs for several new categ ories beginning in 2006. E ach of these CTG updates (or new CTGs) come with the requirement to state and local agencies to submit a SIP
revision that either certifies or demonstr ates that the existing or proposed RACT represents RACT in light of the updated or new CTGs.

Pursuant to section 183(c), EPA has i ssued technical documents which identify alternative controls for certain categories of stationary sources of VOC [and/or NOx] emissions which have a potential to emit 25 tons per year or more of each air pollutant.
The alternative controls are documented in an Alternative Control Technology (ACT) document and ACTs do not define presumptive RACT levels.

Under the former 1-hour ozone NAAQS, Georgia EPD implemented VOC emission reductions that met section 182(b)(2) RACT requirements for Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyt h, Fulton, Gwinnett, Henry, Paulding and Rockdale Counties. The VOC emission threshold for implementing Section 182(b)(2) VOC RACT requirements in the former 1-hour ozone NAAQS area ranged from 15 pounds of VOC emissions per day up to 25 to ns per year. The section 182(b)(2) VOC RACT requirements are specified in Georgia Rule 391-3-1-.02(2) under Emission
Limitations and Standards

.

Section 182(b)(2) of the CAA, in this cas e, specifies additional deadlines for SIP revisions pertaining to VOC RACT. The subm ittal deadline for SIP revisions pursuant to sections 182(b)(2)(B) and 182( b)(2)(C) of the CAA are equivalent to 40 CFR Part 51.912. Submittal deadlines for SIP revisions pursuant to section 182(b)(2)(A) are specified in CTG’s issued between Nove mber 15, 1990 and the attainment date. Submittal deadlines for SIP revisions pursuant to section 182(b)(2)(A) are October 5, 2007, October 9, 2008, and September 30, 2009 depe nding on the VOC source category.

This SIP revision will address the need to demonstrate that existing and/or updated VOC emission standards in Chapter 391-3-1-.02(2) fulfill eight-hour RACT requirements for all VOC sources in the metro Atlanta that are covered by a CTG document, excluding the CTG categories promulgated on September 30, 2008 [i.e., SIP deadline is September 30, 2009].The Atlanta Eight-Hour Ozone Attainment Demonstration

157 10.1.3 Clean Air Act Section 182(f) Requirements SIP revisions required under section 182(b) for major st ationary sources of VOCs shall also apply to major stationary sources of NOx pursuant to section 182(f) of the CAA. Major stationary sour ces of VOC and NOx is define d in section 302 and section 302 defines a major stationary source of either air pollutant as one which has a potential to emit of 100 tons per year or greater.

Under the former 1-hour ozone NAAQS, Ge orgia EPD implemented NOx emission reductions that met section 182(f) requireme nts for Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fult on, Gwinnett, Henry, Paulding and Rockdale Counties. The NOx emission threshold for implementing Section 182(f) NOx emission reductions in the former 1-hour ozone NAAQS area ranged from 1 t on per year of NOx emissions per day up to 25 tons per year. In fact, some NOx emission limitations and standards applied if certain equipment was constructed and operated in the applicable county irregardless of NOx emissions. Th e section 182(f) NOx emission reductions are specified in Georgia Ru le 391-3-1-.02(2) under Emission Limitations and Standards

.

As noted earlier, the EPA has issued CTG documents defining presumptive VOC RACT levels for existing facilities. EPA has also issued several CTGs and ACTs for source categories emitting NOx. There are no additional deadlines for SIP revisions pertaining

to NOx RACT.

This SIP revision will address the need to demonstrate that existing and/or updated NOx emission standards in Chapter 391-3-1-.02(2) fulfill eight-hour RACT requirements for
all NOx sources in the metro Atla nta are covered by a CTG document.

10.1.4 8-Hour Ozone RACT SIP Analysis Elements Georgia EPD reviewed RACT SIP analysis elements provided in various out of state SIP submittals including Baltimore, Charlotte, Dallas-Fort Worth (DFW), and the San Joaquin Valley Unified Air Pollution Contro l District (SJVUAPCD). Georgia EPD is developing its SIP analysis in a manner very similar to DFW and SJVUAPCD. Georgia EPD’s 8-hour ozone RACT SIP analysis includes the following elements:

3⁄4 RACT demonstration for source categories covered under section 182(b)(2)(A) of the CAA as they relate to VOC and NOx emissions.

3⁄4 RACT demonstration for s ource categories covered unde r section 182(b)(2)(B) of the CAA as they relate to VOC and NOx emissions.

3⁄4 RACT demonstration for non-CTG source categories cove red under section 182(b)(2)(C) of the CAA as they relate to VOC and NOx emissions.The Atlanta Eight-Hour Ozone Attainment Demonstration

158 10.2.1 RACT Demonstration for Source Categor ies Covered Section 182(b)(2)(A) of
the Clean Air Act

Section 182(b)(2)(A) of the CAA pertains to each category of VOC and/or NOx sources in the area covered by a CTG document issued by the Administrator between the date of the enactment of the CAAA of 1990 [November 15, 1990] and the date of attainment. The Georgia EPD reviewed CTG and ACT do cuments issued between November 15, 1990 and the present moment which includes Gr oups II, III, and IV CTGs. Table 10-1 specifies the applicable CTG and/or ACT sour ce categories that fall under this section of
the CAAA of 1990 for NOx and VOC emissions.

The Georgia EPD examined the applicable stat e rules mentioned in Table 10-1 to verify that they satisfy the corresponding RACT re quirements for the applicable CTG source categories. To determine if the control t echnologies associated with the existing state emission specifications fulfill RACT requirements for the relevant unit types, the Georgia EPD compared the existing state regulations to the controls contained in the CTG and ACT guidance documents. State regulations that implement the controls suggested in CTG and ACT documents or that implement e quivalent emission cont rol strategies were determined to fulfill RACT requirements.

Because EPA must evaluate SIP-related rules pr ior to approval to determine if those rulesfulfill all applicable U.S.EPA guidelines and policies, any U.S.EPA 1-hour ozone SIPapproved rules were determined to meet th e RACT requirements at the time of federal approval. Each of the federally approved state rules mentioned in Table 10-1 were evaluated to determine if they fulfilled the RACT requirements for the 8-hour ozone standard. Georgia EPD is not aware of any significant changes in control technology that affect original RACT determinations a pproved for the 1-hour ozone NAAQS. As such, Georgia EPD is certifying through this SIP revision, that the VOC state rules mentioned in Table 10-1 satisfy the RACT requirement s of 100 tons per year or more for the applicable CTG sourced categories. Negati ve declarations have been made for VOC source categories where there are no major emission sources within the metro Atlanta
nonattainment area.

The emission specifications in the Georgia Ru les that regulate all major sources of NOx emissions in the area consistently cont ain lower NOx emission limits than those established by ACT documents, EPA guidelines and policies, and those technologies and methodologies currently considered RACT by th e EPA and other affect ed states. These rules include Georgia Rules 391- 3-1-.02(2)(yy), (jjj), (lll), (mmm), and (nnn) which are mentioned in Table 10-1. Therefore, EPD is certifying through this SIP revision that these NOx emission standards satisfy the RA CT requirements of 100 ton per year or more. Negative declarations have been made for NOx sour ce categories where there are no major emission sources within the metro Atlanta nonattainment area.

A majority of VOC provisions in Georgia Rule 391-3-1-.02 (2) apply statewide based on county-specific VOC emission thresholds. Th e applicability of th e VOC provisions that do not apply statewide have been extended to the additional 7 count ies that make up the
metro Atlanta non-attainment area. In a ddition, these VOC provisi ons apply year-round.The Atlanta Eight-Hour Ozone Attainment Demonstration

159 The applicable NOx rules already applied to the 7 additional counties and no change is being implemented at this time and they apply May 1 through September 31.

Table 10-1: Source Categories Covered S ection 182(b)(2)(A) of the Clean Air Act

Air

Pollutant CTG
and/or
ACT? Source Category State Regulations Fulfilling RACT Requirements

VOC ACT Alternative Control Technology Document – Organic Waste Process Vents, EPA-450/3-91-007,
December 1990. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

NOx ACT NOx Emissions from Nitric and Adipic Acid Manufacturing Plants, EPA-453/3-91-026, December
1991. Georgia Rule 391-3-1- .02(2)(i): Emission Limitations and Standards,
Nitric Acid Plants.

VOC ACT Control of Volatile Organic Compound Emissions from Industrial Wastewater CTG (draft), EPA-453/D-93-056, September
1992. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

CTG not finalized but issued
as ACT in 1994.

VOC ACT Bakery Ovens ACT, EPA-453/R92-017, December 1992. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

NA NA Control Techniques for Volatile Organic Compound Emissions from Stationary Sources, EPA-453/R-92- 018, December 1992. This document is often listed with CTGs, but it does not define RACT for any particular source.

NOx ACT NOx Emissions from StationaryCombustion Turbines, EPA-453/R93-007, January 1993. Georgia Rule 391-3-1- .02(2)(mmm): Emission Limitations and Standards,
NOx Emissions from Stationary Gas Turbines and Stationary Engines used to Generate Electricity; and

Georgia Rule 391-3-1- .02(2)(nnn): Emission Limitations and Standards, NOx Emissions from Large Stationary Gas Turbines.

VOC ACT Control of VOC Emissions from the Application of Agricultural Pesticides, EPA-453/R-92-011,
March 1993. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.The Atlanta Eight-Hour Ozone Attainment Demonstration

160 Table 10-1: Source Categories Covered S ection 182(b)(2)(A) of the Clean Air Act

Air

Pollutant CTG
and/or
ACT? Source Category State Regulations Fulfilling RACT Requirements

NOx ACT NOx Emissions from StationaryInternal Combustion Engines, EPA453/R-93-032, July 1993. Georgia Rule 391-3-1- .02(2)(mmm): Emission Limitations and Standards,
NOx Emissions from Stationary Gas Turbines and Stationary Engines used to Generate Electricity.

Updated September 2000.

VOC CTG Control of Volatile Organic Compound Emissions from
Reactor Processes and Distillation Operations in Synthetic Organic Chemical Manufacturing Industry
EPA-450/4-91-031 August 1993 No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

VOC ACT Control of Volatile Organic Compound Emissions from OffsetLithographic Printing, EPA-453/D95-001, September 1993.

CTG created and issued in October
2006. Georgia Rule 391-3-1- .02(2)(ddd): Emission Limitations and Standards,
VOC Emissions from Offset Lithography.

NOx ACT NOx Emissions from Process Heaters, EPA-453/R-93-034, September 1993.

The ACT appears to be focused on petroleum refining industry. Revised September 1993. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

VOC ACT Alternative Control Techniques Document – Volatile Organic Liquid Storage In Floating and Fixed Roof Tanks, EPA-453/R-94- 001, January 1994. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

VOC ACT Control of Volatile Organic Compound Emissions from Batch Processes ACT, EPA-453/R-93- 020, February 1994.

Document also released under the Report ID of EPA-453/R-93-017. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

VOC ACT Alternative Control Techniques Document – Industrial Cleaning Solvents, EPA-453/R-94-015, No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.The Atlanta Eight-Hour Ozone Attainment Demonstration

161 Table 10-1: Source Categories Covered S ection 182(b)(2)(A) of the Clean Air Act

Air

Pollutant CTG
and/or
ACT? Source Category State Regulations Fulfilling RACT Requirements

February 1994.

VOC ACT Alternative Control Techniques Document – Surface Coating of Automotive/Transportation and Business Machine Plastic Parts, EPA-453/R-94-017, February 1994. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

NOx ACT NOx Emissions from Cement Manufacturing, EPA-453/R-94-004,
March 1994. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

Updated September 2000.

NOx ACT NOx Emissions from Industrial, Commercial & Institutional Boilers, EPA-453/R-94-022, March 1994. Georgia Rule 391-3-1- .02(2)(lll): Emission Limitations and Standards,
NOx Emissions from FuelBurning Equipment; and

Georgia Rule 391-3-1- .02(2)(rrr): Emission Limitations and Standards,
NOx Emissions from Small Fuel-Burning Equipment.

NOx ACT Alternative Control Techniques
Document – NOx Emissions from Utility Boilers, EPA-453/R-94-023,
March 1994. Georgia Rule 391-3-1- .02(2)(jjj): Emission Limitations and Standards,
NOx Emissions from Electric Utility Steam Generating Units.

Rule (jjj) applies to only coal combustion, but all Georgia Utilities are covered by this
rule.

VOC ACT Alternative Control Technology Document – Surface Coating Operations at Shipbuilding and Ship Repair Facilities, EPA-453/R-94- 032, April 1994.

For CTG, see 61 FR-44050, August 27,1996. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.The Atlanta Eight-Hour Ozone Attainment Demonstration

162 Table 10-1: Source Categories Covered S ection 182(b)(2)(A) of the Clean Air Act

Air

Pollutant CTG
and/or
ACT? Source Category State Regulations Fulfilling RACT Requirements

VOC ACT Industrial Wastewater Alternative Control Technology, (No Report ID), April 1994.

ACT consists of cover memo withoption tables + CTG (draft) EPA453/D-93-056. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

VOC ACT Alternative Control Techniques
Document – Automotive Refinishing, EPA-453/R-94-031, April 1994. A national rule for autobody refinishing was issued in
1998 after the ACT.

VOC ACT Alternative Control Techniques Document – Surface Coating Operations at Shipbuilding and Ship Repair Facilities, EPA-453/R-94- 032, April 1994.

This ACT was superseded by the Ship Building CTG issued in August 1996. Not applicable.

NOx ACT Alternative Control Techniques
Document – NOx Emissions fromGlass Manufacturing, EPA-453/R94-037, June 1994 Only one major source in the
Atlanta 8-hr ozone nonattainment area (Owens Brockway, AIRS No. 12100020).

This source is subject to Georgia Rule 391-3-1- .02(2)(yy): Emission Limitations and Standards, Emissions of Nitrogen Oxides from Major Sources,and underwent a case-bycase RACT analysis.The Atlanta Eight-Hour Ozone Attainment Demonstration

163 Table 10-1: Source Categories Covered S ection 182(b)(2)(A) of the Clean Air Act

Air

Pollutant CTG
and/or
ACT? Source Category State Regulations Fulfilling RACT Requirements

NOx ACT Alternative Control Techniques
Document – NOx Emissions fromIron and Steel Mills, EPA 453/R94-065, September 1994. Only one major source in the
Atlanta 8-hr ozone nonattainment area (Gerdau Ameristeel, AIRS No. 1500032).

This source is subject to Georgia Rule 391-3-1- .02(2)(yy): Emission Limitations and Standards, Emissions of Nitrogen Oxides from Major Sources,and underwent a case-bycase RACT analysis.

VOC CTG Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations
EPA-453/R-97-004
EPA-68/D1-00115 EPA-453/D-96-016, December
1997

MACT see 59 FR 29216, June 6,
1994 Georgia Rule 391-3-1- .02(2)(kkk): Emission Limitations and Standards,
VOC Emissions from Aerospace Manufacturing
and Rework Facilities

VOC CTG Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations
EPA-453/D-95-002 EPA-453/R-96-007, April 1996

Draft MACT out: May 1994 61 FR 25223 – May 20, 1996 61 FR 50823 – September 27, 1996 Georgia Rule 391-3-1- .02(2)(hhh):Emission Limitations and Standards, Wood Furniture Finishing and Cleaning Operations

VOC CTG Group II: Control Techniques Guidelines for Flexible Packaging Printing
EPA-453/R-06-003 September 2006 Georgia Rule 391-3-1- .02(2)(mm): Emission Limitations and Standards,
VOC Emissions from Graphic Arts Systems

VOC CTG Group II: Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing,
EPA-453/R-06-002 September 2006 Georgia Rule 391-3-1- .02(2)(ddd): Emission Limitations and Standards,
VOC Emissions from Offset LithographyThe Atlanta Eight-Hour Ozone Attainment Demonstration

164 Table 10-1: Source Categories Covered S ection 182(b)(2)(A) of the Clean Air Act

Air

Pollutant CTG
and/or
ACT? Source Category State Regulations Fulfilling RACT Requirements

VOC CTG Group II: Control Techniques Guidelines for Industrial Cleaning
Solvents
EPA-453/R-06-001 September 2006 Reduction in VOC emissions
from the use of industrial cleaning solvents is covered under a majority of the VOC emission provisions in Georgia Rule 391-3-1-.02(2).

VOC CTG Group II: Control Techniques Guidelines for Flat Wood Paneling Coatings
EPA-453/R-06-004 September 2006 Georgia Rule 391-3-1- .02(2)(jj): Emission Limitations and Standards,
VOC Emissions from Surface Coating of Flat Wood Paneling

VOC CTG Group III: Control Techniques Guideline for Paper, Film, and Foil Coatings
EPA-453/R-07-003 September 2007 Georgia Rule 391-3-1- .02(2)(w): Emission Limitations and Standards, VOC Emissions from Paper Coating

VOC CTG Group III: Control Techniques
Guidelines for Metal Furniture Coatings
EPA-453/R-07-005 September 2007 Georgia Rule 391-3-1- .02(2)(y): Emission Limitations and Standards,
VOC Emissions from Metal Furniture Coating

VOC CTG Group III: Control Techniques Guidelines for Large Appliance Coatings
EPA-453/R-07-004 September 2007 Georgia Rule 391-3-1- .02(2)(z): Emission Limitations and Standards, VOC Emissions from Large Appliance Surface Coating

VOC CTG Group IV: Control Techniques
Guidelines for Miscellaneous Metal and Plastic Parts Coatings
EPA-453/R-08-003 September 2008 To be determined. Update will be submitted in separate
SIP revision.

VOC CTG Group IV: Control Techniques
Guidelines for Automobile and Light-Duty Truck Assembly Coatings
EPA-453/R-08-002 and –006 September 2008 To be determined. Update will be submitted in separate
SIP revision.

VOC CTG Group IV: Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials
EPA-453/R-08-004 September 2008 To be determined. Update will be submitted in separate
SIP revision.The Atlanta Eight-Hour Ozone Attainment Demonstration

165 Table 10-1: Source Categories Covered S ection 182(b)(2)(A) of the Clean Air Act

Air

Pollutant CTG
and/or
ACT? Source Category State Regulations Fulfilling RACT Requirements

VOC CTG Group IV: Control Techniques
Guidelines for Miscellaneous
Industrial Adhesives
EPA-453/R-08-005 To be determined. Update will be submitted in separate
SIP revision.

Table 10-4 specifies the metro Atlanta area facilities whose operations have potential VOC or NOx emissions greater than 100 tons per year and have process equipment
covered under a CTG and/or AC T covered under th is chapter.

10.2.2 RACT Demonstration for Source Categor ies Covered Section 182(b)(2)(B) of
the Clean Air Act

Section 182(b)(2)(B) of the CAA pertains to each category of VOC and/or NOx sources in the area covered by a CTG doc ument issued by the Administrator prior to the date of the enactment of the CAAA of 1990, namely November 15, 1990. Table 10-2 specifies the applicable CTG and/or ACT source categ ories that fall under this section of the
CAAA of 1990 for VOC emissions. Note that there are no applicable CTGs or ACTs
that fall under this section of the CAA.

The Georgia EPD examined the applicable stat e rules mentioned in Table 10-2 to verify that they satisfy the corresponding RACT re quirements for the applicable CTG source categories. To determine if the control t echnologies associated with the existing state emission specifications fulfill RACT requirements for the relevant unit types, the Georgia EPD compared the existing state regulations to the controls contained in the CTG and ACT guidance documents. State regulations that implement the controls suggested in CTG and ACT documents or that implement e quivalent emission cont rol strategies were determined to fulfill RACT requirements.

Because EPA must evaluate SIP-related rules pr ior to approval to determine if those rulesfulfill all applicable U.S.EPA guidelines and policies, any U.S.EPA 1-hour ozone SIPapproved rules were determined to meet th e RACT requirements at the time of federal approval. Each of the federally approved state rules mentioned in Table 10-1 were evaluated to determine if they fulfilled the RACT requirements for the 8-hour ozone standard. Georgia EPD is not aware of any significant changes in control technology that affect original RACT determinations a pproved for the 1-hour ozone NAAQS. As such, Georgia EPD is certifying through this SIP revision, that the VOC state rules mentioned in Table 10-2 satisfy the RACT requirement s of 100 tons per year or more for the applicable CTG sourced categories. Negati ve declarations have been made for VOC source categories where there are no major emission sources within the metro Atlanta
nonattainment area.The Atlanta Eight-Hour Ozone Attainment Demonstration

166 Georgia EPD has updated these VOC state rules to be applicable in the 7 additional counties that make up the 8-hour ozone metr o Atlanta nonattainme nt area on March 1, 2009 at a potential VOC emissions thre shold of 100 tons per year.

Table 10-2: Source Categories Covered S ection 182(b)(2)(B) of the Clean Air Act

Air

Pollutant Alternative Control Technology (ACT) Reference Document Corresponding State Rule Fulfilling RACT and Notes Concerning the ACT.

VOC CTG Design Criteria for Stage I Vapor Control Systems – Gasoline Service
Stations
EPA-450/R-75-102 Georgia Rule 391-3-1- .02(2)(rr): Emission Limitations and Standards, Gasoline Dispensing Facility – Stage I;

This reference document is regarded as a CTG although it was never published with
an EPA document number.

VOC CTG Control of Volatile Organic Emissions from Existing Stationary
Sources – Volume I: Control Methods for Surface Coating Operations,

EPA-450/2-76-028
November 1976 Although often listed with
the CTGs for historical reasons, this reference
document does not define RACT for any source. It is a compilation of control techniques.

VOC CTG Control of Volatile Organic Emissions from Existing Stationary
Sources – Volume II: Surface Coating of Cans, Coils, Paper,Fabrics, Automobiles, and LightDuty Trucks

EPA-450/2-77-008 May 1977 Georgia Rule 391-3-1- .02(2)(t): Emission Limitations and Standards,
VOC Emissions from Automobile and Light-Duty Truck Manufacturing

Georgia Rule 391-3-1- .02(2)(u): Emission Limitations and Standards,
VOC Emissions from Can Coating;

Georgia Rule 391-3-1- .02(2)(v): Emission Limitations and Standards,
VOC Emissions from Coil Coating;

Georgia Rule 391-3-1- .02(2)(w): Emission Limitations and Standards, VOC Emissions from Paper Coating; andThe Atlanta Eight-Hour Ozone Attainment Demonstration

167 Table 10-2: Source Categories Covered S ection 182(b)(2)(B) of the Clean Air Act

Air

Pollutant Alternative Control Technology (ACT) Reference Document Corresponding State Rule Fulfilling RACT and Notes Concerning the ACT.

Georgia Rule 391-3-1- .02(2)(x): Emission Limitations and Standards,
VOC Emissions from Fabric and Vinyl Coating.

VOC CTG Control of Volatile Organic
Emissions from Solvent Metal Cleaning

EPA-450/2-77-022
November 1977 Georgia Rule 391-3-1- .02(2)(ff): Emission Limitations and Standards, Solvent Metal Cleaning.

VOC CTG Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit
Turnarounds

EPA-450/2-77-026
October 1977 Georgia Rule 391-3-1- .02(2)(ee): Emission Limitations and Standards, Petroleum Refinery

VOC CTG Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals

EPA-450/2-77-026
October 1977 Georgia Rule 391-3-1- .02(2)(cc): Emission Limitations and Standards,
Bulk Gasoline Terminals

VOC CTG Control of Volatile Organic Emissions from Existing Stationary
Sources – Volume III: Surface Coating of Metal Furniture,

EPA-450/2-77-032
December 1977 Georgia Rule 391-3-1- .02(2)(y): Emission Limitations and Standards,
VOC Emissions from Metal Furniture Coating

VOC CTG Control of Volatile Organic Emissions Stationary Sources – Volume IV: Surface Coating of Insulation of Magnet Wire

EPA-450/2-77-033
December 1977 Georgia Rule 391-3-1- .02(2)(aa): Emission Limitations and Standards,
VOC Emissions from Wire Coating

VOC CTG Control of Volatile Organic Emissions from Existing Stationary
Sources – Volume V: Surface Coating of Large Appliances

EPA-450/2-77-034
December 1977 Georgia Rule 391-3-1- .02(2)(z): Emission Limitations and Standards, VOC Emissions from Large Appliance Surface Coating

VOC CTG Control of Volatile Organic Georgia Rule 391-3-1-The Atlanta Eight-Hour Ozone Attainment Demonstration

168 Table 10-2: Source Categories Covered S ection 182(b)(2)(B) of the Clean Air Act

Air

Pollutant Alternative Control Technology (ACT) Reference Document Corresponding State Rule Fulfilling RACT and Notes Concerning the ACT.

Emissions from Bulk Gasoline
Plants

EPA-450/2-77-035
December 1977 .02(2)(pp): Emission Limitations and Standards,
Bulk Gasoline Plants.

VOC CTG Control of Volatile Organic
Emissions from Use of Cutback Asphalt

EPA-450/2-77-037
December 1977 Georgia Rule 391-3-1- .02(2)(dd): Emission Limitations and Standards, Cutback Asphalt

VOC CTG Control Techniques for Volatile Organic Emissions from Stationary
Sources

EPA-450/2-78-015 May 1978 This document is often listed with CTGs, but it does not define RACT for any particular source.

VOC CTG Control of Volatile Organic Emissions from Existing Stationary
Sources – Volume VI: Surface Coating of Miscellaneous Metal
Parts and Products

EPA-450/2-78-015
June 1978 Georgia Rule 391-3-1- .02(2)(ii): Emission Limitations and Standards,
VOC Emissions from Surface Coating of Flat Wood Paneling

VOC CTG Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VII: Factory Surface Coating of Flat Wood Paneling

EPA-450/2-78-032
June 1978 Georgia rule 391-3-1- .02(2)(jj): Emission Limitations and Standards,
VOC Emissions from Surface Coating of Flat Wood Paneling

VOC CTG Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment

EPA-450/2-78-036
June 1978 Georgia Rule 391-3-1- .02(2)(hh): Emission Limitation and Standards, Petroleum Refinery Equipment Leaks

VOC CTG Control of Volatile Organic
Emissions from Manufacture of Synthesized Pharmaceutical
Products

EPA-450/2-78-029
December 1978 Georgia Rule 391-3-1- .02(2)(kk): Emission Limitations and Standards,
VOC Emissions from Synthesized Pharmaceutical ManufacturingThe Atlanta Eight-Hour Ozone Attainment Demonstration

169 Table 10-2: Source Categories Covered S ection 182(b)(2)(B) of the Clean Air Act

Air

Pollutant Alternative Control Technology (ACT) Reference Document Corresponding State Rule Fulfilling RACT and Notes Concerning the ACT.

VOC CTG Control of Volatile Organic
Emissions from Manufacture of Pneumatic Rubber Tires,

EPA 450/2-78-030
December 1978 Georgia Rule 391-3-1- .02(2)(ll): Emission Limitations and Standards,
VOC Emissions from the
Manufacture of Pneumatic
Rubber Tires

VOC CTG Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VIII: Graphic Arts-Rotogravure and Flexography

EPA-450/2-78-033
December 1978 Georgia Rule 391-3-1- .02(2)(mm): Emission Limitations and Standards,
VOC Emissions from Graphic Arts Systems.

VOC CTG Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof
Tanks

EPA-450/2-78-047
December 1978 Georgia Rule 391-3-1- .02(2)(nn): Emission Limitations and Standards,
VOC Emissions from External Floating Roof
Tanks

VOC CTG Control of Volatile Organic Emissions from Perchloroethylene Dry Cleaning Systems

EPA-450/2-78-050
December 1978 Perchloroethylene has been exempted as a VOC, so this CTG is no longer relevant. However, there is a MACT
standard for perchloroethylene dry
cleaners.

VOC CTG Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems

EPA-450/3-78-051
December 1978 Georgia Rule 391-3-1- .02(2)(ss): Emission Limitations and Standards, Gasoline Transport Vehicles and Vapor Collection Systems.

VOC CTG Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners

EPA-450/3-82-009 September 1982 Georgia Rule 391-3-1- .02(2)(qq): Emission Limitations and Standards, Large Petroleum Dry
Cleaners.

VOC ACT Control Techniques for Organic Emissions from Plywood Veneer Dryers, EPA-450/3-83-012, May
1983. Georgia Rule 391-3-1- .02(2)(jj): Emission Limitations and Standards,
VOC Emissions from Surface Coating of Flat Wood Paneling.The Atlanta Eight-Hour Ozone Attainment Demonstration

170 Table 10-2: Source Categories Covered S ection 182(b)(2)(B) of the Clean Air Act

Air

Pollutant Alternative Control Technology (ACT) Reference Document Corresponding State Rule Fulfilling RACT and Notes Concerning the ACT.

This document is labeled as a control technique document (CTD) rather than an ACT. However, the
information is similar to that
in an ACT.

VOC CTG Control of Volatile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins

EPA-450/3-83-008
November 1983 Georgia Rule 391-3-1- .02(2)(qq): Emission Limitations and Standards,
VOC Emissions from Extruded Polystyrene Products Manufacturing Utilizing a Blowing Agent.

VOC CTG Control of Volatile Organic Compound Emissions from Equipment Leaks from Natural Gas/Gasoline Processing Plants

EPA-450/3-83-007
December 1983 No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

VOC CTG Control of Volatile Organic Compound Leaks from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment

EPA-450/3-83-006
March 1984 No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

VOC CTG Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry

EPA-450/3-84-015
December 1984 No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

VOC ACT Reduction of Volatile Organic Compound Emissions from the Application of Traffic Markings, EPA-450/3-88-007, August 1988. The Architectural and
Industrial Maintenance coatings (AIM) national rule
issued in 1998 includes limits for traffic coatings and superseded the ACT.

VOC ACT Reduction of Volatile Organic No existing major sources inThe Atlanta Eight-Hour Ozone Attainment Demonstration

171 Table 10-2: Source Categories Covered S ection 182(b)(2)(B) of the Clean Air Act

Air

Pollutant Alternative Control Technology (ACT) Reference Document Corresponding State Rule Fulfilling RACT and Notes Concerning the ACT. Compound Emissions fromAutomobile Refinishing, EPA450/3-88-009, October 1988. the Atlanta 8-hour ozone
non-attainment area.

VOC ACT Alternative Control Technology Document – Ethylene Oxide Sterilization / Fumigation Operations, EPA 450/3-89-007,
March 1989. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

VOC ACT Alternative Control Technology Document – Halogenated Solvent Cleaners, EPA-450/3-89-030, August 1989. No existing major sources in
the Atlanta 8-hour ozone
non-attainment area.

VOC ACT Control of VOC Emissions from Polystyrene Foam Manufacturing, EPA-450/3-90-020, September
1990. Georgia Rule 391-3-1- .02(2)(eee): Emission Limitations and Standards,
VOC Emissions from Expanded Polystyrene Products Manufacturing; and

Georgia Rule 391-3-1- .02(2)(qqq): Emission Limitations and Standards,
VOC Emissions from Extruded Polystyrene Products Manufacturing Utilizing a Blowing Agent.

Table 10-4 specifies the metro Atlanta area facilities whose operations have potential VOC or NOx emissions greater than 100 tons per year and have process equipment
covered under a CTG and/or AC T covered under th is chapter.

10.2.3 RACT Demonstration for Non-CTG Source Categories Covered Section 182(b)(2)(C) of the Clean Air Act

Section 182(b)(2)(C) of the C AA pertains to non-CTG [and non-ACT] major stationary
sources of VOCs and NOx located in the metro Atlanta area. Identification of applicable sources came by reviewing the state results of the Consolidated Emissions Reporting Rule (CERR) and Georgia EPD’s permitting database.

The major source thresholds used in this anal ysis is 100 tons per year for VOC and/or
NOx emissions in accordance with the 8-hour ozone implementation rule. Georgia EPD reviewed the 2002 emission inventory database required by the Consolidated EmissionsThe Atlanta Eight-Hour Ozone Attainment Demonstration

172 Reporting Rule (CERR) for emission source s that reported 100 tons per year of VOC
emissions. These sources were reviewed in or der to determine if there are major sources of VOC emissions not covered by a CTG. Si nce any major source of VOC emissions are required to have a Title V operating permit, Georgia EPD also reviewed the Title V database to ensure there were no additional sources of VOC emissions that might have Title V permits or applications pending. Georgia EPD followed the same procedure to find major sources of NOx emissions as was used to find major sources of VOC
emissions.

Table 10-3: Source Categories Covered S ection 182(b)(2)(C) of the Clean Air Act

Air Pollutant Alternative Control Technology (ACT) Reference Document Corresponding State Rule Fulfilling RACT

VOC Volatile Organic Liquid and Handling and Storage Georgia Rule 391-3-1- .02(2)(vv): Emission
Limitations and Standards: Volatile Organic Liquid and Handling and Storage.

VOC Consumer and Commercial Products – Windshield Wiper
Fluids Georgia Rule 391-3-1- .02(2)(aaa): Emission
Limitations and Standards:
Consumer and Commercial
Products

VOC Gasoline Marketing Georgia Rule 391-3-1- .02(2)(bbb): Emission
Limitations and Standards: Gasoline Marketing

VOC Bulk Mixing Georgia Rule 391-3-1- .02(2)(ccc): Emission
Limitations and Standards:
VOC Emissions from Bulk Mixing Tanks

VOC Case-by-Case Georgia Rule 391-3-1- .02(2)(tt): Emission
Limitations and Standards: VOC Emissions from Major

Sources

NOx Case-by-Case Georgia Rule 391-3-1- .02(2)(yy): Emissions of Nitrogen Oxides from Major

Sources

The Georgia EPD stationary source permitti ng program conducted a case-by-case RACT review as part of permit application proce ssing for the applicable sources. The case-bycase RACT reviews were all conducted as part of Georgia EPD’s Title V permit application review. The results of these cas e-by-case RACT reviews were also examined by the permitting program at EPA Region 4 as part of its Title V permitting program. These case-by-case RACT revi ews are contained within EP A Region 4 approved Title VThe Atlanta Eight-Hour Ozone Attainment Demonstration

173air quality permits issued by Georgia EPD. The regulatory authority given for case-bycase RACT reviews is specified by Georgia Rules 391-3-1-.02(2)(tt) and (yy) for VOC and NOx emissions, respectively.

Georgia EPD believes that the existing Georgi a Rule (tt) and Georgia Rule (yy) permit conditions satisfy RACT for purposes of sections 172(c), 182(a), and 182(b) of the CAA. Therefore, Georgia EPD is cert ifying through this SIP revision, that the Georgia Rule (tt) and (yy) permit conditions satisfy RACT requirements of 100 tons per year of more.

Table 10-4 specifies the Georgia air quality permit conditions for metro Atlanta facilities whose potential VOC and/or NOx emissions e qual to or are greater than 100 tons per year that satisfy RACT requirements for non-CTG [and non-ACT] sour ce categories (i.e., case-by-case RACT.The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT DeterminationCase-by-case RACT plan for VOC and NOxincorporated as a whole into air quality permit. Thisplan to be supplied to EPA upon request.1300005BarrowJOHNS MANVILLECORPFiberglass insulationproducts manufacturingfacilityVOCNOx1500011BartowGEORGIA POWERCOMPANY – PLANTBOWENElectric utilityVOCNOxGeorgia Rule 391-3-1-.02(2)(tt) determined to be nocontrols for VOC emissions.Electric utility steam generating units are subject toNOx emission standards specified by Georgia Rule391-3-1-.02(2)(jjj) .Combustion turbines are subject to NOx emissionstandards specified by Georgia Rule 391-3-1-.02(2)(nnn).1500032BartowGERDAU AMERISTEELCORP/Birmingham SESteel MillVOCNOxGeorgia Rule 391-3-1-.02(2)(tt) determined to be noadditional controls for VOC emissions.NOx emissions minimized by requiring that onlynatural gas be burned in the reheat furnace, tundishand tundish nozzle preheaters, tundish dryers, ladlepreheaters, rolling mill cutting torches, ladle dryer,and ladle heater in accordance with Georgia Rule (yy).NOx emissions from the reheat furnace limited to 0.10174The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determinationpounds of NOx per million Btu in accordance withGeorgia Rule (yy) for PSD Avoidance purposes.NOx emissions from the electric arc furnace limited to0.15 pounds of NOx per ton of steel produced inaccordance with Georgia Rule (yy).1500061BartowANHEUSER-BUSCHCOMPANIES INCBeer BreweryVOCNOxGeorgia Rules 391-3-1-.02(2)(tt) was determined to beno controls for VOC emissions.Boilers limited to burning natural gas and/or biogasduring the period May 1 through September 30 exceptduring periods of natural gas curtailment forminimization of NOx emissions per Georgia Rule391-3-1-.02(2)(yy).Permittee must perform annualtune-ups of boilers tominimize NOx emissions per Georgia Rule 391-3-1-.02(2)(yy).175The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determination4500008CarrollSOUTHWIRE COMPANY- COPPER DIVISIONCopper rod productionfacility.VOCRod mill quenching and cooling system must exhaustto the vapor recovery system to minimize VOCemissions in accordance with Georgia Rule (tt).The vapor recovery system (VRS) must exhaust to therod mill shaft furnace during operation of the VRS tominimize VOC emissions in accordance with GeorgiaRule (tt).No additional controls are required for Georgia Rule391-3-1-.02(2)(tt) to minimize VOC emissions.4500012CarrollSOUTHWIRE COMPANY– CARROLLTONBUILDING WIRE PLANTInsulated and noninsulated wire productionfacility.VOC4500038CarrollSOUTHWIRECOMPANY-MACHINESERVICESOperation of a wiremanufacturing facilityalong with machiningequipment.VOCVOC emissions from the paint booth are minimized inaccordance with Georgia Rule(tt) through the use ofcoatings with no more than 3.5 lbs VOC/gallon ofcoating minus water. If that limit cannot be met, thePermittee must comply with the solids equivalent limitof 6.67 lbs VOC/gallon of coating solids delivered tothe coating applicator.4500043CarrollSOUTHWIRE COMPANY- COFER TECHNOLOGYCENTERResearch andDevelopment forSouthwire CompanyVOCNo additional controls are required for Georgia Rule391-3-1-.02(2)(tt) to minimize VOC emissions.176The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determination4500051CarrollSOUTHWIRECOMPANY-CORPORATEENERGY MGMTProvides emergency andpeaking power to coowned and co-locatedSouthwire CompanyVOCNOxNo additional controls are required for Georgia Rule391-3-1-.02(2)(tt) to minimize VOC emissions.IC engines listed at 1,552 hp are subject to GeorgiaRule (mmm) to minimize NOx emissions.IC engines are subject to Part 63 Subpart ZZZZ (RICEMACT).4500052CarrollSOUTHWIRE COMPANY– CARROLLTONUTILITY PRODUCTSInsulated and noninsulated wire productionfacility.VOCVOC emissions from the paint booth are minimized inaccordance with Georgia Rule(tt) through the use ofcoatings with no more than 3.5 lbs VOC/gallon ofcoating minus water. If that limit cannot be met, thePermittee must comply with the solids equivalent limitof 6.67 lbs VOC/gallon of coating solids delivered tothe coating applicator.177The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determination5700036CherokeeATLANTA GAS LIGHTCO LNG PLANT/CherokeeLNGLiquefied Natural GasPlant.NOxTurbine T1 is subject to a NOx emission limit of 128ppmv @ 15% oxygen in accordance with GeorgiaRule (yy). This turbine is subject to case-by-caseRACT due to age and/or size.IC engines with source codes C1, C2, G1, G2, G3, andG4 are subject to a NOx emission standard of 139ppmv @ 15% oxygen in accordance with GeorgiaRule (yy). These IC engines are also subject toGeorgia Rule (mmm); however, the Permittee hasaccepted a more stringent NOx emission limit forpurposes of NSR avoidance.Vaporizer Boilers with sources codes VB1 throughVB9 are subject to Georgia Rule (rrr) for NOxemissions.6300059ClaytonDELTA AIR LINES INCATLANTA STATIONOperation of a facilitythat services airports andflying vehicles.VOCSurface coating operations are subject to Georgia Rule(kkk) and the Aerospace MACT to minimize VOCemissions.Petroleum storage tanks are subject to Georgia Rule(bb) to minimize VOC emissions.Gasoline dispensing facility is subject to GeorgiaRules (rr) and (zz) to minimize VOC emissions.178The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT DeterminationNOx and VOCSolvent metal cleaning operations shall comply withGeorgia Rule (ff) to minimize VOC emissions.IC engines can only be used to generate electricitywhen electric power is not available from the localutility or during test runs conducted for maintenancepurposes for no more than 200 hours each in anyconsecutive 12-month period.6300105ClaytonDELTA AIR LINESTECHNICALOPERATIONS CTROperation of a facilitythat services airplanes.VOCNOx and VOCAerospace surface coating and/or reworkingoperations are subject to Georgia Rule (kkk) [andAerospace MACT, Part 63 Subpart GG] to minimizeVOC emissions.Non-aerospace surface coating and/or reworkingoperations are subject to Georgia Rules (ff) and (vv)and work practice standards of Georgia Rule (kkk) tominimize VOC emissions.IC engines can only be used to generate electricitywhen electric power is not available from the localutility or during test runs conducted for maintenancepurposes for no more than 200 hours each in anyconsecutive 12-month period.179The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT DeterminationPerform annual tune-ups in accordance withmanufacturer’s recommendations for externalcombustion equipment.Only fire natural gas in IC engines and externalcombustion equipment except during periods ofnatural gas curtailment.Boiler rated at or near 61 MMBtu/hr is subject toGeorgia Rule (lll) to minimize NOx emissions.12100807ClaytonDELTA AIRLINES –GENERAL OFFICEOperation of a facilitythat services airplanes.VOCNOx and VOCNon-aerospace surface coating and reworkingoperations are subject to the work practice standardsof Georgia Rule (kkk) to minimize VOC emissions.Non-aerospace solvent cleaning operations mustcomply with Georgia Rule (ff).Cleaning of non-aerospace spray guns must complywith the cleaning provisions of Georgia Rule (kkk),namely subparagraph 7.Gasoline dispensing facility operations must complywith Georgia Rules (rr) and (zz).IC engines in the following equipment groups operate180The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT DeterminationNOxunder hours of operation limits in any twelveconsecutive months to minimize NOx and VOCemissions under Georgia Rules (tt) and (yy):Equipment Group IC 21: 4000 hoursEquipment Group IC22: 2256 hoursEquipment Group IC23: 1500 hoursEquipment Group IC24: 3500 hoursIC engines in Equipment Groups IC21, IC22, IC23,and IC24 shall comply with Georgia Rule (mmm) tominimize NOx emissions.6700022CobbAUSTELL BOX BOARDCORP/Caraustar IndustriesFacility produces paperfrom recycledwastepaper.NOxSubject to Georgia Rule 391-3-1-.02(2)(yy).Diesel Fueled Emergency Firefighting Pump operatesonly 380 hrs per any 12-month period.Coal-fired boiler is subject to a NOx emissionstandard of 0.38lbs/MMBTU heat input (30-dayrolling average) from May 1 through September 30th.Coal-fired boiler is subject to a NOx emissionstandard of 0.65lbs/MMBTU heat input remainder ofyear – 30 day rolling average.Coal-fired boiler: Annual inspections of combustion181The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determinationair pre-heater and boiler burners, extensive burnerthroat repairs and combustion air pre-heater sealmaintenance. Every 1000 hrs preventativemaintenance on 3 pulverizers and classifiers that feedcoal to boiler.Tune-ups on standby boilers at approximately 36month intervals.6700003CobbGA POWER CO PLANTMCDONOUGHGeorgia Rule 391-3-1-.02(2)(tt) determined to be nocontrols for VOC emissions.Electric utility steam generating units are subject toNOx emission standards specified by Georgia Rule391-3-1-.02(2)(jjj) .Electric utilityVOCNOxCombustion turbines are subject to NOx emissionstandards specified by Georgia Rule 391-3-1-.02(2)(nnn).6700074CobbCOLONIAL PIPELINECOMPANY– ATLANTAJUNCTIONPipeline breakout facilityfor refined petroleumproductsVOCGasoline storage tanks are subject to Georgia Rules391-3-1-.02(2)(bb) and (bbb) to minimize VOCemissions.7700001GA POWER CO PLANTYATESElectric utilityVOCCowetaGeorgia Rule 391-3-1-.02(2)(tt) determined to be nocontrols for VOC emissions.182The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT DeterminationNOxElectric utility steam generating units are subject toNOx emission standards specified by Georgia Rule391-3-1-.02(2)(jjj) .Combustion turbines are subject to NOx emissionstandards specified by Georgia Rule 391-3-1-.02(2)(nnn).7700010CowetaNos. 5 and 6 furnaces subject to 40 CFR Part 63,Subpart RRR for VOC emissions.Wet paint coating operation is subject to Georgia Rule391-3-1-.02(2)(ii) to minimize VOC emissions.BON L.MANUFACTURINGCOMPANY, INC.Aluminum ExtrusionFacilityVOCNOx emissions from the furnaces, ovens, and boilerare subject to Georgia Rule 391-3-1-.02(2)(yy).Boiler can only combust natural gas or propane inaccordance with Georgia Rule 391-3-1-.02(2)(yy).NOxNo. 5 Furnace shall only burn natural gas during themonths of May through September. Propane may beused as an alternative if natural gas supply is curtailed.Annual tuneup required to optimize boiler183The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determinationperformance as it relates to NOx and CO emissions.No. 6 Furnace shall only burn natural gas during themonths of May through September. Propane may beused as an alternative if natural gas supply is curtailed.Permittee shall not operatefurnace with an excess airpercentage of greater than 10%.NOx emissions from brite dip operation must beminimized by the use of a caustic scrubber whichmust provide at least 25% NOx removal duringoperation of brite dip system.Subject to Georgia Rule 391-3-1-.02(2)(yy). Burnonly natural gas and propane in boiler. Burn onlynatural gas on other equipment during ozone seasonexcept during times of curtailment – LPG acceptableas alternative. Operate caustic scrubber for brite dipoperation to provide 25% removal of NOx. Tune No.5 furnace burners to optimize fuel/air ratio andoperating point with least NOx emissions (corrected to3% oxygen) and safe CO levels in exhaust. Excess airin No. 6 furnace less than 10%.184The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determination8900086DeKalbGENERAL MOTORSMIDSIZE CAR DIV. -DORAVILLEAutomobile and lightduty truck assembly plantVOCNOxPlant is closed and their air quality permit has beenrevoked. Georgia EPD is awarding GM VOC andNOx emission credits.8900100\DeKalbCHEVRON PRODUCTSCOBulk Gasoline TerminalVOCGasoline storage tanks subject to Georgia Rules 391-3-1-.02(2)(bb), (cc), (nn) (ss), and (bbb) to minimizeVOC emissions.Gasoline transport vehicles are subject to GeorgiaRule (ss) to minimize VOC emissions.Loading rack for gasoline terminal is limited to aVOC emission standard of 0.67 pounds of VOC per1000 gallons of gasoline transferred per Georgia Rule(cc).8900121DeKalbMAGELLANTERMINALS HOLDINGSLP #2/ConocoOperation of a bulkgasoline terminal.VOCVOC emissions minimized facility-wide inaccordance with Georgia Rule 391-3-1-.02(2)(bbb)and 40 CFR part 63 Subpart R.185The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT DeterminationVOC emissions from internal floating roof tanksminimized in accordance with Georgia Rules 391-3-1-.02(2)(bb) and (vv) as well as 40 CFR Part 60Subparts K and Kb.VOC emissions from external floating roof tanksminimized in accordance with Georgia Rules 391-3-1-.02(2)(bb) and (nn).VOC emissions from gasoline loading racksminimized in accordance with Georgia Rules 391-3-1-.02(2)(cc) and (ss).8900128DeKalbTRANSMONTAIGNETERMINALING, INC.Operation of a bulkgasoline terminal.VOCVOC emissions minimized facility-wide inaccordance with Georgia Rule 391-3-1-.02(2)(bbb). .VOC emissions from internal floating roof tanksminimized in accordance with Georgia Rules 391-3-1-.02(2)(bb)as well as 40 CFR Part 60 Subpart Kb.VOC emissions from external floating roof tanksminimized in accordance with Georgia Rules 391-3-1-.02(2)(nn).186The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT DeterminationVOC emissions from gasoline loading racksminimized in accordance with Georgia Rules 391-3-1-.02(2)(cc) and (ss).8900224DeKalbDART CONTAINERCORPORATION OFGEORGIAOperation of anexpandable polystyrenecontainer manufacturingplant.VOCNOxSolvent metal cleaning operations are subject toGeorgia Rule (ff).Storage tanks with a capacity equal to or greater than20,000 gallons are subject to Georgia Rule (vv).EPS process is subject to Georgia Rule (eee).NOx emissions from the boilers are subject to GeorgiaRule (rrr), namely annual tune-ups in accordance withmanufacturer recommendations and the firing of onlynatural gas, pentane, LPG, or propane May throughSeptember.8900005DeKalbCENTERS FOR DISEASECONTROL (CDC)Public health researchNOxSubject to Georgia Rules 391-3-1-.02(2)(lll) and(mmm).08900131DeKalbMOTIVA ENTERPRISESDORAVILLE COMPLEXOperation of a bulkpetroleum, marketingterminalVOCSubject to Georgia Rules 391-3-1-.02(2)(bb), (cc), and(ss).11700005ForsythAMERICAN PROTEINSINC CUMMING DIVPoultry RenderingFacilityVOCCase-by-case RACT plan for VOC emissions isincorporated as a whole into air quality permit. Thisplan to be supplied to EPA upon request.187The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT DeterminationCummingNOxNOx emissions from boilers subject to Georgia Rule(rrr) – do not fire No. 2 fuel oil during the period ofMay 1 through September 30, except during periodsof natural gas curtailment.12100021FultonOWENS CORNINGINSULATING SYSTEMS,LLCOperation of a woolfiberglass insulationmanufacturing facilityVOCNOxVOC emissions from furnaces, forming sections,curing ovens, and cooling sections minimized inaccordance with 40 CFR Part 63 Subpart NNN.Subpart NNN requirements determined to besufficient to meet requirements of Georgia Rule 391-3-1-.02(2)(tt).VOC emissions from flexographic printing minimizedin accordance with Georgia Rule 391-3-1-.02(2)(mm).NOx emissions from glass melting furnacesminimized in accordance with Georgia Rule 391-3-1-.02(2)(yy) through the use of customized burners andwith a NOx emission limit per furnace of 13.5 poundsof NOx per ton of molten glass pulled.NOx emissions from risers, forehearths, formingoperations, and curing ovens minimized in accordancewith Georgia Rule 391-3-1-.02(2)(yy) through the useof customized burners and low NOx burners.188The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determination12100070FultonMEADWESTVACOPACKAGING SYSTEMSLLCOperation of a printedpaperboard cartonmanufacturing plant.VOCVOC emissions from storage tank minimized inaccordance with Georgia Rule 391-3-1-.02(2)(vv).VOC emissions from flexographic and rotogravureprinting operations minimized in accordance withGeorgia Rule 391-3-1-.02(2)(mm).04500039CarrollPRINTPACK INCManufacturing of flexiblepackaging materialsVOCVOC emissions from flexographic presses minimizedin accordance with Georgia Rule 391-3-1-.02(2)(mm).VOC emissions from extrusion laminators minimizedin accordance with Georgia Rule 391-3-1-.02(2)(w).VOC emissions from solvent storage tanks minimizedin accordance with Georgia Rule 391-3-1-.02(2)(vv).VOC emissions from solvent metal cleaningminimized in accordance with Georgia Rule 391-3-1-.02(2)(ff).12100221FultonChattahoochee BPTerminalOperation of a bulkgasoline terminalVOCFacility-wide VOC emissions minimized inaccordance with Georgia Rule 391-3-1-.02(2)(bbb).VOC emissions from internal floating roof tanksminimized in accordance with Georgia Rule 391-3-1-.02(2)(nn). On internal floating roof tank is alsosubject to 40 CFR Part 60 Subpart K.189The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT DeterminationVOC emissions from external floating roof tanksminimized in accordance with Georgia Rule 391-3-1-.02(2)(bb).VOC emissions from gasoline loading rack minimizedin accordance with Georgia Rules 391-3-1-.02(2)(cc)and (ss).12100334FultonOWENS CORNINGROOFING ANDASPHALT, LLCOperation of an asphaltroofing and asphaltprocessing and storagefacility.VOCNOxVOC emissions from applicable bulk mixing tanksminimized in accordance with Georgia Rule 391-3-1-.02(2)(ccc).VOC emissions from applicable storage tanksminimized in accordance with Georgia Rule 391-3-1-.02(2)(vv).NOx emissions from asphalt blowing stills minimizedin accordance with Georgia Rules 391-3-1-.02(2)(yy)and (rrr). Georgia Rule (yy) establishes a NOxemission limit per still of 0.08 pounds of NOx per tonof asphalt charged. Georgia Rule (rrr) requires, in thiscase, annual tune-ups in accordance withmanufacturers recommendations and the burning of190The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determinationnatural gas, LPG, or propane during May throughSeptember of each year.NOx emissions from “small” pieces of fuel burningequipment minimized in accordance with GeorgiaRule 391-3-1-.02(2)(rrr) – annual tune-ups inaccordance with manufacturers recommendations andthe burning of natural gas, LPG, or propane duringMay through September of each year.12100020FultonOWENS-BROCKWAYGLASS CONTAINERINC.Operation of a glasscontainer manufacturingplant.NOxSubject to Georgia Rule 391-3-1-.02(2)(yy). NOxemissions from the glass melting furnaces no morethan 5.50 lbs per ton ofglass produced when the glassmelting furnaces are not idling (not operating at lessthan 25% of production capacity) except GlassFurnace E at less than 3.5 lbs/ton of glass produced.12100705FultonSPURLIN INDUSTRIES,INC.Operation of a reinforcedfiberglass bath productsmanufacturing facilityVOCSubject to Georgia Rule 391-3-1-.02(2)(tt).12100254FultonPPG ARCHITECTURALFINISHES, INC.Operation of a coatingmanufacturing facilityVOCSubject to Georgia Rules 391-3-1-.02(2)(ff), (vv), and(ccc).13900002HallCARGILL INC.-CARGILL’SGAINESVILLEVEGETABLE OIL MILLOperation of avegetable/soy oil mill andan edible oil refinery.VOCSubject to Georgia Rule 391-3-1-.02(2) (tt).RACT determined to beimplementation of MACTrequirements for all isomers of hexane. Limit of 0.2gallons of hexane (all isomers) per tons of soybeans191The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determination& REFINERYNOxprocessed during any12-month period. All monitoringand recordkeeping requirements of the MACT apply.No reductions of HAP as a result of MACTimplementation since the facility switched to a nonHAP isomer of hexane in 1998.Applicable storage tanks are subject to Georgia Rule(vv) for minimization of VOC emissions.Subject to Georgia Rule 391-3-1-.02(2)(yy): NOxemission limit for the coal-fired boiler of 0.41lb/MMBtu and annual tune-ups for all boilers, thereformer, and dryer.13900075HallINDALEX AMERICA INCOperation of analuminum buildingproducts manufacturingand coating facility.VOCVOC emissions from surface coating operationsminimized in accordance with Georgia Rule 391-3-1-.02(2)(ii) and 40 CFR Part 63 Subpart MMMM.15100025HenryStockbridgeTRANSCONTINENTALGAS PIPE LINE STA 120Operation of a natural gascompressor stationVOCVOC emissions from IC engines minimized inaccordance with Georgia Rule 391-3-1-.02(2)(tt)through the use of “Good Combustion ControlPractices” which includes fire only natural gas instationary engines and turbines. Reciprocatingengines must have maintained electronic ignitioncontrollers. Preventative maintenance on combustionequipment including recordkeeping of said192The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT DeterminationNOxmaintenance.NOx emissions from IC engines minimized inaccordance with Georgia Rule 391-3-1-.02(2)(yy)with an ozone season limit of 6.0 grams perhorsepower-hour.21700024NewtonPACTIVE CORPCovington PolystyreneFoam ProductsOperation of apolystyrene foampackaging manufacturingfacility.VOCSubject to Georgia Rule 391-3-1-.02(2)(qqq).21700033GENERAL MILLSOPERATIONS INCOperation of a dry cerealmanufacturing facility.NOxNOx emissions from boiler minimized in accordancewith Georgia Rule 391-3-1-.02(2)(lll).25500047SpaldingEXOPACK LLCOperation of apolyethylene filmproduction and printingfacility.VOCVOC emissions from flexographic printing minimizedin accordance with Georgia Rule 391-3-1-.02(2)(mm).VOC emissions from chemical storage tankminimized in accordance with Georgia Rule 391-3-1-.02(2)(vv).193The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determination25500049SpaldingCOOPER-STANDARDAUTOMOTIVE, INCOperation of an extrudedrubber gasket and sealmanufacturing facilityVOCSpray coating booth on the plastic coating line islimited to 5.0 pounds of VOC per gallon of coatingminus water in accordance with Georgia Rule (tt).All other operations deemedto require no additionalVOC control in accordance with Georgia Rule (tt).29700036WaltonSocial CircleTHE GOODYEAR TIRE& RUBBEROperation of a rubbertread manufacturingfacilityVOCVOC emissions from banbury mixers, dump mills,finish mills, extruders, tread presses, and tread buffersminimized in accordance with Georgia Rule 391-3-1-.02(2)(tt) which in this case was determined to be noadditional VOC control. VOC emissions from theseprocess units also minimized in accordance with 40CFR Part 63 Subpart XXXX.VOC emissions from platen tread cementers numbers1 and 2 to be minimized in accordance with GeorgiaRule 391-3-1-.02(2)(tt) which in this case is theoperation of regenerative thermal oxidizers with aminimum VOC removal efficiency of 97.0%.VOC emissions from platen tread dryers numbers 1and 2 to be minimized in accordance with GeorgiaRule 391-3-1-.02(2)(tt) which in this case is theoperation of regenerative thermal oxidizers with a194The Atlanta Eight-Hour Ozone Attainment DemonstrationTable 10-4: Metro Atlanta Permitted Sources whose VOC and/or NOx Emissions Equal or Exceed 100 tons per yearAIRSNumberGeorgiaCountyNameCompany NameSource DescriptionFor WhichOzonePrecursor?RACT Determinationminimum VOC removal efficiency of 97.0%.VOC emissions from ring tread cementer number 1 tobe minimized in accordance with Georgia Rule 391-3-1-.02(2)(tt) which in this case is the operation of aregenerative thermal oxidizer with a minimum VOCremoval efficiency of 97.0%.29700037TRANSCONTINENTALGAS PIPE LINE STA 125Operation of a natural gaspumping stationNOxNOx emissions minimizedfrom combustion turbinesin accordance with Georgia Rule 391-3-1-.02(2)(yy)with a NOx limit of 15.2 pounds per hour per turbine.29700040MPC Generating, LLCElectric utilityNOxSubject to Georgia Rule 391-3-1-.02(2)(nnn).29700041DOYLE GENERATINGFACILITYElectric utilityNOxSubject to Georgia Rule 391-3-1-.02(2)(nnn).29700042WALTON COUNTYPOWER LLC/LG&EPower/Monroe LLCElectric utilityNOxSubject to Georgia Rule 391-3-1-.02(2)(nnn).195The Atlanta Eight-Hour Ozone Attainment Demonstration

196 

## 11.0 INFRASTRUCTURE SIP ELEMENTS

Section 110(a) of the Clean Air Act (CAA) re quires states to submit an implementation plan to the U.S. EPA Administrator that provides for implementation, maintenance, and enforcement of national ambient air quality standards (NAAQS). Section 110(a)(2) lists the elements that are to comprise the implementation plan. Several of the elements in §110(a)(2) specifically a ddress the need for states to demonstrate the ability to implement, maintain, and enforce the air quality standards. These elements are sometimes compiled and submitted separately in wh at is referred to as an “infrastructure” SIP. This document is the Georgia EPD infrastructure SIP for the 1997 ozone NAAQS.

The elements of §110(a)(2) are listed below.

• Enforceable Emission Limitations and Ot her Control Measures [§110(a)(2)(A)]

• Air Quality Monitoring, Compilation, Data Analysis, and Reporting [§110(a)(2)(B)]

• Enforcement and Stationary Source Permitting [§110(a)(2)(C)]

• Interstate Transpor t (§110(a)(2)(D))

• Resources, Conflict of Interest, a nd Emergency Backstop [§110(a)(2)(E)]

• Stationary Source Emissions Monito ring and Reporting [§110(a)(2)(F)]

• Emergency Powers and Contingency Plans [§110(a)(2)(G)]

• SIP Revision for Revised Air Quality Standards or New Attainment Methods [§110(a)(2)(H)]

• SIP Revisions for New Nonatta inment Areas [§110(a)(2)(I)]

• Consultation and Public Notification [§110(a)(2)(J)]

• Air Quality Modeling and Reporting [§110(a)(2)(K)]

• Major Stationary Source Pe rmitting Fees [§110(a)(2)(L)]

• Consultation with Local Entities [§110(a)(2)(M)]

Most of these elements are addressed in the comprehensive §110(a )(2) SIP submitted by the state of Georgia in response to the CA A of 1970 and approved by U.S. EPA as noted in 40 CFR Parts 52 Subpart L. This submittal continues to affirm Georgia EPD’s commitment to comply with §110(a)(2) requir ements and incorporated by reference into
this submittal.

The purpose of this document is to examin e Georgia’s State Implementation Plan (SIP) and determine if all necessary implementation, maintenance, and enforcement measures for the 1997 ozone National Ambient Air Qual ity Standard (NAAQS) are in place.The Atlanta Eight-Hour Ozone Attainment Demonstration

197 

## GEORGIA’S APPROACH

Section 110(a)(2) of the Clean Air Act Amendm ents of 1990 provides a detailed listing of various requirements for Georgia’s SI P regarding the NAAQS. Below, each subparagraph from (A) through (M) is broken down, with various provisions supporting the requirements.

______________________________________________________________________

§110(a)(2) of the Clean Air Act (Subparagraphs A-M) EPA and Georgia Requirements

_______________________________________________________________________

(A) EPA Requirement:

Include enforceable emission limitations and other control measures, means, or techniques (including economic incentives such as fees, marketable permits, and auctions of emissions rights), as well as schedules and timetables for compliance.

Georgia Requirements

• Georgia Rules for Air Quality 391-3-1-.01 – “Definitions. Amended”’

• Georgia Rules for Air Quality 391-3- 1-.02 – “Provisions. Amended”; and

• Georgia Rules for Air Quality 391-3-1-.03 – “Permits. Amended”.

________________________________________________________________________

(B) EPA Requirement – Air Quality Moni toring, Compilation, Data Analysis, and Reporting:

Provide for establishment and operation of devices, methods, systems, and procedures to: (i) monitor, compile, a nd analyze data on ambient air quality, and (ii) make such data available to EPA.

Georgia Requirement:

As early as 1957, the state of Georgia has monitored air pollutant s. Prior to the CAA of 1970, the state health department conducted air monitoring. In the early 1970’s the Georgia EPD assumed responsibilities for ambient air monitoring to facilitate the identification and control of air contaminants in Georgia.

Georgia EPD produces an annual ambient monitoring network plan and periodic network assessment in accordance with 40 CFR 58.10. The purpose of the annual ambient monitoring network plan is two-fol d. First, the plan confirms that the
network continues to meet the State and Local Air Monitoring Stations (SLAMS) criteria established by federa l regulations, and that the in formation in the state and federal monitoring records properly classi fy each monitoring station. Second, theThe Atlanta Eight-Hour Ozone Attainment Demonstration

198 plan serves as a directory of existing State and Local Air Monitoring Stations (SLAMS), Photochemical Assessment Mon itoring Stations (PAMS), Speciation Trends Network (STN) and Supplemental Speciation sites, National Air Toxics Trends Station (NATTS), Sp ecial Purpose Monitoring (SPM), Georgia Air Toxics Network, Acid Rain sites, and the meteorological parameters performed at each
location.

Georgia’s authority to monitor ambient ai r quality is found in Georgia Air Quality Article 1: Air Quality O.C.G.A. Section 12-9, et seq.

Performance Partnership Agreement ( PPA) between EPA and the State of Georgia establish the obligat ion to operate an ambient monitoring network that complies with applicable federal regulation(s).

No specific statutory or re gulatory authority is necessary to authorize data analysis or the submission of such data to EPA. Federal grant requirements establish the obligation to provide data to EPA.

Georgia has and will continue to subm it data to EPA’s Air Quality System.

________________________________________________________________________

(C) EPA Requirement – Enforcement and Stationary Source Permits:

Include a program to provide for enforcem ent of measures in (A), and regulation
of the modification and cons truction of any stationary source within the areas covered by the plan as necessary to assu re that NAAQS are achieved, including a permit program as required in parts C and D.

Georgia Requirement - Enforcement: Georgia EPD’s Enforcement Program covers mobile and stationary source s, consumer products, and fuels.

Georgia’s enforcement authority is found in Georgia Air Quality Article 1: Air Quality O.C.G.A. Section 12-9, et seq.

Memorandum of Agreement between Georgia EPD and the U.S. EPA.

Performance Partnership Agreement.

Georgia Rule 391-3-1-.07 – “Inspecti ons and Investigations. Amended”

Georgia Rule 391-3-1-.09 – “Enforcement. Amended”

Georgia Requirement – Stationary Source Permitting:

Georgia Air Quality Article 1: Air Quality O.C.G.A. Section 12-9, et seq.

Georgia Rules for Air Quality 391-3-1-.02. - “Provisions. Amended” including:The Atlanta Eight-Hour Ozone Attainment Demonstration

199 PSD requirements under Georgia Rule s for Air Quality 391-3-1-.02(7).

Georgia Rules for Air Quality 391-3-1-.03. – “Permits. Amended” including:

NSR requirements under Georgia Rule s for Air Quality 391-3-1-.03(8).

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(D) EPA Requirement – Interstate Transport:

(i) Contain adequate provisions prohib iting any source or other type of emissions activity from emitting any air pollutant in amounts which
will:

(I) contribute significantly to nonatta inment in, or interfere with maintenance by, any other State with respect to any such national primary or secondary ambient air quality standard.

Georgia Requirement:

• Permitting requirements under Georgia Rule 391-3-1-.03 and
Nonattainment New Source Review re gulations under Georgia Rule 391- 3-1-.03(8).

• Interstate transport requirements under Georgia Rules 391-3-1-.02(12) and 391-3-1-.02(13) per the Clean Air Interstate Rule.

EPA Requirement:

(i) Contain adequate provisions prohib iting any source or other type of emissions activity from emitting any air pollutant in amounts which
will:

(II) interfere with measures required to be included in the applicable implementation plan for any other State under part C to prevent significant deterioration of air quality or to protect visibility.

Georgia Requirement:

• PSD requirements under Georgia Rule for Air Quality 391-3-1-.02(7).

• Georgia is required to develop an d implement a Regional Haze State Implementation Plan to protect visi bility. In addition, Georgia is developing and implementing a PM2.5 SI P that will assi st with reducing visibility-reducing pollutants.The Atlanta Eight-Hour Ozone Attainment Demonstration

200 EPA Requirement:

(ii) Insure compliance with the applicable requirem ents of sections 126 and 115 of the Clean Air Act (interstate a nd international pollution abatement).

Georgia Requirement:

• Georgia Air Quality Article 1: Air Quality O.C.G.A. Section 12-9, et seq.

• PSD regulation under Georgia Rule for Air Quality 391-3-1-.02(7).

• Permitting regulations under Georgia Rule for Air Quality 391-3-1-.03.

• In addition, nothing in Georgia’s statutory or regulatory authority prohibits or otherwise interferes with Georgia’s ability to exercise sections 126 and 115 of the CAA.

________________________________________________________________________

(E) EPA Requirement – Resources, Conflict of Interest, and Emergency Backstop:

Provide:

(i) necessary assurances that the State will have adequate personnel, funding, and authority under State law to carry out such implementation plan (and is not pr ohibited by any provision of Federal or State law from carrying out such plan).

Georgia Requirement:

• This is accomplished through the CAA section 105 grant process , Georgia Air Quality Act Article 1: Air Qu ality O.C.G.A. 12-9-10, and Georgia Rule for Air Quality 391-3-1-.03(9) [Georgia Air Permit Fee System].

EPA Requirement:

(ii) Requirements that the State comply with the requirements respecting State
boards under section 128 of the Clean Air Act.

Georgia Requirement:

• Georgia’s authority is found in Georgia Air Quality Article 1: Air Quality O.C.G.A. Section 12-9, et seq.The Atlanta Eight-Hour Ozone Attainment Demonstration

201 EPA Requirement:

(iii) Necessary assurance that, where the State has relied on a local or regional government, agency, or instrumentality for the implementation of any plan provision, the State has responsibil ity for ensuring adequate of implementation of such plan provision.

Georgia Requirement:

• Georgia does not rely on localitie s for specific SIP implementation.

______________________________________________________________________

(F) EPA Requirement – Stationary Source Emissions Monitoring and Reporting:

Require, as may be prescribed by EPA:

(i) installation, maintenance, an d replacement of equipment, and implementation of other necessary st eps, by owners or operators of stationary sources to monitor emissions.

(ii) Periodic reports on the nature a nd amounts of emissions and emissionsrelated data.

(iii) Correlation of such reports by the State agency with any emission limitations or standards established pur suant to CAA, which reports shall
be available at reasonable times for public inspection.

Georgia Requirement: 40 CFR Part 51.214 require s every SIP to include requirements for the monitoring of emissions from major stationary sources as specified in 40 CFR Part 51 Appendix P. Georgia EPD has adopted regulations to implement these requirements.

• The Georgia Air Quality Act: Article I: Air Quality (O.C.G.A. Section 12-9, et. Seq.)

• Georgia Rule for Air Qualit y 391-3-1-.02(3) – “Sampling”.

• Georgia Rule for Air Quality 391- 3-1-.02(6) – “Source Monitoring”.

• Georgia Rule for Air Quality 391-3-1-.02(11) – “Compliance Assurance Monitoring.”

• Georgia Rule for Air Quality 391-3-1-.03 – “Permits. Amended”.

______________________________________________________________________The Atlanta Eight-Hour Ozone Attainment Demonstration

202 (G) EPA Requirement – Emergency Powers and Contingency Plans:

Provide for authority comparable to that in §303 and adequate contingency plans to implement such authority. Section 303 provides legal authority to the U.S. EPA to halt the emission of air pollutant s causing or contribu ting to injury to public or welfare. U.S. EPA is authorized to either bring a lawsuit in federal court or, if such civil acti on cannot assure prompt protection of public health or welfare, to issue such orders as may be necessary to protect public health or welfare or the
environment.

The requirement for states to provide ad equate contingency plans to implement such authority is intended to establish emergency epis ode plans for responding to elevated pollutant levels in urban areas. Emergency episode plans are required in areas that record ambient pollutant concen trations in excess of threshold levels specified in 40 CFR Part 51.150.

Georgia Requirement:

• The Georgia Air Quality Act: Article I: Air Quality (O.C.G.A. Section 12-9, et. Seq.)

• Georgia Rule for Air Quality 391- 3-1-.04 – “Air Pollution Episodes.”

• January 1972 SIP: “Implementation Plan for Attainment of State and
National Ambient Air Standards” – Air Quality Control Branch, Georgia Department of Public Health (primary pages are 169-266).

_____________________________________________________________________

(H) EPA Requirement – SIP Revisions for Revised Air Quality Standards or New
Attainment Methods:

Provide for revision of such plan:

(i) from time to time as necessary to take account of revisions of such national primary or secondary ambi ent air quality standard or the availability of improved or more ex peditious methods of attaining such
standard.

(ii) except as provided in (3)(C), wh enever EPA finds on the basis of
information available to EPA that th e plan is substantially inadequate to attain the NAAQS which it implemen ts or to otherwise comply with any additional CAA requirements.

Georgia Requirement:

• The Georgia Air Quality Act: Article I: Air Quality (O.C.G.A. Section 12-9, et. Seq.)The Atlanta Eight-Hour Ozone Attainment Demonstration

203 • Performance Partnership Agreement

• Georgia EPD commits to submit SIP revisions whenever revised air quality standards are promulgated by U.S. EPA.

____________________________________________________________________

(I) EPA Requirement – SIP Revisions for New Nonattainment Areas:

In the case of a plan or plan revision for an area designated as a nonattainment area, meet the applicable requirements of part D (relating to nonattainment areas).
States are to submit SIP revisions for newly designated nonattainment areas to meet the requirements of Part D – Plan Requirements for Nonattainment Areas
under Clean Air Act Title I – Air Pollution Pr evention and Control. Part D of the Clean Air Act specifies both general re quirements for all SIPs and specific requirements for different criteria pollutants.

Georgia Requirement:

• The Georgia Air Quality Act: Article I: Air Quality (O.C.G.A. Section 12-9, et. Seq.)

• Georgia Rule for Air Quality 391- 3-1-.02 – “Provisions. Amended”

• Georgia Rule for Air Quality 391-3-1-.03 – “Permits. Amended”

• Georgia EPD commits to submit SIP revi sions whenever areas of the state are newly designated nonattainment fo r any federal ambient air quality
standard.

___________________________________________________________________

(J) EPA Requirement – Consultation and Public Notification:

Meet applicable requirements of §121 (consultation). Section 121 requires that states provide a satisfactor y process of consultation with general purpose local governments, designated organizations of elected officials of local governments, and any affected federal land manager in carrying out CAA requirements.

Georgia Requirement:

• The Georgia Air Quality Act: Article I: Air Quality (O.C.G.A. Section 12-9, et. Seq.)

• Georgia Administrative Proce dures Act (O.C.G.A. §50-13-4)

• Georgia Rule 391-3-1-.02(7) as it relates to Class I areas.The Atlanta Eight-Hour Ozone Attainment Demonstration

204 • Transportation Conformity SIP Revi sion dated April 7, 2000 and approved
in 65 FR 18245. This SIP takes the form of a Memorandum of Agreement (MOA) between the agencies involved including but not limited to the Atlanta Regional Commission, Georgia Department of Transportation, the Metropolitan Atlanta Rapid Trans it Authority, and Georgia EPD.

• Ozone SIP contains equi valent consultation and participation for PM2.5 requirements.

• Georgia EPD commits to maintaini ng a process of consultation with parties designated under Section 121.

EPA Requirement:

Meet applicable requirement s of §127 (public notificati on). Section 127 requires the states to provide measures which will be effective to notify the public on a regular basis of instances or areas in wh ich any air quality standard is exceeded during the preceding calendar year, to advi se the public of the health hazards associated with such pollution, and to e nhance public awareness of measures that can be taken to prevent such standards from being exceeded.

• Georgia EPD forecasts daily ozone and particle levels and issues e-mails to the public, busine sses and the media.

• Daily air quality forecasts may be disse minated to the public in Atlanta via electronic Georgia DOT billboards.

• Non-profit organization “Clean Air Ca mpaign” disseminates statewide air quality information as well as ways to reduce air pollution.

• In addition, air quality calendars display past air quality information and dynamic graphs provide summaries of unhealthy air quality experienced throughout the region. This feature of the web site allows the public to monitor long term air quality and see how one year compares to previous

years.

• Georgia EPD commits to maintaining a public information and education program that satisfies the requirements of Section 127.

EPA Requirement:

Meet applicable requireme nts of Part C (PSD and visibility protection).

Georgia Requirement:

• Georgia Rule for Air Quality 391-3-1- .02(1) – “General Requirements”.The Atlanta Eight-Hour Ozone Attainment Demonstration

205 • Georgia Rule for Air Quality 391-3-1- .02(7) – “Prevention of Significant
Deterioration”.

• Georgia EPD intends to comply with the recently promulgated NSR rules for PM2.5. Per that rule, for PSD, Georgia EPD has up to 3 years to incorporate such changes, until which time Georgia EPD uses PM10 as a surrogate. For Nonattainment NSR, the federal rule requires that Georgia EPD use PM2.5 effective July 15, 2008 under the authority of 40 CFR Part 51 Appendix S. The federal rule does not allow the use of PM10 as a surrogate for PM2.5 in nonattain ment NSR after July 15, 2008.

___________________________________________________________________

(K) EPA Requirement – Air Quality Modeling and Reporting:

(i) Provide for performance of air qual ity modeling as EPA may prescribe for the purpose of predicting the effect on ambient air quality of any emissions of any air pollutant for which EPA has established a NAAQS.

Georgia Requirement:

• The Georgia Air Quality Act: Article I: Air Quality (O.C.G.A. Section 12-9, et. Seq.)

• Inherent in the obligation to meet the NAAQS is the authority for Georgia EPD to perform modeling as required under the CAA to demonstrate
attainment.

EPA Requirement:

(ii) Provide for the submission, upon reque st, of data related to such air quality modeling to EPA.

Georgia Requirement:

• Air quality modeling data is submitted as part of Georgia’s relevant SIP submissions and through federal grant commitments.

______________________________________________________________

(L) EPA Requirement – Major Stat ionary Source Permitting Fees:

Require owner of a major stationary sour ce to pay, as a condition of any permit required under CAA, a fee sufficient to c over: (i) reasonable cost of reviewing and acting upon any permit application, and (i i) if the owner receives a permit, the reasonable costs of implementing and enfo rcing the terms and conditions of the permit (not including court costs or cost s associated with enforcement), until fee requirement is superseded by EPA approval of a Title V fee program.The Atlanta Eight-Hour Ozone Attainment Demonstration

206 Georgia Requirement:

• Georgia Rule for Air Quality 391-3-1-.03(9) – “Permit Fees.”

• Calendar year 2002 was submitted as a SIP revision on June 25, 2003 – appears to be SIP approved.

• Calendar years 2003, 2004, and 2005 were submitted as part of one SIP submittal in July 2006.

• Calendar year 2006 was submitted as a SIP revision on August 22, 2007.

• Georgia EPD commits to implementing a permit fee system in accordance with section 110(a)(2)(M) of the Clean Air Act.

______________________________________________________________

(M) EPA Requirement – Consultation with Local Entities:

Provide for consultation and particip ation by local political subdivisions affected by the plan.

Georgia Requirement:

• The Georgia Air Quality Ac t: Article I: Air Quality (O.C.G.A. Section 12-9, et. Seq.)

• Transportation Conformity SIP Revi sion dated April 7, 2000 and approved
in 65 FR 18245. This SIP takes the form of a Memorandum of Agreement (MOA) between the agencies involved including but not limited to the Atlanta Regional Commission, Georgia Department of Transportation, the Metropolitan Atlanta Rapid Trans it Authority, and Georgia EPD.

• Ozone SIP contains equi valent consultation and participation for the 1997
ozone standard.

______________________________________________________________The Atlanta Eight-Hour Ozone Attainment Demonstration

207 

## 12.0 REFERENCES

Blanchard C.L. and Roth P.M. (1995) Ozone M.A.P.P.E.R. User's Guide – Version 1.1

.

Blanchard C.L., Lurmann F.W., Roth P. M., Jeffries H.E., and Korc M. (1996) The Use of Ambient Data to Corroborate Analys es of Ozone Control Strategies.

Pun, B. K., C. Seigneur, and W. White ( 2003). Day-of-week behavior of atmospheric
ozone in three U.S. cities. J. Air & Waste Management Assoc. 53, 789-801.

Sillman, S., D. He, C. Cardelino, and R. E. Imhoff (1997). The use of photochemical
indicators to ev aluate ozone-NO

x -hydrocarbon sensitivity: Case studies from Atlanta, New York, and Los Angeles. J. Air & Waste Management Assoc. , 47, 1030-1040.

Cohan, D.S., Hu, Y., and Russell, A.G. (2006) , Dependence of ozone sensitivity analysis on grid resolution, Atmospheric Environment 40: 126–135.

Emery, C., E. Tai, and G. Yarwood, 2001: Enhanced meteorological modeling and performance evaluation for two Texas episodes, A report prepared for the Texas Natural
Resources Conservation Co mmission (TNRCC), ENVIRON International Corporation, Novato, CA.

Mass, C. F., D. Ovens, K. Westrick, B. A. Colle, 2002, Does increasing horizontal resolution produce more skillful forecast. Bulletin of American Meteorological Society, 83, 407-430.

EPA, 2007, Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Oz one, PM2.5, and Regional Haze, Office of Air Quality Planning and Standards, Resear ch Triangle Park, NC 27711, EPA-454/B-07-002.

Arunachalam S., Holland A., Do B., and Abraczinskas M. (2006). A quantitative assessment of the influence of grid resolution on predictions of futu re-year air quality in North Carolina, USA. Atmospheric Environment , 40, 5010–5026.

US EPA, OAQPS. Memorandum. Guidan ce on the Reasonably Available Control Measures Requirement and Attainment Demonstration Submissions for Ozone Nonattainment Areas. J.S. Seitz, Director. (no date).

US EPA, OAQPS. 2000. Memorandum. Boundary Guidance on Air Quality Designations for the 8-Hour Ozone National Am bient Air Quality Standards. J.S. Seitz,
Director. March 28.

State of Georgia. 2000. Letter from Roy Ba rnes, Governor of Georgia to Mr. John Hankinson, Regional Administrator, U.S. EP A Region IV with r ecommendations for 8- hour ozone designation status fo r Georgia counties. June 30.The Atlanta Eight-Hour Ozone Attainment Demonstration

208 Atlanta One-Hour Ozone Nonattainment Ar ea Redesignation Request and Maintenance Plan. (no date).

Georgia Department of Natural Resources. Le tter from Harold Rehe is, Director, to Mr. James Palmer, Jr., Regional Administrator, U.S. EPA Region 4 with EPD recommendations for 8-hour ozone designati on status for Georgia counties. July 15.

US EPA, Region 4. 2003. Letter from Mr. Jame s Palmer, Jr., Regional Administrator, to Dr. Carol Couch, Director, Georgia Environm ental Protection Divi sion replying to the
EPD recommendations for 8-hour ozone designation status fo r Georgia counties. Dec. 3.

US EPA. 2005. Federal Regist er, Part II. 40 CFR Parts 51, 52, and 80. Final Rule to Implement the 8-Hour Ozone NAAQS. November 29.

Georgia Department of Natural Resources. 2005 . Environmental Protection Division, Air Branch. Georgia's Redesignation Request and Maintenance Plan for the Atlanta 1-Hour Ozone Nonattainment Area. February 1.

US EPA, OAR. 2007. Memorandum. Decision of the US Court of Appeals for the
District of Columbia Circu it on our Petition for Rehearing for the Phase 1 Rule to Implement the 8-Hour Ozone NAAQS. R.J. Meyers, Acting Assistant Administrator.
June 15.

US EPA. OAR. Technology Transfer Netw ork OAR Policy and Guidance. Memoranda for NAAQS (Title I) – Policy and Guidance Memos. www.epa.gov/ttn/oarpg/t1pgm.html . Accessed 3/26/2007.

US EPA, OAQPS. Memorandum. Transmitta l of NOx Substitution Guidance. J.S. Seitz, Director. December 1993.

US EPA, OAQPS. Memorandum. Novemb er 1994 Submittal Policy. J.S. Seitz,
Director.

US EPA, OAQPS. 1995. Memorandum. Fifteen Percent rate-of-Progress Plans – Additional Guidance. J.S. Seitz, Director. May 5.

US EPA, OAR. Memorandum. Guidance fo r Implementing the 1-Hour Ozone and PreExisting PM10 NAAQS. R.D. Wilson, Acting Assistant Administrator for Air and Radiation. (no date) REF: OZPMRH-5-97.

US EPA. 2005. Federal Register. Vol. 70, No. 228. Rules and Regulations. Appendix A to Preamble. November 29. (Phase II O3 IR, 8-hr O3 RFP Guidance).

US EPA, AQPD. 2006. Memorandum. 8- hr Ozone National Ambient Air Quality Standards Implementation – Reasonable Furt her Progress. W.T. Harnett, Director. August 15.The Atlanta Eight-Hour Ozone Attainment Demonstration

209 US EPA, OAQPS. 2000. Lette r and attachment. Stationary Source Voluntary Measure Draft Policy (6/01/00). J.S. Seitz, Director.

US EPA, OAQPS and OTAQ. 2002. Memo randum. Policy Guidance on the Use of MOBILE6 for SIP Development and Transporta tion Conformity. J.S. Seitz, Director, and M.T. Oge, Directory, OTAQ. January 18.

US OAQPS. Guidance on 5% Increment of Progress (40 CFR 51.905(a)(1)(ii)). L.W. Wegman, Director, Air Quality St rategies & Standards. August 2004.

US EPA, OAQPS. 1995. Memorandum. Fifteen Percent rate-of-Progress Plans – Additional Guidance. J.S. Seitz, Director. May 5.

US EPA, OAQPS. Memorandum. Incorporat ing Voluntary Stationary Source Emission Reduction Programs Into State Implementation Plans – FINAL POLICY. J.S. Seitz, Director. (no date)

US EPA, OAQPS. 2006. Memorandum. S upporting Innovative Strategies to Keep Communities' Air Clean 8-Hour Ozone Flex (8 -O3 Flex) Program. S.D. Page, Director. May 18.

US EPA. AQPD. 2006. Note. RACT Qs & As – Reasonably Available Control Technology Questions and Answers. W.T. Harnett, Director. May 18.

US EPA. 2006. Memorandum. To Dr. G. Gr ay, Assistant Administrator, ORD, Bill Wehrum, Acting Assistant Administrator, OAR. Process for Reviewing National Ambient Air Quality Standards. M. Peacock Deputy Administrator. December 7.

US EPA. OAQPS and OTAQ. 2006. Memo randum. Removal of Stage II Vapor Recovery in Situations Where Widespread Us e of Onboard Refueling Vapor Recovery is Demonstrated. S.D. Page, Director, OAQPS and M.T. Oge, Director, OTAQ. December

12.

US EPA. OAR. 2004. Incorporating Emergi ng and Voluntary Measures in a State Implementation Plan. September.

US EPA. OAP and OAQPS. 2004. Memorandum. Guidance on SIP Credits for Emission Reductions from Electric-Sector Energy Effici ency and Renewable Energy Measures. B. McLean, Director, OAP, and S. Page, Director, OAQPS. August.

National Resources Defense C ouncil. Flying Off Course Environmental Impacts of America's Airports , October 1996.

US EPA. OAQPS. 2008. Presentation. March 2008 Final National Ambient Air Quality
Standards for Ground-level Ozone, General Overview.The Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix A

County-Level Emission Summary Tables for GeorgiaThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix B

Observed and Modeled Spatial Distribution of Daily 8-Hour
Maximum OzoneThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix C

Daily Maximum 8-Hour Ozone, 1- Hour Ozone, NO, and NO2 BarplotsThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix D

Scatter Plots of Hourly 8-Hour Ozone, 1-Hour Ozone, NO, and NO2The Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix E

Time Series Plots of Hourly 8-Hour Ozone, 1-Hour Ozone, and Precursor SpeciesThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix F

Sensitivity of Ozone in Atlanta to
Reductions in NO

x 

# and VOC
EmissionsThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix G

Clean Air Markets - EGU NOx DataThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix H

Sensitivity of Ozone in Macon to
Reductions in NOx Emissions from Various Sources in GeorgiaThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix I

Protocol for Annual MM5 Modeling in Support of VISTASThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix J

MM5 2002 Modeling in Support of
VISTASThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix K

Documentation of VISTAS Inventories and Georgia 2002 CERR InventoryThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix L

Guidance on the Use of Models and

Other Analysis for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional HazeThe Atlanta Eight-Hour Ozone Attainment Demonstration


# Appendix M

Georgia Environmental Protection
Division Comments on:
"Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for

Ozone, PM2.5 and Regional Haze" October 27, 2006The Atlanta Eight-Hour Ozone Attainment Demonstration


# Appendix N

Modeling Protocol for the Atlanta, GA
8-hour Ozone Nonattainment AreaThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix O

VISTAS CEM Emission Rate MemoThe Atlanta Eight-Hour Ozone Attainment Demonstration



# Appendix P

Quality Assurance Project Plan (Draft) for Association for Southeastern Integrated Planning (ASIP) Emissions and Air Quality Modeling to Address 8-Hour Ozone

and PM 2.5 

# Nonattainment in
Southeastern StatesThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix Q

Hartsfield-Jackson Atlanta International Airport
Reduction in Emissions of Ozone

PrecursorsThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix R

MM5 Meteorological Model
Performance EvaluationThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix S

May 11, 2006, Letter to EPA Requesting Concurrence on I/M Applicability

May 31, 2006, Letter from EPA ConcurringThe Atlanta Eight-Hour Ozone Attainment Demonstration 

# Appendix T

Voluntary Reduction of Emissions from Railyards in Metro Atlanta Region

# Appendix U

Mobile Source Emissions Modeling
for Atlanta
Ozone Attainment Demonstration Motor Vehicle Emissions Budgets