Appendix O.1 

FWS and NPS Comments on Draft 

Prehearing SIP 
IN REPLY REFER TO: 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

National Wildlife Refuge System 

Branch of Air Quality 

7333 W. Jefferson Ave., Suite 375 

Lakewood, CO 80235-2017 

February 1 1,2009 

Mr. James P. Johnston, Program Manager 

Georgia Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch, Planning and Support Program 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 

Dear Mr. Johnston: 

AIR PROTECTION Fg 

Planning &-Sipport 

On December 22,2008, the State of Georgia submitted for comment proposed revisions 

to the Georgia State Implementation Plan, describing its proposal to improve air quality 

regional haze impacts at mandatory Class I areas across your region. We appreciate the 

opportunity to work closely with the State through the initial evaluation, development, 

and, now, subsequent review of this plan. Cooperative efforts such as these ensure that, 

together, we will continue to make progress toward the Clean Air Act's goal of natural 

visibility conditions at all of our most pristine National Parks and Wilderness Areas for 

future generations. 

- 

This letter acknowledges that the Department of the Interior, U.S. Fish and Wildlife 

Service (FWS), in coordination with the National Park Service (NPS), have received and 

conducted a substantive review of your proposed Regional Haze Rule implementation 

plan in fulfillment of your requirements under the federal regulations 40 CFR 

51.308(i)(2). Please note, however, that only the U.S. Environmental Protection Agency 

(EPA) can make a final determination regarding the document's completeness and, 

therefore, ability to receive federal approval from EPA. In addition, this letter 

acknowledges the productive conference call on January 22,2009, during which all of the 

comments presented in the enclosure to this letter were discussed. 

As outlined in a letter to each State dated August 1,2006, our review focused on eight 

basic content areas. The content areas reflect priorities for the Federal Land Manager 

agencies, and we have enclosed comments associated with these priorities. We look 

forward to your response, as per section 40 CFR 5 1.308(i)(3). For further information, 

please contact Tim Allen (FWS) (303) 9 14-3 802. 
Mr. James P. Johnston Page 2 

The State of Georgia should be commended for the high quality of work and clear and 

concise writing of proposed Regional Haze SIP. Again, we appreciate the opportunity to 

work closely with the State of Georgia and compliment you on your hard work and 

dedication to significant improvement in our nation's air quality values and visibility. 

Sincerely, 

Sandra V. Silva, Chief 

Branch of Air Quality 

Fish and Wildlife Service 

Enclosure 

cc: 

James A. Capp, Air Branch Chief 

Georgia Department of Natural Resources 

Environmental Protection Division 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 

Kay Prince, Chief 

Air Planning Branch 

US EPA Region 4 

61 Forsyth Street, S.W. 

Atlanta, Georgia 303 03-8960 

Michele Notarianni 

US EPA Region 4 

61 Forsyth Street, S.W. 

Atlanta, Georgia 3 0303 -8960 

Annette Sharp, Executive Director 

CENRAP 

10005 S. Pennsylvania, Ste. C 

Oklahoma City, Oklahoma 73 159 

Christine L. Shaver, Chief 

Air Resources Division 

National Park Service 
Mr. James P. Johnston Page 3 

VISTAS Technical Coordinator 

2090 U.S. 70 Highway 

Swannanoa, North Carolina 28778 

Brian McManus 

Chief, Branch of Fire Management 

US Fish & Wildlife Service 

National Interagency Fire Center 

3 83 3 South Development Ave. 

Boise, Idaho 83705 

Jon Andrew, Chief 

Southeast Region 

National Wildlife Refuge System 

1875 Century Center 

Atlanta, Georgia 30345 

George Constantino 

Project Leader 

Okefenokee National Wildlife Refuge 

Route 2, Box 3330 

Folkston, GA 3 1537 

Jane Griess 

Project Leader 

Wolf Island National Wildlife Refuge 

Savannah Coastal Refuges 

Parkway Business Center 

1000 Business Center Drive, Suite 10 

Savannah, Georgia 3 1405 

James Burnett 

Refuge Manager 

St. Marks National Wildlife Refuge 

P.O. Box 68 

St. Marks, Florida 32355 

James Kraus 

Refuge Manager 

Chassahowitzka National Wildlife Refuge 

1502 SE Kings Bay Drive 

Crystal River, Florida 34429-466 1 
U.S. Fish and Wildlife Sewice and National Park Sewice (NPS) Comments Regarding 

Georgia Draft Regional Haze Rule State Implementation Plan 

On December 22,2008, the State of Georgia submitted a draft Georgia State Implementation 

Plan (SIP) Revision for the Regional Haze Program, pursuant to the requirements codified in 

Federal rule at 40 CFR 5 1.308(i)(2), to the U.S. Department of the Interior, U.S. Fish and 

Wildlife Service (FWS) and the National Park Service (NPS). 

The air program staff of the FWS has conducted a substantive review of the Georgia draft plan 

and provides the comments listed below. 

We are providing these comments to the State and wish them to be placed in the official public 

record. We look forward to your response as per section 40 CFR 5 1.308(i)(3), and we are 

willing to work with the Georgia Environmental Protection Division (Georgia EPD) staff 

towards addressing any of the issues discussed in this letter. For further information, please 

contact Tim Allen with FWS at (303) 914-3802. 

Overall Comments 

Overall the Georgia draft Regional Haze State Implementation Plan (SIP) is comprehensive and 

well written. This SIP is a good example for other states to follow. 

International Impairment 

On page 58, a modified glide slope is presented. This glide slope is based on removing the 

international emissions. However, the international component was not removed from the 

natural conditions. The result effect is minor, but should be corrected in the final version of the 

SIP. 

Rest Available Ketrofit Technologv (BAKT) and Reasonable Progress (RP) 

On page 78, the draft SIP states, "In accordance with Environmental Protection Agency 

guidance, emission units subject to BART review are not subject to reasonable progress goal 

review." The State does have the option of requiring additional controls, if BART is not 

sufficient enough to reach reasonable progress goals. 

Smoke Management Plan 

On page 103, the Smoke Management Plan (SMP) should be referenced in a summary paragraph 

and the SMP should be included as an Appendix to the SIP. The summary paragraph should 

include whether the SMP is voluntary or mandatory and whether the SMP includes Class I areas 

as a sensitive receptor. Additionally, some basic statements should be included as to whether 

emissions from fire are anticipated to shrink, stay the same, or increase over the ten year 

planning period. It is recommended that the SMP should be referenced in a manner that does 

not require SIP updates each time the SMP is updated. 
Construction Activity 

The draft SIP does not contain a discussion on State limits on emissions resulting from 

construction activity. This is a required element of the Regional Haze SIP. 

Impact on out-of-State Class I areas 

The draft SIP should contain a few statements on Georgia's impact on out-of-State Class I areas. 

Best Available Retrofit Technology (BART) Provisions of the Georrria Regional Haze SIP 

Appendix H of the Georgia Regional Haze State Implementation Plan - Draft (RH SIP) contains 

BART Exemption Modeling Reports for a number of facilities, but such reports are not included 

for eight BART-eligible sources. They are: DSM Chemicals North America, Georgia PacificBrunswick Cellulose, Owens Corning, PCA, PCS Nitrogen, Prayon, Inc., Rayonier and 

TronoxJKerr-McGee. Please provide these reports in the record as evidence to confirm that none 

of the above facilities impact any Class I area by 0.5 deciviews or greater. 

It is important that the RH SIP be clear that the Georgia EPD is the entity that accepts and adopts 

required emission controls, because the EPA BART Guidelines require that permit conditions be 

finalized and included in the RH SIP.' Section 7.7.3 implies that Interstate Paper in Riceboro 

developed the BART determination in the reference, "Their BART determination results . . ." 

However, on a January 22,2009 conference call Georgia EPD stated that the BART 

determination was developed by the State. Thus, the wording should be clear that the Required 

Control Options displayed in Table 7.7.3-1 are the conclusions of Georgia EPD, rather than 

merely results presented by Interstate Paper. In the next-to-last paragraph of Section 7.7.2, 

relating to Georgia Pacific - Cedar Springs, Georgia EPD should make it clear that the stated 

emission limits are accepted and adopted by the State. 

The "model plant" criteria for International Paper - Savannah and Lafarge Building Materials - 

Atlanta should be documented. Table 7.7.2-2 makes reference to exempting these facilities from 

BART based on "Model Plant Criteria", but the term has not been defined in the RH SIP. The 

EPA BART Guidelines define what could be accepted by a state as a model plant criteria2, but 

allows a state to develop its own criteria. The RH SIP should state or reference the State's 

definition of "Model Plant Criteria" and it should also show the definitive distance and emission 

characteristics of the above two facilities so as to confirm their meeting the "Model Plant 

Criteria". 

I See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized it's BART Guidelines on 

June 15, 2005, and published the preamble and final rule text in the Federal Register on 

July 6, 2005. The rulemaking action added Appendix Y to Part 51, titled "Guidelines for BART Determinations 

Under the Regional Haze Rule." See Section V. 

' Ibid, Section III.A.3.0ption 2. 
Regarding the BART determination for Interstate Paper-Riceboro, Table 7.7.3-1, under the 

heading "Required Control Option" for the Lime Kiln states, "No cost effective control options 

Available." As discussed below there are cost-effective (i.e., cost per ton) control options 

available for the lime kiln, but as you clarified on a January 22,2009, conference call, the lack of 

cost-effectiveness was on the basis of excessive cost of visibility improvement. Please clarify 

this in Section 7.7.3. For the record it should be noted that cost-effective (i.e., cost per ton) 

control options are available for the lime kiln. The control alternatives of SNCR-NH3 based, 

SNCR-Urea based and Low NOx burner are all under $1,500 per ton of NOx reduced. It should 

be noted that only summary cost data were presented. More detailed cost information should be 

included in BART determinations so that third-party reviewers can more thoroughly review the 

costs and methodologies that were used.