Responses to Comments Received on the Proposed SIP Revision for the 15

-

co unty Atlanta Nonattainment Area Emissions Inventory for the 2008 8

- Hour Ozone NAAQS

On November 7 , 20 14

, Georgia EPD issued a public notice requesting comments on Georgia’s proposed SIP r evi sion for the 15

- county Atlanta nonattainment area emissions inventory for the 2008 8

- Hour o zone NAAQS

. No comments were received during the public hearing on December 9 , 2014 . Written comments were received from USEPA Region 4 and GreenLaw, on b ehalf of the Sierra Club

. USEPA Region 4’s comments, GreenLaw ’s comments

, and EPD’s responses are presented below

.

Written Comments

, USEPA Region 4

Comment: EPA asked EPD to “ clarify the total emissions on page 11, tables 4, 5 and 6. It appears th e Point EGU emissions were not included in the calculations”.

EPD Response: Tables 4, 5, and 6 on page 11 were updated to include Point EGU emissions that were inadvertently left off. In addition, Column J in the Appendix F Excel spreadsheet (Appendi x_F_Emission_Summary.xls) was updated to include Point EGU
emissions t hat were inadvertently left off

.

Written Comments, GreenLaw, on behalf of the Sierra Club

Comment: G reenLaw states “ Georgia EPD should include plants Hammond and
Wan sley in the Emissions Inventory because they emit large amounts of ozone

- causing pollutants, and lack modern controls to reduce this pollution.” In addition, GreenLaw
states “ EPA has stated that a nonattainment area inventory should include both sources
within the non attainment area, as well as sources located outside of nonattainment area that may affect nonattainment areas. See, e.g., EPA, Guidance for 1

- Hour SO2 Nonattainment Area SIP Submissions (Apr. 2014) (“[T]he air agency should also
address sources located ou tside the nonattainment area which may affect attainment in the area.”). For ozone nonattainment areas, EPA has further stated that any major
emissions source within 25 miles of the nonattainment area must be included within the inventory. EPA, Emissions Inventory Requirements for Ozone State Implementation Plans (Mar. 1991), at section 3.2.3; see also Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter NAAQS and Regional Haze Regulations (Aug. 2005), at page 25. Georgia EPD mus t follow EPA’s guidance in order to create an accurate and comprehensive Emissions Inventory. ”

EPD Response: EPD does not agree that plants Hammond and Wan sley need to be included in the Emissions Inventory

. The first reference (E PA, Guidance for 1

- Hour
SO2 Nonattainment Area SIP Submissions, Apr. 2014) applies to SO2 nonattainment areas and does not apply to ozone nonattainment areas. The next two references ( EPA, Emissions Inventory Requirements for Ozone State Imple mentation Plans, Mar.Response s to Comments

– Proposed SIP R evision for the 15

- county Atlanta Nonattainment Area Emissions Inventory for the 2008 8

- Hour Ozone NAAQS

2 1991, section 3.2 .3; EPA, Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter NAAQS and Regional Haze Regulations, Aug. 2005, page 25 ) are outdated and have been replaced with more recent guidance (EPA, Emissions Inventory Guidance for Imple mentation of Ozone [and Particulate Matter] National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations , Apr. 2014).

T his guidance document states in Section 4.4

, Spatial Extent (page 53), “ The spatial extent of an inventory refers to cou nties, states, or other geographic regions covered by the emissions data. As described in previous sections, inventories needing to be included in SIPs are either for the NAA area only (for ozone and PM2.5) or are for the entire state (for regional haze an d ozone or PM2.5 when modeled attainment demonstrations are needed).” Since a m odeled attainment demonstration is not required, an emission inventory is needed for the nonattainment area only.