Georgia Department of Natural Resources 

Environmental Protection Division, Air Protection Branch 

4244 International Parkway, Suite 120, Atlanta, Georgia 30354 

Phone:404/363-7000; Fax:404/363-7100 

Mark Williams, Commissioner 

Judson Turner, Director 

CERTIFICATE OF PUBLIC HEARING 

I do hereby certify that a public hearing was held on June 2, 2012, concerning proposed 

amendments to Georgia's Atlanta PM2.5 Maintenance Plan. 

A public notice posted at air-notices@listserv.dnr.state.ga.us for review and comments on 

May 31,2012. 

~vu_-~~~ NOtaf/l;blic- K. Lynne Collier 

Notary Public, Fayette County, Georgia 

My Commission Expires January 13, 2013 

au 

Date ({ 

~J ?~ 

~ ~nston, Manager 

Ianning and Support Program 

Date 
DEPARTMENT OF NATURAL RESOURCES 

ENVIRONMENTAL PROTECTION DIVISION 

NOTICE OF PUBLIC HEARING AND PROPOSED AMENDMENTS 

TO GEORGIA'S STATE IMPLEMENTATION PLAN 

TO ALL INTERESTED PERSONS AND PARTIES: 

Notice is hereby given that, pursuant to the authority set forth below, the Environmental 

Protection Division (hereinafter, "EPD") of the Georgia Department of Natural Resources 

proposes amendments to Georgia's State Implementation Plan (SIP). The proposed revision is 

described below: 

The proposed State Implementation Plan revision includes Georgia's request under the Clean 

Air Act that the Atlanta annual PM2.5 nonattainment area be redesignated to attainment with 

respect to the 1997 National Ambient Air Quality Standard (NAAQS) for PM2.5 as well as 

Georgia's plan to maintain attainment of the 1997 annual PM2.5 standard in the Atlanta area. 

This notice is being provided to all persons who have requested in writing that they be placed on 

a notification list. The proposed SIP revision may be viewed at 

http://www.qeorqiaair.org/airpermiUhtml/planninqsupport/regdev/sips and revisions/sips and revisions.htm or 

during normal business hours of 8:00a.m. to 4:30p.m. at the Georgia Environmental Protection 

Division, Air Protection Branch, 4244 International Parkway, Suite 120, Atlanta, Georgia 30354. 

Copies may also be requested by contacting the Air Protection Branch at 404/363-7000 or the 

Environmental Protection Division Director's Office at 1-888-373-5947. 

To provide the public an opportunity to comment upon and provide input into the proposed SIP 

revision, a public hearing will be held at 7:00p.m. on July 2, 2012, in the EPD Training 

Center located at 4244 International Parkway, Suite 116, Atlanta, Georgia 30354. At the 

hearing, anyone may present data, make a statement, comment or offer a viewpoint or 

argument either orally or in writing. Lengthy statements or statements of a considerable 

technical or economic nature, as well as previously recorded messages, must be submitted in 

writing for the official record. Oral statements should be concise. 

Written comments are welcomed. To insure their inclusion in EPD's final submission of the SIP 

revision to EPA, written comments should be received by close of business on July 9, 2012. 

Written comments may be emailed to EPDComments@dnr.state.ga.us or sent via regular mail 

addressed to: Branch Chief, Air Protection Branch, 4244 International Parkway, Suite 120, 

Atlanta, Georgia, 30354. 

The proposed SIP revision is proposed pursuant to authority contained in Georgia Air Quality 

Act (O.C.G.A. Section 12-9-1 et. seq.). For further information, contact the Air Protection 

Branch at 404/363-7000. 

1 
[(8i6/201:L)lynne Collier- [Georgia -Air Branch public notices & advisories] Revisions to-G~orgia's State Implementation_ Fl!lBge-1] 

From: <ai r-notices@l istserv. dn r. state.ga. us> 

To: air-notices@listserv.dnr.state.ga_us; air-notices@listserv.dnr.state.ga .... 

Date: 5/31/2012 10:03 AM 

Subject: [Georgia Air Branch public notices & advisories] Revisions to Georgia's State 

Implementation Plan 

Attachments: notice.pdf; Part.002 

DEPARTMENT OF NATURAL RESOURCES 

ENVIRONMENTAL PROTECTION DIVISION 

NOTICE OF PUBLIC HEARING AND PROPOSED AMENDMENTS 

TO GEORGIA'S STATE IMPLEMENTATION PLAN 

TO ALL INTERESTED PERSONS AND PARTIES: 

Notice is hereby given that, pursuant to the authority set forth below, 

the Environmental Protection Division (hereinafter, "EPD") of the 

Georgia Department of Natural Resources proposes amendments to 

Georgia's State Implementation Plan (SIP). The proposed revision 

is described below: 

The proposed State Implementation Plan revision includes Georgia's 

request under the Clean Air Act that the Atlanta annual PM2.5 

nonattainment area be redesignated to attainment with respect to the 

1997 National Ambient Air Quality Standard (NAAQS) for PM2.5 as well as 

Georgia's plan to maintain attainment of the 1997 annual PM2.5 

standard in the Atlanta area. 

This notice is being provided to all persons who have requested in 

writing that they be placed on a notification list. The proposed Sl P 

revision may be viewed at 

http://www.georgiaair.org/airpermit/html/planningsupportlregdev/sips_and_revisions/sips_and_revisions.h 

tm 

or during normal business hours of 8:00a.m. to 4:30p.m. at the 

Georgia Environmental Protection Division, Air Protection Branch, 4244 

International Parkway, Suite 120, Atlanta, Georgia 30354. Copies may 

also be requested by contacting the Air Protection Branch at 

404/363-7000 or the Environmental Protection Division Director's 

Office at 1-888-373-5947. 

To provide the public an opportunity to comment upon and provide input 

into the proposed SIP revision, a public hearing will be held at 7:00 

p.m. on July 2, 2012, in the EPD Training 

Center located at 4244 International Parkway, Suite 116, Atlanta, 

Georgia 30354. At the hearing, anyone may present data, make a 

statement, comment or offer a viewpoint or argument either orally or in 

writing. Lengthy statements or statements of a considerable technical 

or economic nature, as well as previously recorded messages, must be 

submitted in writing for the official record. Oral statements should be 

concise. 

Written comments are welcomed. To insure their inclusion in EPD's 

final submission of the SIP revision to EPA, written comments should be 
received by close of business on July 9, 2012. Written comments may be · 

emailed to EPDComments@dnr.state.ga.us or sent via regular mail 

addressed to: Branch Chief, Air Protection Branch, 4244 International 

Parkway, Suite 120, Atlanta, Georgia, 30354. 

The proposed Sl P revision is proposed pursuant to authority contained 

in Georgia Air Quality Act (O.C.G.A. Section 12-9-1 et. seq.). For 

further information, contact the Air Protection Branch at 404/363-7000. 
Georgia Department of Natural Resources 

2 Martin Luther King, Jr., Drive, S.E., Suite 1152 East, Atlanta, Georgia 30334-4100 

Mark Williams, Commissioner 

Environmental Protection Division 

Judson H. Turner, Director 

Phone: 404/656-4713 FAX: 404/651-5778 

August 8, 2012 

MEMORANDUM 

To: 

From: 

Subject: 

Judson Turner, Director 

Environmental Protection Division 

James Capp, Chief ()or__ 

Air Protection Branch U 

Responses to Comments Received During the Public Comment 

Period Regarding the Proposed Annual PM2.s Maintenance Plan for 

the Atlanta Nonattainment Area 

On December 8, 2011, EPA promulgated its determination (76 FR 76620) that the 

Atlanta nonattainment area had attained the 1997 annual average PM2.5 National 

Ambient Air Quality Standard (NAAQS). As a result, the Environmental Protection 

Division (EPD) of the Georgia Department of Natural Resources is submitting to the 

United States Environmental Protection Agency (EPA) a State Implementation Plan 

(SIP) revision which incorporates a maintenance plan for the Atlanta Nonattainment 

Area. On May 31, 2012, EPD issued a public notice to all persons who have requested 

that they be placed on a notification list and requested comments on the proposed 

amendments to Georgia's SIP. The amendments were described in the notice as 

follows: 'The proposed State Implementation Plan revision includes Georgia's request 

under the Clean Air Act that the Atlanta annual PM2.5 nonattainment area be 

redesignated to attainment with respect to the 1997 National Ambient Air Quality 

Standard (NAAQS) for PM2.5 as well as Georgia's plan to maintain attainment of the 

1997 annual PM2.5 standard in the Atlanta area." 

No oral comments were received during the public hearing held on July 2, 2012. 

Written comments were received from Greenlaw during the public comment period. 

Comments received and EPD's responses are included in the attached document. 

JC:JK:klc 
Responses to Comments Received- Atlanta PM2.5 SIP 

Greenlaw states that the plan does not directly regulate all primary PM2.s 

emissions. 

Response: There are no statutory or regulatory requirements to regulate all PM2.s 

(including condensables) emissions for the purpose of an attainment demonstration or 

maintenance SIP. EPA's Clean Air Fine Particle Implementation Rule (72 FR 20586) 

allows States to identify those pollutants and those sources "with the greatest impact on 

nonattainment and to identify a sound strategy that achieves attainment in the most 

sensible manner." (72 FR 20615) 

Despite this, it must be noted that all stationary sources of PM2.s emissions are subject 

to state or federal regulations for the control of particulate matter, including Georgia 

Power Plant Bowen, which GreenLaw erroneously concluded was not subject to such 

control. This facility is subject to the State particulate matter emission limits of Georgia 

Rule 391-3-1-.02(2)(b) and (d) as well as the Federal requirements of NESHAP Subpart 

uuuuu. 

Greenlaw states that EPD relies on measures to address secondary PM2.5 

emissions that are non-permanent and non-enforceable. 

Response: GreenLaw makes the argument based on the uncertainty regarding the 

Federal programs NOx SIP Call, CAIR, and CSAPR to control the S02 and NOx as not 

permanent and enforceable. However, all statewide emission reductions of S02 that 

are relied upon for maintenance in the plan are due to the permanent and enforceable 

emission limits of Georgia Rule 391-3-1-.02(2)(uuu). 

Georgia's Maintenance Plan is deficient: 

Greenlaw states that contingency measures do not provide for prompt 

corrections of violations. 

Response: The contingency measures in this submittal are consistent with previous 

EPA approvals of Georgia SIP revisions for maintenance plans. Implementation of the 

contingency measures is only required by §175A Clean Air Act upon violation of the 

PM2.s NAAQS. A violation is defined as a 3-year average of the annual mean that is 

above the standard. The plan defines triggers and responses that are initiated prior to 

the violation ofthe PM2.s NAAQS. 

Greenlaw states that the contingency measures are too vague. 

Response: The contingency measures in this submittal are consistent with all previous 

EPA approvals of Georgia SIP revisions for maintenance plans. There are no 

regulatory or statutory requirements to identify specific contingency measures. 

However, EPA guidance (September 4, 1992, John Calcagni) does require that a plan 

identify such measures to be considered, and such measures are typically those that 

would be required by the Clean Air Act if an area was designated as nonattainment. 

2 
Responses to Comments Received -Atlanta PM2.5 SIP 

Response: EPA has issued no finding regarding the inadequacy of the SSM provisions 

in Georgia's SIP. All current rules regarding SSM in Georgia's SIP have been approved 

by EPA. 

Greenlaw states that the request for redesignation is inappropriate at this time. 

Response: GreenLaw makes this argument based on the pending new PM2.5 NAAQS 

and the need to continue to protect public health. The designation process for the 

proposed 2012 PM2. 5 NAAQS is independent of any previous PM2.5 NAAQS or 

maintenance requirements. This redesignation request includes a maintenance plan 

that demonstrates that all measures that were required to attain the 1997 standard will 

be maintained and that future-year emissions stay below the emissions from 2008, one 

of the years used to calculate the attainment design value. The plan is for ten years 

and must be followed by another 1 0-year plan. 

If the state were to not redesignate the area subject to the 1997 PM2.s NAAQS and were 

designated nonattainment with the 2012 PM2.5 NAAQS, the state would be subject to 

the SIP requirement of two simultaneous NAAQS of the same pollutant for differing 

concentration levels of the same averaging period. It takes about two years to develop 

an attainment plan and doubling this effort while meeting the less stringent standard 

would be an enormous waste of public resources with absolutely no public health 

benefit. 

Greenlaw states that the request does not address the effects redesignation will 

have on other NAAQS. 

Response: GreenLaw cites §7410(1) [§110(1)] as the basis that a plan is not approvable 

if it would interfere with attainment or reasonable further progress. However, GreenLaw 

provides no evidence that any emissions are increasing as a result of this SIP that 

would interfere with any applicable requirement concerning attainment and reasonable 

further progress. 

To the contrary, the plan cleqrly demonstrates that the emissions of S02 and NOx are 

significantly reduced. Therefore, the plan alone is a simple and self-evident analysis 

concerning other NAAQS, specifically ozone (for which NOx is a key precursor), 24-hr 

PM2.s (for which S02 is a key precursor), S02 and N02. EPD is not aware of any 

instance where large reductions of ozone, PM2.5, S02 and NOx can result in the 

interference of attainment or maintenance of any NAAQS, including ozone, S02, and 

N02. 

4