y, 

Air Protection Branch 

Environmental Protection Division 

Georgia Department of Natural Resources 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 

Dear Mr. Bentley: 

The U.S. Environmental Protection Agency, Region 4, Air, Pesticides, and Toxics Management 

Division conducted an end-of-year evaluation of the Performance Partnership Grant's (PPG) associated 

fiscal year (FY) 2014 section 105 commitments in the Air Planning Agreement (APA). This letter and 

attached final AP A documents the conclusion of the joint evaluation process required by 40 Code of 

Federal Regulations 35.115. 

There was one work plan activity within the FY 2014 APA that your agency did not commit to 

completing due to resource constraints, although this was acknowledged as an activity the EPA has 

requested state programs to commit to undertake as part of the AP A. The EPA is highlighting below as 

an outstanding concern given the nature and importance of the activities independent of any 

commitment on your part to complete the activities: 

Due to budget constraints, the GA EPD has discontinued program activities associated with 

implementation of the Asbestos National Emission Standard for Hazardous Air Pollutants 

(NESHAP) program. The components that are discontinued are the Asbestos NESHAP 

inspections, complaint follow-up, and enforcement. The EPA assumed responsibilities for 

implementation of those program duties to fulfill our responsibilities under the Clean Air Act 

(CAA). At this time, the EPA has not made any determination regarding the impact of 

discontinuing implementation of the specified program activities on the Asbestos NESHAP 

program delegation or the CAA Section 105 grant. 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed w~h Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
'-t~cliy H. Banister 

Director 

Air, Pesticides, and Toxics Management Division 

Enclosure 
Protecting and Improving Air Quality* 

Goal: Taking Action on Climate Change and Improving Air Quality 

Objective: Improve Air Quality. Achieve and maintain health-based air pollution standards and reduce risk 

from toxic air pollutants and indoor air contaminants. 

Sub-Objective: Reduce Criteria Pollutants and Regional Haze 

Strategic • By 2015, the population-weighted average concentrations of ozone (smog) in all 

Targets: monitored counties will decrease to 0.073 ppm compared to the average of 0.078 ppm in 

2009. 

• By 2015, the population-weighted average concentrations of inhalable fine particles in all 

monitored counties will decrease to 10.5 Jlg/m3 compared to the average of 11.7 Jlg/m3 in 

2009. 

• By 2015, reduce emissions of nitrogen oxides (NOx) to 14.7 million tons per year 

compared to the 2009 level of 19.4 million tons emitted. 

• By 2015, reduce emissions of sulfur dioxide (S02) to 7.4 million tons per year compared 

to the 2009 level of 13.8 million tons emitted. 

• By 2015, reduce emissions of direct particulate matter (PM) to 3.9 million tons per year 

compared to the 2009 level of 4.2 million tons emitted. 

• By 2018, visibility in scenic parks and wilderness areas will improve by 15 percent in the 

East and 5 percent in the West, on the 20 percent worst visibility days, as compared to 

visibility on the 20 percent worst days during the 2000-2004 baseline. 

• By 2015, with EPA support for developing capability including training, policy, and 

administrative and technical support, 15 additional tribes will possess the expertise and 

capability to implement the Clean Air Act in Indian country (as demonstrated by 

successful completion of an eligibility determination under the Tribal Authority Rule), for 

a cumulative total of 62 from the 2009 baseline of 47 tribes . 

• 

* information from EPA's 2011-2015 Strategic Plan 

(http://www .epa. gov /planandbudget/strategicplan.html). 

FY 2014 105 Grant Commitments: 

Implement the PM2.s NAAQS 
Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

3. 

4. As appropriate, address any area violating the PMz.s NAAQS that is not designated nonattainment and 

provide quarterly reports on activities and accomplishments to the Regional Office through the 

reporting database. 

Response: Not applicable 

5. 

Last EPA Reviewer: rwong02- 13:18:37 on 01121115- slakeman- slakeman 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

6. 

7. Implement the 8-hour Ozone NAAQS 
Negotiation Status: Status_OK Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

10. 11. For areas designated nonattainment for the 2008 8-hour ozone NAAQS, meet CAA requirements 

consistent with CAA section 182 for emissions inventory and emissions statements. 

Response: Agree 

12. 

Last EPA Reviewer: rwong02- 13:42:02 on 01/21/15- slakeman- slakeman 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

13. 

14. Implement the Lead NAAQS 
17. 

Last EPA Reviewer: rwong02- 13:42:22 on 01121/15- slakeman- slakeman 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

18. Implement the Regional Haze Program 

19. Submit 5-year progress plan to EPA, no later than 5 years after the state's submission of the initial 

regional haze SIPs. 

Response: Agree 

20. 

Last EPA Reviewer: rwong02- 13:42:31 on 01121115- rrmotarianni- rrmotarianni 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 
24. 

Last EPA Reviewer: rwong02- 13:42:38 on 01121115- slakeman- slakeman 

Negotiation Status: Status_OK Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

25. 26. If not done already, please provide a schedule of when your Agency will submit the 110(a)(2) 

infrastructure element SIP for the 2010 Sulfur Dioxide NAAQS. These submissions were due June 3, 

2013. 

Response: Agree 

27. 

Last EPA Reviewer: mnotarianni- 15:25:32 on 01116/15- mnotarianni- mnotarianni 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 
nonattainment. For areas that violate after the designation, work with Region 4 to develop a plan to 

expeditiously bring each area back into attainment. 

Response: Agree 

31. 

Last EPA Reviewer: rwong02- 13:57:04 on 01121/15- slakeman- slakeman 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

32. 

33. Consistent with the national allocation of section 105 grant resources and the states' and locals' 

voluntary withholding of 105 grant resources for special projects, continue developing regional 

planning capabilities for National Ambient Air Quality Standards (NAAQS) and regional haze, 

including emission inventory development, building air quality modeling capacity, other technical 

analyses and collaboration with other agencies. The state and local contact or section chief in the 

Regulatory Development Section should be notified, at the mid-year point and a month prior to the end 

of the grant period, via e-mail of how the state or local agency is meeting this grant condition, 

specifying applicable specific grants or programs. 

34. 

Response: John Hornback, Executive Director of SESARM, is working with EPA to clarify needs and 

avoid duplicative conditions, avoid duplicative reporting (such as accepting the VISTA 

technical reports to the extent possible), and reconsider reporting deadlines. EPD will wait 

continue to rely on SESARM's reporting for this commitment. 

Last EPA Reviewer: rwong02- 14:02:30 on 01121115- slakeman- slakeman 
_ 

Regional Staff Response: 

35. 

36. Implement Mobile Source Programs 

37. Actively participate in the transportation conformity process, which includes the following activities: 

consult with appropriate transportation and air quality partners on development of motor vehicle 

emissions budgets; participate in the interagency consultation process; develop relationships with 

transportation partners; and develop and update transportation conformity SIPs and consultation 

procedures, as required by the Clean Air Act. 

Response: Agree 

38. 

Last EPA Reviewer: dsmith- 15:40:46 on 02/04/15- dsmith- dsmith 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_ OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

39. 

40. On an annual basis, but within 4 months of the conclusion of the control period, submit a report 

detailing testing program results for the Reid vapor pressure and sulfur if applicable, requirements, and 

any notices of violations or enforcement actions related to the state fuel program. 

Response: This commitment should be rewritten to reflect the agreement we reached in a June 3, 2011 

teleconference with EPA Region 4 staff, and confirmed in the July 26, 2011 mid-year 

evaluation letter for the FY-2011 AP A, that EPD will provide a summary of the 
42. 

Negotiation Comments: Refer back to the 2011 commitment for wording 

Mid Year Status: Status_OK Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

43. Implement NSR Programs 

44. Issue major NSR/Prevention of Significant Deterioration (PSD) permits and minor source permits that 

comply with CAA requirements and enter Best Achievable Control Technology (BACT)!Lowest 

Achievable Emissions Rate (LAER) determinations for major sources in the Reasonably Achievable 

Control Technology (RACT)/BACTILAER Clearinghouse (RBLC). 

Response: Agree, however EPA should use the correct terminology when referring to BACT and 

RACT and replace Achievable with A vail able. · 

45. 

Last EPA Reviewer: aporter- 08:48:39 on 02/09/15- aporter- aporter 

Negotiation Status: Status_ OK 

Negotiation Comments: 

Mid Year Status: Status_ OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

46. 
48. 

Last EPA Reviewer: aporter- 08:48:50 on 02/09/15- aporter- aporter 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_ OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

49. 

50. Ambient Air Monitoring 

51. Operate all criteria pollutant monitors and perform requisite data review and quality assurance/quality 

control elements in compliance with the requirements of the CFR and other applicable federal policy 

and guidance. This commitment includes all reporting and data certification requirements (e.g., annual 

State and Local Air Monitoring Station (SLAMS) reports and data certifications due by May 1 each 

year). The agency will collect strip chart data or its electronic equivalent for quality assurance purposes. 

Electronic strip chart data must be collected on a 1 minute timeframe or less. This data must be retained 

for a minimum of 3 complete monitoring years. 

Response: Agree 

52. 

Last EPA Reviewer: dpalmer- 09:50:41 on 01128/15- dpalmer- dpalmer 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 
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network plan should be consistent with requirements outlined in 40 CFR Parts 50, 53, and 58. Local 

agencies will coordinate with the State in the development of this plan. The annual network plan is to 

be submitted on or by July 1 of each year incorporating any changes, real or proposed. Include in the 

annual ambient monitoring network design plan a certified evaluation of the agency's ambient monitors 

and auxiliary support equipment and categorize the condition of the equipment as "poor" or "good." 

The agency is requested to replace equipment categorized as "poor." 

55. 

56. 

Response: Agree 

Last EPA Reviewer: dpalmer- 09:51:09 on 01128/15- dpalmer- dpalmer 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_OK 

ok. dpalmer 01128/15 

Regional Staff Response: 

57. Maintain an approved quality management plan (QMP) for activities involving the collection and use of 

air quality environmental data. Locals must coordinate with the State if they operate under the State's 

QMP. The QMP will be submitted at least 60 days prior to the expiration of the current QMP and 

address EPA Requirements for Quality Management Plans (EPA QA/R-2, 

http://www.epa.gov/guality/gs-docs/r2-final.pd0. For additional information and guidance see 

http://www.epa.gov/guality/gmps.html. 

Response: Agree 

58. 

Last EPA Reviewer: dpalmer- 09:51:34 on 01128/15- rguillot- dpalmer 
59. 

ok. dpalmer 01128/15 

Regional Staff Response: 

60. State and Local agencies will review and update their Quality Assurance Project Plans (QAPPs) for 

their respective criteria pollutant networks, as appropriate, and submit modifications to EPA prior to 

modifying their networks. All QAPPs should be reviewed at least once every five years. If no changes 

are necessary, the agency is required to resubmit the existing QAPP stating that it has been reviewed 

and no changes were required. 

61. 

62. 

Response: Agree Last EPA Reviewer: dpalmer- 09:52:29 on 01128/15- rguillot- dpalmer 

Negotiation Status: Status_OK Negotiation Comments: 

Mid Year Status: Status_ OK 

Mid Year Comments: 

Current Status: Status_ OK 

ok. dpalmer 01128/15 

Regional Staff Response: 

63. For all new pollutants to be monitored and methods to be used during the fiscal year, submit a revised 

Quality Assurance Project Plan three months prior to collection of environmental data. 

Response: Agree 

64. 

Last EPA Reviewer: rguillot- 16:16:31 on 01128/15- dpalmer- rguillot 
65. 

Current Status: Status_OK 

ok. dpalmer 01/28/15 

Regional Staff Response: 

66. Review and update quality assurance procedures, if needed, to reflect current/revised Federal quality 

assurance requirements. Local agencies will coordinate Standard Operating Procedures (SOP) changes 

through the State. If changes or revisions are anticipated, submit the following information, in hard 

copy and/or electronic format, to EPA Region 4's Science and Ecosystems Support Division (SESD), 

Superfund and Air Section with an email copy to Daniel Garver: 

A. Revisions to current SOPs as they are completed, and 

B. SOPs for new monitoring and ancillary equipment used in the SLAMS network six months after 

equipment is installed. 

Response: Agree Last EPA Reviewer: rguillot- 07:07:34 on 01/29/15- dpalmer- rguillot 

Negotiation Status: Status_OK Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_OK 

ok. dpalmer 01/28/15 

Regional Staff Response: 

67. For all SLAMS and Special Purpose Monitors (SPMs) meeting the requirements of 40 CFR 58, notify 

EPA as soon as possible, but no later than 30 days, after the determination of exceedances/violations of 

the NAAQS for all criteria pollutants, including PMz.s. For the 8 hour ozone NAAQS, report all 4th 
69. 

Negotiation Status: Status_OK Negotiation Comments: 

Mid Year Status: Status_ OK 

Mid Year Comments: 

Current Status: Status_OK 

ok. dpalmer 01/28/15 

Regional Staff Response: 

70. Comply with the requirements in 40 CFR Section 50.14 regarding treatment of data influenced by 

exceptional events. (Note: EPA Region 4 will neither review nor concur on either State or Local 

requests to exclude data unless the State is in compliance with the appropriate requirements.) 

71. 

72. 

Response: Agree 

Last EPA Reviewer: dpalmer- 10:17:46 on 01/28/15 - dpalmer- dpalmer 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK Mid Year Comments: two requests are in that the region needs to take action on. dpalmer 06/15/14 

Current Status: Status_ OK 

ok. dpalmer 01128/15 

Regional Staff Response: 

73. In conjunction with the AQI, agencies are encouraged to submit an Air Quality Forecast for MSA's 

greater than 350,000 people to the EPA AIRNow Web site. The Air Quality Forecast should be 
74. 

75. 

Last EPA Reviewer: dpalmer- 10:19:23 on 01128/15- dpalmer- dpalmer 

Negotiation Status: Status_ OK 

Negotiation Comments: 

Mid Year Status: Status_OK Mid Year Comments: 

Current Status: 

Regional Staff Response: 

Status_ OK 

Agree that forecasting that is not required by 40 CFR Part 58. ok. dpalmer 

01128/15 

76. Support staff participation at the following meetings: 

A. The Region 4 Ambient Air Monitoring Work Shop; and 

B. The National AQS Conference (only those agencies submitting data directly to AQS). 

Response: Agree, to the extent state budget and travel restrictions allow. 

Last EPA Reviewer: dpalmer- 10:21:23 on 01128/15- dpalmer- dpalmer 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 
basis. Notify EPA immediately if a problem arises that will prevent the agency from meeting a data 

completeness requirement for any pollutant. Provide reasons why the data completeness requirement 

will not be met, a schedule for correcting the problem, and corrective actions that will be taken to avert 

the problem from recurring. Notify EPA by mail or e-mail no more than 45 days after the end of the 

quarter of any monitor not meeting the 75% data recovery requirement. Data recovery may become part 

of a regional/national statistical report published by EPA. 

78. 

79. 

Response: Disagree with the proposed commitment to notify EPA by mail or e-mail no more than 45 

days after the end of the quarter of any monitor not meeting the 75% data recovery 

requirement. 40 CFR 58 allows up to 90 days after the end of the monitoring quarter to 

submit data to AQS. We will not know if the 75% data recovery has occurred until we have 

submitted the data to AQS. 

Last EPA Reviewer: dpalmer- 10:24:39 on 01128/15- dpalmer- dpalmer 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_OK 

I am notified appropriately. ok. dpalmer 01/28/15 

Regional Staff Response: 
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• 

*information from EPA's 2011-2015 Strategic Plan 

(http://www.epa.gov/planandbudget/strategicplan.html). 

FY 2014 105 Grant Commitments: 

1. Collect ambient air quality data for toxics from monitoring sites as appropriate for special studies 

funded under a Section 105 grant. (Note: NATTS and Community-scale Grants are .monitored through 

their respective grants. Requirements for those grants are identical to those listed in the AP A. Those 

agencies should reply to the APA commitments by indicating the program in which they participate.) 

Include any planned air toxics monitoring in the ambient monitoring network design plan that is 

submitted to EPA in July annually. If no monitoring is planned, clearly state, "No monitoring will be 

performed." 

Response: Agree. NA TIS. 

2. 

Last EPA Reviewer: dsturdiv- 11:03:41 on 01129/15- acooper- acooper 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

3. 

4. Ensure that the QA/QC procedures for air toxics monitoring and lab analysis, including necessary 

quality assurance project plans (QAPPs) and standard operating procedures (SOPs), are submitted (in 
6. 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

7. If applicable, encourage laboratories conducting analyses for air toxics to participate in any available 

national or regional inter-laboratory proficiency testing programs and audits and make identified 

modifications to enhance data quality. 

Response: Agree 

8. 

Last EPA Reviewer: dsturdiv- 11:03:51 on 01129/15- acooper- acooper 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_ OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

9. 
12. 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Response: 

13. Assume delegation and implementation of all promulgated Clean Air Act Section 112, 111, and 129 

rules and standards [National Emission Standard for Hazardous Air Pollutant (NESHAP), and New 

Source Performance Standards (NSPS)] within 9 to 12 months of EPA's promulgation, as appropriate, 

if a rulemaking is required to take delegation via the Agency's CAA Title V approval process. Notify 

Region 4 by submitting rule adoption documentation within 60 days of adoption. 

14. 

Response: Agree with assuming all Section 112, 111, and 129 rules. As discussed and agreed to in a 

January 13, 2014 teleconference with EPA Region 4, EPD agrees to submit rule adoption 

documentation within a reasonable timeframe after adoption. 

Last EPA Reviewer: 

Negotiation Status: Negotiation 

Comments: 

Mid Year Status: Mid Year Comments: 

Current Status: 

lpage- 08:15:59 on 01129/15 -lpage -lpage 

Status_ OK 

Rule delegation documentation is needed to verify whether the agency has met 

this commitment. 

Status_ OK 

Status_ OK 
17. 

18. 

of air toxics. The Part 61 and Part 63 standards are adopted into the Georgia Rules and 

incorporated into source operating permits. In addition to implementing the federal air 

toxics regulations, EPD has developed the Guidelines for Ambient Impact Assessment of 

Toxic Air Pollutant Emissions. The guidelines are used in the review of air quality permit 

applications. Permit engineers are trained on the use of the guidelines. 

Last EPA Reviewer: lpage- 08:17:14 on 01129/15 -lpage -lpage 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

19. Make case-by-case MACT determinations for all applicable sources under CAA, section 112(g) 

including appropriate compliance monitoring measures, and copy EPA Region 4 on all final 112(g) 

determinations. 

Response: Agree 

20. 

Last EPA Reviewer: lpage- 08:17:43 on 01129/15 -lpage -lpage 

Negotiation Status: Status_ OK 

Negotiation Comments: 

Mid Year Status: Status_OK 
22. Maintain a record of all approved alternatives to monitoring, testing, recordkeeping, and reporting 

requirements made for sources subject to MACT standards and report number of requests processed 

semi-annually (this is required by rule; see 40 CFR Part 63.91(g)(1)(ii)). 

Response: Agree 

23. 

Last EPA Reviewer: lpage- 08:17:51 on 01/29/15 -lpage -lpage 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

24. 

25. Prepare and submit CAA sections 111(d) and 129 state plans and letters of certification in accordance 

with regulatory timeframes. In addition, collect and submit reports on progress of sections 111 (d) and 

129 plans annually, pursuant to 40 CFR 60.25(e) and (f). 

Response: Agree 

26. 

Last EPA Reviewer: skukier- 07:45:07 on 01/20/15- skukier- skukier 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_ OK 

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Targets: result of concluded enforcement actions (5-year cumulative). (FY 2005-2008 baseline: 

480 million pounds, annual average over the period) 

• 

*information from EPA's 2011-2015 Strategic Plan 

(http://www.epa.gov/planandbudget/strategicplan.html). 

FY 2014 105 Grant Commitments: 

1. Ensure complete, accurate and timely data consistent with the Compliance Monitoring Strategy, High 

Priorities Violations Policy, and the AIRS Facility Subsystem (AFS) requirements under the 

Information Collection Request. 

2. 

Response: Agree. This commitment is accomplished through the use of the Integrated Air Information 

Platform database. The required MDR data is batch-uploaded to AFS once every two 

weeks. EPD interprets the recommended full compliance evaluation frequencies in the 

Compliance Monitoring Strategy (CMS) to apply to operating sources only. Temporarily 

closed sources, sources under construction, planned sources, and permanently shut down 

sources shall not be considered part of Georgia's CMS universe. 

Last EPA Reviewer: ktaylor- 11:33:52 on 01/30/15- ktaylor- ktaylor 

Negotiation Status: Status_ OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: Status_ OK 

Current Status: Status_OK 

Regional Staff Response: 
Last EPA Reviewer: ktaylor- 11:33:59 on 01/30/15- ktaylor- ktaylor 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: Status_OK 

Current Status: Status_OK 

Regional Staff Response: 

6. 

7. Inspect 25% of all NESHAP asbestos demolition/renovation projects. These projects should be selected 

so that all removal contractors are inspected at least once. Alternatively, lower inspection rates can be 

negotiated if an effective contractor certification program is in place. Lower inspection rates can also be 

negotiated if a non-notifier strategy is developed and implemented. 

8. 

Response: Georgia returned enforcement responsibilities, including inspections, back to EPA in March 

2009. Every year since, Georgia has consistently disagreed with this as a commitment. 

However, senior EPA and EPD management have recently commenced negotiations 

regarding the level of commitment Georgia is willing to reassume with regards to the 

Asbestos NESHAP program. 

Last EPA 

Reviewer: 

Negotiation 

Status: 

Negotiation 

Comments: 

Mid Year 

Status: 

pmcilvai- 14:42:58 on 01122115- pmcilvai- pmcilvai 

Status_Not_Acceptible 

EPA management is discussing the issue with GA EPD - GA gave back the 

enforcement and inspection elements of the NESHAP program in 2009 - EPA 

Region 4 now performs these functions. 

Status_Not_Acceptible 
9. 

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10. Observe asbestos work practices in progress whenever possible to assess compliance. Special priority 

will be given to entering a project of a contractor with a work practice violation within the previous 12-

month period. 

11. 

12. 

Response: Georgia returned enforcement responsibilities, including inspections, back to EPA in March 

2009. Every year since, Georgia has consistently disagreed with this as a commitment. 

However, senior EPA and EPD management have recently commenced negotiations 

regarding the level of commitment Georgia is willing to reassume with regards to the 

Asbestos NESHAP program. 

Last EPA 

Reviewer: 

Negotiation 

Status: 

Negotiation 

Comments: 

Mid Year 

Status: 

Mid Year 

Comments: 

Current Status: 

Regional Staff 

Response: 

pmcilvai- 14:43:18 on 01122/15- pmcilvai- pmcilvai 

Status_Not_Acceptible 

EPA management is discussing the issue with GA EPD - GA gave back the 

enforcement and inspection elements of the NESHAP program in 2009 - EPA 

Region 4 now performs these functions. 

Status_Not_Acceptible 

EPA management is discussing the issue with GA EPD - GA gave back the 

enforcement and inspection elements of the NESHAP program in 2009 - EPA 

Region 4 now performs these functions. 

Status_Not_Acceptible 

EPD - GA gave back the enforcement and inspection elements of the NESHAP 

program in 2009 - EPA Region 4 now performs these functions. 

13. ACTS/NARS database is no longer available. Report the following asbestos NESHAP activities at least 

forty-five (45) days after each fiscal six-month period 1) number of notifications received; 2) number 
14. 

15. 

Last EPA 

Reviewer: 

Negotiation 

Status: 

Negotiation 

Comments: 

Mid Year 

Status: 

Mid Year 

Comments: 

Current Status: 

Regional Staff 

Response: 

pmcilvai- 14:43:33 on 01122/15- pmcilvai- pmcilvai 

Status_Not_Acceptible 

EPA management is discussing the issue with GA EPD - GA gave back the 

enforcement and inspection elements of the NESHAP program in 2009 - EPA 

Region 4 now performs these functions 

Status_Not_Acceptible 

EPA management is discussing the issue with GA EPD - GA gave back the 

enforcement and inspection elements of the NESHAP program in 2009 - EPA 

Region 4 now performs these functions. 

Status_Not_Acceptible 

EPD - GA gave back the enforcement and inspection elements of the NESHAP 

program in 2009 - EPA Region 4 now performs these functions. 

16. Maintain a State/Local health and safety plan for asbestos demolition/renovation inspectors. Plan to 

include medical monitoring, protective equipment, and training as minimum requirements. 

Alternatively, implement EPA's "Health and Safety Guidelines for EPA Asbestos Inspectors,"·aated· 

March 1991. These documents will be reviewed by EPA during state program visits. 

17. 

Response: Georgia returned enforcement responsibilities, including inspections, back to EPA in March 

2009. Every year since, Georgia has consistently disagreed with this as a commitment. 

However, senior EPA and EPD management have recently commenced negotiations 

regarding the level of commitment Georgia is willing to reassume with regards to the 

Asbestos NESHAP program. 

Last EPA 

Reviewer: 

pmcilvai- 14:43:52 on 01122/15- pmcilvai- pmcilvai 
18. 

Mid Year EPA management is discussing the issue with GA EPD - GA gave back the 

Comments: enforcement and inspection elements of the NESHAP program in 2009 - EPA 

Region 4 now performs these functions. 

Current Status: Status_Not_Acceptible 

EPD - GA gave back the enforcement and inspection elements of the NESHAP 

Regional Staff program in 2009 - EPA Region 4 now performs these functions. 

Response: 

19. Recommend (where appropriate) cases and provide support to the EPA Criminal Enforcement 

Program. 

Response: Agree 

20. 

Last EPA Reviewer: ktaylor- 11:34:24 on 01/30/15- ktaylor- ktaylor 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: Status_ OK 

Current Status: Status_OK 

Regional Staff Response: 

21. 

22. Implement the CAA section 112(r) program for affected sources. Develop a 112(r) work plan with 

projected priorities including risk management program audits and facility inspections. Compile endof-year report of accomplishments. 

Response: Agree 
Mid Year Status: Status_OK Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

24. 25. Submit a narrative summary of compliance assistance activities for non major sources. 

26. 

27. 

Response: EPD will meet this commitment by submitting the State Small Business Stationary Source 

Technical and Environmental Compliance Assistance Program Annual Reporting Form 

(OMB Control Number 2060-0337). 

Last EPA Reviewer: ktaylor- 11:34:42 on 01130/15- ktaylor- ktaylor 

Negotiation Status: Status_ OK Negotiation Comments: 

Mid Year Status: Status_OK Mid Year Comments: Status_ OK 

Current Status: Status_OK 

Regional Staff Response: 

28. Encourage self disclosure of violations by non major sources. 

Response: Agree. Self-disclosed violations will be encouraged by treating such cases more leniently 

on a case-by-case basis. 
Mid Year Status: Status_OK 

Mid Year Comments: Status_OK 

Current Status: Status_OK 

Regional Staff Response: 

30. 31. Utilize compliance incentives for non major sources as appropriate. 

32. 

33. 

Response: Agree. Compliance audits will be conducted by the SSCP for selected source categories, 

and a grace period to achieve compliance will be allowed before formal enforcement action 

is taken, unless serious violations are discovered. 

Last EPA Reviewer: ktaylor- 11:35:00 on 01/30/15- ktaylor- ktaylor 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: Status_ OK 

Current Status: Status_OK 

Regional Staff Response: 

34. Develop and implement compliance incentive activities for non-major sources. 

Response: Agree. Additional compliance incentives will be pursued as the budget allows. 

35. 
Mid Year Comments: Status_OK 

Current Status: Status_OK 

Regional Staff Response: 

36. 
FY 2014 105 Grant Commitments: 

Emission Inventories - Criteria Air Pollutants 

1. Develop and submit to EPA, emissions inventory information for all applicable point sources, CAP 

pollutants and time frames consistent with the Air Emissions Reporting Requirements (AERR) Rule 

published in the December 17, 2008; 73 Federal Register 76539 and any clarifying or updated·policy. 

The 2012 CAPs point source emissions inventories should be submitted to EPA Headquarters through 

the Emissions Inventory System (EIS) Gateway by no later than December 31, 2013. Early submittals 

are recommended. Also, support Emissions Inventory System (EIS) in finishing the 2011 National 

Emissions Inventory (NEI), work towards submission of the 2013 CAP point sources (but not submit 

until the following fiscal year), and plan for any state/local data system changes needed to support the 

2014 NEI. Information on the EIS Gateway can be found at: 

http://www.epa.gov/ttn/chief/eis/gateway/index.html. The Chief of the Regulatory Development 

Section should be notified via email when the 2012 submittal is made to EPA. 

Response: Agree 

2. 

Last EPA Reviewer: elouis- 13:31:57 on 01/27115- bjohnson- bjohnson 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 
6. 

Last EPA Reviewer: mechols- 11:32:58 on 01120/15- mechols- mechols 

Negotiation Status: Status_OK 

Negotiation Comments: 

Mid Year Status: Status_OK 

Mid Year Comments: 

Current Status: Status_ OK 

Regional Staff Response: 

7. 

8. Participate with EPA in an end of year evaluation of performance to be completed by January 31, 2015. 

This evaluation will be based on an annual summary report submitted by the agency by December 31, 

and on progress reports received throughout the year. In accordance with 40 CFR 35.115 and the EPA 

Policy on Managing Unliquidated Obligations and Ensuring Progress under EPA Assistance 

Agreements, the joint evaluation process will include: 

A. discussions of accomplishments as measured against work plan commitments; 

B. discussions of the cumulative effectiveness of the work performed under all work plan 

components; 

C. discussions of existing and potential problem areas; 

D. suggestions for improvement, including, where feasible, schedules for making improvements; 

and 

E. discussions of how effectively grant funds were managed and utilized, taking into account any 

accumulation of unliquidated obligations. 

Response: Agree 

Last EPA Reviewer: mechols- 11:32:47 on 01120/15- mechols- mechols 
Current Status: Status_ OK 

Regional Staff Response: 

Agency Expectations of EPA (optional) 

9. Enter Agency's expectations of EPA (i.e., assistance needed from EPA to meet the commitments under 

this Air Planning Agreement). 

Response: 

-

. 

10. 

Last EPA Reviewer: mechols- 13:36:16 on 06/09/14- ddeakin- ddeakin 

Negotiation Status: Status_OK Negotiation Comments: 

Mid Year Status: Status_OK Mid Year Comments: 

Current Status: 

Regional Staff Response: 

11.