1



# Technical Support Document for

Georgia Regional Haze SIP Submittal

January 201 2

U.S. EPA

– Region 4 Atlanta, GA2 

### Technical Support Document (TSD) for Georgia Regional Haze SIP Submittal

Table of Contents

I. Background

II. Summary of EPA’s Action

III. Evaluation of State Regional Haze Submittal

A. Identification of Areas

B. Reasonable Progress Goals Development

1. Calculations of Baseline Visibility Conditions

2. Calculations of Natural Visibility Conditions

3. Uniform Rate of Progress (UROP or “Glidepath”)

for Reasonable Progress

C. Long Term Strategy

1. Technical Basis for Strategy

2. Identification of Sources and Factors to be

Considered

3. Source or Source Category Specific Analyses for Reasonable Progress

4. Enforceability of Reasonable Progress Measures

D. Best Available R etrofit Technology (BART) Requirements

1. Identification of all BART Eligible Sources

2. Modeling or other Demonstrations for BART Exempt Sources

3. Identification of Sources Addressed by the Clean Air Interstate Rule ( CAIR )

4. Source Specific BART Determinations

5. Enfo rceability of BART

E. Coordination of Regional Haze and RAVI Requirements

F. Monitoring Strategy and Other Implementation Requirements

G. Emission Inventory

IV. Conclusion

_______________________________________________________________________

Note : Italicized text i n this document that appears under the “State Regional Haze Submittal” headings are excerpts from relevant portions of the Georgia regional haze submittal as cited. Figure and table citations under these headings reflect the actual

references as listed in the State’s SIP submittal. Page numbers refer to the SIP Narrative, unless otherwise specified.3 

### TSD for Georgia Regional Haze SIP Submittal

I. Background

In Section 169A of the 1977 Amendments to the Clean Air Act (CAA), Congress set forth a program for protecting visibility in Federal Class I areas which calls for the “prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Federal Class I areas which impairment results from manmade air pollution.” Congress adopted the visibility provisions to protect visibility in 156 Federal Class I areas, which include certain national parks , memorial parks, and wilderness areas over a certain size, and all international parks . These areas are defined at 40 CFR 81.400

, and listed by s tate at 40 CFR 81.401

- 81.437 . On December 2, 1980, EPA promulgated regulations to address visibility impairment that is “reasonably attributable” to a single source or small group of sources. 45 FR 80084

. These regulations represented the first phase in addressing visibility impairment and deferred action on regional haze that emanates from a variety of sources until monitoring, modeling and scient ific knowledge about the relationships between pollutants and visibility impairment improved.

In the 1990 Amendments to the CAA, Congress added Section 169B and called on EPA

to issue r egional h aze rules. The Regional Haze rule (RHR) that EPA promulgated on July 1, 1999 (64 FR 35713) revised the existing visibility regulations to integrate provisions addressing regional haze visibility impairment and establish a comprehensive visibility protection program for Federal Class I areas. States are required to submit state implementation plans (SIPs) to EPA that set out each state’s plan for complying with the RHR, including consultation and coordination with other states and with Federal Land Managers (FLMs). States must submit a r egional h aze SIP to EPA with in three years after the date of designation of areas under the National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM2.5) . EPA promulgated PM2.5 designations on December 17, 2004, and thus, regional haze SIPs were to be submitted t o EPA by December 17, 2007, which is also specified at 40 CFR 51.308(b).

The RH R addressed the combined visibility effects of various pollution sources over a wide geographic region. Consequently, all 50 states , including those without Class I

areas
, Washington, D.C., and the Virgin Islands, are required to submit Regional Haze

SIPs. 40 CFR 51.300(b)(3). EPA designated five Regional Planning Organizations (RPOs) to assist with the coordination and cooperation needed to address the visibility

issue. Th e RPO that makes up the southeastern portion of the contiguous United States is known as VISTAS (Visibility Improvement

– State and Tribal Association of the Southeast) . VISTAS members include : the E astern B and of the Cherokee Indians , other Federally Re cognized Tribes and Local Air Programs within the geographic area, and the following states: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, and West Virginia. The State of Georgia Department of Natura l Resources through the Georgia Environmental Protection Division (GA EPD) chose to participate in VISTAS to develop the technical analyses needed to fulfill the requirements of the RH R.4 Figure 1. Geographical Areas of Regional Planning Organizations

Figure 2 . Class I Areas in the VISTAS Region5

II. Summary of Action

EPA is proposing a limited approval of a revision to the Georgia state implementation plan (SIP) submitted by the State of Georgia through the Georgia Department of Natural Resources, Environmental Protection Division (GA EPD), on February 11, 2010, as

sup plemented on November 19, 2010 , that addresses regional haze for the first implementation period. This SIP revision, as supplemented, addresses the requirements of the Clean Air Act (CAA) and EPA’s rules that require states to prevent any future and

remed y any existing anthropogenic impairment of visibility in mandatory Class I areas (national parks and wilderness areas) caused by emissions of air pollutants from numerous sources located over a wide geographic area (also referred to as the “regional haze p rogram”). States are required to assure reasonable progress toward the national goal of achieving natural visibility conditions in Class I areas. EPA is proposing a limited approval of this SIP revision to implement the regional haze requirements for

Geo rgia on the basis that the revision, as a whole, strengthens the Georgia SIP. EPA has previously proposed a limited disapproval of the Georgia regional haze SIP because of deficiencies in the State’s regional haze SIP submittal arising from the remand by the

U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit ) to EPA of the Clean Air Interstate Rule (CAIR). Consequently, EPA is not proposing to take action in this rulemaking to address the State’s reliance on CAIR to meet certain regi onal haze requirements.6

III. Evaluation of State Regional Haze Submittal

A

. Identification of Areas

The SIP must identify each mandatory Class I Federal area located within the State and in each mandatory Class I Federal area located outside the State that may be affected by emissions from within the State. Where a mandatory Class I Federal area is in multiple states, a description of how the states have assigned responsibilities for the area needs to

be included.

State Regional Haze Submittal Georgia SIP Narrative, Pages 4

- 5:

Georgia has three Class I areas within its borders: Cohutta Wilderness Area, Okefen okee Wilderness Area and Wolf Island as designated in 40 CFR Part 81 Subpart 408 where visibility has been determined to be an important value. The Georgia Environmental Protection Division (GA EPD) in the Georgia Department of Natural Resources is respons ible for developing the Regional Haze SIP. This SIP establishes reasonable progress goals for visibility improvement at each of these Class I areas, and a long

- term strategy that will achieve those reasonable progress goals within the first regional haze p lanning period.

In developing this SIP, we have also considered that emission sources outside of Georgia may affect visibility at these Georgia Class I areas, and emission sources within Georgia that may affect visibility at the following Class I areas i n neighboring states. Through VISTAS, the southeastern states have worked together to assess state

- by

- state contributions to visibility impairment in specific class I areas, including those in GA and those affected by emissions from Georgia.

.... Visibility at the following class I areas in the neighboring states may be affected by emission sources with Georgia: • Cape Romain Wilderness Area, South Carolina • Linville Gorge Wilderness Area, North Carolina • Shining Rock Wilderness Area, North Carolina • Joyce Kilmer

- Slick Rock Wilderness Area, North Carolina and Tennessee • Great Smoky Mountains, Tennessee, North Carolina • Sipsey Wilderness area, Alabama • St. Marks, Florida • Chassahowitzka, Florida7

EPA Findings : EPA proposes to find that G eorgia has adequately addressed this provision.8

III. Evaluation of Regional Haze Submittal

B

. Reas onable Progress Goals Developmen t
B.1. Calculations of B aseline V isibility C onditions : ((40 CFR 51.308(d)(2)(i))

The period for establishing baseline visibility conditions is 2000 to 2004. For each mandatory Class I Federal area located within the State, the State must determine the average degree of visibility impairment (expressed in deciviews) for the most impair ed and least impaired days (i.e. the 20% most impaired days and 20% least impaired days) for each of these years

. Baseline conditions are the average of the se annual values

. For each mandatory Class I Federal area located within the State, the SIP needs to calculate the number of deciviews by which baseline conditions exceed natural visibility conditions for the most impaired and least impaired days.

Where onsite monitoring is not available the baseline visibility conditions must be established using th e most representative monitoring available for the 2000

- 2004 period

in consultation with EPA.

State R egional H aze Submittal Georgia SIP Narrative, Pages 12

- 13:

2.2 Estimating Baseline Conditions for Georgia Class I Areas Baseline visibility conditions at each Georgia Class I area are estimated using sampling data collected at IMPROVE monitoring sites. A 5 year average (2000 to 2004) was calculated for each of the 20 percent worst and 20 percent best visibility days in

acco rdance with 40 CFR 51.308(d)(2) and the US EPA Guidance for Tracking Progress Under the Regional Haze Rule. IMPROVE data records for Okefenokee for the period 2000 to 2004 meet US EPA requirements for data completeness (75 percent for the year and 50 perce nt for each quarter). Cohutta did not meet completeness criteria in 2000, 2001, and 2003. Data records for 2001 and 2003 were filled using data substitution procedures outlined in Appendix B, but there was too little data in 2000 to perform data filling. I MPROVE does not operate a monitor at Wolf Island and considers the IMPROVE monitor at Okefenokee Wilderness Area to be representative of visibility at Wolf Island. The light extinction and deciview visibility values for the 20 percent worst and 20 percent best visibility days at the Class I areas are based on data and calculations included in Appendix B of this SIP. The 20 percent worst and 20 percent best visibility days with their respective extinction values are presented in Appendix B.1.9

EPA Finding s : EPA proposes to find that G eorgia has adequately addressed th is provision. EPA proposes to concur with the use of the data substitution methodology for

2001 and 200 3 for the Cohutta Wilderness Area and the use of 2001

- 2004 data due to the

lack of sufficient data from 2000 because the procedures used in Appendix B

- 1 are consistent with EPA guidance on data substitution

. EPA also EPA proposes to find that

the use of data from the IMPROVE site in the Okefenokee Wilderness area is appropriate

for esta blishing baseline conditions for the Wolf Island W ilderness area because the site is sufficiently close to the Okefenokee Wilderness area to be a surrogate for

measurements at Wolf Island.10

III. Evaluation of Regional Haze Submittal

B . Reasonable Progress Goals Development

B.2. Calculations of N atural V isibility C onditions: ((40 CFR 51.308(d)(2)(iii))

For each mandatory Class I Federal area located within the State, natural visibility conditions must be calculated by estimating the degree of visibility impairment existing under natural conditions for the most impaired and least impaired days, based on

a vailable monitoring information and appropriate data analysis techniques as specified in

EPA

- 454/B

- 03

- 005

, Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Program or an approved alternative technique

.

State R egional H aze Subm ittal Georgia SIP Narrative, Pages 11

- 12:

2.1 Estimating Natural Conditions for Georgia Class I Areas Natural background visibility, as defined in 2003 US EPA guidance, is based on annual average concentrations of fine particle components. The same annual average natural background visibility is assumed for all Class I areas in the eastern United States (separate values are estimated for the western United States). Natural background visibility for the 20 percent worst days is estimated by assuming that fine particle concentrations for natural background are normally distributed and the 90 th percentile of the annual distribution represents natural background visibility on the 20 percent worst days.

In the 2003 guidance, US EPA also provided that states may use a “refined approach” to estimate the values that characterize the natural visibility conditions of the Class I areas. The purpose of such a refinement would be to provide more accurate estimates with changes to the extinction algorithm that may include the concentration values, factors to calculate extinction from a measured particular species and particle size, the extinction coefficients for certain c ompounds, geographical variation (by altitude) of a fixed value, and the addition of visibility pollutants.

In 2005, the IMPROVE Steering Committee made recommendations for a refined equation that modifies the terms of the original equation to account for the most recent data. The choice between use of the old or the new equation for calculating the visibility metrics for each Class I area is made by the state in which the Class I area is located.

b ext ≈ 2.2 x f

S (RH) x [Small Sulfate] + 4.8 f L (RH) x [Larg e Sulfate] + 2.4 x f

S (RH) x [Small Nitrate] + 5.1 f L (RH) x [Large Nitrate] + 2.8 x [Small Organic Mass] + 6.1 x [Large Organic Mass] + 10 x [Elemental Carbon] + 1 x [Fine Soil] + 1.7 x f

SS (RH) x [Sea Salt] + 0.6 x [Course Mass] + Rayleigh Scattering (Site Specific) + 0.33 x [NO 2 (ppb)]11

The new IMPROVE equation accounts for the effect of particle size distribution on light extinction efficiency of sulfate, nitrate, and organic carbon hence the total sulfate, nitrate and organic carbon compound concentrations are each split into two fractions, representing small and large size distributions of those components. The mass multiplier for organic carbon (particulate organic matter) is increased from 1.4 to 1.8.

New terms are added to the equation to account for li ght extinction by sea salt and light absorption by gaseous nitrogen dioxide. Site

- specific values are used for Rayleigh scattering to account for the site

- specific effects of elevation and temperature. Separate relative humidity enhancement factors are use d for small

- and large

- sized distributions of ammonium sulfate and ammonium nitrate and for sea salt. The elemental carbon (light

absorbing carbon), fine soil, and coarse mass terms do not change between the original and new IMPROVE equation.

The VISTAS s tates chose to use the new IMPROVE equation as the basis for the conceptual description because it takes into account the most recent review of the science and because it is recommended by the IMPROVE Steering Committee. For more detailed discussion of the two IMPROVE equations, see Appendix B.

Georgia EPD requested in writing (from Carol Couch to J.I. Palmer, dated August 19, 2008) to use the new IMPROVE equation to calculate light extinction effects from two

BART

- eligible facilities: Georgia Pacific Ceda r Springs and Georgia Power Plant Bowen. EPA Region IV approved this request in a letter dated September 11, 2008.

.... Georgia SIP Narrative, Pages 12

- 13:

2.3 Summary of Natural Background and Baseline Conditions for Georgia Class I

Areas

Table 2.3

- 1 presents estimated natural background and baseline visibility metrics for Georgia Class I areas. Note that Georgia is not considering international emissions to be a component of natural background. Baseline visibility on the 20 percent worst d ays at Cohutta Wilderness Area, Okefenokee Wilderness Area, and Wolf Island is generally between 27 and 30 dv. Natural background visibility at all three sites is predicted to be between 11 and 12 dv. The class I area with the worst visibility impairment i s Cohutta Wilderness Area at greater than 30 dv on the 20 percent worst days.12

EPA Findings : EPA proposes to find that Georgia has appropriately addressed this provision and that t he natural background conditions that were used in the reasonable

progres s assessment were developed in an acceptable manner. G A EPD requested in writing (from Carol Couch to J.I. Palmer, dated August 19, 2008) to use the new IMPROVE equation to calculate light extinction effects from two BART

- eligible facilities: Georgia Paci fic Cedar Springs and Georgia Power Plant Bowen. EPA Region 4 approved this request in a letter dated September 11, 2008. Although the request was for evaluating BART sources, the considerations for granting approval are identical and applicable for estim ating natural conditions ( Georgia SIP, Appendix H.9a and H.9.b)

.13

III. Evaluation of Regional Haze Submittal

B . Reasonable Progress Goals Development

B.3. Uniform Rate of Progress ( UROP or “ Glidepath ” ) for Reasonable Progress : (40 CFR 51.308(d )(1) and (40 CFR 51.308(d)(1) (i)(B))

For each mandatory Class I Federal area located within the State, the State must establish goals (expressed in deciviews) that provide for reasonable progress towards achieving natural visibility conditions. For each Class I area within the S tate, the S tate must analyze and determine the rate of progress needed to attain natural visibility conditions by the year 2064 and determine the uniform rate of visibility improvement (measured in deciviews) that would ne ed to be maintained during each implementation period in order to attain natural visibility conditions by 2064. The State must show that the reasonable progress goal for each mandatory Class I Federal area represents at least as much visibility improvement as is expected to result from implementation of other requirements of the CAA during the applicable planning period. 40 CFR 51.308(d)(1)(vi)

. The reasonable progress goals must provide for an improvement in visibility for the most impaired days over the p eriod of the implementation plan and ensure no degradation in visibility for the least impaired days over the same period.

State Regional Haze Submittal Georgia SIP Narrative, Pages 18

- 19 :

3.0 GLIDEPATHS FOR CLASS I AREAS IN GEORGIA The following are gl idepaths for the 20 percent most impaired days Cohutta Wilderness Area, assuming uniform rate of progress toward regional haze goals. Natural background visibility at all four sites is predicted to be between 11 and 12 dv. The Class I area with the steepes t slope from baseline to natural background conditions is Cohutta Wilderness Area. Note that the rate of progress for Okefenokee is considered representative of Wolf Island.

EPA Note: In the Georgia submittal (i.e., Figures 7.2.4

- 4 and 7.2.4

- 5), symbols denoting “Method 1” represent the State’s RPG for that area as predicted by modeling and for that case depicted in the figure (i.e., “best” or “worst” 20 % days).1415

G eorgia SIP Narrative, Pages 50

- 54 :

7.2.4 Model Results for the 2018 Base G4 Inventory Compared to the Uniform Rate of Progress Glidepaths for Georgia Class I Areas Using 2000

- 2004 IMPROVE monitoring data, the deciview values for the 20 percent best days in each year are averaged together, producing a single average deciview value for the best days. Similarly, the deciview values for the 20 percent worst days in each year are averaged together, producing a single average deciview value for the worst days.

Figures 7.2.4

- 1 through 7.2.4

- 6 il lustrate the predicted visibility improvement by 2018 resulting from the Base G4 inventory that represents implementation of existing Federal and State regulations, compared to the Uniform Rate of Progress glidepath for Cohutta Wilderness Area (COHU), Okef enokee Wilderness Area (OKEF), and Wolf Island Wilderness Area (WOLF). The pink lines show the target natural condition in 2064 for the 20 percent worst days or 20 percent best days, and the incremental deciview changes resulting from a uniform rate of pro gress between current and natural conditions in 2064 for average 20 percent worst visibility days or 20 percent best visibility days in the 2000

- 2004 baseline period. The purple lines show the improvement expected from existing and planned emission control s during the period of the first long

- term strategy.

Note that at Cohutta wilderness area in Georgia, visibility improvement on the 20 percent worst days is expected to be better than the uniform rate of progress glidepath by 2018 based solely on reducti ons from existing and planned emissions controls. A 4.4 dv improvement in visibility would meet uniform rate of progress in 2018; expected emissions reductions by 2018 are projected to achieve a 7.41 dv improvement.

Okefenokee Wilderness Area and Wolf Isl and expected emissions reductions by 2018 are projected to achieve a 3.28 dv of improvement in visibility, while a 3.6 dv of improvement in visibility would meet uniform rate of progress in 2018.

In Figure 7.2.4

- 7 the percentage of the target reduction ac hieved for the Georgia Class I areas using the new IMPROVE equation is 90

- 170 percent. This means that the rate of improvement is between

– 10 to +70 percent of the required uniform rate of progress by

2018.

In addition to improving visibility on the 20 pe rcent worst visibility days, states are also required to protect visibility on the 20 percent best days at the Class I areas. As illustrated in Figure 7.2.4

- 8, visibility on the 20 percent best days is projected to improve

in 2018 at all VISTAS Class I are as as a result of the 2018 Base G4 emissions reductions. In Figure 7.2.4

- 8 the percentage of the target achieved for the Georgia Class I areas is

about

- 10 percent. Zero percent change would mean no change in visibility;

- 10 percent means that visibility i s better than no change, or a 10 percent improvement (values lower than current conditions).16

The expected change in visibility at any VISTAS and neighboring class I areas between

2000

- 2004 baseline conditions on the 20 percent worst days and 2018 projecti ons for Base G4 is illustrated in Figure 7.2.4

- 7. In contrast, natural background visibility conditions for the 20 percent best days are illustrated in Figure 7.2.4

- 8.171819

EPA Findings : EPA proposes to find that Georgia has adequately addressed this provision.20

III. Evaluation of Regional Haze Submittal

C . Long

- Term Strategy

C.1. Technical Basis for Strategy (40 CFR 51.308(d )( 3)(iii))

The SIP must document the technical basis, including modeling, monitoring and

emissions information, on which the State is relying to determine its apportionment of emission reduction obligations necessary for achieving reasonable progress in each mandatory Class I Federal area it affects. The State may meet this requirement by relying

on te chnical analyses developed by the regional planning organization and approved by all State participants.

Modeling is not used to determine reasonable progress goals and does not determine whether reasonable progress has been met. Modeling is one part of the reasonable progress analysis. The modeling results are used to compare progress made through emission reductions with future year visibility at Class I areas

. Note that the emission inventory requirements under 40 CFR 51.308(d)(4)(v) are addressed in this section.

State Regional Haze Submittal

EPA Note : The RHR requires states to establish RPGs for visibility improvement at each affected Class I area covering each approximately 10

- year period until 2064. Georgia’s first set of RPGs will comprise a long term strategy (LTS) covering the period from the present until 2018. Appendix H of the Georgia submittal provides an overview

of this first LTS.

The following is taken and/or summarized from Georgia’s January 25, 2010 , regional

haze SIP submitta l :

Georgia’s LTS contains the following components:

I. Inventory of all controls required or expected under all federal and state regulations by 2009 and 2018.

II. Modeled expected visibility improvement and Comparison of modeling results for

2018 to the unifor m rate of progress, or “glidepath” for Georgia’s Class I area. (See also EPA TSD Section III.B.3)

III. Discussion of emissions sensitivity model runs to help determine which pollutants and source categories are contributing the most to visibility impairment at Georgia ’s Class I area (runs conducted by the Georgia Institute of Technology).

IV. Examination of SO 2 Area of Influence (AOIs) projections for each of the State’s Class I areas, and also for any surrounding states’ Class I areas whose AOI includes any Georgi a source s, to determine which specific sources are most likely to be impairing visibility at specific Class I areas.

V. Application of the four “statutory factors,” listed in 40 CFR 51.308(d)(1)(i)(A) to those sources identified in the previous step. (See also EPA TSD Section III.C.3)21

VI. Using the results of the four factor analyses, identification of control determinations for specific sources.

VII. Identification of BART

- eligible sources. (See also EPA TSD Section III.D.1 )

VIII. BART exemption modeling for BART

- eligib le sources. (See also EPA TSD

Section III.D.2 )

IX. BART determinations for sources subject to BART. (See also EPA TSD Section

III.D.3 )

X. Modeling demonstration of visibility improvement after inclusion of BART and reasonable progress control determinations.

XI. D etermination of RPGs based on the visibility improvement expected by 2018.

Georgia SIP Narrative, P age s 2 6

- 34 :

5.0 REGIONAL HAZE MODELING METHODS AND INPUTS Modeling for regional haze was performed by VISTAS for the ten southeastern states, including Georgia. The sections below outline the methods and inputs used by VISTAS for the regional modeling. Additional details are provided in Appendices C, D, and E. 5.1 Analysis Method The modeling analysis is a complex technical evaluation that begins by sele ction 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, progn ostic meteorological model routinely used for urban

- and regional

- scale photochemical, fine particulate matter, and regional haze regulatory modeling studies. • Emissions Model: The Sparse Matrix Operator Kernel Emissions (SMOKE) modeling system is an emis sions modeling system that generates hourly, gridded, speciated emission inputs of mobile, non

- road mobile, area, point, fire and biogenic emission sources for photochemical grid models. • Air Quality Model: US EPA‟s Models

- 3/ Community Multiscale Air Quality (CMAQ) modeling system is a „One

- Atmosphere‟ photochemical grid model capable of addressing ozone, particulate matter (PM), visibility and acid deposition at regional scale for periods up to one year. The US EPA Modeling Guidance (Appendix G) recommends modeling an entire year or at a minimum several days in each quarter of a year to adequately represent the range of meteorological conditions that contribute to elevated levels of fine particulate matter. The year 2002 was selected by VISTAS as the modeling year for this demonstration. Meteorological inputs were developed for 2002 using the meteorological model. Emission inventories were also developed for 2002 and processed through the emissions model. These inputs were used in the air quality m odel to predict fine particle mass and visibility. The model results for 2002 were compared with observed meteorological and air quality data to evaluate model performance. Several configurations of the meteorological and air quality model were evaluated t o select a configuration that gave the best overall performance for the VISTAS region. Once model performance was deemed adequate, the current

- and future

- year emissions were processed through the emissions model. The air quality modeling22

results are used to determine a relative reduction in future visibility impairment, which is used to determine reasonable progress. The complete modeling protocol used for this analysis can be found in Appendix D.

..... 5.4 Modeling Domains 5.4.1 Horizontal Modeli ng Domain The US EPA‟s modeling guidance (Appendix G) recommends a 12

- km modeling grid resolution for PM2.5 modeling while a 36

- km grid is considered acceptable for regional haze. For the VISTAS modeling, a coarse 36

- km grid resolution was used for modelin g the entire United States and a finer 12

- km grid was used to model the eastern United

States. The CMAQ model was run in one

- way nested grid mode. This allowed the larger outer domains to feed concentration data to the inner nested domain. The horizontal coarse grid modeling domain boundaries were determined through a national effort to develop a common grid projection and boundary. A smaller 12

- km grid, modeling domain was selected in an attempt to balance location of areas of interest, such as ozone and fine particulate matter non

- attainment areas, as well as Class 1 and wilderness areas for regional haze. Processing time was also a factor in choosing a smaller 12

- km grid, modeling domain.

The coarse 36

- km horizontal grid domain covers the continental Uni ted States. This domain was used as the outer grid domain for MM5 modeling with the CMAQ domain nested within the MM5 domain. Figure 5.4.1

- 1 shows the MM5 horizontal domain as the outer most, blue grid with the CMAQ 36

- km domain nested in the MM5 domain.

F igure 5.4.1

- 1 shows the MM5 horizontal domain as the outer most, blue grid with the CMAQ 36

- km domain nested in the MM5 domain. Figure 5.4.1

- 2 shows the 12

- km grid, modeling domain for the VISTAS region.

Figure 5.4.1

- 1. The MM5 horizontal domain is the outer most, blue grid, with the CMAQ 36

- km domain nested in the MM5 domain.23

Figure 5.4.1

- 2. A more detailed view of the 12

- km grid over the VISTAS region.

Emissions Controls Modeled ( G eorgia SIP Narrati ve , Pages 46

- 47 )

There are significant control programs being implemented between the baseline period and 2018. These programs are described in more detail below. 7.2.1 Federal and State Control Requirements • Clean Air Interstate Rule (CAIR). Utility pro jections are based on Integrated Planning Model.US EPA issued CAIR, which will permanently cap emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx) in the eastern United States. CAIR achieves large reductions of SO2and/or NOx emissions across 28 eas tern states and the District of Columbia. When fully implemented, CAIR will reduce SO2 emissions in these states by over 70 percent and NOx emissions by over 60 percent from 2003 levels. These

reductions were taken into account in the 2018 base G4 inventor y • Heavy Duty Diesel (2007) Engine Standard. A PM emissions standard for new heavy

duty engines of 0.01 grams per brake

- horsepower

- hour (g/bhp

- hr), to take full effect for diesels in the 2007 model year. Also includes standards for NOx and non

- methane hydrocarbons(NMHC) of 0.20 g/bhp

- hr and 0.14 g/ bhp

- hr, respectively. These NOx and NMHC standards will be phased in together between 2007 and 2010 for diesel engines. Sulfur in diesel fuel must be lowered to enable modern pollution

- control technology to b e effective on these trucks and buses. EPA will require a 97 percent reduction in the sulfur content of highway diesel fuel from its current level of 500 parts per million (low sulfur diesel, or LSD) to 15 parts per million (ultra

- low sulfur diesel, or UL SD). • Tier 2 Tailpipe. US EPA‟s Tier 2 is a fleet averaging program, modeled after the California LEV II standards. Manufacturers can produce vehicles with emissions ranging from relatively dirty to zero, but the mix of vehicles a manufacturer sells each year must have average NOx emissions below a specified value. • Large Spark Ignition and Recreational Vehicle Rule. In this rule, US EPA sets emission standards for these categories of non

- road engines and vehicles.

• Non

- Road Diesel Rule. In this rule, US EPA implements a low

- sulfur fuel requirement that affects both future (Commercial Marine Vessels) CMV and locomotive emissions. • Combustion Turbine MACT. US EPA issued this rule; however, the projection

inventories do not include the NOx co

- benefit effects resulting from this rule. EPA estimates them to be small compared to the overall inventory.24

• Industrial Boiler/Process Heater/RICE MACT. The Environmental Protection Agency (EPA) issued final rules to substantially reduce emissions of toxic air pollutants from industrial, commercial and institutional boilers, process heaters and from stationary reciprocating internal combustion engines (RICE). These rules reduce emissions of a number of toxic air pollutants, including hydrogen chloride, manganese, lead, arsenic and mercury by 2009. This rule also reduces emissions of sulfur dioxide and particulate matter in conjunction with the toxic air pollutant reductions. The applied Maximum Achievable Control Technology (MACT) control efficiencies w ere 4 percent for SO2 and 40 percent for PM10 and PM2.5. However, EPA‟s industrial boiler MACT rules were vacated on June 8, 2007. The emissions reductions that were modeled to account for the industrial boiler MACT were 1,343.5 tons/year of SO2, 879.4 ton s/year of PM2.5, and 1,304.2 tons/year of PM10. These reductions are insignificantly small (0.69% for SO2, 0.39% for PM2.5, and 0.13% for PM10) compared to the statewide totals (193,665.5 tons/year SO2; 225,104.5 tons/year PM2.5; and 1,002,873.2 tons/year PM10) and should not impact the conclusions made in the SIP. If another VISTAS “best and final” modeling run is performed, it will remove control assumptions solely due to this MACT rule.

• VOC 2

- , 4

- , 7

- , and 10

- year MACT Standards. The point source MACTs and associated emission reductions were designed from Federal Register (FR) notices and discussions with EPA‟s Emission Standards Division (ESD) staff. We did not apply reductions for MACT standards with an initial compliance date of 2001 or earlier, assu ming that the effects of these controls are already accounted for in the 2002 inventories supplied by the

States. • Georgia Rule 391

- 3

- 1

- .02(2)(yy), (i.e. Emissions of Nitrogen Oxides from Major sources based on Section 182 of the Federal CAA Amendments of 1990, requires that every major source (i.e. source with potential to emit > 50 tons/yr) of NOx located in 13 county Atlanta non

- attainment area should apply reasonably available control technology (RACT) in controlling NOx emissions. Georgia EPD has requ ired full compliance with NOx RACT limits since July 31, 1995; however, Georgia EPD has not taken these emission reductions into account in any inventory or modeling scenario.

• 1

- hr Ozone SIPs (Atlanta/Birmingham/Northern Kentucky). These SIPs have been

i mplemented for attainment and maintenance of the 1

- hour ozone National Ambient Air Quality Standard (NAAQS). Reductions from these SIPs have been taken into account in the 2018 modeling runs. • Georgia Rule 391

- 3

- 1

- .02(2)(sss), Multipollutant Control for E lectric Utility Steam Generating Units, was adopted in 2007. The effective date of the rule varies for various EGU units but will start being effective from December 31, 2008, and required controls for all affected units will be in place before June 1, 201 5. When fully implemented, Rule (sss) will reduce SO2 emissions by about 90 percent, NOx emissions by approximately 85 percent and mercury emissions by approximately 79 percent.

Sources and Pollutants relied on for LTS ( Georgia SIP Narrative, Pages 61

- 6 5 ) :

7.4 Relative Contributions to Visibility Impairment: Pollutants, Source Categories, and Geographic Areas An important step toward identifying further reasonable progress measures is to identify the key pollutants contributing to visibility impairment at each Class I area. To25

understand the relative benefit of further reducing emissions from different pollutants, source sectors, and geographic areas, VISTAS engaged the Georgia Institute of Technology to perform emission sensitivity model runs using CMAQ. Emissions sensitivities were initially performed for three episodes representing winter and summer conditions: January 2002, July 2001, and July 2002. These runs used the initial 2018 projections inventory and considered 30 percent reductions from specific pollutants, source categories, and geographic areas. Emissions sensitivities were repeated using the 2009 Base D projection inventory and two

- month

- long episodes from 2002: June 1

- July 10 and November 19 through December 19. Emissions in 2009 were reduced by 30 percent for each pollutant sensitivity run. The pollutant contributions that were

evaluated were: • SO2 from EGU sources in each VISTAS state, other RPOs in the VISTAS 12 km grid, and Boundary Conditions from outside the 12 km domain;

• SO2 from non

- EGU point sources in each VISTAS state, other RPOs, and Boundary Conditions; • NOx from ground level (on

- road plus non

- road plus area) sources in each VISTAS state and other RPOs; • NOx from point (EGU plus non

- EGU) sources in each VISTAS state an d other
RPOs; • NH3 from all sources in VISTAS and other RPOs; • Volatile Organic Compounds from anthropogenic and biogenic sources in the 12 km modeling domain; • Primary Carbon from all ground level sources in each VISTAS state and other
RPOs; • Primary Carbon from all point sources in each VISTAS state and other RPOs;

and • Primary Carbon from all fires in each VISTAS state and other RPOs.

.... As Figures 7.4

- 1 through 7.4

- 2 illustrate, the greatest visibility benefits on the 20 percent worst days for the Georgia Class I areas are projected to result from further reducing SO2 from EGUs. At the mountain Class I areas, benefits are projected from SO2 reductions from EGUs in several VISTAS states including Alabama, Georgia, Kentucky, North Carolina, South Caro lina, Tennessee, Virginia, and West Virginia. Contributions from other RPOs and from the boundary conditions are comparatively small and the greatest benefits would likely be from further EGU reductions within the VISTAS states.

MRPO states have some contribution, as do SO2 and SO4 coming into the modeling domain from outside the boundary. Additional, smaller benefits are projected from additional SO2 emission reductions from

non

- utility, industrial point sources. The pattern of relative SO2 contributi ons from non

EGUs among the various VISTAS states is similar to the pattern of relative SO2 contributions from EGUs.

.... We conclude that reducing SO2 emissions from EGU and non

- EGU point sources in the VISTAS states would have the greatest visibility ben efits for the GA Class I areas. Contributions from the Midwest RPO and MANE

- VU are greater at the Class I areas bordering these RPOs. Contributions from outside the VISTAS 12

- km modeling domain26

are more important for the coastal Class I areas. These result s are consistent with the CMAQ model results indicating that contributions from international emissions to visibility impairment at VISTAS Class I areas are greater closer to the boundaries of the modeling domain (see summary in Section 7.3 and further dis cussion in Appendix I).

Model Performance Evaluation ( Georgia SIP Narrative, Pages 3 5

- 42 ):

6.0 MODEL PERFORMANCE EVALUATION The initial modeling effort focused on evaluating previous regional air quality modeling applications and testing candidate model configurations for the SMOKE emissions and CMAQ model for the VISTAS 36

- km and 12

- km modeling domains. This effort resulted in a report recommending the model configuration for the annual emissions and air quality modeling, whi ch is included as part of the VISTAS Emissions and Air Quality Modeling Protocol. The evaluation of the meteorological modeling configuration can be found in Appendix F, with a summary of the final meteorological and air quality modeling configuration in A ppendix F and Appendix E, respectively. Air quality model performance for the 2002 modeling year was initially tested in 2004 using an early version of the VISTAS emissions inventory. In keeping with the one atmosphere objective of the CMAQ modeling platfo rm, model performance was evaluated based on measured ozone, fine particles, and acid deposition in the Air Quality System (AQS), IMPROVE, Speciated Trends Network (STN), Southeastern Aerosol Research and Characterization (SEARCH), National Acid Deposition Program (NADP) and Clean Air Status and Trends Network (CASTNet) monitoring networks (Figure 6.0

- 1).

.... 6.3 Georgia Class I Areas Performance

.... A cursory view of the stacked bar charts reiterates that sulfates are a large contributor

to light extinction in the Georgia Class I areas on both 20% best days and 20% worst days. The bar charts also suggest that organic carbon and nitrates are important on the 20% best days at the two IMPROVE sites of interest for Georgia. The bar charts for th e 20% best reiterate the general over prediction. The over prediction of sulfate on most of the 20% best days appears to be the crux of the over prediction, with the over prediction of nitrate factoring in heavily on some days. Comparing the 20% best day c harts to the 20% worst days charts, the various components of particle pollution play a more prominent role in the 20% best days than with the 20% worst days. Also, the species makeup on the 20% best days varies more widely compared to the 20% worst days. This suggests accurately modeling each species is especially important on the 20% best days. With the bar chart for the 20% worst days, you can see the general under prediction. The under prediction of sulfate on some of the 20% worst days appears to be th e cause of the overall under prediction with the under prediction of organic carbon factoring in heavily on few days.Overall, the GA EPD found model performance to fall within acceptable limits for model performance. The GA EPD further asserts the “one atmosphere” modeling performed by the VISTAS contractors is representative of27

conditions in the southeastern states and is applicable for use in attainment

demonstrations.

EPA Findings : In accordance with 40 CFR 51.308(d)(3), the State of Georgia provid ed the appropriate supporting documentation for all required analyses used to determine the State’s LTS. The technical analyses and modeling used to develop the glidepath and to support the
LTS are consistent with EPA’s RHR and interim and final EPA Model ing Guidance. EPA proposes to accept the VISTAS technical modeling to support the LTS and to determine visibility improvement for the uniform rate of progress because the modeling system was chosen and simulated according to EPA Modeling Guidance. EPA pr oposes to agree with the VISTAS model performance procedures and results, and that the CMAQ is an appropriate tool for the regional haze assessments for the Georgia LTS and regional haze SIP.

CAIR is also an element of Georgia’s LTS. CAIR rule revisions were approved into the Georgia SIP in 2009. See 72 FR 57202 (October 9, 2007). Georgia opted to rely on CAIR emission reduction requirements to satisfy the BART requirements for SO 2 and

NO X from EGUs. See 40 CFR 51.30 8(e)(4). Therefore, Georgia only required its

BART

- eligible EGUs to evaluate PM emissions for determining whether they are subject to BART, and if applicable, for performing a BART control assessment. Additionally, for this first implementation period, G eorgia concluded that no additional controls beyond CAIR are reasonable for reasonable progress for SO 2 for subject EGUs for Class I areas that are clearly expected to meet or exceed the glidepath.

Prior to the remand of CAIR, EPA believed the State’s reliance on CAIR for specific BART and reasonable progress provisions affecting its EGUs was adequate. The regional haze provisions specify that a state may not adopt a RPG that represents less

visibil ity improvement than is expected to result from other CAA requirements during the planning period (40 CFR 51.308(d)(1)(vi)). As such, Georgia took into account emissions reductions anticipated from the CAIR in determining its 2018 RPGs.

The RHR allows states to implement an alternative program in lieu of BART so long as the alternative program can be demonstrated to achieve greater reasonable progress toward the national visibility goal than would BART. Under regulations issued in 2005 revising the reg ional haze program, EPA made just such a demonstration for CAIR. See 70 FR 39104 (July 6, 2005). EPA’s regulations provide that states participating in the CAIR cap

- and trade program under 40 CFR part 96 pursuant to an EPA

- approved CAIR

SIP or which rema in subject to the CAIR Federal Implementation Plan in 40 CFR part 97

need not require affected BART

- eligible electrical generating (EGUs) to install, operate,

and maintain BART for emissions of SO 2 and NOx. See 40 CFR 51.308(e)(4). Because

CAIR did not a ddress direct emissions of PM, states were still required to conduct a BART analysis for PM emissions from EGUs subject to BART for that pollutant. Challenges to CAIR, however, resulted in the remand of the rule to EPA. See North

Carolina v. EPA , 550 F.3 d 1175 (D.C. Cir. 2008).28

EPA issued a new rule in 2011 to address the interstate transport of NOx and SO 2 in the

eastern United States. See 76 FR 48208 (August 8, 2011) (“the Transport Rule,” also

known as the Cross

- State Air Pollution Rule). On Decem ber 30, 2011, EPA proposed to find that the trading programs in the Transport Rule would achieve greater reasonable progress towards the national goal than would BART in the states in which the Transport Rule applies. See 76 FR 82219. Based on this propo sed finding, EPA also proposed to revise the RHR to allow states to substitute participation in the trading programs under the Transport Rule for source

- specific BART. EPA has not yet taken final action on that rule. Also on December 30, 2011, the D.C. C ircuit issued an order addressing the status of the Transport Rule and CAIR in response to motions filed by numerous parties seeking a stay of the Transport Rule pending judicial review. In that order, the D.C. Circuit stayed the Transport Rule pending th e court’s resolutions of the petitions for review of

that rule in EME Homer Generation, L.P. v. EPA (No. 11

- 1302 and consolidated cases). The court also indicated that EPA is expected to continue to administer CAIR in the

interim until the court rules on the petitions for review of the Transport Rule.

In a separate action, EPA has proposed a limited disapproval of the Georgia regional haze SIP because of deficiencies in the State’s regional haze SIP submittal arising from the

State’s reliance on C AIR to meet certain regional haze requirements. See 76 FR 82219 (December 30, 2011). EPA is not proposing to take action in this rulemaking on issues associated with Georgia’s reliance on CAIR in its regional haze SIP.

In addition , on July 30, 2007, the D.C. Circuit mandated the vacatur and remand of the Industrial Boiler MACT Rule. Notwithstanding the vacatur of this rule, the VISTAS states, including Georgia , decided to leave these controls in the modeling for their regional haz e SIPs since it is believed that by 2018, EPA will have re

- promulgated an industrial boiler MACT rule or the states will have addressed the issue through state

- level

case

- by

- case MACT reviews in accordance with section 112(j) of the CAA.

EPA proposes to find this approach acceptable for the following reasons. Effective July 30, 2007, the D.C. Circuit mandated the vacatur and remand of the Industrial Boiler

MACT Rule. 1 This MACT was vacated since it was directly affected by the vacatur and

remand of the Commercial and Industrial Solid Waste Incinerator Definition Rule. EPA proposed a new Industrial Boiler MACT rule to address the vacatur on June 4, 2010, (75 FR 32006) and issued a final rule on March 21, 2011 (76 FR 15608). The VISTAS modeling included emissions reductions from the vacated Industrial Boiler MACT rule, and Georgia did not redo its modeling analysis when the rule was re

- issued. Even though Georgia’s modeling is based on the vacated Industrial Boiler MACT limits, the State’s modeling conc lusions are unlikely to be affected because the expected reductions due to the vacated rule were relatively small compared to the State’s total SO 2 , PM 2.5 , and coarse particulate matter (PM 10 ) emissions in 2018 (i.e., 0.1 to 0.7 percent, depending on the p ollutant, of the projected 2018 SO 2 , PM 2.5 , and PM 10 inventory). Thus, EPA does not expect that differences between the vacated and final Industrial Boiler MACT emissions limits would affect the adequacy of the existing Georgia regional haze SIP. If

ther e is a need to address discrepancies between projected emissions reductions from the

1 See NRDC v. EPA , 489 F.3d 1250 (D.C. Cir. 2007).29

vacated Industrial Boiler MACT and the Industrial Boiler MACT issued March 21, 2011 (76 FR 15608), EPA expects Georgia to do so in the State’s five

- year progress report.

References used in EPA ’s review:

1. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze

. EPA

- 454/B

- 07

- 002, April

2007. http://www.epa.gov/scram001/guidance/guide/final

- 03

- pm

- rh

- guidance.pdf

.

2. “(Draft) Guidance for Demonstrating Attainment of Air Quality Goals for PM2.5 and Regional Haze”, EP A, 2001. h ttp://www.epa .gov/ttn/scram/guidance_sip.htm

.

3. 2002 Base Year Emission Inventory SIP Planning: 8

- hr Oz o ne, PM2.5 and Regional

Haze

, EPA memorandum from Lydia Wegman to Peter Tsirigotis, November 18,

2002.

4. July 9, 2008

, e

- mail from Travis Blake

, Tennessee Department of Environmental Conservation, to Brenda Johnson , EPA Region 4 . Subject: R: question about MACT

reductions.

5. CAA §§112(j)(2), (3), (5), and (6).

6. CAA §505 specifies procedures for notification to the Administrator and affected

State s.30

III. Evaluation of Regional Haze Submittal

C . Long

- Term Strategy

C.2 . Identification of Sources and Factors to be Considered for Reasonable Progress : (40 CFR 51.308(d)(3)( iv

- v))

The State must identify all anthropogenic sources of visibility impairment considered by the State in developing its long

- term strategy. The State should consider major and minor stationary sources, mobile sources, and area sources. The State must consider , at a
min imum, the following factors in developing its long

- term strategy : (A) emission reductions due to ongoing air pollution control programs, including measures to address reasonably attributable visibility impairment; (B) m easures to mitigate the impacts of

co nstruction activities; (C) e missions limitations and schedules for compliance to achieve the reasonable progress goal; (D) source retirement and replacement schedules; (E) smoke management techniques for agricultural and forestry management purposes

includ ing plans as currently exist within the State for these purposes; measures to mitigate the impacts of construction activities; (F) enforceability of emission limitations and control measures; and the (G) anticipated net effect on visibility due to projecte d

c hanges in point, area, and mobile source emissions over the period.

State Regional Haze Submittal Georgia SIP Narrative , Pages 76

- 81:

7.6 Reasonable Progress Determinations for Individual Sources The following summarizes the process for determining reasonable progress for Georgia sources and the results of the determinations. This process was based on U.S. EPA‟s “Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program,”

June of 2007 [Reasonable Progress guidance]. For a detailed discussion of the reasonable progress assessments for all emissions units contributing greater than half a percent of sulfate impact to any Class I area in Georgia or in neighboring states, see Appendi x H.

7.6.1 Process for Determining Reasonable Progress Step 1: Determine pollutants of concern. VISTAS evaluated the species contribution on the 20 percent worst visibility days and concluded that sulfate accounted for greater than 70 percent of the visibility impairing pollution. The VISTAS States concluded that controlling SO2 emissions was the appropriate step in addressing the reasonable progress assessment for 2018. The VISTAS findings were consistent with the findings of SAMI. As stated previous ly, SAMI confirmed that sulfate particles account for the greatest portion of the haze affecting Class I areas in the Southern Appalachian region and that these sulfates were produced in large part from SO2 emissions from coal combustion.

Step 2: Determin e which source sectors should be evaluated for reasonable progress. Since SO2 point source emissions in 2018 are projected to represent greater than 95 percent of the total SO2 emissions inventory, the VISTAS states concluded that the focus31

should be on el ectric generating unit (EGU) and non

- EGU point sources of SO2

emissions

.

Step 3: Consideration of Emissions Reductions from State and Federal Control

Measures. 64 FR 35733 states that “In determining the emissions and visibility improvement

achieved durin g each implementation period, states should include all air quality improvements that will be achieved by other programs and activities under the CAA and any state air pollution control requirements.” In keeping with this recommendation, Georgia, as part o

f its long

- term reasonable progress analysis to consider potential sources contributing to visibility impairment, examined other CAA requirements such as CAIR. Under Georgia‟s CAIR rule for SO2 [391

- 3

- 1

- .02(13)], SO2 emissions from Georgia EGUs will be cap ped at 149,140 tons in 2015, a 70 % reduction from 2002 actual emissions. In addition, a 70 % reduction of SO2 emissions is expected during this time period across all CAIR

- affected EGUs in 28 eastern states. Through these programs between the present and 2018, EPD concluded that additional EGU control during this time period is not reasonable for sources that significantly contribute to visibility impairment at Class I areas that clearly projected to meet the uniform rate of progress (URP) in 2018. However

, for sources that significantly contribute to visibility impairment at Class I areas not clearly meeting the URP (such as Okefenokee and Wolf Island), EPD did consider additional controls at CAIR

- affected units.

For EGUs subject to CAIR, EPA evaluated a number of factors, including the cost of compliance and time necessary for compliance. In the CAIR rule, EPA determined “that the earliest reasonable deadline for compliance with the final highly cost effective control levels for reducing emissions was 20 15...” (70 FR 25197

– 25198, May 12, 2005). The State believes that the cost of compliance and time necessary for compliance are the dominant factors for determining if additional reductions would be reasonable from

CAIR

- subject EGUs. The detailed analyses i n the preamble to the May 12, 2005, CAIR rule support a conclusion that CAIR controls satisfy reasonable progress for SO2 for the first regional haze planning period ending in 2018.

The SO2 emission reductions that are predicted by the IPM to meet the CAI R requirements are not certain due to the current rule‟s reliance on unchecked trading and the use of banked Title IV allowances. The GA EPD intends to re

- evaluate the IPM predictions of SO2 reductions for CAIR for EGUs at the time of the first five

- year

p eriodic report [40 CFR 51.308(g)] to ensure that the reductions currently predicted by IPM for CAIR are in fact taking place where they are expected and needed .

The Cohutta Class I Area is expected, based on modeling, to clearly meet the glide slope in 2018. GA EPD has therefore concluded that CAIR constitutes reasonable measures for Georgia EGUs that significantly impact visibility in Cohutta during this first assessment

pe riod (between baseline and 2018). Because the Okefenokee, Wolf Island, and Saint Marks areas are not expected to clearly meet the glide slope, controls required under CAIR have not been deemed to constitute reasonable measures for Georgia EGUs that signifi cantly impact visibility in these Class I areas.32

Georgia Power Company, in anticipation of CAIR requirements, has committed to implementing SO2 emission reduction measures on 22 of its EGUs. All of the 22 affected units are located in the northern half of the state and their predicted emissions reductions have been accounted for in the modeling used to predict 2018 visibility levels

in this SIP. These reduction measures and the associated emissions reductions are
summarized in Table 7.6.1

- 1.

Step 4: Deter

mine which emission units would be evaluated based on impact. The GA EPD calculated the projected 2018 fractional contribution from all emission units within the SO2 Area of Influence for a given Class I area, including contributions from EGUs after planne d SO2 controls. EPD then identified those emission units with a contribution of half a percent or more to the sulfate visibility impairment at the specific Class I area. See section 5.0 of Appendix H for the rationale for the selection of the one

half perc ent threshold for this analysis. As noted in Step 3, SO2 controls on EGUs that impact visibility at Cohutta, as required by CAIR, are deemed to be reasonable measures. Therefore, these units were exempted from four

- factor evaluation even if

their sulfate visibility impairments were half a percent or more.

Step 5: Evaluate the four factors. Each emission unit identified in Step 4 above was evaluated using the following four statutory and regulatory factors of 1) cost of compliance, 2) time necessa ry for compliance, 3) the energy and non

- air quality environmental impacts of compliance, and 4) the remaining useful life of the emissions unit.33

7.6.2 Sources Eligible for Four Factor Analysis in Georgia As part of the Regional Haze reasonable progress goal analysis, GA EPD initially identified 29 emission units for analysis of additional controls for meeting the reasonable progress requirements of the Regional Haze program in accordance with the above four statutory factors. The 29 units were selected b ased on analyses that indicated that each one‟s contribution to total sulfate visibility impairment was at least 0.5% of the total sulfate visibility impairment at one or more Class I areas. The analysis for eligibility assumed that the units‟ 2018 sulfate emissions were their VISTAS

- projected emissions. The eligible units are listed below in Table 7.6.2

- 1. Details of the eligible unit selection process are presented in Section 5.0 of Appendix H.34

GA EPD requested four

-

factor analyses from these facilities . In response to this request, additional information regarding projected 2018 actual emissions was received from a number of sources. As a result of this revised information, seven units were removed from consideration for additional controls based on an analysis that the emission units would not contribute half a percent or greater of the total sulfate visibility impairment at any Class I area in 2018. Those seven units are listed below in Table

7.6.2

- 2.35

In addition, three facilities requested and have received emission limits to reduce the sulfate visibility impairment from each emissions unit to less than 0.5%. Those facilities and the affected emission units are listed below in Table 7.6.2

- 3.

Furthermore, one of the emissions units is subject to B est Available Retrofit Technology (BART) Review under the Regional Haze Rule. In accordance with EPA‟s June 1, 2007 ”Guidance For Setting Reasonable Progress Goals under the Regional Haze Program” (pages 4

- 2 and 4

- 3), for emissions units subject to BART, t he State will already have completed a BART analysis. Since the BART analysis is based, in part, on an assessment of many of the same factors that must be addressed in establishing reasonable progress goals, it is reasonable to conclude that any control re quirements imposed in the BART determination also satisfy the RPG

- related requirements for source review in the first RPG planning period. (This exclusion does not include units at facilities that are exempt from BART review through screening modeling.) Th at emissions unit is Interstate Paper

– Power Boiler F1.

Georgia SIP Narrative, P age 110 :

Section 308(d)(3)(v) of the regional haze rule lists several factors that must be

addressed in each SIP. These factors include smoke management techniques for agricultural and forestry management purposes and measures to mitigate emissions from

construction activities.

As discussed in Section 2.4 and demonstrated in Figures 2.4

- 1 and 2.4

- 2, elemental carbon (sources include agriculture, prescribed wildland fires, and wildfires) is a relatively minor contributor to visibility impairment at the Class I areas in Georgia.36

Ho wever, on July 11, 2008, GA EPD entered into a memorandum of understanding with the Georgia Forestry and Georgia Department of Natural Resources Wildlife Resources Division adopting a smoke management plan that addresses the issues laid out in US

EPA‟s 199 8 draft guidance for smoke management plans. This plan is sufficient to satisfy the directive in section 308(d)(3)(v)(E). A copy of the current smoke management plan can be obtained from Georgia EPD, or it can be viewed on the Georgia EPD web page.

Georgi a‟s Rules for Air Quality Control include requirements for precautions to prevent fugitive dust from becoming airborne and also limit the opacity of fugitive emissions to less than 20 percent. The requirements of rule 391

- 3

- 1

- .02(n) include preventive

meas ures for construction activities and are deemed adequate to satisfy the directive in Section 308(d)(3)(v)(B) of the Regional Haze rule. The current version of Georgia‟s air rules is available on the Georgia EPD web site.

EPA Findings : EPA proposes to fin d that Georgia has adequately addressed this provision

. Prior to the remand of CAIR, EPA believed the State’s reliance on CAIR for specific BART and reasonable progress provisions affecting its EGUs was adequate. The regional haze provisions specify that a state may not adopt a RPG that represents less visibility improvement than is expected to result from other CAA requirements during the planning period (40 CFR 51.308(d)(1)(vi)). As such, Georgia took into account emissions reductions anticipated from the CAIR in determining its 2018 RPGs.

In a separate action proposing limited disapproval of the regional haze SIPs of a number of states, EPA noted that these states relied on the trading programs of CAIR to satisfy the BART requirement and the require ment for a LTS sufficient to achieve the state

adopted RPGs. See 76 FR 82219 (December 30, 2011). In that action, EPA proposed a limited disapproval of Georgia’s regional haze SIP submittal insofar as the SIP relied on CAIR. For that reason, EPA is not ta king action on that aspect of Georg i a’s regional

haze SIP in this action.37

III. Evaluation of Regional Haze Submittal

C . Long

- Term Strategy

C.3 . Source or Source Category Specific Analyses for Reasonable Progress : (40 CFR 51.308(d)(1)(i)(A)

For the significant sources and source categories located within the State and determined to be significantly impacting a mandatory Class I Federal area, the S tate must document

that it considered the costs of compliance, the time necessary for compliance, the energy

and non

- air quality environmental impacts of compliance, the remaining useful life of any potentially affected sources, and how these factors were taken into consideration in establishing the reasonable progress goal.

State Regional Haze Submittal Georgia SIP Narrative, Page s 8 1

- 9 8 :

7.6.3 Regional Haze Reasonable Progress Four

- Factor Analysis The regional haze rule requires that states consider the following factors and demonstrate how these factors were taken into consideration in select ing the reasonable progress goal: • Costs of compliance; • Time necessary for compliance; • Energy and non

- air quality environmental impacts of compliance; and • Remaining useful life of any potentially

- affected sources.

The general considerations taken into account in Georgia EPD‟s 4

- factor evaluations and the evaluations of the specific emissions units are presented below.

Costs of Compliance

– General Considerations GA EPD evaluated the cost of compliance using a variety of factors. Facilities provide d data for various control options for each affected unit. The data typically included total capital costs and cost

-

per

- ton of pollutant removed ($/ton). GA EPD compared this data with similarly controlled units as well as AirControlNET estimates. Costs we re presented in 2007 dollars for consistency. In addition, GA EPD conducted CMAQ modeling to determine the amount of visibility improvement resulting from each ton of SO2 reduced from each unit subject to analysis. This cost

- efficiency metric is expressed in dollar

- per

inverse megameter ($/Mm

- 1) and was considered in addition to cost efficiency expressed in $/ton. This approach is similar to the approach used by Georgia EPD to evaluate cost efficiency for other SIPS (e.g., ozone, PM2.5).

Time Necessary For Compliance

– General Considerations GA EPD based the time necessary for compliance on the installation and operation of controls by the beginning of the year 2012. Since the next Regional Haze SIP will be due December 17, 2017, a compliance date of 2012 w ill result in visibility improvement for all five years of monitoring data (2012, 2013, 2014, 2015, and 2016) that will be assessed to determine conformity with 2018 progress goals at the time the next Regional Haze SIP is due. Any control options that can be installed and operated prior to 201238

were determined to be timely. Control options that cannot be installed and operated prior to 2012, but can be prior to 2018, would not result in the optimal amount of visibility improvement by the 2018 reasonable pr ogress goal, but were still considered. Control options that could not be installed and operated until 2018 or after, were not considered for this Regional Haze SIP.

Energy And Non

-

Air Quality Environmental Impacts Of Compliance

– General

Considerations

A dditional factors that were considered were the energy requirements of the control technology and the non

- air impacts (that is, impacts on other environmental media). Energy impacts were generally included in the cost

- efficiency estimates. Non

- air impacts that were considered included solid waste disposal, water withdrawal, and wastewater discharge. The review of control strategies that were not eliminated because of excessive cost efficiencies and that involved water withdrawal and wastewater discharge wer e coordinated with GA EPD‟s Watershed Protection Branch.

Remaining Useful Life

– General Considerations The remaining useful life of an affected emissions unit can potentially impact reasonableness of control strategies in two ways. If the remaining usefu l life of an affected emission unit did not extend past 2018, no controls would be considered for that unit. If the remaining useful life of a unit was less than the amortization period for a particular control option, the shorter period was used in annual izing the capital costs of the control option when determining the cost efficiency. It should be noted that remaining useful life was not an issue for any of the control options reviewed by GAEPD. Results of Unit

- Specific Analyses As stated previously, GA EPD performed 4

- factor analyses for 15 emissions units. The results are summarized below. For more details refer to Appendix H.

Georgia Pacific, Brunswick Cellulose

- Power Boiler U700 (F1)

– This unit significantly contributes to the sulfate visibility i mpairment at two Class I areas (approximately 12.6% at Wolf Island and 3.9% at Okefenokee). This is the highest level of visibility impairment contribution to any Class I Area caused by any single emissions unit of those analyzed. The baseline SO2 emissions were 1642 tons

- per

- year. However, the boiler had already reduce d emissions to approximately 1099 tons

- per year due to a 2002 modification achieving higher efficiency. The 4

- factor analysis reviewed wet FGD,

in

- duct sorbent injection, and a limitation on fuel oil usage coupled with lower fuel oil sulfur content (2.2% and 1.0%). It should be noted that the fuel oil usage limitation proposed by the company is representative of their current usage rate. Of these control measures, the fuel oil changes could take place prior to 2012 and the wet FGD and in

duct sorbent injec tion could be installed before 2013. The remaining useful life of the unit extended past 2018 and the control equipment amortization period. The wet FGD had an impact on water usage and wastewater discharge and in

- duct sorbent injection resulted

in additio nal solid waste. There were no significant energy impacts addressed by the company. Out of all of the control options considered, both in

- duct sorbent injection and a switch to 1.0% fuel oil coupled with a five

- million

- gallon

- per

- year usage limit were cons idered39

reasonably cost effective ($3562/ton and $20.7MM/Mm

- 1 at Wolf Island for in

- duct sorbent injection and $3228/ton and $18.8MM/Mm

- 1 at Wolf Island for 1.0% fuel oil).

These were considered cost effective due to the relatively high visibility impact o n two Class I areas and the fact that neither of these Class I areas were clearly meeting the uniform rate of progress. Both in

- duct sorbent injection and 1.0% sulfur fuel oil achieve approximately the same amount of emissions reductions (769 tpy for sorbe nt injection and 731 tpy for 1.0% sulfur) from the current level of 1099 tons/year. Implementation of the less restrictive of these two options would reduce SO2 emissions to 368 tons/12

- consecutive months (1099 tpy

– 731 tpy).

Supplemental information pr ovided by the facility indicated that the two controls deemed to be reasonable would control emissions from oil combustion but would not affect SO2 emissions from combustion of wood waste and tire

- derived fuel (TDF). The facility requested an allowance for an additional 200 tons of emissions based on calculations of historical emissions from wood waste and TDF. This request was also supported by the facility‟s assertion that the sulfur content of locally available TDF may be above what

has been burned histo rically. EPD concurred with the facility‟s request and established an SO2 emissions limit for the power boiler of 568 tons (368 plus 200) for Regional Haze reasonable progress with a compliance date of 2012.

Georgia Pacific, Brunswick Cellulose

- Recovery Boiler R407 (M24)

- This unit contributes about 1.3 % to the sulfate visibility impairment at Wolf Island. The baseline SO2 emissions were 193 tons/year. Georgia Pacific‟s four

- factor submittal found combustion control and wet FGD (scrubber) to be the onl y technically feasible control options. The company stated that emissions of SO2 of 38 ppm, as measured in a 2006 stack test, is too low of a load for effective operation of a wet scrubber. Therefore, the company ruled out wet FGD based on cost effectivene ss. Combustion control, the other technically feasible control option, is already included in the boiler design. Due to the fact that this emission unit only contributes to visibility impairment at one Class I area and the relatively low baseline emission s level, no additional controls are required for Regional Haze reasonable progress.

Georgia Pacific, Cedar Springs, Power Boiler U500 (Power Boiler 1) and Power Boiler U501 (Power Boiler 2)

– These are two nearly identical power boilers. Each of these

uni ts contribute about 1.1% to the sulfate visibility impairment at Saint Marks Class I area. The baseline SO2 emissions were 1976 tons/year for each boiler.

The 4

- factor analyses reviewed wet FGD, addition of spray towers and caustic to the existing venturi scrubbers, adding caustic to the existing scrubbers (79% SO2 reduction), in

- duct sorbent injection, coal washing, and coal switching. In addition to these control measures, Georgia Pacific submitted two control scenarios as part of their BART exemption mod eling request (see section 7.7) that included the addition of lower amounts of caustic to their existing scrubbers approximately 68% and 37% SO2 reduction). All of the control options could be installed prior to 2012 except the wet FGD

which could be insta lled before 2013. All three of the scrubber options (wet FGD, adding spray towers to the existing scrubbers, and adding caustic to the existing venturis) result40

in 15,000 tons/year of solid waste. There were no significant energy impacts addressed by the c ompany. The remaining useful life of the unit extended past 2018 and the control equipment amortization period.

Out of all the control options considered, adding caustic to the existing venturi scrubber

and in

- duct sorbent injection were considered reason ably cost effective ($1675/ton and $849.2MM/Mm

- 1 at Saint Marks for adding caustic to the scrubber and $1663/ton and $843. 2MM/Mm

- 1 at Saint Marks for in

- duct sorbent injection). These were considered cost effective due to the relatively low visibility imp act on only one Class I area (although St. Marks is not clearly meeting the uniform rate of progress.) Since the company submitted control options for three different levels of caustic use (79%, 68%, and 37% SO2 reduction), GA EPD analyzed the information to determine which level of caustic use was considered reasonable (in

- duct sorbent injection achieves approximately 70% reduction, which is within the range of control efficiencies for caustic scrubbing). As part of Georgia Pacific‟s BART exemption modelin g, the company has proposed SO2 emission limits of 135 pounds each per hour from Power Boilers 1 and 2, along with additional limits of Recovery Boiler 3 (see section 7.7.2 for further discussion on these BART exemption limits). A limit of 135 lb/hr would result in maximum annual emissions of 591 tons/yr of SO2. This results in a 70% reduction. The actual annual reduction should be even higher since the boiler would not be expected to emit SO2 at the maximum allowable level for an entire year. Therefore, th e 70+% reduction required by the BART exemption limit satisfies the requirement for reasonable progress. No additional limitations will be required.

Georgia Pacific, Cedar Springs, Recovery Boiler R402 (Recovery Boiler 3)

– This unit

contributes about 0.8 % to the sulfate visibility impairment at Saint Marks class I area. The baseline SO2 emissions were 1726 tons/year. (Although, Georgia

- Pacific submitted 2006 and 2007 SO2 emissions significantly lower than this baseline at 462 and 741 tons/year, respectiv ely).

The 4

- factor analyses reviewed switching from No. 6 fuel oil to No. 2 fuel oil (0.5 % sulfur), switching to 1% sulfur No. 6 fuel oil, and the installation of a new concentrator

and new multi

- level air system. The company did not provide any indicati ons that any of the control options could not be installed prior to 2012. No negative energy impacts or

non

- air quality environmental impacts were addressed by the company. Remaining useful life of the units extended past 2018 and the control equipment amo rtization periods.

Of all of the control options considered, none were considered reasonable, given the relatively low visibility impact on a single Class I area. Therefore no additional controls will be required for Regional Haze Reasonable Progress.

Ge orgia Pacific, Savannah River, Mill Boilers B001, B002, and B003 (Nos. 3, 4, and 5 Boilers)

– These are three relatively similar boilers, with B002 and B003 being almost identical. The units significantly impact one class I area (approximately 1.1%, 0.9%,a nd 0.8% at Wolf Island for B001, B002, and B003, respectively). The baseline SO2 emissions for the three boilers are 1659 tons/yr, 1195 tons/yr, and 1190 tons/yr. Note that41

all three of these are re

- circulating fluidized bed boilers with limestone injectio n in the combustion chamber. B001 currently achieves approximately 87% SO2 removal and Boilers B002 and B003 achieve approximately 90% SO2 removal. The 4

- factor analyses reviewed wet FGD, circulating fluidized bed scrubber, switching from petroleum coke to 100% coal, increased limestone injection, and rotating opposed fire air. Out of all the proposed changes, only increased limestone injection could occur prior to 2012.

All other control measures could not be installed until after 2012, although estimate d control dates were not provided. Wet FGD controls would result in increased water use and wastewater discharges. No significant energy impacts were addressed by the company. Remaining useful life of the units extended past 2018 and the control equipment amortization periods. Increased limestone injection would result in increased solid waste generation. Georgia

- Pacific conducted trial operations with increased limestone injection rates and found that SO2 removal could only be increased by an additional tw o percent (from 87% to 89% for B001 and from 90% to 92% for B002 & B003). Revised cost estimates were also derived from the trial operations.

Of all of the control options considered, none were considered reasonable, given the resulting control efficiencies and the relatively low visibility impact on a single Class I area. Therefore no additional controls will be required for Regional Haze Reasonable Progress.

Georgia Power, Plant Kraft, Steam Generators 1, 2, and 3

– These are three coal fired steam generating units (i.e., boilers) rated at 50, 54, and 104 MW, respectively. Units 1 and 2 each impact Wolf Island Class I area by approximately 0.5%. Unit 3 was initially determined to impact three Class I areas (approximately 3.3% at Wolf Island, 0 .9% at Okefenokee, and 0.8% at Cape Romain). However, with the projected reduction in SO2 emissions by 2018, the impact on Okefenokee and Cape Romain should drop below the 0.5% threshold and the impact at Wolf Island should drop below 2%. The 2018 baseline SO2 emissions for units 1 through 3 were initially estimated by VISTAS at 691 tpy, 704 tpy, and 4474 tpy, respectively. As part of the supporting documentation for the 4

- factor analyses, Georgia Power provided projected heat input through 2018 for these u nits. Those projections indicate that SO2 emissions will be 632 tpy, 889 tpy, and 2455 tpy, respectively. While the heat inputs provided by Georgia Power for units 1 and 2 are similar to the VISTAS 2018 projections, Georgia Power‟s projection for Unit 3 represents a 45 percent reduction in heat input and SO2. This was explained by Georgia Power as the result of additional capacity coming on line somewhere else between 2010 and 2017. The reduction in heat input for Plant Kraft is expected to occur by aroun d 2015. GA EPD has utilized these revised heat inputs in conducting the 4

-

factor analyses

. GA EPD can verify the heat input reduction during development of the next Regional Haze SIP (due in 2017).

The same control measures were analyzed for the four sta tutory factors for all three units: wet FGD, coal switching, and coal washing. Wet FGD could not be installed until42

2016 because of required control device installations scheduled up until 2015 in Georgia Power‟s system. The company did not address the imp lementation time for the other control options. All three control options would require additional energy usage. Wet FGD and coal washing would result in increased water usage and wastewater discharges as well as additional solid waste generation. The rem aining useful life of the units extended past 2018 and the control equipment amortization periods. The costs of wet FGD and coal switching were relatively high ($3216 to $8161/ton and $56.9MM to $144.5MM/Mm

- 1 for wet FGD and $4041to $4306/ton and $71.5MM/M m

- 1 for coal switching). Coal washing was relatively cost effective ($1839 to $1847/ton and $32.5 to $32.7/Mm

- 1) but the control efficiency is only 6%. Regarding non

- air environmental impacts, the company indicated that coal switching could possibly reduce boiler efficiency, would use up to 7500 gallons (at Unit 3) per day of water, would result in acidic wastewater requiring treatment, and would result in coal refuse in the amount of approximately 5% of the total coal consumption. This control efficiency is projected to achieve low extinction reductions (which are visibility improvements) at Wolf Island. Based on the relatively low control efficiency of this option, the negative non

- air environmental impacts, and the relatively low visibility impact, coal washing was determined not to be reasonable. Based on the above considerations, no additional controls will be required for any of the Plant Kraft units.

Georgia Power, Plant McIntosh, Steam Generator 1

– This coal

- fired steam generating unit (i.e., boile r) is rated at 178 MW. This unit was initially determined to impact five Class I areas (approximately 4.1% at Wolf Island, approximately 1.2% at Okefenokee, approximately 0.6% at Saint Marks, approximately 1.5% at Cape Romain, and approximately 0.7% at Swa nquarter). However, with the projected reduction in SO2 emissions by 2018, the impact on all of these except Wolf Island should drop below the 0.5% threshold and the impact at Wolf Island should drop to close to 1%. The 2018

baseline SO2 emissions were in itially estimated by VISTAS at 7015 tpy. As part of the supporting documentation for the 4

- factor analyses, Georgia Power provided projected heat input through 2018 for this unit. Those projections indicate that SO2 emissions will drop to 1860 tpy by 2018. Georgia Power‟s projection represents a 73 percent reduction in heat input and SO2. This was explained by Georgia Power as a result of additional capacity coming on line somewhere else between 2010 and 2017.

The reduction in heat input for Plant McIntosh is to occur between around 2011 and 2016. GA EPD has utilized this revised SO2 emission rate in conducting the 4

- factor analyses. GA EPD can verify the heat input reduction during development of the next Regional Haze SIP (due in 2017). Georgia Power ana lyzed the following control measures: wet FGD, coal switching, and coal washing. Wet FGD could not be installed until 2016 because required control device installations scheduled up until 2015 in Georgia Power‟s system. The company did not address the impl ementation time for the other control options. All three control options would require additional energy usage. Wet FGD and coal washing would result in increased water usage and wastewater discharges as well as additional solid waste generation. The remai ning useful life of the units extended past 2018 and the control equipment amortization periods. The cost effectiveness of all the control operations were43

relatively high ($7131/ton and $118.5MM/Mm

- 1 for wet FGD, $4306/ton and $71.5MM/Mm

- 1 for coal switchi ng, and $5334/ton and $91.9MM/Mm

- 1 for coal washing). Based on these factors, no additional controls will be required Plant McIntosh.

Georgia Power, Plant Mitchell, Steam Generator 3

– This coal

- fired steam

- generating unit (i.e., boiler) is rated at 163 M W. (Note that this is the only remaining operational boiler at Plant Mitchell.) This unit was initially determined to impact two Class I areas (approximately 0.8% at Okefenokee and approximately 2.7% at Saint Marks).

However, with the projected reduction in SO2 emissions by 2018, the impact on Okefenokee should drop below the 0.5% threshold and the impact on Saint Marks should drop to below 1%. The 2018 baseline SO2 emissions were initially estimated by VISTAS at 4930 tpy. As part of the supporting documen tation for the 4

- factor analyses, Georgia Power provided projected heat input through 2018 for this unit. Those projections indicate that SO2 emissions will drop to 1189 tpy by 2018. Georgia Power‟s projection represents a 76 percent reduction in heat inpu t and SO2. This was explained by Georgia Power as a result of additional capacity coming online somewhere else starting in 2010. The reduction in heat input for Plant Mitchell is to occur between around 2008 and 2010.
GA EPD has utilized this revised SO2 e mission rate in conducting the 4

- factor analyses. GA EPD can verify the heat input reduction during the Regional Haze mid

- course review

in 2012.

Georgia Power analyzed the following control measures: wet FGD and coal switching.

Wet FGD could not be insta lled until 2016 because required control device installations scheduled up until 2015 in Georgia Power‟s system. The company did not address the implementation time for coal switching. Both control options would require additional energy usage. Georgia Pow er did not indicate any additional water use, wastewater discharge, or solid waste generation issues for any of the control options. The remaining useful life of the units extended past 2018 and the control equipment amortization periods. The cost effectiv eness for wet FGD was high ($9119/ton and $148.5MM/Mm

- 1). The cost effectiveness for coal switching was more reasonable ($2347/ton and $38.2MM/Mm

- 1), but the control efficiency was relatively low at 43%.

Based on these factors, including the projected sig nificant utilization drop within the next few years, no additional controls will be required for Plant Mitchell.

International Paper, Savannah, Power Boiler 13

– This is a 1280 MMBtu/hr coal, oil, and wood waste fired boiler. It also combusts both low

- vol ume high

- concentration (LVHC) and high

- volume low

- concentration (HVLC) non

- condensable gases from the pulping process and stripper off

- gas (SOG) from the stripper used to control HAP emissions from wastewater streams. Baseline emissions are 8578 tons/year with approximately 1944 tons/yr of this coming from the combustion of LVHC, HVLC, and SOG. This unit significantly contributes to the sulfate visibility impairment at five Class I areas (approximately 6.4% at Wolf Island, approximately 1.7% at Okefenokee, approximately 0.7% at Saint Marks, approximately 1.6% at Cape Romain, and approximately 0.9% at Swanquarter). This is the highest number of Class I areas44

significantly impacted by any single emissions unit of all those reviewed. The 4

- factor analysis revie wed wet FGD (packed tower), FGD (wet limestone spray tower), semi

- dry lime spray tower, fuel switching to natural gas, dry sorbent injections, and a stand

- alone RTO with SO2 scrubbing for the control of LVHC, HVLC, and SOG (this control option

was presente d as three different combinations of LVHC, HVLC, and SOG combustion). Also, International Paper (IP) later suggested an SO2 reduction of 2000 tons/year as a control option that would provide maximum flexibility for compliance. Except for the 2000 ton/year reduction alternative, all of these control options could be implemented by 2012. International Paper requested a 2016 compliance date for the 2000 ton/yr reduction alternative. This compliance date is necessary in order for the company to take into consid eration any reductions that will occur as a result of the Boiler MACT and the uncertainty surrounding that standard.

The remaining useful life of the unit extended past 2018 and the control equipment amortization period. The wet FGD and all three RTO options had an impact on water usage and wastewater discharge. GA EPD Air Branch checked with GA EPD Watershed Protection Branch (WPB) personnel to discuss the potential water usage and wastewater discharges associated with t hese controls. WPB associates indicated that they would not be a problem as long as there was not additional BOD load on the Savannah River. Based on the type of chemicals that would be associated with effluent from a wet FGD,

WPB associates stated that th e controls should not result in additional BOD load. However, because of the current problem with dissolved oxygen in the Savannah River (there are strict limitations and perhaps a moratorium on any additional DO load to the river), any projects that could possibly increase DP load were not considered reasonable at this time. FGD (wet limestone spray tower, semi

- dry lime spray tower, and dry sorbent injection) resulted in additional solid waste generation. There were energy impacts

associated with all but t he fuel switching options. These energy costs were factored into the overall control cost efficiency.

Regarding the company‟s cost efficiency estimates, EPD‟s review indicated that the cost estimates for a packed tower wet FGD and wet limestone spray towe r were higher than expected based on a number of metrics (cost per ACFM is about four times higher than other units of comparable size, company‟s estimate is three to eight times higher than EPA cost estimation software, and I nternational Paper used an adm ittedly conservative retrofit factor) plus the company used a cost estimation model not recommended by EPA. In a letter to IP on 12/21/2007, GA EPD requested site

- specific cost analyses for these control options. In that letter, GA EPD stated that if site

- specific estimates were not provided, that control option recommendations would be made with the understanding that the cost estimates may be overstated. In response, International Paper chose not to provide site

- specific cost estimates as requested. Howev er, despite the possibly high cost effectiveness numbers the FGD

- wet limestone spray tower ($4391/ton) was determined not to be cost effective. Wet FGD

– packed tower, was not considered reasonable because of the possible impact on DO load to the Savanna h River. Fuel switching to natural gas ($9506/ton), and dry sorbent injection ($5223/ton) were determined not to be reasonable because of cost effective.45

The next most effective control option is a 6758 tons per year emission limit. However, since the op tion was proposed by the company, it had to be considered cost

- effective. No specific emission reduction methodologies were associated with this control option, however, there are certain control methodologies that are under consideration (see Appendix H f

or details). The 6758 ton per year limit was determined by reducing the projected 2018 SO2 emissions baseline of 8758 tons per year by 2000 tons. EPD reviewed recent SO2 emissions data and determined that the 8758 tons per year baseline

is a reasonable and not over

- inflated baseline. A compliance date of 2016 was proposed in order to take into consideration any controls that will be required under the Boiler MACT currently under development. The Boiler MACT has been vacated and remanded to EPA, and EPA is d eveloping a proposed boiler MACT rule. A 2016 compliance date should provide sufficient time for the MACT to be proposed and promulgated, provide the three years required for compliance with the standard, and provide time to determine an appropriate method for complying with the 6758 SO2 emissions limit from Power Boiler 13 following compliance with the MACT standard.

Out of all of the control options considered, a 2000 tons per year reduction alternative was considered reasonably cost effective. This resu lts in an emission limit of 6758 tons per year. The baseline SO2 emissions are 8578 tons/yr. A review of past CERR reports SO2 emissions from PB13 at 7620 to 7699 tpy from 2002

- 2005 and increasing to 8974 tpy in 2006. The increase in 2006 may be due to the compliance date for phase II of the “Cluster Rule” MACT standard that required collection and treatment of emissions from pulp mill condensate beginning in 2006. This would have resulted in increased sulfur emission from SOG which were then combusted in P B13 to form SO2. Therefore, the 8578 ton/year estimate is a good baseline for determining allowable emissions based on a selected control technology. A 2000 tons per year reduction results in an emission limit of 6578 tons/year. This limit will include SO 2 emissions resulting from the combustion of LVHC, HVLC, and SOG, whether they are combusted in Power Boiler 13 or some other combustion device. In order to provide flexibility for the facility, an emission limit of

6578 tons/12

- consecutive months will be required for Power Boiler 13 as a requirement of Regional Haze reasonable progress with a compliance date of 2016.

Temple

- Inland Rome Linerboard, No. 4 Power Boiler

- This is a 565 MMBtu/hr coal and oil fired boiler. This unit significantly contributes t o the sulfate visibility impairment at two Class I areas (approximately 4.4% at Cohutta and approximately 1.0% at Joyce Kilmer/Slickrock).

The 4

- factor analysis reviewed two wet FGD configurations [magnesium enhanced lime (MEL) and limestone forced oxida tion (LSFO)], dry FGD (lime absorbent), fuel switching, and dry sorbent injection. All of these control options could be implemented by 2012. The remaining useful life of the unit extended past 2018 and the control equipment amortization period. The wet FG D options had an impact on water usage. GA EPD Air Branch checked with GA EPD Watershed Protection Branch personnel to discuss the potential water usage and was informed that the mill had sufficient capacity within their currently permitted water withdrawa l permit to easily handle the increased water use associated with wet FGD. All of the control options resulted in additional solid waste46

generation. There were energy impacts associated with all of the control options. These energy costs were factored into the overall control cost efficiency. None of the control options considered had a cost effectiveness that was determined reasonable at this time. Of all of the control options considered, none were considered reasonable at this time. The fact that the aff

ected Class I areas impacted by this unit are predicted to meet the Uniform Rate of Progress in 2018 with controls that are already on the books was a key factor in determining what was considered “reasonable” for reasonable progress requirements for this source. This determination may be revisited at the midcourse review or when determining future Regional Haze reasonable progress goals (i.e., future Regional Haze SIPs).

7.6.4 Required Controls for Sources Subject to Four

- Factor Analysis in Georgia

Table 7.6.4

- 1 provides a summary of the required emission limits for the sources subject to 4

-

factor analysis in Georgia. The final determinations were based on the 4

- factor analyses and reviews and are detailed in Appendix H. GA EPD decided on limits

that would be consistent with controls that were reasonably cost effective. Reasonable costs were based on the number of Class I areas impacted, the magnitude of visibility impact on Class I area, progress of the impacted Class I area relative to the glide slope,

an d cost effectiveness. Once the control or controls were determined to be reasonable, an emission limit was applied based on the expected emission reduction from the control technology or technologies to allow the facility flexibility in meeting the limit. The control technology was not required. This approach was determined to be an effective means of obtaining reasonable emission reductions.

Note that this table presents four

- factor data only for controls that were deemed to be

reasonable and cost

- effect ive. Table 6.1 of Appendix H includes four

- factor data on control options that were deemed not cost

- effective.

The required emission limits will be implemented by adding them as permit conditions (see Appendix M) to the Title V operating permits of the a ffected facilities. Recordkeeping, monitoring, and testing requirements will be included to demonstrate compliance with the limits. These requirements will be consistent with Georgia EPD‟s Procedures for Testing and Monitoring Sources of Air Pollutants (PT M) and must meet the requirements of Compliance Assurance Monitoring (40 CFR Part 64) or Periodic Monitoring [40 CFR 70.6(3)(i)(B)], as appropriate.

Three facilities, due to resource limitations and/or uncertainty regarding future operations, requested l imits on their affected emissions units in lieu of performing four factor analyses: Rayonier Performance Fibers, Packaging Corporation of America, and Southern States Phosphate and Fertilizer. The required limits dropped the sulfate contributions of these units below 0.5 percent of the total sulfate impact on any affected

Class I areas.4748

EPA Findings : EPA proposes to find that Georgia has adequately addressed this provision

. The State appropriately documented the technical analysis applied to assess the need and implementation of r easonable p rogress controls as applicable for those non

CAIR EGU units emitting SO 2

. The analyses identified existing controls on applicable emission units, potential control options for applicable emissions, and successfully applied the four factors to determine the feasibility of these controls to address r easonable

p rogress. E PA also notes that the visibility improvements projected for the affected Class

I areas are in excess of that needed to be on the glidep ath for Cohutta, and are very close to the glidepaths for Wolf Island and Okefenokee.49

Georgia also adequate ly presented its basis for considering certain CAIR sources as part

of its reasonable progress analysis. Prior to the remand of CAIR, EPA believed the State’s reliance on CAIR for specific BART and reasonable progress provisions affecting its EGUs was adequate and was fully approvable and in accordance with 40 CFR 51.308(e)(4). However, the BART assessments for CAIR EGUs for NOx and SO 2 and other provisions in this SIP revision are based on CAIR.

In a separate action proposing limited disapproval of the regional haze SIPs of a number of states, EPA noted that these states relied on the trading programs of CAIR to satisfy the BART requirem ent and the requirement for a LTS sufficient to achieve the state

adopted RPGs. See 76 FR 82219 (December 30, 2011). In that action, EPA proposed a limited disapproval of Georgia’s regional haze SIP submittal insofar as the SIP relied on

CAIR. For that re ason, EPA is not taking action on that aspect of Georgia’s regional

haze SIP in this action.50

III. Evaluation of Regional Haze Submittal

C . Long

- Term Strategy

C.4. Enforceability of Reasonable Progress Measures: The SIP needs to provide

enforceable emis sions limitations and schedules for compliance for each newly adopted measure needed to achieve the reasonable progress goal s

.

State Regional Haze Submittal Georgia SIP Narrative, Pages 97

- 98 :

Table 7.6.4

- 2 lists the limits and compliance dates for the four

- factor and the four

-

factor exempted units. In addition the estimated tons reduced with the new limits are presented. Limits for the four

-

factor units are on actual emissions as currently stated, but this could change if additional conditions are added during the permit amendment process. The limits for the four

-

factor exempted units are based on actual (rather than potential) emissions, as the permit conditions do not depend solely on fuel sulfur content or on equipment capacities. Note that the permit limits for PB02, RF01, and RF04 at Rayonier Performance Fibers are on fuel usage and on stack SO2 concentrations (RF01 and RF04 only) that have been calculated to achieve the ton

- per year limits shown in the table. The limit on RF01 becomes effective upon the completion of the Plant‟s Phase 1 projects, which include the addition of SO2 control (staged air combustion). The limit on RF04 becomes effective upon the completion of the Plant‟s Phase 2 projects, which include the addition of SO2 control (staged a ir combustion). The permitting of Phases 1 and 2 allows for increased production and burning of black liquor solids, but only after the emissions controls are installed. At the time of this SIP submittal, the projects were suspended due to depressed market conditions in 2009.5152

EPA Findings : EPA proposes to find that Georgia has adequately addressed this provision

.53

III. Evaluation of Regional Haze Submittal

D

. Best Available Retrofit Technology (BART) Requirements

D.1 Identification of all BART Eligible Sources: The SIP should include a list of all

BART

- eligible sources within the State

.

State Regional Haze Submittal Georgia SIP Narrative, Pages 100

- 102 :

7.7 Control Determinations Representing Best Available Retrofit Technology (BART) for Individual Sources Section 169A of the CAA directs States to assess certain large, older emission sources for additional controls in order to address visibility impacts. States are directed to conduct BART determinations for such sou rces in specific source categories and which contribute to visibility impairment in Class I areas. The 1999 regional haze rule includes the BART requirement, and directs States to include BART in their regional haze SIPs.

On July 6, 2005, US EPA published a revised final rule, including Appendix Y to 40 CFR Part 51, the Guidelines for BART Determinations Under the Regional Haze Rule (the “BART Guidelines”) that provides direction to states on determining which of these sources should be subject to BART, an d how to determine BART for each source.

A BART

- eligible source is one which has the potential to emit 250 tons or more of a visibility

- impairing air pollutant, one which was put in place between August 7, 1962, and August 7, 1977, and one whose operation s fall within one or more of 26 specifically listed source categories. Under the CAA, BART is required for any BART

- eligible source that a State determines „„emits any air pollutant which may reasonably be anticipated to cause or contribute to any impairme nt of visibility in any such area.‟‟

For those sources subject to BART, Section 169A(g)(7) of the CAA requires that States must consider the following factors in making BART determinations: (1) the costs of compliance, (2) the energy and non

- air quality e nvironmental impacts of compliance, (3) any existing pollution control technology in use at the source, (4) the remaining useful life of the source, and (5) the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

BART

- eligible sources were identified using the methodology in the BART Guidelines: • One or more emissions units at the facility fit within one of the 26 categories listed in the BART Guidelines; • The emission unit(s) were in existence on August 7, 1977, and began operation at some point on or after August 7, 1962; and • The limited potential emissions from all emission units identified in the previous

two bullets emission units were greater than 250 tons or more per year of any of these visibility

- impairing pollutants: SO2, NOx, and PM10.

The BART Guidelines recommend addressing these visibility

- impairing pollutants: SO2, NOx, and particulate matter, and suggest that States use their best judgment in54

determining whether to address VOC or ammonia emissions. GA EPD addressed SO2 and NOx, and used particulate matter less than 10 microns in diameter (PM10) as an indicator for particulate matter to identify BAR T

- eligible units, as the BART guidelines recommend. As discussed in detail in Appendix H, VISTAS modeling demonstrated that VOCs and ammonia from point sources are not visibility

- impairing pollutants. For this reason GA EPD did not evaluate emissions of VO Cs and ammonia in BART

determinations.

Table 7.7.1

- 1. Facilities with BART

- eligible sources in Georgia

BART

– Eligible Sources Chemical Products Corporation DSM Chemicals, North America Georgia Pacific

– Cedar Springs Georgia Power

– Plant Bowen Georgia Po wer Plant Branch Georgia Power

– Plant Hammond Georgia Power

– Plant McDonough Georgia Power

– Plant Mitchell Georgia Power

– Plant Scherer Georgia Power

– Wansley Georgia Power

– Yates International Paper

– Augusta International Paper

– Savannah

Interstat e Paper, LLC Koch Cellulose (Georgia Pacific

– Brunswick / Brunswick Pulp & Paper) Lafarge Building Materials (Blue Circle Cement

– Atlanta Plant) Owens Corning

PCA

– Valdosta (Tenneco Packaging, Inc.) PCS Nitrogen Prayon, Inc. Rayonier (Rayonier ITT, Inc.)

Savannah Electric

– Plant Kraft

Savannah Electric

– Plant McIntosh Tronox (Kerr

– McGee / Kemira)

EPA Findings : EPA proposes to find that Georgia has adequately addressed this provision.55

III. Evaluation of Regional Haze Submittal

D . Best Available Retrofit Technology (BART) Requirements

D

. 2. Modeling or O ther Demonstrations for BART Exempt Sources: For each

BART

- eligible source in the State exempted from BART a demonstration, using an acceptable approach, that the source or group of sources does no t violate the established threshold. The established exemption threshold for determining if a BART

- eligible source contributes to regional haze cannot exceed 0.5 deciviews.

State Regional Haze Submittal Georgia SIP Narrative , Pages 102

- 107:

7.7.2 Determination of Sources Subject to BART in Georgia Under the BART Guidelines, GA EPD may consider exempting some sources from BART if we find that they do not cause or contribute to visibility impairment in a Class I area.

In accordance with the BAR T guidelines, GA EPD chose to perform source specific analyses to determine which sources cause or contribute to visibility impairment using the CALPUFF model. The CALPUFF modeling protocol used for determining which facilities are subject to BART is inclu ded in Appendix H.7. In accordance with the Guidelines, a contribution threshold of 0.5 deciviews was used for determining which sources were subject to BART.

All of Georgia‟s BART

- eligible sources submitted exemption modeling demonstrations. Twenty

- two o

f the twenty

-

four sources were able to demonstrate exemption. Additional details including BART modeling protocols and exemption reports submitted by the facilities are available in Appendix H. Supporting files and databases that would be impracticable to print are available electronically, both on the submitted CD

- R and via permanent EPD web links. In addition, files are permanently archived on EPD computer networks. To request access to any of these files please contact the Georgia EPD Air

Protection Bran ch at (404) 363

- 7000. Facilities found to be subject to BART must complete a BART analysis.

Table 7.7.2

- 1 represents the facilities that were able to demonstrate exemption from BART based on CALPUFF modeling conducted using the VISTAS modeling protocol.

All the listed facilities used old IMPROVE equation except Georgia Pacific Cedar Springs which used new IMPROVE equation to demonstrate its exemption from BART.

Table 7.7.2

- 2 represents the facilities that were able to demonstrate exemption from BART based on model plant criteria or by accepting emissions limits for visibility causing pollutants. Georgia Pacific Cedar Springs was able to demonstrate exemption from BART by accepting SO2 emissions limits on Power Boilers 1 and 2 (135 lb/hr each) and on Recovery Boiler 3 (350 ppm). These limits result in 0.499 deciview impact at St. Marks and a 0.306 deciview impact at Okefenokee NWR. The permit will be issued with

Fe derally

- enforceable limits and a Federally

- enforceable condition that requires the56

facility to monitor their emissions and to notify EPD if they exceed the BART exemption

limit.

EPA established specific exemption thresholds or criteria based on CALPUFF m odeling conducted for a model plant. The criteria that sources must meet include potential emissions of SO2 and NOx combined of less than 500 tons per year and a distance of greater than 50km from any Class I area, or combined potential emissions less than 1000 tons per year with a distance greater than 100km from any Class I area. In situations where combined SO2 and NOx emissions are less than 500 or 1000 tons per year, but PM emissions are greater than 15 tons per year, the emissions of SO2, NOx and PM m ay be combined using weighting factors (Appendix P) and compared to 500 or 1000 tons. Both Lafarge Building Materials and International Paper

– Savannah meet the model plant exemption criteria. Please see Table 7.7.2

- 2 for emissions and distances from Clas s I areas.

One of Georgia‟s BART

- eligible sources is an EGU. This Georgia power plant Bowen is subjected to CAIR. US EPA has determined that, as a whole, the CAIR cap

- and

- trade program improves visibility more than implementing BART for individual sources in states affected by CAIR. A State that opts to participate in the CAIR program under Part

96 AAA

- EEE need not require an affected BART

- eligible EGU to install, operate, and maintain BART for SO2 or NOx emissions. Since Georgia is participating in CAIR a nd accepts US EPA‟s overall finding that CAIR “substitutes” for BART for NOx and SO2, Georgia‟s EGUs were allowed to submit BART exemption modeling demonstrations for PM emissions only. All EGUs other than Georgia Power

- Plant Bowen demonstrated that they d o not contribute to visibility impairment in any Class I area.

In total, twenty

- two of Georgia‟s twenty

- four BART

- eligible sources were able to demonstrate that they did not cause or contribute to visibility impairment in any Class I area within 300 km of the source.57585960

Georgia SIP , Appendix H Pages 104

- 105:

The EPA argues that a contribution threshold of less than 0.5

- dv

- impact

- per

- source is appropriate when multiple sources contribute, in order to limit the combined effect of these sources. As an example, EPA asserts that if there were 100 sources, each affe cting visibility by 0.1 dv (presumably an imperceptible amount), their total impact would be 10 dv (which can be expected to be quite perceptible).7 The point remains that multiple sources can cause a larger impact than a single one. For BART purposes, vis ibility impacts are calculated as 24

- hour averages of 1

- hour plume impacts, so if the plumes from the various sources each impact the point of interest at some time during a 24

- hour period (not necessarily all at the same hour) then the 24

- hour average wil l reflect their combined impact.61

Georgia EPD concluded that the EPA

- suggested contribution threshold of 0.5 dv was appropriate in this situation since there are a limited number of sources that impact the

various Class I areas in the State.

Georgia SIP Narrative, Page 9 : 1.6 Supporting Documentation for the SIP Supporting files and databases that would be impracticable to print are available electronically, both on the submitted CD

- R and via permanent EPD web links. In addition, files are permanently ar chived on EPD computer networks. To request access to any of these files please contact the Georgia EPD Air Protection Branch at (404) 363

- 7000.

EPA Findings : EPA proposes to find that t he State has adequately identified the BART

- eligible sources

and th ose sources subject to BART controls. It successfully developed and provided the technical analyses to support the BART assessment provision for the non

- CAIR sources. However, Georgia opted to have CAIR satisfy BART for SO 2 and NO

x for affected CAIR EGUs, as allowed under the Regional Haze regulations. As explained in Section III.C.1

– EPA Findings, the State’s demonstration regarding CAIR and reasonable progress for EGUs, and other provisions in this SIP revision, are based on CAIR

.

In a separate action proposing limited disapproval of the regional haze SIPs of a number of states, EPA noted that these states relied on the trading programs of CAIR to satisfy the BART requirement and the requirement for a LTS sufficient to achieve th e state

adopted RPGs. See 76 FR 82219 (December 30, 2011). In that action, EPA proposed a limited disapproval of Georgia’s regional haze SIP submittal insofar as the SIP relied on CAIR. For that reason, EPA is not taking action on that aspect of Georgia’s regional

haze SIP in this action.

CALPUFF MODELING EPA proposes to find that t he CALPUFF 2 modeling system was appropriately applied by GA EPD in the assessment of visibility impairment in Class I areas for specific sources subject to the BART regulatio ns. The BART regulations indicate that CALPUFF or other appropriate models can be used to determine if an individual source is anticipated to cause or contribute to impairment of visibility in Class I areas. T he current regulatory

niche for the CALPUFF m odeling system in 40 CFR part 51, Appendix W: Guideline on Air Quality Models (Appendix W) is for compliance with non

- attainment New Source Review (NNSR) and Prevention of Significant Deterioration (PSD) permitting requirements for long range transport (i. e., greater than 50 KM) applications at Class I areas. There is no preferred model for assessing visibility impact under BART.

2 Note that EPA’s reference to CALPUFF encompasses the whole CALPUFF modeling system, including CALMET/CALPUFF/CALPOST and other pre and post processors. The different versions of CALPUFF have correspo nding versions of CALMET, CALPOST, etc. which may not be compatible with previous versions (e.g., the output from a newer version of CALMET may not be compatible with an older version of CALPUFF). The different versions of the CALPUFF modeling system are available from the model developer on the following website: http://www.src.com/verio/download/download.htm62

However, EPA believes that it is appropriate for the State of Georgia to use the CALPUFF modeling system for its BART exemption and control determination modeling.

VISTAS developed a “Protocol for the Application of CALPUFF for BART Analyses.” The final VISTAS BART Modeling Protocol (Revision 3.2, dated Aug. 6, 2006) states that VISTAS will use CALPUFF ver. 5.754 and CALMET ver. 5.7 (i.e., the VISTAS

version of CALP UFF). No formal approval of the CALPUFF VISTAS version (either ver. 5.754 or 5.756) has been made by EPA Region 4. However, there has been an implied acceptance of the VISTAS CALPUFF version as EPA Region 4 has reviewed

and commented on the VISTAS BART Mo deling Protocol and the source

- specific modeling protocols and reports that were developed by the Georgia specific sources performing BART modeling. The VISTAS BART modeling protocol underwent an extensive stakeholder development and review process, that involved EPA, FLMs, industrial sources, trade groups, lawyers and other interested parties, before the S tate decided to require CALPUFF modeling to evaluate the BART requirements.

The S tate required all BART

- eligible sources to perform BART exemption m odeling and to develop source

- specific protocols that complied with the VISTAS protocol. EPA Region 4 provided reviews and comments on the source

- specific protocols and their subsequent exemption modeling reports. The exemption protocols and modeling rep orts are presented in the appendices to Georgia’s regional haze SIP.

New IMPROVE Equation The CALPUFF model was simulated with the default inputs as recommended in the March 16, 2006 EPA memorandum, “Dispersion Coefficients for Regulatory Air Quality

Mod eling in CALPUFF.” A new methodology was used by the VISTAS s tates to process the mass concentrations from CALPOST (post

- CALPUFF processor) using the new IMPROVE equation so that the BART analyses could consider both the old and new IMPROVE equations. EPA Headquarters and other EPA regional offices and the Federal Land Managers (FLMs) from the National Park Service and the U.S. Fish and Wildlife Service consulted on the VISTAS innovative approach that was developed to utilize the new IMPROVE equation in th e BART assessment and to determine the change in visibility impacts. W hile these other parties were consulted in preparation of EPA Region 4’s response, the response represented the EPA Region 4 position on the new methodology. EPA required the State of Georgia to submit a request to the EPA Regional Administrator requesting the use of this new methodology for the BART

CALPUFF

- based modeling. GA EPD requested in writing (from Dr. Carol Couch to J.I. Palmer, dated August 19, 2008) to use the new IMPROVE e quation to calculate light

extinction effects from two BART

- eligible facilities: Georgia Pacific Cedar Springs and Georgia Power Plant Bowen. EPA Region 4 approved this request in a letter dated September 11, 2008.

The new methodology uses a spreadsheet developed by VISTAS to post

- process the visibility modeling output from the CALPUFF and CALPOST models. The spreadsheet implements the new IMPROVE equation for calculating visibility impacts that was63

adopted by the IMPROVE Steering Committee in December 2005. EPA Region 4 has previously provided comments indicating that new methodology is an alternative modeling approach and should meet the requirements in Section 3.2 of Appendix W, Guideline on Air Quality Models contained in 40 CFR part 51. Th e State’ s demonstration included a rationale for the need to use the new IMPROVE equation, a discussion of the performance of the equation versus measured values, a submittal of the modified post

- processing methodology and documentation to support the development of concentrations for the different terms in the equation.

Contribution Threshold With respect to the contribution threshold used in the CALPUFF modeling, the State was also required to justify its choice of the 0.5 dv contribution threshold for exempting sources from BART eligibility. EPA proposes to agree with the State’s rationale for choosing this threshold value since there are a limited number of sources in close proximity to each of the State’s Class I areas. C onsidering results of the visibi lity impacts modeling conducted , a 0.5 dv threshold was appropriate and a lower threshold was not warranted since the majority of the visibility impacts were well below 0.5 deciviews. Also, even though several sources impac ted each Class I area, the overall impacts were low from the BART sources, and EPA has not made any adverse comments

on the use of the CALPUFF VISTAS versions.

References used in the EPA review:

1. 40 CFR Part 5 1 , Appendix W: Guideline on Air Quality Model s

.

2. September 11, 2008

, letter from James I. Palmer, Regional Administrator, EPA Region 4, to Dr. Carol Couch, GA DNR, the use of the VISTAS methodology for use of the New IMPROVE equation with CALPUFF model results.

3. 40 CFR Part 51 , Appendix Y: Guidelin es for BART Determinations Under the Regional Haze Rule.

4. IWAQM. 1998. Interagency Workgroup on Air Quality Modeling (IWAQM) Phase 2 Summary Report and Recommendations for Modeling Long

- Range Transport and Impacts on Regional Visibility. EPA

- 454/R

- 98

- 019. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC.

5. VISTAS, 2006. Tombach, I., P. Brewer, T. Rogers, and C. Arrington, Protocol for the Application of the CALPUFF Model for Analysis of Best Available Retrofit Technology (BART) Revision 2

– 3/9/06 developed through consultation with EPA, the FLMs, VISTAS state and local Agencies and industry stakeholders VISTAS, 2006. Tombach, I., P. Brewer, T. Rogers, and C. Arrington, Located at http://www.vistas

sesarm.org/documents/BARTModelingProtocol_rev3.2_31Aug06.pdf

.64

6. March 16, 2006

, EPA memo randum from Dennis Atkinson to Kay T. Prince on Dispersion Coefficient s for Regulatory Air Quality Modeling in CALPUFF

.

7. Additional Regional Haze Questions

, EPA, September 27, 2006 Revision. Answers to questions that PA received from various States and Regional Planning Organizations (RPOs) related to the submission of regi onal haze SIPs under the program described by 40 CFR 51.308. This document provides guidance to the State air pollution control agencies and the general public on meeting the regional haze SIP requirements.65

III. Evaluation of Regional Haze Submittal

D . Best Available Retrofit Technology (BART) Requirements

D.3. Identification of Sources Addressed by CAIR : States which adopt the CAIR cap and trade program for SO 2 and NOx are allowed to apply CAIR controls as a substitute for controls required under BART. The SIP should include a list of all BART

- eligible sources within the State for which the CAIR rule is being applied.

State Regional Haze Submittal Georgia SIP , Appendix H, Page 103:

EPA Findings : EPA proposes to find that Georgia has adequately addressed this provision . EPA believes that t he State has appropriately identified the BART

- eligible sources and those sources subject to BART controls. However, Georgia opted to have CAIR satisfy BART for SO 2 and NO

x for affected CAIR EGUs, as allowed under the Regional Haze regulations. A s explained in Section III.C.1

– EPA Findings, the State’s demonstration regarding CAIR and reasonable progress for EGUs, and other prov isions in this SIP revision, are based on CAIR

. In a separate action, EPA has proposed a limited disapproval of the Georgia regional haze SIP because of deficiencies in the State’s regional haze SIP submittal arising from the State’s reliance on CAIR to m eet certain regional haze requirements. See 76 FR 82219 (December 30, 2011). EPA is not proposing to take action in this rulemaking on issues associated with Georgia’s reliance on CAIR in its regional haze SIP.

.66

III. Evaluation of Regional Haze Submi ttal

D . Best Available Retrofit Technology (BART) Requirements

D.4. Source Specific BART Determinations: For each BART

- eligible source in the State subject to BART, a determination of BART based on an analysis of the best system

of continuous emission control technology available and associated emission reductions

achievable (unless the State demonstrates that an emissions trading program or other alternative will achieve greater reasonable progress toward natural visibility conditions).

To address the requirements for BART, the State must take into consideration all of the “Five Factors” from 51.308(e)(1)(ii)(A): (1) the technology available, (2) the costs of compliance, (3) the energy and non

- air quality environmental impacts of compliance, any pollu tion control equipment in use at the source, (4) the remaining useful life of the source, and (5) the degree of improvement in visibility that may reasonably be anticipated to result from the use of such technology.

State Regional Haze Submittal Georgia SIP Narrative, Pages 107

- 108;

Two sources, Interstate Paper in Riceboro, Georgia, and Georgia Power Plant Bowen in Cartersville, Georgia, were unable to demonstrate a contribution of less than 0.5 dv at all Class I areas within 300 km from their BART

- eligible sources. These two sources are considered to be “subject to BART” and were required to do a complete BART determination containing their evaluation of potential BART options and accordingly

submi t permit applications. Interstate Paper failed to perform a BART determination, therefore the analysis was performed by EPD and the results presented are those determined by EPD. Their BART determination results are give in table 7.7.3

- 1, for a

more detail ed discussion of the BART determinations, please see Appendix H.8

....67

Georgia SIP

, Appendix H

. 8_IP

- BACT

, Pages 1

- 2:

The Best Available Retrofit Technology (BART) analysis follows the “five factor” approach. The basic steps of a “five factor” analysis are as follows: 1. Cost of Controls 2. Energy and non

- air quality environmental impacts 3. Existing controls at the s ource 4. Remaining useful life of the source 5. Visibility improvement reasonably expected from the controls

A detailed description of cost of controls for BART

- subject units at Interstate Paper, LLC mill in Riceboro, Georgia is given in the BART engin eering analysis section. Most of the control costs were obtained from AirControlNET

- 4.1. Fuel switching cost was based on the facilities fuel usage and the cost of fuel in 2007 based on number provided by the facility itself. This section also gives an in

- depth description and usage of the existing

controls at the source.

There are no known energy and non

- air quality environmental impacts related to BART determined controls for Interstate Paper, LLC. Remaining useful life of the source is

known to be at l east 10 years. Visibility improvement reasonably expected from application of the controls is described in the modeling analysis section.

Georgia EPD performed the five steps for each visibility

- affecting pollutant emitted from

the BART

- subject units. Re levant pollutants are only: sulfur dioxide (SO

2 ), nitrogen

oxides (NO

x ) and particulate matter (PM

10 ).

.... Georgia SIP

, Appendix H

. 8_IP

- BACT

, Page 23:

The Georgia Environmental Protection Division (GA EPD) completed a BART Determination assessment of several alternative scenarios. Based on the detailed BART analysis of control options feasible for each of the BART

- eligible sources, GA EPD

determined that the most beneficial control option would be to limit the Power Boiler to burning natural gas.

In developing appropriate emissions estimates for this scenario, it was noticed that the Power Boiler is permitted as a back

- up device for controlling non

- cond ensable gases (NCGs). The current Title V application list the SO

2 emission rate due solely to

combusting NCGs as 53.8 pounds of SO

2 per hour, and includes a limit of such operation

to 1480 hours per year. AP

- 42 was used to calculate the SO

2 and NOx emissi on rates

appropriate for firing the Power Boiler at 100% capacity. The AP

- 42 emission rate was increased by the maximum SO

2 emissions due to combustion of NCGs in the Power

Boiler. These emissions, indicated in Table 7 and 8, were modeled for this alternat ive scenario. The modeling was conducted in the same manner as the other two modeled

scenarios.68

The results of modeling the natural gas combustion scenario are presented in Tables 9 and 10. Only Wolf Island receptors were evaluated, since the other Class I areas had already been demonstrated to be unaffected by Interstate Paper emissions, or Interstate Paper was able to be exempted from further BART requirements in these other Class I

areas.

In contrast to the baseline scenario, the natural gas firing sc enario showed a total of 14 occurrences of impacts over 0.5 ΔdV at Wolf Island versus 30 occurrences in the baseline

scenario. Thus the 3

- yr period impacts decreased below the exemption level on this basis. In 2001, the number of 24

- hr average exceedances of 0.5 ΔdV decreased from 8 to 6 per year; in 2002, the number decreased from 12 to 6 per year; and in 2003, the number decreased from 10 to 2 per year. Since none of the modeled years in the natural gas

firing scenario showed a 98 th percentile high impact in excess of 0.5 ΔdV, the facility meets both exemption criteria by implementing this scenario.

.... Georgia SIP Appendix H

. 8_IP

- BACT , Pages 16

- 17:

Georgia Tech performed a study for EPD that compared the impacts of statewide reductions of point SO2 and point NOx emissions on visibilities at the Wolf Island and Okefenokee Class I areas (see Appendix A). The metric used for visibility improvement

was l ight extinction (specifically reduction of light extinction), expressed in units of

inverse megameters (Mm - 1 ). The study found that a statewide reduction of one ton per year of point SO2 emissions would effect estimated light extinction reductions of 1.97 x

10 - 5 Mm - 1 at Wolf Island and 2.59 x 10 - 5 Mm - 1 at Okefenokee. A one

- ton

- per

- year reduction of point NOx emissions (statewide) would achieve estimated reductions in light

extinction of 0.319 x 10 - 5 Mm - 1 at Wolf Island and 0.159 x 10 - 5 Mm - 1 at Okefenokee. T he ratios of light extinction reduction from SO2 reduction to light extinction reduction from NOx reduction are then 6.2 at Wolf Island and 16.4 at Okefenokee. SO2 reductions are therefore expected to provide substantially more visibility improvement than NOx reductions at both of these Class I areas.

Sections 3.3, 4.3, and 4.4 evaluate potential BART control options for Interstate Paper‟s Lime Kiln and Power Boiler emissions. Using the results of the Georgia Tech study and EPD‟s calculations of visibilit y impacts due to SO2 reductions at specific emissions sources, it is possible to estimate the total visibility improvements for the potential control technologies. The visibility improvements are presented only for Wolf Island

since it has been determined (Section 7.1) that the benefits of Interstate Paper emissions controls on visibility at Okefenokee are too small to be considered. The SO2 visibility

impact (0.000076 Mm - 1 /tpy) used in this calculation is based on site

- specific modeling performed by EPD of the impact of Interstate Paper‟s SO2 emissions on light extinction at Wolf Island (Appendix N.1, Table 1). This is believed to be a more accurate estimate of the impact than the SO2 impacts determined from the statewide emissions impact study.

The NOx v isibility impact is then determined by applying the ratio (1/6.2) of the NOx impact to the SO2 impact (from the state

- wide study) to the site

- specific SO2 visibility69

impact, resulting in 0.000013 Mm - 1 /tpy. Note that EPD did not directly model the impact of NOx reductions at specific sites on visibility.

These impacts (0.000076 Mm - 1 /tpy and 0.000013 Mm - 1 /tpy) are then applied to the specific emissions reductions associated with the potential control options. Tables 5.1 and 5.2 show the light extinction redu ctions associated with the potential control options presented in Sections 3 and 4 for the lime kiln and the power boiler. The light extinction

reductions from the SO2 control options range from 0.0147 to 0.0225 Mm - 1 . The light

extinction reductions from t he NOx control options range from 0.0006 to 0.0041 Mm - 1

.

Due to the lower extinction reductions (visibility improvements) for the NOx controls they were excluded from further consideration as feasible BART control options.

.... Georgia SIP Narrative , Page 107:

One of Georgia ‟s BART

- eligible sources is an EGU. This Georgia Power

- Plant Bowen is subjected to CAIR. US EPA has determined that, as a whole, the CAIR cap

- and

- trade program improves visibility more than implementing BART for individual sources in states affected by CAI

R. A State that opts to participate in the CAIR program under Part

96 AAA

- EEE need not require an affected BART

- eligible EGU to install, operate, and maintain BART for SO2 or NOx emissions. Since Georgia is participating in CAIR and accepts US EPA‟s overal l finding that CAIR “substitutes” for BART for NOx and SO2, Georgia‟s EGUs were allowed to submit BART exemption modeling demonstrations for PM emissions only. All EGUs other than Georgia Power

- Plant Bowen demonstrated that they do not contribute to visibi lity impairment in any Class I area.

EPA Findings : EPA proposes to find that Georgia has adequately addressed this provision. For Interstate Paper (the non

- CAIR source in the State subject to BART )

, t he State appropriately documented the technical analys is to assess the need and implementation of BART controls as applicable for PM, SO 2 and NOx precursor emissions. This involved identification of existing controls on applicable emission units, potential control options for applicable emission precursors, and the successful application of the f

ive f actors to determine the feasibility of controls that constituted

BART. T he NOx controls identified , except for their visibility impact, are sufficient ly cost effective that they likely would otherwise have been considered BART. However, consideration of the relative degree of improvement in visibility from the NOx controls (extrapolated from modeled sensitivity of visibility improvement from NOx emission reductions) as discussed in section 5 of Appendix H.8 of the Georgia SIP submittal was an appropriate factor in the determination of BART. EPA proposes to agree with Georgia’s analyses and conclusions for BART for Interstate Paper because the analyses
were conducted consistent with EPA’s BART Guidelines and EPA’s Air Pollution

Control Cost Manual , and the conclusions reflect a reasonable application of EPA’s guidance to these sources.

Regard ing the BART determination for Georgia Power

- Plant Bowen, Georgia opted to have CAIR satisfy BART for SO 2 and NO

x , as allowed under the Regional Haze70

regulations. However, as explained in Section III.C.1

– EPA Findings, the State’s demonstration regarding CAIR and reasonable progress for EGUs, and other provisions in this SIP revision, are based on CAIR

.

In a separate action proposing limited disapproval of the regional haze SIPs of a number of states, EPA noted that these states relied on the trading programs of CAIR to satisfy the BART requirement and the requirement for a LTS sufficient to achieve the s tate

adopted RPGs. See 76 FR 82219 (December 30, 2011). In that action, EPA proposed a limited disapproval of Georgia’s regional haze SIP submittal insofar as the SIP relied on CAIR. For that reason, EPA is not taking action on that aspect of Georgia’s re gional

haze SIP in this action.

.71

III. Evaluation of Regional Haze Submittal

D . Best Available Retrofit Technology (BART) Requirements

D.5. Enforceability of BART: For each BART

- eligible source in the State subject to BART, the SIP should include emission limitations representing BART and schedules for compliance with BART. For each BART

- eligible source in the State subject to BART,

the SIP must include a requirement that each source subject to BART be required to install and operate BART as expeditiously as practicable, but in no event later than five years after approval of the implementation plan revision and a requirement that each source subject to BART maintains the control equipment required by this subpart and establishes procedures to ensure such equipment is properly operated and maintained.

State Regional Haze Sub mittal Georgia SIP Narrative, Page 108 :

The required operational restrictions will be implemented by adding them as permit conditions to the Title V operating permit of Interstate Paper (see Appendix M). Georgia EPD has notified Interstate Paper in writi ng of the intent to revise its air permit. Recordkeeping, monitoring, and testing requirements will be included to demonstrate compliance with the limits. These requirements will be consistent with Georgia EPD‟s Procedures for Testing and Monitoring Sourc es of Air Pollutants (PTM) and must meet the requirements of Compliance Assurance Monitoring (40 CFR Part 64) or Periodic Monitoring [40 CFR 70.6(3)(i)(B)], as appropriate.

.... G eorgia SIP Appendix M :

Emissions Limits Established Through BART Analysis

Per mit Conditions for Interstate Paper, Power Boiler 1. The Permittee shall: (a) burn only natural gas in the Power Boiler (Source Code PW01) except during periods of natural gas curtailment, and (b) burn TRS

containing waste gas streams in the Power Boiler only during periods when both the Lime Kiln (primary TRS waste control device) and the Multi

- fuel Boiler (secondary TRS waste control device) are out of service. This requirement shall be effective on the first day of the sixty

- first month after the month in which Georgia‟s Regional Haze State Implementation Plan (for the progress period ending in 2018) is approved by U.S. EPA. 2. The Permittee shall submit a plan for any physical or operational changes required

to meet Condition 1 not later than 18 months prior to the effective date of Condition 1.. The plan, if required, shall include all permit applications required under Georgia Air Quality Control Rules 391

- 3

- 1

- .03. 3. The Permittee shall submit a proposal to satisfy the periodic monitoring requiremen ts of 40 CFR 70.6(a)(3)(i)(B) or a Compliance Assurance Monitoring Plan as required by 40 CFR Part 64, whichever is applicable, in order to ensure compliance with Condition 1. The Permittee shall submit the proposal (or plan) not later than 18 months prior to the effective date of Condition 1.72

Emissions Limits Established Through Four

- Factor Analysis Permit Conditions for GA Pacific Brunswick Cellulose, Power Boiler No. 4 1. Effective January 1, 2012, the Permittee shall not discharge, or cause the discharge, into the atmosphere from Power Boiler #4 (Source Code U700) sulfur dioxide (SO2) emissions in excess of 568 tons during any twelve

- consecutive month period. The first compliance period shall be January through December, 2012. 2. The Permittee shall submit a plan for complying with the emission limit of condition 1, including all required permit applications required under Georgia Air Quality

Control Rules 391

- 3

- 1

- .03 for any physical or operational changes requ ired to meet the emission limit of condition 1, on or before June 30, 2010. 3. The Permittee shall submit a proposal to satisfy the periodic monitoring requirements of 40 CFR 70.6(a)(3)(i)(B) or a Compliance Assurance Monitoring Plan as required by 40 CFR Part 64, whichever is applicable, in order to ensure compliance with condition 1, on or before June 30, 2010.

Permit Conditions for International Paper Savannah Mill, Power Boiler No. 13 1. Effective January 1, 2016, the Permittee shall not discharge, or cause the discharge, into the atmosphere from Power Boiler No. 13 (Source Code PB13) and from the combustion of low

- volume high

- concentration (LVHC) non

- condensable gases, high

- volume low

- concentration (HVLC) non

- condensable gases, and stripper off

gase s (SOG) (excluding the combustion of any of these gases No. 7 Lime Kiln (LK07)) sulfur dioxide (SO2) emissions in excess of 6578 tons respectively during any twelve

- consecutive month period. The first compliance period shall be January through December, 20 16. 2. The Permittee shall submit a plan for complying with the emission limit of condition 1, including all required permit applications required under Georgia Air Quality

Control Rules 391

- 3

- 1

- .03 for any physical or operational changes required to

meet the emission limit of condition 1, on or before June 30, 2014. 3. The Permittee shall submit a proposal to satisfy the periodic monitoring requirements of 40 CFR 70.6(a)(3)(i)(B) or a Compliance Assurance Monitoring Plan as required by 40 CFR Part 64, whi chever is applicable, in order to ensure compliance with condition 1, on or before June 30, 2014.

Permit Conditions for Georgia

- Pacific Cedar Springs Recovery Boiler 3 and Power

Boilers 1 and 2 (Note that these conditions have been proposed as a Title V permit amendment in order to exempt the facility from BART determination requirements as well as to satisfy the reasonable progress requirements of Regional Haze.) 1.3 Process Description of Modification Georgia

- Pacific Corporation

- Cedar Springs operati on is making the following changes at the facility to comply with BART regulations. Addition of caustic, limestone or both as a scrubbing media to the existing scrubbers use to control PM emissions from Power Boiler No. 1 and Power

Boiler No.273 Limiting t he SO2 emissions from the recovery boiler to 350 ppm when firing black liquor on a daily average basis Limit the daily average SO2 emissions from the Power Boiler No. 1 and Power

Boiler No. 2 to 135 lb/hr each. Install CEMS on Recovery Boiler No. 3 to mo nitor SO2 emissions. Repair concentrator sets, install a new caustic day tank and a new lift station to connect power boiler scrubber blowdown to the waste water treatment system. 3.2.6 Upon completion of the BART project, the Permittee shall not dischar ge or cause the discharge into the atmosphere from Recovery Boiler No. 3 (Source Code R402) any gases which contain: c. Sulfur dioxide emissions in excess of 350 ppm on a dry basis corrected to 8 percent oxygen as a 24

- hour average when firing black liquo r solids 3.2.19 Upon completion of the BART project, the Permittee shall abide by the following

emission limits: a. The Permittee shall not discharge or cause the discharge into the atmosphere from Power Boiler No. 1 and Power Boiler No. 2 any gases that contain sulfur dioxide(SO2) exceeding 135 pound per hour each averaged over a 24 hour period. 4.2.26 Within 90 days of the completion of the BART Project, the Permittee shall perform an initial compliance test on Power Boilers No. 1 and 2 to determine co mpliance with the limits specified in Condition 3.2.19 and also establish the excursion limits for pH of the scrubbing solution to meet the limits specified in Condition 3.2.19. The RATA test and the performance test shall be performed simultaneously. The compliance with the emission limits in condition 3.2.19 will be demonstrated using continuous 24 hour of CEMS data, the first hour starting with the first hour of RATA testing. 4.2.27 Within 90 days of the completion of the BART Project, the Permittee shall perform an initial compliance test on Recovery Boiler No. 3 (Source Code R402) to determine compliance with the limits specified in Condition 3.2.6. The RATA test and the performance test shall be performed simultaneously. The compliance with

the em ission limits in condition 3.2.6 will be demonstrated using continuous 24 hour of CEMS data, the first hour starting with the first hour of RATA testing. 5.2.1 The Permittee shall install, calibrate, maintain, and operate a system to continuously monitor and record the indicated pollutants on the following equipment. Each system shall meet the applicable performance specification(s) of the Division's monitoring requirements. c. Opacity, TRS, sulfur dioxide and oxygen from Recovery Boiler No. 3 (Source

Cod e R402). The requirement for the installation of a continuous monitor for sulfur dioxide will be effective on the date of the completion of the BART project 5.2.2 The Permittee shall install, calibrate, maintain, and operate a system to continuously moni tor and record the indicated parameters on the following equipment. Where such performance specification(s) exist, each system shall meet the applicable performance specification(s) of the Division's monitoring requirements.74 d. Pressure drop, pH and scrub bant flow rate from the scrubbers on Power Boiler No. 1 and No. 2 (Source Codes U500 and U501). The requirement for the measurement of pH will be effective on the date of the completion of the BART project. 5.2.19 The following pollutant specific emissio n units (PSEUs) are subject to the Compliance Assurance Monitoring (CAM) Rule in 40 CFR 64.

Emission Unit Pollutant Power Boiler Nos. 1 and 2 (Source Codes U500 and U501) SO2 In addition, the Permittee shall meet the requirements, as applicable, of 40 C FR 64.7, 64.8, and 64.9. 5.2.21 The Permittee shall comply with the performance criteria listed in the table below for the particulate matter and sulfur dioxide emissions from Power Boiler Nos. 1 and 2 (Source Codes U500 and U501):

Performance Criteria Indicator No. 1
Scrubbant Flow Rate Indicator No. 2 Pressure Drop Across
Scrubber Indicator No. 3 PH of Scrubbing
Media A. Data Representativeness The flow rate is measured using
standard
instrumentation provided for this

purpose. The differential pressure

across the scrubber will be measured using
standard
instrumentation provided for this

purpose. Continuous monitoring of scrubbant pH.

B. Verification of Operational Status (new/modified monitoring equipment only) N/A N/A N/A

C. QA/QC Practices and Criteria Annual Calibration. Annual Calibration. Annual Calibration.
D. Monitoring Frequency Continuous. Continuous. Continuous.

E. Data Collection Procedures Recorded by the mill data collection system. Recorded by the mill data collection system. Recorded by the mill data collection system. F. Averaging Period 3

- hour average. 3

- hour average. 3

- hour average.

5.2.29 For sulfur dioxide CEMS installed on Recovery Boiler No.3 (Source Code R402)

the Permittee shall perform annual RATA tests, quarterly accuracy determinations, and daily CEMS drift checks in accordance with the following procedures and requirements: a. A Relative Accuracy Test Audit (RATA) shall be conducted on the CEMS at

least once e very four successive operating quarters. The procedures of Appendix F of 40 CFR Part 60 shall be used to conduct the RATA. The results of a RATA shall be submitted to the Division within 60 days of completion of the RATA. b. A cylinder gas audit shall be conducted at least once every quarter in accordance with Appendix F of 40 CFR 60. c. CEMS drift checks shall be conducted daily in accordance with 40 CFR 60.13(d). 6.1.7 For the purpose of reporting excess emissions, exceedances or excursions in the

repo rt required in Condition 6.1.4, the following excess emissions, exceedances, and excursions shall be reported:75

a. Excess emissions: (means for the purpose of this Condition and Condition 6.1.4, any condition that is detected by monitoring or record keepin g which is specifically defined, or stated to be, excess emissions by an applicable requirement)

Recovery Boilers No. 3 xv. Upon completion of the BART project, the Permittee shall abide by the following : For Recovery Boiler No. 3 (Source Codes R402), a ny 24

- hour period during which the SO2 concentration, expressed as the arithmetic average of 24 contiguous 1

- hour periods, measured and recorded in accordance with 5.2.1.c is in excess of 350 ppm on a dry basis corrected to 8 percent oxygen when firing bla ck liquor only.

Power Boilers No. 1 and 2 xvi. Upon completion of the BART project, the Permittee shall abide by the following: For Power Boiler No. 1 and 2 (Source Codes U500 and U501), any 24

- hour period during which the SO2 concentration, expressed a s the arithmetic average of 24 contiguous 1

- hour periods, measured and recorded in accordance with 5.2.1.b and

calculated in accordance with Conditions 6.2.18 exceed 135 lbs per hour. c. Excursions: (means for the purpose of this Condition and Condition 6 .1.4, any departure from an indicator range or value established for monitoring consistent with any averaging period specified for averaging the results of the monitoring)

Power Boilers No. 1 and No. 2 viii. Upon completion of the BART project, the Permi ttee shall abide by the following: Any three consecutive 1

- hour periods during which the pH measured and recorded in accordance with Condition 5.2.2.d for either scrubber on Power Boiler No. 1 or No. 2 (Source Codes U500 and U501) fall below the values es tablished during the performance test required by condition 4.2.26. 6.2.47 The Permittee shall submit the actual date of the completion of the BART Project. This submittal shall include certification that a final inspection has shown that the BART Project was completed in accordance with Application No.18385. This notification shall be submitted within 15 days following the completion of the BART Project.76

6.2.48 At the end of each calendar month and while Power Boiler No. 1 and Power Boiler No. 2 (Source Code U500 and 501) is subject to Condition 3.3.19, the Permittee shall calculate and record both monthly emission totals and twelve

month rolling emission totals for sulfur dioxide (SO2) using the daily results of Condition 6.2.18. When a monthly emission total exceeds 49.27 tons for SO2 for any of the Power Boilers, the Permittee shall submit a statement indicating how the Permittee intends to meet the applicable limit(s) specified in Condition 3.3.19; this statement shall be submitted by the 30th day of t he following calendar month. Records of all monthly and twelve

- month rolling emission totals, records of demonstration calculations, records of any factors used in the calculation of criteria pollutant emissions, and other supporting documentation shall be maintained. These records shall be kept available for inspection by or submittal to the Division for a period of five years following the date of record. 7.14.1 The scrubber modification for Power Boilers 1 and 2 and repairs to the

concentrators sets (BART project) along with all changes identified in Condition 1.3 to comply with BART shall be completed by July 30, 2011

.

EPA Findings : EPA proposes to find that Georgia has adequately addressed this provision. In a November 19

, 2010 supplemental submittal , the State provided copies of

the t itle V permits with the add ed conditions to make the limits federally enforceable

. EPA proposes to find for Interstate Paper ( the BART

- eligible source in the State subject

to BART )

, that the t itle V operating permit adequately includes emission limitations representing BART and schedules for compliance with BART that require the source to install and operate BART as expeditiously as practicable, but in no event later than five years after appr oval of the implementation plan revision

. The conditions in the operating permit will ensure that each source subject to BART maintains the control equipment required by this subpart and establishes procedures to ensure such equipment is properly operated and maintained.

Similarly

, the t itle V permits for the two r easonable p rogress affected sources ( GA

Pacific Brunswick Cellulose ( Power Boiler No. 4 ) and International Paper Savannah Mill ( Power Boiler No. 13) ) are consistent with EPA guidance on enforceability and expeditiousness.

With regard to the Georgia

- Pacific Corporation

- Cedar Springs operation which is adopting limits and installing controls so that it will be exempt from BART

, EPA proposes to find that the operating permit adequately includes emission limitations and schedules for compliance that require the source to install and operate control equipment as expeditiously as practicable. In this instance

, compliance with the regulatory limit requires the installation of control equip ment that could not be reasonably be completed by the SIP submittal date. Also

, GA EPD has concluded and EPA proposes to agree that, that had the source completed a BART analysis, it is unlikely any additional controls

would have been identified as reason able. Finally

, EPA notes that compliance will be

within the 18 months of the submittal

, which is the time allowed under the CAA for EPA

to take final action on a SIP submittal. Since the schedule for compliance is expeditious (July 3 0 , 2011) considering t he installation of equipment necessary for compliance and77

the limits are legally enforceable, EPA proposes to determine that the BART exemption determination is acceptable in this instance

.

In a separate action, EPA has proposed a limited disapproval of the Georgia regional haze SIP because of deficiencies in the State’s regional haze SIP submittal arising from the State’s reliance on CAIR to meet certain regional haze requirements. See 76 FR 82219 (December 30, 2011). EPA is not proposing to take actio n in this rulemaking on issues associated with Georgia’s reliance on CAIR in its regional haze SIP.78

III. Evaluation of Regional Haze Submittal

E

. Coordination of Regional Haze and RAVI Requirements

The State must revise its SIP to provide for review and revision of a coordinated long

term strategy for addressing reasonably attributable and regional haze visibility impairment

.

State Regional Haze Submittal

EPA Note : Georgia did not explicitly address this requirement regarding a coordinated RAVI and regional haze long

- term strategy . However, GA EPD has included provisions in this SIP submittal that updated the elements subject to the RAVI long

- term strategy requirements (inc luding monitoring and new source review (NSR)) :

G eorgia SIP Narrative, Pages 114

- 117 :

Monitoring Strategy The primary monitoring network for regional haze is the IMPROVE network. Given that IMPROVE monitoring data from 2000

- 2004 serve as the baseline for the regional haze program, the future regional haze monitoring strategy must necessarily be based on, or directly comparable to, IMPROVE. The IMPROVE measurements provide the only long

term record available for tracking visibility improvement or degradati on and, therefore, Georgia intends to rely on the IMPROVE network for complying with the regional haze monitoring requirement in the Regional Haze Rule. There are currently two IMPROVE

sites in the State.

GA EPD will use South Eastern Aerosol Research and Characterization (SEARCH) data from the sites illustrated below for further the understanding of both PM2.5 and visibility formation and trends in Georgia. The SEARCH monitors provides the following data related to the nature of ambient fine particulate m atter:
• 24

- hr PM2.5 filter samples, analyzed for mass, ions (sulfate, nitrate, ammonium), organic carbon (OC), elemental (black) carbon (EC or BC), and elements as measured by X

- ray fluorescence (XRF);

• 24

- hr PM coarse mass, ions, and XRF elements;

• 24

- hr gaseous ammonia as collected with an annular denuder; • Continuous (minute to hourly) PM2.5 mass, OC, EC, ammonium, nitrate, and sulfate; light scattering and light absorption; • Continuous gaseous ozone, nitric oxide, nitrogen dioxide, total oxidized n itrogen (NOy), nitric acid, carbon monoxide, and sulfur dioxide; and

• Continuous 10

- m meteorological parameters: wind speed, wind direction, precipitation, temperature, barometric Pressure, relative humidity and solar

radiation.

The Clean Air Status and Trends Network (CASTNet) provides atmospheric data on the dry deposition component of total acid deposition, ground

- level ozone and other forms of atmospheric pollution. All measurements utilize a 1

- week sample period and include79

sulfur dioxide, particula te sulfate, particulate nitrate, nitric acid, particulate ammonium, particulate calcium, particulate sodium, particulate magnesium, particulate potassium, and ozone. In addition, GA EPD operates a fairly comprehensive PM2.5 network of the filter

- based Fede ral reference method (FRM) monitors, continuous mass monitors (TEOMs), filter

- based speciated monitors (STN) and the continuous speciated monitors described above. A map of the various locations around the State is included in Figure

9.0.1. These PM2.5 mea surements help GA EPD characterize air pollution levels in areas across the state, and, therefore, aid in the analysis of visibility improvement in

and near the Class I areas.

The IMPROVE measurements are central to Georgia‟s regional haze monitoring

stra tegy, and it is difficult to visualize how the objectives listed above could be met without the monitoring provided by IMPROVE. Any reduction in the scope of the IMPROVE network in Georgia would jeopardize the State‟s ability to demonstrate reasonable prog ress toward visibility improvement in some of its Class I areas. In particular, Georgia‟s regional haze strategy relies on emission reductions that will on different timelines and will most likely not be spatially uniform.

Because each of the current IMPR OVE monitors in Georgia represents a different airshed, reduction of the IMPROVE network by shutting down one of these monitoring sites impedes tracking progress at reducing haze at the affected Class I area. In the event this occurs, Georgia, in consultat ion with the US EPA and relevant Federal Land Managers, will develop an alternative approach for meeting the tracking goal, perhaps by seeking contingency funding to carry out limited monitoring or by relying on data from nearby urban monitoring sites to d emonstrate trends in speciated PM2.5 mass.

Data produced by the IMPROVE monitoring network will be used nearly continuously for preparing the 5

- year progress reports and the 10

- year SIP revisions, each of which relies on analysis of the preceding five years of data. Consequently, the monitoring data from the IMPROVE sites needs to be readily accessible and to be kept up to date.

Presumably, IMPROVE will continue to process information from its own measurements at about the same pace and with the same a ttention to quality as it has shown in the recent past. The VIEWS web site has been maintained by VISTAS and the other Regional Planning Organizations (RPOs) to provide ready access to the IMPROVE data and data analysis tools. Georgia is encouraging VISTAS and the other RPOs to maintain VIEWS or a similar data management system to facilitate analysis of the IMPROVE data.

G eorgia SIP Narrative, Page 121 :

Ten Year Plan and Five Year Plan Update 40 CFR Section 51.308(f) requires the GA EPD to revise its regional haze implementation plan and submit a plan revision to US EPA by July 31, 2018, and every ten years thereafter. In accordance with the requirements listed in Section 51.308(f) of the Federal rule for regional haze, Georgia commits to revising and submitting this regional haze implementation plan by July 31, 2018, and every ten years thereafter.80

In addition, Section 51.308(g) requires periodic reports evaluating progress towards the reasonable progress goals established for each mandatory Class I a rea. In accordance with the requirements listed in Section 51.308(g) of the Federal rule for regional haze, the GA EPD commits to submitting a report on reasonable progress to US EPA every five years following the initial submittal of the SIP. The report w ill be in the form of a SIP revision. The reasonable progress report will evaluate the progress made towards the reasonable progress goal for each mandatory Class I area located within Georgia and in each mandatory Class I area located outside Georgia whic h may be affected by emissions from within Georgia

.

G eorgia SIP Narrative, Page 124:

Consultation 40 CFR 51.308(i)(4) requires the plan (or plan revision) to include procedures for continuing consultation between the State and Federal Land Managers on th e implementation of the visibility protection program, including development and review of implementation plan revisions and 5

- year progress reports, and on the implementation of other programs having the potential to contribute to impairment of visibility in mandatory Class I Federal areas. GA EPD will offer the Federal Land Managers an opportunity for consultation on a yearly basis, including the opportunity to discuss the implementation process and the most recent IMPROVE monitoring data and VIEWS

data. Records of annual consultations and progress report consultations will be maintained in Georgia EPD‟s Regional Haze files.

EPA Findings : EPA proposes to find that this regional haze submittal adequately supplements and augments Georgia’s RAVI visibility provisions to address regional haze, updating the monitoring and LTS provisions as summarized below in this section.

Under EPA’s RAVI regulations, the RAVI po rtion of a state SIP must address any integral vistas identified by the FLMs pursuant to 40 CFR 51.304. An integral vista is defined in 40 CFR 51.301 as a “view perceived from within the mandatory Class I Federal area of a specific landmark or panorama lo cated outside the boundary of the mandatory Class I Federal area.” Visibility in any mandatory Class I area includes any integral vista associated with that area. The FLMs did not identify any integral vistas in Georgia. In addition, the Class I areas i n Georgia are neither experiencing RAVI nor are any of its sources affected by the RAVI provisions. Thus, the Georgia regional haze SIP submittal does not explicitly address the two requirements regarding coordination of the regional haze with the RAVI LT S and monitoring provisions. However, Georgia previously made a commitment to address RAVI should the FLMs certify visibility impairment from an individual source. 3 EPA proposes to find that this regional haze submittal appropriately supplements and augm ents Georgia’s RAVI visibility provisions

3 Georgia submitted its visibility SIP revision s address ing RAVI on August 31, 1987, which EPA approved on July 12, 1988, (53 FR 26253).81

to address regional haze by updating the monitoring and LTS provisions as summarized

below in this section.

In its January 25, 2010, submittal, GA EPD updated its visibility monitoring program and developed a LTS to address regional haze. Also in this submittal, GA EPD affirmed its commitment to complete items required in the future under EPA’s RHR. Specifically, GA EPD made a commitment to review and revise its regional haze implementation plan and submit a plan revision to EPA by July 31, 2018, and every 10 years thereafter. See 40 CFR 51.308(f). In accordance with the requirements listed in 40 CFR 51.308(g) of EPA’s regional haze regulations and 40 CFR 51.306(c) of the RAVI LTS regulations,

GA EPD committed t o submit a report to EPA on progress towards the RPGs for each mandatory Class I area located within Georgia and for each mandatory Class I area located outside Georgia that may be affected by emissions from within Georgia. The progress report is required to be in the form of a SIP revision and is due every five years following the initial submittal of the regional haze SIP. Co nsistent with EPA’s monitoring regulations for RAVI and regional haze, Georgia will rely on the IMPROVE network for compliance pur poses, in addition to any RAVI monitoring that may be

needed in the future. See 40 CFR 51.305, 40 CFR 51.308(d)(4). Also, the Georgia new source review rules, previously approved in the State’s SIP, continue to provide a

framework for review and coordina tion with the FLMs on new sources which may have an adverse impact on visibility in either form (i.e., RAVI and/or regional haze) in any

Class I area.82

III. Evaluation of Regional Haze Submittal

F

. Monitoring Strategy and Other Implementation Requirements

Monitoring Strategy: The SIP must include a monitoring strategy for measuring, characterizing, and reporting of regional haze visibility impairment that is representative of all mandatory Class I Federal areas within the State and/or summarize monitoring strategy of States with affected mandatory Class I Federal areas . Compliance with this requirement may be met through participation in the Interagency Monitoring of Protected Visual Environments (IMPROVE) network.

O ther Requirements: The implementation plan must also provide for the following:

A. The establishment of any additional monitoring sites or equipment needed to assess whether reasonable progress goals to address regional haze for all mandatory Class I Federal areas within the State are being achieved.

B. Procedures by which monitoring data and other information are used in determining the contribution of emissions from within the State to regional haze visibility impairment at mandatory Class I Federal areas both within and outside

the State.

C. The reporting of all visibility monitoring data at least annually for each mandatory Class I Federal area in the State. To the extent possible, the State should report monitoring data for visibility electronically and use of t he Visibility Information Exchange Web System (VIEWS) is encouraged.

D. Other elements, including reporting, recordkeeping, and other measures, necessary to assess and report on visibility.

State Regional Haze Submittal

G eorgia SIP Narrative , Pages 114

– 1 17:

The State Implementation Plan is to be accompanied by a strategy for monitoring regional haze visibility impairment. Specifically, the Regional Haze Rule states at 40 CFR 51.308(d)(4): “(4) Monitoring strategy and other implementation plan requirement s. The State must submit with the implementation plan a monitoring strategy for measuring, characterizing, and reporting of regional haze visibility impairment that is representative of all mandatory Class I Federal areas within the State. This monitoring strategy must be coordinated with the monitoring strategy required in §51.305 for reasonably attributable visibility impairment. Compliance with this requirement may be met through participation in the IMPROVE network. The implementation plan must also provide for the following:

(i) The establishment of any additional monitoring sites or equipment needed to assess whether reasonable progress goals to address regional haze for all mandatory Class I Federal areas within the State are being achieved.

(ii)

- (vi) [Other implementation plan requirements that pertain to reporting83

and use of monitoring data and an emission inventory.]”

Such monitoring is intended to provide the data needed to satisfy four objectives:

1. Track the expected vis ibility improvements resulting from emissions reductions identified in this SIP; 2. Better understand the atmospheric processes of importance to haze; 3. Identify chemical species in the ambient particulate matter and relate them to emissions from sources; and 4. Evaluate regional air quality models for haze and construct relative response factors (RRFs) for using those models.

The primary monitoring network for regional haze is the IMPROVE network. Given that IMPROVE monitoring data from 2000

- 2004 serve a s the baseline for the regional haze program, the future regional haze monitoring strategy must necessarily be based on, or directly comparable to, IMPROVE. The IMPROVE measurements provide the only long

term record available for tracking visibility improv ement or degradation and, therefore, Georgia intends to rely on the IMPROVE network for complying with the regional haze monitoring requirement in the Regional Haze Rule. There are currently two IMPROVE

sites in the State.

Table 9.0

- 1. Class I areas in Ge orgia and IMPROVE monitors that represent conditions at each of them.

GA EPD will use South Eastern Aerosol Research and Characterization (SEARCH) data from the sites illustrated below for further the understanding of both PM2.5 and visibility formation and trends in Georgia. The SEARCH monitors provides the following data related to the nature of ambient fine particulate matter:

• 24

- hr PM2.5 filter samples, analyzed for mass, ions (sulfate, nitrate, ammonium), organic carbon (OC), elemental (black) carb on (EC or BC), and elements as measured by X

- ray fluorescence (XRF);

• 24

- hr PM coarse mass, ions, and XRF elements;

• 24

- hr gaseous ammonia as collected with an annular denuder; • Continuous (minute to hourly) PM2.5 mass, OC, EC, ammonium, nitrate, and sulfate; light scattering and light absorption; • Continuous gaseous ozone, nitric oxide, nitrogen dioxide, total oxidized nitrogen (NOy), nitric acid, carbon monoxide, and sulfur dioxide; and

• Continuous 10

- m meteorological parameters: wind speed, wind direction, precipitation, temperature, barometric Pressure, relative humidity and solar

radiation.84

The Clean Air Status and Trends Network (CASTNet) provides atmospheric data on the dry deposition component of total acid deposition, ground

- level ozone and other forms of atmospheric pollution. All measurements utilize a 1

- week sample period and include sulfur dioxide, particulate sulfate, particulate nitrate, nitric acid, particulate ammonium particulate calcium, particulate sodium, particulate magnesium, p articulate potassium,
and ozone.

In addition, GA EPD operates a fairly comprehensive PM2.5 network of the filter

- based Federal reference method (FRM) monitors, continuous mass monitors (TEOMs), filter

- based speciated monitors (STN) and the continuous spe ciated monitors described above. A map of the various locations around the State is included in Figure 9.0.1. These PM2.5 measurements help GA EPD characterize air pollution levels in areas across the state, and, therefore, aid in the analysis of visibilit y improvement in and

near the Class I areas.

Figure 9.0

- 1. PM2.5 Monitoring Network in Georgia85

The IMPROVE measurements are central to Georgia‟s regional haze monitoring strategy, and it is difficult to visualize how the objectives listed above could b e met without the monitoring provided by IMPROVE. Any reduction in the scope of the IMPROVE network in Georgia would jeopardize the State‟s ability to demonstrate reasonable progress toward visibility improvement in some of its Class I areas. In particular

, Georgia‟s regional haze strategy relies on emission reductions that will on different timelines and will most likely not be spatially uniform.

Because each of the current IMPROVE monitors in Georgia represents a different airshed, reduction of the IMPR OVE network by shutting down one of these monitoring sites impedes tracking progress at reducing haze at the affected Class I area. In the event this occurs, Georgia, in consultation with the US EPA and relevant Federal Land Managers, will develop an alter native approach for meeting the tracking goal, perhaps by seeking contingency funding to carry out limited monitoring or by relying on data from nearby urban monitoring sites to demonstrate trends in speciated PM2.5 mass.

Data produced by the IMPROVE moni toring network will be used nearly continuously for preparing the 5

- year progress reports and the 10

- year SIP revisions, each of which relies on analysis of the preceding five years of data. Consequently, the monitoring data from the IMPROVE sites needs to be readily accessible and to be kept up to date.

Presumably, IMPROVE will continue to process information from its own measurements at about the same pace and with the same attention to quality as it has shown in the recent past. The VIEWS web site has b een maintained by VISTAS and the other Regional Planning Organizations (RPOs) to provide ready access to the IMPROVE data and data analysis tools. Georgia is encouraging VISTAS and the other RPOs to maintain VIEWS or a similar data management system to fac ilitate analysis of the IMPROVE data.

.

EPA Findings : EPA proposes to find that Georgia has adequately addressed this provision.86

III. Evaluation of Regional Haze Submittal

G

. Emission Inventory (40 CFR 51.308(d)(4)(v) (See also TSD Section III.C.) )

The SIP must include a statewide inventory of emissions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I

Federal area within the S tate . The inventory must include emissions for a baselin e year, emissions for the most recent year for which data are available, and estimates of future projected emissions

, and a commitment to update the inventory periodically.

State Regional Haze Submittal Georgia SIP Narrative

, Pages 20

- 24 :

4.1 Baseline Emissions Inventory The Regional Haze Rule at 51.308(d)(4)(v) requires a statewide emissions inventory of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I area. An inventory was developed f or the baseline year 2002 and projected to 2009 and 2018. The pollutants inventoried include volatile organic compounds (VOCs), nitrogen oxides (NOx), fine particulate (PM2.5), coarse particulate (PM10), ammonia (NH3) and sulfur dioxide (SO2). The baseline emissions inventory for 2002 was developed for Georgia following the methods described in Appendix C.

There are five different emission inventory source classifications: stationary point and area sources, off

- road and on

- road mobile sources, and biogeni c sources. Stationary point sources are those sources that emit greater than a specified tonnage per year, with data provided at the facility level. Electric generating utilities and industrial sources are the major categories for stationary point sources. Stationary area sources are those sources whose individual emissions are relatively small, but due to the large number of these sources, the collective emissions from the source category could be significant (i.e., dry cleaners, service stations, agricult ural sources, fire emissions, etc.). These types of emissions are estimated on a countywide level. Non

- road (or off

- road) mobile sources are equipment that can move but do not use the roadways, i.e., lawn mowers, construction equipment, railroad locomotive s, aircraft, etc. The emissions from these sources, like stationary area sources, are estimated on a countywide level. On

- road mobile sources are automobiles, trucks, buses, and motorcycles that use the roadway system. The emissions from these sources are estimated by vehicle type and road type and are summed to the countywide level. Biogenic sources are the natural sources like trees, crops, grasses and natural decay of plants. The emissions from these sources are estimated on a countywide level.

In addi tion to the various source classifications, there are also various types of emission inventories. The first is the actual base

- year inventory. This inventory is the base

- year emissions that correspond to the meteorological data used, which for this modelin g effort is data from 2002. These emissions are used for evaluating the air quality model performance.87

The second type of inventory is the typical base year inventory. This inventory is similar

to the actual base

- year inventory, except that for sources wh ose emissions change significantly from year to year, a more typical emission value is used. In this modeling effort, typical emissions were developed for the electric generating units (EGUs) and the wildland fire emissions. The air quality modeling runs u sing the typical base

- year inventory provide results, which are then used to calculate relative reduction factors for future years. These relative reduction factors for future years are then used to demonstrate reasonable progress toward visibility goals.

Below is an overview of the inventories used for each source classification. More detailed discussion of the emissions inventory development is contained in Appendix C.

4.1.1 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 sources emitting at least 100 tons per year (tpy) of VOC, PM10, PM2.5, NH3, SO2, or NOx are inventoried

. The point source emissions data can be grouped as EGU sources and other industrial point sources, also called non

EGUs.

Electric Generating Units The actual base year inventory for the EGU sources used 2002 continuous emissions monitoring (CEM) data rep orted to the US EPA‟s Acid Rain program or 2002 hourly emissions data provided by stakeholders. The data provides hourly emissions profiles for SO2 and NOx that can be used in air quality modeling. Emissions profiles are used to estimate emissions of other pollutants (volatile organic compounds, carbon monoxide, ammonia, fine particles, soil) based on measured emissions of SO2 and NOx.

Emissions from EGUs vary daily and seasonally as a function of variability in energy demand and utilization and outage sch edules. To avoid anomalies in future

- year emissions created by relying on 2002 operations to represent future operations, a typical

base

- year emissions inventory was developed for EGUs. This approach is consistent with the US EPA‟s modeling guidance (Appen dix G). To develop a typical year 2002 emissions inventory for EGU sources, each unit‟s average CEM heat input for 2000 through 2004 was 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 because the modeling current design values use monitored data from this same 5

- year period. If a unit was shut down for an entire year during the 2000 throu gh 2004 period, the average of the years the unit was operational was used. If a unit was shut down in 2002, but not permanently shutdown, the emissions and heat inputs from 2001 (or 2000) were used in the normalizing calculations.

As part of the VISTAS a ir quality modeling, VISTAS, in cooperation with the other eastern RPOs, contracted with ICF Resources, L.L.C., to generate future

- year emission inventories for the electric generating sector of the contiguous United States using the88

Integrated Planning Mo del (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 the entire electric power system. The dynamic nature of IPM enables projecti on of the behavior of the power system over a specified future period. Optimization logic in IPM determines the least

- cost means of meeting electric generation and capacity requirements while complying with specified constraints including air pollution reg ulations, transmission bottlenecks, and plant

- specific operational constraints. The versatility of IPM allows users to specify which constraints to exercise and to populate IPM with their own datasets. The IPM modeling runs took into

consideration both CA IR implementation and Georgia‟s Multipollutant rule requirements for Georgia Power.

Other Industrial Point Sources

For the non

- EGU sources, the same inventory is used for both the actual and typical

base

- year emissions inventories. The non

- EGU category us es annual emissions as reported under the Consolidated Emissions Reporting Rule (CERR) for the year 2002. These emissions are temporally allocated to month, day, and hour using source category code (SCC)

- based allocation factors.

The general approach for assembling future

- year data was to use recently updated growth and control data consistent with US EPA‟s CAIR analyses. This data was supplemented with state

- specific growth factors and stakeholder input on growth assumptions.

4.1.2 Stationary Area Source s Stationary area sources are sources whose individual emissions are relatively small, but due to the large number of these sources, the collective emissions could be significant (i.e., combustion of fuels for heating, structure fires, 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 households, or population. Stationary area source emissions are estimated at the countywide level.

The VISTAS cont ractor used data reported by Georgia under CERR for 2002 area source inventory. GA EPD only provided additional data from other years in order to generate typical fire emissions.

The actual base

- year inventory will serve as the typical base

- year inventory for all area source categories except for wildland fires. For wildland fires, a typical year inventory was used to avoid anomalies in wildfire activity in 2002 compared to longer

- term averages. Development of a typical year fire inventory provided the cap ability of using a comparable data set for both the base year and future years. Thus, fire emissions remain the same for air quality modeling in both the base and any future years. The VISTAS Fire Special Interest Work Group used State records to ratio the number of acres burned over a longer term period (three or more years, as available from state records) to 2002. Based on these ratios, the 2002 acreage was then scaled up or down to develop a typical year inventory.89

Future Year Emissions

The VISTAS cont ractor generated future

- year emissions inventories for 2009 and 2018 for the regional haze modeling. Growth factors, supplied either by states or taken from the CAIR emission projections, were applied to project the controlled emissions to 2018. If no grow th factor was available from either a state or the CAIR growth factor files, then the US EPA‟s Economic Growth and Analysis System Version 5 growth factors were

used.

4.1.3 Off

- Road Mobile Sources Off

- road (or non

- road) mobile sources are equipment that can move but do not use the roadways, such as construction equipment, aircraft, railroad locomotives, lawn and garden equipment, etc. For the majority of the non

- road mobile sources, the emissions fo r 2002 were estimated using the US EPA‟s NONROAD2005 model. For the three source categories not included in the NONROAD model, i.e., aircraft engines, railroad locomotives and commercial marine, more traditional methods of estimating the

emissions were use d. The same inventory is used for both the actual and typical base year

emissions inventories.

For the source categories estimated using the US EPA‟s NONROAD model, the model growth assumptions were used to create the 2009 and 2018 future

- year inventories . The NONROAD model takes into consideration regulations affecting emissions from these source categories. For the commercial marine, railroad locomotives and the airport emissions, the VISTAS contractor calculated the future growth in emissions using

deta iled inventory data (both before and after controls) for 1996 and 2010, obtained from the CAIR Technical Support Document. When available, state

- specific growth factors

were used.

4.1.4 Highway Mobile Sources

For on

- road vehicles, the newest version of th e MOBILE model, MOBILE6.2, was used. Key inputs for MOBILE include information on the age of vehicles on the roads, the average speeds on the roads, the mix of vehicles on the roads, any programs in place in an area to reduce emissions for motor vehicles ( e.g., emissions inspection programs), and

temperature.

The MOBILE model takes into consideration regulations that affect emissions from this source sector. The same MOBILE run is used to represent the actual and typical year emissions for on

- road vehicles using input data reflective of 2002. The MOBILE model then is run for 2018 inventory using input data reflective of that year. Area

- specific vehicle age distributions were modeled. Emissions were modeled using vehicle miles traveled estimates obtained fro m the Georgia Department of Transportation.

4.1.5 Biogenic Emission Sources Biogenic emissions were prepared with the SMOKE

- BEIS3 (Biogenic Emission Inventory System 3 version 0.9) preprocessor. SMOKE

- BEIS3 is a modified version of the

Urban Airshed Model (UAM)

- BEIS3 model. Modifications include use of MM5 data,90

gridded land use data, and improved emissions characterization. The emission factors

that are used in SMOKE

- BEIS3 are the same as the emission factors as in UAM

- BEIS3. The basis for the grid

ded land use data used by BEIS3 is the county land use data in the Biogenic Emissions Landcover Database version 3 (BELD3) provided by the US EPA. A separate land classification scheme, based upon satellite (AVHRR, 1 km spatial resolution) and census infor mation, aided in defining the forest, agriculture and urban portions of each county.

4.1.6 Model Performance Improvements through Emissions Inventory Improvements Since the initial model performance evaluation, VISTAS has made several improvements to the emissions inventory, which, in turn, improve model performance. These inventory improvements are detailed in the VISTAS emissions inventory report and Appendix C, and are summarized here:

• For electric generating utilities, the Integrated Planning Model (IPM) was used to provide estimates of future

- year utility production and emissions. Continuous Emissions Monitoring data was used to define seasonal variability in production and emissions. For Base G4 emissions, states updated IPM model projections from 2005 with control data provided by utility companies in 2006 through winter

2007.

• For on

- road vehicle emissions, states and local agencies provided updated MOBILE model input and vehicle

- miles

- traveled data. • For ammonia emissions from agricultural sou rces, the Carnegie Mellon University ammonia model was used to improve annual and monthly estimates. • For fires, the VISTAS states provided fire activity data for 2002 for wildfires, prescribed fire, land clearing and agricultural burning and MACTEC developed a 2002 fire inventory. Where data allowed, Alpine Geophysics modeled fire events as point sources. In 2006, the United States Forest Service and the Fish and Wildlife Service provided proje ctions of increased prescribed burning in 2009 and 2018. The data was incorporated in the Base G inventory for all states except

Florida.

• For non

- road engines, the updated US EPA NONROAD2005 emissions model

was used in Base G.

For commercial marine emis sions in shipping lanes in the Gulf of Mexico and Atlantic Oceans, ENVIRON created gridded emissions for the VISTAS modeling domain using inventory data newly developed for US EPA by Corbett at University of Delaware.

These emissions were incorporated in the Base G modeling. Updated inventories from the neighboring RPOs, Mexico, and Canada were incorporated as available.

4.1.7 Summary 2002 Base G2 Baseline Emissions Inventory for Georgia Table 4.1 is a summary of the 2002 baseline emission inventory for G eorgia. The91

complete inventory and discussion of the methodology is contained in Appendix C. The emissions summaries for other VISTAS states can also be found in Appendix C.

.... G eorgia SIP Narrative, Pages 46

- 48 :

7.2 Expected Visibility Results in 2018 for Georgia Class I Areas under existing and planned emissions controls (Base G4 Inventory) There are significant control programs being implemented between the baseline period and 2018. These programs are described in more detail below.

7.2.1 Federal and State Control Requirements • Clean Air Interstate Rule (CAIR). Utility projections are based on Integrated Planning Model. US EPA issued CAIR, which will permanently cap emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx) in the eastern United St ates. CAIR achieves large reductions of SO2 and/or NOx emissions across 28 eastern states and the District of Columbia. When fully implemented, CAIR will reduce SO2 emissions in these states by over 70 percent and NOx emissions by over 60 percent from 2003 levels. These reductions were taken into account in the 2018 base G4 inventory.

• Heavy Duty Diesel (2007) Engine Standard. A PM emissions standard for new heavy

duty engines of 0.01 grams per brake

- horsepower

- hour (g/bhp

- hr), to take full effect for diesels in the 2007 model year. Also includes standards for NOx and non

- methane hydrocarbons (NMHC) of 0.20 g/bhp

- hr and 0.14 g/ bhp

- hr, respectively. These NOx and NMHC standards will be phased in together between 2007 and 2010 for diesel engines. Sulfur in diesel fuel must be lowered to enable modern pollution

- control technology to be effective on these trucks and buses. EPA will require a 97 percent reduction in the sulfur content of highway diesel fuel from its current level of 500 parts per million (lo w sulfur diesel, or LSD) to 15 parts per million (ultra

- low sulfur diesel, or ULSD).

• Tier 2 Tailpipe. US EPA‟s Tier 2 is a fleet averaging program, modeled after the California LEV II standards. Manufacturers can produce vehicles with emissions ranging from relatively dirty to zero, but the mix of vehicles a manufacturer sells each year must have average NOx emissions below a specified value.92

• Large Spark Ignition and Recreational Vehicle Rule. In this rule, US EPA sets emission standards for these cat egories of non

- road engines and vehicles.

• Non

- Road Diesel Rule. In this rule, US EPA implements a low

- sulfur fuel requirement that affects both future (Commercial Marine Vessels) CMV and locomotive emissions.

• Combustion Turbine MACT. US EPA issued th is rule; however, the projection

inventories do not include the NOx co

- benefit effects resulting from this rule. EPA estimates them to be small compared to the overall inventory.

• Industrial Boiler/Process Heater/RICE MACT. The Environmental Protection A gency (EPA) issued final rules to substantially reduce emissions of toxic air pollutants from industrial, commercial and institutional boilers, process heaters and from stationary reciprocating internal combustion engines (RICE). These rules reduce emissio ns of a number of toxic air pollutants, including hydrogen chloride, manganese, lead, arsenic and mercury by 2009. This rule also reduces emissions of sulfur dioxide and particulate matter in conjunction with the toxic air pollutant reductions. The applied Maximum Achievable Control Technology (MACT) control efficiencies were 4 percent for SO2 and 40 percent for PM10 and PM2.5. However, EPA‟s industrial boiler MACT rules were vacated on June 8, 2007. The emissions reductions that were modeled to account for the industrial boiler MACT were 1,343.5 tons/year of SO2, 879.4 tons/year of PM2.5, and 1,304.2 tons/year of PM10. These reductions are insignificantly small (0.69% for SO2, 0.39% for PM2.5, and 0.13% for PM10) compared to the statewide totals (193,665.5 tons/year SO2; 225,104.5 tons/year PM2.5; and 1,002,873.2 tons/year PM10) and should not impact the conclusions made in the SIP. If another VISTAS “best and final” modeling run is performed, it will remove control assumptions solely due to this MACT rule.

• VOC 2

- , 4

- , 7

- , and 10

- year MACT Standards. The point source MACTs and associated emission reductions were designed from Federal Register (FR) notices and discussions with EPA‟s Emission Standards Division (ESD) staff. We did not apply reductions for

MA CT standards with an initial compliance date of 2001 or earlier, assuming that the effects of these controls are already accounted for in the 2002 inventories supplied by the

States.

• Georgia Rule 391

- 3

- 1

- .02(2)(yy), (i.e. Emissions of Nitrogen Oxides fr om Major sources based on Section 182 of the Federal CAA Amendments of 1990, requires that every major source (i.e. source with potential to emit > 50 tons/yr) of NOx located in 13 county Atlanta non

- attainment area should apply reasonably available contro l technology (RACT) in controlling NOx emissions. Georgia EPD has required full compliance with NOx RACT limits since July 31, 1995; however, Georgia EPD has not taken these emission reductions into account in any inventory or modeling scenario.

• 1

- hr Oz one SIPs (Atlanta/Birmingham/Northern Kentucky). These SIPs have been implemented for attainment and maintenance of the 1

- hour ozone National Ambient Air Quality Standard (NAAQS). Reductions from these SIPs have been taken into account in the 2018 modeling runs.93

• Georgia Rule 391

- 3

- 1

- .02(2)(sss), Multipollutant Control for Electric Utility Steam Generating Units, was adopted in 2007. The effective date of the rule varies for various EGU units but will start being effective from December 31, 2008, and required controls for all affected units will be in place befo re June 1, 2015. When fully implemented, Rule (sss) will reduce SO2 emissions by about 90 percent, NOx emissions by approximately 85 percent and mercury emissions by approximately 79 percent.

7.2.2 Additional State Programs to Reduce Emissions

In addition to accounting for specific emission reductions due to ongoing air pollution programs as required under the RHR Section 308 (d)(3)(v)(A), states are also required to consider the air quality benefits of measures to mitigate the impacts of construction

acti vities [Section 308(d)(3)(v)(B)] and agricultural and forestry smoke management [Section 308(d)(3)(v) (E)].

7.2.3 Projected 2009 and 2018 Base G4 Emissions Inventories The Base G inventories for 2009 and 2018 account for post

- 2002 emission reductions from promulgated and proposed federal, state, local, and site

- specific control programs as of July 1, 2004. In general, emissions inventories were developed for 2009 and 2018 using current control information in Georgia and for growing the 2002 inventory using EGAS6, MOBILE6, and IPM for electric generating units (EGUs).

For EGUs, IPM results were adjusted based on State and local (S/L) agency knowledge of planned emission controls at specific EGUs, including controls required by Georgia‟s Rule (sss). These u

pdates for Base G4 are documented in the MACTEC emissions inventory report “Documentation of the 2002 Base Year and 2009 and 2018 Projection Year Emission Inventories for VISTAS” dated February 2007.

For non

- EGUs, we used recently updated growth and control data consistent with the data used in US EPA‟s CAIR analyses supplemented by State and local agency data and updated forecasts from the Department of Energy (DOE).

Area source controls were estimat ed using known state

- level, Stage I controls on gasoline dispensing facilities and open burning estimates, as well as controls used to project emissions for US EPA‟s Heavy Duty Diesel rulemaking and for the CAIR rulemaking.

Mobile source controls included local controls underlying the 2002 baseline inventory (vehicle emission inspection, Stage II vapor recovery, anti

- tampering, etc.) with changes based on specific State input. Non

- road control data and projections for 1996, 2010, 2015, and 2020 were obtain ed from the US EPA's Clean Air Interstate Rule (CAIR) Technical Support Document, and straight line projections were used to estimate 2009

and 2018 levels.

.... G eorgia SIP Narrative, Page 50 :94

Summary of Final Base G4 Emissions Inventories for 2009 and 2018

Table 7.2.3

- 1 is a summary of the 2009 Base G4 emission inventory. The complete inventory and discussion of the methodology is contained in Appendix C.

Table 7.2.3

- 2 is a summary of the 2018 Base G4 emission inventory. The complete inventory and discussion of the methodology is contained in Appendix C.

EPA Findings : EPA proposes to find that Georgia has adequately addressed this provision.95

I V. Conclusion EPA is proposing a limited approval of a revision to the Georgia SIP submitted by the

Sta te of Georgia on February 11, 2010, and supplemented on November 19, 2010, as meeting some of the applicable regional haze requirements as set forth in sections 169A

and 169B of the CAA and in 40 CFR 51.300

- 308, as described previously in this action.

In a separate action, EPA has proposed a limited disapproval of the Georgia regional haze SIP because of deficiencies in the State’s regional haze SIP submittal arising from the State’s reliance on CAIR to meet certain regional haze requirements. See 76 F R 82219 (December 30, 2011). EPA is not proposing to take action in this rulemaking on issues associated with Georgia’s reliance on CAIR in its regional haze SIP.