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Technical Support Document for

Georgia Regional Haze SIP Submittal

January 2012

U.S. EPA – Region 4 Atlanta, GA
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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 Retrofit 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. Enforceability 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 in 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.
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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 state 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 scientific 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 regional haze 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 regional haze SIP to EPA within 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 to EPA by 

December 17, 2007, which is also specified at 40 CFR 51.308(b).

The RHR 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. The 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 Eastern Band of the Cherokee Indians, other 

Federally Recognized 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 Natural 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 RHR.
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Figure 1. Geographical Areas of Regional Planning Organizations 

 

 Figure 2. Class I Areas in the VISTAS Region 
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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 

supplemented 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 

remedy 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 program”). 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 

Georgia 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 regional haze 

requirements.
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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,

Okefenokee 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 responsible 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 planning 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 in 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, Florida
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EPA Findings: EPA proposes to find that Georgia has adequately addressed this 

provision. 
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III. Evaluation of Regional Haze Submittal

B. Reasonable Progress Goals Development 

B.1.Calculations of Baseline Visibility Conditions: ((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 impaired 

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 these 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 the most representative monitoring available for the 2000-2004 period 

in consultation with EPA.

State Regional Haze 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 

accordance 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 percent 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. IMPROVE 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.
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EPA Findings: EPA proposes to find that Georgia has adequately addressed this

provision. EPA proposes to concur with the use of the data substitution methodology for 

2001 and 2003 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 establishing baseline conditions for the Wolf Island Wilderness area because the site 

is sufficiently close to the Okefenokee Wilderness area to be a surrogate for 

measurements at Wolf Island.
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III. Evaluation of Regional Haze Submittal

B. Reasonable Progress Goals Development 

B.2. Calculations of Natural Visibility Conditions: ((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 

available 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 Regional Haze Submittal

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 90th 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 compounds, 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.

bext ≈ 2.2 x fS(RH) x [Small Sulfate] + 4.8 fL(RH) x [Large Sulfate]

+ 2.4 x fS(RH) x [Small Nitrate] + 5.1 fL(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 fSS(RH) x [Sea Salt]

+ 0.6 x [Course Mass]

+ Rayleigh Scattering (Site Specific)

+ 0.33 x [NO2(ppb)]
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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 light 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 used for small- and large-sized distributions of 

ammonium sulfate and ammonium nitrate and for sea salt. The elemental carbon (lightabsorbing carbon), fine soil, and coarse mass terms do not change between the original 

and new IMPROVE equation.

The VISTAS states 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 Cedar 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 days 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 is Cohutta 

Wilderness Area at greater than 30 dv on the 20 percent worst days.
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EPA Findings: EPA proposes to find that Georgia has appropriately addressed this 

provision and that the natural background conditions that were used in the reasonable 

progress assessment were developed in an acceptable manner. GA 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 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 estimating natural conditions (Georgia SIP, Appendix H.9a and H.9.b). 
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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 State, the State 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 need 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 period 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 glidepaths 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 steepest 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).
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15

Georgia 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 illustrate 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), Okefenokee 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 progress 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 controls 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 reductions 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 Island 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 achieved 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 percent 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 areas 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 is better than no change, or a 10 percent improvement (values lower 

than current conditions).
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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 projections 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.
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18
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EPA Findings: EPA proposes to find that Georgia has adequately addressed this 

provision. 
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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 technical 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 submittal:

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 uniform 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 SO2 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 Georgia sources, 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)
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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-eligible 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. Determination of RPGs based on the visibility improvement expected by 2018.

Georgia SIP Narrative, Pages 26-34:

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 selection 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, prognostic 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 emissions 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 model 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 to 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 modeling
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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 Modeling 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 modeling

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 United 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.

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. 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. 
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Figure 5.4.1-2. A more detailed view of the 12-km grid over the VISTAS region.

Emissions Controls Modeled (Georgia SIP Narrative, 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 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 States. CAIR achieves large 

reductions of SO2and/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 heavyduty 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 (low 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.

• 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.
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• 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 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 

MACT 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 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 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 Ozone 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.

• 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 before 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.

Sources and Pollutants relied on for LTS (Georgia SIP Narrative, Pages 61-65):

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. To
25

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 and 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 Carolina, 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 contributions from nonEGUs 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 benefits 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 domain 
26

are more important for the coastal Class I areas. These results 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 discussion in Appendix I).

Model Performance Evaluation (Georgia SIP Narrative, Pages 35-42): 

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, which 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 Appendix 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 platform, 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 the

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 charts 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 the 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 of 
27

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 provided 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 Modeling 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 proposes 

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 SO2 and 

NOX from EGUs. See 40 CFR 51.308(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, Georgia concluded that no additional controls 

beyond CAIR are reasonable for reasonable progress for SO2 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 

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. 

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 regional 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 remain 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 SO2 and NOx. See 40 CFR 51.308(e)(4). Because 

CAIR did not address 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.3d 1175 (D.C. Cir. 2008). 
28

EPA issued a new rule in 2011 to address the interstate transport of NOx and SO2 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 December 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 proposed 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. Circuit 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 the 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 CAIR 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 haze 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 conclusions are unlikely to be affected because the expected reductions due to 

the vacated rule were relatively small compared to the State’s total SO2, PM2.5, and 

coarse particulate matter (PM10) emissions in 2018 (i.e., 0.1 to 0.7 percent, depending on 

the pollutant, of the projected 2018 SO2, PM2.5, and PM10 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 

there 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”, EPA, 2001. http://www.epa.gov/ttn/scram/guidance_sip.htm.

3. 2002 Base Year Emission Inventory SIP Planning: 8-hr Ozone, 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 

States.
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 

minimum, 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) measures to mitigate the impacts of 

construction activities; (C) emissions 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 

including 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 projected 

changes 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 

Appendix 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 previously, 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: Determine 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 focus 
31

should be on electric 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 during 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 of 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 capped 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 2015...” (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 in 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 CAIR

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 

periodic 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 

period (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 

significantly 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: Determine 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 planned 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 onehalf percent 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 necessary 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 based 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 Best 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, the 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 requirements 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.) That emissions unit is Interstate Paper 

– Power Boiler F1.

Georgia SIP Narrative, Page 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

However, 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 1998 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.

Georgia‟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 

measures 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 find 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 requirement for a LTS sufficient to achieve the stateadopted 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. 
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 State 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, Pages 81-98:

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 selecting 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 provided 

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 were 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-perinverse 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 will 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 2012 
38

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 progress 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

Additional 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 were 

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 useful 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 annualizing 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 impairment 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 reduced 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 induct sorbent injection 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 additional 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 considered 
39

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 on 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 sorbent 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 provided 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 historically. 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 only 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 effectiveness. 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 emissions 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 

units 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 modeling 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 installed before 2013. All three of the scrubber options (wet FGD, adding 

spray towers to the existing scrubbers, and adding caustic to the existing venturis) result 
40

in 15,000 tons/year of solid waste. There were no significant energy impacts addressed 

by the company. 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 reasonably 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 impact 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 modeling, 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, the 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, respectively).

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 indications 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 amortization 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.

Georgia 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%,and 

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 that 
41

all three of these are re-circulating fluidized bed boilers with limestone injection 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 estimated 

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 two 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 units. 

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 around 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 statutory factors for all three 

units: wet FGD, coal switching, and coal washing. Wet FGD could not be installed until 
42

2016 because of required control device installations scheduled up until 2015 in Georgia 

Power‟s system. The company did not address the implementation 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 remaining 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/Mm-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., boiler) 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 Swanquarter). 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 initially 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 analyzed 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 implementation 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 remaining useful life of the units extended past 2018 and the control 

equipment amortization periods. The cost effectiveness of all the control operations were 
43

relatively high ($7131/ton and $118.5MM/Mm-1 for wet FGD, $4306/ton and 

$71.5MM/Mm-1 for coal switching, 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 MW. (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 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 1189 tpy by 2018. Georgia Power‟s projection 

represents a 76 percent reduction in heat input 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 emission 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 installed 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 Power 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 effectiveness 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 significant 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-volume 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 areas 
44

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

analysis reviewed 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 presented 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 consideration 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 these 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 the 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 the 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 tower 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 International Paper used an admittedly 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. However, 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 Savannah 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 option 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 for 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 developing 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 results 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 PB13 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 SO2 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 to 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 oxidation (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 FGD 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 withdrawal permit to easily handle the increased water use 

associated with wet FGD. All of the control options resulted in additional solid waste 
46

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 affected 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, 

and 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-effective. 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 affected 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 (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. 

Three facilities, due to resource limitations and/or uncertainty regarding future 

operations, requested limits 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.
47
48

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 reasonable progress controls as applicable for those nonCAIR EGU units emitting SO2. 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 reasonable 

progress. EPA also notes that the visibility improvements projected for the affected Class 

I areas are in excess of that needed to be on the glidepath for Cohutta, and are very close 

to the glidepaths for Wolf Island and Okefenokee. 
49

Georgia also adequately 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 SO2 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 stateadopted 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. 
50

III. Evaluation of Regional Haze Submittal

C. Long-Term Strategy 

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

enforceable emissions limitations and schedules for compliance for each newly adopted 

measure needed to achieve the reasonable progress goals. 

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 air 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.
51
52

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 sources 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, and 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 operations 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 impairment 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 environmental 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 in 
54

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 BART-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 VOCs 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 Power 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

Interstate 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 Other 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 not 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 BART 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 included 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 of 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 Branch 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 

Federally-enforceable limits and a Federally- enforceable condition that requires the 
56

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 modeling 

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 may 

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 Class 

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 and 

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 do 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.
57
58
59
60

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 affecting 

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, visibility 

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 will 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 archived 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 the State has adequately identified the BART-eligible sources 

and those 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 SO2 and NOx 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 the stateadopted 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 the CALPUFF2 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 regulations. 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. The current regulatory 

niche for the CALPUFF modeling 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 corresponding 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.htm
62

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 CALPUFF). 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 Modeling 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 State 

decided to require CALPUFF modeling to evaluate the BART requirements. 

The State required all BART-eligible sources to perform BART exemption modeling 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 reports 

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 

Modeling in CALPUFF.” A new methodology was used by the VISTAS states 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 the BART assessment and to determine the change in 

visibility impacts. While 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 equation 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 was 
63

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. The 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. Considering results of the visibility 

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 impacted 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 51, Appendix W: Guideline on Air Quality Models.

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: Guidelines 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.vistassesarm.org/documents/BARTModelingProtocol_rev3.2_31Aug06.pdf.
64

6. March 16, 2006, EPA memorandum from Dennis Atkinson to Kay T. Prince on 

Dispersion Coefficients 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 regional 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 SO2 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 the State has appropriately identified the BART-eligible 

sources and those sources subject to BART controls. However, Georgia opted to have 

CAIR satisfy BART for SO2 and NOx 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, 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 action in this rulemaking on issues associated with Georgia’s reliance 

on CAIR in its regional haze SIP. 

.
66

III. Evaluation of Regional Haze Submittal

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 

pollution 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 

submit 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 detailed 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 source 

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 engineering 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 least 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. Relevant pollutants are only: sulfur dioxide (SO2), nitrogen 

oxides (NOx) and particulate matter (PM10).

....

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-condensable gases 

(NCGs). The current Title V application list the SO2 emission rate due solely to 

combusting NCGs as 53.8 pounds of SO2 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 emission rates 

appropriate for firing the Power Boiler at 100% capacity. The AP-42 emission rate was 

increased by the maximum SO2 emissions due to combustion of NCGs in the Power 

Boiler. These emissions, indicated in Table 7 and 8, were modeled for this alternative 

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 scenario 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 light 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. The 

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 visibility 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 visibility 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 visibility 
69

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 reductions 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 the 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 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 and 

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 do not contribute to visibility 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), the 

State appropriately documented the technical analysis to assess the need and 

implementation of BART controls as applicable for PM, SO2 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 five factors to determine the feasibility of controls that constituted 

BART. The NOx controls identified, except for their visibility impact, are sufficiently

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.

Regarding the BART determination for Georgia Power-Plant Bowen, Georgia opted to 

have CAIR satisfy BART for SO2 and NOx, as allowed under the Regional Haze 
70

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 stateadopted 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. 

.
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 Submittal

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 writing 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 Sources 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.

....

Georgia SIP Appendix M:

Emissions Limits Established Through BART Analysis 

Permit 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 TRScontaining 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 

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. 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 required 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 offgases (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, 2016. 

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, whichever 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 operation 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.2 
73

Limiting the 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 monitor 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 discharge 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 liquor 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 compliance 

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 emission 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 

Code 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 monitor 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 scrubbant 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 emission 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 CFR 

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 every 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 

report 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 keeping 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), any 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 black 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 as 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 Permittee 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 established 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 twelvemonth 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 the 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 title V permits with the added 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 title 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 approval 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 title V permits for the two reasonable progress 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 equipment 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 reasonable. 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 30, 2011) considering the installation of equipment necessary for compliance and 
77

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 action 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 longterm 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 (including monitoring and new source review (NSR)):

Georgia 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 longterm record available for tracking visibility improvement 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.

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) 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 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.

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 
79

sulfur dioxide, particulate 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 Federal 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 measurements 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

strategy, 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 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 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 consultation 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 demonstrate 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 attention 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.

Georgia 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 area. 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 will 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 which may be affected by 

emissions from within Georgia.

Georgia 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 the

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 portion 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 located 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 in 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 LTS 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 augments Georgia’s RAVI visibility provisions 

 

3 Georgia submitted its visibility SIP revisions addressing 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 to 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. Consistent with EPA’s 

monitoring regulations for RAVI and regional haze, Georgia will rely on the IMPROVE 

network for compliance purposes, 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 coordination 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. 

Other 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 the 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

Georgia SIP Narrative, Pages 114 – 117:

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 requirements. 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 reporting
83

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 visibility 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 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 longterm record available for tracking visibility improvement 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 Georgia 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) 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 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, particulate 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 speciated 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 visibility improvement in and 

near the Class I areas.

Figure 9.0-1. PM2.5 Monitoring Network in Georgia
85

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

strategy, 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 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 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 consultation 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 demonstrate 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 attention 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.

. 

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 State. The inventory must include emissions for a baseline 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 for 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 biogenic 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, agricultural 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 locomotives, 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 addition 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 modeling 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 whose 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 using 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 nonEGUs.

Electric Generating Units

The actual base year inventory for the EGU sources used 2002 continuous emissions 

monitoring (CEM) data reported 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 schedules. 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 (Appendix 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 through 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 air 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 the 
88

Integrated Planning Model (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 projection 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 regulations, 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 CAIR 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 uses 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 Sources

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, etc.). 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 contractor 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 capability 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 contractor 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 growth 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 

for 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 used. 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 

detailed 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 the 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 from 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 gridded 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 information, 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 sources, 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 projections 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 emissions 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 Georgia. The
91

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.

....

Georgia 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 States. 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 heavyduty 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 (low 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 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.

• 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 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 

MACT 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 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 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 Ozone 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 before 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 

activities [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 updates 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 estimated 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 obtained 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.

....

Georgia SIP Narrative, Page 50:
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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

IV. Conclusion

EPA is proposing a limited approval of a revision to the Georgia SIP submitted by the 

State 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 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.