Regional Administra

o

U.S. EPA, Region 4 

61 Forsyth Street, S.W. 

Atlanta, Georgia 30303-3104 

Re: Georgia's Recommendations for S02 Nonattainment Areas Near the Lathrop & Augusta S02 

Monitor in Chatham County 

Dear Ms. McTeer Toney: 

On June 2, 2010, the U.S. Environmental Protection Agency (EPA) revised the primary national 

ambient air quality standards (NAAQS) for sulfur dioxide (S0

2) by establishing a new 1-hour 

standard at a level of 75 parts per billion (ppb). EPA is required to conduct an expedited round 

of S02 attainment status designations by July 2, 2016 as a result of the consent decree 

between the EPA and Sierra Club and the Natural Resources Defense Council. Based on this 

schedule, states are required to provide recommendations and supporting information to EPA 

for this round of designations by September 18, 2015. The expedited round of designations are 

categorized into two groups: (1) areas that have newly monitored violations and (2) areas that 

contain any stationary source, not announced for retirement, that emitted more than 16,000 tons 

of S02, or emitted more than 2,600 tons of S02 and had a emission rate greater than 0.45 

lbs/MMbtu in 2012. 

The Lathrop & Augusta S02 monitor (13-051-1002) currently has a 2012-2014 design value of 

78 ppb which is above the NAAQS level of 75 ppb. Therefore, the area surrounding this monitor 

has been identified for early designation. The Lathrop & Augusta S02 monitor is located in 

Savannah, GA (Chatham County). 

Previous air quality modeling and back trajectory analysis by Georgia EPD clearly showed that 

International Paper - Savannah Mill (IP-Savannah) was the only significant S02 source 

contributing to exceedances of the NAAQS. Therefore, IP-Savannah submitted a dispersion 

modeling report and related modeling files prepared by AECOM, Inc. to support this early 

designation. Georgia EPD has reviewed the modeling report and files to ensure that the 

dispersion modeling has been conducted in accordance with the final Data Requirements Rule 

(ORR) and Modeling Technical Assistance Document (TAD) using the most recently available 

information. Based on this review, Georgia EPD made some adjustments to the modeling files 

that were submitted to insure the most reliable results were used in the analysis. 

Based on the final modeling analysis, S02 emissions from IP-Savannah do not lead to any 

violations of the 1-hour S02 NAAQS. However, the modeling does indicate that S02 emissions 

from IP-Savannah can cause exceedances of the NAAQS. Since the Lathrop & Augusta S02 

monitor is currently violating the NAAQS and IP-Savannah is the only significant S02 source 

contributing to exceedances of the NAAQS, GA EPD recommends that the land parcel including 

the IP-Savannah main mill and the area surrounding the Lathrop & Augusta S02 monitor 

(Jasper Spring Park) be designated nonattainment. Specifically, GA EPD recommends the 

following nonattainment area: 
g

(13-051-1 002) is representative of maximum S02 impacts. In early 2015, IP-Savannah changed 

from burning coal in the power boiler to burning natural gas (resulting in a 50% decrease in so2 

emissions from IP-Savannah); therefore, it is very likely that this monitor will have a 2013-2015 

design value which is below the NAAQS level of 75 ppb. Thus far in 2015, the 1st high S02 

value is 58 ppb and the 4th high S02 value is 35 ppb. If the ggth percentile 1-hour S02 maximum 

daily S02 concentration at the Lathrop & Augusta monitor is at or below 66 ppb, the 2013-2015 

design value will not violate the NAAQS level of 75 ppb. In this case, Georgia EPD will early 

certify the so2 data at this monitor and immediately update our so2 designation 

recommendation from nonattainment to unclassifiable/attainment. 

Should you or your staff have any questions, please feel free to contact James Boylan at (404) 

363-7014. 

JHT:JB 

c: Lynorae Benjamin, EPA Region 4 

Karen Hays, Branch Chief, EPD Air Protection Branch 

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