# Georgia Department

of Natural Resources Environmental Protection Division Ms. Heather McTeer Toney Regional Administrator U.S. EPA, Region

4 61 Forsyth Street, S.W. Atlanta, Georgia 30303-3104

2 Martin Luther King, Jr
. Drive, Suite 1456, Atlanta, Georgia 30334 Judson

H . Turner, Director (404) 656-4713 

# SE P 1 7 

# 2 0 1 5 Re: Georgia's Recommendations

for S0 2 Nonattainment Areas Near the Lathrop

& Augusta S0 2 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 S0 2 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 S0 2 and had a emission rate greater than 0.45 lbs/MMbtu

in 2012

. The Lathrop

& Augusta S0 2 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 S0 2 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 S0 2 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, S0 2 emissions from IP-Savannah
do not lead to any violations
of the 1-hour S0 2 NAAQS. However, the modeling does indicate that S0 2 emissions from IP-Savannah can cause exceedances

of the NAAQS

. Since the Lathrop
& Augusta S0 2 monitor
is currently violating the NAAQS and IP-Savannah

is the only significant S0 2 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 S0 2 monitor (Jasper Spring Park) be designated nonattainment. Specifically, GA EPD recommends the following nonattainment area:• The area of land bounded by the following description: south of the Savannah River, and east of Allen Blvd

. and east of the western most part of Chip Mill Loop Road, and north of 1-516, and west of the Seaboard Air Line Railway track extended
to the Savannah River

; and • The area of land bounded by the following description: south of Augusta Avenue, and east of Old W. Lathrop Avenue, and north of Stratford Street

, and east of the US-8011

- 516 southbound entrance ramp

. Georgia EPD has demonstrated that the current location of the Lathrop
& Augusta S0 2 monitor (13-051-1 002) is representative

of maximum S0 2 impacts

. In early 2015, IP-Savannah changed from burning coal in the power boiler to burning natural gas (resulting

in a 50% decrease

in so 2 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 S0 2 value is 58 ppb and the 4th high S0 2 value is 35 ppb

. If the ggth percentile 1-hour S0 2 maximum daily S0 2 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 so 2 data at this monitor and immediately update our so 2 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 Attachments