# Revision to the Georgia S**tate**

**Implementation Plan for the Removal of**  **Georgia Rule 391**  **- 3**  **- 1**  **- .02(zz) Gasoline Dispensing**  **Facilities –**  **St age II**  **September 2**  **5 , 2014** 

**Prepared by:** 

# Georgia Department of Natural Res **our ces**  **Envir onmental Pr** **otection Division Air**  **Pr otection Branch** DRAFT 

### Revision **to the**  **Georgia St**  **ate Implementation**  **Plan for**  **the Removal**  **of Georgia**  **Rule 391 -** **3 -** **1 -** 

**.02(zz) Gasoline D ispensing**  **Facilities –**  **St age II** 

i 

### Executive Summary This document contains Georgia’ s request to revise the Georgia State Implementation Plan (SIP) to remove Georgia Rule 391 - 3 - 1 - .02(2)(zz), Gasoline Dispensing Facilities

– St age II otherwise known as Georgia Rule (zz) from the Georgia SIP . As a former 1990 Clean Air Act serious ozone nonattainment area, Georgia submitted its initial Stage II gasoline vapor recovery rule Georgia Rule ( zz) on November 13, 1992, to the U.S. Environmental Protection Agency ( EP

A) for initial approval. EP A approved Georgia Rule (zz) into the Georgia SIP on February 2, 1996 [ 61 FR 3819 ] . T his request to remove Georgia Rule (zz) is based on EP A Guidance Document EP

A -457/B - 12 - 001, August 7, 2012, “Guida nce on Removing S tage II Gasoline Va por Contr

ol Pr ograms fr om S tate Implementation Plans and Assessing Comparable Measur es” . Georgia EPD demonstrate s in this SIPrevision that removal of Georgia Rule 391 - 3 - 1 - .02(2)(zz), “Gasoline Dispensing Facilities

– St age II” from Georgia’ s SIPi s consistent with section 11 0 (l) of the CAA and will not interfere with the attainment of the NAAQS and with reasonable further progress toward that attainment. Removal of Georgia Rule 391 - 3 - 1 - .02(2)(zz), “Gasoline Dispensing Facilities

– Stage II” from Georgia’ s SIP will result in VOC emission reductions beginning in 2016.DRAFT 

### Revision **to the**  **Georgia St**  **ate Implementation**  **Plan for**  **the Removal**  **of Georgia**  **Rule 391 -** **3 -** **1 -** 

**.02(zz) Gasoline D ispensing**  **Facilities –**  **St age II** 

i **TA BLE OF** **CONTENTS Executive Summary**  **................................ ................................**  **................................ .........................**  **i** 

### 1.0 **Intr**

**oduction and Background ................................**  **................................ .....................**  **1 1.1**  **The Atlanta Ozone Nonattainment**  **Area ................................**  **................................ ...........**  **1 1.2**  **St age II V** 

**apor Recovery Rule ................................**  **................................ ............................**  **3 1.3**  **On -** **Board Refueling V apor Recovery Controls**  **................................ ................................**  **4 1.4**  **Wi despread Use**  **................................ ................................**  **................................ ...................**  **4** 

### 2.0 **Removal Request ................................**  **................................ ................................**  **.......... 6**  **2.1 Clean**  **Air Act Provisions**  **................................ ................................**  **................................ .....**  **6 2.2**  **11 0(** **l) ................................**  **................................ ................................**  **................................ .....**  **6 2.3**  **Removal Request ................................**  **................................ ................................**  **................. 6**  

### 3.0 **Emissions Calculations ................................**  **................................ ................................**  **9 3.1**  **Incremental Benefit ................................**  **................................ ................................**  **............. 9**  **3.2 Area**  **- Wi**  **de VOC Inventory Impacts ................................**  **................................ ................**  **12 3.3**  **Motor V**

**ehicle Emissions Comparisons ................................**  **................................ ...........**  **14** 

### 4.0 **Decommissioning Provisions ................................**  **................................ .....................**  **17 5.0**  **NO**

**x** 

### and **VO C Sensitivity**  **................................ ................................**  **........................... 19**  **5.1 Sensitivity of Ozon**  **e in Atlanta to NO**  **x and VOC Emissions**  **................................ .........**  **19** 5.1.1 Sensitivity Modeling NO x and VOC Emissions ................................ ................................ ............ 19 5.1.2 Modeling Scenarios ................................ ................................ ................................ ....................... 19 5.1.1 Modeling Results ................................ ................................ ................................ .......................... 19 

### 6.0 **Conclusion ................................**  **................................ ................................**  **................. 22**  **7.0 References**  **................................ ................................**  **................................ ..................**  **23**DRAFT 

### Revision **to the**  **Georgia St**  **ate Implementation**  **Plan for**  **the Removal**  **of Georgia**  **Rule 391 -** **3 -** **1 -** 

**.02(zz) Gasoline D ispensing**  **Facilities –**  **St age II** 

ii **LIST OF T** 

**ABLES Ta** **ble 3 -**  **1. Emissions Benefit of Maintaining S tage II VRS in**  **Atlanta ................................**  **........ 10**  **Ta ble 3**  **- 2. Compatibility Factor**  **................................ ................................**  **................................ ......**  **11 Ta** **ble 3 -**  **3. Incompatibility of V acuum**  **Assisted S tage II VRS and OR**  **VR ................................**  **.. 11**  **Ta ble 3**  **- 4. Incre**  **mental Benefit of S tage II VRS Controls**  **................................ .............................**  **12 Ta** **ble 3 -**  **5. The Atlanta**  **Ar ea Portion of National Gasoline Consumption**  **................................ ....**  **13 Ta** **ble 3 -**  **6. P ro** **jected Gasoline Consumption of the Atlanta Nonattainment**  **Area ......................**  **13 Ta** **ble 3 -**  **7. Impact on the Area Wide VOC Inventory**  **................................ ................................**  **.... 14**  **Ta ble 3**  **- 8.**  **Attainment Baseline V OC Emissions Inventory for Motor V**  **ehicles Compared to Modeled V** **OC Emissions Inventory with S tage II VRS.**  **................................ ........................**  **15 Ta** **ble 3 -**  **9. Attainment Baseline V** **OC Emissions Inventory for Motor V**  **ehicles Compared to Modeled V** **OC Emissions Inventory without S tage II VRS.**  **................................ ..................**  **15 Ta** **ble 3 -**  **10. V OC Emissions Inventory with S** **tage II VRS Compared to V OC Emissions**  **Inventory with only OR VR.**  **................................ ................................**  **................................ .....**  **16 Ta** **ble 5 -**  **1. Normalized NO x**  **and VOC Sensitivity at 10 Atlanta Ozone Monitors**  **...................... 20** DRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

**.02(zz) Gasoline D ispensing Facilities**  **– St**  **age II**

iii **LIST of**  **APPENDICES** Appendix A St age II VRS Incremental Benefit Analysis Appendix B Ozone Sensitivity in Atlanta in Relation to the SEMAP Sensitivity S tudy Appendix C SEMAPSensitivity S tudy Appendix D St age II Rule Package Appendix E Emissions and Air Quality Modeling for SEMAP -Final ReportDRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

**.02(zz) Gasoline D ispensing Facilities**  **– St**  **age II**

iv **List of Acronyms**  **Acronym Meanin**  **g Acronym**  **Meaning** AERR Air Emissions Reporting

Requirement NAA Nonattainment Area ARC Atlanta Regional

Commision NAAQS National Ambient Air Quality Standard CAA Clean Air Act NO x Nitrogen Oxides CAAA Clean Air Act Amendment O3 Ozone CB - IV Carbon Bond IV OR VR On - Board Refueling V apor Recovery CDR Conformity Determination

Report OTR Ozone Transport Region CFR Code of Federal

Regulations Ppt Parts Per T rillion CMAQ Community Multiscale Air

Quality RFP Reasonable Further Progress DV Design V

alue SIP St ate Implementation Plan EP A Environmental Protection Agency TPD To ns Per Day EPD Environmental Protection

Division UST Underground Storage Tank GDF Gasoline Dispensing

Facilities VI ST AS Vi sibility Improvement St ate and Tribal Association of the Southeast MOVES Motor Vehicle Emissions

Simulator VOC Vo latile Organic Compound MVEB Motor Vehicle Emissions

BudgetDRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

**.02(zz) Gasoline D ispensing Facilities**  **– St**  **age II**

Page 1 of 2 3 

## 1.0 **Introduction and Background**  This document contains the technical support for the Georgia Environmental Protection Division's (EPD’ s) request to modify the Georgia S tate Implementation Plan (S IP ) by removing Georgia Rule 391 - 3 - 1 - .02 (zz) (Gasoline Dispensing Faci lities

— St age II) . This plan will focus on the Atlanta Ozone Nonattainment Area since the primary pollutant emitted from gasoline dispens ing facilities is volatile organic compounds (VOCs) , a precursor along with nitrogen oxide (NO x) for ozone . VOC is not a precurso r for PM 2.5 . 

### 1.1 **The Atlanta Ozone Nonattainment Area** 1990 1 - Hour Ozone S tandard Pursuant to the Clean Air Act Amendments of 199 0 (CAAA), the Atlanta area was designated as nonattainment for the 1 -hour ozone National Ambient Air Quality S tandard (NAAQS) by U.S. EP A and was classified as a serious nonattainment area on November 6, 1991. The nonattainment area (NAA) was, at that time , geographically defined as the following 13 Georgia counties: Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry , Paulding, and Rockdale. Because Atlanta failed to attain the 1 -hour ozone NAAQS by November 15, 199 9, EP A issued a final rulemaking action in the September 26, 2003, Federal Register (68 FR 55469) determining that, by operation of law

, the Atlanta area was being reclassified as a "severe" ozone nonattainment area (NAA) effective January 1, 2004. In addition to having been required to submit state implementation plan(SIP) revisions meeting requirements for marginal, moderate, and serious ozone nonattainment areas, Georgia was required to submit plans meeting the additional requirements for areas classifi ed as severe, including Stage II VOC emission controls for gasoline dispensing facilities. As a result of EP A's implementation of the original federal Clean Air Act (CAA) of 1970, the Clean Air Act Amendments of 1977, and the Clean Air Act Amendments of 19 90, Georgia EPD completed, and EP A approved (67 FR 30574), SIP revisions to address the 1 -hour ozone Atlanta NAA. On February 1, 2005, EPD requested under the CAAA of 1990 that the Atlanta area be redesignated from nonattainment to attainment with respect to the 1 -hour ozone NAAQS. This request was based on three years, 2002 through 2004, of ambient monitoring data at all 1 1 ozone monitors in the Atlanta NAA

showing no violation of the 1 -hour ozone NAAQS; the implementation of permanent and enforceable reductions in ozone precursor emissions; compliance with all applicable requirements; and the Atlanta Maintenance Plan with projections demonstrating that the 2002 emission levels in this area will not be exceeded through at least the year 2015. EPD also petitioned EP A to make a determination that the Atlanta area was eligible for application of EP A's Clean Data Policy , based on the Atlanta area's attainment of the 1 -hour ozone NAAQS. EP A approved the plan and redesignation request effective June 14, 2005 (70 F R 34660). 1997 and 2008 8 - Hour Ozone S tandards Georgia EPD submitted its nonattainment area designation recommendations under the 8 -hour ozone standard to EP A on July 15, 2003. Georgia recommendedDRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

**.02(zz) Gasoline D ispensing Facilities**  **– St**  **age II**

Page 2 of 2 3 the following counties be designated nonattainment for the 8 -hour ozone standard: Barrow , Bartow , Carroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Henry

, Newton, Paulding, Rockdale, Spalding, and W alton. Georgia recommended that Pickens County be excluded from th e nonattainment designation even though the county is part of the Atlanta Metropolitan Statistical Area (MSA). Georgia based this exclusion, in part, on the fact that the county did not exceed any of the State's criteria for inclusion into a nonattainment area. Other parameters used in the analysis included the county's population and summer day NO x and VOC emissions. EP

A concurred with Georgia's recommendations in a letter dated December 3, 2003. On April 30, 2004, EP

A designated 20 metropolitan Atlanta counties as a "marginal" nonattainment area under the 1997 8 -hour ozone standard. The eight -hour ozone nonattainment area encompasses the 13 counties of the former 1 -hour ozone nonattainment area plus seven additional "ring" counties: Barrow , Bartow , Carrol l, Hall, Newton, Spalding, and Walton. W ith an attainment deadline of Ju ne15, 2007, marginal areas were required to attain the NAAQS by the 2006 ozone season. On October 16, 2007, the U.S. EP A published a rulemaking proposing its determination that the Atl anta Area did not attain the 8 -hour ozone NAAQS by June 15, 2007, the applicable attainment date for marginal nonattainment areas. The proposed finding was based on ambient air quality data from years 2004, 2005, and 2006. The U.S. EP A explained that, con sistent with Section 181(b)(2) of the CAA, when EP

A finalizes its determination that the Atlanta Area failed to attain, and that requirement becomes effective, the Atlanta Area would be reclassified by operation of law to the next highest classification or “moderate” nonattainment. The "moderate" area attainment date for the Atlanta, Georgia, area would then be "as expeditiously as practicable," but no later than June 15, 2010. The U.S. EP

A finalized this finding on March 6, 2008 [73FR 12013 - 12017]. The S tate of Georgia prepared and submitted an ozone attainment demonstration plan for the metro Atlanta 8 -hour Ozone Nonattainment Area to EP A Region 4 on October 21, 2009. The plan was based on a modeled attainment demonstration performed according to EP A guida nce. The modeling resulted in a single monitor in the Atlanta NAA exceeding the 8 -hour ozone NAAQS (design value of 86 ppb at the Confederate Avenue monitoring site). However, the weight of evidence analysis demonstrated in Section 6.2 of the October 2009 plan provides strong evidence that the Atlanta 8 - Hour Ozone NAA

would demonstrate attainment of the ozone NAAQS by 2009. The attainment demonstration with the weight of evidence analysis was shown to be effective since the unmonitored area analysis showed no modeling grid cell greater than 86 ppb. On June 9, 2010, Georgia EPD submitted a request for a one -year extension of the attainment date in accordance with 40 CFR 51.907. The Atlanta nonattainment area qualified for an extension because it had met the c ondition specified in 69 FR 23968 in which an area is eligible for the first of the 1 - year extensions if, for the attainment year, the area’ s fourth highest daily 8 -hour average is 0.084ppm or less. On November 30, 2010, EP A published a final rule extending the attainment date for the Atlanta nonattainment area to June 15, 201 1 [75FR 73969 - 73972]. On June 23, 201 1, EP

A promulgated its determination [76 FR 36873] that the metro Atlanta nonattainment area had attained the 1997 8 - Hour Ozone NAAQS. This determination was based upon quality- assured and certified ambient air monitoring data for the 2008 - 2010 period, which showed design values ranging from 0.068 ppm to 0.080 ppm. W ith the clean data determination, EP A suspended the requirements for the nonattainment area to submit an attainment demonstration, a reasonable further progress (RFP) plan, and contingency measures. The attainment demonstration was subsequently withdrawn on April 4, 2012. These requirements are suspended as long as the areaDRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

**.02(zz) Gasoline D ispensing Facilities**  **– St**  **age II**

Page 3 of 2 3 continues to attain the standard. This final rule became effective on July 25, 201 1. On December 15, 2 01 1, EP A proposed its determination [76 FR 77950] that the metro Atlanta nonattainment area attained the 1997 8 -hour ozone NAAQS by its applicable attainment date of June 15, 201 1.On April 4, 2012, EPD requested under CAAA of 1990 that the Atlanta area be redesignated from nonattainment to attainment with respect to the 1997 8 -hour ozone NAAQS based on ambient monitoring data from 2008 - 2010. This includes provisions showing no violation of the 1997 8 -hour ozone NAAQS, the implementation of permanent and enforceable reductions in ozone precursor emissions, compliance with all applicable requirements; and the Atlanta Maintenance Plan with projections demonstrating that 200 8 emissions levels in this area will not be exceeded through at least the year 2024. EPD also petitioned EP A to make a determination that the Atlanta area was eligible for application of EP A's Clean Data Policy

, based on the Atlanta area's attainment of th e 1997 8 -hour ozone NAAQS. EP A approved the plan and redesignation request and promulgated a proposed rule on February 4, 2013 (78 FR 7705), that was published in the federal register as a final rule on December 2, 2013 (78 FR 72040). On May 21, 2012, EP

A published a final rule in the federal register designating a new **15 -**  **county** Atlanta area marginal nonattainment for the 2008 8 -hour Ozone National Ambient Air Quality St andard (which lowered the NAAQS from 0.08 ppm to 0.075 ppm) . The 15 - county area include s the counties of Bartow

, Cherokee, Clayton, Cobb, Coweta, Dekalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry

, Newton, Paulding, and Rockdale. 

### 1.2 **Stage II Vapor Recovery Rule** Volatile	organic	compounds	(VOC)	are	emitted	from	the	refueling	of	gasolin e	vehicles	and trucks	at	gasoline	dispensing	facilities	(GDF).	Stage	II	Vapor	Recovery	Systems	(VRS)	refers	to processes	at	GDFs	when	the	gasoline	is	delivered	or	transferred	from	the	underground	storage tank	(UST)	to	the	vehicle	fuel	tank.	When	gasoline	i s	pumped	into	a	vehicle,	the	empty	space	in the	tank	has	gasoline	vapors	that	are	forced	out	of	the	tank.		With	Stage	II	VRS,	instead	of	being emitted	into	the	air,	those	vapors	are	directed	into	the	UST. There	are	two	types	of	Stage	II	VRS	controls.		The first	is	a	balance	type	of	Stage	II	system.		A balance	system	has	a	rubber	boot	around	the	gasoline	nozzle	spout	that	fits	snugly	up	to	a vehicle’s	fill	pipe.		When	the	gasoline	is	pumped	into	the	vehicle,	an	increase	in	pressure	in	the vacant	space	of	th e	vehicle	gas	tank,	combined	with	a	slight	decrease	in	pressure	in	the	UST from	emptying	fuel,	forces	the	gasoline	vapors	from	the	tank,	through	fill	pipe	into	the	UST. The	second	is	a	vacuum	assist	system	that	uses	a	vacuum	pump	on	the	vapor	return	line to help	draw	the	vapors	from	the	vehicle	fill	pipe	into	the	UST. Nearly	a ll	commercial	facilities	in Georgia	use	vacuum	assist	systems. The	Stage	II	Vapor	Recovery	Program	is	required	by	section	182(b)(3)	of	the	Clean	Air	Act (CAA).		State	and	local	agen cies	with	nonattainment	areas	classified	as	“moderate”	or	worse ozone	are	required	to	implement	Stage	II	VRS	at	gasoline	dispensing	facilities. Georgia	submitted	its	initial	Stage	II	gasoline	vapor	recovery	rule	Georgia	Rule	(zz)	on November	13,	1992,	to EPA	for	initial	approval	and	EPA	approved	Georgia	Rule	(zz)	into	the Georgia	SIP	on	February	2,	1996	[61	FR	3819].	Georgia	Rule	(zz)	Gasoline	Dispensing Facilities -- Stage	II	requires	all	gasoline	dispensing	facilities	located	in	the	counties	of	Cherokee,DRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

**.02(zz) Gasoline D ispensing Facilities**  **– St**  **age II**

Page 4 of 2 3 C layton,	Cobb,	Coweta,	DeKalb,	Douglas,	Fayette,	Forsyth,	Fulton,	Gwinnett,	Henry,	Paulding, and	Rockdale	to	be	equipped	with	and	operating	with	an	approved	Stage	II	VRS	to	recover	the displacement	vapors	from	the	vehicle’s	gasoline	storage	tank. 

### 1.3 **On -**  **Board Refueling Vapor Recovery Controls**  Onboard	Refueling	Vapor	Recovery	(ORVR)	is	a	vehicle	emission	control	system	that	captures fuel	vapors	from	the	vehicle	gas	tank	during	refueling	on	the	vehicle	itself.		With	ORVR,	the	gas tank	and	fill	pipe	are	designed so	that	when	refueling	the	vehicle,	fuel	vapors	in	the	gas	tank travel	to	an	activated	carbon	packed	canister,	which	adsorbs	the	vapor.			To	prevent	vapors from	escaping	through	the	fill	pipe	opening,	a	seal	in	the	fill	pipe	allows	liquid	gasoline	to	ente r, but	blocks	the	vapors	from	escaping.		When	the	engine	is	in	operation,	it	draws	the	gasoline vapors	into	the	engine	intake	manifold	to	be	used	as	fuel. There	is	some	incompatibility	between	ORVR	and	the	vacuum	assisted	Stage	II	VRS	where emissions	ca n	increase	rather	than	decrease.	Incompatibility	refers	to	excess	emissions resulting	from	Stage	II	VRS	and	ORVR	being	used	together	because	the	two	emission	controls together	result	in	extra	venting	of	VOCs	from	the	underground	storage	tank	into	the	ambie nt air.		Studies,	including	one	conducted	by	the	California	Air	Resources	Board	(CARB),	further indicate	that	incompatibility	between	the	vacuum	assist	version	of	the	Stage	II	VRS	(the	type used	in	Atlanta)	and	ORVR	degrade	the	benefit	of	keeping	the	Stage II	VRS 1 . On	April	16,	1994,	EPA	promulgated	regulations	[59	FR	16262]	under	Section	202(a)(6)	of	the CAA	requiring	the	phase - in	of	ORVR	controls	on	new	vehicles,	beginning	in	1998	for	passenger cars,	2001	for	light	duty	trucks,	and	2004	for	heavy	duty	tr ucks	under	14,000	GVWR	(Gross Vehicle	Weight	Rating). 

### 1.4 **Widespread Use** Section	202(a)(6) of	the	CAA also	allows	EPA	to	waive	certain	requirements	of	the	Stage	II vapor	recovery	program	when	the	EPA	Administrator	finds	that	ORVR	systems	are	in widespread	u se	in	the	vehicle	fleet: **“the	requirements	of	section	[182]a(b)(3)	of	this	title	(relating	to	stage	II	gasoline vapor	recovery)	for	areas	classified	under	section	[181]	of	this	title	as	moderate	for**  **ozone	shall	not	apply** after	promulgation	of	such	standards	and	the	Administrator	may, by	rule,	revise	or	waive	the	application	of	the	requirements	of	such	section	[182]a		(b)(3) of	this	title	for	areas	classified	under	section	[181]	of	this	title	as	Serious,	Severe,	or

1 CARB, Preliminary Draft Test Report, Total Hydrocarbon Emissions from Two Phase II Vacuum Assist Vapor Recovery Systems During Baseline Operations and Si mulated Refueling of O nboard Refueling Vapor Recovery (ORVR) Equipped Vehicles, Project Number ST - 98 - XX, June 1999.DRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

**.02(zz) Gasoline D ispensing Facilities**  **– St**  **age II**

Page 5 of 2 3 Extreme	for	ozone,	as	appropriate, **after	s uch	time	as	the	Administrator	determines**  **that	onboard	emissions	control	systems	required	under	this	paragraph	are	in widespread	use	throughout	the	motor	vehicle	fleet.”**  On	May	16,	2012,	EPA	published	in	the	federal	register	its	determination	that	the	us e	of	ORVR for	capturing	gasoline	vapor	when	gasoline - powered	vehicles	are	refueled	is	in	widespread	use throughout	the	highway	motor	vehicle	fleet	[77	FR	28772]. Section	202(a)(6)	of	the	CAA	gives	EPA	discretionary	authority	to	revise	or	waive	the	sectio n 182(b)(3)	Stage	II	requirement	by	rule	after	the	Administrator	determines	that	ORVR	is	in widespread	use	throughout	the	motor	vehicle	fleet.	EPA	also	has	broad	discretion	in	how	it defines	widespread	use	and	the	manner	in	which	any	final	determination	is implemented. Stage	II	VRS	control	efficiency	is	assumed	by	EPA	to	be	86	percent from	the	MOVES	2010b default	database .		The	percentage	of	gasoline	pumped	into	vehicles	from	GDFs	with	Stage	II control	is	estimated	by	EPA	to	be	90	percent as	per	EPA	guidan ce .		By	multiplying	these	two numbers,	the	expected	area - wide	control	efficiency	of	Stage	II	VRS	is	77.4	percent. Because	the	percentage	of	vehicles	without	ORVR	is	decreasing	on	a	yearly	basis	and	the amount	of	gasoline	pumped	to	these	vehicles	is	decrea sing	as	well,	EPA	could	predict	a	date	for ORVR	widespread	use.		EPA	considered	two	different	approaches.		They	first	looked	at	the assumed	98	percent	control	efficiency	of	ORVR [77FR	28775 and	EPA	guidance ] ,	and	then	used the	Motor	Vehicle	Emissions	Simul ator	(MOVES)	2010	motor	vehicle	emissions	model	to determine	the	number	of	vehicles	with	ORVR	projected	out	to	the	year	2020.		Overall	ORVR efficiency	was	determined	by	multiplying	the	fraction	of	gasoline	dispensed	into	vehicles	with ORVR	by	the	assumed	9 8	percent average	in - use control	efficiency.		Using	this	approach,	ORVR control	efficiency	reached	the	equivalent	Stage	II	VRS	control	efficiency	of	77.4	percent by	May 2013 [77Fr	28778] .		The	second	approach	used	observations	from	the	first	approach	to de termine	that	by	the	end	of	the	calendar	year	2012;	more	than	75	percent	of	gasoline	will	be dispensed	into	vehicles	with	ORVR,	resulting	in	an	overall	ORVR	control	efficiency	close	to	the Stage	II	VRS	control	efficiency	and	allowing	for	a	phased - in	approac h	to	ORVR.		Further information	on	EPA’s	approach	for	determining	widespread	use	can	be	found	in	EPA’s determination	[77	FR	28772]	and	its	proposal	published	in	the	federal	register	on	July	15, 2011	[76	FR	41731].DRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

**.02(zz) Gasoline D ispensing Facilities**  **– St**  **age II**

Page 6 of 2 3 

## 2.0 **Removal Request 2.1**  **Clean Air Act Provisions** EP A can only propose approval of a SIP revision seeking to discontinue an existing SIP - approved St age II control program if the SIP revision meets the following CAA provisions:

 The requirements of 1 10( l),  The requirements of Section 193 for any current nonattainment area that adopted a Stage II control program into its SIP prior to November 15, 1990, and  The requirements of Section 184(b)(2) which applies to any area of the northeast ozone transport region (OTR). The S tate of Georgia is not a part of the northeast OTR, as such Section 184(b)(2) does not apply . Additionally

, since the State of Georgia adopted its Stage II V apor Recovery Program into its SIP on February 2, 1996 [61 FR 3819], Section 193 also does not apply . Therefore, the remainder of this section includes a detailed description of the requirements of Section 1 10( l). 

### 2.2 **110( l)**  Section 1 10( l) of the CAA, governs EP A’ s ability to approve all SIP revisions. Specifically

, section 11 0( l) states: Each r evision to an implementation plan sub mitted by a S tate under this chapter shall be adopted by such S tate after r

easonable notice and public hearing. The Administrator shall not appr ove a revision of a plan if the r

evision would interfer

e with any applicable r

equir ement concerning attainment a nd r

easonable further pr

ogr ess (as defined in section 171 of this title), or any other applicable r

equir ement of this chapter . This SIPrevision uses the analysis provided by EP A’ s “Guidance on Removing Stage II Gasoline Vapor Control Programs from State Implementation Plans and Assessing Comparable Measures” (herein after called the guidance document) to demonstrate that the removal of Georgia’ s Rule (zz) will not interfere with attainment, reasonable further progress or any other requirement of the Clean Air Act. 

### 2.3 **Removal Request** With the submissions of this Plan Revision, Georgia EPD is requesting the removal of Georgia Rule 391 - 3 - 1 - .02(2)(zz), “Gasoline Dispensing Facilities

– Stage II” from Georgia’s SIP. This document was prepared using the analysi s provided by Section 3 of the EPA’s Guidance Document that the removal of Georgia Rule (zz) is consistent with section 110 (l) of the CAA.DRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

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Page 7 of 2 3 Specifically, Georgia EPD will present calculations comparing VOC emissions with Stage II and ORVR controls in plac e to VOC emissions with only ORVR in place. Using methods described in EPA’s Guidance Document, Georgia EPD will show that the emission control gain , identified in the guidance as the “increment” (or incremental benefits) , of Stage II VRS controls decrea ses as ORVR controls are phased- in. Once the incremental benefit has been evaluated, the increment is then used to show the impact on the area -wide VOC emission inventory and that removal of Stage II VRS controls will not interfere with attainment of the NAAQS or with further reasonable progress. In addition, to further sho w that removal of Stage II VRS controls will not contribute to interference under 110( l), EPD has separated the motor vehicle emissions budget and compared both the budget and the motor vehicle VOC emission inventory from the 2008 Atlanta Area Maintenance SIP with the projected VOC emissions from motor vehicle with and without Stage II VRS controls. The State of Georgia is a NO x limited area, which means that due to the over- abundance of biogenic VOC, the control of NO x is the limiting factor in ozone formation. T he sensitivity of ozone formation in the Atlanta area to reductions of NO x and VOC emissions are described in Section 5 of this document. This document will demonstrate that the short -term incremental increase in emissions during the phase - out period will not contribute to interference under 110( l). The result is a demonstration that the removal of Georgia Rule (zz) will not interfere with the attainment of the NAAQS or with reasonable further progress as defined by the CAA. In the 2008 8 -hour proposed ozone rule [78 FR 34184 , June 6, 2013 ] , EPA stated for marginal areas that, “When Congress amended the CAA in 1990, it anticipated that nonattainment areas with ozone concentrations close to the level of the NAAQS would likely come into attainment within 3 years of after designation without any additional local planning .” Therefore a s a p art of the sensitivity demonstration , Georgia EPD included a sensitivity study conducted using part of the **S** outh**E** astern **M** odeling, **A**nalysis, and **P** lanning (SEMAP) proj ect and information from a G eorgia Tech analysis of the sensitivity of ozone concentrations in the Eastern U.S. to reductions in emissions of both NO x and VOCs. EPA’s August 7, 2012, “ Guidance on Removing Stage II Gasoline Vapor Control Programs from State Implementation Plans and Assessing Comparable Measures ” states on page 4, “ In evaluating whether a given SIP revision would interfere with attainment or maintenance, as required by section 110( l), the EPA generally considers whether the SIP revision will allow for an increase in actual emissions into the air over what is allowed under the existing EPA - approved SIP. The EPA has not required that a state produce a new complete attainment demonstration for every SIP revision, provided that the status quo air quality is preserved. ” The removal of Rule (zz) will result in a relatively small increase in VOC emissions for a short period of time. The sensitivity study information in Section 4 will show that any increase in ozone levels are insignificant and short - lived and will show that the status quo air quality will be preserved. EPA’s August 7, 2012 guidance also states on page 5 states “[I] n areas where ozone formation is limited by the availability of NO x emissions, a small (and ever- declining) increase in VOC emissions may have little or no effect on future ozone levels. The EPA would consider any air quality analyses and supporting information provided by a state to show that a proposed SIP revision would notDRAFT 

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Page 8 of 2 3 interfere with attainment and maintenance of the NAAQS. ” This document shows that complete removal of Stage II will result in a slight increase in VOC in 2014, declining to a smaller increase in 2015, and resulting in ever- increasing emission reduction starting in 2016. The sensitivity study in Section 4 will demonstrate that this small, temporary increase in VOC emissions will have no observable effect on current or future ozone levels and will not interfere with attainment or maintenance of the NAAQS . Also, since VOC is not a precursor for particulate matter, there is no possibility that removal of the Georgia Rule (zz) will impact the ambient air quality standard for the PM 2.5 NAAQS in the Atlanta area or interfere with attainment or maintenance of the standard. EPA’s waiver of the statutory requirement for the implementation of Stage II Vapor Recovery, which is include d in their determination that the use of ORVR is in widespread use throughout the on - road motor vehicle fleet, allows that the removal of Georgia Rule (zz) will not interfere with any applicable requirement of the CAA.DRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

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## 3.0 **Emissions Calculations**  This section includes calculations as described in EP A’ s Guidance Document for the analysis of the incremental benefit of maintaining St age II VRS controls as OR VR technology is phased - in. T hese calculations show that regardless of the small yet temporary increase in emissions that could result from removing St age II VRS controls, the incremental benefit of keeping St age II VRS controls as OR VR controls are phased- in is an ever decreasing benefit, which eventually becomes a disbenefit. Additionally

, Section 11 0( l) requires that a SIPrevision does not interfere with any applicable requirement concerning attainment, and reasonable further progress (as defined in section 171). EP A state s in the Guidance Document that there are circumstanc es under which a planned phase - out of St age II would result in an area -wide VOC emissions increase, and yet may still be consistent with the conditions of Section 11 0( l). This occurs when the phase - out of St age II would result in a small increase in emiss ions that diminishes rapidly over time as OR VR is phased in, since the increase will not interfere with attainment or progress toward attainment, especially in areas that are NO x limited for the formation of ozone. B ecause of this, the impact on the area -wide VOC inventory has been calculated and evaluated to show that it is consistent with Section 1 10 ( l). The Atlanta 8 - Hour Ozone Maintenance Plan for the 1997 8 -hour Ozone NAAQS, submitted to EP A on October 10, 2009, lists 2008 as its attainment or basel ine year. F or the purposes of consistency and to show that removal of the St age II VRS controls will not interfere with attainment or progress toward attainment, 2008 has been chosen as the baseline year for the purpose of the comparative analysis detaile d in this section, while all analysis of the benefit of S tage II will be calculated for the current year to the future when a disbenefit is demonstrated. In addition, 2008 is also a year for which states are required to submit an inventory required by EP A ’sAir Emissions Reporting Requirement (AERR), which results in a comprehensive statewide inventory. The calculations are used to demonstrate emissions changes beginning in 2014, however, decommissioning cannot begin until May 1, 2014 and must be complete d by April 30, 2016. There is no schedule for station decommissioning, only the requirement that the stations have the decommissioning completed by the deadline . T he emission increase demonstrated for 2014 is larger than that which will actually occur be cause the calculations assume that all decommissioning activities occur in 2014 . 

### 3.1 **Incremental Benefit** In EP A’ s Guidance Document, the overall St age II

– OR VR increment is defined as the annual area wide emission control gain from St age II installations at GDFs as OR VR technology phases in. The increment is quantified as the fractional reduction of VOC from refueling in a given nonattainment area over the ozone season for a given year for the 13 counties in the Atlanta area with St age II controls. B ecaus e there are only a small number of non - OR VR equipped vehicles and that number continues to grow smaller , there is only a small level of future emissions reductions achievable from St age II VRS controls, resulting in an eventual net increase in emissions of VOC over time when taking all factors into account. A more detailed analysis of the calculation of the incremental benefit can be found in Appendix A. Tocalculate the increment, the emissions benefit of maintaining S tage II VRS controls is adjusted by taking into account the incompatibility of vacuum assisted S tage II VRS and OR VR. Because of this incompatibility

, as more vehicles become equipped with OR VR, there is a benefit loss fromDRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

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Page 10 of 2 3 maintaining St age II VRS controls due to incompatibility of the two control options . All calculations used in this analysis can be found in detail in Appendix A. 

### Table 3 **- 1. Emissions Benefit of Maintaining Stage II VRS in Atlanta** 

Note: All emissions values in this chart refer solely to on - road mobile source emissions. Table 3 - 1 shows the maximum potential emissions benefit of Stage II VRS controls from 2012 to 2017 in the 13 - county Atlanta area. These maximum potential emissions benefits were calculated by first removing the portion of OR VR equipped vehicles from consideration, so that incompatibility is not an issue in the calculation and since there is no derived benefit of St age II with OR VR equipped vehicles. T he fraction of gasoline dispensed to vehicles with only St age II VRS (1 - QOR VRi) was multiplied by both the fraction of gasoline pumped to these vehicles from facilities equipped with St age II VRS and the control ef ficiency of the St age II VRS controls. F urther information can be found in Appendix A. As indicated above, the incremental benefit is based on the emissions benefit of the Stage II VRS controls, but it is adjusted based on the incompatibility of vacuum assist ed S tage II VRS and OR VR. Inorder to calculate this incompatibility , the increase in the UST vent pipe emissions beyond what is considered normal emission losses must be determined. T his increase is called the compatibility factor Ye ar (i) Fraction of Gasoline Covered by Stage II VRS (Q SII) Fraction of Gasoline

Disp ensed ToOR

VR Vehicles (Q OR VRi) Control Ef

ficiency Of S tage II VRS (NiuSII) Emissions Benefit of

St age II VRS Controls (fractional reduction) 2012 0.9 0.777 0.62 0.124 2013 0.9 0.810 0.62 0.106 2014 0.9 0.840 0.62 0.089 2015 0.9 0.865 0.62 0.075 2016 0.9 0.886 0.62 0.064 2017 0.9 0.903 0.62 0.054DRAFT 

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Page 11 of 2 3 

### Table 3 **- 2. Compa** **tibility Factor**

Note: All emissions values in this chart refer solely to on - road mobile source emissions. Table 3 - 2 shows the criteria used to determine the compatibility factor for each year under consideration. EPA’ s Guidance Document states that the compatibility factor is a function of the fraction of gasoline dispensed to ORVR vehicles, but that using the vehicle miles traveled by ORVR equipped vehicles is an acceptable substitute. T he vehicle miles used in this calculation are multiplied by a constant term provided for the States by EPA in the Guidance Document. T he resulting compatibility factor is then used to calculate the incompatibility of vacuum assist Stage II VRS with ORVR. More detailed calculations can be found in Appendix A. 

### Table 3 **- 3. Incompatibility of Vacuum Assisted Stage II VRS and ORVR** 

Note: All emissions values in this chart refer solely to on - road mobile source emissions. Ye ar (i) Constant Fraction of Annual Area -Wi de Vehicle Miles Traveled by OR

VR Equipped V

ehicles (VMT OR

VRi) Compatibility Factor (CF i)

2012 0.07645 0.800 0.061 2013 0.07645 0.834 0.064 2014 0.07645 0.863 0.066 2015 0.07645 0.888 0.068 2 016 0.07645 0.909 0.069 2017 0.07645 0.925 0.071

Ye ar (i) Fraction of Gasoline Dispensed Through V

acuum Assist S tage II VRS (Q SIIva) Compatibility Factor (CF i) Incompatibility

2012 0.95 0.061 0.058 2013 0.95 0.064 0.061 2014 0.95 0.066 0.063 2015 0.95 0.068 0.064 2016 0.95 0.069 0.066 2017 0.95 0.071 0.067DRAFT 

### Revision **to the**  **Georgia St**  **ate Im**  **plementation Plan**  **for the**  **Removal of**  **Georgia Rule 391**  **- 3** **- 1**  **-**

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Page 12 of 2 3 As Table 3 - 3 shows the fraction of gasoline dispensed through vacuum assist St age II VRS as 0.95. This number is an assigned value in EP A’ s Guidance Document that was based on the percentage of facilities in the 13 - county Atlanta area with the vacuum assist controls in use. T he compatibility factor is multiplied by this fraction in order to calculate the incompatibility between St age II VRS controls and OR

VR controls. 

### Table 3 **- 4. Incremental Benefit of Stage II VRS Controls** 

N ote: All emissions values in this char t refer solely to on - road mobile source emissions. Positive values indicate a benefit while negative values indicate a benefit loss. As shown in Table 3 -4, by adjusting the emissions benefit of Stage II VRS controls to take into account the incompatibil ity of OR VR controls and vacuum assisted St age II VRS controls, the increment continues to decrease for Stage II VRS controls as OR VR controls are phased - in and decreases until 2016, at which point there is a benefit loss from maintaining St age II VRS controls. For more information on the calculation of incompatibility , see Appendix A. 

### 3.2 **Area -** **Wide VOC Inventory Im** **pacts** Once the increment of maintaining St age II VRS controls has been calculated, it is necessary to evaluate the impact on the area -wide VOC emission inventory. This is determined by multiplying projected future gasoline consumption for the Atlanta area with an emission factor for refueling losses and adjusting for the increment. Ye ar Emissions Benefit of Stage II VRS Controls (fractional reduction) Incompatibility of OR VR and Vacuum Assisted Stage II VRS Controls Increment

(fraction) 2012 0.124 0.058 0.066 2013 0.106 0.061 0.045 2014 0.089 0.063 0.027 2015 0.075 0.064 0.01 1 2016 0.064 0.066 - 0.002 2017 0.054 0.067 - 0.013DRAFT 

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Page 13 of 2 3 

### Table 3 **- 5. The Atlanta Area Portion of National Gasoline Con**  **sumption**

N ote: All emissions values in this chart refer solely to on - road mobile source emissions. Table 3 - 5 shows the Atlanta area’ s consumption of gasoline based on the year 2010 according to the FHW A Highway St atistics - monthly gasoline reported by states. More detailed explanations and calculations can be found in Appendix A. 

### Table 3 **- 6. Projected Gasoline Consumption of the Atlanta Nonattainment Area** 

Note: All emissions values in this chart refer solely to on - road mobile source emissions. By using a projected ratio for gasoline consumption from the Department of Energy’ s E IA Annual Outlook (AEO)

– Liquid Fuels Supply and Disposition Reference case table, the gasoline consumption of the 13 - county Atlanta area was projected for 2012 through 2017 as shown in Ta ble 3 - 6. More detailed calculations can be found in Appendix A . Ye ar Atlanta Area’ s Portion

of To tal National Gasoline Consumption To tal National Gasoline Consumption

– May Through September (gallons) Atlanta Area

Consumption

– May Through September 2010 (gallons) 2010 0.01677214 59,588,199,000 999,421,616

Ye ar Atlanta Area

Consumption

– May Through September 2010 (gallons) Projected Ratio

for Gasoline Consumptio n Growth Projected Gasoline Consumption of the

13 - county Atlanta Nonattainment Area

(gallons/season) 2010 999,421,616 N/A N/A 2012 999,421,616 1.0343 1,033,701,777 2013 999,421,616 1.0399 1,039,298,538 2014 999,421,616 1.0410 1,040,397,902 2015 999,42 1,616 1.0421 1,041,497,266 2016 999,421,616 1.0443 1,043,695,994 2017 999,421,616 1.0377 1,037,099,81 1DRAFT 

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Page 14 of 2 3 

### Table 3 **- 7. Impact on the Area Wide VOC Inventory** 

Note: All emissions values in this chart refer solely to on - road mobile source emissions. Positive values indicate a benefit while negative values indicate a benefit loss . Table 3 - 7 shows the tons of reduction in VOC emissi ons for each ozone season beginning in 2012 if St age II VRS is maintained as OR VR is phased in. As OR

VR is phased in, beginning in 2016, there is an increase in emissions from the incompatibility of the two control systems. 

### 3.3 **Motor Vehicle Emissions Compa risons**  An additional method of showing the impact of maintaining St age II VRS, as OR VR is phased in, is to compare motor vehicle emissions with and without Stage II in place to the motor vehicle emissions budget (MVEB). Motor vehicle emissions budget values for 2006 with St age II in place and projected emissions for 2016 with S tage II VRS in place were taken from the Atlanta Regional Commission’ s (ARC) V olume II: Plan 2040 Conformity Determination Report (CDR)’ s transportation conformity demonstration. VOC emissions with St age II VRS in place for the years 2008, 2010 and 2013 were modeled using MOVES, after which, the emissions for interim years were calculated using interpolation. The motor vehicle VOC emissions with and without St age II VRS controls in place were then compared to both the motor vehicle VOC emissions budget and the motor vehicle VOC emissions in the 2008 Maintenance SIP . Ye ar Increment Uncontrolled Displacement (non - OR VR) Refueling Emission Factor (grams/gallon) Projected Gasoline

Consumption of the 13 - county Atlanta Nonattainment Area (gallons/ season) Area

–Wi de VOC Inventory Reduction (tons per season) 2012 0.066 4.6 1,033,701,777 347.68 2013 0.045 4.6 1,039,298,538 239.51 2014 0.027 4.6 1,040,397,902 140.34 2015 0.01 1 4.6 1,041,497,266 57.23 2016 - 0.002 4.6 1,043,695,994 - 12.74 2017 - 0 .013 4.6 1,037,099,81 1 - 68.65DRAFT 

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Page 15 of 2 3 

### Table 3 **- 8**  **. Attainment Baseline VOC Emissions Inventory for Motor Vehicles Compared to Modeled VOC Emissions Inve**  **ntory with Stage II VRS.**

Note: All emissions values in this chart refer solely to on - road mobile source emissions Table 3 - 8 indicates that with St age II VRS controls, the VOC emissions decrease between 2008 and 2016, and remain less than both the MVEB and the motor vehicle baseline emissions in the 2008 maintenance plan . 

### Table 3 **- 9**  **. Attainment Baseline VOC Emissi ons Inventory for Motor Vehicles**  **Compared to Modeled VOC Emissions Inventory without Stage II VRS.**

Note: All emissions values in this chart refer solely to on - road mobile source emissions The analysis further continues by similarly evaluating the motor vehicle VOC emissions without emissions reductions attributable to Stage II VRS controls. As Ta ble 3 - 3 indicates, a decrease in overall area -wide VOC emissions also occurs with only OR VR controls in place with VOC emissions remaining less than both the MVEB and the motor vehicle baseline emissions in the 2008 Ye ar Motor Vehicle

Emissions Budget (tons per day) 2008 Maintenance Plan

Motor Vehicle Baseline VOC Emissions Inventory (tons per day) Motor Vehicle VOC Emissions Modeled in MOVES 2010 Wi th St age II VRS Controls In Place (tons per day) 2008 171.83 165.53 165.53 2012 171.83 165.53 127.33 2013 171.83 165.53 11 7.78 2014 171.83 165.53 108.23 2015 171.83 165.53 98.68 2016 171.83 165.53 89.13

Ye ar Motor Vehicle

Emissions Budget (tons per year) VOC Baseline

Emissions 2008 (tons per year) VOC Emission W ithout Stage II (tons per day) 2008 171.83 165.53 N/A 2012 171.83 165.53 N/A 2013 171.83 165.53 N/A 2014 171.83 165.53 109.15 2015 171.83 165.53 99.05 2016 171.83 165.53 89.05DRAFT 

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Page 16 of 2 3 maintenance plan. See Appendix A further details . 

### Table 3 **- 10**  **. VOC Emissions Inventory with Stage II VRS Compared to VOC**

**Emissions Inventory with only ORVR.**

Note: All emissions values in this chart refer solely to on - road mobile source emissions. By comparing VOC emissions with continued implementation of Stage II VRS and VOC Emissions with only OR

VR controls in place to the 2008 baseline emissions inventory as shown in Table 3 - 10 above, the p hase - out of S tage II would result in a small increas e in emissions beginning in 2014 that diminishes rapidly over time as OR VR is phased in, but that increase will not interfere with attainment or progress toward attainment. By 2016, the removal of Stage II VRS requirements will result in a greater decrease in motor vehicle VOC emissions than the decrease attributable to maintaining Stage II VRS controls . Y ear VOC Baseline

Emissions 2008 (tons per year) VOC Emission W ith Wi th Stage II VRS Controls In Place (tons per day) VOC Emissions with

St age II VRS Removed (only OR VR) (tons per day) **VO C Emission**  **Difference Between S** **tage II VRS In Place and**  **Removed Incremental**  **Benefit (tons per day)**  2008 165.53 165.53 N/A **N/A** 2012 165.53 127.33 N/A N/A 2013 165.53 11 7.78 N/A N/A 2014 165.53 108.23 109.15 **+0.92** 2015 165.53 98.68 99.05 **+0.37** 2016 165.53 89.13 89.05 **- 0.085** DRAFT 

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Page 17 of 2 3 

## 4.0 **Decommissioning Provisions** Included in the removal of the rule is the process of decommissioning the Stage II VRS c ontrols in such a way that it is done in a safe and environmentally appropriate manner. Not only will the owner/operator follow the decommi ssioning process as amended in Georgia Rule (zz) , he will also perform testing and maintain record s for two years after decommissioning of the St age II VRS Controls . All end points of tubes and piping will be disconnected or removed, and sealed. In particular , if the vapor recovery piping can be accessed easily at the tank, then it must be sealed to be vapor tight. If the system has a vapor pump for each fueling position, then each vapor pump is to be disabled or removed. If the system has a centrally located vacuum pump, then that mechanism is to be removed and sealed. All liquid- collection points will be emptied of liquid and any tubes leading to submersible pumps will be disconnected at the pump and sealed properly so that they are vapor tight. As an alternative, the tubes can be removed as long as the openings in the liquid- collection point are sealed to be vapor tight. A plug must be installed in the vacuum pump to seal the vacuum port and the liquidc ollection point cap must create a vapor tight seal when placed on the liquid- collection point. Once the station has followed the necessary steps for removing the S tage II VRS equipment it will then be necessary for the station to perform a pressure decay test and tie -tank test to insure that the system is vapor tight and that the storage tanks are still functional. St ations can begin decommissi oning May 1, 2014 . U.S. EP A released a proposed rule on July 15, 201 1 that would establish widespread use of onboard refueling vapor recovery (OR VR) as of June 30, 2013 and would allow areas requiring Stage II equipment at gasoline dispensing facilities to be decommissioned. A final rule was issued by EP A on May 16, 2012 that determined widespread use of OR VR as the ef

fective date of the rulemaking, which was May 16, 2012. As a result of the proposed and final rule, Georgia EPD began receiving a number of requests from new gasoline dispensing facilities and those undergoing major modification to have the S tage II requirements waived or be exempt from the rule. The first of the letters were received in late 201 1 and EPD continued to receive requests until the S tage II rule was amended. EPD took no action on these letters until the rule was amended. Most of the facilities that had requested the waiver/exemptions did not install the equipment. The costs to install Stage II are in the tens of thousands o f dollars and would cost between $1,500 and $2,500 to remove. Most of the facilities would have had Stage II installed for 3 years or less before they would need to remove it. During these two years, the Stage II systems would provide very little to no emission reductions, but the costs would average well over $25,000 per facility for the installation and removal of the Stage II systems. Exempting new facilities and those undergoing major modification since December 31, 201 1 covered most of the facilitie s that had requested the waiver/exemption. There is no schedule for station decommissioning, only the requirement that all stations must have decommissioning completed by April 30, 2016 . Emissions calculations performed in Section 3.0 of this document a ssume all decommissioning occurs in 2014. Although the S tage II rule allows forDRAFT 

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Page 18 of 2 3 decommissioning to begin May 1, 2014, many facilities will continue to operate, maintain, and test their S tage II systems until early 2016. EPD will continue to implement the St age II rule through 2016 . These decommissioning procedures follow PEI/RP300 - 09 recommended practices related to capping and sealing vapor recovery underground piping and vapor recovery dispenser piping , and the associated tests in recommended practices. EPD chose to deviate from the PEI recommended practices related to the hanging hardware on dispensers. EPD has chosen not to require that the hanging hardware be replaced since it will not result in any emission losses or present a safety hazard. The c ost of replacing the hanging hardware can easily double or triple the cost of decommissioning a S tage II system if required. Georgia Rule (zz) has been amended to include these requirements pertaining to the decommissioning of the S tage II VRS equipment and can be found in Appendix D.DRAFT 

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Page 19 of 2 3 

## 5.0 **NO x**  

## and VOC **Sensitivity** A s stated in Section 1 .0 above, 11 0(l) of the CAA requires that a SIPrevision not interfere with any applicable requirement concerning attainment, and reasonable further progress (as defined in section 171 and 182 of the CAA). EP A has recently stated in its “ Guidance on Removing S tage II Gasoline Va por Contr

ol Pr ograms fr om S tate Implementation Plans and Assessing Comparable Measur es ” that the removal of a VOC control c ould result in an area -wide V OC emissions increase, and yet may still be consistent with the conditions of Section 110(l) , is “in areas where ozone formation is limited by the availability of NO x emissions .” In this situation, “a small (and ever- declining) increase in VOC emissions may have little or no ef fect on future ozone levels .” 

### 5.1 **Sensitivity of Ozone in Atlanta to NO x**  

### and VOC Emissions Control of NO x and VOC are generally considered the most important component s of an ozone control strategy

, and NO x and VOC make up the largest controllable contribution to ambient ozone formation . However, the metro Atlanta nonattainment area has shown a greater sensitivity of elevated ozone to NO x controls rather than VOC controls. This is due to the biogenic nature of VOC emissions in Georgia. Therefore, implemented control measures have focused on the control of NO x emissions. T he Atlanta nonattainment area is NO x limited in such a way that changes in VOC emissions have little effect on ozone formation. **5.1.1 Sensitivity Modeling NO**  **x and VOC Emiss**  **ions** As part of the **S** outh**E** astern **M** odeling, **A**nalysis, and **P** lanning (SEMAP) project, Georgia Tech performed an analysis of the sensitivity of ozone concentrations in the Eastern U.S. to reductions in emissions of both nitrogen oxides (NO x) and volatile organic compounds (VOCs). This analysis was based off of the 2007 and 2018 SEMAP modeling which used CMAQ version 5.01 with updates to the vertical mixing coefficients and land-water interface. The entire "ozone season" was modeled (May 1

– September 30) using a 12 - km modeling grid that covered the Eastern U.S. Details of the modeling platform set -up can be found in Appendix E. **5.1.2 Modeling Scenarios**  Sensitivities were modeled relative to 2018 emissions to evaluate the impact of NO x and VOC reductions on daily 8 -hour maximum ozone concentrations. Each emission sensitivity run reduced the 2018 anthropogenic NO x or VOC emissions (point, area, mobile, NONROAD, marine/aircraft/rail) within a specific geographic region by 30%. Georgia EPD, performed a sensitivity study with the information provided by the SEMAP modeling project and the Georgia Tech analysis to examine the normalized sensitivities of NO x and VOC emissions on 8 -hour daily maximum ozone concentrations (part per trillion ozone/ton per day, ppt/TPD) at 10 ozone monitors in Atlanta. EPD used an 85 parts per billion (ppb) threshold to address the 1997 ozone NAAQS and a 75 parts per billion (ppb) threshold to address the 2008 ozone NAAQS. For further details on the modeling assumptions and approach use d to calculate the normalized sensitivities of NO x and VOC, please see Appendix B . **5.1.1 Modeling Results** DRAFT 

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### Table 5 **- 1.**  **Normalized NO x**  

### and VOC Sensitivity at 10 Atlanta Ozone Monitors

AIRS ID Site Name NO x w/ 75 ppb threshold (ppt/TPD) NOx w/ 8 5 ppb

thresh old (ppb /TPD) VOC w/ 75 ppb threshold (ppb /TPD) VOC w/ 8 5 ppb

threshold (ppb /TPD)

13 - 067 - 0003 Kennesaw - 0.0 74 27 - 0.07972 - 0.004 53 - 0.004 85 13 - 077 - 0002 Newnan - 0.0 8 090 - 0.0 9 576 - 0.001 76 - 0.00 156 13 - 085 - 0001 Dawsonville - 0.0 62 19 - 0.0 62 19 - 0. 00 702 - 0. 000 70 13 - 089 - 0002 South DeKalb - 0.0 77 14 - 0.0 87 44 - 0.00 5 80 - 0.00 685 13 - 097 - 0004 Douglasville - 0.0 79 71 - 0.08374 - 0.00 416 - 0.00 72 3 13 - 121 - 0055 Confederate Ave. - 0.0 61 17 - 0.06693 - 0.00 766 **- 0.0**  **105 8**  13 - 135 - 0002 Gwinnett - 0.0 76 25 - 0.0 90 08 - 0.00 26 4 - 0.00 2 93 13 - 151 - 0002 McDonough - 0.08692 - 0.09052 - 0.00 335 - 0.00 462 13 - 223 - 0003 Dallas /Yorkville - 0.0 69 25 - 0.0 69 25 - 0.00 115 - 0.00115 13 - 247 - 0001 Conyers - 0.08975 **- 0.**  **100 19**  - 0.00 312 - 0.00 321 These results show that NO x emission reductions are generally 10 - 20 times more effective than VOC emission reductions at reducing ozone concentrations . In order to look at the impact of removing NO x or VOC controls on the 1997 and 2008 ozone NAAQS, the most conservative approach would be to use the highest normalized NO x and VOC sensitivity value across the 10 Atlanta ozone monitors. The highest normalized NO x sensitivity is 0.10019 ppb/TPD at the Conyers ( 13 - 247 - 0001) Site and the highest normalized VOC sensitivity is 0.01058 ppb/TPD at the Confederate Avenue, ( 13 - 121 - 0055 ) Site. (Note that both of these highest sensitivities are based on an 85 ppb threshold used to address the 1997 ozone NAAQS. Use of sensitivities based on the 2008 ozone NAAQS threshold of 75 ppb would result in lower normalized sensitivities and thus less of an impact on ambient ozone levels.) Based on the most conservative approach, f or every ton per day of VOC increased in the Atlanta area there is a corresponding increase of 0.0 1058ppb in ozone at the monitor ; while for every ton per day of NO x increased in the Atlanta area there is a corresponding increase of 0.10019ppb at the monitor. The 2014 increase in VOC emission due to the removal of Stage II of 0.92 tons per day. Applying the sensitivity to VOC to 0.92 tons per day will result in a corresponding increase in the concentration of ozone in the Atlanta area of 0.00973 ppb, a very insignificant amount. T his value will decrease for each year thereafter until 2016, as the ozone concentration begins to decrease due to the emissions benefit of removing Stage II controls.DRAFT 

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## 6.0 **Conclusion** In this SIP revision, Georgia EPD is requesting the removal of Georgia Rule 391 - 3 - 1 - .02(2)(zz), “Gasoline Dispensing Facilities

– Stag e II” from Georgia’s SIP . Section 202(a)(6) of the CAA gives EPA discretionary authority to revise or waive the section 182(b)(3) Stage II requirement by rule after the Administrator determines that ORVR is in widespread use throughout the motor vehicle fleet. EPA also has broad discretion in how it defines widespread use and the manner in whic h any final determination is implemented. On May 16, 2012, EPA published in the federal register its determination that the use of ORVR for capturing gasoline vapor when gasoline -powered vehicles are refueled is in widespread use throughout the highway mo tor vehicle fleet [77 FR 28772]. In that notice the Administrator also exercised her authority to waive the statutory requirement that Serious, Severe, and Extreme ozone nonattainment areas adopt and implement EPA programs requiring Stage II gasoline vapor recovery systems (VRS) at certain gasoline dispensing facilities (GDFs). On August 7, 2012, EPA issued “ Guidance on Removing Stage II Gasoline Vapor Control Programs from State Implementation Plans and Assessing Comparable Measures ”. Georgia EPD has f ollowed that guidance to show that: 1 ) the emissions control gain (or incremental benefits) of Stage II VRS control decreases as ORVR controls are phased in; 2) removal of Stage II VRS controls will not interfere with attainment of the NAAQS or with furth er reasonable progress ; 3) c alculations of motor vehicle emissions without Stage II VRS show that emissions will be below the MVEB and the motor vehicle VOC baseline emission inventory from the 2008 Atlanta Maintenance SIP ; 4) Atlanta’s ozone sensitivity to NOx rather than to VOC emissions provides evidence that removal of Georgia Rule (zz) will not interfere with the attainment or reasonable further progress towards attainment of any NAAQS . EPA can propose approval of a SIP revision seeking to discontinue an existing SIP - approved Stage II control program if Georgia’s SIP revision meets the requirements of 110( l) . Georgia EPD has demonstrated in this SIP revision that removal of Georgia Rule 391 - 3 - 1 - .02(2)(zz), “Gasoline Dispensing Facilities

– Stage I I” from Georgia’s SIP is consistent with section 110 (l) of the CAA and will not interfere with the attainment of the NAAQS and with reasonable further progress toward that attainment. Removal of Georgia Rule 391 - 3 - 1 - .02(2)(zz), “Gasoline Dispensing Facil ities

– Stage II” f rom Georgia’s SIP will result in VOC emission reductions beginning in 2016. Georgia EPD has demonstrated in this SIP revision that the removal of Georgia Rule (zz) from the Georgia SIP is consistent with section 110 (l) of the CAA .DRAFT 

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## 7.0 **R eferences**  Atlanta Regional Commission’s (ARC), Volume II: Plan 2040 Conformity Determination Report (CDR) (see Table 2) CARB, Preliminary Draft Test Report, Total Hydrocarbon Emissions from Two Phase II Vacuum Assist Vapor Recovery Systems During Baseline Operations and Simulated Refueling of Onboard Refueling Vapor Recovery (ORVR) Equipped Vehicles, Project Number ST - 98 -XX, June 1999. CARB, Uncontrolled Vapor Emission Factor at Gasoline Dispensing Facilities, January 5, 2000. Department of Energy, EIA Annual Energy Outlook (AEO); “Liquid Fuels Supply and Distribution

- Reference Case”, http://www.eia.gov/oiaf/aeo/tablebrowser/#release=AEO2011&subject=0 - AEO2011&table=11 -AEO2011®ion=0 - 0&cases=ref2011 - d020911a . State of Georgia, Rules for Air Quality Control, Chapter 391 - 3 - 1, Effective August 9, 2012. USEPA, “Guidance on Removing Stage II Gasoline Vapor Control Programs from State Implementation Plans and Assessing Comparable Measures,” Office of Air Quality Planning and Standards, EPA -457/B - 12 - 001, August 7, 2012. USEPA “ Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements”, 78 FR 34178 through 78 FR 34239, Proposed Rule, June 6, 2013. 1997 Atlanta 8 - Hour Ozone Maintenance Plan, March 2 1, 2012, submitted to EPA on April 4, 2012. USEPA, EPA Memorandum, “Calculating Stage II Vacuum Assist Stage II VRS and ORVR Excess Emissions,” Glenn W. Passavant, May 2012. USEPA, Technical Guidance - Stage II Vapor Recovery Systems for Control of Gasoline Refueling Emissions at Gasoline Dispensing Facilities Vol. 1,” EPA -45 - 0/3 - 91 - 022a, November 1991