Revision to the Georgia State 

Implementation Plan for the Removal of 

Georgia Rule 

391-3-1-.02(zz) Gasoline Dispensing 

Facilities – Stage II

September 25, 2014

Prepared by:

Georgia Department of Natural Resources

Environmental Protection Division

Air Protection Branch
DRAFT Revision to the Georgia State Implementation Plan for the Removal of Georgia 

Rule 391-3-1-.02(zz) Gasoline Dispensing Facilities – Stage II

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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 – Stage 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 (EPA) for initial approval. EPA approved Georgia Rule (zz) into the Georgia SIP

on February 2, 1996 [61 FR 3819]. This request to remove Georgia Rule (zz) is based on EPA 

Guidance Document EPA-457/B-12-001, August 7, 2012, “Guidance on Removing Stage II Gasoline 

Vapor Control Programs from State Implementation Plans and Assessing Comparable Measures”.

Georgia EPD demonstrates in this SIP revision that removal of Georgia Rule 391-3-1-.02(2)(zz), 

“Gasoline Dispensing Facilities – Stage II” 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 Facilities – Stage II” from Georgia’s SIP will result in VOC emission reductions 

beginning in 2016.

 
DRAFT Revision to the Georgia State Implementation Plan for the Removal of Georgia 

Rule 391-3-1-.02(zz) Gasoline Dispensing Facilities – Stage II

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TABLE OF CONTENTS

Executive Summary .........................................................................................................................i

1.0 Introduction and Background..................................................................................... 1

1.1 The Atlanta Ozone Nonattainment Area...........................................................................1

1.2 Stage II Vapor Recovery Rule ............................................................................................3

1.3 On-Board Refueling Vapor Recovery Controls................................................................4

1.4 Widespread Use...................................................................................................................4

2.0 Removal Request.......................................................................................................... 6

2.1 Clean Air Act Provisions.....................................................................................................6

2.2 110(l).....................................................................................................................................6

2.3 Removal Request.................................................................................................................6

3.0 Emissions Calculations................................................................................................ 9

3.1 Incremental Benefit.............................................................................................................9

3.2 Area-Wide VOC Inventory Impacts................................................................................12

3.3 Motor Vehicle Emissions Comparisons...........................................................................14

4.0 Decommissioning Provisions..................................................................................... 17

5.0 NOx and VOC Sensitivity ........................................................................................... 19

5.1 Sensitivity of Ozone in Atlanta to NOx and VOC Emissions.........................................19

5.1.1 Sensitivity Modeling NOx and VOC Emissions............................................................................19

5.1.2 Modeling Scenarios.......................................................................................................................19

5.1.1 Modeling Results ..........................................................................................................................19

6.0 Conclusion ................................................................................................................. 22

7.0 References.................................................................................................................. 23
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LIST OF TABLES

Table 3-1. Emissions Benefit of Maintaining Stage II VRS in Atlanta ........................................10

Table 3-2. Compatibility Factor...................................................................................................... 11

Table 3-3. Incompatibility of Vacuum Assisted Stage II VRS and ORVR .................................. 11

Table 3-4. Incremental Benefit of Stage II VRS Controls.............................................................12

Table 3-5. The Atlanta Area Portion of National Gasoline Consumption....................................13

Table 3-6. Projected Gasoline Consumption of the Atlanta Nonattainment Area......................13

Table 3-7. Impact on the Area Wide VOC Inventory....................................................................14

Table 3-8. Attainment Baseline VOC Emissions Inventory for Motor Vehicles Compared to 

Modeled VOC Emissions Inventory with Stage II VRS.........................................................15

Table 3-9. Attainment Baseline VOC Emissions Inventory for Motor Vehicles Compared to 

Modeled VOC Emissions Inventory without Stage II VRS...................................................15

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

Inventory with only ORVR. .....................................................................................................16

Table 5-1. Normalized NOx and VOC Sensitivity at 10 Atlanta Ozone Monitors ......................20
DRAFT Revision to the Georgia State Implementation Plan for the Removal of Georgia 

Rule 391-3-1-.02(zz) Gasoline Dispensing Facilities – Stage II

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LIST of APPENDICES

Appendix A Stage II VRS Incremental Benefit Analysis

Appendix B Ozone Sensitivity in Atlanta in Relation to the SEMAP Sensitivity Study

Appendix C SEMAP Sensitivity Study

Appendix D Stage II Rule Package

Appendix E Emissions and Air Quality Modeling for SEMAP-Final Report
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List of Acronyms

Acronym Meaning Acronym Meaning

AERR Air Emissions Reporting 

Requirement

NAA Nonattainment Area

ARC Atlanta Regional 

Commision

NAAQS National Ambient Air Quality Standard

CAA Clean Air Act NOx Nitrogen Oxides

CAAA Clean Air Act Amendment O3 Ozone

CB-IV Carbon Bond IV ORVR On-Board Refueling Vapor Recovery

CDR Conformity Determination 

Report

OTR Ozone Transport Region

CFR Code of Federal 

Regulations

Ppt Parts Per Trillion

CMAQ Community Multiscale Air 

Quality

RFP Reasonable Further Progress

DV Design Value SIP State Implementation Plan

EPA Environmental Protection 

Agency

TPD Tons Per Day

EPD Environmental Protection 

Division

UST Underground Storage Tank

GDF Gasoline Dispensing 

Facilities

VISTAS Visibility Improvement State and Tribal 

Association of the Southeast

MOVES Motor Vehicle Emissions 

Simulator

VOC Volatile Organic Compound

MVEB Motor Vehicle Emissions 

Budget
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1.0 Introductionand Background

This document contains the technical support for the Georgia Environmental Protection Division's 

(EPD’s) request to modify the Georgia State Implementation Plan (SIP) by removing Georgia Rule

391-3-1-.02(zz) (Gasoline Dispensing Facilities—Stage II). This plan will focus on the Atlanta 

Ozone Nonattainment Area since the primary pollutant emitted from gasoline dispensing facilities is 

volatile organic compounds (VOCs), a precursor along with nitrogen oxide (NOx) for ozone. VOC is 

not a precursor for PM2.5.

1.1 The Atlanta Ozone Nonattainment Area

1990 1-Hour Ozone Standard

Pursuant to the Clean Air Act Amendments of 1990 (CAAA), the Atlanta area was designated as 

nonattainment for the 1-hour ozone National Ambient Air Quality Standard (NAAQS) by U.S. EPA 

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, 1999, EPA 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 classified as severe, including Stage II 

VOC emission controls for gasoline dispensing facilities. As a result of EPA'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 1990, Georgia EPD completed, and EPA 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 11 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 

EPA to make a determination that the Atlanta area was eligible for application of EPA's Clean Data 

Policy, based on the Atlanta area's attainment of the 1-hour ozone NAAQS. EPA approved the plan 

and redesignation request effective June 14, 2005 (70 FR 34660).

1997 and 2008 8-Hour Ozone Standards Georgia EPD submitted its nonattainment area designation 

recommendations under the 8-hour ozone standard to EPA on July 15, 2003. Georgia recommended 
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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 Walton. Georgia recommended that Pickens 

County be excluded from the 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 NOx and VOC 

emissions. EPA concurred with Georgia's recommendations in a letter dated December 3, 2003.

On April 30, 2004, EPA 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, Carroll, Hall, Newton, Spalding, and Walton. With an attainment deadline of 

June15, 2007, marginal areas were required to attain the NAAQS by the 2006 ozone season. On 

October 16, 2007, the U.S. EPA published a rulemaking proposing its determination that the Atlanta 

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. EPA explained that, consistent with Section 181(b)(2) of the 

CAA, when EPA 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. EPA finalized this finding on March 6, 2008 [73FR 12013-12017].

The State of Georgia prepared and submitted an ozone attainment demonstration plan for the metro 

Atlanta 8-hour Ozone Nonattainment Area to EPA Region 4 on October 21, 2009. The plan was 

based on a modeled attainment demonstration performed according to EPA guidance. 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 condition 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, EPA published a final rule extending the attainment date for the 

Atlanta nonattainment area to June 15, 2011 [75FR 73969-73972].

On June 23, 2011, EPA 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. With the clean data determination, 

EPA 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 area 
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continues to attain the standard. This final rule became effective on July 25, 2011. On December 15, 

2011, EPA 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, 2011.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 2008 emissions levels in this area will not be exceeded through at 

least the year 2024. EPD also petitioned EPA to make a determination that the Atlanta area was 

eligible for application of EPA's Clean Data Policy, based on the Atlanta area's attainment of the 

1997 8-hour ozone NAAQS. EPA 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, EPA 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 

Standard (which lowered the NAAQS from 0.08 ppm to 0.075 ppm). The 15-county area includes 

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	gasoline	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	is	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	the	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	all	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	agencies	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,	
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Clayton,	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	enter,	

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	can	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	ambient	

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	VRS1.

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	trucks	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	use	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 Simulated Refueling of Onboard Refueling Vapor 

Recovery (ORVR) Equipped Vehicles, Project Number ST-98-XX, June 1999.
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Extreme	for	ozone,	as	appropriate,	after	such	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	use	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	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	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	guidance.		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	decreasing	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	Simulator	(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	98	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	

determine	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	approach	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].
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2.0 Removal Request

2.1 Clean Air Act Provisions

EPA can only propose approval of a SIP revision seeking to discontinue an existing SIP-approved 

Stage II control program if the SIP revision meets the following CAA provisions:

 The requirements of 110(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 State 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 Vapor 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 110(l).

2.2 110(l)

Section 110(l) of the CAA, governs EPA’s ability to approve all SIP revisions. Specifically, section 

110(l) states: 

Each revision to an implementation plan submitted by a State under this chapter shall be adopted by 

such State after reasonable notice and public hearing. The Administrator shall not approve a 

revision of a plan if the revision would interfere with any applicable requirement concerning 

attainment and reasonable further progress (as defined in section 171 of this title), or any other 

applicable requirement of this chapter.

This SIP revision uses the analysis provided by EPA’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 analysis 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.
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Specifically, Georgia EPD will present calculations comparing VOC emissions with Stage II and 

ORVR controls in place 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 decreases 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 show 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 NOx limited area, which means that due to the over-abundance of biogenic 

VOC, the control of NOx is the limiting factor in ozone formation. The sensitivity of ozone 

formation in the Atlanta area to reductions of NOx 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 as a part of the sensitivity 

demonstration, Georgia EPD included a sensitivity study conducted using part of the SouthEastern 

Modeling, Analysis, and Planning (SEMAP) project and information from a Georgia Tech analysis 

of the sensitivity of ozone concentrations in the Eastern U.S. to reductions in emissions of both NOx

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 NOx 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 not 
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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 PM2.5 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 included 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.
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3.0 Emissions Calculations

This section includes calculations as described in EPA’s Guidance Document for the analysis of the 

incremental benefit of maintaining Stage II VRS controls as ORVR technology is phased-in. These 

calculations show that regardless of the small yet temporary increase in emissions that could result 

from removing Stage II VRS controls, the incremental benefit of keeping Stage II VRS controls as 

ORVR controls are phased-in is an ever decreasing benefit, which eventually becomes a disbenefit.

Additionally, Section 110(l) requires that a SIP revision does not interfere with any applicable 

requirement concerning attainment, and reasonable further progress (as defined in section 171). EPA

states in the Guidance Document that there are circumstances under which a planned phase-out of 

Stage II would result in an area-wide VOC emissions increase, and yet may still be consistent with 

the conditions of Section 110(l). This occurs when the phase-out of Stage II would result in a small 

increase in emissions that diminishes rapidly over time as ORVR is phased in, since the increase will 

not interfere with attainment or progress toward attainment, especially in areas that are NOx limited 

for the formation of ozone. Because of this, the impact on the area-wide VOC inventory has been 

calculated and evaluated to show that it is consistent with Section 110 (l).

The Atlanta 8-Hour Ozone Maintenance Plan for the 1997 8-hour Ozone NAAQS, submitted to EPA 

on October 10, 2009, lists 2008 as its attainment or baseline year. For the purposes of consistency 

and to show that removal of the Stage 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 detailed in this section, while all analysis of the benefit of Stage 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 EPA’s Air 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 completed by April 30, 2016. There is no schedule for station 

decommissioning, only the requirement that the stations have the decommissioning completed by the 

deadline. The emission increase demonstrated for 2014 is larger than that which will actually occur

because the calculations assume that all decommissioning activities occur in 2014. 

3.1 Incremental Benefit

In EPA’s Guidance Document, the overall Stage II – ORVR increment is defined as the annual areawide emission control gain from Stage II installations at GDFs as ORVR 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 Stage II 

controls. Because there are only a small number of non-ORVR equipped vehicles and that number 

continues to grow smaller, there is only a small level of future emissions reductions achievable from 

Stage 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.

To calculate the increment, the emissions benefit of maintaining Stage II VRS controls is adjusted by 

taking into account the incompatibility of vacuum assisted Stage II VRS and ORVR. Because of this 

incompatibility, as more vehicles become equipped with ORVR, there is a benefit loss from 
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maintaining Stage 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 ORVR equipped vehicles from consideration, so that incompatibility is 

not an issue in the calculation and since there is no derived benefit of Stage II with ORVR equipped 

vehicles. The fraction of gasoline dispensed to vehicles with only Stage II VRS (1-QORVRi) was 

multiplied by both the fraction of gasoline pumped to these vehicles from facilities equipped with 

Stage II VRS and the control efficiency of the Stage II VRS controls. Further 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 assisted Stage II VRS and ORVR. 

In order to calculate this incompatibility, the increase in the UST vent pipe emissions beyond what is 

considered normal emission losses must be determined. This increase is called the compatibility 

factor

Year

(i)

Fraction of 

Gasoline Covered 

by Stage II VRS

(QSII)

Fraction of Gasoline 

Dispensed To ORVR 

Vehicles

(QORVRi)

Control Efficiency 

Of Stage II VRS

(NiuSII)

Emissions Benefit of 

Stage 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 0.054
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Table 3-2. Compatibility 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. The vehicle miles used in this calculation are 

multiplied by a constant term provided for the States by EPA in the Guidance Document. The 

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. 

Year

(i)

Constant Fraction of Annual Area-Wide Vehicle Miles 

Traveled by ORVR Equipped Vehicles

(VMTORVRi)

Compatibility Factor

(CFi)

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

2016 0.07645 0.909 0.069

2017 0.07645 0.925 0.071

Year

(i)

Fraction of Gasoline Dispensed 

Through Vacuum Assist Stage II VRS

(QSIIva)

Compatibility Factor

(CFi)

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 0.067
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As Table 3-3 shows the fraction of gasoline dispensed through vacuum assist Stage II VRS as 0.95. 

This number is an assigned value in EPA’s Guidance Document that was based on the percentage of 

facilities in the 13-county Atlanta area with the vacuum assist controls in use. The compatibility 

factor is multiplied by this fraction in order to calculate the incompatibility between Stage II VRS 

controls and ORVR controls.

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

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.

As shown in Table 3-4, by adjusting the emissions benefit of Stage II VRS controls to take into 

account the incompatibility of ORVR controls and vacuum assisted Stage II VRS controls, the 

increment continues to decrease for Stage II VRS controls as ORVR controls are phased-in and 

decreases until 2016, at which point there is a benefit loss from maintaining Stage II VRS controls. 

For more information on the calculation of incompatibility, see Appendix A.

3.2 Area-Wide VOC Inventory Impacts

Once the increment of maintaining Stage 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.

Year Emissions Benefit of Stage II VRS 

Controls

(fractional reduction)

Incompatibility of

ORVR 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 0.011

2016 0.064 0.066 -0.002

2017 0.054 0.067 -0.013
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Table 3-5. The Atlanta Area Portion of National Gasoline Consumption

Note: 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 

FHWA Highway Statistics- 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 EIA 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 Table 

3-6. More detailed calculations can be found in Appendix A.

Year Atlanta Area’s Portion 

of Total National 

Gasoline Consumption

Total 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

Year Atlanta Area 

Consumption –

May Through 

September 2010

(gallons)

Projected Ratio 

for Gasoline 

Consumption 

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 999,421,616 1.0421 1,041,497,266

2016 999,421,616 1.0443 1,043,695,994

2017 999,421,616 1.0377 1,037,099,811
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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 emissions for each ozone season beginning in 2012 if 

Stage II VRS is maintained as ORVR is phased in. As ORVR 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 Comparisons

An additional method of showing the impact of maintaining Stage II VRS, as ORVR 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 Stage II in place and projected emissions for 

2016 with Stage II VRS in place were taken from the Atlanta Regional Commission’s (ARC) Volume 

II: Plan 2040 Conformity Determination Report (CDR)’s transportation conformity demonstration. 

VOC emissions with Stage 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 Stage 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.

Year Increment Uncontrolled 

Displacement 

(non-ORVR) 

Refueling 

Emission Factor

(grams/gallon)

Projected Gasoline 

Consumption of the 13-

county Atlanta 

Nonattainment Area 

(gallons/season)

Area –Wide 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 0.011 4.6 1,041,497,266 57.23

2016 -0.002 4.6 1,043,695,994 -12.74

2017 -0.013 4.6 1,037,099,811 -68.65
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Table 3-8. Attainment Baseline VOC Emissions Inventory for Motor Vehicles 

Compared to Modeled VOC Emissions Inventory 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 Stage 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 Emissions 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 Table 3-3 indicates, a decrease in 

overall area-wide VOC emissions also occurs with only ORVR controls in place with VOC 

emissions remaining less than both the MVEB and the motor vehicle baseline emissions in the 2008 

Year 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 With 

Stage II VRS Controls In Place

(tons per day)

2008 171.83 165.53 165.53

2012 171.83 165.53 127.33 

2013 171.83 165.53 117.78

2014 171.83 165.53 108.23 

2015 171.83 165.53 98.68

2016 171.83 165.53 89.13

Year Motor Vehicle 

Emissions Budget

(tons per year)

VOC Baseline 

Emissions 2008 

(tons per year)

VOC Emission Without 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 89.05
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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 ORVR controls in place to the 2008 baseline emissions inventory as shown in Table 3-10

above, the phase-out of Stage II would result in a small increase in emissions beginning in 2014 that 

diminishes rapidly over time as ORVR 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.

Year VOC Baseline 

Emissions 

2008 

(tons per year)

VOC Emission With 

With Stage II VRS 

Controls In Place 

(tons per day)

VOC Emissions with 

Stage II VRS Removed 

(only ORVR) 

(tons per day) 

VOC Emission 

Difference 

Between Stage 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 165.53 117.78 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
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4.0 Decommissioning Provisions

Included in the removal of the rule is the process of decommissioning the Stage II VRS controls in 

such a way that it is done in a safe and environmentally appropriate manner. Not only will the 

owner/operator follow the decommissioning process as amended in Georgia Rule (zz), he will also 

perform testing and maintain records for two years after decommissioning of the Stage 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 liquidcollection 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 Stage 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. Stations can begin 

decommissioning May 1, 2014. 

U.S. EPA released a proposed rule on July 15, 2011 that would establish widespread use of onboard 

refueling vapor recovery (ORVR) 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 EPA on 

May 16, 2012 that determined widespread use of ORVR as the effective 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 Stage II requirements waived or be exempt from the rule. The first of the letters were 

received in late 2011 and EPD continued to receive requests until the Stage 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 of 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, 

2011 covered most of the facilities 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 assume all decommissioning occurs in 2014. Although the Stage II rule allows for 
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decommissioning to begin May 1, 2014, many facilities will continue to operate, maintain, and test 

their Stage II systems until early 2016. EPD will continue to implement the Stage II rule through 

2016.

These decommissioning procedures follow PEI/RP 300-09 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 cost of replacing the hanging hardware can easily double or triple the cost of 

decommissioning a Stage II system if required.

Georgia Rule (zz) has been amended to include these requirements pertaining to the 

decommissioning of the Stage II VRS equipment and can be found in Appendix D.
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5.0 NOx and VOC Sensitivity

As stated in Section 1.0 above, 110(l) of the CAA requires that a SIP revision not interfere with any 

applicable requirement concerning attainment, and reasonable further progress (as defined in section 

171 and 182 of the CAA). EPA has recently stated in its “Guidance on Removing Stage II Gasoline 

Vapor Control Programs from State Implementation Plans and Assessing Comparable Measures” 

that the removal of a VOC control could result in an area-wide VOC 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 NOx emissions.” In this situation, “a small (and ever-declining) increase in 

VOC emissions may have little or no effect on future ozone levels.”

5.1 Sensitivity of Ozone in Atlanta to NOx and VOC Emissions

Control of NOx and VOC are generally considered the most important components of an ozone 

control strategy, and NOx 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 NOx 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 NOx

emissions. The Atlanta nonattainment area is NOx limited in such a way that changes in VOC 

emissions have little effect on ozone formation.

5.1.1 Sensitivity Modeling NOx and VOC Emissions

As part of the SouthEastern Modeling, Analysis, and Planning (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 (NOx) 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 NOx and VOC 

reductions on daily 8-hour maximum ozone concentrations. Each emission sensitivity run reduced 

the 2018 anthropogenic NOx 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 NOx 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 used to calculate the 

normalized sensitivities of NOx and VOC, please see Appendix B. 

5.1.1 Modeling Results
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Table 5-1. Normalized NOx and VOC Sensitivity at 10 Atlanta Ozone Monitors

AIRS ID Site Name

NOx w/ 75 ppb 

threshold (ppt/TPD)

NOx w/ 85 ppb 

threshold (ppb/TPD)

VOC w/ 75 ppb 

threshold 

(ppb/TPD)

VOC w/ 85 ppb 

threshold 

(ppb/TPD)

13-067-0003 Kennesaw -0.07427 -0.07972 -0.00453 -0.00485

13-077-0002 Newnan -0.08090 -0.09576 -0.00176 -0.00156

13-085-0001 Dawsonville -0.06219 -0.06219 -0.00702 -0.00070

13-089-0002 South DeKalb -0.07714 -0.08744 -0.00580 -0.00685

13-097-0004 Douglasville -0.07971 -0.08374 -0.00416 -0.00723

13-121-0055 Confederate Ave. -0.06117 -0.06693 -0.00766 -0.01058

13-135-0002 Gwinnett -0.07625 -0.09008 -0.00264 -0.00293

13-151-0002 McDonough -0.08692 -0.09052 -0.00335 -0.00462

13-223-0003 Dallas /Yorkville -0.06925 -0.06925 -0.00115 -0.00115

13-247-0001 Conyers -0.08975 -0.10019 -0.00312 -0.00321

These results show that NOx 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 

NOx or VOC controls on the 1997 and 2008 ozone NAAQS, the most conservative approach would 

be to use the highest normalized NOx and VOC sensitivity value across the 10 Atlanta ozone 

monitors. The highest normalized NOx 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, for every ton per day of VOC increased in the Atlanta area 

there is a corresponding increase of 0.01058ppb in ozone at the monitor; while for every ton per day 

of NOx 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. This 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 Revision to the Georgia State Implementation Plan for the Removal of Georgia 

Rule 391-3-1-.02(zz) Gasoline Dispensing Facilities – Stage II

Page 21 of 23
DRAFT Revision to the Georgia State Implementation Plan for the Removal of Georgia 

Rule 391-3-1-.02(zz) Gasoline Dispensing Facilities – Stage II

Page 22 of 23

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 – Stage 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 which 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 motor 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 followed 

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 further reasonable progress; 3) calculations 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 II” 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 Facilities – Stage II” from 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 Revision to the Georgia State Implementation Plan for the Removal of Georgia 

Rule 391-3-1-.02(zz) Gasoline Dispensing Facilities – Stage II

Page 23 of 23

7.0 References

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 21, 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