# Georgia Department of Natural Resources

AUG 30 2012

Ms. Gwendolyn Keyes Fleming Regional Administrator U.S. EPA, Region 4 61 Forsyth Street, S.W. Atlanta, Georgia 30303-3104 Environmental Protection Division • Air Protection Branch 4244 International Parkway • Suite 120 • Atlanta • Georgia 30354 404/363-7000 • Fax: 404/363-7100 Mark Williams, Commissioner Judson H. Turner, Director

RE: Maintenance Plan and Redesignation Request for the Atlanta, Georgia, 1997 Annual PM2

.5 NonattainmentArea Dear Ms. Fleming:
With this letter, the Georgia Environmental Protection Division (EPO) is submitting for approval and incorporation the proposed revisions to Georgia's State Implementation Plan (SIP) to include a plan, consistent with §175A ofthe Clean Air Act, to provide for maintenance ofthe 1997 Annual PM2.s National Ambient Air Quality Standard (NAAQS) in the Atlanta area. This submittal also serves as a request that the Atlanta NonattainmentArea be redesignated as an area attaining the 1997 Annual PM2.s NAAQS. On December 8, 2011, EPA published a final rule determining that the Atlanta area had attained the 1997 fine particulate matter standards. Additionally on December 8, 2011, EPA determined that the Atlanta Area had attained the 1997 annual PM2

.5 standard prior to the April 5, 2010 attainment date. Georgia EPD withdrew its previous submittal of nonattainment planning documents for the Atlanta area in a letterto EPA dated December 29, 2011. The emissions inventory submitted with the July 6, 2010 (cover date is May 24, 2010) SIP revision to comply with the Clean Air Act requirements of§172 for nonattainment areas was not affected by the December29, 2011 request. The public notice for the proposed SIP revision was advertised using the EPD Air Protection Branch listserv mailing list for public notices. Also attached to this transmittal letter is EPD's response to the comments received during the public comment period. As required by the federal SIP-processing regulations, we have enclosed certifications that the required public notices were provided and that a public hearing was held. We have also enclosed the administrative and technical support checklists to satisfy the SIP submittal completeness criteria. This submittal includes one paper copy of each ofthe relevant

· documents and a compact disk with an electronic version ofthe documents. The electronic

version is an exact duplicate ofthe paper copy.Ms. Gwendolyn Keyes Fleming Page2 

# AUG 302012

We look forward to your review and approval ofthese revisions. Should you oryour staff have any questions, please feel free to contact Jimmy Johnston at (404) 363-7014. 

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Enclosures:

- Maintenance plan (one paper and one CD)

Administrative checklist

- Technical checklist

- Certification of public hearing

- Copy of public notice

- Response to comments memo Copy w/o encl: Scott Davis, EPA Region 4 Lynorae Benjamin, EPA Region 4 James A. Capp, Branch Chief, EPD Air Protection Branch

### AtlantaPM2.5 NonattainmentArea- RedesignationRequest and Maintenance Plan

Administrative Materials for SIP submittal dated: August 16, 2012
1. A formal letter ofsubmittal from the Governor or his designee, requesting EPA approval ofthe plan or revision thereof (hereafter "the plan"). The coverlettertransmitting thisproposedmaintenance plan is the forma/letter of submission.
2. Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement (hereafter "document") in final form. That evidence shall include the date of adoption or final issuance as well as the effective date ofthe plan, if different from the adoption/issuance date. The State promulgated Georgia Rules 391-3-1.02(2){sss) and (uuu), which require S0 2 controls andestablish minimum S02 control efficiencies on multiple Georgia electric generating units. These rules are a part ofthe subjectmaintenance plan.
3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. The Georgia AirQualityAct, Article 1:AirQuality (O.C.G.A. 12-9, et. seq.) provides the necessarylegalauthorityunderState lawto adopt andimplement the revisions. The Act, in its entirety, is locatedathttp://www.lexisnexis.com/hottopicslgacodelunder TJt/e 12, Chapter9, Article 1.
4. A copy ofthe actual regulation, ordocument submitted for approval and incorporation by reference into the plan, including indication ofthe changes made to the existing approved plan, where applicable. The submittal shall be a copy of the official State regulation/ document signed, stamped, dated by the appropriate State official indicating that it is fully enforceable by the State. The effective date ofthe regulation/document shall, whenever possible, be indicated in the document itself. Enclosedis a copyofthe affectedMaintenance Plan datedAugust 16, 2012, for approval andincorporation into the plan. This maintenance demonstration plan maintains allpreviously-adoptedcontrolmeasures containedin allpreviouslysubmitted attainment demonstration submittals.
5. Evidence that the State followed all ofthe procedural requirements ofthe State's laws and Constitution in conducting and completing the adoption/issuance ofthe plan and compilation of public comments and the State's response thereto. The procedural requirements associated with thisplan andpublic commentperiod are includedin the submittal to EPA.
6. Evidence that public notice was given ofthe proposed change consistent with procedures approved by EPA, including the date of publication ofsuch notice and Certification that public hearings(s) Were held in accordance with the information provided in the public notice and the State's laws and constitution, ifapplicable. Documentation forthe public notice (posted May31, 2012), hearing (heldJuly2, 2012} and comment requirements is includedin the submittal to EPA.

### AtlantaPM2.5 NonattainmentArea- RedesignationRequest and MaintenancePlan

Technical Support for SIP Submittal dated: August 16, 2012

1. Identification of all regulated pollutants affected by the plan. The proposedMaintenance Plan covers emissions of primaryPM2.5 and of

### S02 andNOx, which are PM2.5precursors. 2. Identification ofthe locations of affected sources including the EPA attainment/non-attainment designation ofthe locations and the status ofthe attainment plan for the affected areas(s). The Maintenance Plan is applicable to the Atlanta, Georgia, AnnualPM2.5 NonattainmentArea in Georgia.
3. Quantification ofthe changes in plan allowable emissions from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantification of changes in actual emissions from affected sources through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result ofthe revision. Referto the maintenance plan.
4. The State's demonstration that the national ambient air quality standards, prevention of significant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are protected ifthe plan is approved and implemented. For all requests to redesignate an area to attainment for a national primary ambient air quality standard, under section 107 ofthe Act, a revision must be submitted to provide for the maintenance ofthe national primary ambient air quality standards for at least 10 years as required by Section 175A of the Act. The NAAQS will be protected through 2024 ifthis revision is approved and implemented.
5. Modeling information required to support the proposed revision, including input data, output data, models used, justification of model selections, ambient monitoring data used, meteorological data used, justification for use of offsite data (where used), modes of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analysis. Referto the maintenance plan.
6. Evidence, where necessary, that emission limitations are based on continuous emission reduction technology. The State andFederal controlmeasures forpointsources, onroadmobile sources, andnonroadmobile sources that are documentedin Section 2 ofthe maintenance plan are allbased on continuous emission reduction technology.

### AtlantaPM2.5 NonattairunentArea- RedesignationRequest and Maintenance Plan

7. Evidence that the plan contains emission limitations, work practice standards and recordkeeping/reporting requirements, where necessary, to ensure emission levels. Section 2 ofthe maintenance plan documents Federal and State measures that have contributed to permanentandenforceable emissions reductions in the Atlanta Area and thathave resulted in attainment ofthe annual PM2.5 standard. Section 3 ofthe maintenance plan demonstrates that, with the Federal and State measures in place, emission levels will be kept atlevels sufficient to maintain attainment ofthe standard through the year2024. 8. Compliance/enforcement strategies, including how compliance will be determined in practice. Enforcement will be carriedout as describedin the State/EPA Enforcement Agreement. 9. Special economic and technological justifications required by any applicable EPA policies, or an explanation ofwhy such justifications are not necessary. No special economic ortechnologicaljustifications are required for this proposed Maintenance Plan.