Ms. Heather McTeer Toney 

Regional Administrator 

U.S. EPA, Region 4 

61 Forsyth Street, S.W. 

Atlanta, Georgia 30303-3104 

Georgia Department of Natural Resources 

Environmental Protection Division 

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

Judson H. Turner, Director 

(404) 656-4713 

FEB 0 6 2015 

RE: Section 182(a)(1) Emission Inventory SIP Requirement 

Section 182(a)(2)(C) Permit Program Requirement 

Section 182(a)(3)(B) Emission Statements Requirement 

Dear Ms. Toney: 

With this Jetter, the Georgia Environmental Protection Division (EPD) is submitting for approval 

and incorporation the proposed revision to Georgia's State Implementation Plan (SIP) to 

include an emission inventory, consistent with §182(a}(1) of the Clean Air Act (the Act), for the 

15-county Atlanta 8-hour Ozone Nonattainment Area for 2008 8-hour Ozone National Ambient 

Air Quality Standard (NAAQS) published as a final rule in the federal register by EPA on March 

26, 2008 [73 FR 16436]. EPD is also submitting certification that existing requirements satisfy 

the Permit Program and Emission Statements requirements required by §182(a)(2)(C) and 

§182(a)(3}(B}, respectively. 

§ 182(a)(1) of the Act requires States to submit a "comprehensive, accurate, current inventory 

from all sources, as described in §172(c)(3) for the relevant pollutants for the area, in 

accordance with guidance provided by the Administrator." §172(c)(3) describes such a plan to 

have provisions that "shall include a comprehensive, accurate, current inventory of actual 

emissions from all sources of the relevant pollutant or pollutants in such area, including such 

periodic revisions as the Administrator may determine necessary to assure that the 

requirements of this part are met." 

The attached inventory has been prepared consistent with 78 FR 34178, "Implementation of 

the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan 

Requirements: Proposed Rule," and 40 Code of Federal Regulations (CFR) Subpart A (51.15). 

§182(a)(2)(C) of the Act requires States to submit a revision that includes each of the following: 

(i) Provisions to require permits, in accordance with sections 172(c)(5) and 173 of this 

title, for the construction and operation of each new or modified major stationary source 

(with respect to ozone) to be located in the area. 

(ii) Provisions to correct requirements in (or add requirements to) the plan concerning 

permit programs as were required under section 172(b)(6) of this title (as in effect 

immediately before November 15, 1990}, as interpreted in regulations of the 

Administrator promulgated as of November 15, 1990. 
Ms. Heather McTeer Toney 

Page 2 

EPD certifies that existing State of Georgia Air Quality Control rule 391-3-1-.03(8) exceeds the 

requirements of section 182 (a)(2)(C)(i) for the 15-county Atlanta 8-hour Ozone Nonattainment 

Area for 2008 8-hour Ozone National Ambient Air Quality Standard (NAAQS). No corrections 

to this rule are needed to meet the requirements of section 182(a)(2)(C)(ii). Section 

182(a)(3)(B) of the Act requires areas classified as Marginal and above to include in their SIP a 

. requirement for stationary sources of nitrogen oxides (NOx) and volatile organic compounds 

(VOC) to provide the state with a statement showing actual emissions of NOx and VOC. EPD 

certifies that existing State of Georgia Air Quality Control rule 391-3-1-.02(6)(a)4. meets the 

requirements of section 182(a)(3)(B) for the 15-county Atlanta 8-hour Ozone Nonattainment 

Area for 2008 8-hour Ozone National Ambient Air Quality Standard (NAAQS). 

As required by the federal Sl P-processing regulations, we have enclosed certifications that the 

required public notices were provided and that public hearings were held. Written public 

comments were received via e-mail from Greenlaw, on behalf of the Sierra Club, that were 

addressed in the attached document titled "Responses to Comments Received on the 

Proposed SIP Revision for the 15-county Atlanta Nonattainment Area Emissions Inventory for 

the 2008 8-Hour Ozone NAAQS". No verbal public comments were received at the public 

hearing. EPA submitted one comment asking to "clarify the total emissions on page 11, tables 

4, 5 and 6. It appears the Point EGU emissions were not included in the calculations". Tables 

4, 5, and 6 on page 11 were updated to include Point EGU emissions that were inadvertently 

left off. In addition, Column J in the Appendix F Excel spreadsheet 

(Appendix_F _Emission_Summary.xls) was updated to include Point EGU emissions that were 

inadvertently left off. 

We have also enclosed the administrative materials and technical support to satisfy the SIP 

submittal completeness criteria checklist. This submittal includes one paper copy of the 

relevant document and a compact disk with an electronic version of the document. The 

electronic version is an exact duplicate of the paper copy with the following exceptions. Per 

Attachment A of Janet McCabe's April 6, 2011, memo pertaining to consistency of SIP 

administrative requirements, the following portions of the submittal are provided in the 

electronic copy only: 

• Appendix A: Annual and Summer Day 2011 Emission Calculations for the 15 Atlanta 

Nonattainment Counties 

• Appendix E: Hartsfield-Jackson Atlanta International Airport: Documentation for the CY 

2011 Criteria Air Pollutant Emission Inventory 

• Appendix F: Emission Summaries 

• Appendix G: Georgia QAPP Documents 

• Appendix H: SESARM Documents 

• Appendix 1: Emission Inventory Technical Support Documents 

Paper copies of these large data files are not provided in order to relieve unnecessary paper 

burden. 
Ms. Heather McTeer Toney 

Page 3 

One copy of this submittal will be sent to the EPA Region 4 associates noted below. We look 

forward to your review and approval of these revisions. Should you or your staff have any 

questions, please feel free to contact James Boylan at (404) 363-7014. 

⁢~cerely, 

7

JudsonH Turner 

1

/Director 

JHT:EM 

c: Scott Davis, EPA Region 4 

Lynorae Benjamin, EPA Region 4 

Keith Bentley, Branch Chief, EPD Air Protection Branch 

Enclosures: - Memorandum 

- Administrative Checklist 

- Technical Checklist 

- Certification of Public Hearing 

- Copy of Public Notice