Ms. Heather McTeerToney 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 062015

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) ofthe Clean AirAct (the Act), forthe 15-countyAtlanta 8-hour Ozone NonattainmentArea for 2008 8-hour Ozone National Ambient Air Quality Standard (NAAQS) published as afinal 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) ofthe Act requires Statesto submit a "comprehensive, accurate, current inventory from all sources, as described in §172(c)(3) forthe relevant pollutantsforthe 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 ofactual emissions from all sources ofthe relevant pollutant or pollutants in such area, including such periodic revisions as the Administrator may determine necessaryto assure that the requirements ofthis part are met." The attached inventory has been prepared consistent with 78 FR 34178, "Implementation of the 2008 National AmbientAirQuality Standardsfor Ozone: State Implementation Plan Requirements: Proposed Rule," and 40 Code of Federal Regulations (CFR) Subpart A (51.15). §182(a)(2)(C) ofthe Act requires States to submit a revision that includes each ofthe following: (i) Provisions to require permits, in accordancewith sections 172(c)(5) and 173 ofthis title, forthe construction and operation ofeach new or modified majorstationary 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 undersection 172(b)(6) ofthis title (as in effect immediately before November 15, 1990}, as interpreted in regulations ofthe Administrator promulgated as of November 15, 1990.Ms. Heather McTeerToney Page 2

EPD certifies that existing State of Georgia Air Quality Control rule 391-3-1-.03(8) exceeds the requirements ofsection 182 (a)(2)(C)(i) forthe 15-countyAtlanta 8-hour Ozone Nonattainment Area for 2008 8-hour Ozone NationalAmbient Air Quality Standard (NAAQS). No corrections to this rule are needed to meetthe requirements ofsection 182(a)(2)(C)(ii). Section 182(a)(3)(B) ofthe 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 certifiesthat existing State of Georgia Air Quality Control rule 391-3-1-.02(6)(a)4. meets the requirements ofsection 182(a)(3)(B) forthe 15-countyAtlanta 8-hour Ozone Nonattainment Area for 2008 8-hour Ozone National AmbientAirQuality Standard (NAAQS). As required by the federal SlP-processing regulations, we have enclosed certifications thatthe required public noticeswere provided and that public hearings were held. Written public comments were received via e-mail from Greenlaw, on behalf ofthe Sierra Club, that were addressed in the attached documenttitled "Responses to Comments Received on the Proposed SIP Revision forthe 15-countyAtlanta NonattainmentArea Emissions Inventoryfor the 2008 8-Hour Ozone NAAQS". No verbal public comments were received at the public hearing. EPA submitted one comment asking to "clarifythe 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 emissionsthat 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 supportto satisfythe SIP submittal completeness criteria checklist. This submittal includes one paper copy ofthe relevant document and a compact diskwith an electronicversion ofthe document. The electronicversion is an exact duplicate ofthe paper copy with the following exceptions. Per AttachmentA of Janet McCabe'sApril 6, 2011, memo pertaining to consistency of SIP administrative requirements, the following portions ofthe submittal are provided in the electronic copy only:

• Appendix A: Annual and Summer Day 2011 Emission Calculationsforthe 15Atlanta

Nonattainment Counties • Appendix E: Hartsfield-Jackson Atlanta InternationalAirport: Documentation forthe CY

2011 Criteria Air Pollutant Emission Inventory • Appendix F: Emission Summaries • Appendix G: Georgia QAPP Documents • Appendix H: SESARM Documents • Appendix 

### 1: Emission InventoryTechnical Support Documents Paper copies ofthese large datafiles are not provided in orderto relieve unnecessary paper burden.Ms. Heather McTeerToney Page 3

One copy ofthis submittal will be sent to the EPA Region 4 associates noted below. We look forward to your review and approval ofthese revisions. Should you or your staff have any questions, please feel free to contact James Boylan at (404) 363-7014.**⁢~cerely,**

7JudsonH 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