# Aorgia Department

# o~tural Resources

APR 0 42012

Ms. Gwen 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



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EPA-REGION #<\ A'l'LAlrfA. Gt\ Mark Williams, Commissioner Judson H. Turner, Director

RE: Maintenance Plan and Redesignation Request; Withdrawal of Ozone SIP Revisions Pertaining to the Atlanta NonattainmentArea

Dear Ms. Fleming:

With this letter, the Georgia Environmental Protection Division (EPD) 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 AirAct, to provide for the maintenance ofthe 1997 8-hour Ozone National Ambient Air Quality Standard (NAAQS) forthe Atlanta 8-hour Ozone NonattainmentArea. The submittal also serves as a request that the Atlanta NonAttainment Area be redesignated as an area attaining the 1997 8-Hour Ozone NAAQS.

On June 23, 2011, EPA published a final rule determining that the Atlanta Area attained the 1997 8-hour ozone standards. On March 7, 2012, EPA published a final rule making a determination that the Atlanta Area attained the 1997 8-hour ozone standards prior to the June 15, 2011 attainment date. Upon determination by EPA that an area, designated nonattainment for the ozone NAAQS, has attained the standard, 40 Code of Federal Regulations Part 51.918 provides that the requirement for such area to submit attainment demonstrations and associated reasonably-available control measures, contingency measures, and planning documents related to attainment ofthe ozone NAAQS shall be suspended until the area is redesignated to attainment, at which time, the requirement no longer applies. Since the plan that GA EPD submitted October21, 2009, relating to nonattainment designations for the 1997 ozone NAAQS
are no longer necessary forthe Atlanta area, we are withdrawing the nonattainment planning documents (attainment demonstration and contingency provisions) forAtlanta. The reasonable further progress plan and the emissions inventory submitted with this SIP revision to comply with the Clean AirAct requirements of§172 and §182 for nonattainment areas are not affected by this request.

The public notice forthe proposed SIP revision was advertised by noticing individuals using EPD Air Protection Branch's list serve mailing list for public notices. There were no comments received for eitherthe SIP revisions or proposed rules during the public comment period. EPA provided a suggestion during their prehearing review that did not result in changes to the plan.

### Ms. Gwen Keyes Fleming Page Two 

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As required by the federal SIP-processing regulations, we have enclosed certifications that the required public notices were provided and that public hearings were held. 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 each ofthe relevant documents and a compact disk with an electronic version ofthe documents, including a copy of the interpolation spreadsheets used for interim inventory years. The electronic version is an exact duplicate of the paper copy.

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 Jimmy Johnston at (404) 363-7014.

JHT:JK:klc

c: Scott Davis, EPA Region 4 Lynorae Benjamin, EPA Region 4 James 

### A. Capp, Branch Chief, EPD Air Protection Branch

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Administrative Materials for SIP submittal dated: March 21, 2012



### 1. A formal letter of submittal from the Governor or his designee, requesting EPA approval ofthe plan or revision thereof (hereafter "the plan"). The coverlettertransmitting this proposedAtlanta 8-HourMaintenance Plan is the forma/letterofsubmission.



### 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 orfinal issuance as well as the effective date ofthe plan, ifdifferentfrom the adoption/issuance date. The State promulgated Georgia Rule 391-3-1.02(2)(jjj)- "NOx Emissions from Electric Steam Generating Units"as a part ofthe Atlanta 8-Hour Ozone Maintenance Plan, which establishednewNOx emission limits for Georgia Power Plants Bowen, McDonough, and Yates.



### 3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. The Georgia Air QualityAct, Article 1: AirQuality(0.C.G.A. 12-9, et. seq.) provides the necessarylegal authorityunderState law to adoptandimplement the revisions. The Act, in its entirety, is locatedathttp://www.lexisnexis.comlhottopics/gacodelunder Title 12, Chapter

### 9, 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 copy ofthe affectedMaintenance Plan, dated March 21, 2012, for approvalandincorporation into the plan. This maintenance demonstration plan maintains allpreviously-adoptedcontrolmeasures containedin allpreviouslysubmittedattainmentdemonstration 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 proceduralrequirements 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, hearing andcommentrequirements is included in the submittal to EPA.

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Technical Supportfor SIP Submittal dated: March 21, 2012

1. Identification ofall regulated pollutants affected by the plan. The proposedMaintenance Plan covers the ozone precursors (NOx and VOC) emissions.



### 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 Atlanta, 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 ofthe differences between certain baseline levels and allowable emissions anticipated as a result ofthe revision. Referto the Atlanta 8-HourMaintenance 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 forthe maintenance ofthe national primary ambient air quality standards for at least 10 years as required by section 175A of the Act. The NAAQS, PSD increments, RFP demonstration and visibility willbe protectedif this revision is approvedandimplemented.



### 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 ofoffsite data (where used), modes of models used, assumptions, and other information relevant to the determination ofadequacy ofthe modeling analysis. Referto the Atlanta 8-Hour Ozone Maintenance Plan.



### 6. Evidence, where necessary, that emission limitations are based on continuous emission reduction technology. The State promulgated Georgia Rule 391-3-1.02(2)@)- "NOx Emissions from Electric Steam Generating Units"as a part ofthe Atlanta 8-Hour Ozone Maintenance Plan, which establishednewNOx emission limits for Georgia Power Plants Bowen, McDonough, and Yates verifiedbyexistingAcidRain Monitors. This rule was subject to the public commentperiodofDecember 17, 2006 through January 19, 2007.

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7. Evidence that the plan contains emission limitations, work practice standards and recordkeeping/reporting requirements, where necessary, to ensure emission levels. The State promulgated Georgia Rule 391-3-1.02(2)(jjj)- "NOx Emissions from Electric Steam Generating Units"as a part ofthe Atlanta 8-Hour Ozone Maintenance Plan, which establishednewNOx emission limits for Georgia Power Plants Bowen, McDonough, and Yates. This rule was subject to the public commentperiodofDecember 17, 2006 through January 19, 2007.

8. Compliance/enforcement strategies, including how compliance will be determined in practice. Enforcement will be carriedoutas 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 forthis proposed Maintenance Plan.