Aorgia Department o~tural Resources 

APR 0 4 2012 

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 

AJ1it PLANNING BEi.:..'«~ 

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Mark Williams, Commissioner 

Judson H. Turner, Director 

RE: Maintenance Plan and Redesignation Request; 

Withdrawal of Ozone SIP Revisions Pertaining to the Atlanta Nonattainment Area 

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 of the Clean Air Act, to provide for the maintenance of the 

1997 8-hour Ozone National Ambient Air Quality Standard (NAAQS) for the Atlanta 8-hour 

Ozone Nonattainment Area. 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 of the 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 October 21, 2009, relating to nonattainment designations for the 1997 ozone NAAQS 

are no longer necessary for the Atlanta area, we are withdrawing the nonattainment planning 

documents (attainment demonstration and contingency provisions) for Atlanta. The reasonable 

further progress plan and the emissions inventory submitted with this SIP revision to comply 

with the Clean Air Act requirements of§ 172 and § 182 for nonattainment areas are not affected 

by this request. 

The public notice for the 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 either the 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 

APR 04 Z012 

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 of the relevant 

documents and a compact disk with an electronic version of the 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 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 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 
• • 

Administrative Materials for SIP submittal dated: March 21, 2012 

1. A formal letter of submittal from the Governor or his designee, requesting EPA 

approval of the plan or revision thereof (hereafter "the plan"). 

The cover letter transmitting this proposed Atlanta 8-Hour Maintenance 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 of the plan, if different from 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 of the Atlanta 8-Hour Ozone 

Maintenance Plan, which established new NOx 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 Quality Act, Article 1: Air Quality (0. C. G .A. 12-9, et. seq.) 

provides the necessary legal authority under State law to adopt and implement the 

revisions. The Act, in its entirety, is located at http://www.lexisnexis. comlhottopics/gacodel under Title 12, Chapter 9, Article 1. 

4. A copy of the actual regulation, or document submitted for approval and 

incorporation by reference into the plan, including indication of the 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 

of the regulation/document shall, whenever possible, be indicated in the document 

itself. 

Enclosed is a copy of the affected Maintenance Plan, dated March 21, 2012, for 

approval and incorporation into the plan. This maintenance demonstration plan 

maintains all previously-adopted control measures contained in all previouslysubmitted attainment demonstration submittals. 

5. Evidence that the State followed all of the procedural requirements of the State's 

laws and Constitution in conducting and completing the adoption/issuance of the 

plan and compilation of public comments and the State's response thereto. 

The procedural requirements associated with this plan and public comment period 

are included in the submittal to EPA. 

6. Evidence that public notice was given of the proposed change consistent with 

procedures approved by EPA, including the date of publication of such 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, if applicable. 

Documentation for the public notice, hearing and comment requirements is 

included in the submittal to EPA. 
• • 

Technical Support for SIP Submittal dated: March 21, 2012 

1. Identification of all regulated pollutants affected by the plan. 

The proposed Maintenance Plan covers the ozone precursors (NOx and VOC) 

emissions. 

2. Identification of the locations of affected sources including the EPA 

attainment/non-attainment designation of the locations and the status of the 

attainment plan for the affected areas(s). 

The Maintenance Plan is applicable to Atlanta, Georgia. 

3. Quantification of the 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 of the revision. 

Refer to the Atlanta 8-Hour 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 if the 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 of the Act, a 

revision must be submitted to provide for the maintenance of the 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 will be protected if 

this 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. 

Refer to 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 of the Atlanta 8-Hour Ozone 

Maintenance Plan, which established new NOx emission limits for Georgia Power 

Plants Bowen, McDonough, and Yates verified by existing Acid Rain Monitors. 

This rule was subject to the public comment period of December 17, 2006 through 

January 19, 2007. 
• 

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 of the Atlanta 8-Hour Ozone 

Maintenance Plan, which established new NOx emission limits for Georgia Power 

Plants Bowen, McDonough, and Yates. This rule was subject to the public 

comment period of December 17, 2006 through January 19, 2007. 

8. Compliance/enforcement strategies, including how compliance will be determined 

in practice. 

Enforcement will be carried out as described in the State/EPA Enforcement 

Agreement. 

9. Special economic and technological justifications required by any applicable EPA 

policies, or an explanation of why such justifications are not necessary. 

No special economic or technological justifications are required for this proposed 

Maintenance Plan.