Revision to the Georgia State Implementation 

Plan for the Removal of Georgia Rules for 

Consumer and Commercial Products and for 

Gasoline Marketing, and for the Revision of 

the Georgia Rule for NOx Emissions from 

Stationary Gas Turbines and Stationary 

Engines used to Generate Electricity

December 22, 2014

Prepared by:

Georgia Department of Natural Resources

Environmental Protection Division

Air Protection Branch
Revision to the Georgia State Implementation Plan for the Removal of Georgia Rules for 

Consumer and Commercial Products and Gasoline Marketing

i

Executive Summary

This document contains Georgia’s request to revise the Georgia State Implementation Plan (SIP) to 

remove Georgia Rule 391-3-1-.02(2)(aaa), Consumer and Commercial Products; and Georgia Rule

391-3-1-.02(2)(bbb), Gasoline Marketing; from the Georgia SIP; and Georgia’s request to revise the 

Georgia SIP to amend Georgia Rule 391-3-1-.02(2)(mmm), NOx Emissions from Stationary Gas 

Turbines and Stationary Engines used to Generate Electricity.

This request to revise the Georgia SIP is based on the requirement that it is consistent with section 

110 (l) of the Clean Air Act (CAA or Act).
Revision to the Georgia State Implementation Plan for the Removal of Georgia Rules for 

Consumer and Commercial Products and Gasoline Marketing

ii

TABLE OF CONTENTS

Executive Summary .........................................................................................................................i

1.0 Introduction and Background..................................................................................... 1

1.1 The Atlanta Nonattainment Area.......................................................................................1

1.2 Clean Air Act Provisions.....................................................................................................4

1.3 Section 110(l) Requirement ................................................................................................5

1.4 Removal Request.................................................................................................................6

2.0 Georgia Rule 391-3-1-.02(aaa), Consumer and Commercial Products..................... 7

2.1 Calculations and Emissions................................................................................................7

2.1.1 VOC Emission Differences.............................................................................................................7

3.0 Georgia Rule 391-3-1-.02(bbb), Gasoline Marketing................................................. 9

3.1 Impact of Switching From Georgia Gas to Conventional Gasoline..............................10

3.1.1 NOx Emission Analysis – Ozone NAAQS....................................................................................10

3.1.2 VOC Emissions Analysis – Ozone NAAQS.................................................................................13

3.1.3 NOx Emission Analysis - PM2.5 NAAQS ......................................................................................15

3.2 Emissions Compared to Motor Vehicle Emission Budgets............................................18

3.2.1 NOx and VOC Emissions Analysis – Ozone NAAQS ..................................................................18

3.2.2 NOx Emissions Analysis - PM2.5 NAAQS ....................................................................................21

3.3 15-County Analysis............................................................................................................23

3.3.1 15-County NOx Emissions Analysis .............................................................................................23

3.3.1 15-County VOC Emissions Analysis............................................................................................25

3.4 Attainment Inventory Comparison .................................................................................26

3.4.1 Total NOx Emissions and the 2008 Attainment Inventory ............................................................26

3.4.2 Total VOC Emissions and the 2008 Attainment Inventory...........................................................28

3.4.3 Total NOx Emissions and the 2008 Attainment Inventory ............................................................30

4.0 Georgia Rule 391-3-1-.02(mmm), NOx Emissions from Stationary Gas Turbines 

and Stationary Engines used to Generate Electricity .......................................................... 33

4.1 Purpose of the Rule Revision............................................................................................33

4.2 Rule Revision and Prevention of Increase in Emissions – Ozone NAAQS ..................34

4.3 Rule Revision – PM2.5 NAAQS .........................................................................................34

5.0 NOx and VOC Sensitivity ........................................................................................... 36

5.1 Sensitivity of Ozone in Atlanta to NOx and VOC Emissions.........................................36

5.1.1 Sensitivity Modeling NOx and VOC Emissions............................................................................36

5.1.2 Modeling Scenarios.......................................................................................................................36

5.1.3 Modeling Results ..........................................................................................................................37

6.0 Emission Offsets......................................................................................................... 39

6.1 Emissions Increase ............................................................................................................39

6.2 Emissions Offset ................................................................................................................40

6.2.1 Locomotive and Diesel Retrofit Conversion Offsets ....................................................................43
Revision to the Georgia State Implementation Plan for the Removal of Georgia Rules for 

Consumer and Commercial Products and Gasoline Marketing

iii

6.3 Offset Equivalency Demonstration..................................................................................45

7.0 Contingency Measures .............................................................................................. 46

7.1.1 Contingency Provisions - Stationary Source Offsets ....................................................................46

7.1.2 Contingency Measure Triggers.....................................................................................................54

7.1.3 Contingency Measures - Implementation......................................................................................55

8.0 Conclusion ................................................................................................................. 56

References............................................................................................................................. 57
Revision to the Georgia State Implementation Plan for the Removal of Georgia Rules for 

Consumer and Commercial Products and Gasoline Marketing

iv

LIST OF FIGURES

Figure 3-1: Annual Trend of NOx Emissions Increase From Switch Over to Conventional 

Gasoline...................................................................................................................................... 11

Figure 3-2: Annual Trend VOC Emissions Increase From Switch Over to Conventional 

Gasoline......................................................................................................................................13

Figure 3-3: Annual Trend of PM2.5 NOx Emissions Increase From Switch Over To 

Conventional Gasoline in the Atlanta PM2.5 Nonattainment Area .......................................15

Figure 3-4: NOx Emissions: Comparison of Georgia Gas and Conventional Gas to Baselines 

and Budgets for the 1997 Ozone Maintenance Plan NAAQS ...............................................19

Figure 3-5: VOC Emissions: Comparison of Georgia Gas and Conventional Gas to Baselines 

and Budgets ...............................................................................................................................20

Figure 3-6: NOx Emissions: Comparison of Georgia Gas and Conventional Gas to Baselines 

and Budgets for the 1997 PM2.5 NAAQS Maintenance Plan.................................................22

Figure 3-7: NOx Emissions Increase Trends Associated With Switch to Conventional Gasoline

.....................................................................................................................................................24

Figure 3-8: VOC Emissions Increase Trends Associated With Switch to Conventional Gasoline

.....................................................................................................................................................25

Figure 3-9: Comparison of Total NOx Emissions Inventory: Georgia Gasoline and 

Conventional Gasoline vs. 2008 Attainment Inventory .........................................................27

Figure 3-10: Comparison of Total VOC Emissions Inventory: Georgia Gasoline and 

Conventional Gasoline vs. 2008 Attainment Inventory .........................................................29

Figure 3-11: Comparison of Total NOx Emissions Inventory: Georgia Gasoline and 

Conventional Gasoline vs. 2008 Attainment Inventory .........................................................31
Revision to the Georgia State Implementation Plan for the Removal of Georgia Rules for 

Consumer and Commercial Products and Gasoline Marketing

v

LIST OF TABLES

Table 2-1. VOC Emission Difference Due to Georgia Rule (aaa)...................................................8

Table 3-1. Comparison of On-Road NOx Emissions Between Georgia Gas and Conventional 

Gas..............................................................................................................................................12

Table 3-2. Comparison of On-Road VOC Emissions Between Georgia Gas and Conventional 

Gas..............................................................................................................................................14

Table 3-3. Comparison of On-Road NOx Emissions Between Georgia Gas and Conventional 

Gas..............................................................................................................................................16

Table 3-4. Comparison of NOx On-Road Emissions With Conventional Gas Versus 1997 Ozone 

NAAQS Maintenance Plan MVEBs........................................................................................20

Table 3-5. Comparison of VOC On-Road Emissions With Conventional Gas Versus MVEBs 21

Table 3-6. Comparison of NOx On-Road Emissions With Conventional Gas Versus 1997 PM2.5

NAAQS Maintenance Plan MVEBs........................................................................................23

Table 3-7. Comparison of On-Road NOx Emissions Between Georgia Gas and Conventional 

Gas..............................................................................................................................................24

Table 3-8. Comparison of On-Road VOC Emissions Between Georgia Gas and Conventional 

Gas..............................................................................................................................................26

Table 3-9. 2008 Ozone NAA Inventory Comparison to Georgia Gas Margin and Conventional 

Gas Margin................................................................................................................................27

Table 3-10. Margin Allotted to Conventional Gasoline.................................................................28

Table 3-11. Georgia Gas Margin and Conventional Gas Margin ................................................29

Table 3-12. Margin Allotted to Conventional Gasoline.................................................................30

Table 3-13. 1997 PM2.5 NAA Inventory Comparison to Georgia Gas Margin and Conventional 

Gas Margin................................................................................................................................32

Table 3-14. Margin Allotted to Conventional Gasoline.................................................................32

Table 5-1. Normalized NOx and VOC Sensitivity at 10 Atlanta Ozone Monitors ......................37

Table 5-2. Emissions Increases Due to Georgia Rules (aaa) and (bbb) and Effects on Ozone 

Formation ..................................................................................................................................38

Table 6-1. Interpolation of Emissions Increase Due to Georgia Rule (bbb) ...............................39

Table 6-2. Emissions Offsets Needed from Removal of Georgia Rules (aaa) and (bbb)............40

Table 6-3. Locomotive Conversion Schedule .................................................................................43
Revision to the Georgia State Implementation Plan for the Removal of Georgia Rules for 

Consumer and Commercial Products and Gasoline Marketing

vi

Table 6-5. Emissions Decrease Due to All Retrofits.......................................................................45

Table 6-6. Emissions Increases Compared to Available Emissions Offsets.................................45

Table 7-1. Plant Yates Unit 3 Emissions Baseline For 2012 ..........................................................48

Table 7-2. Plant Yates Unit 3 Emissions Baseline For 2013 ..........................................................49

Table 7-3. Plant Yates Unit 3 Annual Average Emissions Baseline For 2012 - 2013...................49

Table 7-4. Plant Yates Units 2 and 3, Actual Emissions For 2012 ................................................50

Table 7-5. Plant Yates Units 2 and 3, Actual Emissions For 2013 ................................................50

Table 7-6. Comparison of Yates Unit 3 actual emission rate and heat input to Acid Rain 

averaging plan alternative NOx and heat input limits 2012. .................................................51

Table 7-7. Comparison of Yates Unit 3 actual emission rate and heat input to Acid Rain 

averaging plan alternative NOx and heat input limits 2013. .................................................52

Table 7-8. Comparison of Yates Actual Emission Rates for CAIR Allocations 2012..................52

Table 7-9. Comparison of Yates Actual Emission Rates for CAIR Allocations 2013..................53
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

vii

LIST of APPENDICES

Appendix A Consumer Products Analysis, and Washer Fluid Emissions Spreadsheet

Appendix B Gasoline Marketing Analysis

Appendix C Sensitivity Analysis of Ozone to NOx and VOC Emissions in the Atlanta Area, and 

Spreadsheet of Data for Sensitivity Analysis

Appendix D SEMAP Sensitivity Study Final Report

Appendix E Diesel Retrofit Documentation

Appendix F Rulemaking Documents
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

viii

LIST of ACRONYMS

Acronym Meaning Acronym Meaning

CAA Clean Air Act MVEB Motor Vehicle Emissions Budget

CAAA Clean Air Act 

Amendments NAA Nonattainment Area

CARB California Air Resources 

Board NAAQS National Ambient Air Quality Standard

CB-IV Carbon Bond IV NOx Nitrogen Oxides

CFFP Clean Fuel Fleet Program NTE Not-To-Exceed

CMAQ Community Multi-scale 

Air Quality PPB Parts Per Billion

DNR Department of Natural 

Resources PPT Parts Per Trillion

DV Design Value RACM Reasonably Achievable Control Measures

EPA Environmental Protection 

Agency

RFP Reasonable Further Progress

EPD Environmental Protection 

Division

RVP Reid Vapor Pressure

ESC European Stationary Cycle SIP State Implementation Plan

FR Federal Register TPD Tons Per Day

FTP Federal Test Procedure VISTAS Visibility Improvement State and Tribal 

Association of the Southeast

LEV Low Emission Vehicle
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

1 of 57

1.0 Introductionand Background

This document contains the technical support for the Georgia Environmental Protection Division's 

(EPD’s) request to modify the Georgia State Implementation Plan (SIP) by removing the following 

Georgia rules:

Georgia Rule 391-3-1-.02(2)(aaa), “Consumer and Commercial Products”

Georgia Rule 391-3-1-.02(2)(bbb), “Gasoline Marketing”

This document also contains the analysis for Georgia EPD’s request to modify the Georgia SIP by 

amending Georgia Rule 391-3-1-.02(2)(mmm), “NOx Emissions from Stationary Gas Turbines and 

Stationary Engines used to Generate Electricity”.

These rules were included in the Georgia State Implementation Plan to reduce emissions contributing 

to the nonattainment of the ozone NAAQS in the Atlanta metropolitan area. This section will 

provide for the history of the Atlanta Ozone Nonattainment Area and the regulatory requirement for 

the removal of these rules.

The analysis contained in this document focus on the impact of the removal and revision of thes rules 

on ozone and fine particulate matter nonattainment and maintenance areas within the geographic area 

covered by the rules. These revisions will also not interfere with attainment or maintenance of the 

sulfur dioxide (SO2), nitrogen dioxide (NO2), carbon monoxide (CO), or lead (Pb) National Ambient 

Air Quality Standards (NAAQS). There are no nonattainment or maintenance areas in Georgia for 

SO2, NO2, CO, or Pb. All of the SO2, NO2, CO, and Pb monitors in the affected area are currently 

measuring levels well below the NAAQS and the these revisions will result in little or no increase in 

emissions of these pollutants or their precursors. Although U.S. EPA has not completed designations 

for the 2010 SO2 NAAQS, these revisions will not increase emissions of SO2 or its precursors to the 

extent that the SO2 NAAQS will be violated.

1.1 The Atlanta Nonattainment Area

1990 1-Hour Ozone Standard

Pursuant to the Clean Air Act Amendments of 1990 (CAAA), the Atlanta area was designated as 

nonattainment for the 1-hour ozone National Ambient Air Quality Standard (NAAQS) by U.S. EPA 

and was classified as a serious nonattainment area on November 6, 1991. The nonattainment area 

(NAA) was, at that time, geographically defined as the following 13 Georgia counties: Cherokee, 

Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, and 

Rockdale. 

Because Atlanta failed to attain the 1-hour ozone NAAQS by November 15, 1999, EPA issued a final

rulemaking action in the September 26, 2003, Federal Register (68 FR 55469) determining that, by

operation of law, the Atlanta area was being reclassified as a "severe" ozone nonattainment area

effective January 1, 2004. 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

2 of 57

In addition to having been required to submit state implementation plan (SIP) revisions meeting 

requirements for marginal, moderate, and serious ozone nonattainment areas, Georgia was required 

to submit plans meeting the additional requirements for areas classified as severe. As a result of 

EPA's implementation of the original federal Clean Air Act of 1970, the Clean Air Act Amendments 

of 1977, and the Clean Air Act Amendments of 1990, Georgia EPD completed, and EPA approved 

(67 FR 30574), SIP revisions to address the 1-hour ozone Atlanta NAA.

On February 1, 2005, EPD requested under the CAAA of 1990 that the Atlanta area be redesignated

from nonattainment to attainment with respect to the 1-hour ozone NAAQS. This request was based

on three years, 2002 through 2004, of ambient monitoring data at all 11 ozone monitors in the

Atlanta NAA showing no violation of the 1-hour ozone NAAQS; the implementation of permanent

and enforceable reductions in ozone precursor emissions; compliance with all applicable

requirements; and the Atlanta Maintenance Plan with projections demonstrating that the 2002

emission levels in this area will not be exceeded through at least the year 2015. EPD also petitioned

EPA to make a determination that the Atlanta area was eligible for application of EPA's Clean Data

Policy, based on the Atlanta area's attainment of the 1-hour ozone NAAQS. EPA approved the plan

and redesignation request effective June 14, 2005 (70 FR 34660).

1997 and 2008 8-Hour Ozone Standards

Georgia EPD submitted its nonattainment area designation recommendations under the 8-hour ozone

standard to EPA on July 15, 2003. Georgia recommended the following 20-counties be designated 

nonattainment for the 8-hour ozone standard: Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb,

Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Henry, Newton, Paulding,

Rockdale, Spalding, and Walton. Georgia recommended that Pickens County be excluded from the

nonattainment designation even though the county is part of the Atlanta MSA. Georgia based this

exclusion, in part, on the fact that the county did not exceed any of the State's criteria for inclusion

into a nonattainment area. Other parameters used in the analysis included the county's population and

summer day NOx and VOC emissions. EPA concurred with Georgia's recommendations in a letter

dated December 3, 2003.

On April 30, 2004, EPA designated 20 metropolitan Atlanta counties as a "marginal" nonattainment 

area under the 1997 8-hour ozone standard. The eight-hour ozone nonattainment area encompasses 

the 13-counties of the former 1-hour ozone nonattainment area plus seven additional "ring" counties. 

These 7-counties included the counties of Barrow, Bartow, Carroll, Hall, Newton, Spalding, and 

Walton. With an attainment deadline of June15, 2007, marginal areas were required to attain the 

National Ambient Air Quality Standard (NAAQS) by the 2006 ozone season. On October 16, 2007, 

the U.S. EPA published a rulemaking proposing its determination that the Atlanta Area did not attain 

the 8-hour ozone NAAQS by June 15, 2007, the applicable attainment date for marginal 

nonattainment areas. The proposed finding was based on ambient air quality data from years 2004, 

2005, and 2006. The U.S. EPA explained that, consistent with Section 181(b)(2) of the Clean Air Act 

(CAA), when EPA finalizes its determination that the Atlanta area failed to attain, and that 

requirement becomes effective, the Atlanta area would be reclassified by operation of law to the next 

highest classification or “moderate” nonattainment. The "moderate" area attainment date for the 

Atlanta, Georgia, area would then be "as expeditiously as practicable," but no later than June 15, 

2010. The U.S. EPA finalized this finding on March 6, 2008 [73FR 12013-12017].
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

3 of 57

The State of Georgia prepared and submitted an ozone attainment demonstration plan for the metro 

Atlanta 8-hour Ozone Nonattainment Area to EPA Region 4 on October 21, 2009. The plan was 

based on a modeled attainment demonstration performed according to EPA guidance. The modeling 

resulted in a single monitor in the Atlanta NAA exceeding the 8-hour ozone NAAQS (design value 

of 86 ppb at the Confederate Avenue monitoring site). However, the weight of evidence analysis 

demonstrated in Section 6.2 of the October 2009 plan provides strong evidence that the Atlanta 8-

Hour Ozone NAA would demonstrate attainment of the ozone NAAQS by 2009. The attainment 

demonstration with the weight of evidence analysis was shown to be effective since the unmonitored 

area analysis showed no modeling grid cell greater than 86 ppb.

On June 9, 2010, Georgia EPD submitted a request for a one-year extension of the attainment date in 

accordance with 40 CFR 51.907. The Atlanta nonattainment area qualified for an extension because 

it had met the condition specified in 69 FR 23968 in which an area is eligible for the first of the 1-

year extensions if, for the attainment year, the area’s fourth highest daily 8-hour average is 0.084ppm 

or less. On November 30, 2010, EPA published a final rule extending the attainment date for the 

Atlanta nonattainment area to June 15, 2011 [75FR 73969-73972].

On June 23, 2011, EPA promulgated its determination [76 FR 36873] that the metro Atlanta 

nonattainment area had attained the 1997 8-Hour Ozone NAAQS. This final rule became effective 

on July 25, 2011. This determination was based upon quality-assured and certified ambient air 

monitoring data for the 2008-2010 period, which showed design values ranging from 0.068 ppm to 

0.080 ppm. With the clean data determination, EPA suspended the requirements for the 

nonattainment area to submit an attainment demonstration, a reasonable further progress (RFP) plan, 

and contingency measures. Because of this, EPD’s attainment demonstration was subsequently 

withdrawn on April 4, 2012. These requirements are suspended as long as the area continues to attain 

the standard. On December 15, 2011, EPA proposed its determination [76 FR 77950] that the metro 

Atlanta nonattainment area attained the 1997 8-hour ozone NAAQS by its applicable attainment date 

of June 15, 2011.

Although the Atlanta area attained the 1997 8-hour ozone standard on June 15, 2011, in order to 

formally be redesignated attainment, Georgia EPD was required to submit a maintenance plan. On 

April 4, 2012 Georgia EPD submitted a maintenance plan under the CAAA of 1990 requesting that

the Atlanta area be redesignated from nonattainment to attainment based on ambient monitoring data 

from 2008-2010. It included provisions showing no violation of the 1997 8-hour ozone NAAQS, the 

implementation of permanent and enforceable reductions in ozone precursor emissions, compliance 

with all applicable requirements; and the Atlanta Maintenance Plan with projections demonstrating 

that 2008 emissions levels in this area will not be exceeded through at least the year 2024. EPD also 

petitioned EPA to make a determination that the Atlanta area was eligible for application of EPA's 

Clean Data Policy, based on the Atlanta area's attainment of the 1997 8-hour ozone NAAQS. EPA 

approved the plan and redesignation request and promulgated a proposed rule on February 4, 2013 

(78 FR 7705), that was published in the federal register as a final rule on December 2, 2013 (78 FR 

72040).

On May 21, 2012, EPA published a final rule in the federal register designating a new 15-county

Atlanta area marginal nonattainment for the 2008 8-hour Ozone National Ambient Air Quality 

Standard. The 15-county area includes the counties of Bartow, Cherokee, Clayton, Cobb, Coweta, 

Dekalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, and Rockdale.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

4 of 57

1997 PM2.5 Standards

Georgia EPD submitted its nonattainment area designation recommendations under the annual PM2.5

standard to EPA on February 13, 2004, and modified those recommendations on June 29, 2004. 

Georgia recommended the following 20-counties be designated nonattainment for the annual PM2.5

ozone standard: Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, 

Fayette, Forsyth, Fulton, Gwinnett, Hall, Henry, Newton, Paulding, Rockdale, Spalding, and Walton. 

In addition, EPD recommended that a portion of Heard County be included as part of the 

nonattainment area. EPA responded to Georgia's recommendations in a letter dated June 29, 2004, 

with a proposed nonattainment area that included EPD’s recommendation plus Heard and Putnam 

Counties.

On January 5, 2005, EPA designated 20 metropolitan Atlanta counties plus portions of Heard and 

Putnam Counties as nonattainment area under the 1997 annual PM2.5 standard. 

The State of Georgia prepared and submitted an attainment demonstration plan for the metro Atlanta 

annual PM2.5 Nonattainment Area to EPA Region 4 on July 6, 2010. The plan was based on a 

modeled attainment demonstration performed according to EPA guidance. The modeling resulted 

attainment of the annual PM2.5 NAAQS by 2012.

On December 8, 2011, EPA promulgated its determination [76 FR 76620] that the metro Atlanta 

nonattainment area had attained the 1997 annual PM2.5 NAAQS. This determination was based upon 

quality-assured and certified ambient air monitoring data for the 2007-2009 period. With the clean 

data determination, EPA suspended the requirements for the nonattainment area to submit an 

attainment demonstration, RACM, RFP plans, contingency measures and other planning SIPs related 

to attainment of the 1997 annual PM2.5 NAAQS. The attainment demonstration was subsequently 

withdrawn. These requirements are suspended as long as the area continues to attain the standard. 

This final rule became effective on January 9, 2012. 

On August 30, 2012, EPD requested under CAAA of 1990 that the Atlanta area be redesignated from 

nonattainment to attainment with respect to the 1997 annual PM2.5 NAAQS based on ambient 

monitoring data from 2008-2010. This includes provisions showing no violation of the 1997 annual

PM2.5 NAAQS, the implementation of permanent and enforceable reductions in PM2.5 emissions and 

PM2.5 precursor emissions, compliance with all applicable requirements; and the Atlanta 

Maintenance Plan with projections demonstrating that 2008 emissions levels in this area will not be 

exceeded through at least the year 2024. EPD also petitioned EPA to make a determination that the 

Atlanta area was eligible for application of EPA's Clean Data Policy, based on the Atlanta area's 

attainment of the 1997 annual PM2.5 NAAQS. 

1.2 Clean Air Act Provisions

EPA can only propose approval of a SIP revision seeking to discontinue an existing SIP-approved 

program if the SIP revision is consistent with the provisions of 110(l). This section, therefore, 

consists of a detailed description of those requirements.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

5 of 57

1.3 Section 110(l) Requirement

Section 110(l) of the CAA, governs EPA’s ability to approve all SIP revisions. Specifically, section 

110(l) states: 

Each revision to an implementation plan submitted by a State under this chapter shall be adopted by 

such State after reasonable notice and public hearing. The Administrator shall not approve a 

revision of a plan if the revision would interfere with any applicable requirement concerning 

attainment and reasonable further progress (as defined in section 171 of this title), or any other 

applicable requirement of this chapter.

This SIP revision will demonstrate that the removal of the Georgia Rules described in Section 1.4

will not interfere with attainment, reasonable further progress or any other requirement of the Clean 

Air Act.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

6 of 57

1.4 Removal Request

With the submission of this plan revision, Georgia EPD is requesting the removal of Georgia Rule 

391-3-1-.02(2)(aaa), “Consumer and Commercial Products” and Georgia Rule 391-3-1-.02(2)(bbb), 

“Gasoline Marketing” from Georgia’s SIP; and the amendment of Georgia Rule 391-3-1-

.02(2)(mmm), “NOx Emissions from Stationary Gas Turbines and Stationary Engines used to 

Generate Electricity” in Georgia’s SIP. This document was prepared using the requirements of 

110(l), which demonstrate this revision will not interfere with attainment and reasonable further 

progress, as a basis for the removal of these rules. 

In the 2008 8-hour proposed ozone rule [78 FR 34184] on June 6, 2013, EPA stated for marginal 

areas that, “When Congress amended the CAA in 1990, it anticipated that nonattainment areas with 

ozone concentrations close to the level of the NAAQS would likely come into attainment within 3 

years after designation without any additional local planning.” Therefore as a part of the sensitivity 

demonstration, Georgia EPD has conducted a sensitivity study conducted using part of the 

SouthEastern Modeling, Analysis, and Planning (SEMAP) project and information from a Georgia 

Tech analysis of the sensitivity of ozone concentrations in the Eastern U.S. to reductions in

emissions of both NOx and VOCs.

Also, since VOC is not a significant precursor for particulate matter1

, there is no possibility that 

removal of the Georgia Rule (aaa) will impact the ambient air quality standard for the PM2.5 NAAQS

in the Atlanta area or interfere with attainment of the standard.

Additional evidence that the removal of these rules will not interfere with the requirements of 110(l)

can be found in Section 6 of this document. The State of Georgia is a NOx limited area and Section 6

describes the sensitivity of ozone formation in the Atlanta area to reductions of NOx and VOC 

emissions.

 

1 See 40 CFR 51.1002(c)(3)
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

7 of 57

2.0 Georgia Rule 391-3-1-.02(aaa), Consumer and Commercial Products

Windshield wiper fluid contains the volatile organic compound (VOC), methyl alcohol which 

evaporates easily at room temperature from windshield wiper fluid when refilling the fluid storage 

tank and when used to clean automobile windshields.

Georgia Rule 391-3-1-.02(2)(aaa), “Consumer and Commercial Products” or Georgia Rule (aaa) 

limits the type of windshield washer fluid that can be sold in the original 1-hour ozone 13-county 

Atlanta nonattainment area. The rule does not allow for the sale of windshield washer fluid 

containing more than 8 percent VOCs by weight. Concentrated formulas and fluid designed to work 

in temperatures below 20 degrees Fahrenheit contain more than 8 percent VOC and retailers are 

prohibited from selling them. This rule was implemented prior to the determination that Atlanta is a 

NOx limited area and was never expanded to the surrounding counties.

Determining compliance with this rule is a time consuming and resource intensive process. It 

involves an unannounced visit of any retail establishment that could possibly sell windshield washer 

fluid, finding the fluid on the shelves, and noting the product name, manufacturer, and the VOC 

content of the product. Because the Atlanta area is NOx limited with very little benefit from reducing 

VOC emissions, removal of Georgia Rule (aaa) will have negligible effect on air quality. Therefore, 

the cost of enforcing this regulation is significantly out of proportion to the benefit achieved.

2.1 Calculations and Emissions

On a national level EPA generally considers windshield washer fluid to have a 35 percent VOC 

content. In the Southeast, windshield washer fluid typically has a VOC content of between 8 and 10 

percent during the summertime, and 30 percent during the winter months. However, Georgia Rule 

(aaa) limits the VOC content of windshield washer fluid to 8 percent year round. Additional 

information on assumptions concerning the VOC content of windshield washer fluid can be found in 

Appendix A.

2.1.1 VOC Emission Differences

By comparing calculated VOC emissions that are based on a typical VOC content for windshield 

washer fluid in the Southeast and VOC emissions for windshield washer fluid with the same VOC 

content as required by Georgia Rule (aaa), the VOC difference in the Atlanta area can be used to 

evaluate how the removal of the rule will impact ozone monitors in the area. Table 2-1 shows a 

VOC difference of 0.17 tons/day. This value was calculated using 2010 census data and an EPA perperson usage factor to get the emissions difference for the area. For the purposes of these 

calculations summertime is considered ozone season or 244 days during the months of March 1 

through October 31. More details and information on these calculations can be found in Appendix 

A. 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

8 of 57

Table 2-1. VOC Emission Difference Due to Georgia Rule (aaa)

County Population 

from 2010 

Census Data

Summer VOC 

Emissions based on 

Typical Southeastern 

VOC Content of 

Windshield Washer 

Fluid

(tons)

Georgia 

Summer 

VOC 

Emissions 

with Rule In 

Place

(tons)

Summer VOC 

Emissions 

Difference Due 

to Georgia Rule 

(aaa)

(tons)

Daily VOC 

Emissions 

Difference Due 

to Georgia Rule 

(aaa) 

(tons per day)

Cherokee 214,346 10.01338774 8.010710189 2.002677547 0.008207695

Clayton 259,424 12.11925158 9.695401267 2.423850317 0.009933813

Cobb 688,078 32.14425185 25.71540148 6.42885037 0.026347747

Coweta 127,317 5.947740972 4.758192778 1.189548194 0.004875198

Dekalb 691,893 32.32247339 25.85797871 6.464494678 0.026493831

Douglas 132,403 6.185338548 4.948270838 1.23706771 0.00506995

Fayette 106,567 4.978383972 3.982707178 0.995676794 0.004080643

Forsyth 175,511 8.199171876 6.559337501 1.639834375 0.006720633

Fulton 920,581 43.005862 34.4046896 8.601172399 0.035250707

Gwinnett 805,321 37.62137584 30.09710067 7.524275167 0.030837193

Henry 203,922 9.526420152 7.621136122 1.90528403 0.007808541

Paulding 142,324 6.648807984 5.319046387 1.329761597 0.005449843

Rockdale 85,215 3.98090394 3.184723152 0.796180788 0.003263036

Total 13-

County Area

4,552,902 212.6933698 170.1547 42.53867397 0.17

Note: Please see Appendix A for more details on the population data and the VOC content of the washer fluid.

An emissions difference due to Georgia Rule (aaa) of 0.17 tons per day has extremely small nonmeasurable impact on ozone monitors in the metro area. In order to impact a monitor by even 1 part 

per billion, the emission difference must be equivalent to at least 15-25 tons per day of VOC 

emissions. Further information on the sensitivity study used in this evaluation and the emission 

offset for the removal of Rule (aaa) can be found in Sections 5 and 6 of this document.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

9 of 57

3.0 Georgia Rule 391-3-1-.02(bbb), Gasoline Marketing

Operating motor vehicles that burn gasoline releases sulfur dioxide, NOx, and VOCs into the air. 

Georgia Rule 391-3-1-.02(2)(bbb), “Gasoline Marketing” or Georgia Rule (bbb) was created to 

ensure the distribution of low sulfur and seasonal low Reid Vapor Pressure (RVP) gasoline into the 

metro Atlanta ozone nonattainment area and an area of influence outside of the Atlanta NAA. This 

cleaner-burning gasoline helps reduce emissions of ozone precursors, nitrogen oxides (NOx), and 

volatile organic compounds (VOCs), from motor vehicles. The Gasoline Marketing Program's fuel 

control area encompasses 45 counties (area of influence) in and around metro Atlanta. The 45-

county area of influence includes the following counties: Banks, Barrow, Bartow, Butts, Carroll, 

Chattooga, Cherokee, Clarke, Clayton, Cobb, Coweta, Dawson, Dekalb, Douglas, Fayette, Floyd, 

Forsyth, Fulton, Gordon, Gwinnett, Hall, Haralson, Heard, Henry, Jackson, Jasper, Jones, Lamar, 

Lumpkin, Madison, Meriwether, Monroe, Morgan, Newton, Oconee, Paulding, Pickens, Pike, Polk, 

Putnam, Rockdale, Spalding, Troup, Walton, and Upson. The 45-county area of influence consists 

of the 20-county 8-hour ozone maintenance area for the 1997 ozone NAAQS plus an additional 25 

surrounding counties that are attaining the standard. The program requires a specially blended 

gasoline (Georgia Gas) to be sold in the area of influence year round with the most stringent 

requirements occurring during the summer. 

Over the years, the federal conventional gas requirements have changed to be close to or identical to 

Georgia Gas requirements. This has eliminated the need for a specially blended gasoline in the 

Atlanta area. Conventional gasoline is equivalent to Georgia Gas in all ways except for the Reid 

Vapor Pressure (RVP) during summer months. Conventional gasoline is restricted to an RVP of 10 

psi2 from June 1 to September 15, including a 1.0 psi waiver for gasoline containing 10% ethanol. 

Further details can be found in Appendix B. Conventional gasoline is also required to meet an 

annual average sulfur content of 30 ppm. EPA recently adopted Tier 3 gasoline standards that reduce

the annual sulfur content limit to 10 ppm starting in 2017. From June 1 to September 15 of any year, 

Georgia Gas Reid Vapor Pressure (RVP) is restricted to 8.0 psi or less. This RVP limit includes a 1.0 

psi waiver for gasoline containing 10% ethanol. Georgia Gas limits the amount of sulfur to an 

annual average concentration of 30 parts per million by weight throughout the year, similar to 

conventional gasoline and less restrictive that Tier 3 gasoline.

By estimating NOx and VOC emissions, first with Georgia Rule (bbb) in place and then estimating 

those same pollutants with the requirements of conventional gas in place, GA EPD can show the 

impact of eliminating the Georgia Rule (bbb) on NOx and VOC emissions. This analysis is 

performed with the Federal Summer RVP requirement (8.8 psi upper limit for gasoline containing 

10% ethanol) retained for 13 counties in the original 1-hr ozone nonattainment area. Emission 

impacts for both pollutants decrease over time with NOx impacts eventually disappearing altogether. 

Additional details of the modeling and analysis associated with these scenarios can be found in 

Appendix B.

Georgia Rule (bbb) was required in 45-county “area of influence” as described above. Georgia EPD 

conducted several analyses to determine how the switch from Georgia gas to conventional gasoline 

 

2 With removal of the Georgia gasoline requirements, conventional gasoline will be restricted to an RVP of 7.8 

psi (plus up to 1.0 psi ethanol waiver) in the original 13-county 1-hr ozone nonattainment area.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

10 of 57

in this 45-county area will affect several maintenance and nonattainment areas.

To demonstrate that maintaining attainment of the 1997 Ozone NAAQS is not interfered with by 

switching from Georgia gas to conventional gasoline, analysis is conducted to evaluate the impact of 

this switch on the 20-county ozone maintenance area for VOC and NOx.

To demonstrate that attaining and maintaining the 1997 PM2.5 NAAQS is not interfered with by 

switching from Georgia gas to conventional gasoline, additional analysis is conducted to evaluate the 

impact of this switch on the 20-county PM2.5 maintenance area (plus a small portion of Putnam and 

Heard counties) for NOx. No other precursors need investigation since direct PM2.5 emissions do not 

change with RVP and VOCs have been not been determined to be a significant contributor to the 

PM2.5 nonattainment problem (40 CFR Parts 93.119(f)(7) through (10)).

To demonstrate that attaining the 2008 Ozone NAAQS is not interfered with by switching from 

Georgia gas to conventional gasoline, analysis is conducted to evaluate the impact of this switch on

the 15-county ozone nonattainment area for VOC and NOx.

3.1 Impact of Switching From Georgia Gas to Conventional Gasoline

3.1.1 NOx Emission Analysis – Ozone NAAQS

NOx and VOC emissions were analyzed using MOVES 2010b to show the change in on-road 

emissions from the switch from Georgia Gas to conventional gasoline. Emissions increases from 

switching to conventional gasoline are minimal, and continue to decrease into the future. Figure 3-1 

shows the annual trend for NOx emission increases.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

11 of 57

0

0.5

1

1.5

2

2.5

3

3.5

4

2005 2010 2015 2020 2025 2030 2035 2040

NOx Emissions Increase (tons/day)

Year

Annual Trend of NOx Emission Increase From Switch Over 

to Conventional Gasoline 

NOx 45cnty NOx 20 cnty NAA

Figure 3-1: Annual Trend of NOx Emissions Increase From Switch Over to

Conventional Gasoline

The impact of switching from Georgia Gas to conventional gas in the 20-county 1997 8-hour ozone

nonattainment area is that any NOx emissions increase associated with the switch decreases steadily 

from 1.32 tons/day in 2013 and then to zero by 2040. If we include the entire 45-county area subject 

to Georgia Gas requirements, the NOx emissions increase is 2.12 tons /day in 2013, dropping to zero 

by 2040. 

Catalytic emission control systems, used on passenger cars since 1975, are the primary method of 

controlling NOx emissions from motor vehicles. Sulfur in gasoline inhibits the emission control 

performance of catalyst technology. As a result, Georgia EPD established sulfur content limits for 

gasoline sold in the 45-county area in Rule (bbb). However, EPA’s Tier 2 gasoline standard 

established requirements for all gasoline sold in the United States starting in 2004. The Tier 2 sulfur 

requirements are basically the same as Georgia Gasoline. Furthermore, EPA’s Tier 3 fuel standards 

will require the sale of gasoline with sulfur content even lower than Rule (bbb) requirements starting 

in 2017. However, the volatility of the gasoline does impact the combustion process in gasoline 

engines. Thus the higher RVP allowed in conventional gasoline, compared to Georgia gas, will 

result in a very small increase in NOx emissions in the 45-county area.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

12 of 57

Table 3-1 shows the comparison of the NOx emissions between Georgia Gas and Conventional Gas 

in the different areas and over a variety of years. The year 2008 is used as the first year of the 

analysis as it is the year of the MVEB for the 2008 RFP SIP and the baseline year in the Atlanta 

Maintenance Plan for the 1997 8-hr Ozone Standard. Additional years include those used in Atlanta 

Regional Commission (ARC) transportation conformity determination reports (2010, 2016, 2024, 

2030, and 2040) and the MVEB year (2024) in the 1997 Atlanta Ozone Maintenance Plan. Because

Georgia Gasoline covers the entire 45-county area, all 45 counties were used in the analysis for 

determining the impact of removal of the rule rather than just the current 15-county nonattainment 

area. Additional details can be found in Appendix B.

Table 3-1. Comparison of On-Road NOx Emissions Between Georgia Gas and Conventional Gas

Pollutant and Region Year Georgia Gas Conventional 

Gas

Emissions 

Increase with 

Conventional 

Gas

Emissions 

Increase with 

Conventional 

Gas

NOx tpd tpd tpd %

13-county NAA

2008

2010

2013

2016

2024

2030

2040

280.50

229.41

174.49

135.45

74.29

70.52

74.76

281.85

230.47

175.20

135.90

74.37

70.56

74.76

1.35

1.05

0.72

0.44

0.08

0.04

0.00

0.48

0.46

0.41

0.33

0.11

0.06

0.00

7-county area

2008

2010

2013

2016

2024

2030

2040

86.71

69.29

50.59

36.12

24.82

22.68

24.73

87.65

70.05

51.19

36.55

24.90

22.71

24.73

0.94

0.76

0.60

0.42

0.08

0.03

0.00

1.09

1.09

1.19

1.18

0.32

0.15

0.00

20-county NAA

2008

2010

2013

2016

2024

2030

2040

367.21

298.70

225.08

171.57

99.11

93.19

99.49

369.50

300.51

226.39

172.44

99.27

93.27

99.49

2.30

1.81

1.32

0.87

0.16

0.08

0.00

0.63

0.61

0.58

0.51

0.17

0.08

0.00

25-county area not in NAA*

2008

2010

2013

2016

2024

2030

2040

118.62

95.75

69.74

49.57

34.00

31.11

34.46

119.90

96.77

70.54

50.13

34.10

31.14

34.46

1.28

1.02

0.80

0.56

0.10

0.04

0.00

1.08

1.06

1.15

1.13

0.29

0.12

0.00

45-county Marketing

Rule Area

2008

2010

2013

2016

2024

2030

2040

485.82

394.45

294.82

221.14

133.11

124.30

133.95

489.40

397.28

296.94

222.57

133.37

124.41

133.95

3.58

2.83

2.12

1.43

0.26

0.11

0.00

0.74

0.72

0.72

0.64

0.20

0.09

0.00

*Note: 45-county area is the 20-county nonattainment area with an additional 25-counties that are not nonattainment included to complete 

the Georgia Marketing Rule geographic area. This refers to emissions from those additional counties.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

13 of 57

3.1.2 VOC Emissions Analysis – Ozone NAAQS

VOC emissions were also analyzed using MOVES 2010b to show the change in on-road emissions 

from the switch to conventional gasoline. Figure 3-2 shows a trend similar to that of the NOx

emissions where emission increases from switching to conventional gasoline are minimal, and 

continue to decrease into the future. For VOCs, the impacts are greater than NOx as can be seen in 

the Figure 3-2 and Table 3-2 because VOC emissions, unlike NOx, are not only associated with 

combustion, but also evaporative emissions which are directly linked to RVP. Even in this case, the 

impacts would have been greater if emissions controls were not in place in on-road motor vehicles to 

handle volatility. As more aged vehicles are replaced with newer cleaner vehicles that have 

improved evaporative controls, the difference in VOC emissions between Georgia gasoline and 

conventional gasoline decreases over time (see Figure 3-2 and Table 3-2). The basis for the years 

illustrated in Table 3-2 are described in Section 3.1.1 as well as the reason for assessing the trends 

and magnitude of emission impact for the entire 45 county area.

0

1

2

3

4

5

6

7

8

9

2005 2010 2015 2020 2025 2030 2035 2040

VOC Emissions Increase (tons/day)

Year

Annual Trend of VOC Emission Increase From Switch Over 

to Conventional Gasoline 

VOC 45 cnty VOC 20 cnty NAA

Figure 3-2: Annual Trend VOC Emissions Increase From Switch Over to Conventional 

Gasoline
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

14 of 57

VOC emission increases associated with the switch from Georgia Gas to conventional gas in the 20-

county nonattainment area decrease from 3.35 tons/day in 2013 to approximately 1.16 ton/day in 

2040. If we include the 45-county area of influence, the VOC emission increase is still only 5.66

tons/day in 2013 decreasing to 1.94 tons/day in 2040. Table 3-2 shows the difference in emissions 

between the use of Georgia Gas and Conventional Gas in the different areas.

Table 3-2. Comparison of On-Road VOC Emissions Between Georgia Gas and Conventional Gas

Pollutant and Region Year Georgia Gas Conventional Gas Emissions 

Increase with 

Conventional 

Gas

Emissions 

Increase with 

Conventional 

Gas

VOC tpd tpd tpd %

13-county NAA

2008

2010

2013

2016

2024

2030

2040

132.57

109.58

83.76

66.48

47.54

46.05

50.37

134.84

111.60

85.34

67.58

48.20

46.60

50.95

2.27

2.02

1.58

1.10

0.66

0.55

0.58

1.72

1.84

1.89

1.65

1.39

1.19

1.15

7-county area

2008

2010

2013

2016

2024

2030

2040

38.74

32.44

26.63

21.45

13.96

13.30

15.03

41.07

34.52

28.40

22.74

14.61

13.82

15.61

2.34

2.08

1.77

1.30

0.65

0.53

0.58

6.04

6.41

6.64

6.05

4.65

3.95

3.85

20-county NAA

2008

2010

2013

2016

2024

2030

2040

171.30

142.02

110.39

87.93

61.50

59.35

65.40

175.91

146.12

113.74

90.32

62.82

60.42

66.56

4.61

4.10

3.35

2.39

1.31

1.07

1.16

2.69

2.89

3.03

2.72

2.13

1.80

1.77

25-county area not in NAA

2008

2010

2013

2016

2024

2030

2040

50.54

41.71

33.98

27.12

17.58

16.89

19.26

53.67

44.45

36.29

28.81

18.42

17.59

20.04

3.13

2.73

2.31

1.69

0.84

0.70

0.78

6.19

6.55

6.80

6.23

4.78

4.15

4.06

45-county Marketing

Rule Area

2008

2010

2013

2016

2024

2030

2040

221.84

183.74

144.37

115.04

79.08

76.24

84.66

229.59

190.57

150.03

119.13

81.24

78.01

86.60

7.74

6.83

5.66

4.08

2.15

1.77

1.94

3.49

3.72

3.92

3.55

2.72

2.33

2.29

*Note: 45-county area is the 20-county nonattainment area with an additional 25-counties that are not nonattainment included to complete 

the Georgia Marketing Rule geographic area. This refers to emissions from those additional counties.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

15 of 57

3.1.3 NOxEmission Analysis- PM2.5 NAAQS

NOx is regulated as a precursor to PM2.5 and the Atlanta area is currently designated nonattainment 

for the 1997 annual PM2.5 NAAQS. Therefore, the increase in on-road NOx emissions in the current 

Atlanta PM2.5 nonattainment area that will result from the switch from Georgia Gas to conventional 

gasoline was determined using MOVES 2010b. Emissions increases from switching to conventional 

gasoline are minimal, and continue to decrease into the future. Figure 3-3 shows the annual trend for 

NOx emission increases. The impact seen here is even smaller than the case with ozone because 

PM2.5 NAAQS is an annual standard with annualized emissions where RVP between Georgia 

gasoline and conventional gasoline are identical for over 2/3 of the year (the annual, year-round 

sulfur requirements for conventional gas and Georgia gasoline are the same). Direct PM2.5 is not 

impacted at all by volatility with the impact of RVP change on PM2.5 direct emissions being zero. 

This has been confirmed by MOVES modeling. For further details see Appendix B.

0.0

0.5

1.0

2005 2010 2015 2020 2025 2030 2035 2040

NOx Emissions Increase (tons/day)

Year

Annual Trend of PM2.5 NOx Emission Increase From Switch 

Over to Conventional Gasoline in the Atlanta PM2.5

Nonattainment Area

20 cnty NAA*

Figure 3-3: Annual Trend of PM2.5 NOx Emissions Increase From Switch Over To 

Conventional Gasoline in the Atlanta PM2.5 Nonattainment Area

Figure 3-3 also includes emissions form a portion of Putnam County that is part of the Atlanta PM2.5

nonattainment area. The portion of Heard County that is part of the Atlanta PM2.5 nonattainment area

does not have regular public vehicular traffic. 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

16 of 57

The impact of switching from Georgia Gas to conventional gas in the 1997 annual PM2.5

nonattainment area is that any NOx emissions increase associated with the switch decreases steadily 

from only 0.28 tons/day in 2016 to zero by 2040. Table 3-3 shows the comparison of the NOx

emissions between Georgia Gas and Conventional Gas in the different areas. The years illustrated in 

Table 3.3 were chosen for similar reasons described in Section 3.1.1 except that 2008 is the baseline 

year in the submitted 1997 PM2.5 Atlanta Maintenance Plan and 2024 is the MVEB year in the Plan.

Table 3-3. Comparison of On-Road NOx Emissions Between Georgia Gas and Conventional Gas

*Small portion of Putnam County is considered in maintenance along with 20 full counties for the 1997 PM2.5 annual NAAQS standard 

Pollutant and 

Region Year Georgia Gas Conventional Gas Emissions Emissions

Increase with Increase with

Conventional 

Gas Conventional Gas

NOx tpd tpd tpd Percent

2008 297.19 297.64 0.44 0.15

13-county 2016 144.72 144.86 0.14 0.10

2024 79.14 79.17 0.03 0.03

2030 74.99 75.01 0.01 0.02

2040 79.27 79.27 0.00 0.00

2008 82.85 83.13 0.28 0.33

7-county 2016 36.80 36.94 0.13 0.36

2024 23.62 23.64 0.02 0.10

2030 21.28 21.29 0.01 0.04

2040 22.77 22.77 0.00 0.00

2008 0.41 0.41 0.002 0.41

2016 0.19 0.19 0.001 0.34

Putnam 2024 0.09 0.09 0.000 0.12

in NAA* 2030 0.07 0.07 0.000 0.05

2040 0.06 0.06 0.000 0.00

2008 380.45 381.18 0.72 0.19

20-county 2016 181.71 181.99 0.28 0.15

NAA 2024 102.84 102.89 0.05 0.05

and Putnam* 2030 96.34 96.37 0.02 0.02

2040 102.11 102.11 0.00 0.00
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

17 of 57

In the Final Redesignation of the Rome, Georgia, Nonattainment Area for the 1997 Annual Fine 

Particulate Matter to Attainment on May 14, 2014 [79 FR 27493 through 27496], EPA agrees that 

repealing Georgia Rule 391-3-1-.02(2)(bbb) entitled “Gasoline Marketing.'' is expected to result in a

minimal emission increase and unlikely to interfere the attainment of the PM2.5 air quality standard. 

“Subsequent to publication of the proposed rule, GA EPD notified EPA that the Georgia 

Board of Natural Resources ...had repealed Georgia Rule 391–3– 1–.02(2)(bbb) entitled 

‘‘Gasoline Marketing.”...’ The Gasoline Marketing rule, enacted to improve ozone levels in 

the Atlanta Area, required that fuel sold in the Atlanta ozone nonattainment area and in areas 

determined to have contributed to ozone levels in the nonattainment area contain reduced 

sulfur and have a reduced Reid Vapor Pressure. This rule applied to fuel sold in the Rome 

Area, and the projected mobile source emissions in GA EPD’s maintenance plan assumed 

continued implementation of the rule through the maintenance period. GA EPD has 

subsequently provided calculations to EPA demonstrating that the repeal of the Gasoline 

Marketing rule increases the on-road NOx emissions projected for 2023 in the Rome Area by 

approximately 3 tons per year (tpy) and does not change the projected emissions of SO2 or 

direct PM2.5.” 

“EPA has concluded that the changes to the aforementioned rules do not affect the Agency’s 

decision to approve the redesignation request and maintenance plan for the Rome Area. Any 

increase in emissions that may result from these modifications is expected to be minimal and 

well within the margin necessary to maintain attainment of the 1997 Annual PM2.5 standard.”

EPA has also agreed with this assessment for the Final Redesignation of the Macon, Georgia 

Nonattainment Area for the 1997 Annual Fine Particulate Matter to Attainment also, dated May 13, 

2014 [79 FR 27194 through 27196].

This document demonstrates that EPA’s conclusions that repeal of Georgia rule (bbb) is unlikely to 

interfere with attainment and maintenance of the PM2.5 air quality standard in the Rome and Macon 

nonattainment areas also hold true for the Atlanta PM2.5 nonattainment area.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

18 of 57

3.2 Emissions Compared to Motor Vehicle Emission Budgets

It is important to evaluate on-road NOx and VOC emissions from both Georgia Gas and conventional 

gasoline to show that the removal of the Georgia Rule (bbb) will not affect transportation conformity. 

Motor vehicle emission budgets provide limitations of on-road mobile emissions, vital to assuring 

that future emissions from mobile sources will not interfere with the region’s ability to attain a 

NAAQS standard (PM2.5 and ozone most specifically in this case), demonstrate rate of progress, or 

maintain pollutant levels below the standard. Here it is shown how removal of the Georgia Rule 

(bbb) does not require any changes to the motor vehicle emissions budgets nor interferes with 

transportation planning’s ability to continue to demonstrate conformity with the SIP budgets in place.

3.2.1 NOx and VOC Emissions Analysis – Ozone NAAQS

Figure 3-4 shows the NOx emissions for both Georgia Gas and conventional gas and how the 

emissions relate to the 2008 and 2024 MVEBs in Georgia’s Redesignation Request and Maintenance 

Plan for the Atlanta 1997 8-hour Ozone Nonattainment Area [78 FR 72040]. The difference in the 

two lines is nearly indistinguishable showing how Georgia Marketing Rule removal will not 

significantly affect these trends or the magnitude of emissions.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

19 of 57

50

100

150

200

250

300

2010 2015 2020 2025 2030 2035 2040

NOx Emissions (tons/day)

Year

NOx On-Road Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Versus 2008 & 2024 Ozone 

NAAQS MVEBs 

NOx Inventory-Georgia Gas 20 cnty NAA

NOx Inventory-Conventional Gas 20 cnty NAA

2008 Atlanta RFP SIP NOx MVEB

2024 Maintenance Plan NOx MVEB

Figure 3-4: NOx Emissions: Comparison of Georgia Gas and Conventional Gas to 

Baselines and Budgets for the 1997 Ozone Maintenance Plan NAAQS

The green line describing the 2024 NOx MVEB for the 1997 8-hour Ozone Maintenance Plan (2024 

Maintenance Plan NOx MVEB for short on Figure 3-4) begins at 2024 because this budget only 

applies from 2024 onward in the maintenance plan. The emissions from Georgia Gas and 

conventional gasoline are compared in this graph to the motor vehicle emissions budgets (MVEBs) 

to show that the removal of the Georgia Marketing Rule clearly does not impact Atlanta’s ability to 

keep NOx emissions below requirements. The dashed line represents the 2008 Atlanta RFP budget

for NOx in Georgia’s 15% Reasonable Further Progress State Implementation Plan Revision for the 

Atlanta 8-hour Ozone Nonattainment Area [78 FR 65877]. 

In both the Georgia Gas and conventional gas cases the NOx and VOC emissions after 2012 are well 

below the 2008 MVEB while emissions from 2024-2040 never exceed the 2024 MVEB . Table 3-4

shows the NOx emissions for both types of gasoline in comparison to the two MVEBs.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

20 of 57

Table 3-4. Comparison of NOx On-Road Emissions With Conventional Gas Versus 1997 

Ozone NAAQS Maintenance Plan MVEBs

Year 2008 RFP MVEB 

(tons/day)

2024 Maintenance Plan 

SIP MVEB

(tons/day)

Conventional Gas 

Emissions

(tons/day)

2013 272.67 N/A 226.39

2016 272.67 N/A 172.44

2024 272.67 126 99.27

2030 272.67 126 93.27

2040 272.67 126 99.49

A similar comparison can be made for VOC emissions. Figure 3-5 shows that comparison using both 

Georgia Gas and conventional gas and how the emissions relate to the 2008 and 2024 MVEBs.

50

70

90

110

130

150

170

190

2010 2015 2020 2025 2030 2035 2040

VOC Emissions (tons/day)

Year

VOC On-Road Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Versus 2008 & 

2024 Ozone NAAQS MVEBs 

VOC Inventory-Georgia Gas 20 cnty NAA

VOC Inventory-Conventional Gas 20 cnty NAA

2008 Atlanta RFP SIP NOx MVEB

2024 Maintenance Plan VOC MVEB

Figure 3-5: VOC Emissions: Comparison of Georgia Gas and Conventional Gas to 

Baselines and Budgets
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

21 of 57

Similar to NOx, the difference in the two lines for VOC is also extremely small showing how the 

removal of the Georgia Marketing Rule will not significantly affect these trends or the magnitude of

emissions.

The green line describing the 2024 MVEB for VOC begins at 2024 because this budget only applies 

from 2024 onward as also shown in the Atlanta 1997 8-hour Ozone Maintenance Plan [78 FR 

72040]. The emissions from Georgia Gas and conventional gasoline are compared in this graph to 

the motor vehicle emissions budgets (MVEBs) to show that the removal of the Georgia Marketing 

Rule clearly does not impact Atlanta’s ability to keep VOC emissions below requirements. The 

dashed line represents the 2008 Atlanta RFP budget for VOC in Georgia’s 15% Reasonable Further 

Progress State Implementation Plan Revision for the Atlanta 8-hour Ozone Nonattainment Area [78 

FR 65877]. 

In both the Georgia Gas and conventional gas cases the NOx and VOC emissions after 2012 are well 

below the 2008 MVEB while emissions from 2024-2040 never exceed the 2024 ozone maintenance 

plan MVEB. Table 3-5 shows the VOC emissions for conventional gasoline in comparison to the 

two MVEBs.

Table 3-5. Comparison of VOC On-Road Emissions With Conventional Gas Versus MVEBs

Year 2008 RFP MVEB 

(tons/day)

2024 Maintenance Plan 

SIP MVEB

(tons/day)

Conventional Gas 

Emissions

(tons/day)

2013 171.83 N/A 113.74

2016 171.83 N/A 90.32

2024 171.83 92 62.82

2030 171.83 92 60.42

2040 171.83 92 66.56

3.2.2 NOxEmissions Analysis- PM2.5 NAAQS

Figure 3-6 shows the NOx emissions for both Georgia Gas and conventional gas and how the 

emissions relate to the 2002 baseline and 2024 NOx MVEB for the 1997 PM2.5 NAAQS Maintenance 

Plan. The difference in the two lines is nearly indistinguishable showing how Georgia Marketing 

Rule removal will not significantly affect these trends or the magnitude of emissions. The 2002 

baseline year (applied to 1997 PM2.5 NAAQS) is used here since there is no MVEB before 2024 

and this is the value that emissions are compared to when conducting transportation conformity 

determinations for model years before 2024 (once the PM2.5 Maintenance Plan is approved, until 

then every year is compared to 2002 through the “baseline year interim emissions test” established in 

the transportation conformity final rule (69 FR 40004)).
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

22 of 57

50

100

150

200

250

300

350

400

450

500

2010 2015 2020 2025 2030 2035 2040

NOx Emissions (tons/day)

Year

NOx On-Road Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Versus 2002 Baseline & 

2024 PM2.5 NAAQS MVEB 

PM NOx Inventory-Georgia Gas

PM NOx Inventory-Conventional Gasoline

2002 PM NOx Baseline

2024 Maintenance Plan PM NOx MVEB

Figure 3-6: NOx Emissions: Comparison of Georgia Gas and Conventional Gas to 

Baselines and Budgets for the 1997 PM2.5 NAAQS Maintenance Plan

In Georgia’s Redesignation Request and Maintenance Plan for the Atlanta 1997 Annual PM2.5

Nonattainment Area, submitted to EPA on August 30, 2012, the 2024 MVEB for NOx also begins at 

2024 because this budget only applies from 2024 onward. NOx is the only pollutant listed because it 

is the only significant PM2.5 precursor impacted by the removal of the Georgia Gas rule or volatility. 

Direct PM2.5 is not impacted by volatility. This MVEB is represented in Figure 3-6 by a green line. 

The emissions from Georgia Gas and conventional gasoline are compared in this graph to the 

MVEBs to show that the removal of the Georgia Marketing Rule and waiver of the RVP rule clearly 

does not impact Atlanta’s ability to keep NOx emissions below these requirements. The dashed line

represents the 2002 emissions baseline. 

In both the Georgia Gas and conventional gas cases the NOx emissions are well below the 2002 

baseline while emissions from 2024-2040 never exceed the 2024 PM2.5 maintenance plan MVEB. 

Table 3-6 shows the NOx emissions for both types of gasoline in comparison to the two MVEBs.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

23 of 57

Table 3-6. Comparison of NOx On-Road Emissions With Conventional Gas Versus 1997 

PM2.5 NAAQS Maintenance Plan MVEBs

Year 2002 Baseline Emissions 

(tons/day)

2024 Maintenance Plan 

SIP MVEB

(tons/day)

Conventional Gas 

Emissions

(tons/day)

2016 432.85 N/A 181.99

2024 432.85 121.72 102.89

2030 432.85 121.72 96.37

2040 432.85 121.72 102.11

3.3 15-County Analysis

As presented above in greater detail in Section 1.0, the Atlanta area was designated nonattainment in 

1991 for 13-counties for the 1990 1-hour ozone standard: Cherokee, Clayton, Cobb, Coweta, 

DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, and Rockdale. On April 30, 

2004, EPA designated a 20-county nonattainment area under the 1997 8-hour ozone standard. The 

eight-hour ozone nonattainment area encompasses the 13-counties of the former 1-hour ozone 

nonattainment area plus seven additional "ring" counties. These 7-counties included the counties of 

Barrow, Bartow, Carroll, Hall, Newton, Spalding, and Walton. 

On May 21, 2012, EPA published a final rule in the federal register designating a new 15-county

Atlanta area marginal nonattainment for the 2008 8-hour Ozone National Ambient Air Quality 

Standard. The 15-county area includes the counties of Bartow, Cherokee, Clayton, Cobb, Coweta, 

Dekalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, and Rockdale.

Georgia Rule (bbb) covered the 20-county nonattainment area plus an additional 25 counties to be 

called the 45-county area of influence.

In order to show that the new 15-county marginal non-attainment area will not be affected by the 

removal of the Gasoline Marketing Rule, NOx and VOC emissions were analyzed in the same 

manner as in the 20-county and 45-county areas to show the change in emissions from the switch to 

conventional gasoline. Emissions increases from switching to conventional gasoline are minimal, 

and continue to decrease into the future. 

3.3.1 15-County NOx Emissions Analysis

Figure 3-7 shows the annual trend for NOx emission increases.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

24 of 57

0.0

0.5

1.0

2010 2015 2020 2025 2030 2035 2040

NOx Emissions Increase (tons/day)

Year

Annual Trend of NOx Emission Increase From Switch Over to 

Conventional Gasoline

NOx 15 cnty NAA

Figure 3-7: NOx Emissions Increase Trends Associated With Switch to Conventional 

Gasoline

As shown in Table 3-7, replacing Georgia Gasoline with Conventional Gasoline in the new 15-

county NAA results in only ~0.80 tons/day increase in NOx emissions in 2013 decreasing to 0.11

tons/day by 2024 and zero by 2040.

Table 3-7. Comparison of On-Road NOx Emissions Between Georgia Gas and Conventional 

Gas

Pollutant and Region Year Georgia Gas Conventional Gas Emissions Increase 

with Conventional Gas

Emissions 

Increase with 

Conventional 

Gas

NOx tpd tpd tpd %

15-county

2013

2016

2024

2030

2040

191.55

147.49

83.06

78.67

83.79

192.38

148.13

83.17

78.73

83.79

0.82

0.64

0.11

0.05

0.00

0.43

0.43

0.13

0.07

0.00
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

25 of 57

3.3.1 15-County VOC Emissions Analysis

A similar comparison can be made for VOC emissions. The trend for VOC emission increases, 

associated with the switch from Georgia Gas to conventional gas in the 20-county nonattainment 

area, also decreases as shown in Figure 3-8.

0.0

0.5

1.0

1.5

2.0

2.5

2010 2015 2020 2025 2030 2035 2040

VOC Emissions Increase (tons/day)

Year

Annual Trend of VOC Emission Increase From Switch Over to 

Conventional Gasoline

VOC 15 cnty NAA

Figure 3-8: VOC Emissions Increase Trends Associated With Switch to Conventional 

Gasoline

Table 3-8 shows the VOC emissions, associated with the switch from Georgia Gas to conventional 

gas in the new 15 county NAA results in 2.31 tons/day increase in VOC emissions in 2013 

decreasing to 0.86 tons/day by 2024, continuing through 2040 to 0.75 tons/day.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

26 of 57

Table 3-8. Comparison of On-Road VOC Emissions Between Georgia Gas and 

Conventional Gas

Pollutant and Region Year Georgia Gas Conventional Gas Emissions Increase 

with Conventional Gas

Emissions 

Increase with 

Conventional 

Gas

VOC tpd tpd tpd %

15-county

2013

2016

2024

2030

2040

91.80

72.89

51.79

50.12

54.99

94.11

74.56

52.65

50.83

55.75

2.31

1.67

0.86

0.71

0.75

2.52

2.29

1.65

1.41

1.37

3.4 Attainment Inventory Comparison

In Georgia’s April 4, 2012, submittal of the Redesignation Request and Maintenance Plan for the 

1997 8-hour Ozone Standard, Table 3-13 shows the consolidated emissions projections of all metro 

Atlanta sources from 2008 to 2024. The approved 1997 plan [78 FR 72040] demonstrated that that 

future NOx and VOC emissions through 2024, or the maintenance inventory, remained well below 

the emission levels calculated in 2008, the attainment inventory year.

Also, in Georgia’s August 30, 2012, submittal of the Redesignation Request and Maintenance Plan 

for the 1997 PM2.5 Standard, Table 3-15 shows the consolidated emissions projections of all metro 

Atlanta sources from 2008 to 2024. The plan demonstrated that future NOx emissions through 2024, 

the maintenance inventory, remained well below the emission levels calculated in 2008, the 

attainment inventory year. Again direct PM is not impacted by RVP or sulfur content.

A comparison of the attainment inventory with the emissions that result from the removal of the 

Gasoline Marketing Rule has been made and confirms that conventional gas emissions remains

below those in the attainment inventory just as in the case with Georgia gas. If current and future 

emissions of precursors to NAAQS pollutants are shown to be below the emission levels determined 

the year the Atlanta region attained the standard, then the Atlanta region will continue pollutant 

concentration levels below the 1997 ozone and PM2.5 standards.

3.4.1 Total NOx Emissions and the 2008 Attainment Inventory

Figure 3-9 shows that there is no discernable difference in the total NOx emissions inventory 

between Georgia Gasoline and conventional gasoline; and compared to the 2008 attainment 

inventory, both stay well below. 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

27 of 57

0

100

200

300

400

500

600

700

2010 2015 2020 2025 2030

NOx Emissions (tons/day)

Year

NOx Total Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Total Inventory vs. 2008 

Attainment Inventory

Total Inventory Georgia Gasoline

Total Inventory Conventional Gas

Total 2008 Attainment Inventory

Figure 3-9: Comparison of Total NOx Emissions Inventory: Georgia Gasoline and 

Conventional Gasoline vs. 2008 Attainment Inventory

Table 3-9 shows the difference between the total NOx emissions inventory for both Georgia Gas and 

for conventional gasoline. By calculating this difference, a margin of safety is demonstrated well 

below the attainment inventory. This margin is the difference between actual emissions and the level 

at which an increase in emissions could indicate a scenario where the area could fall into possible 

nonattainment with the 1997 8-hour ozone standard. A large margin indicates that emissions are well 

below a level where there would be any concern over maintaining criteria pollutant concentration 

levels below the NAAQS in a maintenance area.

Table 3-9. 2008 Ozone NAA Inventory Comparison to Georgia Gas Margin and 

Conventional Gas Margin

Year Total 2008 

NOx

Attainment 

Inventory

Total NOx

Emissions 

Inventory with 

Georgia Gasoline

Total NOx Emissions 

Inventory with 

Conventional Gasoline

Georgia Gas 

Margin

(NOx)

Conventional Gas 

Margin

(NOx)

tpd tpd tpd tpd tpd

2010

2013

2014

2016

2017

2020

2024

2030

606.78

606.78

606.78

606.78

606.78

606.78

606.78

606.78

564.39

500.80

479.60

437.21

416.01

367.67

303.19

206.47

566.20

502.11

480.77

438.07

416.84

368.40

303.35

206.55

42.39

105.98

127.18

169.57

190.77

239.11

303.59

400.31

40.58

104.67

126.01

168.71

189.94

238.38

303.43

400.23
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

28 of 57

A comparison of the attainment inventory with the emissions that result from the removal of the 

Gasoline Marketing Rule, confirm that conventional gas emissions remain below those in the 

attainment inventory. After calculating the margin for both Georgia Gas and conventional gas, it is 

important to evaluate the amount of the margin allotted to the removal of the Gasoline Marketing 

Rule and more specifically the switch to conventional gasoline. In Table 3-10, the increase in 

emissions with Gasoline Marketing rule removal is 0.16 tons/day or just 0.054% of the margin in 

2024.

Table 3-10. Margin Allotted to Conventional Gasoline

Year Georgia 

Gas 

Margin

(NOx)

Conventional 

Gas Margin

(NOx)

Amount of Margin 

Allotted to Switch to 

Conventional 

Gasoline

% of Margin 

Allotted to Switch to 

Conventional 

Gasoline

tpd tpd tpd %

2010

2013

2014

2016

2017

2020

2024

2030

42.39

105.98

127.18

169.57

190.77

239.11

303.59

400.31

40.58

104.81

126.18

168.93

190.16

238.57

303.46

400.24

1.81

1.32

1.17

0.87

0.83

0.73

0.16

0.08

4.27

1.24

0.92

0.51

0.43

0.30

0.05

0.02

3.4.2 Total VOC Emissions and the 2008 Attainment Inventory

Figure 3-10 below shows a slight difference in the total VOC emissions inventory between Georgia 

Gasoline and conventional gasoline compared to the 2008 attainment inventory, however, just as in 

the case of total VOC emissions inventory, both stay well below the 2008 attainment inventory. 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

29 of 57

0

100

200

300

400

500

600

2010 2015 2020 2025 2030

VOC Emissions (tons/day)

Year

VOC Total Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Total Inventory vs. 2008 

Attainment Inventory 

Total Inventory Georgia Gasoline

Total Inventory Conventional Gas

Total 2008 Attainment Inventory

Figure 3-10: Comparison of Total VOC Emissions Inventory: Georgia Gasoline and 

Conventional Gasoline vs. 2008 Attainment Inventory

Table 3-11 shows the difference between the total VOC emissions inventory for both Georgia Gas 

and for conventional gasoline and the calculation results used to determine the margin for both 

Georgia Gas and conventional gas. In both cases, the margins increase beginning in 2010 through to 

the year 2040.

Table 3-11. Georgia Gas Margin and Conventional Gas Margin

Year Total 2008 

VOC 

Attainment 

Inventory

Total VOC Emissions 

Inventory with Georgia 

Gasoline

Total VOC Emissions 

Inventory with Conventional 

Gasoline

Georgia Gas Margin 

(VOC)

Conventional Gas 

Margin

(VOC)

tpd tpd tpd tpd tpd

2010

2013

2014

2016

2017

2020

2024

2030

491.82

491.82

491.82

491.82

491.82

491.82

491.82

491.82

481.47

465.94

460.76

450.41

445.23

440.23

433.35

423.03

485.57

469.29

463.79

452.80

447.60

442.57

434.66

424.10

10.35

25.88

31.06

41.41

46.59

51.59

58.47

68.79

6.25

22.53

28.03

39.02

44.22

49.25

57.16

67.72
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

30 of 57

A comparison of the attainment inventory with the emissions that result from the removal of the 

Gasoline Marketing Rule, confirm that conventional gas emissions remain below those in the 

attainment inventory. After calculating the margin for both Georgia Gas and conventional gas, the 

margin allotted to the switch to conventional gasoline is shown in Table 3-12, at 1.31 tons/day or just 

2.24% of the margin in 2024.

Table 3-12. Margin Allotted to Conventional Gasoline

Year Georgia Gas 

Margin

(VOC)

Conventional Gas 

Margin

(VOC)

Amount of Margin Allotted to 

Switch to Conventional 

Gasoline

% of Margin Allotted to 

Switch to Conventional 

Gasoline

tpd tpd tpd %

2010

2013

2014

2016

2017

2020

2024

2030

10.35

25.88

31.06

41.41

46.59

51.59

58.47

68.79

6.25

22.53

28.03

39.02

44.25

49.25

57.16

67.72

4.10

3.35

3.03

2.39

2.37

2.34

1.31

1.07

39.57

12.93

9.76

5.77

5.08

4.54

2.24

1.56

3.4.3 Total NOxEmissions and the 2008 Attainment Inventory

Figure 3-11 shows that there is no discernable difference in the total NOx emissions inventory 

between Georgia Gasoline and conventional gasoline; and compared to the 2008 attainment 

inventory, both stay well below. 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

31 of 57

50

150

250

350

450

550

650

750

850

2010 2015 2020 2025 2030 2035 2040

NOx Emissions (tons/day)

Year

PM2.5 NOx On-Road Emissions Inventory:

Georgia Gasoline and Conventional Gasoline Total Inventory vs. 2008 

Attainment Inventory

Total Inventory Georgia Gasoline Total Inventory Conventional Gas

Total 2008 Attainment Inventory

Figure 3-11: Comparison of Total NOx Emissions Inventory: Georgia Gasoline and 

Conventional Gasoline vs. 2008 Attainment Inventory

Table 3-13 shows the difference between the total NOx emissions inventory for both Georgia Gas and 

for conventional gasoline and resulting safety margins. By demonstrating that the margin of safety is 

well below the attainment inventory for both scenarios, the removal of Georgia Rule (bbb) is shown

not to impact the ability of Atlanta to remain below the 1997 annual NAAQS standard for PM2.5. 

This safety margin is the difference between forecasted actual emissions and the level (attainment 

emission level or “overall attainment inventory”) at which an increase in emissions could indicate a 

scenario where the area could fall into possible nonattainment with the 1997 annual PM2.5 standard. 

The year 2008 is being used here for PM2.5 (in lieu of 2002) because it represents when Atlanta 

attained the 1997 PM2.5 standard based on ambient monitoring, and overall emissions levels (all 

sectors, not just on-road where the baseline year of 2002 or MVEBs matter most) that year make up 

the “attainment inventory”. 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

32 of 57

Table 3-13. 1997 PM2.5 NAA Inventory Comparison to Georgia Gas Margin and 

Conventional Gas Margin

Year Total 2008 

NOx

Attainment 

Inventory

Total NOx

Emissions 

Inventory with 

Georgia Gasoline

Total NOx Emissions 

Inventory with 

Conventional Gasoline

Georgia Gas 

Margin 

Conventional Gas 

Margin

tpd tpd tpd tpd tpd

2014

2016

2017

2020

2024

2030

743.92

743.92

743.92

743.92

743.92

743.92

539.48

471.44

437.42

391.43

330.22

238.40

539.80

471.72

437.68

391.66

330.27

238.44

204.44

272.48

306.50

352.49

413.70

505.52

204.12

272.20

306.24

352.26

413.65

505.48

A comparison of the attainment inventory with the emissions that result from the removal of the 

Gasoline Marketing Rule, confirm that conventional gas emissions remain below those in the 

attainment inventory. After calculating the margin for both Georgia Gas and conventional gas, it is 

important to evaluate the amount of the margin allotted to the removal of the Gasoline Marketing 

Rule and more specifically the switch to conventional gasoline. In Table 3-14, the increase in 

emissions with Gasoline Marketing rule removal is 0.05 tons/day or just 0.01% of the margin in 

2024. As with Table 3-3 a small portion of Putnam County is considered in this non-attainment area 

along with 20 full counties for the 1997 PM2.5 annual NAAQS standard.

Table 3-14. Margin Allotted to Conventional Gasoline

Year Georgia 

Gas 

Margin

Conventional 

Gas Margin

Amount of Margin 

Allotted to Switch to 

Conventional 

Gasoline

% of Margin 

Allotted to Switch to 

Conventional 

Gasoline

tpd tpd tpd %

2014

2016

2017

2020

2024

2030

204.44

272.48

306.50

352.49

413.70

505.52

204.12

272.20

306.24

352.26

413.65

505.48

0.32

0.28

0.26

0.23

0.05

0.04

0.15

0.10

0.08

0.07

0.01

0.01
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

33 of 57

4.0 Georgia Rule 391-3-1-.02(mmm), NOxEmissions from Stationary Gas Turbines and 

Stationary Engines used to Generate Electricity

As stated in Section 1.0 above, 110(l) of the CAA requires that a SIP revision not interfere with any

applicable requirement concerning attainment, and reasonable further progress (as defined in section 

171 and 182 of the CAA). 

4.1 Purpose of the Rule Revision

On March 25, 2014, the Georgia Board of Natural Resources (DNR Board) adopted revisions to 

Georgia Rule 391-3-1-.02(2)(mmm), “NOX Emissions from Stationary Gas Turbines and Stationary 

Engines used to Generate Electricity” that added subparagraph 8 pertaining to stationary engines at 

data centers.

Rule (mmm) was adopted by the DNR Board and submitted to EPA as part of Georgia’s October 28, 

1999, serious attainment plan for the 1-hour ozone NAAQS, and the revised plan dated July 17, 

2001. Similar to the Gasoline Marketing Program described in section 3.0, Rule (mmm) is 

applicable to 45 counties (area of influence) in and around metro Atlanta. The 45-county area of 

influence includes the following counties: Banks, Barrow, Bartow, Butts, Carroll, Chattooga, 

Cherokee, Clarke, Clayton, Cobb, Coweta, Dawson, Dekalb, Douglas, Fayette, Floyd, Forsyth, 

Fulton, Gordon, Gwinnett, Hall, Haralson, Heard, Henry, Jackson, Jasper, Jones, Lamar, Lumpkin, 

Madison, Meriwether, Monroe, Morgan, Newton, Oconee, Paulding, Pickens, Pike, Polk, Putnam, 

Rockdale, Spalding, Troup, Walton, and Upson. The 45-county area of influence consists of the 20-

county 8-hour ozone maintenance area for the 1997 ozone NAAQS plus an additional 25 

surrounding counties that are attaining the standard. 

Section 3.2.1.1.5.b. of the 2001 attainment plan explains the purpose of this new rule (mmm). The 

rule was developed and has been implemented to reduce emissions from stationary engines that tend 

to operate during high electricity demand days. These engines are referred to as “peaking engines”.

Engines that are used solely for emergency power outages were not subject to the emission limits of 

the rule. This emergency generator exemption is found in existing subparagraph 7 with the 

definition of the type of engine and turbine that qualify in subparagraph 4.(i) as follows:

Emergency standby stationary gas turbines and stationary engines” means any stationary gas 

turbine or stationary engine that operates only when electric power from the local utility is 

not available and which operates less than 200 hours per year.

Prior to the March 25, 2014, revision to rule (mmm), emergency generators at data centers were 

required to operate in accordance with the definition of emergency standby engines found in 

subparagraph 4.(i) However, these units at data centers have an operational need that differs slightly 

from that envisioned when rule (mmm) was originally adopted. Data centers are equipped with 

uninterruptable power supplies (UPSs). During a power outage, the data centers will receive power 

from the UPSs and not the generators, as envisioned by the definition of emergency standby 

engines. Instead the generators need to operate when the UPSs fail or become unreliable. Also, in 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

34 of 57

order to retain reliability, emergency generators at data centers need to be operated for routine testing 

and maintenance.

4.2 Rule Revision and Prevention of Increase in Emissions – Ozone NAAQS

As a result of these difficulties, EPD added subparagraph 8 to specifically address the needs of data 

centers. The limit on hours of operation for data centers is 500 hours per year, compared to 200 

hours per year for emergency standby engines, in order to meet contractual, regulatory, and/or legal 

requirements. The new data center provision also limits routine testing and maintenance to the hours 

of 10 p.m. and 4 a.m., a time of day in which ozone formation does not occur during the May 

through September ozone season. The new provision requires recordkeeping to ensure compliance 

with the provisions of the rule. The new subparagraph 8. is shown below.

8. Stationary engines at data centers that meet all of the following criteria are not subject to 

the emission limitations in subparagraph 1:

(i) Operate only for routine testing and maintenance, when electric power from the local 

utility is not available, or during internal system failures; 

(ii) Total annual operation for the engine is less than 500 hours per year; 

(iii) Operation for routine testing and maintenance during the months of May through 

September occurs only between 10 p.m. to 4 a.m. Operation for routine testing and 

maintenance during the months of January through April and October through December 

may be done during any time of day; and 

(iv) The facility maintains records of all operation, including the reason for the operation.

As stated above, prior to the addition of the data center provision to Rule (mmm), generators at data 

centers were operated in accordance with the definition of emergency standby stationary engines. 

Such engines are exempt from permitting in accordance with 391-3-1-.03(6)(b)11(i). Since such 

engines are not required to be permitted, EPD does not have specific information on the number or 

capacity of generators at data centers. The generators at data centers remain exempt from permitting 

in accordance with 391-3-1-.03(b)(6)(b)11(iii) provided that the total horsepower of all engines at a 

facility remain below 1500 horsepower and no engine operates for more than 1000 hours per year.

4.3 Rule Revision – PM2.5 NAAQS

In the Final Redesignation of the Rome, Georgia Nonattainment Area for the 1997 Annual Fine 

Particulate Matter to Attainment on May 14, 2014 [79 FR 27493 through 27496], EPA agrees that 

amending Georgia Rule 391–3–1–.02(2)(mmm) is an expected minimal increase and unlikely to 

interfere the attainment of the PM2.5 air quality standard. 

“Subsequent to publication of the proposed rule, GA EPD notified EPA that the Georgia 

Board of Natural Resources had modified Georgia Rule 391–3–1–.02(2)(mmm) entitled 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

35 of 57

‘‘NOx Emissions from Stationary Gas Turbines and Stationary Engines used to Generate 

Electricity’’ to exempt certain engines at data centers from the rule’s NOx limits...

GA EPD adopted Georgia Rule 391–3–1–.02(2)(mmm) as a statewide ozone control 

measure3

, and the recent amendment exempts stationary engines at data centers from the 

rule’s NOx emission limits provided that the engines operate for less than 500 hours per year 

and only for routine testing and Maintenance (limited to May through September between 10 

p.m. and 4 a.m.), when electric power from a utility is not available, or during internal 

system failures. These data centers are equipped with uninterruptable power supplies (UPSs) 

that supply electricity during a power outage, and the exempted engines are designed to 

provide power only when the UPSs malfunction. Given the nature of the exempted engines 

and the conditions necessary to qualify for the exemption, any emissions increase is likely 

negligible...EPA has concluded that the changes to the aforementioned rules do not affect 

the Agency’s decision to approve the redesignation request and maintenance plan for the 

Rome Area. Any increase in modifications is expected to be minimal and well within the 

margin necessary to maintain attainment of the 1997 Annual PM2.5 standard.”

EPA has agreed with this assessment for the Final Redesignation of the Macon, Georgia 

Nonattainment Area for the 1997 Annual Fine Particulate Matter to Attainment also, dated May 13, 

2014 [79 FR 27194 through 27196]. For the same reason that EPA concluded that the revision to 

Rule (mmm) did not affect their decision to approve the redesignation requests for Rome or Macon, 

this rule change will have no impact on the ability to attain or maintain ambient air quality standards 

in the Atlanta area. This rule revision does not change or impose a new emission limit on stationary 

engines at data centers. Stationary engines that operate as emergency standby stationary engines, 

which applied to data centers prior to the change, were exempt from the NOx emission limits of Rule 

(mmm). Under the revised rule, stationary engines at data centers are still exempt from the NOx

emission limits of Rule (mmm). Because the revision to the rule limits operation of data center 

generator engines to less than 500 hours per year and limits routine testing and maintenance 

operations to night-time hours (10 p.m. to 4 a.m.), a period during which ozone and fine particulate 

matter atmospheric photochemical formation does not occur, this change will not result in an 

emissions increase and thus has no impact on maintenance or attainment of the PM2.5 and ozone 

NAAQS.

 

3 It should be noted that rule (mmm) is not a statewide ozone control measure. Rule (mmm) only applies to 20 

counties that were designated nonattainment and 25 additional counties determined by EPD to contribute to 

nonattainment for the 1997 ozone NAAQS. Rome is located in Floyd County which is one of those 25 

additional counties. Monroe County, a portion of which is located in the Macon nonattainment area, is also 

one of the 25 additional counties.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

36 of 57

5.0 NOx and VOC Sensitivity

As stated in Section 1.0 above, 110(l) of the CAA requires that a SIP revision not interfere with any 

applicable requirement concerning attainment, and reasonable further progress (as defined in section 

171 and 182 of the CAA). This section will demonstrate that the emissions increases resulting from 

the removal of Georgia Rules (aaa) and (bbb) will insignificant to no impact on ozone 

concentrations in the Atlanta areas.

5.1 Sensitivity of Ozone in Atlanta to NOx and VOC Emissions

Control of NOx and VOC are generally considered the most important components of an ozone 

control strategy, and NOx and VOC make up the largest controllable contribution to ambient ozone

formation. However, the metro Atlanta nonattainment area has shown a greater sensitivity of groundlevel ozone to NOx controls rather than VOC controls. This is due to the biogenic nature of VOC 

emissions in Georgia. Therefore, implemented control measures have focused on the control of NOx

emissions. The Atlanta nonattainment area is NOx limited in such a way that changes in VOC 

emissions have little effect on ozone formation.

5.1.1 Sensitivity Modeling NOx and VOC Emissions

As part of the SouthEastern Modeling, Analysis, and Planning (SEMAP) project, Georgia Tech 

performed an analysis of the sensitivity of ozone concentrations in the Eastern U.S. to reductions in 

emissions of both nitrogen oxides (NOx) and volatile organic compounds (VOCs). This analysis was 

based off of the 2007 and 2018 SEMAP modeling which used CMAQ version 5.01 with updates to 

the vertical mixing coefficients and land-water interface. May 1st through September 30th was 

modeled using a 12-km modeling grid that covered the Eastern U.S. Details of the modeling 

platform set-up can be found in Appendix D.

5.1.2 Modeling Scenarios

Sensitivities were modeled relative to 2018 emissions to evaluate the impact of NOx and VOC 

reductions on daily 8-hour maximum ozone concentrations. Each emission sensitivity run reduced 

the 2018 anthropogenic NOx or VOC emissions (point, area, mobile, NONROAD, 

marine/aircraft/rail) within a specific geographic region by 30%. 

Georgia EPD performed a sensitivity study with the information provided by the SEMAP modeling 

project and the Georgia Tech analysis to examine the normalized sensitivities of NOx and VOC 

emissions on 8-hour daily maximum ozone concentrations (part per billion ozone/ton per day, 

ppt/TPD) at 10 ozone monitors in Atlanta. EPD used a 75 parts per billion (ppb) threshold to 

address the 2008 ozone NAAQS. For further details on the approach used to calculate the 

normalized sensitivities of NOx and VOC, please see Appendix C. 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

37 of 57

5.1.3 Modeling Results

Table 5-1. Normalized NOx and VOC Sensitivity at 10 Atlanta Ozone Monitors

AIRS ID Site Name NOx (ppb/TPD) VOC (ppb/TPD)

13-067-0003 Kennesaw -0.0743 -0.0045

13-077-0002 Newnan -0.0806 -0.0018

13-085-0001 Dawsonville -0.0622 -0.0007

13-089-0002 South DeKalb -0.0771 -0.0058

13-097-0004 Douglasville -0.0797 -0.0042

13-121-0055 Confederate Ave. -0.0612 -0.0077

13-135-0002 Gwinnett -0.0763 -0.0026

13-151-0002 McDonough -0.0869 -0.0034

13-223-0003 Dallas /Yorkville -0.0693 -0.0011

13-247-0001 Conyers -0.0898 -0.0031

AVERAGE (ppb/TPD) -0.0757 -0.0035

The results in Table 5-1 above show that NOx emission reductions are generally 15-25 times more 

effective than VOC emission reductions at reducing ozone concentrations. In order to look at the

impact of removing NOx or VOC controls on the 2008 ozone NAAQS, the site-specific normalized 

sensitivities are multiplied by the increase in NOx and/or VOC emissions.

The site-specific normalized NOx and VOC sensitivities were applied to the expected emission 

increases due to the removal of the Consumer and Commercial Products Rule, Georgia Rule (aaa) 

and the Gasoline Marketing Rule, Georgia Rule (bbb). The emission increases are based on 2013 

values and represent the largest impact as the emissions increase will decrease each successive year. 

The removal of the Georgia Rule (aaa) results in an increase of VOC emissions of 0.17 tons per day 

in 2013. The removal of Georgia Rule (bbb) results in an increase of 5.03 tons per day of VOC in 

2013 for the 45-county area decreasing over time to 1.76 tons per day by 2040; while NOx emissions 

increase to 3.20 tons per day in the 45-county decreasing over time to zero by 2040. The 

corresponding ozone increases at each monitor are found in Table 5-2 and demonstrate very 

insignificant increases in ozone concentrations. The calculated changes in ozone levels are below 

the level of precision of the ambient ozone monitors (1 ppb).
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

38 of 57

Table 5-2. Emissions Increases Due to Georgia Rules (aaa) and (bbb) and Effects on Ozone 

Formation

Monitor Rule (aaa) Rule (bbb) Combined

2013 

VOC 

Emissions 

Increase 

with 

Removal 

of 

Georgia 

Rule 

(aaa)

(tons/day)

Corresponding 

Ozone 

Increase at 

Monitor

(ppb)

2013 NOx

Emissions 

Increase with 

Conventional 

Gas

(tons/day)

Corresponding 

Ozone 

Increase at 

Monitor

(ppb)

2013 VOC 

Emissions 

Increase with 

Conventional 

Gas

(tons/day)

Corresponding 

Ozone 

Increase at 

Monitor

(ppb)

Corresponding 

Ozone 

Increase at 

Monitor

(ppb)

Kennesaw 0.17 0.0077 2.08 0.1545 5.03 0.0226 0.1848

Newnan 0.17 0.0003 2.08 0.1676 5.03 0.0091 0.1770

Dawsonville 0.17 0.0001 2.08 0.1294 5.03 0.0035 0.1330

South 

DeKalb

0.17 0.0010 2.08 0.1604 5.03 0.0292 0.1906

Douglasville 0.17 0.0007 2.08 0.1658 5.03 0.0211 0.1876

Confederate 

Ave.

0.17 0.0013 2.08 0.1273 5.03 0.0387 0.1673

Gwinnett 0.17 0.0004 2.08 0.1587 5.03 0.0131 0.1722

McDonough 0.17 0.0006 2.08 0.1808 5.03 0.0171 0.1985

Dallas 

/Yorkville

0.17 0.0002 2.08 0.1441 5.03 0.0055 0.1498

Conyers 0.17 0.0005 2.08 0.1868 5.03 0.0156 0.2029
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

39 of 57

6.0 Emission Offsets

In cases where VOC or NOx emissions have increased due to the removal of a rule or a program in a 

nonattainment area, offset measures may be considered in a state’s 110(l) demonstration. If an offset 

measure is used, it must be reproducible, enforceable, surplus, quantifiable, and a permanent 

measure. The emission reduction must also not otherwise be relied upon to meet air quality 

attainment requirements in other air quality programs related to the SIP. 

6.1 Emissions Increase 

As indicated in section 2.1.1, the removal of the Georgia Rule (aaa) results in an increase of VOC 

emissions of 0.17 tons per day in 2013 resulting in an equivalent ozone season increase in emissions 

of 42.54 tons.

The removal of Georgia Rule (bbb), is shown in sections 3.1.1 and 3.1.2 and results in an increase of 

5.66 tons per day of VOC in 2013 for the 45-county area decreasing over time to 1.94 tons per day 

by 2040; while NOx emissions increase to 2.12 tons per day in the 45-county decreasing over time to 

zero by 2040. The removal of Georgia Rule (bbb) will not be approved by EPA until 2015, and the 

gasoline suppliers will continue to comply with the rule until that time. Therefore, for purposes of 

calculating offsets, Georgia EPD is interpolating between 2013 and 2016 for the 2015 emissions 

increase as shown in Table 6-1.

Table 6-1. Interpolation of Emissions Increase Due to Georgia Rule (bbb)

2013 NOx

(tons/day)

2013 VOC

(tons/day)

2015 NOx

(tons/day)

2015 VOC

(tons/day)

2016 NOx

(tons/day)

2016 VOC

(tons/day)

2.12 5.66 1.66 4.61 1.43 4.08

The revision to rule (mmm) adds a provision that allows engines that were previously classified as 

“emergency generators” to be operated in accordance with a new provision for “data centers”. Since 

emergency generators are not subject to the emission limits in rule (mmm), reclassifying these units 

as data center engines will not result in any increase in emissions.

Section 5 addresses the ozone formation in the Atlanta area and the sensitivity to reductions of NOx

and VOC emissions, and since the Atlanta area is a NOx limited area, the control of NOx emissions 

result in greater reductions of ozone at the monitor. The maximum VOC emissions increase 

resulting from the removal of Rules (aaa) 0.17 and (bbb) is 4.06 tons per day, respectively. This 

increase in VOC emissions can be converted to an equivalent increase in NOx emissions based on the 

ratio of normalized ozone sensitivities found in section 5 as follows:

From Georgia Rule (aaa)

0.17 TPD VOC x (-0.0035 ppb/TPD VOC)/(-0.0757 ppb/TPD NOx) = 0.0079 TPD NOx
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

40 of 57

Converted to Ozone Season Emissions:

0.0079 TPD x 244 days = 1.92 tons of NOx

There are no NOx emissions increases from Georgia Rule (aaa).

From Georgia Rule (bbb)

4.61TPD VOC x (-0.0035 ppb/TPD VOC)/(-0.0757 ppb/TPD NOx) = 0.2131 TPD NOx

Converted to Number of Tons from the number of days the Rule is in effect*:

0.2131 TPD x 107 days = 22.81 tons of NOx

*Note: Georgia Rule (bbb) is in effect only from June 1 to September 15 of any calendar year, and 

therefore in effect only 107 days per year. 

By adding the actual NOx emissions increase to the equivalent NOx emissions increase from VOC 

emissions using the sensitivity calculation, the resulting NOx emissions increase leads to the needed 

emissions offset.

1.66 TPD x 107 days = 177.62 tons of NOx + 22.81 tons of sensitivity NOx

200.43 = tons of NOx offsets needed.

Table 6-2 summarizes the total offsets needed from both Georgia Rules (aaa) and (bbb).

Table 6-2. Emissions Offsets Needed from Removal of Georgia Rules (aaa) and (bbb)

Offsets Needed from 

Georgia Rule (aaa)

(tons)

Offsets Need from Georgia Rule 

(bbb)

(tons)

Total Offsets Needed

(tons)

1.92 200.43 202.35

6.2 Emissions Offset

Because of the temporary increase in NOx and VOC emissions in the nonattainment area due to the 

removal Rules (aaa) and (bbb), Georgia EPD is securing NOx emissions offsets to ensure that both 

the original 13-county 1990 1-hour ozone maintenance area, the 1997 20-county ozone maintenance 

area, and the 1997 22-county4 PM2.5 maintenance area remain in attainment with their respective 

 

4 20 entire counties plus 2 partial counties.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

41 of 57

NAAQS and that the rule removal will not interfere with attainment of the 2008 ozone NAAQS for 

the 15 county Atlanta nonattainment area. Georgia proposes to demonstrate noninterference by 

substituting the quantifiable, permanent, surplus, enforceable and contemporaneous 

measures described herein to achieve equivalent or greater emission reductions to offset 

these expected emission increases. The following is an analysis and calculations to 

determine the offsets needed to address the removal of the Rule (bbb) in 45 counties that 

encompass each of these maintenance and nonattainment area and the removal of Rule (aaa) 

in the 13 counties of the 1-hour ozone maintenance area, which is included within the 1997 

and 2008 maintenance and nonattainment areas. As described more fully in this submission, 

a minimum of 202.35 tons of NOx emission reductions will be achieved through 

implementation of the Locomotive Conversion Program5 and school bus early 

replacements6. As such, these measures will fully offset the expected emission increases 

associated with the removal of Rules (aaa) and (bbb).7 

This SIP revision obligates the State to fully implement the Locomotive Conversion 

Program and is detailed in: 1) the attached Norfolk Southern Railway Company Scope of

 

5 The Locomotive Conversion Program will result in the: 

• Conversion of 20 Norfolk Southern Railway locomotives in the Atlanta area from Tier 0 or lower 

locomotives with at least five years of expected remaining life, to ten mother/slug sets, where the 

“mother” locomotive will be ECO710 3,000 horsepower locomotives meeting EPA Tier 3 switch-duty 

emission standards or better (i.e., with lower emissions) to be completed by October 30, 2015;

• Installation of locomotive technology to accommodate an electric layover system on the converted 

Norfolk Southern Railway locomotives and install plug-in stations and associated yard infrastructure 

to operate an electric layover heating system at the Norfolk Southern Atlanta Terminal in Atlanta, 

Georgia; and 

• Conversion of six CSX Transportation locomotives in the Atlanta Area from Tier 0 or a lower rating 

to 3,000 horsepower locomotives meeting EPA Tier 3 Line-haul and Tier 2 Switch emission standards 

or better (i.e., with lower emissions) to be completed by October 15, 2016.

• Conversion of two Norfolk Southern Railway locomotives in the Rome area from Tier 0 or lower 

locomotives with at least five years of expected remaining life, to two mother/slug sets, where the 

“mother” locomotive will be ECO710 3,000 horsepower locomotives meeting EPA Tier 3 switch-duty 

emission standards or better (i.e., with lower emissions) to be completed by November 23, 2015.

6 School bus early replacements resulting in 5.08 tons per year of NOx reductions in the 45-county area were 

completed in 2014. 

7 Georgia EPD notes that the Atlanta Area is NOx-limited, so the impact on ozone formation of reducing NOx 

emissions is greater than it is for reducing emissions of VOCs. Accordingly, for purposes of calculating the 

emissions reductions necessary to offset the removal of Rules (aaa) and (bbb) from the SIP, Georgia is relying 

on NOx emission reductions. As described in this SIP revision, Georgia performed a sensitivity analysis to 

calculate the NOx equivalent emissions reductions necessary to offset the expected emissions increase in NOx 

and VOCs associated with removal of Rules (aaa) and (bbb). Georgia EPD further notes that the impact of the 

NOx and VOC emissions increase on ambient PM2.5 concentrations is not expected to interfere with current 

progress toward attainment of the 1997 Annual PM2.5 standard.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

42 of 57

Work for Atlanta, Paragraphs A through C; 2) the attached CSX Transportation, Inc., Scope 

of Work, Paragraphs A through C; and 3) the attached Norfolk Southern Railway Company 

Scope of Work for Rome, Paragraphs A through C. These attachments are included as part 

of this SIP revision. The Georgia Department of Natural Resources has entered into 

contracts with the Norfolk Southern Railway Company (contracts date April 29, 2014 and 

November 25, 2014) and CSX Transportation, Inc. (contract date August 19, 2014), to 

complete this work. In total, the Locomotive Conversion Program will result in at least 

199.20 tons of NOx reductions by no later than October 15, 2016. More detail is provided 

below.

In addition, Georgia will make publically available the reports described in the attached 

Scope of Work documents, Paragraphs D through G. All future reports submitted to the 

Georgia Department of Natural Resources pursuant to these Scope of Work documents shall 

be transmitted to EPA within 30 days of receipt by the Department.

.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

43 of 57

6.2.1 Locomotive and Diesel Retrofit Conversion Offsets

Georgia EPD has both a locomotive retrofit program and a diesel school bus early replacement

program. These programs will provide adequate emissions reductions to be used for offsets for the 

removal of Georgia Rules (aaa) and (bbb).

Locomotive Retrofits:

Georgia EPD has been working with the railroad industry to retrofit existing diesel locomotive

engines with lower emitting locomotive engines. 

The locomotive emission reduction program underway in Georgia is expected to reduce 199.20 tons 

of NOx per year for 10 years or more. These projects are funded through the US DOE Congestion 

Mitigation and Air Quality Program (CMAQ) and established though project awards from the GA 

DOT to the GA EPD and executed contracts between the GA EPD and Norfolk Southern Railway, 

Inc. and CSX. The Atlanta projects represent $24,000,000.00 in CMAQ funding and $10,290,000.00 

in private match from the railroads invested in implementing these low-emission technologies. The 

Rome project represents $900,000.00 in CMAQ funding and $1,452,000.00 in private match.

Locomotives have very large engines (3000 – 3500 hp in these projects) and traditionally run on 

‘locomotive-grade’ non-road diesel with resulting high emissions of PM, NOx, and VOC. Under the

CMAQ projects, 17 older traditional switcher locomotives, which operate 24-hours per day yearround, are repowered with newly-available low-emission engines. In addition, 11 switchers will be 

converted to ‘slugs’, which are driven by electrical motors whose electricity is received from 

companion ‘mother’ locomotives. (This configuration is referred to as ‘mother-slug’ locomotives.) 

The slugs will have no associated diesel-combustion emissions. 

As shown in Table 6-3, the emission reductions are phased in over 3 years starting in 2014, fitting 

into the March 2014 to September 2016 contemporaneous period. 

Table 6-3. Locomotive Conversion Schedule

Conversion Period Number of Locomotives 

Repowered

Number of Locomotives 

Converted to Slugs

Nov- Dec 2014 2 2

Feb – Oct 2015 8 8

during or before Nov 2015 1 1

May – Aug 2016 6 0
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

44 of 57

NOx reductions from the locomotive reductions will yield 190.78 tons/year in Atlanta and 8.42 

tons/year in Rome for a total of 199.20 tons/yr. Further details on the locomotive reductions can be 

found in Appendix E.

The converted low-emission locomotives are required to remain in the assigned operating areas (in 

and near the rail yards) for at least 10 years after entering revenue service. Of note, other states that 

have supported locomotive emission reductions through the CMAQ program have had 2 to 5 year 

commitment periods. We are unaware of any other state that was able to secure 10-year periods of 

commitment. 

During this 10-year period, 2008 Federal Locomotive Emission Standards are phasing in (EPA Fact 

Sheet EPA-420-/f-09-025 (Table 2). April 2009.). While locomotive fleets have a slow turnover (20 

to 40 years for a Class 1 switcher locomotive), they are re-manufactured every 15 to 20 years and 

must be brought up to standards at that time. According to the Regulatory Impact Analysis released 

with the 2008 Locomotive Standards, reductions from large railroad switch locomotives by the end 

of the 10 year period (2025) is estimated to be 11,886 tons of NOx for the national fleet of 5206 

switchers (page 3-79, section 3.3.2.2 and table 3-88, of the Regulatory Impact Analysis: Control of 

Emissions of Air Pollution from Locomotive Engines and Marine Compression Ignition Engines 

Less than 30 Liters Per Cylinder (RIA)). Scaling this to the approximately 30 switchers in Norfolk 

Southern’s Inman Yard and 10 switchers in CSX’s Tilford yard, the switcher fleet upgrades will 

reduce, on average, emissions of ~91 tons/year of NOx. This does not account for the additional 

large emission reductions anticipated from the line-haul traffic that moves through the Atlanta 

railyards. By 2025, the increased emissions from removing GA Rule 391-3-.02(2)(aaa) (consumer 

products) and 391-3-.02(2)(bbb) is estimated to be only ~38 tons/year so the stricter standards in 

2025 will more than offset the increase in emissions that would be expected with rules removal. 

Further, Class I railroads assign the more advanced fleets to their large, urban, complex yards such as 

in Atlanta. These locomotives often have specialized equipment installed to aid in their control and 

operation. For example, the Norfolk Southern locomotives converted under the GA EPD CMAQ 

program will have an Electric Layover Heating System installed so that they can be plugged into 

power systems installed in the yard to reduce the need for idling. It is highly unlikely that these 

locomotives will be transferred even after the 10-year commitment period expires. 

Conversion schedules for this retrofit program can be found in Appendix E.

School Bus Early Replacement:

Georgia EPD also has a strong school bus early replacement program. Recently completed 2014 

projects funded by DERA and CMAQ grants, have resulted in NOx emissions reductions of 5.08 tons 

per year in the 45-county area covered by Rule (bbb). Calculations of NOx emissions within the 

contract time frame of the emission reduction can be found in Appendix E. 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

45 of 57

6.3 Offset Equivalency Demonstration

Based on the amount of offsets available from school bus early replacements and railroad locomotive 

engine retrofits, Georgia EPD has offsets in excess of the increase in emissions due to the removal of 

Georgia Rules (aaa) and (bbb). Tables 6-2 through 6-6 show in detail the emission increases and the 

available offsets for comparison. 

Table 6-5. Emissions Decrease Due to All Retrofits

Source of Offset Locomotive Retrofits School Bus 

Replacements

Total Decrease

NOx Emissions 

Decrease 

(tons/year) 199.20 5.08 204.28

The offsets available from both bus replacements and rail locomotive diesel retrofits totals 204.28

tons per year of NOx. 

As shown in Table 6-6, the annual NOx decrease from the school bus replacements and locomotive 

retrofits are more than adequate to offset the maximum NOx and VOC increase expected from the 

repeal of rules 391-3-1-.02(2)(aaa) and (bbb). The increase in emissions from removal of these rules 

is at a maximum immediately following their repeal and gradually decreases over time.

Table 6-6. Emissions Increases Compared to Available Emissions Offsets

Emissions Increases 

Due to Georgia Rule 

(aaa)

(tons)

Emissions 

Increases Due to 

Georgia Rule 

(bbb)

(tons)

Total Emissions 

Increase from 

Rule Removals

(tons)

Total Available 

Offsets

(tons)

1.92 200.43 202.35 204.28
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

46 of 57

7.0 Contingency Measures

All of the school bus early replacements that will be used as offsets have already occurred in a 

contemporaneous timeframe, and therefore meet the requirement that offsets be reproducible, 

enforceable, surplus, quantifiable, and permanent. However, some of the locomotive retrofits 

(although cotemporaneous) will occur after this SIP revision is submitted to U.S. EPA. Therefore, 

Georgia EPD is putting into place a contingency measure for the likelihood that some of the 

locomotive retrofits are not completed. This contingency measure will ensure that sufficient 

substitute emission reductions occur to replace any emission reductions that would not be realized by 

locomotive retrofits not be completed. 

7.1.1 Contingency Provisions - Stationary Source Offsets

On December 30, 2013, Georgia Power Company submitted a construction application to Georgia 

EPD for Yates Steam – Electric Generating Plant in Newnan, Georgia. Existing coal-fired Units 6 

and 7 are to be modified to operate at 100% natural gas, and upon completion of the project existing 

coal-fired Units 1, 2, 3, 4, and 5 will be retired. The net decrease in NOx emissions at the facility is 

9,123.7 tons per year. The actual decrease in NOx emissions from Units 1 through 5 will be 7435.0 

tons per year. Georgia Power is not relying on the NOx decrease from retiring Units 1 through 5 to 

net out of or avoid any applicable requirements (including nonattainment NSR). Furthermore, EPD 

has not relied on the retirement of Units 1 through 5 in any SIP revisions or any NAAQS attainment 

or maintenance requirements. Units 1 through 5 will be permanently retired by April 16, 2015.

The facility’s Title V permit modification was issued August 29, 2014. Since the emissions 

reduction from the retirement of Units 1 through 5 is significantly larger than the emissions increase 

from the removal of Rules (aaa) and (bbb), EPD only needs to rely on the emissions decrease from 

one of the units for offsetting emissions. EPD has elected to use the emission reductions from Plant 

Yates Unit 3 for offsetting emissions. 

REGULATORY REQUIREMENTS:

In order to determine the amount of emissions reductions resulting from the shutdown of Plant Yates 

Unit 3 available for use as offsets, EPD used the provisions of Appendix S to Part 51 - Emission 

Offset Interpretative Ruling to conduct an evaluation.

Section IV.C. of Appendix S defines the Baseline for determining credit for emissions and air quality 

offsets in the following manner:

The baseline for determining credit for emission and air quality offsets will be the SIP emission 

limitations in effect at the time the application to construct or modify a source is filed. Thus, credit 

for emission offset purposes may be allowable for existing control that goes beyond that required by 

the SIP. Emission offsets generally should be made on a pounds per hour basis when all facilities 

involved in the emission offset calculations are operating at their maximum expected or allowed 

production rate. The reviewing agency should specify other averaging periods (e.g., tons per year) in 

addition to the pounds per hour basis if necessary to carry out the intent of this Ruling. When offsets 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

47 of 57

are calculated on a tons per year basis, the baseline emissions for existing sources providing the 

offsets should be calculated using the actual annual operating hours for the previous one or two year 

period (or other appropriate period if warranted by cyclical business conditions). Where the SIP 

requires certain hardware controls in lieu of an emission limitation (e.g., floating roof tanks for 

petroleum storage), baseline allowable emissions should be based on actual operating conditions for 

the previous one or two year period (i.e., actual throughput and vapor pressures) in conjunction with 

the required hardware controls.

In Section IV.C. of Appendix S, offsets created through shutting down an existing source, must 

adhere to the following requirements:

3. Emission Reduction Credits from Shutdowns and Curtailments.

(i) Emissions reductions achieved by shutting down an existing source or 

curtailing production or operating hours may be generally credited for 

offsets if they meet the requirements in paragraphs IV.C.3.i.1. through 2 of 

this section.

(1) Such reductions are surplus, permanent, quantifiable, and federally 

enforceable.

(2) The shutdown or curtailment occurred after the last day of the base year 

for the SIP planning process. For purposes of this paragraph, a 

reviewing authority may choose to consider a prior shutdown or 

curtailment to have occurred after the last day of the base year if the 

projected emissions inventory used to develop the attainment 

demonstration explicitly includes the emissions from such previously 

shutdown or curtailed emission units. However, in no event may credit 

be given for shutdowns that occurred before August 7, 1977.

(ii) Emissions reductions achieved by shutting down an existing source or 

curtailing production or operating hours and that do not meet the 

requirements in paragraphs IV.C.3.i.1. through 2 of this section may be 

generally credited only if:

(1) The shutdown or curtailment occurred on or after the date the new 

source permit application is filed; or

(2) The applicant can establish that the proposed new source is a 

replacement for the shutdown or curtailed source, and the emissions 

reductions achieved by the shutdown or curtailment met the requirements of 

paragraphs IV.C.3.i.1. through 2 of this section.

BASELINE EMISSIONS:

The provisions for determining baseline credit specified in Appendix S states that the SIP limits are 

in effect when a permit application is submitted. The requested SIP revision does not involve 

permitting activity, so this definition is not directly applicable. However, Georgia EPD is submitting 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

48 of 57

a SIP for the revision and the removal of several air quality rules. Thus, EPD will use the SIP limits 

in place at the time of submittal of the SIP revision. The emissions increase from the SIP revision 

has been determined on a ton per year basis. However, some of the limitations are on a 30-day 

rolling average basis. Thus, the analysis is carried out based on annual emission rates and, where a 

30-day rolling average applies, monthly emission rates. The baseline provision also states that 

baseline emissions should be calculated using actual annual operating hours for the previous one or 

two year period (or other appropriate period if warranted by cyclical business conditions). EPD has 

used the two most-recent available calendar year period (2012 and 2013) for calculating baseline 

emissions. This data was obtained from EPA’s Clean Air Markets Program Data website. Baseline 

emissions for 2012 were 688 tons. Baseline emissions for 2013 were 632 tons. The average baseline 

emissions for this 2-year period are 660 tons/year.

Tables 7-1 through 7-3 show the baseline NOx emissions of Plant Yates Unit 3 for 2012 at 687.70 

tons per year and for 2013 at 631.34 tons per year with a resulting annual average emissions baseline 

for 2012-2013 as 659.62 tons.

Table 7-1. Plant Yates Unit 3 Emissions Baseline For 2012

Facility 

Name

Facility 

ID 

(ORISPL)

Unit 

ID

Year Month Average 

NOx Rate 

(lb/MMBtu)

NOx

(tons)

Heat 

Input 

Rate 

(MMBtu)

Operating 

Time

Yates 728 Y3BR 2012 1 0.3439 62.274 358224.7 703.50

Yates 728 Y3BR 2012 2 0.3172 54.950 347173.9 671.50

Yates 728 Y3BR 2012 3 0.3615 86.559 449601.7 744.00

Yates 728 Y3BR 2012 4 0.3052 56.666 371056.0 720.00

Yates 728 Y3BR 2012 5 0.2746 54.091 392058.9 744.00

Yates 728 Y3BR 2012 6 0.2782 14.377 103071.7 211.25

Yates 728 Y3BR 2012 7 0.2532 48.787 382052.6 744.00

Yates 728 Y3BR 2012 8 0.2599 50.466 386369.9 744.00

Yates 728 Y3BR 2012 9 0.2552 51.948 406316.0 720.00

Yates 728 Y3BR 2012 10 0.2977 54.004 355901.8 646.75

Yates 728 Y3BR 2012 11 0.3833 82.964 424649.2 720.00

Yates 728 Y3BR 2012 12 0.3301 70.616 426410.4 744.00

Yates 728 Y3BR 2012 All 687.702
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

49 of 57

Table 7-2. Plant Yates Unit 3 Emissions Baseline For 2013

Facility 

Name

Facility 

ID 

(ORISPL)

Unit 

ID

Year Month Average 

NOx Rate 

(lb/MMBtu)

NOx

(tons)

Heat 

Input 

Rate 

(MMBtu)

Operating 

Time

Yates 728 Y3BR 2013 1 0.4881 109.57 444385.9 744.00

Yates 728 Y3BR 2013 2 0.4173 86.65 415304.8 672.00

Yates 728 Y3BR 2013 3 0.4508 105.17 465671.8 744.00

Yates 728 Y3BR 2013 4 0.4280 95.97 447970.6 720.00

Yates 728 Y3BR 2013 5 0.2600 58.73 450211.5 744.00

Yates 728 Y3BR 2013 6 0.2310 45.93 387750.5 720.00

Yates 728 Y3BR 2013 7 0.2571 52.44 404768.0 744.00

Yates 728 Y3BR 2013 8 0.3430 77.06 430355.7 500.75

Yates 728 Y3BR 2013 9

Yates 728 Y3BR 2013 10

Yates 728 Y3BR 2013 11

Yates 728 Y3BR 2013 12

Yates 728 Y3BR 2013 All 631.53

Table 7-3. Plant Yates Unit 3 Annual Average Emissions Baseline For 2012 - 2013

Facility Name Facility ID 

(ORISPL)

Unit ID Year NOx (tons) Annual Average 

Emissions Baseline 

Yates 728 Y3BR 2012 687.70

Yates 728 Y3BR 2013 631.53

Yates 728 Y3BR 2012 - 2013 659.62

SURPLUS:

Surplus is defined in 40 CFR 51.491 as “at a minimum, emissions reductions in excess of an 

established program baseline which are not required by SIP requirements or State regulations, relied 

upon in any applicable attainment plan or demonstration, or credited in any RFP or milestone 

demonstration, so as to prevent the double-counting of emissions reductions.” 

The shutdown of Yates Unit 3 has not been relied upon by any attainment plan or demonstration or 

credited in any RFP demonstration.

Yates Unit 3 is subject to the following SIP requirements and SIP-approved state regulations:

• Georgia Air Quality Control Rule 391-3-1-.02(2)(jjj), “NOx Emissions from Electric Utility 

Generating Units” [Rule (jjj)],

• 40 CFR Part 76, the Acid Rain Nitrogen Oxides Emission Reduction Program, and 

• The Clean Air Interstate Rule
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

50 of 57

For Georgia Rule (jjj), the surplus was determined by first considering the sections of rule that 

pertain to the facility. Plant Yates is located in Coweta County and is therefore subject to 

subparagraphs 3 and 5 of Rule (jjj). Both subparagraphs 3 and 5 state that each affected unit(s) shall 

not exceed the alternative emission limit established in the Title V permit for the affected units(s). 

The current alternative limits are found in condition 3.4.8 of Title V permit 4911-077-001-V-03-0 

issued July 27, 2010. Condition 3.4.8 establishes a combined 30-day rolling average emission limit 

of 0.38 lb/MMBtu from the combined emissions from Yates Units 2 and 3. 

Table 7-4. Plant Yates Units 2 and 3, Actual Emissions For 2012

Month Avg. NOx

Rate 

(lb/MMBtu) 

Unit 2

NOx

(tons) 

Unit 2

Heat Input 

(MMBtu) 

Unit 2

Avg. NOx

Rate 

(lb/MMBtu) 

Unit 3

NOx

(tons) 

Unit 3

Heat Input 

(MMBtu) 

Unit 3

NOx

(tons) 

Units 

2&3

Heat Input 

(MMBtu) 

Units 2&3

Avg. NOx

Rate 

(lb/MMBu) 

Units 2&3

Rule (jjj) 

limit 

(lb/MM

Btu)

1 0.384 37.41 190618.7 0.344 62.27 358224.7 99.69 548843.4 0.363

2 0.317 58.79 368492.0 0.317 54.95 347173.9 113.74 715665.9 0.318

3 0.362 85.95 445547.9 0.362 86.56 449601.7 172.51 895149.6 0.385

4 0.305 57.71 379976.0 0.305 56.67 371056.0 114.38 751032.0 0.305

5 0.275 54.67 397491.6 0.275 54.09 392058.9 108.76 789550.5 0.275 0.38

6 0.284 49.88 350706.8 0.278 14.38 103071.7 64.26 453778.4 0.283 0.38

7 0.253 49.96 387965.9 0.253 48.79 382052.6 98.75 770018.5 0.256 0.38

8 0.260 48.73 375171.8 0.260 50.47 386369.9 99.20 761541.7 0.261 0.38

9 0.255 44.33 347220.1 0.255 51.95 406316.0 96.28 753536.1 0.256 0.38

10 0.264 18.55 140419.9 0.298 54.00 355901.8 72.56 496321.7 0.292

11 0.383 82.96 424649.2 82.96 424649.2 0.391

12 0.330 70.62 426410.4 70.62 426410.4 0.331

Table 7-5. Plant Yates Units 2 and 3, Actual Emissions For 2013

A comparison of actual emissions from Yates Units 2 and 3 for the baseline period is compared to 

this limit in Tables 7-4 and 7-5. Actual emissions were obtained from EPA’s Air Markets Program 

Data website. Actual emissions were lower than the Rule (jjj) alternative limits for each of the 

months in which the rule was applicable. 

When considering the Acid Rain Nitrogen Oxides Emission Reduction Program (40 CFR Part 76), 

Yates Unit 3 is subject to a multi-state NOx averaging plan in accordance with 40 CFR 76.11. 

Condition 7.9.7 of Title V permit 4911-077-001-V-03-0 issued July 27, 2010, established an annual 

Month Avg. NOx

Rate 

(lb/MMBtu) 

Unit 2

NOx

(tons) 

Unit 2

Heat 

Input 

(MMBtu) 

Unit 2

Avg. NOx

Rate 

(lb/MMBtu) 

Unit 3

NOx

(tons) 

Unit 3

Heat 

Input 

(MMBtu) 

Unit 3

NOx

(tons) 

Units 

2&3

Heat 

Input 

(MMBtu) 

Units 

2&3

Avg. NOx

Rate 

(lb/MMBu) 

Units 2&3

Rule 

(jjj) 

limit 

(lb/MM

Btu)

1 0.488 109.57 444385.9 109.57 444385.9 0.493

2 0.417 86.66 415304.8 86.66 415304.8 0.417

3 0.451 105.17 465671.8 105.17 465671.8 0.452

4 0.428 95.97 447970.6 95.97 447970.6 0.428

5 0.260 58.73 450211.5 58.73 450211.5 0.261 0.38

6 0.288 12.34 76983.7 0.231 45.93 387750.5 58.26 464734.2 0.251 0.38

7 0.257 52.44 404768.0 52.44 404768.0 0.259 0.38

8 0.300 29.84 193346.5 0.343 77.06 430355.7 106.9 623702.2 0.343 0.38

9 0.259 65.57 501190.0 65.57 501190.0 0.262 0.38

10 0.485 99.20 409047.9 99.20 409047.9 0.485

11 0.539 106.96 397407.5 106.96 397407.5 0.538

12 0.561 87.83 312954.9 87.83 312954.9 0.561
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

51 of 57

average alternative contemporaneous emission limitation of 0.48 lb/mmBtu for unit 3. This 

condition also establishes an annual heat input limit of 4,830,444 mmBtu. 

Tables 7-6 and 7-7 compare actual NOx emissions and heat input for unit 3 to the alternative 

emission and heat input limits. This comparison uses data from Tables 7-1 and 7-2. Both the actual 

emission rate and heat input were below the limits during the baseline period.

Table 7-6. Comparison of Yates Unit 3 actual emission rate and heat input to Acid 

Rain averaging plan alternative NOx and heat input limits 2012.

Year Month NOx (tons) Heat Input 

(MMBtu)

NOx (lb/MMBtu)

2012 1 62.27 358,224.7

2012 2 54.95 347,173.9

2012 3 86.56 449,601.7

2012 4 56.67 371,056.0

2012 5 54.09 392,058.9

2012 6 14.37 103,071.7

2012 7 48.79 382,052.6

2012 8 50.47 386,369.9

2012 9 51.95 406,316.0

2012 10 54.00 355,901.8

2012 11 82.96 424,649.2

2012 12 70.62 426,410.4

2012 entire year 687.70 4,402,887.6 0.31

Acid Rain Averaging Plan 

Alternative Limits

4,830,444.0 0.48
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

52 of 57

Table 7-7. Comparison of Yates Unit 3 actual emission rate and heat input to Acid 

Rain averaging plan alternative NOx and heat input limits 2013.

Year Month NOx (tons) Heat Input (MMBtu) NOx (lb/MMBtu)

2013 1 109.57 444,385.9

2013 2 86.66 415,304.8

2013 3 105.17 465,671.8

2013 4 95.97 447,970.6

2013 5 58.73 450,211.5

2013 6 45.93 387,750.5

2013 7 52.44 404,768.0

2013 8 77.06 430,355.7

2013 9

2013 10

2013 11

2013 12

2013 entire year 631.53 3,446,419.8 0.37

Acid Rain Averaging Plan 

Alternative Limits

4,830,444.0 0.48

For EPA’s Clean Air Interstate Rule (CAIR) annual NOx program, the State of Georgia is not subject 

to the CAIR ozone season NOx program. CAIR is a market-based trading program and does not 

establish facility-level or unit-level emission limits. Instead, allocations are issued to each effective 

facility and compliance is demonstrated through an inter-state trading program administered by EPA. 

The 2012 and 2013 NOx allocations for Plant Yates were 5045 and 5122 tons, respectively. These 

figures do not include unused new-unit set aside allowances allocated to Plant Yates. Actual 

emissions from Plant Yates, as obtained from EPA’s Air Markets Program Data website, are shown 

in Tables 7-8 and 7-9. 

Table 7-8. Comparison of Yates Actual Emission Rates for CAIR Allocations 2012.

State

Facility 

Name

Facility 

ID 

(ORISPL)

Year

Month

Y1BR

NOx

(tons)

Y2BR

NOx

(tons)

Y3BR

NOx

(tons)

Y4BR

NOx

(tons)

Y5BR

NOx

(tons)

Y6BR

NOx

(tons)

Y7BR

NOx

(tons)

Total

NOx

(tons)

GA Yates 728 2012 1 41.88 37.41 62.27 107.41 13.65 215.98 478.60

GA Yates 728 2012 2 58.79 54.95 215.40 329.14

GA Yates 728 2012 3 85.95 86.56 21.33 86.00 171.07 450.92

GA Yates 728 2012 4 57.71 56.67 33.98 97.77 28.06 274.19

GA Yates 728 2012 5 54.67 54.09 156.20 264.96

GA Yates 728 2012 6 49.88 14.38 149.73 213.99

GA Yates 728 2012 7 49.96 48.79 159.80 44.87 303.43

GA Yates 728 2012 8 48.73 50.47 19.23 163.53 281.96

GA Yates 728 2012 9 44.33 51.95 155.81 252.09

GA Yates 728 2012 10 18.55 54.00 210.86 283.41

GA Yates 728 2012 11 82.96 210.41 30.11 323.49

GA Yates 728 2012 12 70.62 237.77 308.38

2012 Entire Year 3764.55

2012 CAIR Allocation 5045.00
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

53 of 57

Table 7-9. Comparison of Yates Actual Emission Rates for CAIR Allocations 2013.

State

Facility 

Name

Facility 

ID 

(ORISPL)

Year

Month

Y1BR

NOx

(tons)

Y2BR

NOx

(tons)

Y3BR

NOx

(tons)

Y4BR

NOx

(tons)

Y5BR

NOx

(tons)

Y6BR

NOx

(tons)

Y7BR

NOx

(tons)

Total

NOx

(tons)

GA Yates 728 2013 1 109.57 235.97 345.54

GA Yates 728 2013 2 86.66 225.50 312.16

GA Yates 728 2013 3 105.17 29.092 134.27

GA Yates 728 2013 4 95.97 95.97

GA Yates 728 2013 5 58.73 58.73

GA Yates 728 2013 6 9.31 12.34 45.93 107.38 57.70 232.65

GA Yates 728 2013 7 52.44 78.27 41.30 172.00

GA Yates 728 2013 8 29.84 77.06 234.98 219.75 561.63

GA Yates 728 2013 9 65.57 203.52 205.57 474.66

GA Yates 728 2013 10 99.20 11.26 110.46

GA Yates 728 2013 11 106.96 38.19 145.16

GA Yates 728 2013 12 87.83 87.83

2013 Entire Year 2731.05

2013 CAIR Allocation 5122.00

As shown in the tables, actual NOx emissions from Plant Yates were below the facility’s CAIR 

allocations for both 2012 and 2013.

Condition 3.2.6 of Title V permit amendment 4911-077-0001-V-03-5, issued August 29, 2014, 

requires Georgia Power to shut down Yates Unit 3 (as well as Units 1, 2, 4, and 5) once both 

repowered Yates Units 6 and 7 commence operation following conversion to natural gas. Yates 

Units 6 and 7 must be converted to natural gas by April 16, 2015. Therefore, Yates Unit 3 must be 

shut down by April 16, 2015. On and after that date, actual emissions from Yates Unit 3 will be 

zero. Since the baseline actual emissions from Unit 3 are all below the applicable current SIP 

requirements, the emission reduction associated with shutting down Unit 3 (660 tons/year) is surplus.

PERMANENT:

Since Yates Unit 3 will be permanently shut down on or before April 16, 2015, the emissions 

reduction from the shutdown of Unit 3 is permanent.

QUANTIFIABLE:

The baseline emissions for Yates Unit 3 were obtained from EPA’s Clean Air Markets Program Data 

website. Emissions data contained in this website were obtained using continuous emissions 

monitors required by 40 CFR Part 75. Emissions following a shutdown are, by definition, zero. 

Therefore, the emission reductions are quantifiable.

ENFORCEABLE:

Enforceability of the emission reductions from Yates Unit 3 are addressed separately in Section 7.1.3

of this document.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

54 of 57

ADDITIONAL REQUIREMENTS:

Other Requirements of Appendix S, Section IV.C.3, specifically, Paragraph (i)(2) of Section IV.C.3. 

states that emission reductions from shutting down an existing source is creditable only if the 

shutdown or curtailment occurred after the last day of the base year for the SIP planning process. 

EPA’s June 6, 2013, proposed rule for implementing the 2008 Ozone standard, “Implementation of 

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

Requirements; Proposed Rule”, states that states should use the calendar year for most recently 

available triennial emissions reporting inventory (2011) as the base year. The emission reductions 

from Unit 3 will occur at the time that the unit is shut down, which will be on or before April 16, 

2015. Therefore, emission reductions from the shutdown of Yates Unit 3 are creditable.

SUMMARY:

This analysis shows that the emission reductions resulting from the shutdown of Yates Unit 3 meet 

the requirements of 40 CFR 51 Appendix S and are therefore creditable as offsets. The amount of 

available offsets is the average of the 2012-2013 baseline period, 660 tons per year.

In Section 6.1, EPD has determined that 202.35 tons [200.43 from Rule (bbb) and 1.92 from Georgia 

Rule (aaa)] of NOx reductions are necessary to offset the maximum NOx and VOC emissions 

increase that will result from the repeal of Georgia Rules 391-3-1-.02(2)(aaa) and (bbb). 

The annual NOx decrease from the retirement of Plant Yates Unit 3 is more than adequate to offset 

the maximum NOx and VOC increase expected from the repeal of rules 391-3-1-.02(2)(aaa) and 

(bbb). 

7.1.2 Contingency Measure Triggers

Because some of the locomotive retrofits discussed in Section 6.2 have not yet been completed, 

Georgia EPD is aware that events could occur that could prevent the completion of the locomotive 

retrofit projects on which Georgia EPD relies for offsets. In order to ensure that there are sufficient 

offsets available for the emissions increase attributed to the removal of Georgia Rules (aaa) and 

(bbb), Georgia EPD is committing in this SIP revision to obtain any remaining necessary offsets 

from the contingency measure described in Section 7.1.1, above.

Upon the determination that sufficient offsets will not be achieved by the railroad retrofit projects 

within one year from the date of EPA’s final action to remove the Georgia Rules (aaa) and (bbb) 

from the SIP, Georgia EPD will take action to ensure that equivalent offsets necessary to satisfy the 

entire emission reduction commitment of the State are achieved from the contingency measure 

described in Section 7.1.1 no later than one year from the date of EPA’s final action to remove 

Georgia Rules (aaa) and (bbb) from the SIP. Implementation of the contingency measure is 

discussed in Section 7.1.3.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

55 of 57

7.1.3 Contingency Measures -Implementation

As stated in the introduction to this section, if an offset measure is used, it must be contemporaneous, 

reproducible, enforceable, surplus, quantifiable, and a permanent measure. The implementation 

component of this section of the SIP specifically addresses enforceability.

If it is necessary to implement the contingency measure described in Section 7.1.1, Georgia EPD will 

revise Georgia Rule 391-3-1-.02(12)(f), Clean Air Interstate Rule NOx Annual Trading Program, for 

the purposes of retiring or reducing the appropriate New Source Set Asides and submit that rule 

revision as a SIP revision. This SIP revision will also include the permit condition requiring Yates 

Unit 3 to shut down. 
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

56 of 57

8.0 Conclusion

In this SIP revision, Georgia EPD demonstrates that the removal of Georgia Rules 391-3-1-

.02(2)(aaa), Consumer and Commercial Products and Georgia Rule 391-3-1-.02(2)(bbb), Gasoline 

Marketing; from the Georgia SIP does not interfere with the requirements of 110(l).

Georgia Rules 391-3-1-.02(2)(aaa), Consumer and Commercial Products decreases VOC emissions 

in the nonattainment area only 0.17 tons per day. Therefore, removal of this rule will have a very

minimal impact on ozone monitors in the metro area. 

The benefit of Georgia Rule 391-3-1-.02(2)(bbb), Gasoline Marketing that requires Georgia Gas in 

the nonattainment area is also now minimal. Analysis shows that for both Georgia Gas and 

conventional gasoline, the NOx and VOC emissions after 2012 are well below the 2006 MVEB or 

2008 ozone maintenance plan levels while emissions from 2024-2040 never exceed the 2024 ozone 

maintenance plan MVEB.

Georgia Rules 391-3-1-.02(2)(mmm), NOX Emissions from Stationary Gas Turbines and Stationary 

Engines used to Generate Electricity is being amended so that the nonattainment area will not be 

impacted at all. Therefore, revision of this rule will have no impact on ozone monitors in the metro 

area. 

Furthermore, the State of Georgia is a NOx limited area and the sensitivity of ozone formation in the 

Atlanta area to reductions of NOx is greater than the sensitivity to reductions in VOC emissions.

Therefore the conclusions in this plan are consistent with EPA’s “Guidance on Removing Stage II 

Gasoline Vapor Control Programs from State Implementation Plans and Assessing Comparable 

Measures” which states that the removal of a VOC control could result in an area-wide VOC 

emissions increase, and yet may still be consistent with the conditions of Section 110(l) “in areas 

where ozone formation is limited by the availability of NOx emissions.”

Offsetting emissions are available from early replacement of school buses and locomotive retrofits 

that more than cover the increase in NOx and VOC emissions from the removal of Georgia Rules 

(aaa) and (bbb). This SIP contains a commitment from Georgia EPD that it will replace any offset 

not achieved through the diesel retrofits with stationary source contingency measure offsets that are 

contemporaneous, reproducible, enforceable, surplus, quantifiable, and a permanent measure as 

required by 40 CFR 51 Appendix S.

For these reasons, the removal of these rules meet the requirements of 110(l); specifically that their 

removal will not interfere with attainment, reasonable further progress or any other requirement of 

the Clean Air Act.
Revision to the Georgia State Implementation Plan for the Removal of Miscellaneous 

Georgia Rules

57 of 57

References

State of Georgia, Rules for Air Quality Control, Chapter 391-3-1, Effective September 5, 2013.

EPA Consumer and Commercial Solvent Use Final Report: August 1996. 

USEPA, National Emissions Inventory: Inventory years 2008, and 2010.

USEPA “Implementation of the 2008 National Ambient Air Quality Standards for 

Ozone: State Implementation Plan Requirements”, 78 FR 34178 through 78 FR 34239, Proposed 

Rule, June 6, 2013.1997 

Atlanta 8-Hour Ozone Maintenance Plan, March 21, 2012, submitted to EPA on April 4, 2012.