EPA-450/3-75-042

APRIL 1975
      IMPLEMENTATION PLAN REVIEW
                   FOR
               GEORGIA
              AS REQUIRED
                   BY
           THE ENERGY SUPPLY
                   AND
   ENVIRONMENTAL COORDINATION ACT
      U. S. ENVIRONMENTAL PROTECTION AGENCY

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EPA-450/3-75-042

APRIL 1975
      IMPLEMENTATION PLAN REVIEW
                   FOR
               GEORGIA
              AS REQUIRED
                   BY
           THE ENERGY SUPPLY
                   AND
   ENVIRONMENTAL COORDINATION ACT
      U. S. ENVIRONMENTAL PROTECTION AGENCY

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                                      EPA-450/3-75042


                   GEORGIA

ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT

  SECTION IV - STATE IMPLEMENTATION PLAN REVIEW
     PREPARED BY THE FOLLOWING TASK FORCE:

  U.  S.  Environmental  Protection Agency, Region IV
          1421 Peachtree Street, NE
           Atlanta, Georgia 30309

    Energy and Environmental  Systems Division
           Argonne National Laboratory
            Argonne, Illinois 60439
               (EPA-IAG-D5-0463)

    U. S. Environmental  Protection Agency
     Office of Air and Waste  Management
 Office of Air Quality Planning and Standards
 Research Triangle Park, North Carolina 27711
                 April  1975

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                        IMPLEMENTATION PLAN REVIEW

                                   FOR

                                 GEORGIA

     Required by the Energy Supply and Environmental  Coordination Act

                             Table of Contents

                                                                       Page


1.0  EXECUTIVE SUMMARY .  	      1

2.0  GEORGIA STATE IMPLEMENTATION PLAN REVIEW  	      7

     2.1  Summary  .  -	      7

     2.2  Air Quality Setting for the State of Georgia	     11

          2.2.1  Georgia  Air Quality Control  Regions  	     11
          2.2.2  Georgia  Ambient Air Quality Standards 	     11
          2.2.3  Georgia  Air Quality Status  	     11
          2.2.4  Georgia  Emissions Summary 	     14

     2.3  Background on the Development of the Current
          State Implementation Plan	     14

          2.3.1  General  Information 	     14
          2.3.2  Particulate Control Strategy	,	     15
          2.3.3  Sulfur Dioxide Control Strategy	     15

     2.4  Special Considerations - State of Georgia  	     15
                                    m

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                         IMPLEMENTATION PLAN REVIEW
                                    FOR
                           THE STATE OF GEORGIA
       REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT

1.0  EXECUTIVE SUMMARY
     The enclosed report is the U. S.  Environmental Protection Agency's
(EPA) response to Section IV of the Energy Supply and Environmental
Coordination Act of 1974 (ESECA).   Section IV requires EPA to review each
State Implementation Plan (SIP) to determine if control  regulations for
stationary fuel combustion can be revised without interfering with the
attainment and maintenance of the National Ambient Air Quality Standards
(NAAQS).  In addition to requiring that EPA advise the state as to whether
control regulations can be revised, ESECA provides that EPA must approve
or disapprove any revised regulations  relating to fuel burning stationary
sources within three months after they are submitted to EPA by the states.
The states may, as under the Clean Air Act of 1970, initiate State Implemen-
tation Plan revisions; ESECA does  not, however, require states to change
any existing plan.
     Congress has intended that this report provide the state with
information on excessively restrictive control  regulations.   The intent of
ESECA is that SIPs, wherever possible, be revised in the interest of con-
serving low-sulfur fuels or converting to coal, sources  which burn oil or
natural gas.   EPA's objective in carrying out the SIP reviews, therefore,
has been to try to determine if emissions from certain combustion sources
may be increased without interfering with the attainment and maintenance
of standards.  If so, it may be possible through altered resource allocations
to effect significant "clean fuel  savings" in a manner consistent with both
environmental and national  energy  needs.
     In many respects, the ESECA SIP reviews parallel the implementation of
EPA's policy on clean fuels.  Under the Clean Fuels Policy,  implementation
plans have been reviewed with a view to saving low sulfur fuels.   Where the
primary sulfur dioxide air quality standards will not be exceeded, states
have been encouraged to either defer attainment of secondary standards or

                                    1

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to revise the S02 emission regulations.  The states have also been asked
to discourage large-scale shifts from coal to oil where this could be done
without jeopardizing the attainment and maintenance of the NAAQS.
     To date, this activity has involved only those states with the
largest clean fuels savings potentials.  Several of these states have revised
or are currently in the process of revising their S02 regulations.  These
states are generally in the eastern half of the United States.   ESECA, how-
ever, requires the analysis of potentially over-restrictive regulations in
all 55 states and territories.  In addition, the current reviews address
the attainment and maintenance of all the National Ambient Air Quality
Standards.
     The adoption of emission limitations which may, in some areas of the
states, be overly restrictive (or not restrictive enough) resulted largely
from the use of the "example region" approach along with analyses which
considered the "hot spots" of an Air Quality Control Region (AQCR) rather
than the entire region.  This type of approach was offered in EPA guidelines
for plan development when states were preparing their original  plans.  Many
states, through concurrence with EPA, adopted the example region approach,
largely because of the short timetable dictated by the Clean Air Act.  Also,
in most cases, the original SIPs were designed to attain and maintain the
original NAAQS, some of which have since been designated as "guides"  only
or actually rescinded.  However, many states adopted and retained the
original federal  standards or, in a few cases, adopted more restrictive
state standards,  and these served as the basis on which their SIPs were
approved.  As a result, the requirements of many state plans conflict with
legitimate national energy concerns, and thus a review of the State Imple-
mentation Plans is a logical  follow-up to EPA's initial appraisal (1972) of
the SIPs.  At the time, SIPs were approved by EPA if they demonstrated the
attainment of the original NAAQS or the more stringent state air quality
standards.  Also, at that time an acceptable method for formulating control
strategies was the use of an example region for demonstrating the attainment
of the standards.
     The example  region concept permitted a state to identify the most
polluted air quality control  region and adopt control  regulations which would

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be adequate to attain the NAAQS in that region.  In using an example region,
it was assumed that NAAQS would be attained in the other AQCRs of the state
if the control regulations were applied to similar sources.  But use of an
example region can result in excessive controls, especially in the utiliza-
tion of clean fuels, for areas of the state where sources would not
otherwise contribute to NAAQS violations.  For example, a control strategy
based on a particular region or source can result in a regulation requiring
one percent sulfur oil to be burned statewide, even though the use of three
percent sulfur coal would be adequate to attain NAAQS in some locations.
     EPA anticipates that a number of states will use the review findings
to assist them in deciding whether or not to revise portions of their State
Implementation Plans.  However, it is most important for such states to
recognize the limitations of the present review.  The findings of this report
are by no means conclusive and are neither intended nor adequate to be the
sole basis for SIP revisions; they do, however, represent EPA's best judgment
and effort in complying with the ESECA requirements.  The time and resources
which EPA has had to prepare the reports has not permitted the consideration
of growth, economics, and control  strategy tradeoffs.  Also, there has been
only limited dispersion modeling data available by which to address indivi-
dual point source emissions.  Where the modeling data for specific sources
was found, however, it was used in the analysis.
     The data upon which the reports' findings are based is the most
currently available to the federal government.  However, EPA believes that
the states possess the best information for developing revised plans.  The
states have the most up-to-date air quality and emissions data, a better
feel for growth, and the fullest understanding for the complex problems
facing them in the attainment and maintenance of air quality.   Therefore,
those states desiring to revise a plan are encouraged to verify and, in
many instances, expand the modeling and monitoring data used to support EPA's
findings.  States are encouraged to consider the overall impact which the
potential relaxation of overly restrictive emissions regulations for com-
bustion sources might have on their future control  programs.  This may
include air quality maintenance, prevention of significant deterioration,
increased TSP, NO , and HC emissions which occur in fuel switching, and
                 /\
other potential air pollution situations.
                                    3

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     Although the enclosed analysis has attempted to address the attain-
ment of all the NAAQS, most of the review has focused on total  suspended
particulate matter (TSP) and sulfur dioxide (SCO emissions.  This is
because stationary fuel combustion sources constitute the greatest source
of SOp emissions and are a major source of TSP emissions.
     The Georgia SIP control strategy, includes regulations for SO^ and TSP
which consists of emission limitations based upon both source capacity/fuel
sulfur content (or equivalent emissions) and source stack height.  Presently
these stack height regulations are under litigation in the 5th Circuit
Court of Appeals (Natural  Resources Defense Council, Inc., vs.  Environmental
Protection Agency, Case No. 72-2402).   In response to the case EPA was re-
quired to analyze the effectiveness of the source capacity/fuel sulfur content
regulation in providing attainment of the NAAQS without considering the effect
of the stack height dependent regulation.  The results of the analysis showed
that with the exception of SOg emissions from three power plants, the source
capacity/fuel sulfur content regulation was sufficient to provide attainment
of the NAAQS.  If the Court rules in favor of EPA's analysis, the Georgia SIP
emission limitations will  be approved in all cases except for three specific
power plants, where specific S02 emission limits will then be promulgated.
This report has attempted to analyze only the restrictiveness of the source
capacity/fuel sulfur content regulation on potential Clean Fuels savings.
     The following are the principle findings for the State of Georgia (Air
Quality Control Regions are shown in Figure 1-1):
     t  Georgia's ambient air quality standards for TSP are
        essentially identical to the federal secondary NAAQS,1
        while the state S02 standards are more stringent than the
        corresponding federal standards.
     •  The statewide regulations for TSP and SCL are based upon
        the example region approach.
         The only difference between the federal and state standards is
         that Georgia does not permit any excesses of the 24-hour
         standard, whereas the federal standard permits one excess per
         year of the 24 hour standard.

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Within the framework of this limited analysis, there appears to
be little potential for revising participate emission limiting
regulations in all Georgia AQCR's, with the exception of the
Augusta-Aiken Interstate {#53} and the Northeast Georgia Intra-
state (#57).  However, in the Augusta-Aiken Interstate (#53),
the reported TSP air quality values are only slightly below the
standards.  Thus any relaxation of particulate emission limiting
regulations would only tend to aggravate the existing situation.
Due to the limited amount of air quality data available in the
Northeast Georgia Intrastate (#57), a more detailed analysis is
necessary to determine the potential for regulation revision.
Based on reported 1973 air quality data in Georgia, all regions
have the potential for relaxing SCL emission limiting regula-
tions.  However, present regulations allow for the consumption of
up to 3% sulfur content fuel which is readily available.   Thus
the necessity for regulation revision does not appear to exist,
as the present regulations do not require the use of cleaner,
low sulfur fuels.  However, the three power plants
mentioned in the EPA report to the 5th Circuit Count of
Appeals (Natural Resources Defense Council, Inc. vs.
Environmental  Protection Agency, Case No. 72-2402) will
require less than 3% sulfur fuels in order to protect the
NAAQS as shown below:

Power Plant               AQCR                % Sulfur Required
Hammond          Chattanooga Interstate (#55)       0.7
Atkinson         Metropolitan Atlanta               0.9
                    Intrastate (#56)
Yates            Metropolitan Atlanta               2.5
                    Intrastate (#56)

These limits will need to be promulgated upon the Court's
acceptance of the EPA's report.

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CHATTANOOGA
INTERSTATE
(GEORGIA-
                                  NORTHEAST
                                  GEORGIA
                                  IN
                                                 AUGUSTA- (#53)
                                                 AIKEN
                                                 INTERSTATE
                                                 (GEORGIA-
                                                 SOUTH CAROLINA)
                                                         CENTRAL
                                                         GEORGIA   (#54)
                                                         INTRASTATE
                                                                 SAVANNAH-
                                                                 BEAUFORT
                                                                 INTERSTATE
                                                                 (GEORGIA-
                                                                 SOUTH .CAROLINA)
                                                                         (#58)
METROPOLITAN
ATLANTA
INTRASTATE

  (#56)
 COLUMBUS
 PHENIX CITY
 INTERSTATE
 (GEORGIA-
 ALABAMA)

  (#2)

 SOUTHWEST
 GEORGIA
 INTRASTATE
  (#59)
                                                                     JACKSONVILLE-
                                                                     BRUNSWICK
                                                                     INTERSTATE    ("#491
                                                                     (FLORIDA-          •*
                                                                     GEORGIA)
               Figure  1-1.   Georgia Air Quality  Control  Regions (AQCRs)

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2.0  GEORGIA STATE IMPLEMENTATION PLAN REVIEW

2.1  SUMMARY

     A revision of fuel combustion source emissions regulations will depend

on many factors.  For example:

     t  Does the state have air quality standards which are more
        stringent than NAAQS?

     t  Does the state have emission limitation regulations for
        control of (1) power plants, (2) industrial sources, (3)
        area sources?

     •  Did the state use an example region approach for demon-
        strating the attainment of NAAQS or more stringent state
        standards?

     •  Has the state initiated action to modify combustion
        source emission regulations for fuel savings; i.e., under
        the Clean Fuels Policy?

     •  Are there proposed Air Quality Maintenance Areas?

     t  Are there indications of a sufficient number of monitoring
        sites within a region?

     •  Is there an expected 1975 attainment date for NAAQS?

     •  Based on (1973) air quality data, are there reported
        violations of NAAQS?

     t  Based on (1973) air quality data, are there indications
        of a tolerance for increasing emissions?

     •  Are the total emissions from stationary fuel combustion
        sources a relatively small portion of the regional  total?

     •  Do modeling results for specific fuel combustion sources
        show a potential  for a regulation revision?

     •  Is there a significant clean fuels savings potential in
        the region?


     This  SIP review has  answered these questions based on  an overall

evaluation of EPA's current information.   Based on these answers, each AQCR has

been assessed as a good,  marginal, or poor candidate for regulation relaxation.

Table 2-1  summarizes the  conclusions of this State Implementation Plan Review

and gives  the overall candidacy assessment for each AQCR.
Vor interstate AQCR's, the assessment is for the Georgia portion.

                                  7

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     The ratings which are shown in Table 2-1  were determined  by  assessing
the following criteria:
         Good

1) Adequate number of
   air monitoring
   sites
2) No NAAQS violations
3) Attainment data of
   1975 for NAAQS in
   the SIP
4) No proposed AQMAs
5) Modeling results
   show a potential
   for regulation
   revision
       Poor

1) Violation of NAAQS
2) Attainment data for
   NAAQS later than
   1975
3) Proposed AQMA
4) Model results show
   no potential for
   regulation
   revision
     Marginal

1) No air quality data or
   insufficient number of
   monitoring  sites
2) Inconsistent "indicators"
     For an AQCR to be rated as a good candidate,  all  of the  criteria  listed
under "Good" would have to be satisfied.   The overriding factor in  rating  an
AQCR as a poor candidate is a violation of either  the  primary or secondary
National Ambient Air Quality Standards during 1973.  However, if any of the
other conditions listed under "Poor"  exists,  the AQCR  would still receive  that
rating.  The predominant reason for a marginal  rating  is a lack of  sufficient
air quality data.  In Priority III regions, air monitoring was not  required
during 1973; therefore there are little if any data  with which to determine
the current air quality status.  Marginal  ratings  are  also given when  there
are varying or inconsistent "indications".

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Table  2-1    STATE  IMPLEMENTATION  PLAN  REVIEW  (SUMMARY)
                                     COLUMBUS-    JACKSONVILLE-             CENTRAL                METROPOLITAN  NORTHEAST    SAVANNAH-   SOUTHWEST
                                     PHENIX      BRUNSWICK   AUGUSTA-AIKEN   GEORGIA     CHATTANOOGA  ATLANTA      GEORGIA      BEAUFORT    GEORGIA
                                     INTERSTATE   INTERSTATE   INTERSTATE     INTRASTATE  INTERSTATE   INTRASTATE    INTRASTATE    IKTERSTATE  INTRASTATE
                             STATE     AQCR 12     AQCR 049    AQCR 153       AQCR 054    AQCR 055                           —	
"INDICATORS"
• Does the State have air quality standards
which are more stringent than NAAQS?
• Does the State have emission limiting regu-
lations for control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example region approach
for demonstrating the attainment of NAAQS or
more stringent State standards?
• Has the State initiated action to modify
combustion source emission regulations for fuel
savings; i.e.. under the Clean Fuels Policy?
» Are there proposed Air Quality Maintenance
Areas?
t Are there indications of a sufficient number
of monitoring sites within a region?
• Is there an expected 1975 attainment date
for NAAQS?3
• Based on reported (1973) Air Quality Data,
does air quality meet NAAQS?
• Based on reported (1973) Air Quality Data,
increasing emissions?
« Are the total emissions from stationary fuel
combustion sources lower than those of other
sources?
•' Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?
• Must emission regulations be revised to accom-
plish significant fuel switching?
• Based on the above indicators, what is the
potential for revising fuel combustion source
emission limiting regulations?
TSP
HO
YES
YES
YES
YES
NO










SO,,
YES
YES
YES
YES
YES
YES










TSP




NO
YES
YES
NO

NO
YES
NDA
N/A
POOR
S0?




NO
YES
1
YES

YES
YES
NDA
NO
GOOD
TSP




NO
YES
YES
NO

NO
YES
NDA
N/A
POOR
S0?




NO
YES
YES
NO4

NO4
NO
YES
NO
MARGI-
NAL
TSP




NO
YES
1
YES

YES
YES
NDA
N/A
POOR
S0?




NO
YES
1
YES

YES
NO
YES
NO
GOOD
TSP




NO
YES
YES
NO

NO
YES
NDA
N/A
POOR
50?




NO
YES
1
YES

YES
NO
•YES
NO
GOOD
TSP




YES
YES
YES
NO

NO
YES
NDA
N/A
POOR
S0?




NO
YES
1
YES

YES
NO
YES
NO
GOOD
TSP




YES
YES
YES
NO

NO
YES
NDA
N/A
POOR
S0?




NO
YES
1
YES

YES
NO
NO
NO
POOR
TSP




NO
NO
1
YES

YES
YES
NDA
N/A
1ARGI-
NAL
so2




NO
NO
2
NDA

N/A
NO
YES
NO
MARGI-
NAL
TSP




YES
YES
YES
NO

NO
YES
NDA
N/A
POOR
so2




NO
YES
1
YES

YES
NO
YES
NO
GOOD
TSP




YES
YES
YES
NO

NO
YES
NDA
N/A
POO)
so2




NO
YES
1
YES

YES
NO
YES
NO
GOOD

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         Table 2-1.  STATE IMPLEMENTATION PLAN REVIEW (SUMMARY)
                              (Continued)
  Presently meeting standards
p
  Attainment schedule indicates region is below standards; current
  data is unavailable

  Attainment dates soecified in Federal  Register (May 31, 1972)
4
  Violations in Florida portion of interstate AQCR.

NDA = No data available

N/A = Not applicable
                                      10

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2.2  AIR QUALITY SETTING FOR THE STATE OF GEORGIA
2.2.1  Georgia Air Quality Control Regions
     The State of Georgia is divided into nine Air Quality Control Regions
as shown in Figure 1-1.  There are four intrastate and five interstate   •
regions of which only two, the Chattanooga Interstate (#55) and the Metro-
politan Atlanta Intrastate (#56), have a relatively large (greater than 75
people per square mile) population density.  Based on present conditions and
growth projections for the state, no counties in Georgia are proposed as Air
Quality Maintenance Areas (AQMAs) for sulfur oxides.  However, Catoosa and
Walker Counties in the Chattanooga Interstate AQCR (#55); Clayton, Cobb,
DeKalb and Fulton Counties in the Metropolitan Atlanta Intrastate AQCR (#56);
Chatham County in the Savannah-Beaufort Interstate AQCR (#58); and Dougherty
County in the Southwest Georgia Intrastate (#59); are Georgia counties which
have been proposed as AQMAs for particulate matter (Figure 2-1).
2.2.2  Georgia Ambient Air Quality Standards
     The State of Georgia, except for one minor difference , has adopted the
federal secondary National Ambient Air Quality Standard for total  suspended
particulates as its only standard for TSP.   The State sulfur oxides standards
consist of an annual  and 24-hour standard which are more stringent than the
corresponding federal standards, plus a one hour standard.  The State does not
have an annual standard for nitrogen dioxide.  Georgia air quality standards
are summarized in Table 2-2.   This review considers only the attainment of
the federal  NAAQS.
2.2.3  Georgia Air Quality Status
     Based on data available in the SAROAD data banks as of June 1974, the
24-hour particulate NAAQS has been violated in all except two regions, these
being the Augusta-Aiken Interstate AQCR (#53) and the Northeast Georgia Intra-
state AQCR (#57).  The annual particulate NAAQS has been exceeded in five
regions - Columbus-Phenix City Interstate (#2), Jacksonville-Brunswick Interstate
(#49), Central Georgia Intrastate (#54), Chattanooga Interstate (#55) and the
Metropolitan Atlanta Intrastate (#56).  No annual data is available for the
  The difference is that the 24-hour Georgia TSP standard cannot be exceeded
  anytime, whereas the federal  standard can be exceeded once a year.
                                       11

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^   CHATTANOOGA
»?\S) CHATTANOOGA
                                                                                 LEGEND
                                                                      ®   Places of 100,000 or more inhabitants
                                                                      •   Places of 50,000 to 100,000 inhabitants
                                                                      O   Places of 25,000 to 50.000 inhabitants outside SMSA's
     FLOfQ
    »OMfO
                  0S
                                                                                 Standard Metropolitan
                                                                            . _____ 3  Statistical Areas (SMSA's)
                                                                                  TSP  DESIGNATION
                                                                WILKES  \ LINCOLN
                                                                                       !'    AIKEN
                          »*ALONC -^ WITS
                                                             WASHINGTON
 COLUMBUS
% ^ KUSULL
             COLUMHJ:
            CNATTAMOOCMff
                                                                                CANDLER I   BULLOCK   V  ErflNGHAM
                                                                                                            AVANNAH
                                                                                                        w
                                                            cofrti    U   Mc
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                                     Table 2-2.    Georgia Ambient Air Quality Standards
                                                                       4
                                           All concentrations in ugms/nT

Federal Primary
Secondary
State
Total Suspended Particulate
Annual 24 -Hour
75(G) 260a
60 (G) 150a
60 (G) 150
Sulfur Oxides
Annual 24-Hour S'-Hour 1-Hour
80 (A) 365a
1300a
43 (A) 229 --- 715
Nitrogen Dioxide
Annual
100 (A)
100 (A)
—
LO
              to be exceeded more than once per year.
         (A)   Arithmetic mean
         (G)   Geometric mean

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iortheast Georgia Intrastate AQCR (#57).   Thus,  with the possible  exceptions
of the Augusta-Aiken Interstate (#53)  and the Northeast Georgia Intrastate (#57)
regions, it appears that the relaxation of particulate emission regulations
would not be possible without disrupting NAAQS attainment or maintenance.
     S02 air quality data is unavailable for the Northeast Georgia Intrastate
region (#57).  In the remaining eight regions, only one, the Jacksonville-
Brunwick Interstate (#49) reports any violations of the S02 NAAQS.  However,
these violations  are in the Florida portion of this AQCR.

2.2.4  Georgia Emissions Summary
     Georgia fuel combustion  particulate emissions account for less than
half of the total particulate emissions in all AQCR's.  Power plants are
the major fuel combustion particulate sources in the Central Georgia Intra-
state (#54), while industrial/commercial/institutional point sources predominate
in the Jacksonville-Brunswick Interstate (#49),  Augusta-Aiken Interstate (#53),
Savannah-Beaufort Interstate (#58), Southwest Georgia Intrastate (#59) and the
Chattanooga  Interstate (#55) regions.
     Power plants contribute the largest fraction  of  sulfur dioxide emissions
in six AQCR's - the Jacksonville-Brunswick Interstate (#49), the Central Georgia
Intrastate (#54), the Chattanooga Interstate  (#55), Metropolitan Atlanta Intra-
state (#56), Savannah-Beaufort Interstate  (#58), and the Southwest Georgia
Intrastate (#59).  Industrial/commercial/institutional point fuel  combustion
sources are the major S02 emitters in the Augusta-Aiken Interstate (#53) region.
Area sources are significant in the Columbus-Phenix City Interstate (#2) and
the Northeast Georgia  Intrastate  (#57) AQCR's.

2.3   BACKGROUND  ON  THE DEVELOPMENT  OF THE  CURRENT  STATE IMPLEMENTATION  PLAN
2.3.1   General Information
      The  example region approach  was  used  in  developing the Georgia State
Implementation Plan, with  the  Metropolitan Atlanta (#56)  and  Savannah-Beaufort
(#58) AQCR's  being  selected.   Both  of these  regions were  used to  develop
control strategies  for particulate  matter  and S02>  A dispersion  model  (the
Air  Quality  Display  Model)  was  employed  to demonstrate  the  effectiveness of
the  strategies.
                                       14

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2.3.2  Parti oil ate Control Strategy
     The control strategy for particulate matter for fuel combustion
sources consists of enforcing Section 391-3-1-.02 of the Georgia Department
of Natural Resources rules.  The strategy basically consists of two parts,
one for equipment in operation or under construction before January 1, 1972
and one for all equipment constructed after that date.  Emission limits were
imposed based on a heat input and stack height basis.   Table 2-3 summarizes
the regulations.
2.3.3  Sulfur Dioxide Control Strategy
     The SCL control  strategy involves imposing emission limits based on
the location (urban or rural), heat input (in terms of Btu's per hour), fuel
sulfur content and stack height(s) of a fuel  burning installation.
2.4  SPECIAL CONSIDERATIONS - STATE OF GEORGIA
     The Georgia SIP control  strategy includes regulation for S02 and TSP
which consists of emission limitations based  upon both source capacity/fuel
sulfur content (or equivalent emissions) and  source stack height.  Presently
these stack height regulations are under litigation in the 5th Circuit Court
of Appeals (Natural Resources Defense Council, Inc. vs. Environmental Protec-
tion Agency, Case No. 72-2402).   In response  to the case EPA was required to
analyze the effectiveness of the source capacity/fuel  sulfur content regula-
tion in providing attainment of the NAAQS without considering the effect of
the stack height dependent regulation.  The results of the analysis showed
that with the exception of S02 emissions from three power plants, the source
capacity/fuel sulfur content regulation was sufficient to provide attainment
of the NAAQS.  If the Court rules in favor of EPA's analysis, the Georgia SIP
emission limitations will be approved in all  cases except for three specific
power plants  where specific S02 emission limits will  then need to be
promulgated.
Hhese are Hammond in the Chattanooga Interstate AQCR (#55); Atkinson and Yates
 in the Metropolitan Atlanta Intrastate AQCR (#56).
                                    15

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          Table 2-3 Georgia Fuel  Combustion  Emission  Regulations

Parti oil ate Matter
     (1)   No person shall  cause,  let,  suffer,  permit  or  allow  the emission
          of fly ash and/or other particulate  matter  from  any  fuel-burning
          equipment in operation  or under construction on  or before
          January 1, 1972; in amounts  equal  to or exceeding the following:
          (i)  for equipment less than 10 million Btu heat input per  hour:
               P = 0.7 pounds per million Btu  heat input;
         (ii)  for equipment equal  to  or greater  than 10 million Btu
               heat input per hour; or equal to or less  than 2,000
               million Btu heat input  per hour:

               P = 0.7 f     °'202   pounds  per million Btu heat input;
               R = heat input of fuel  burning  equipment in  million
                   Btu per hour
        (iii)  equipment larger than 2,000 million Btu  heat input per  hour:
               P = 0.24 pounds per million Btu heat input.
     (2)  No person shall cause, let,  suffer,  permit or allow the emission
          of fly ash and/or other particulate  matter from any fuel-burning
          equipment constructed after  January  1,  1972,  in amounts equal  to
          or exceeding the following:
          (i)  for equipment less than 10 million Btu heat  input per hour:
               P = 0.5 pounds per million Btu  heat input
         (ii)  for equipment equal to  or greater  than 10 million Btu
               heat input per hour, or equal  to or less than 250 million
               Btu heat input per hour:
                          (\ n R
                        i n \   *
                        •K^-j      pounds per million Btu heat input:
               R = heat input of fuel  burning  equipment in  million
                   Btu per hour
        (iii)  for equipment greater than 250  million Btu heat input per hour:
               P = b.10 pounds per million Btu heat input
                                          16

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  Table 2-3  Georgia Fuel  Combustion  Emission  Regulations  (Cont'd)


(3)   At any site from either fuel  burning or manufacturing process

     emission sources, located within one mile from the  limits  of

     a city having a population of 50,000 or more,  with  the excep-

     tion of asphaltic concrete hot mix plants,  cupola furnaces for

     metallurgical melting,  and Kaolin and Fuller's earth  processes,

     no person shall cause,  let, permit, suffer or  allow the emission

     of fly ash and/or other particulate matter equal to or

     exceeding:

     (i)   for stack heights  below 120 feet - P = 0.48 h
          pounds per hour;

    (ii)   for stack heights  below 120 feet but equal to  or
                                           h
                                            s
                                              ,3
          greater than  120  feet  -  P  =  900  (37575-)   pounds  per  hour;
   (iii)   for stack  heights  equal  to  or  greater  than  300  feet
                     h    2
          -  P =  900  (3Q-Q-)  pounds  per hour;
    (iv)   P  =  the maximum fly  ash  and/or other  particulate  emissions  in
          pounds  per hour;

     (v)   h  = the stack height  in feet;

    (vi)   if several  stacks  are  located  at  a  given  site,  then  the
          stack height  to be used  in  the above  equations  will  be
          the  weighted  average stack  height given by:

                h,A,  +  hJL  +  '  '  '  '  h, An
          L.  _   I  1     22            h n
           s               Atotal
          where h,  is  the  height  of  the  first  stack, A,  is  the  fly
          ash  and/or particulate  matter  emission  from  the first stack,
          \\2  is the height of  the second stack, and so forth.   A.  .  ,
          is  the total  ash and particulate matter emissions  at  tne
          site, in  pounds  per  hour.   No  single stack may equal  or
          exceed the above allowed emissions calculated using its
          own  stack height.
                                17

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    Table 2-3 Georgia Fuel  Combustion Emission Regulations  (Continued)


Sulfur Dioxide

     (1)  No person shall  cause, let, suffer,  permit or allow from  any

          source the emission of sulfur dioxide (S02) equal  to or exceeding:

          (i)  for stack height(s) less than 300 feet -
               S = 4,OOOF I OQQ 1   , in pounds per hour;



         (ii)  for stacks 300 feet or greater in height  -


                          / h  \2
              'S = 4,OOOF I 300 )   . in pounds per hour;
        (iii)  F = 0.8, when two or more fuel -burning sources each having
               a heat input of more than 500 million Btu's per hour and
               burning fuel containing more than 1% sulfur by weight
               are located in an urban area;

         (iv)  F = 1, for other fuel -burning sources located in an urban
               area, and for all other kinds of sources emitting sulfur
               dioxide regardless of location;

          (v)  F = 2, for fuel -burning sources having a heat input less
               than 10,000 million Btu's per hour, and located in a
               rural area;

         (vi)  F = 3, for fuel burning sources having a heat input equal
               to or greater than 10,000 Btu's per hour, and located in
               a rural area.

        (vii)  For the purposes of this section, the term "urban" shall
               mean any site located within or 5 miles from the limits
               of a city having a population of 50,000 or more; the term
               "rural" will apply to all other site locations.

       (viii)  h  is the stack height in feet.  If several stacks are
               located at a given site, then the stack height to be used
               above will be the weighted average stack height given by


               h. -h!Sl +h2S2 + "-- + hnSn
                                Stotal
               where h, is the height of the first stack, S,  is the sulfur
               dioxide emitted from the first stack, h« Is the height of the
                                    18

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Table 2-3.   Georgia Fuel  Combustion Emissions  Regulations  (Continued)
            second  stack,  and  so  forth.  Stotal  1S the total
            sulfur  dioxide emission  at  the  site.  S  is expressed
            in  pounds  per  hour sulfur dioxide from a stack.  No
            single  stack may exceed  the above allowed emission
            calculated using its  own actual  height.
  (2)   New fuel-burning sources over 250 million Btu's of heat input per
       hour,  that are  constructed or extensively modified after January 1, 1972,
       may not  emit sulfur dioxide equal to  or exceeding:
       (i)  0.8 Ibs of sulfur  dioxide per million Btu's of heat
            input when oil  is  fired,
      (ii)  1.2 Ibs of sulfur  dioxide per million Btu's of heat
            input when coal is fired,
     (iii)  when different fuels  are burned  simultaneously in any
            combination, the applicable standard, expressed as
            pounds  of  sulfur dioxide per million Btu's of heat input,
            shall be determined by proration.  Compliance shall be
            determined using the  following  formula:
                      Y  (0.80) + Z  (1.2)
                          x + y + 2

            where    x  =  percent of  total heat input derived from gas;
                    y  =  percent of  total heat input derived from oil;
                    2  =  percent of  total heat input derived from coal.
  (3)   In  addition  to  the  stipulations and limitations in paragraphs  (1)
       and (2)  of this subsection,  all fuel burning sources below 100
       million  Btu's of  heat input  per hour shall not burn fuel containing
       more  than 2.5 percent sulfur  by weight.  All fuel burning sources
       having a heat input of 100 million Btu's per hour or greater shall
       not burn a fuel containing more than 3 percent sulfur by weight.
  (4)   Notwithstanding the limitations of sulfur content of fuels stated
       in  paragraph (3)  above, the  director may allow sulfur content  greater
       than  that allowed in paragraph (3) above, provided that the source
       utilizes sulfur dioxide removal and the sulfur dioxide emission does
       not exceed that allowed by paragraph (3) above, utilizing no sulfur
       dioxide  removal.
                                       19

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
   EPA-450/3-75-042
                                                            3. RECIPIENT'S ACCESSIOWNO.
4. TITLE AND SUBTITLE
                                                            5. REPORT DATE
    IMPLEMENTATION  PILAN REVIEW FOR GEORGIA AS
    REQUIRED BY THE ENERGY SUPPLY AND  ENVIRONMENTAL
    COORDINATION ACT                   	
             6, P,EB.F0RMING ORGANIZATION CODE
7. AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
                                                            10. PROGRAM ELEMENT NO.
    U.S.  Environmental  Protection Agency,  Office of Air
    Quality Planning  and Standards, Research Triangle
    Park, N.C., Regional Office IV, Atlanta, Georgia,
    and Arqonne National Laboratory, Argnnnp,
              11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
    U.S.  Environmental  Protection Agency
    Office of Air and Waste Management
    Office of Air Quality Planning and Standards
    Research Triangle Park. North Carolina  ?7711
              14. SPONSORING AGENCY CODE
16. SUPPLEMENTARY NOTES
16. ABSTRACT
          Section IV of  the Energy Supply  and Environmental  Coordination Act of  1974,
    (ESECA) requires EPA to review each  State Implementation Plan (SIP) to determine
    if  revisions can be  made to control  regulations for stationary fuel combustion
    sources without interfering with the attainment and maintenance of the national
    ambient air quality  standards.  This document, which  is  also required by Section
    IV  of ESECA, is EPA's report to the  State indicating  where  regulations might be
    revised.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS  C.  COSATI Field/Group
   Air Pollution
   State Implementation  Plans
18. DISTRIBUTION STATEMENT
   Release unlimited
                                               19. SECURITY CLASS (ThisReport)
                                                 Unclassified
                                                                          21. NO. OF PAGES
                                22
20. SECURITY CLASS (Thispage)

  Unclassified	
                                                                          22. PRICE
EPA Form 2220-1 O-73)

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