Attachment
5
Nonattainment
Area
Designations
for
Atlanta
under
the
PM2.5
Standard
Additional
Analysis
for
Jasper
and
Putnam
Counties
U.
S.
EPA's
June
29,
2004
letter
added
Jasper
and
Putnam
Counties
to
Georgia
EPD's
recommendation
for
the
Atlanta
PM2.5
nonattainment
area.
EPA's
letter
states
that
Putnam
County
was
included
in
EPA's
recommendation
in
order
to
ensure
that
a
sufficient
portion
of
the
county
that
includes
identifiable
large
emitting
facilities
be
included
within
the
boundaries
of
the
nonattainment
area.
EPA
invited
Georgia
EPD
to
submit
a
recommendation
of
a
partial
county
that
will
include
these
large
emitting
facilities.
Based
on
conversations
with
U.
S.
EPA
staff,
the
"
large
emitting
facility"
of
concern
in
Putnam
County
is
Georgia
Power's
Plant
Branch.
Based
on
conversations
with
EPA
Region
4
staff,
it
is
also
EPD's
understanding
that
U.
S.
EPA
is
also
amenable
to
considering
a
partial
county
area
for
Jasper
county
in
order
to
include
large
emitting
facilities.
For
Jasper
County,
the
"
large
emitting
facilities"
is
the
Georgia­
Pacific
complex
located
in
Monticello.

EPD
has
determined
that
is
not
practical
to
design
partial
county
nonattainment
boundaries
for
Jasper
or
Putnam
Counties
which
include
the
Geogia­
Pacific
complex
and
Plant
Branch
that
are
contiguous
to
the
remainder
of
the
Atlanta
PM2.5
nonattainment
area.
This
is
because
the
Georgia­
Pacific
complex
is
located
in
the
middle
of
Jasper
County
and
Plant
Branch
is
located
in
the
southeastern
corner
of
Putnam
County.

There
are
only
three
major
sources
of
PM2.5
emissions
or
precursors
in
Jasper
County.
All
three
are
part
of
a
Georgia­
Pacific
Complex
southwest
of
Monticello.
These
include
Georgia­
Pacific
Corporation
 
Monticello
Plywood
Plant,
Georgia­
Pacific
Corporation
 
Monticello
Panelboard
Plant,
and
Georgia­
Pacific
Corporation
 
Monticello
MDF
plant.
PM2.5
emissions
and
precursor
emissions
as
reported
in
the
2003
CERR
(
for
Panelboard
and
MDF)
and
2002
CERR
(
for
Plywood)
are
shown
below.

Facility
VOC
(
tons/
yr)
NOx
(
tons/
yr)
SO2
(
tons/
yr)
PM2.5
(
tons/
yr)
Ammonia
(
tons/
yr)
Plywood
74.7
115.2
0
0
0
Panelboard
178.5
13.4
0.1
0.3
0
MDF
1.5
14.8
1.3
0
0
Total
254.7
143.4
1.4
0.3
0
The
Georgia­
Pacific
complex
emits
no
ammonia
and
insignificant
amounts
of
sulfur
dioxide
and
PM2.5.
The
VOC
emissions
of
254
tons/
yr
and
NOx
emissions
of
143.4
tons/
yr
are
insignificant
to
the
total
VOC
emissions
of
231,140
tons/
yr
and
NOx
emissions
of
286,049
tons/
yr
for
EPD's
recommended
PM2.5
nonattainment
area
for
Atlanta.

The
Georgia­
Pacific
Monticello
Complex
is
approximately
43
miles
and
Plant
Branch
is
approximately
65
miles
from
the
nearest
PM2.5
monitor
in
the
Atlanta
area
(
South
DeKalb
monitor).
Georgia­
Pacific
Monticello
and
Plant
Branch
are
closer
to
other
PM2.5
monitors
than
they
are
to
the
closest
Atlanta
monitor.
Georgia­
Pacific
is
approximately
54
miles
NW
of
the
Sandersville
monitor,
33
miles
NW
of
the
Gordon
monitor,
and
33
miles
N
of
both
Macon
monitors.
Plant
Branch
is
approximately
32
miles
NW
of
the
Sandersville
monitor,
21
miles
N
of
the
Gordon
monitor,
and
about
36
miles
NE
of
both
Macon
monitors.

Wind
frequency
data
was
obtained
from
U.
S.
EPA's
PM2.5
Designation
Technical
Information
web
page
(
www.
epa.
gov/
ttn/
naaqs/
pm/
pm25_
tech_
info.
html)
for
Clayton,
DeKalb,
and
Gwinnett
Counties.
These
three
counties
contain
the
PM2.5
monitors
in
the
Atlanta
area
that
are
closest
to
Jasper
and
Putnam
Counties
and
thus
would
more
likely
affected
by
emissions
from
those
counties
than
other
monitors
in
the
Atlanta
area.
Review
of
this
data
shows
that
the
prevailing
winds
for
all
three
counties
are
predominantly
from
the
northwest
and
secondarily
from
the
east.
Both
Jasper
and
Putnam
Counties
lie
southeast
of
the
Atlanta
area.
While
the
wind
patterns
in
middle
Georgia
are
fairly
evenly
dispersed,
the
most
frequent
wind
direction
for
all
three
of
these
counties
is
from
the
WNW.

Because
of
the
distances
and
wind
patterns
of
these
monitors
in
relation
to
Georgia­
Pacific
Monticello
and
Plant
Branch,
both
of
these
facilities
would
have
a
bigger
impact
on
the
Sandersville
and
Gordon
monitors,
both
of
which
are
in
compliance
with
the
PM2.5
standard
(
14.0
ug/
m3
for
Sandersville
and
14.9
ug/
m3
for
Gordon)
than
the
closest
non­
complying
monitors
(
15.7
ug/
m3
for
the
South
DeKalb
monitor
and
15.2
for
the
Macon­
Allied
Chemical
monitor).

In
Georgia
EPD's
June
17,
2004,
submittal,
we
stated
that
both
Putnam
and
Jasper
Counties
met
only
one
of
the
six
"
other
factor"
thresholds
as
determined
by
EPD.
The
June
17
submittal
also
discusses
how
both
Jasper
and
Putnam
Counties
are
already
subject
to
VOC
and
NOx
control
regulations
that
are
more
stringent
than
other
portions
of
the
state.

EPA's
April
1,
2003,
guidance
memo
"
Designations
for
the
Fine
Particulate
National
Ambient
Air
Quality
Standards"
states
the
following:

Boundaries
used
for
implementation
of
the
8­
hour
ozone
standard
may
also
be
an
important
factor
in
determining
boundaries
for
the
PM2.5
nonattainment
areas.
Indeed,
there
are
many
areas
that
violate
both
the
8­
hour
ozone
and
the
PM2.5
standards,
and
States
and
Tribes
may
wish
the
nonattainment
boundaries
for
the
two
pollutants
to
be
identical
in
order
to
coordinate
air
quality
planning,
control
strategy
development,
and
the
implementation
of
the
transportation
conformity
rule.

Thus,
keeping
the
Atlanta
PM2.5
nonattainment
area
as
similar
as
possible
to
the
existing
8­
hour
ozone
nonattainment
will
ensure
more
efficient
air
quality
and
transportation
planning
and
control
strategy
development.
The
only
difference
between
the
8­
hour
ozone
nonattainment
area
and
EPD's
recommended
PM2.5
nonattainment
area
for
Atlanta
is
a
small
portion
of
northeast
Heard
County.
There
are
no
public
roads
in
this
section
of
Heard
County
and
only
one
stationary
source
of
emissions
 
Georgia
Power's
Plant
Wansley.

All
of
the
above
information
provides
sound
evidence
that
neither
Jasper
nor
Putnam
County
should
be
included
in
the
Atlanta
PM2.5
nonattainment
area.
As
stated
in
EPD's
June
17th
submittal,
should
EPD
find
it
necessary
to
require
emission
reductions
from
Plant
Branch
(
or
any
other
source
not
located
within
a
designated
nonattainment
area)
to
achieve
and
maintain
attainment
of
the
PM2.5
standard
in
Atlanta,
EPD
already
has
the
authority
to
require
such
controls
under
Rule
391­
3­
1­.
03(
8)(
e).
