Revision to the Georgia State Implementation Plan for the Removal of
Georgia Rule 

391-3-1-.02(zz) Gasoline Dispensing 

Facilities – Stage II

September 25, 2014

 

Prepared by:

Georgia Department of Natural Resources

Environmental Protection Division

Air Protection Branch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)(zz),
Gasoline Dispensing Facilities – Stage II otherwise known as Georgia
Rule (zz) from the Georgia SIP. 

As a former 1990 Clean Air Act serious ozone nonattainment area, Georgia
submitted its initial Stage II gasoline vapor recovery rule Georgia Rule
(zz) on November 13, 1992, to the U.S. Environmental Protection Agency
(EPA) for initial approval. EPA approved Georgia Rule (zz) into the
Georgia SIP on February 2, 1996 [61 FR 3819]. This request to remove
Georgia Rule (zz) is based on EPA Guidance Document EPA-457/B-12-001,
August 7, 2012, “Guidance on Removing Stage II Gasoline Vapor Control
Programs from State Implementation Plans and Assessing Comparable
Measures”.

Georgia EPD demonstrates in this SIP revision that removal of Georgia
Rule 391-3-1-.02(2)(zz), “Gasoline Dispensing Facilities – Stage
II” from Georgia’s SIP is consistent with section 110 (l) of the CAA
and will not interfere with the attainment of the NAAQS and with
reasonable further progress toward that attainment.  Removal of Georgia
Rule 391-3-1-.02(2)(zz), “Gasoline Dispensing Facilities – Stage
II” from Georgia’s SIP will result in VOC emission reductions
beginning in 2016.

  TABLE OF CONTENTS

  TOC \o "1-4" \h \z \u    HYPERLINK \l "_Toc400689581"  Executive
Summary	  PAGEREF _Toc400689581 \h  i  

  HYPERLINK \l "_Toc400689582"  1.0	Introduction and Background	 
PAGEREF _Toc400689582 \h  1  

  HYPERLINK \l "_Toc400689583"  1.1	The Atlanta Ozone Nonattainment Area
  PAGEREF _Toc400689583 \h  1  

  HYPERLINK \l "_Toc400689584"  1.2	Stage II Vapor Recovery Rule	 
PAGEREF _Toc400689584 \h  3  

  HYPERLINK \l "_Toc400689585"  1.3	On-Board Refueling Vapor Recovery
Controls	  PAGEREF _Toc400689585 \h  4  

  HYPERLINK \l "_Toc400689586"  1.4	Widespread Use	  PAGEREF
_Toc400689586 \h  4  

  HYPERLINK \l "_Toc400689587"  2.0	Removal Request	  PAGEREF
_Toc400689587 \h  6  

  HYPERLINK \l "_Toc400689588"  2.1	Clean Air Act Provisions	  PAGEREF
_Toc400689588 \h  6  

110(ℓ)	  PAGEREF _Toc400689589 \h  6  

  HYPERLINK \l "_Toc400689590"  2.3	Removal Request	  PAGEREF
_Toc400689590 \h  6  

  HYPERLINK \l "_Toc400689591"  3.0	Emissions Calculations	  PAGEREF
_Toc400689591 \h  9  

  HYPERLINK \l "_Toc400689592"  3.1	Incremental Benefit	  PAGEREF
_Toc400689592 \h  9  

  HYPERLINK \l "_Toc400689593"  3.2	Area-Wide VOC Inventory Impacts	 
PAGEREF _Toc400689593 \h  12  

  HYPERLINK \l "_Toc400689594"  3.3	Motor Vehicle Emissions Comparisons	
 PAGEREF _Toc400689594 \h  14  

  HYPERLINK \l "_Toc400689595"  4.0	Decommissioning Provisions	  PAGEREF
_Toc400689595 \h  17  

  HYPERLINK \l "_Toc400689596"  5.0	NOx and VOC Sensitivity	  PAGEREF
_Toc400689596 \h  19  

  HYPERLINK \l "_Toc400689597"  5.1	Sensitivity of Ozone in Atlanta to
NOx and VOC Emissions	  PAGEREF _Toc400689597 \h  19  

  HYPERLINK \l "_Toc400689598"  5.1.1	Sensitivity Modeling NOx and VOC
Emissions	  PAGEREF _Toc400689598 \h  19  

  HYPERLINK \l "_Toc400689599"  5.1.2	Modeling Scenarios	  PAGEREF
_Toc400689599 \h  19  

  HYPERLINK \l "_Toc400689600"  5.1.1	Modeling Results	  PAGEREF
_Toc400689600 \h  20  

  HYPERLINK \l "_Toc400689601"  6.0	Conclusion	  PAGEREF _Toc400689601
\h  22  

  HYPERLINK \l "_Toc400689602"  7.0	References	  PAGEREF _Toc400689602
\h  23  

 

LIST OF TABLES

  TOC \f c \h \z \t "Table Heading,1" \c "Table"    HYPERLINK \l
"_Toc400689570"  Table 3-1.  Emissions Benefit of Maintaining Stage II
VRS in Atlanta	  PAGEREF _Toc400689570 \h  10  

  HYPERLINK \l "_Toc400689571"  Table 3-2.  Compatibility Factor	 
PAGEREF _Toc400689571 \h  10  

  HYPERLINK \l "_Toc400689572"  Table 3-3.  Incompatibility of Vacuum
Assisted Stage II VRS and ORVR	  PAGEREF _Toc400689572 \h  11  

  HYPERLINK \l "_Toc400689573"  Table 3-4.  Incremental Benefit of Stage
II VRS Controls	  PAGEREF _Toc400689573 \h  12  

  HYPERLINK \l "_Toc400689574"  Table 3-5. The Atlanta Area Portion of
National Gasoline Consumption	  PAGEREF _Toc400689574 \h  13  

  HYPERLINK \l "_Toc400689575"  Table 3-6.  Projected Gasoline
Consumption of the Atlanta Nonattainment Area	  PAGEREF _Toc400689575 \h
 13  

  HYPERLINK \l "_Toc400689576"  Table 3-7.  Impact on the Area Wide VOC
Inventory	  PAGEREF _Toc400689576 \h  14  

  HYPERLINK \l "_Toc400689577"  Table 3-8.  Attainment Baseline VOC
Emissions Inventory for Motor Vehicles Compared to Modeled VOC Emissions
Inventory with Stage II VRS.	  PAGEREF _Toc400689577 \h  15  

  HYPERLINK \l "_Toc400689578"  Table 3-9.  Attainment Baseline VOC
Emissions Inventory for Motor Vehicles Compared to Modeled VOC Emissions
Inventory without Stage II VRS.	  PAGEREF _Toc400689578 \h  15  

  HYPERLINK \l "_Toc400689579"  Table 3-10.  VOC Emissions Inventory
with Stage II VRS Compared to VOC Emissions Inventory with only ORVR.	 
PAGEREF _Toc400689579 \h  16  

  HYPERLINK \l "_Toc400689580"  Table 5-1.  Normalized NOx and VOC
Sensitivity at 10 Atlanta Ozone Monitors	  PAGEREF _Toc400689580 \h  20 


 

LIST of APPENDICES

Appendix A	Stage II VRS Incremental Benefit Analysis

Appendix B	Ozone Sensitivity in Atlanta in Relation to the SEMAP
Sensitivity Study

Appendix C	SEMAP Sensitivity Study

Appendix D	Stage II Rule Package

Appendix E	Emissions and Air Quality Modeling for SEMAP-Final Report



List of Acronyms

Acronym	Meaning	Acronym	Meaning

AERR	Air Emissions Reporting Requirement	NAA	Nonattainment Area

ARC	Atlanta Regional Commision	NAAQS	National Ambient Air Quality
Standard

CAA	Clean Air Act	NOx	Nitrogen Oxides

CAAA	Clean Air Act Amendment	O3	Ozone

CB-IV	Carbon Bond IV	ORVR	On-Board Refueling Vapor Recovery

CDR	Conformity Determination Report	OTR	Ozone Transport Region

CFR	Code of Federal Regulations	Ppt	Parts Per Trillion

CMAQ	Community Multiscale Air Quality	RFP	Reasonable Further Progress

DV	Design Value	SIP	State Implementation Plan

EPA	Environmental Protection Agency	TPD	Tons Per Day

EPD	Environmental Protection Division	UST	Underground Storage Tank

GDF	Gasoline Dispensing Facilities	VISTAS	Visibility Improvement State
and Tribal Association of the Southeast

MOVES	Motor Vehicle Emissions Simulator	VOC	Volatile Organic Compound

MVEB	Motor Vehicle Emissions Budget



Introduction and 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 Georgia Rule
391-3-1-.02(zz)  (Gasoline Dispensing Facilities—Stage II). This plan
will focus on the Atlanta Ozone Nonattainment Area since the primary
pollutant emitted from gasoline dispensing facilities is volatile
organic compounds (VOCs), a precursor along with nitrogen oxide (NOx)
for ozone.  VOC is not a precursor for PM2.5.

The Atlanta Ozone 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 (NAA) effective January 1, 2004. 

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,
including Stage II VOC emission controls for gasoline dispensing
facilities. As a result of EPA's implementation of the original federal
Clean Air Act (CAA) 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
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 Metropolitan Statistical Area
(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:  Barrow, Bartow, Carroll, Hall, Newton, Spalding, and Walton.
With an attainment deadline of June15, 2007, marginal areas were
required to attain the 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 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].

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 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.  The attainment demonstration was
subsequently withdrawn on April 4, 2012. These requirements are
suspended as long as the area continues to attain the standard. This
final rule became effective on July 25, 2011. 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.On April 4, 2012, EPD
requested under CAAA of 1990 that the Atlanta area be redesignated from
nonattainment to attainment with respect to the 1997 8-hour ozone NAAQS
based on ambient monitoring data from 2008-2010. This includes
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 (which lowered
the NAAQS from 0.08 ppm to 0.075 ppm).  The 15-county area includes the
counties of Bartow, Cherokee, Clayton, Cobb, Coweta, Dekalb, Douglas,
Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, and
Rockdale.

Stage II Vapor Recovery Rule

Volatile organic compounds (VOC) are emitted from the refueling of
gasoline vehicles and trucks at gasoline dispensing facilities (GDF).
Stage II Vapor Recovery Systems (VRS) refers to processes at GDFs when
the gasoline is delivered or transferred from the underground storage
tank (UST) to the vehicle fuel tank. When gasoline is pumped into a
vehicle, the empty space in the tank has gasoline vapors that are forced
out of the tank.  With Stage II VRS, instead of being emitted into the
air, those vapors are directed into the UST.

There are two types of Stage II VRS controls.  The first is a balance
type of Stage II system.  A balance system has a rubber boot around the
gasoline nozzle spout that fits snugly up to a vehicle’s fill pipe. 
When the gasoline is pumped into the vehicle, an increase in pressure in
the vacant space of the vehicle gas tank, combined with a slight
decrease in pressure in the UST from emptying fuel, forces the gasoline
vapors from the tank, through fill pipe into the UST.  The second is a
vacuum assist system that uses a vacuum pump on the vapor return line to
help draw the vapors from the vehicle fill pipe into the UST.  Nearly
all commercial facilities in Georgia use vacuum assist systems.

The Stage II Vapor Recovery Program is required by section 182(b)(3) of
the Clean Air Act

(CAA).  State and local agencies with nonattainment areas classified as
“moderate” or worse ozone are required to implement Stage II VRS at
gasoline dispensing facilities. 

Georgia submitted its initial Stage II gasoline vapor recovery rule
Georgia Rule (zz) on November 13, 1992, to EPA for initial approval and
EPA approved Georgia Rule (zz) into the Georgia SIP on February 2, 1996
[61 FR 3819]. Georgia Rule (zz) Gasoline Dispensing Facilities--Stage II
requires all gasoline dispensing facilities located in the counties of
Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth,
Fulton, Gwinnett, Henry, Paulding, and Rockdale to be equipped with and
operating with an approved Stage II VRS to recover the displacement
vapors from the vehicle’s gasoline storage tank. 

On-Board Refueling Vapor Recovery Controls

Onboard Refueling Vapor Recovery (ORVR) is a vehicle emission control
system that captures fuel vapors from the vehicle gas tank during
refueling on the vehicle itself.  With ORVR, the gas tank and fill pipe
are designed so that when refueling the vehicle, fuel vapors in the gas
tank travel to an activated carbon packed canister, which adsorbs the
vapor.   To prevent vapors from escaping through the fill pipe opening,
a seal in the fill pipe allows liquid gasoline to enter, but blocks the
vapors from escaping.  When the engine is in operation, it draws the
gasoline vapors into the engine intake manifold to be used as fuel.  

There is some incompatibility between ORVR and the vacuum assisted Stage
II VRS where emissions can increase rather than decrease.
Incompatibility refers to excess emissions resulting from Stage II VRS
and ORVR being used together because the two emission controls together
result in extra venting of VOCs from the underground storage tank into
the ambient air.  Studies, including one conducted by the California Air
Resources Board (CARB), further indicate that incompatibility between
the vacuum assist version of the Stage II VRS (the type used in Atlanta)
and ORVR degrade the benefit of keeping the Stage II VRS.

On April 16, 1994, EPA promulgated regulations [59 FR 16262] under
Section 202(a)(6) of the CAA requiring the phase-in of ORVR controls on
new vehicles, beginning in 1998 for passenger cars, 2001 for light duty
trucks, and 2004 for heavy duty trucks under 14,000 GVWR (Gross Vehicle
Weight Rating). 

Widespread Use

Section 202(a)(6) of the CAA also allows EPA to waive certain
requirements of the Stage II vapor recovery program when the EPA
Administrator finds that ORVR systems are in widespread use in the
vehicle fleet:

“the requirements of section [182]a(b)(3) of this title (relating to
stage II gasoline vapor recovery) for areas classified under section
[181] of this title as moderate for ozone shall not apply after
promulgation of such standards and the Administrator may, by rule,
revise or waive the application of the requirements of such section
[182]a  (b)(3) of this title for areas classified under section [181] of
this title as Serious, Severe, or Extreme for ozone, as appropriate,
after such time as the Administrator determines that onboard emissions
control systems required under this paragraph are in widespread use
throughout the motor vehicle fleet.”  

On May 16, 2012, EPA published in the federal register its determination
that the use of ORVR for capturing gasoline vapor when gasoline-powered
vehicles are refueled is in widespread use throughout the highway motor
vehicle fleet [77 FR 28772]. 

Section 202(a)(6) of the CAA gives EPA discretionary authority to revise
or waive the section 182(b)(3) Stage II requirement by rule after the
Administrator determines that ORVR is in widespread use throughout the
motor vehicle fleet. EPA also has broad discretion in how it defines
widespread use and the manner in which any final determination is
implemented.

Stage II VRS control efficiency is assumed by EPA to be 86 percent from
the MOVES 2010b default database.  The percentage of gasoline pumped
into vehicles from GDFs with Stage II control is estimated by EPA to be
90 percent as per EPA guidance.  By multiplying these two numbers, the
expected area-wide control efficiency of Stage II VRS is 77.4 percent.

Because the percentage of vehicles without ORVR is decreasing on a
yearly basis and the amount of gasoline pumped to these vehicles is
decreasing as well, EPA could predict a date for ORVR widespread use. 
EPA considered two different approaches.  They first looked at the
assumed 98 percent control efficiency of ORVR [77FR 28775 and EPA
guidance], and then used the Motor Vehicle Emissions Simulator (MOVES)
2010 motor vehicle emissions model to determine the number of vehicles
with ORVR projected out to the year 2020.  Overall ORVR efficiency was
determined by multiplying the fraction of gasoline dispensed into
vehicles with ORVR by the assumed 98 percent average in-use control
efficiency.  Using this approach, ORVR control efficiency reached the
equivalent Stage II VRS control efficiency of 77.4 percent by May 2013
[77Fr 28778].  The second approach used observations from the first
approach to determine that by the end of the calendar year 2012; more
than 75 percent of gasoline will be dispensed into vehicles with ORVR,
resulting in an overall ORVR control efficiency close to the Stage II
VRS control efficiency and allowing for a phased-in approach to ORVR. 
Further information on EPA’s approach for determining widespread use
can be found in EPA’s determination [77 FR 28772] and its proposal
published in the federal register on July 15, 2011 [76 FR
41731].Removal Request

Clean Air Act Provisions

EPA can only propose approval of a SIP revision seeking to discontinue
an existing SIP-approved Stage II control program if the SIP revision
meets the following CAA provisions:

The requirements of 110(ℓ), 

The requirements of Section 193 for any current nonattainment area that
adopted a Stage II control program into its SIP prior to November 15,
1990, and 

The requirements of Section 184(b)(2) which applies to any area of the
northeast ozone transport region (OTR).

The State of Georgia is not a part of the northeast OTR, as such Section
184(b)(2) does not apply.  Additionally, since the State of Georgia
adopted its Stage II Vapor Recovery Program into its SIP on February 2,
1996 [61 FR 3819], Section 193 also does not apply.  Therefore, the
remainder of this section includes a detailed description of the
requirements of Section 110(ℓ). 

110(ℓ)

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 uses the analysis provided by EPA’s “Guidance on
Removing Stage II Gasoline Vapor Control Programs from State
Implementation Plans and Assessing Comparable Measures” (herein after
called the guidance document) to demonstrate that the removal of
Georgia’s Rule (zz) will not interfere with attainment, reasonable
further progress or any other requirement of the Clean Air Act. 

Removal Request

With the submissions of this Plan Revision, Georgia EPD is requesting
the removal of Georgia Rule 391-3-1-.02(2)(zz), “Gasoline Dispensing
Facilities – Stage II” from Georgia’s SIP.  This document was
prepared using the analysis provided by Section 3 of the EPA’s
Guidance Document that the removal of Georgia Rule (zz) is consistent
with section 110 (l) of the CAA.

Specifically, Georgia EPD will present calculations comparing VOC
emissions with Stage II and ORVR controls in place to VOC emissions with
only ORVR in place.   Using methods described in EPA’s Guidance
Document, Georgia EPD will show that the emission control gain,
identified in the guidance as the “increment” (or incremental
benefits), of Stage II VRS controls decreases as ORVR controls are
phased-in.

Once the incremental benefit has been evaluated, the increment is then
used to show the impact on the area-wide VOC emission inventory and that
removal of Stage II VRS controls will not interfere with attainment of
the NAAQS or with further reasonable progress.

w that removal of Stage II VRS controls will not contribute to
interference under 110(ℓ), EPD has separated the motor vehicle
emissions budget and compared both the budget and the motor vehicle VOC
emission inventory from the 2008 Atlanta Area Maintenance SIP with the
projected VOC emissions from motor vehicle with and without Stage II VRS
controls.

The State of Georgia is a NOx limited area, which means that due to the
over-abundance of biogenic VOC, the control of NOx is the limiting
factor in ozone formation. The sensitivity of ozone formation in the
Atlanta area to reductions of NOx and VOC emissions are described in
Section 5 of this document.  This document will demonstrate that the
short-term incremental increase in emissions during the phase-out period
will not contribute to interference under 110(ℓ).  The result is a
demonstration that the removal of Georgia Rule (zz) will not interfere
with the attainment of the NAAQS or with reasonable further progress as
defined by the CAA.

In the 2008 8-hour proposed ozone rule [78 FR 34184, 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 of after designation without any additional local planning.”
Therefore as a part of the sensitivity demonstration, Georgia EPD
included 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.

In evaluating whether a given SIP revision would interfere with
attainment or maintenance, as required by section 110(ℓ), the EPA
generally considers whether the SIP revision will allow for an increase
in actual emissions into the air over what is allowed under the existing
EPA-approved SIP. The EPA has not required that a state produce a new
complete attainment demonstration for every SIP revision, provided that
the status quo air quality is preserved.”  The removal of Rule (zz)
will result in a relatively small increase in VOC emissions for a short
period of time.  The sensitivity study information in Section 4 will
show that any increase in ozone levels are insignificant and short-lived
and will show that the status quo air quality will be preserved.  

EPA’s August 7, 2012 guidance also states on page 5 states “[I]n
areas where ozone formation is limited by the availability of NOx
emissions, a small (and ever-declining) increase in VOC emissions may
have little or no effect on future ozone levels. The EPA would consider
any air quality analyses and supporting information provided by a state
to show that a proposed SIP revision would not interfere with attainment
and maintenance of the NAAQS.”  This document shows that complete
removal of Stage II will result in a slight increase in VOC in 2014,
declining to a smaller increase in 2015, and resulting in
ever-increasing emission reduction starting in 2016.  The sensitivity
study in Section 4 will demonstrate that this small, temporary increase
in VOC emissions will have no observable effect on current or future
ozone levels and will not interfere with attainment or maintenance of
the NAAQS.

Also, since VOC is not a precursor for particulate matter, there is no
possibility that removal of the Georgia Rule (zz) will impact the
ambient air quality standard for the PM2.5 NAAQS in the Atlanta area or
interfere with attainment or maintenance of the standard.

EPA’s waiver of the statutory requirement for the implementation of
Stage II Vapor Recovery, which is included in their determination that
the use of ORVR is in widespread use throughout the on- road motor
vehicle fleet, allows that the removal of Georgia Rule (zz) will not
interfere with any applicable requirement of the CAA.

Emissions Calculations

This section includes calculations as described in EPA’s Guidance
Document for the analysis of the incremental benefit of maintaining
Stage II VRS controls as ORVR technology is phased-in.  These
calculations show that regardless of the small yet temporary increase in
emissions that could result from removing Stage II VRS controls, the
incremental benefit of keeping Stage II VRS controls as ORVR controls
are phased-in is an ever decreasing benefit, which eventually becomes a
disbenefit.

wide VOC inventory has been calculated and evaluated to show that it is
consistent with Section 110 (ℓ).

The Atlanta 8-Hour Ozone Maintenance Plan for the 1997 8-hour Ozone
NAAQS, submitted to EPA on October 10, 2009, lists 2008 as its
attainment or baseline year.  For the purposes of consistency and to
show that removal of the Stage II VRS controls will not interfere with
attainment or progress toward attainment, 2008 has been chosen as the
baseline year for the purpose of the comparative analysis detailed in
this section, while all analysis of the benefit of Stage II will be
calculated for the current year to the future when a disbenefit is
demonstrated.  In addition, 2008 is also a year for which states are
required to submit an inventory required by EPA’s Air Emissions
Reporting Requirement (AERR), which results in a comprehensive statewide
inventory.  The calculations are used to demonstrate emissions changes
beginning in 2014, however, decommissioning cannot begin until May 1,
2014 and must be completed by April 30, 2016.  There is no schedule for
station decommissioning, only the requirement that the stations have the
decommissioning completed by the deadline.  The emission increase
demonstrated for 2014 is larger than that which will actually occur
because the calculations assume that all decommissioning activities
occur in 2014. 

Incremental Benefit

In EPA’s Guidance Document, the overall Stage II – ORVR increment is
defined as the annual area-wide emission control gain from Stage II
installations at GDFs as ORVR technology phases in.  The increment is
quantified as the fractional reduction of VOC from refueling in a given
nonattainment area over the ozone season for a given year for the 13
counties in the Atlanta area with Stage II controls.  Because there are
only a small number of non-ORVR equipped vehicles and that number
continues to grow smaller, there is only a small level of future
emissions reductions achievable from Stage II VRS controls, resulting in
an eventual net increase in emissions of VOC over time when taking all
factors into account.  A more detailed analysis of the calculation of
the incremental benefit can be found in Appendix A.

To calculate the increment, the emissions benefit of maintaining Stage
II VRS controls is adjusted by taking into account the incompatibility
of vacuum assisted Stage II VRS and ORVR.  Because of this
incompatibility, as more vehicles become equipped with ORVR, there is a
benefit loss from maintaining Stage II VRS controls due to
incompatibility of the two control options.   All calculations used in
this analysis can be found in detail in Appendix A.

Table 3-1.  Emissions Benefit of Maintaining Stage II VRS in Atlanta 

Year

(i)	Fraction of Gasoline Covered by Stage II VRS

(QSII)	Fraction of Gasoline Dispensed To ORVR Vehicles

(QORVRi)	Control Efficiency Of Stage II VRS

(NiuSII)	Emissions Benefit of Stage II VRS Controls

(fractional reduction)

2012	0.9	0.777	0.62	0.124

2013	0.9	0.810	0.62	0.106

2014	0.9	0.840	0.62	0.089

2015	0.9	0.865	0.62	0.075

2016	0.9	0.886	0.62	0.064

2017	0.9	0.903	0.62	0.054

Note: 	All emissions values in this chart refer solely to on-road mobile
source emissions. 

Table 3-1 shows the maximum potential emissions benefit of Stage II VRS
controls from 2012 to 2017 in the 13-county Atlanta area.  These maximum
potential emissions benefits were calculated by first removing the
portion of ORVR equipped vehicles from consideration, so that
incompatibility is not an issue in the calculation and since there is no
derived benefit of Stage II with ORVR equipped vehicles.  The fraction
of gasoline dispensed to vehicles with only Stage II VRS (1-QORVRi) was
multiplied by both the fraction of gasoline pumped to these vehicles
from facilities equipped with Stage II VRS and the control efficiency of
the Stage II VRS controls.  Further information can be found in Appendix
A.

As indicated above, the incremental benefit is based on the emissions
benefit of the Stage II VRS controls, but it is adjusted based on the
incompatibility of vacuum assisted Stage II VRS and ORVR.  In order to
calculate this incompatibility, the increase in the UST vent pipe
emissions beyond what is considered normal emission losses must be
determined.  This increase is called the compatibility factor

Table 3-2.  Compatibility Factor

Year

(i)	Constant	Fraction of Annual Area-Wide Vehicle Miles Traveled by ORVR
Equipped Vehicles

(VMTORVRi)	Compatibility Factor

(CFi)

2012	0.07645	0.800	0.061

2013	0.07645	0.834	0.064

2014	0.07645	0.863	0.066

2015	0.07645	0.888	0.068

2016	0.07645	0.909	0.069

2017	0.07645	0.925	0.071

Note: 	All emissions values in this chart refer solely to on-road mobile
source emissions. 

Table 3-2 shows the criteria used to determine the compatibility factor
for each year under consideration.  EPA’s Guidance Document states
that the compatibility factor is a function of the fraction of gasoline
dispensed to ORVR vehicles, but that using the vehicle miles traveled by
ORVR equipped vehicles is an acceptable substitute.  The vehicle miles
used in this calculation are multiplied by a constant term provided for
the States by EPA in the Guidance Document.  The resulting compatibility
factor is then used to calculate the incompatibility of vacuum assist
Stage II VRS with ORVR. More detailed calculations can be found in
Appendix A.

Table 3-3.  Incompatibility of Vacuum Assisted Stage II VRS and ORVR

Year

(i)	Fraction of Gasoline Dispensed Through Vacuum Assist Stage II VRS

(QSIIva)	Compatibility Factor

(CFi)	Incompatibility

2012	0.95	0.061	0.058

2013	0.95	0.064	0.061

2014	0.95	0.066	0.063

2015	0.95	0.068	0.064

2016	0.95	0.069	0.066

2017	0.95	0.071	0.067

Note: 	All emissions values in this chart refer solely to on-road mobile
source emissions. 

As Table 3-3 shows the fraction of gasoline dispensed through vacuum
assist Stage II VRS as 0.95. This number is an assigned value in EPA’s
Guidance Document that was based on the percentage of facilities in the
13-county Atlanta area with the vacuum assist controls in use.  The
compatibility factor is multiplied by this fraction in order to
calculate the incompatibility between Stage II VRS controls and ORVR
controls.

Table 3-4.  Incremental Benefit of Stage II VRS Controls

Year	Emissions Benefit of Stage II VRS Controls

(fractional reduction)	Incompatibility of ORVR and Vacuum Assisted Stage
II VRS Controls	Increment

(fraction)

2012	0.124	0.058	0.066

2013	0.106	0.061	0.045

2014	0.089	0.063	0.027

2015	0.075	0.064	0.011

2016	0.064	0.066	-0.002

2017	0.054	0.067	-0.013

Note: 	All emissions values in this chart refer solely to on-road mobile
source emissions. 

Positive values indicate a benefit while negative values indicate a
benefit loss.

As shown in Table 3-4, by adjusting the emissions benefit of Stage II
VRS controls to take into account the incompatibility of ORVR controls
and vacuum assisted Stage II VRS controls, the increment continues to
decrease for Stage II VRS controls as ORVR controls are phased-in and
decreases until 2016, at which point there is a benefit loss from
maintaining Stage II VRS controls. For more information on the
calculation of incompatibility, see Appendix A. 

Area-Wide VOC Inventory Impacts

Once the increment of maintaining Stage II VRS controls has been
calculated, it is necessary to evaluate the impact on the area-wide VOC
emission inventory.  This is determined by multiplying projected future
gasoline consumption for the Atlanta area with an emission factor for
refueling losses and adjusting for the increment.

Table 3-5. The Atlanta Area Portion of National Gasoline Consumption

Year	Atlanta Area’s Portion of Total National Gasoline Consumption
Total National Gasoline Consumption – May Through September

(gallons)	Atlanta Area Consumption – May Through September 2010

(gallons)

2010	0.01677214	59,588,199,000	999,421,616

Note:  All emissions values in this chart refer solely to on-road mobile
source emissions.

Table 3-5 shows the Atlanta area’s consumption of gasoline based on
the year 2010 according to the FHWA Highway Statistics- monthly gasoline
reported by states. More detailed explanations and calculations can be
found in Appendix A.

Table 3-6.  Projected Gasoline Consumption of the Atlanta Nonattainment
Area

Year	Atlanta Area Consumption – May Through September 2010

(gallons)	Projected Ratio for Gasoline Consumption Growth	Projected
Gasoline Consumption of the 13-county Atlanta Nonattainment Area
(gallons/season)

2010	999,421,616	N/A	N/A

2012	999,421,616	1.0343	1,033,701,777

2013	999,421,616	1.0399	1,039,298,538

2014	999,421,616	1.0410	1,040,397,902

2015	999,421,616	1.0421	1,041,497,266

2016	999,421,616	1.0443	1,043,695,994

2017	999,421,616	1.0377	1,037,099,811

Note:  All emissions values in this chart refer solely to on-road mobile
source emissions.

By using a projected ratio for gasoline consumption from the Department
of Energy’s  EIA Annual Outlook (AEO) – Liquid Fuels Supply and
Disposition Reference case table, the gasoline consumption of the
13-county Atlanta area was projected for 2012 through 2017 as shown in
Table 3-6.  More detailed calculations can be found in Appendix A.

Table 3-7.  Impact on the Area Wide VOC Inventory

Year	Increment	Uncontrolled Displacement (non-ORVR) Refueling Emission
Factor

(grams/gallon)	Projected Gasoline Consumption of the 13-county Atlanta
Nonattainment Area (gallons/season)	Area –Wide VOC Inventory Reduction

(tons per season)



2012	0.066	4.6	1,033,701,777	347.68

2013	0.045	4.6	1,039,298,538	239.51

2014	0.027	4.6	1,040,397,902	140.34

2015	0.011	4.6	1,041,497,266	57.23

2016	-0.002	4.6	1,043,695,994	-12.74

2017	-0.013	4.6	1,037,099,811	-68.65

Note:  All emissions values in this chart refer solely to on-road mobile
source emissions. Positive values indicate a benefit while negative
values indicate a benefit loss.

Table 3-7 shows the tons of reduction in VOC emissions for each ozone
season beginning in 2012 if Stage II VRS is maintained as ORVR is phased
in.  As ORVR is phased in, beginning in 2016, there is an increase in
emissions from the incompatibility of the two control systems. 

Motor Vehicle Emissions Comparisons

An additional method of showing the impact of maintaining Stage II VRS,
as ORVR is phased in, is to compare motor vehicle emissions with and
without Stage II in place to the motor vehicle emissions budget (MVEB). 


Motor vehicle emissions budget values for 2006 with Stage II in place
and projected emissions for 2016 with Stage II VRS in place were taken
from the Atlanta Regional Commission’s (ARC) Volume II: Plan 2040
Conformity Determination Report (CDR)’s transportation conformity
demonstration.  VOC emissions with Stage II VRS in place for the years
2008, 2010 and 2013 were modeled using MOVES, after which, the emissions
for interim years were calculated using interpolation.

The motor vehicle VOC emissions with and without Stage II VRS controls
in place were then compared to both the motor vehicle VOC emissions
budget and the motor vehicle VOC emissions in the 2008 Maintenance SIP.

Table 3-8.  Attainment Baseline VOC Emissions Inventory for Motor
Vehicles Compared to Modeled VOC Emissions Inventory with Stage II VRS.

Year	Motor Vehicle Emissions Budget

(tons per day)	2008 Maintenance Plan Motor Vehicle Baseline VOC
Emissions Inventory 

(tons per day)	Motor Vehicle VOC Emissions Modeled in MOVES 2010 With
Stage II VRS Controls In Place

(tons per day)

2008	171.83	165.53	165.53

2012	171.83	165.53	127.33 

2013	171.83	165.53	117.78

2014	171.83	165.53	108.23 

2015	171.83	165.53	98.68

2016	171.83	165.53	89.13

Note:  All emissions values in this chart refer solely to on-road mobile
source emissions

Table 3-8 indicates that with Stage II VRS controls, the VOC emissions
decrease between 2008 and 2016, and remain less than both the MVEB and
the motor vehicle baseline emissions in the 2008 maintenance plan.

Table 3-9.  Attainment Baseline VOC Emissions Inventory for Motor
Vehicles Compared to Modeled VOC Emissions Inventory without Stage II
VRS.

Year	Motor Vehicle Emissions Budget

(tons per year)	VOC Baseline Emissions 2008 

(tons per year)	VOC Emission Without Stage II  

(tons per day) 

2008	171.83 	165.53	N/A

2012	171.83	165.53	N/A

2013	171.83	165.53	N/A

2014	171.83	165.53	109.15

2015	171.83	165.53	99.05

2016	171.83	165.53	89.05

Note:  All emissions values in this chart refer solely to on-road mobile
source emissions

The analysis further continues by similarly evaluating the motor vehicle
VOC emissions without emissions reductions attributable to Stage II VRS
controls.  As Table 3-3 indicates, a decrease in overall area-wide VOC
emissions also occurs with only ORVR controls in place with VOC
emissions remaining less than both the MVEB and the motor vehicle
baseline emissions in the 2008 maintenance plan. See Appendix A further
details.

Table 3-10.  VOC Emissions Inventory with Stage II VRS Compared to VOC
Emissions Inventory with only ORVR.

Year	VOC Baseline Emissions 2008 

(tons per year)	VOC Emission With   With Stage II VRS Controls In Place 

(tons per day)	VOC Emissions with Stage II VRS Removed (only ORVR) 

(tons per day) 	VOC Emission Difference Between Stage II VRS In Place
and Removed

Incremental Benefit

(tons per day)

2008	165.53	165.53	N/A	N/A

2012	165.53	127.33	N/A	N/A

2013	165.53	117.78	N/A	N/A

2014	165.53	108.23	109.15	+0.92

2015	165.53	98.68	99.05	+0.37

2016	165.53	89.13	89.05	-0.085

Note: 	All emissions values in this chart refer solely to on-road mobile
source emissions. 

By comparing VOC emissions with continued implementation of Stage II VRS
and VOC Emissions with only ORVR controls in place to the 2008 baseline
emissions inventory as shown in Table 3-10 above, the phase-out of Stage
II would result in a small increase in emissions beginning in 2014 that
diminishes rapidly over time as ORVR is phased in, but that increase
will not interfere with attainment or progress toward attainment.   By
2016, the removal of Stage II VRS requirements will result in a greater
decrease in motor vehicle VOC emissions than the decrease attributable
to maintaining Stage II VRS controls.



Decommissioning Provisions

Included in the removal of the rule is the process of decommissioning
the Stage II VRS controls in such a way that it is done in a safe and
environmentally appropriate manner.   Not only will the owner/operator
follow the decommissioning process as amended in Georgia Rule (zz), he
will also perform testing and maintain records for two years after
decommissioning of the Stage II VRS Controls.

All end points of tubes and piping will be disconnected or removed, and
sealed. In particular, if the vapor recovery piping can be accessed
easily at the tank, then it must be sealed to be vapor tight. 

If the system has a vapor pump for each fueling position, then each
vapor pump is to be disabled or removed.  If the system has a centrally
located vacuum pump, then that mechanism is to be removed and sealed.  

All liquid-collection points will be emptied of liquid and any tubes
leading to submersible pumps will be disconnected at the pump and sealed
properly so that they are vapor tight.  As an alternative, the tubes can
be removed as long as the openings in the liquid-collection point are
sealed to be vapor tight.    A plug must be installed in the vacuum pump
to seal the vacuum port and the liquid-collection point cap must create
a vapor tight seal when placed on the liquid-collection point. 

Once the station has followed the necessary steps for removing the Stage
II VRS equipment it will then be necessary for the station to perform a
pressure decay test and tie-tank test to insure that the system is vapor
tight and that the storage tanks are still functional.  Stations can
begin decommissioning May 1, 2014.  

U.S. EPA released a proposed rule on July 15, 2011 that would establish
widespread use of onboard refueling vapor recovery (ORVR) as of June 30,
2013 and would allow areas requiring Stage II equipment at gasoline
dispensing facilities to be decommissioned.  A final rule was issued by
EPA on May 16, 2012 that determined widespread use of ORVR as the
effective date of the rulemaking, which was May 16, 2012.  As a result
of the proposed and final rule, Georgia EPD began receiving a number of
requests from new gasoline dispensing facilities and those undergoing
major modification to have the Stage II requirements waived or be exempt
from the rule.   The first of the letters were received in late 2011 and
EPD continued to receive requests until the Stage II rule was amended. 
EPD took no action on these letters until the rule was amended.  Most of
the facilities that had requested the waiver/exemptions did not install
the equipment.  The costs to install Stage II are in the tens of
thousands of dollars and would cost between $1,500 and $2,500 to remove.
 Most of the facilities would have had Stage II installed for 3 years or
less before they would need to remove it.  During these two years, the
Stage II systems would provide very little to no emission reductions,
but the costs would average well over $25,000 per facility for the
installation and removal of the Stage II systems.  Exempting new
facilities and those undergoing major modification since December 31,
2011 covered most of the facilities that had requested the
waiver/exemption.  

There is no schedule for station decommissioning, only the requirement
that all stations must have decommissioning completed by April 30, 2016.
 Emissions calculations performed in Section 3.0 of this document assume
all decommissioning occurs in 2014. Although the Stage II rule allows
for decommissioning to begin May 1, 2014, many facilities will continue
to operate, maintain, and test their Stage II systems until early 2016. 
EPD will continue to implement the Stage II rule through 2016.

These decommissioning procedures follow PEI/RP 300-09 recommended
practices related to capping and sealing vapor recovery underground
piping and vapor recovery dispenser piping, and the associated tests in
recommended practices.  EPD chose to deviate from the PEI recommended
practices related to the hanging hardware on dispensers.  EPD has chosen
not to require that the hanging hardware be replaced since it will not
result in any emission losses or present a safety hazard.  The cost of
replacing the hanging hardware can easily double or triple the cost of
decommissioning a Stage II system if required.

Georgia Rule (zz) has been amended to include these requirements
pertaining to the decommissioning of the Stage II VRS equipment and can
be found in Appendix D.

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).  EPA has recently stated in its “Guidance on
Removing Stage II Gasoline Vapor Control Programs from State
Implementation Plans and Assessing Comparable Measures” 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), is “in areas where ozone formation is limited by the
availability of NOx emissions.”  In this situation, “a small (and
ever-declining) increase in VOC emissions may have little or no effect
on future ozone levels.”

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
elevated 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.

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.  The entire "ozone season" was modeled (May 1 –
September 30) using a 12-km modeling grid that covered the Eastern U.S. 
Details of the modeling platform set-up can be found in Appendix E.

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 trillion ozone/ton per day,
ppt/TPD) at 10 ozone monitors in Atlanta.   EPD used an 85 parts per
billion (ppb) threshold to address the 1997 ozone NAAQS and a 75 parts
per billion (ppb) threshold to address the 2008 ozone NAAQS.  For
further details on the modeling assumptions and approach used to
calculate the normalized sensitivities of NOx and VOC, please see
Appendix B. 

Modeling Results

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

AIRS ID	

Site Name	NOx w/ 75 ppb threshold (ppt/TPD)	NOx w/ 85 ppb threshold
(ppb/TPD)	VOC w/ 75 ppb threshold (ppb/TPD)	VOC w/ 85 ppb threshold
(ppb/TPD)

13-067-0003	Kennesaw	-0.07427	-0.07972	-0.00453	-0.00485

13-077-0002	Newnan	-0.08090	-0.09576	-0.00176	-0.00156

13-085-0001	Dawsonville	-0.06219	-0.06219	-0.00702	-0.00070

13-089-0002	South DeKalb	-0.07714	-0.08744	-0.00580	-0.00685

13-097-0004	Douglasville	-0.07971	-0.08374	-0.00416	-0.00723

13-121-0055	Confederate Ave.	-0.06117	-0.06693	-0.00766	-0.01058

13-135-0002	Gwinnett	-0.07625	-0.09008	-0.00264	-0.00293

13-151-0002	McDonough	-0.08692	-0.09052	-0.00335	-0.00462

13-223-0003	Dallas /Yorkville	-0.06925	-0.06925	-0.00115	-0.00115

13-247-0001	Conyers	-0.08975	-0.10019	-0.00312	-0.00321



These results show that NOx emission reductions are generally 10-20
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 1997 and 2008 ozone NAAQS, the most conservative
approach would be to use the highest normalized NOx and VOC sensitivity
value across the 10 Atlanta ozone monitors.  The highest normalized NOx
sensitivity is 0.10019 ppb/TPD at the Conyers (13-247-0001) Site and the
highest normalized VOC sensitivity is 0.01058 ppb/TPD at the Confederate
Avenue, (13-121-0055) Site.  (Note that both of these highest
sensitivities are based on an 85 ppb threshold used to address the 1997
ozone NAAQS.  Use of sensitivities based on the 2008 ozone NAAQS
threshold of 75 ppb would result in lower normalized sensitivities and
thus less of an impact on ambient ozone levels.)

Based on the most conservative approach, for every ton per day of VOC
increased in the Atlanta area there is a corresponding increase of
0.01058ppb in ozone at the monitor; while for every ton per day of NOx
increased in the Atlanta area there is a corresponding increase of
0.10019ppb at the monitor.

The 2014 increase in VOC emission due to the removal of Stage II of 0.92
tons per day. Applying the sensitivity to VOC to 0.92 tons per day will
result in a corresponding increase in the concentration of ozone in the
Atlanta area of 0.00973 ppb, a very insignificant amount.  This value
will decrease for each year thereafter until 2016, as the ozone
concentration begins to decrease due to the emissions benefit of
removing Stage II controls.



Conclusion

In this SIP revision, Georgia EPD is requesting the removal of Georgia
Rule 391-3-1-.02(2)(zz), “Gasoline Dispensing Facilities – Stage
II” from Georgia’s SIP.  

Section 202(a)(6) of the CAA gives EPA discretionary authority to revise
or waive the section 182(b)(3) Stage II requirement by rule after the
Administrator determines that ORVR is in widespread use throughout the
motor vehicle fleet. EPA also has broad discretion in how it defines
widespread use and the manner in which any final determination is
implemented.

On May 16, 2012, EPA published in the federal register its determination
that the use of ORVR for capturing gasoline vapor when gasoline-powered
vehicles are refueled is in widespread use throughout the highway motor
vehicle fleet [77 FR 28772]. In that notice the Administrator also
exercised her authority to waive the statutory requirement that Serious,
Severe, and Extreme ozone nonattainment areas adopt and implement EPA
programs requiring Stage II gasoline vapor recovery systems (VRS) at
certain gasoline dispensing facilities (GDFs).   

On August 7, 2012, EPA issued “Guidance on Removing Stage II Gasoline
Vapor Control Programs from State Implementation Plans and Assessing
Comparable Measures”.  Georgia EPD has followed that guidance to show
that:  1) the emissions control gain (or incremental benefits) of Stage
II VRS control decreases as ORVR controls are phased in; 2) removal of
Stage II VRS controls will not interfere with attainment of the NAAQS or
with further reasonable progress; 3) calculations of motor vehicle
emissions without Stage II VRS show that emissions will be below the
MVEB and the motor vehicle VOC baseline emission inventory from the 2008
Atlanta Maintenance SIP; 4)  Atlanta’s ozone sensitivity to NOx rather
than to VOC emissions provides evidence that removal of Georgia Rule
(zz) will not interfere with the attainment or reasonable further
progress towards attainment of any  NAAQS.

EPA can propose approval of a SIP revision seeking to discontinue an
existing SIP-approved Stage II control program if Georgia’s SIP
revision meets the requirements of 110(ℓ). 

	

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I” from Georgia’s SIP is consistent with section 110 (l) of the CAA
and will not interfere with the attainment of the NAAQS and with
reasonable further progress toward that attainment.  Removal of Georgia
Rule 391-3-1-.02(2)(zz), “Gasoline Dispensing Facilities – Stage
II” from Georgia’s SIP will result in VOC emission reductions
beginning in 2016.  

Georgia EPD has demonstrated in this SIP revision that the removal of
Georgia Rule (zz) from the Georgia SIP is consistent with section 110
(l) of the CAA.

References

Atlanta Regional Commission’s (ARC), Volume II: Plan 2040 Conformity
Determination Report (CDR) (see Table 2)

CARB, Preliminary Draft Test Report, Total Hydrocarbon Emissions from
Two Phase II Vacuum Assist Vapor Recovery Systems During Baseline
Operations and Simulated Refueling of Onboard Refueling Vapor Recovery
(ORVR) Equipped Vehicles, Project Number ST-98-XX, June 1999.

CARB, Uncontrolled Vapor Emission Factor at Gasoline Dispensing
Facilities, January 5, 2000.

Department of Energy, EIA Annual Energy Outlook (AEO); “Liquid Fuels
Supply and Distribution 

-Reference Case”,
http://www.eia.gov/oiaf/aeo/tablebrowser/#release=AEO2011&subject=0-AEO2
011&table=11-AEO2011&region=0-0&cases=ref2011-d020911a .

State of Georgia, Rules for Air Quality Control, Chapter 391-3-1,
Effective August 9, 2012.

USEPA, “Guidance on Removing Stage II Gasoline Vapor Control Programs
from State Implementation Plans and Assessing Comparable Measures,”
Office of Air Quality Planning and Standards, EPA-457/B-12-001, August
7, 2012.

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.

USEPA, EPA Memorandum, “Calculating Stage II Vacuum Assist Stage II
VRS and ORVR Excess Emissions,” Glenn W. Passavant, May 2012.

USEPA, Technical Guidance-Stage II Vapor Recovery Systems for Control of
Gasoline Refueling Emissions at Gasoline Dispensing Facilities Vol.
1,” EPA-45-0/3-91-022a, November 1991

 CARB, Preliminary Draft Test Report, Total Hydrocarbon Emissions from
Two Phase II Vacuum Assist Vapor Recovery Systems During Baseline
Operations and Simulated Refueling of Onboard Refueling Vapor Recovery
(ORVR) Equipped Vehicles, Project Number ST-98-XX, June 1999.

DRAFT    Revision to the Georgia State Implementation Plan for the
Removal of Georgia Rule 391-3-1-.02(zz) Gasoline Dispensing Facilities
– Stage II

  PAGE  i  

  PAGE  ii  

DRAFT   Revision to the Georgia State Implementation Plan for the
Removal of Georgia Rule 391-3-1-.02(zz) Gasoline Dispensing Facilities
– Stage II

  PAGE  iv 

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