UNITEDSTATESENVIRONMENTALPROTECTIONAGENCYREGION4ATLANTAFEDERALCENTER61FORSYTHSTREETATLANTA,GEORGIA30303-8960Ms.KarenHaysChiefAirProtectionBranchEnvironmentalProtectionDivisionGeorgiaDepartmentofNaturalResources4244InternationalParkway,Suite120Atlanta,Georgia30354DearMs.Hays:.OCT1 3ThankyouforsubmittingtheStateofGeorgia's2015annualambientairmonitoringnetworkplan(NetworkPlan)receivedJune15,2015.TheNetworkPlanisrequiredby40CodeofFederalRegulations(CFR)§58.10.TheU.S.EnvironmentalProtectionAgencyRegion4understandsthattheGeorgiaEnvironmentalProtectionDivisionprovidedthepublica30-dayreviewperiodendingJune10,2015,andnoexternalcommentswerereceived.SeveralupdatesidentifiedinternallywereaddressedinAppendixDoftheNetworkPlan.Anadditionalpublicinspectionperiodisnotrequired.Withthisletter,theEPAisapprovingtheEPD'sNetworkPlanandhasattachedcomments.ThesecommentsincludeupdatesandchangesthatrequireyourattentionbyDecember31,2015andthatwillneedtobeincludedintheplanyouragencywillsubmitin2016.ThankyouforworkingwithustomonitorairpollutionandpromotehealthyairqualityinGeorgia.Pleaseletusknowofanyproblemsinmeetinganyoftherequirementswehaveidentified.Ifyouhaveanyquestionsorconcerns,pleasecontactGreggWorleyat(404)562-9141orDarrenPalmerat(404)562-9052.Enclosurecc:LauraAckerman,SESDSincerely,BeverlyH.Banister"1J1DirectorAir,PesticidesandTaxiesManagementDivisionInternetAddress(URL)•http://www.epa.govRecycled/Recyclable•PrintedwithVegetableOHBasedInksonRecycledPaper(Mnimum30%Postconsumer)CY 2015 State of Georgia Ambient Air Monitoring Network Plan U.S. EPA Region

4 Comments and Recommendations This document contains the U.S. Environmental Protection Agency comments and recommendations

on the state of Georgia's 2015 ambient air monitoring network plan {Network Plan). Ambient air monitoring rules, which include regulatory requirements that address network plans

, data certification, and minimum monitoring requirements, among other requirements, are found in 40 CFR Part 58. Minimum monitoring requirements
for criteria pollutants are listed in 40 CFR Part 58, Appendix D. Minimum monitoring requirements are listed for ozone (O J ), particulate matter less than 2.5 microns {PM2.s), particulate matter less than 10 microns (PM

t o ), nitrogen dioxide (N02), sulfur dioxide (S02), carbon monoxide (CO), and lead (Pb). The minimum monitoring requirements are based on core based statistical areas (CBSA) and metropolitan statistical area (MSA) boundaries
as defined by the U.S. Office of Management and Budget, July 1, 2014 population estimates from the U.S. Census Bureau, and historical ambient air monitoring data

. OMB currently defines 15 MSAs in the state of Georgia. These MSAs and the respective July 1, 2014 population estimates from the U.S. Census Bureau are shown in Table 1. Table 1: Metropolitan Statistical Areas and Populations MSAName
Population Atlanta-Sandy Springs-Roswell, GA 5,614,323 Augusta-Richmond County, GA-SC
583,632 Chattanooga, TN-GA

544,559 Savannah, GA

372,708 Columbus, GA-AL

314,005 Macon,GA

230,450 Athens-Clarke County

, GA

199,016 Gainesville, GA

190,761 Warner Robins, GA

187,516 Albany,GA

154,925 Valdosta, GA

143,317 Dalton, GA

142.952 Brunswick, GA

114.806 Rome, GA

96,063 Hinesville, GA

82.311 Monitoring Network Changes Proposed The Georgia Environmental Protection Division (GA EPD) lists in Section
1. 7 of its Network Plan changes proposed
to the network, as well as changes that it has made to the network since the EPA's review of its 2014 Network Plan. The first four changes provide information on monitors which will be added to two near-road sites in the Atlanta CBSA. Since receiving the EPA's response to its 2014 plan, the GA EPD provided

a Network Plan addendum for the establishment
of the second near-road site in the Atlanta CBSA. This site is fully approved. The EPA acknowledges that monitoring was not conducted
at your Summerville site at the beginning of the 2015 03 season due to on-site construction

. Since we calculate data completeness
on a seasonal basis for ozone,
it is still possible to have
a complete three-year ozone design value at the end of this season, provided there are no other data gaps.As was noted, the EPA defunded several supplemental speciation monitors in Georgia. We understand

that the A th en's monitor was discontinued after January 24, 2015, and that the GA EPD will operate the

suppleme n tal speciation monitor at the General Coffee site for the foreseeable future.

The EPA had dis cussions w i th GA EPD on relocating the S02 and PM2.s monitors at the Rome-Coosa

E l ementary School site (AQS ID 13- 1 15-0003) due to the property be ing purchased by International

Paper. We have p rovided prelim inary comments via email on GA EPD's plan to re l ocate these monitors

to the nearby middle school or high school. Another con sideration for the future is whether the International Paper facility must be characterized

under the recent Data Requ i rements Rule (DRR), signed August 10, 2015. By January 1 5,2016, EPD

mu s t subm i ta final lis t of sources to EPA Region 4 identifying the sources in the state around which

S02 air quality mu st be characterized. We have provided additional i nformat ion in the.. S02 Monitoring
Requirements" section below.

On April 17, 2015, the EPA received a site reloca t ion request for the PM2.s monitor in Sandersville

(AQS ID 13- 303-0001) located at the Washi n gton County Health Department. We understand a building

renovation at the Health Department included replacing the flat roof with a new pitched roof making

reinstallation of the monitor infeasible. The new locat ion is approximately 0. 5 miles away at the Oconee

Center Washington County Service Center. From the information provided, some work will be needed

for the siting criteria to be met. Because some of the trees look young, special consideration s hould be

given to monitor location and probe height. While the EPA approves the relocation of the PM2.s ambient

air measurements at the Sandersville site (AQS ID 13-303-0001), the EPA requests that the GA EPD

provide i nformation confirming that all sit ing criteria are met. If requested, the EPA is will ing to vis it

the site with GA EPD to he lp verify that 40 CFR Part 58, Appendix E siting criteria will be met bef ore

s i te insta ll ation beg ins. It is not necessary to change the Air Quality System (AQS) number for the site.

We ask that GA EPD include a comment in the AQS site record that the site was previously located on

the Washington County Health Department building. Waivers for Ambient Air Monitoring Requirements

Several requests for waivers of ambient air monitoring requirement s are included in Section 1. 8 of the

Network Plan. A d i scussion on 03 monitoring in the Savannah MSA is included in the "03 Monitor ing

Req u irements" sect ion below. Likewise, a discussion on Pb source mon i toring around the Gerdau

Ameristeel facility in Bartow County is i nclu d ed in the.. Lead (Pb) Monitoring Requirements " section

below. No ot her waiv ers were included in the Network.

Air Quality Index ( A QI) Reporting

40 CFR §58.50 AQI reporting is req u ir ed in MSAs with populations over 350,000 based on the most recent decennial

census. Three MSA s, who lJy or part ly in the state, are required to report an AQI: Atlanta-Sandy Sp ringsRoswell, Augusta -R i chmond County, and Chattanooga, Tennessee. The Network Plan i ncludes a link on

Page 5 to the GA EPD 's Web site where this info r mation is available. The sta te is meeting its AQI

reporting re qu i remen ts. The EPA also recognizes that the GA EPD provides this service to other areas

across the state, an d that the Tennessee Department of Environment and Conservation prov i des this

service for the Chatta n ooga MSA.National Core (NCore) Monitoring Network 40 CFR Part 58, Appendix D, 3.0 The state is required to have one NCore site. The NCore site must measure,
at a minimum, PM2.s particle mass using continuous and integrated/filter-based samplers, speciated PM2.s, PM10

- 2.s particle mass, 03, S02, CO, NO/NOy, wind speed, wind direction, relative humidity, and ambient temperature. NCore sites in CBSAs with populations
of 500,000 people (as determined

in the latest census) or greater shall also measure Pb either as Pb-TSP or Pb-PM1o. The South DeKalb site (AQS ID 13-089-0002) was approved as the state's NCore site by the Office of Air Quality Planning and Standards (OAQPS) on October 30, 2009. The EPA Regional Administrator approved an alternative location for the Pb measurement. The NCore Pb sampling

is currently approved
to be conducted

at the nearby DMRC site (AQS ID 13-089- 0003). The NCore sites currently meet all requirements. OJ Monitoring Requirements 40 CFR Part 58, Appendix D, Table D-2 The network described
in the 2015 Network Plan meets the minimum 03 monitoring requirements specified by 40 CFR Part 58, Appendix D, Table D-2 in all areas. According
to the latest available census figures, the Savannah MSA's 2014 population estimate was 372,708. As discussed in your plan,
a second 03 monitoring site would be required
in this MSA if the most recent 3-year design value is greater than or equal to 85 percent of the NAAQS (0.063 ppm). Because the 2012-2014 design value is 0.059 ppm, GA EPD is not required to operate

a second 03 monitor in the Savannah MSA at this time. Because the design value is close to 85 percent of the NAAQS,

it could potentially be above that after this 03 season ending on October 31, 2015. We will continue evaluating this in 2016

. The EPA will also work with your agency and the South Carolina Department
of Health and Environmental Control to determine whether exploratory OJ monitoring

is warranted and feasible in South Carolina, just north of the Savannah MSA, in order to capture the modeled maximum concentration

as shown on Page
8 of your Network Plan

. The minimum requirements for 03 monitoring are being met at this time. CO Monitoring Requirements 40 CFR, Part 58, Appendix D, 4.2 Ambient air monitoring network design criteria for CO are found in Section 4.2 of Appendix

D to 40 CFR Part 58
. This section requires CBSAs with populations over one million to operate one CO monitor collocated with
a near-road N02 monitor. CBSAs with populations over 2.5 million people were required by 40 CFR §58.13 to operate

a near-road CO monitor by January

1, 2015. The CO monitor at the Georgia Tech near-road site (AQS ID 13-121-0056) fulfills the requirement for the Atlanta CBSA. NCore sites are also required to have CO monitors

. GA EPD operates

a CO monitor in the Atlanta MSA at the NCore site (AQS ID 13-089-0002). Thus, all minimum requirements for CO monitoring are being met at this time. N02 Monitoring Requirements 40 CFR Part 58, Appendix D, 4.3 Ambient air monitoring network design criteria for N02 are found in Section 4.3 of Appendix
D to 40 CFR Part 58
. Three types of N02 monitoring are required: near-road, area-wide, and Regional Administrator. These types of N02 monitoring are described
in sections 4.3.2, 4.3.3, and 4
. 3.4, respectively.

3The EPA approved the selection of the South DeKalb site (AQS ID 13- 089-0002) in fulfillment of the

area-wide N02 monitoring requirement for the Atlanta CBSA in 20 13.

Neither EPA nor GA EPD have identified Georg i a monitors that meet the requiremen t s for RA-40 sites

and GA EPD is not required to have a RA-40 site.

The EPA approved the first near-road N02 site to be located at Georgia Tech along the l -75/1-85

Connector. That site is installed and fully operational. Because of its population , the Atlanta CBSA is

required to have a second N02 near-road si t e. The EPA received an addendum to the state's Network

Plan outlining its near-road plans . The EPA approved the state •s proposed location for the second s ite,

which is adjacent to the NCore site's collocated Pb monitors. The EPA views this as a unique

opportunity to have a near-road N02 site close to a NCore site. The EPA commends the GA EPD for

establishing this site quickly. The EPA fully approves the second near-road monitoring site in the

Atlanta CBSA. Section 4.3.2 of Appendix D to 40 CFR Part 58 also requires CBS As with populat i ons between 500,000

and 1, 000,000 people to operate a near-road N02 monitor starting in January 1, 2017. Georgia ha s two

CBSAs with populations in this range: Chattanooga and Augusta. As a result of the 5-year NAAQS

review cycle , the N02 monitoring requ i rements, including near-road requirements, may be changed for

CBS As with a populations between 500, 000 and 1 ,000,000 people.

S02 Monitoring Requirements

40 CFR Part 58, Appendix D, 4.4 Ambient air monitoring network design criteria for S02 are found in Section 4.4 of Appendix D to 40

CFR Part 58. This section requires that "The population w e ighted emissions index (PWEI) shall be

calculated by states for each core based statistical area (CBSA). " As a re s ult, the S02 monitoring site(s)

required in each CBSA will satisfy min i mum monitoring requirement s if the monitor(s) i s sited within

the boundaries of the parent CBSA and is one of the following site types: population exposure,

max i m u m concentration, source- orienred, general background, or regional transport. An 502 monitor at

an NCore station may sat i sfy min i mum monitoring requirements if that monitor i s located within a

CB5A w i th minimally required monitors consistent with Appendix D, 4.4.

I n 2012, the EPA 's OAQPS updated the population weighted em i ssion index (P WE I) calculations using

the latest available emissions inventory da t a and population estimates. The S02 monitoring network

design outlined in the Network Plan meets the minimum requirements of 40 CFR Part 58 based on the

la t est calculations. The EPA finalized the 502 Data Requirements Rule (DRR) on August 10, 2015. This rule will r e quire

that a i r qua li ty near sources with S02 em i ssio n s greater than 2, 000 ton s per year be characterized using

ambient air monitor i ng or modeling. We encourage you to begin having conversations with affected

sources in your state to determine an agreed upon approach for meeting the DRR requirements. By

January 15, 2016, GA EPD must subm i t a final plan to the EPA Region 4 identifying the sources in the

state around which S0 2 air quality must be characterized. For sources that EPD decides to evaluate

u s i ng a m b i ent air monitoring, new si t e proposals must be included in the 2016 Network Plan.

4The location of these monitoring sites should be selected using the process outlined in the S02 NAAQS Designations Source-Oriented Monitoring Technical Assistance Document

1 • Pb Monitoring Requirements 40 CFR Part 58, Appendix D, 4.5 40 CFR Part 58, Appendix D, 4.5 requires that "At a minimum, there must be one source-oriented SLAMS [state and local air monitoring station] site located to measure the maximum Pb concentration in ambient air resulting from each non-airport Pb source which emits 0.50 or more tons per year and from each airport which emits 1.0 or more tons per year ... " Monitoring

is ongoing
at the Exide Technologies facility in Columbus. This is the only non-airport source in the state which emits over 0.50 tons per year (tpy). In 2013, GA EPD requested

a waiver of the source-oriented monitoring requirement near the Gerdau steel mill in Cartersville, which the EPA approved. Sampling was discontinued on February 22, 2014. The GA EPD re-applied for a waiver this year. The waiver is approved and in effect until2020 when the next 5-year network assessment

is due. GA EPD has also submitted revised Pb emissions for two facilities that had emissions greater than 0.5 tpy in the 2011 National Emissions Inventory

: the R.M. Clayton Water Reclamation Center in Atlanta, and Temple Inland in Rome. The EPA concurs with these revised emissions calculations and agrees that the ambient air monitoring

is not warranted near either of these sources. The Pb monitoring network described
in the Network Plan meets all of the design criteria of 40 CFR Part 58. PM1o Monitoring Requirements 40 CFR Part 58, Appendix A, 3.3.1 40 CFR Part 58, Appendix D, Table D-4 All PM10 collocation requirements for manual methods found in 40 CFR Part 58, Appendix A, 3.3.1 are being met. These include the requirement that 15 percent of each network of manual PM10 methods (at least one site) be collocated. Also, the sites with collocated monitors should be among those measuring annual mean concentrations

in the highest 25 percent of the network. These collocation requirements are assessed at the primary quality assurance organization level. The state of Georgia's PM 10 primary monitoring network meets the minimum requirements for all areas. PMz.s Monitoring Requirements 40 CFR Part 58, Appendix A, 3.2.5 40 CFR Part 58, Appendix D, Table D-5 The state of Georgia's current primary PM2

. s monitoring network meets the minimum requirements found in 40 CFR Part 58, Appendix D, Table D-5 for all MSAs. The PM2.s collocation requirement found in 40 CFR Part 58, Appendix A, 3.2

. 5.2 for manual reference and equivalent methods
is being met. 1 S02 NAAQS Designations Source-Oriented Monitoring Technical Assistance Document.

U

. S . EPA Office of Air Quality Planning and Standards Air Quality Assessment Divis ion, Draft December 2013. h llp://www3 .epa.gov/a irgual

i 1 y/su I funt iox

i de/pdfs/S02Mo

n itori 11 gT AD .pdf 5PM2.s Near-road Monitoring Requirement

40 CFR Part 58, Appendix D, 4.7.1 (b) (2) Regulatory requirements in 40 CFR Part 58, Appendix D, 4. 7.1 (b) (2) require that "CBSAs with a

popula t ion of 1, 000, 000 or more persons, at least one PM2. s mon i tor is to be collocated at a near-road

N0 2 station. " CBSA s w i th populations over 2. 5 million people, such as the Atlanta CBSA, are required

by 40 CFR §58.13 to operate a near· road PM2. s mon i tor by January 1, 2015. GA EPA operates a PM2.s

monitor at its Georg i a Tech near-road site (AQS ID 13-121-0056) which meets this requirement.

PM!.s Continuous Monitoring R e quirements

40 CFR Part 58, Appendix D, 4.7.2 Regulatory requirements for cont i nuous PM2. s monitoring require that "the state, or where appropriate,

local agencies must operate contin u ous PM2. s analyzers equal to at least one-half (round up) the

minimum required sites listed in T a ble D- 5 of this Appendix. At least one required continuous analyzer

in each MSA must be colloc a ted with one of the required FRMIFEM/ ARM [federal reference
method/federal equivalent method/approved regional method] monitors, unless at least one of the

required FRMIFEM/ ARM monitors is itself a continuous FEM or ARM monitor in which case no

collocation requirement applies. " These minimum continuous PM2. s monitoring requirements are met in

all MSAs. Also, the continuous PM2.s collocation requirements are met in all MSAs. Therefore, the

continuous PM 2. s mo n itoring network described in the 2015 Network Plan meets all of the design

cr i teria of 40 C F R Part 58. PM2.s Background and Transport Sites

40 CFR Part 58, Appendix D, 4. 7.3 Regulatory requirements in 40 CFR Part 58, Append i x D, 4. 7.3 require that "each s tate shall install and

operate at least one PM2.s s i te to monitor for regional background and at lea s t one PM2.s site to monitor

for regional transport." The 2015 Network Plan identifies the photochemical assessment monitoring

station PM2.s monitor in Yorkville (AQS ID 13-223-0003) as a background site and the PM2. s site in

Rossville (AQS ID 13-295-0002) as a transport site. Therefore, the state has satisfied the requireme nt s

of 40 CFR Part 58 for background and transport sites. Chemical Speciation Network (CSN)

40 CFR Part 58, Appendix D, 4.7.4

The EPA has been conducting an asse s sment of the CSN in an effort to optimize and create a sustainable

network. As a result of this assessment, the EPA has defunded a n umber of monitoring sites, eliminating

CSN PM2.s mass measurement, reducin g the frequency of carbon blanks, reducing sample frequency at

some monitoring sites, and reducing the number of icepacks in shipme n ts during the cooler months of

the year. With respect to the impacts on the Georgia CSN network, funding for the Athens and Douglas

(General Coffee) sites (AQS ID 13- 059-0002 and AQS ID 13-069-0002, respectively) was eliminated.

GA EPD has decided to continue operating the Genera l Coffee site using its own fu n ding. Also, PM 2. s

mass measurement was eliminated a t all other funded CSN sites, the frequency of carbon blanks was

reduced, and the number of icepacks for shipp i ng were reduced. The CSN PM2. s mass measurement was

eliminated in October 2014 and all other changes took place in January 2015. GA EPD listed these

changes in Section 1.7 of the Network P l an. These changes are acceptable and the CSN**requirem~nt** will

continue to be met. 6Photochemical Assessment Monitoring Station (P AMS) 40 CFR Part 58, Appendix D, 5.0 The Atlanta, GA MSA is the only area in Region

4 where
P AMS is required. The area is required to have an upwind (Type 1) site and a downwind (Type 2) site

. The upwind site is located in Paulding County (AQS ID 13-223-0003). The downwind site is located in DeKalb County (AQS ID 13-089- 0002)

. In 2013, the EPA approved the discontinuation

of PAMS monitoring
at the second Type
2 site in Rockdale County (AQS ID 13-247-0001) because summertime VOC sampling

is no longer required. Section

3
. 7 in next year's plan should be updated to reflect this change. The PAMS requirement

is being met in the state of Georgia. Other Comments Site evaluation comments are listed in Section

6
. 0 on Pages 30-32 of the Network Plan. We appreciate that GA EPD evaluates its monitoring sites on an ongoing basis to ensure confidence
in the data quality. We also appreciate that GA EPD includes this information
in its Network Plan

. As most of these sites are used in regulatory decision-making,
we understand that EPD judiciously tries to correct issues as soon as practicable

. Thank you for the work that has already been done to ensure all sites continue to meet siting criteria.

7