UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960

Ms. Karen Hays Chief Air Protection Branch Environmental Protection Division Georgia Department of Natural Resources 4244 International Parkway, Suite 120 Atlanta, Georgia 30354 Dear Ms. Hays: 

# .OCT 1 3**ZUl~**

Thank you for submitting the State of Georgia's 2015 annual ambient air monitoring network plan (Network Plan) received June 15, 2015. The Network Plan is required by 40 Code of Federal Regulations (CFR) §58. 10. The U.S. Environmental Protection Agency Region 4 understands that the Georgia Environmental Protection Division provided the public a 30-day review period ending June 10, 2015, and no external comments were received. Several updates identified internally were addressed in Appendix D of the Network Plan. An additional public inspection period is not required. With this letter, the EPA is approving the EPD's Network Plan and has attached comments. These comments include updates and changes that require your attention by December 31, 2015 and that will need to be included in the plan your agency will submit in 2016. Thank you for working with us to monitor air pollution and promote healthy air quality in Georgia. Please let us know of any problems in meeting any ofthe requirements we have identified. Ifyou have any questions or concerns, please contact Gregg Worley at (404) 562-9141 or Darren Palmer at (404) 562-9052.

Enclosure
cc: Laura Ackerman, SESD Sincerely,

## qi'"'IIV~ Beverly H. Banister 

# "1J1 Director Air, Pesticides and Taxies Management Division

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable OH Based Inks on Recycled Paper (M nimum 30% 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 (OJ), particulate matter less than 

### 2.5 microns {PM2.s), particulate matter less than 10 microns (PMto ), 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 ofManagement 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 Athen's monitor was discontinued after January 24, 2015, and that the GA EPD will operate the supplemental speciation monitor at the General Coffee site for the foreseeable future. The EPA had discussions with GA EPD on relocating the S02 and PM2
.s monitors at the Rome-Coosa Elementary School site (AQS ID 13- 1 15-0003) due to the property being purchased by International Paper. We have provided preliminary comments via email on GA EPD's plan to relocate these monitors to the nearby middle school or high school. Another consideration for the future is whether the International Paper facility must be characterized under the recent Data Requirements Rule (DRR) , signed August 10, 2015
. By January 15,2016, EPD must submit a final list of sources to EPA Region 4 identifying the sources in the state around which S02 air quality must be characterized. We have provided additional information in the
..S02 Monitoring Requirements" section below. On April 17, 2015, the EPA received a site relocation request for the PM2
.s monitor in Sandersville (AQS ID 13

-303-0001) located at the Washington County Health Department. We understand a building renovation at the Health Department included replacing the flat roof with a new pitched roof making reinstallation ofthe monitor infeasible
. The new location 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 t o be met. Because some of the trees look young, special consideration should 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 information confirming that all siting criteria are met. Ifrequested, the EPA is willing to vi sit the site with GA EPD to help verify that 40 CFR Part 58, Appendix E siting criteria will be met bef ore site installation begins . 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 requirements are included in Section 1
.8 of the Network Plan. A discussion on 

### 03 monitoring in the Savannah MSA is included in the "03 Monitor ing Requirements" section below. Likewise, a discussion on Pb source monitoring around the Gerdau Ameristeel facility in Bartow County is included in the
..Lead (Pb) Monitoring Requirements " section below. No ot her waivers were included in the Network
. 

### Air Quality Index (AQI) Reporting 40 CFR §58.50 AQI reporting is req uired in MSAs with populations over 350,000 based on the most recent decennial census. Three MSAs , wholJy or partly in the state, are required to report an AQI: Atlanta-Sandy Spri ngsRoswell, Augusta

-Richmond County, and Chattanooga, Tennessee
. The Network Plan includes a link on Page 5 to the GA EPD ' s Web site where this information is available
. The stat e is meeting its AQI reporting requirements . The EPA also recognizes that the GA EPD provides this service to other areas across the state, and that the Tennessee Department of Environment and Conservation provi des this service for the Chattanooga 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 ofthe 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 ofthe area-wide N02 monitoring requirement for the Atlanta CBSA in 20 13
. Neither EPA nor GA EPD have identified Georgia monitors that meet the requirements 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 ofits population, the Atlanta CBSA is required to have a second N02 near-road site. 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 site, 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 ofAppendix D to 40 CFR Part 58 also requires CBSAs with populations between 500,000 and 1,000,000 people to operate a near-road N02 monitor starting in January 1, 2017
. Georgia has two CBSAs with populations in this range: Chattanooga and Augusta. As a result ofthe 5-year NAAQS review cycle, the N02 monitoring requirements, including near-road requirements, may be changed for CBSAs 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 weighted emissions index (PWEI) shall be calculated by states for each core based statistical area (CBSA)
." As a result, the S02 monitoring site(s) required in each CBSA will satisfy minimum monitoring requirements if the monitor(s) is sited within the boundaries of the parent CBSA and is one of the following site types: population exposure, maximum concentration, source-orienred, general background, or regional transport. An 502 monitor at an NCore station may satisfy minimum monitoring requirements if that monitor is located within a CB5A with minimally required monitors consistent with Appendix D, 4.4. I n 2012, the EPA ' s OAQPS updated the population weighted emission index (PWEI) calculations using the latest available emissions inventory data and population estimates
. The S02 monitoring network design outlined in the Network Plan meets the minimum requirements of40 CFR Part 58 based on the lat est calculations
. The EPA finalized the 502 Data Requirements Rule (DRR) on August 10, 2015. This rule will r equire that air quality near sources with S02 em issions greater than 2 ,000 tons per year be characterized using ambient air monitor ing 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 submit a final plan to the EPA Region 4 identifying the sources in the state around which S02 air quality must be characterized. For sources that EPD decides to evaluate using ambient air monitoring, new site proposals must be included in the 2016 Network Plan.



### 4The location ofthese 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 ofthese sources. The Pb monitoring network described in the Network Plan meets all of the design criteria of40 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 Division, Draft December 2013. h

llp://www3 .epa.gov/airguali1 y/su I funt iox ide/pdfs/S02Mon itori 11gTAD.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 population of 1,000,000 or more persons, at least one PM2
.s monitor is to be collocated at a near-road N02 station
. " CBSAs with 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 monitor by January 1, 2015
. GA EPA operates a PM2.s monitor at its Georgia Tech near-road site (AQS ID 13-121-0056) which meets this requirement. 

### PM!.s Continuous Monitoring Requirements 40 CFR Part 58, Appendix 

### D, 4.7.2 Regulatory requirements for continuous PM2
.s monitoring require that "the state, or where appropriate, local agencies must operate continuous PM2
.s analyzers equal to at least one-half (round up) the minimum required sites listed in Table D

- 5 of this Appendix
. At least one required continuous analyzer in each MSA must be collocated 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 PM2
.s monitoring network described in the 2015 Network Plan meets all ofthe design criteria of40 C FR Part 58. PM2.s Background and Transport Sites 40 CFR Part 58, Appendix 

### D, 4. 7.3 Regulatory requirements in 40 CFR Part 58, Appendi x D, 4.7.3 require that " each state shall install and operate at least one PM2.s site to monitor for regional background and at least 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 requirements of40 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 assessment of the CSN in an effort to optimize and create a sustainable network
. As a result ofthis assessment, the EPA has defunded a number of monitoring sites, eliminating CSN PM2.s mass measurement, reducing the frequency of carbon blanks, reducing sample frequency at some monitoring sites, and reducing the number of icepacks in shipments 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 General Coffee site using its own funding
. Also, PM2.s mass measurement was eliminated at all other funded CSN sites, the frequency ofcarbon blanks was reduced, and the number of icepacks for shipping 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 Plan. These changes are acceptable and the CSN**requirem~nt** will continue to be met. 

### 6

### Photochemical 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 PAMS 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 EPDjudiciously 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