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 of the requirements we have identified. If you 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 (PM to), 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 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 13-115-0003) 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 of the 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 to 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. If requested, the EPA is willing to visit 

the site with GA EPD to help verify that 40 CFR Part 58, Appendix E siting criteria will be met before 

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 Monitoring 

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 other waivers were included in the Network. 

Air Quality Index (AQI) Reporting 

40 CFR §58.50 

AQI reporting is required 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 SpringsRoswell, 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 state 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 provides 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 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. 

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The 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 2013. 

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 of its 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 of Appendix D to 40 CFR Part 58 also requires CBS As 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 of the 5-year NAAQS 

review cycle, the N02 monitoring requirements, 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 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. 

In 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 of 40 CFR Part 58 based on the 

latest calculations. 

The EPA finalized the 502 Data Requirements Rule (DRR) on August 10, 2015. This rule will require 

that air quality near sources with S02 emissions greater than 2,000 tons per year be characterized using 

ambient air monitoring 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. 

4 
The location of these monitoring sites should be selected using the process outlined in the S02 NAAQS 

Designations Source-Oriented Monitoring Technical Assistance Document1

• 

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 Division, 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 

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PM2.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 of the design 

criteria of 40 CFR Part 58. 

PM2.s Background and Transport Sites 

40 CFR Part 58, Appendix D, 4. 7.3 

Regulatory requirements in 40 CFR Part 58, Appendix 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 

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 assessment of the CSN in an effort to optimize and create a sustainable 

network. As a result of this 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 of carbon 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 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. 

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