Air Protection Branch 

Environmental Protection Division Georgia Department of Natural Resources 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 Thank you hr submitting the state of Georgia's 201 1 annual ambient air monitoring network plan 

(Network Plan) dated August 201 1. The Network Plan is required by 40 Code of Federal Regulations 

(CFR) 558.10. 

The U. S. Environmental Protection Agency Region 4 understands that the Georgia Environmental 

Protection Division provided the public a 30-day review period. Several external comments were 

received and forwarded, along with EPD's response, to EPA Region 4 on October 12,201 1. We have 

reviewed EPD's response to comments and have determined that EPA does not need an additional 

Based upon our review of the Network Plan, EPA Region 4 has determined that the plan satisfies the 

applicable requirements of 40 CFR Part 58 and by this letter is approving the Georgia Network Plan. 

In preparation for the 2012 Network Plan, EPA Region 4 is enclosing comments regarding the plan 

and information regarding network upgrades that will be needed in order to address sulfur dioxide 

monitoring requirements that become effective on January 1,20 1 3. 

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 Doug Neeley at (404) 562-9097 or Darren Palmer (404) 562- 

9052. 

Gwendolyn Keyes Fleming 

Regional Administrator 

Enclosure 

Internet Address (URL) http:llwww.epa.gov 

RecycledlRecyclable Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
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. New national ambient 

air quality standards (NAAQS) were promulgated in 2010 for nitrogen dioxide (NO2) and sulh 

dioxide (Sa) with minimum monitoring requirements effective January 1,20 13. In 201 1, while the 

NAAQS for carbon monoxide (CO) was not changed, new minimum monitoring requirements were 

announced and will become effective on January 1,201 5. The state's plans for implementing these 

requirements will not have to be identified until July 1,2014 when the 2014 Network Plan is due. 

Minimum monitoring requirements are listed for ozone (O3), particulate matter less than 2.5 microns 

(PMZ5), particulate matter less than 10 microns (PMlo), and lead (Pb). 

The minimum monitoring requirements are based on metropolitan statistical area (MSA) boundaries as 

defined by the U.S. Office of Management and Budget (Om), July 1,201 0, population estimates 

fiom the U.S. Census Bureau and historical ambient air monitoring data. OMB currently defines 14 

MSAs in the state of Georgia. These MSAs and the respective July 1,2009, population estimates fiom 

the U.S. Census Bureau are shown in Table 1. 

Table 1: Metropolitan Statistical Areas and Populations 

MSA Name Population Atlanta-Sandy Springs-Marietta, GA 5,475,213 

Augusta-Richmond County, GA-SC 539,154 

Chattanooga, TN-GA . 524,303 

Savannah, GA 343,092 

Columbus, GA-AL 292,795 

Macon, GA 23 1,576 

Athens-Clarke County, GA 192,222 

Gainesville, GA 187,743 

Albany, GA 1 65,440 

Valdosta, GA 135,804 

Wamer Robins, GA 135,715 

Dalton, GA 134,3 19 

Brunswick, GA 103,841 

Rome, GA 96,250 

Hinesville-Fort Stewart, GA 74,420 
Minimum PMlo Monitoring Requirements 40 CFR Part 58, Appendix A, 3.3.1 40 CFR Part 58, Appendix D, Table D-4 All PMlo collocation requirements for manual methods found in 40 CFR Part 58, Appendix A, 3.3.1 

are currently being met. These include the requirement that fifteen percent of each network of manual 

PMlo methods (at least one site) must 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 current PMli, primary monitoring network meets the minimum requirements for all areas. 

Minimum PMu 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 PM2.5 monitoring network meets the minimum requirements 

found in 40 CFR Part 58, Appendix D, Table D-5 for all MSAs. However, the PM25 collocation 

requirement is currently not being met. Regulatory requirements in 40 CFR Part 58, Appendix A, 3.2.5.2 for manual method collocated PM2.5 monitoring require that ". . . monitors selected for P 

collocation must also meet the following requirements: (a) A primary monitor designated as an EPA 

Federal Reference Method (FRM) shall be collocated with an audit monitor having the same EPA 

FRM designation." We understand the EPD is diligently working to replace all of its Andersen PM2.s 

FRM monitors. This action will allow the state to meet this collocation requirement. 

PMzs 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 PM2.5 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 FRM/FEM/ARM [Federal 

Reference MethodLFederal Equivalent Method/Approved Regional Method] monitors, unless at least 

one of the required FRM/FEM/ARM monitors is itself a continuous FEM or ARM monitor in which 

case no collocation requirement applies." These minimum continuous PM2.5 monitoring requirements 

are currently met in all of the MSAs in the state. Also, the continuous PM2.S collocation requirements 

are currently met in all MSAs. Therefore, the continuous PM2.5 monitoring network described in the 

201 1 Network Plan meets all of the design criteria of 40 CFR Part 58. 
monitor for regional transport.

 The 201 1 Network Plan identifies the photochemical assessment 

monitoring station PM2.5 monitor in Yorkville (AQS ID: 13-223-0003) as a background site and the 

PM2.5 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. 

Lead (Pb) Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.5 EPA recently revised the monitoring requirements for lead found in 40 CFR Part 58, Appendix D 

Section 4.5 (see 75 Federal Register 81 126). These revisions reduced the emissions threshold for 

facilities near which source oriented Pb monitoring is required fiom 1.0 tons per year (tpy) to 0.5 tpy. 

The rule also removed population based monitoring requirements for Pb and replaced them with a 

requirement to monitor for Pb at urban NCore sites. Pb monitoring at NCore sites is required to begin 

on December 27,201 1. 

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 fiom each non-airport Pb source which emits 0.50 or more tons @ per year and from each airport which emits 1 .O or more tons pa year.. ." Monitoring sites are already 

operating as required near the Exide Corporation facility in Columbus and the Gerdau Ameristeel 

facility in Cartersville. 

Regarding the Exide facility, we are recommending a short-term study to determine if the existing 

monitor is in the best location. The estimated emissions fiom the Exide Technologies Facility in 

Columbus, Georgia are expected to be 0.64 tpy, with a predicted modeled ambient air concentration of 

0.1 76 ugfm3. As noted, this facility does not qualifjr for a source-oriented monitoring waiver. In our 

review of the modeling results, we are concerned that the existing monitor is not sited in the area of 

predicted maximum Pb concentration. Instead of establishing a new Pb monitoring site around the 

facility, we recommend that the state restart two dormant sites around the facility by January 1,2012, 

and operate them for one calendar year. If, after a year of monitoring, the Pb levels at these two sites 

are below the Pb levels at the existing site, the state will be allowed to shut the two sites down again. 

However, if the Pb levels at either one or both of the two sites are higher than the data fiom the 

existing site, then the highest reading site must be continued and the remaining sites will be allowed to 

shutdown. Our understanding is that this approach will be more cost effective for the state than 

establishing a completely new location around the facility. Since the facility is applying for a permit to 

expand operations, we would also recommend the state add a permit requirement for the facility to 

conduct ambient air monitoring. 
The state of Georgia has requested EPA grant one of the seven facilities a waiver of source-oriented 

Pb monitoring requirements. This facility is Georgia Power Company's Plant Bowen in Cartersville, 

GA. Section 4.5(a)(ii) of Appendix D to 40 CFR Part 58 provides the following provisions for a 

waiver of the Pb monitoring requirements: 

"(ii) The Regional Administrator may waive the requirement in paragraph 4.5(a) for 

monitoring near Pb sources if the state or, where appropriate, local agency can demonstrate the 

Pb source will not contribute to a maximum Pb concentration in ambient air in excess of 50% 

of the NAAQS (based on historical monitoring data, modeling, or other means). The waiver 

must be renewed once every 5 years as part of the network assessment required under 58.10(d). 

The state has submitted air modeling indicating that Plant Bowen will not contribute to a maximum Pb 

concentration in the ambient air in excess of 50% the NAAQS. EPA has reviewed this information and 

concurs that the Pb emissions fiom this source will not contribute to a maximum Pb concentration in 

the ambient air in excess of 50% of the NAAQS. Therefore, EPA is granting a waiver of the sourceoriented ambient air monitoring requirements at this source. This waiver must be renewed once every 

5 years as part of the network assessment required under 40 CFR $58.lO(d). r\ 

For the other six of the seven previously mentioned facilities, the state has requested that EPA 

consider revised emissions data related to source-oriented Pb monitoring requirements. The state 

submitted information indicating that the actual Pb emissions fiom these six sources, listed below, are 

below 0.50 tpy: 

Georgia Power Company Plant Scherer 

Juliette, GA 

Temple-Inland 

Rome Linerboard Mill 

Rome, GA 

Gilman Building Products Co. Fitzgerald, GA 

R.M. Clayton Water Reclamation Center Atlanta, GA 

Georgia Power Company Plant Branch 

Milledgeville, GA 

Gilman Building Products 

Blackshear, GA 

EPA has reviewed this information, and concurs that the actual Pb emissions fiom this source are below 

0.50 tpy. Therefore, ambient air monitoring is not required at these sources. 

The Pb monitoring network described in the 201 1 Network Plan meets all of thedesign criteria of 40 

CFR Part 58 

0 
the boundaries of the parent CBSA and is one of the following site types: population exposure, 

maximum concentration, source-oriented, general background, or regional transport. An SO2 monitor at 

an NCore station may satisfl minimum monitoring requirements if that monitor is located within a 

CBSA with minimally required monitors consistent with Appendix D, 4.4. 

The SO2 network is to be operational beginning January 1,2013. The SO2 monitoring network design 

outlined in your Network Plan will meet the minimum requirements under 40 CFR Part 58 once the 

additional samplers are added in the Atlanta and Augusta MSAs. The closures of the S@ samplers at the 

Bmswick - Risley Middle School and Columbus Airport are approved. 

Air Quality Index (AQI) Reporting 

40 CFR g58.50 

AQI reporting is required in MSAs with populations over 350,000. Three MSAs wholly or partly in the 

state are required to report an AQI: Atlanta-Sandy Springs-Marietta, Augusta-Richmond County, and 

Chattanooga, Tennessee. The Network Plan includes a link on Page 5 to the Georgia EPD Web site 

where this information is available for these areas. The state is meeting the AQI &porting requirements. 

t-l 

' Monitoring Network Changes Proposed by GA EPD 

In its 201 1 Network Plan, the state proposed several other changes to its monitoring network not already 

addressed above. These changes to the SO2, NO2, CO and PM2.5 networks are necessary to meet 

applicable regulations in 40 CFR Part 58 listed on Pages 6 and 7 of the Network Plan. The requested 

changes are approved. 

The Met One Beta Attenuation Mass (BAM) 1020 monitor was certified as a FEM per Federal Register: 

Vol. 73, page 13224, on March 12,2008. This monitor should now be incorporated into the state's 

ambient air monitoring network as an approved monitoring method for PM2.5. 

National Core (NCore) Monitoring Network 

The state is required to have one NCore site. The South DeKalb site, AQS #13-089-0002, was approved 

as the state's NCore site by EPA's Office of Air Quality Planning and Standards on October 30,2009. It 

currently meets all requirements. After the NCore sites were approved, EPA established a population 

oriented Pb monitoring requirement for NCore sites that takes effect on December 27,201 1. EPA has 

determined that this requirement will be met by the collocated Pb monitor at the nearby site, AQS #13- 

089-0003.