Mr
. Keith Bentley Chief AirProtection Branch UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA30303-8960

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Environmental Protection Division Georgia Department ofNatural Resources 4244 International Parkway, Suite 120 Atlanta, Georgia 30354 Dear Mr
. Bentley: Thank you for submitting the state ofGeorgia's 2014 annual ambient air monitoring network plan (Network Plan) received July 1, 2014

. The Network Plan is required by40 Code ofFederal Regulations (CFR) §58

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. The U.S

. Environmental Protection Agency Region 4 understands that the Georgia Environmental Protection Division (GA EPD) provided the public a 30-day review period ending June 27, 2014, and no external comments were received. One update was addressed in Appendix F ofthe Network Plan. An additional public inspection period is not required. With this letter, the EPA is approving the GA EPD's Network Plan with the exception ofthe provision to establish a second near-road nitrogen dioxide (N02) site in the Atlanta core based statistical area (CBSA)

. We have enclosed our analysis ofyourNetwork Plan and will continue to work with your agency on the second near-road N02 site in the Atlanta CBSA. The state will need to provide additional infonnation on the second near-road monitoring site in the Atlanta CBSA. Once the EPA is in agreement with the proposed locations for these sites, the state will need to make the information available for public inspection

. Upon completion ofthe public inspection process, the addendum to the Network Plan must be submitted to the EPA Region 4 for approval. Thank you for working with us to monitor air pollution and promote healthy air quality in Georgia. Please let us know ofany problems in meeting any ofthe requirements we have identified

. Ifyou have any questions orconcerns, please contact Gregg Worley at (404) 562-9141 or Darren Palmer at (404) 562-9052

. Sincerely,

# =:**~** Director

### ~· Air, Pesticides and Toxics Management Division

Enclosure Internet Addrass (URL) • http: //www.epa.gov Racyclad/Racyclabla • Printed with Vegetable 08 Based Inkson Recycled Paper (Minimum30% Poslconsumer)

## CY 2014 State ofGeorgia Ambient Air Monitoring Network Plan U.S. EPA Region 4 Comments and Recommendations This document contains the U.S. EPA Region 4 comments and recommendations onthe state of Georgia's 2014 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 (03), particulate matter less than 2.5 microns (PM2.5), particulate matterless than 10 microns (PMw), 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 defmed by the U.S. Office ofManagement and Budget (OMB), July 1, 2013 population estimates from the U.S. Census Bureau and historical ambient air monitoring data. OMB currently defmes 15 MSAs in the state ofGeorgia. These MSAs and the respective July 1, 2013 population estimates from the U.S. Census Bureau are shown in Table 1. Table 1: Metropolitan Statistical Areas andPopulations

MSAName Atlama-Sandy Springs-Roswell, GA Augusta-Richmond County, GA-SC Chattanooga,TN-GA Savannah, GA Columbus, GA-AL Macon,GA Athens-Clarke County, GA Gainesville, GA Warner Robins, GA Albany,GA Valdosta, GA Dalton, GA Brunswick, GA Rome,GA Hinesville, GA 

### Minimum OJ Monitoring Requirements 40 CFRPart58, Appendix D, Table D-2 Population 5,522,942

580,270 541.744 366,047 316,554 231,259 197,905 187,745 186,214 155,694 142,897 142,212 113,807 95,821 80,759

The network described in the 2014 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 2013 population estimate was 366,047. As outlined 

### in yourplan, a second 03 monitoring site would berequired in this MSA ifthe most recent 3-year design value is greater than or equal to 85 percent ofthe National Ambient Air Quality Standard (NAAQS) (0.063ppm after truncation). The official design value for the 2011-2013 period is 0.062 parts permillion (ppm). As a result the EPA does not require a second ozone monitor in the Savannah MSA at this time. We recognize the current design value is very close to 85 percent ofthe NAAQS and could potentiallybe above that after this ozone seasonending on October 31, 2014. We will reevaluate this situation in 2015 and continue working with your agency and the South Carolina Department ofHealth andEnvironmental Control to determine whether exploratory ozone monitoring is warranted and/or feasible in South Carolinajust north ofthe Savannah MSA in order to capture the modeled maximum concentration as shown on Page 8 in your final plan submitted last year. The EPA approves no other changes to the 

### 03 monitoring network. Minimum PM1o Monitoring Requirements 40 CFR Part58, Appendix A, 3.3.1 40 CFR Part 58, Appendix D,Table D-4 All PMw collocation requirements for manual methods found in 40 CFR Part 58, Appendix A, 3

.3.1 are being met. These include the requirement that fifteen percent ofeach network ofmanual 

### PMw methods (at least one site) be collocated. Also, the sites with collocated monitors should be among those measuring annual meanconcentrations in the highest 25 percent ofthe network. These collocation requirements are assessed atthe primary quality assurance organization level. The state ofGeorgia's PMto primary monitoring network meets the minimum requirements for all areas. Minimum PMz..s Monitoring Requirements 40 CFR Part 58, Appendix A, 3.2.5 40 CFR Part 58, AppendixD, Table D-5 The state ofGeorgia's current primary PM2

. s monitoring network meets the minimum requirements found 

### in40 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. PM2.s Continuous MonitoringRequirements 40 CFR Part58, 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 ofthis Appendix. At least one required continuous analyzer 

### in each MSA mustbe collocated with one ofthe required FRMIFEM/ARM [federal reference method/federal equivalent method/approved regional method] monitors, unless at least one ofthe required FRMIFEM/ ARM monitors is itselfa continuous FEM orARM monitor in which case no collocation requirement applies." These minimum continuous PM2.s monitoring requirements are met in all MSAs. Also, the continuous 

### PMz.s collocationrequirements are met in all MSAs. Therefore, the continuous PM2

.s monitoring network described in the 2014 Network Plan meets all ofthe design criteria of40 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

### PMz.s site to monitor for regional transport." The 2014 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.s site inRossville (AQS ID: 

### 13-295-0002) as a transport site. Therefore, the state has satisfied therequirements of

### 40 CFR Part 

### 58 forbackground and transport sites. 

### PM2.s Near-roadMonitoring Requirement 40 CFR Part58, Appendix D, 4.7.1 (b) (2) Regulatory requirements in

### 40 CFR Part

### 58, Appendix D, 

### 4.7.1 (b) 

### (2) require that in "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 

### NOz station." The GA EPD's Network Plan states that a 

### PMz.s monitor will operate at the Georgia Tech (AQS 

### # 13-121-0056) near-road site. 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 byJanuary 

### 1, 2015. 

### Lead (Pb) Monitoring Requirements 40 CFRPart58, AppendixD,4.5 40 CFR Part 

### 58, Appendix D, 

### 4.5 requires that "At a minimum, there mustbe 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 ormore tons per year..." Monitoring is ongoing at theExide Technologies facility in Columbus. This is the only non-airport source in the state which emits over 

### 0.50 tons per year. Last year, GA EPD requested a waiver ofthe source-oriented monitoring requirement near the Gerdau steel mill in Cartersville, which the EPA approved. Sampling was discontinued as of February 

### 22, 2014. 40 CFR Part 

### 58, Appendix D, 3(b) requires that "NCore sites in CBSA with a population of

### 500,000 people (as determined in the latest Census) or greater shall also measure Pb either as Pb-TSPorPbPMJO." The Network Plan indicates that Pb-TSP sampling is ongoing at the DMRC site (AQS ID: 

### 13- 089-0003), which is located at 

### 3073 Panthersville Road, Decatur near the South DeKalb NCore site (AQS ID: 

### 13-089-0002). The EPA has previously agreed thatPb monitoring at the DMRC site can be used to meet the NCore Pb monitoring requirement. The Pb monitoring network described in the Network Plan meets all ofthe design criteria of

### 40 CFR Part 

### 58. 

### Sulfur Dioxide (S02)

### Monitoring Requirements 40 CFRPart58, Appendix D,4.4 Ambient air monitoring network design criteria for 

### SOz are found in Section

### 4.4 ofAppendix D to 

### 40 CFR Part 

### 58. This section requires that "Thepopulation weighted emissions index (PWEI) shall be calculated by states for each core based statistical area (CBSA)." As a result, the 

### SOz monitoring site(s) required in each CBSA will satisfy minimum monitoring requirements ifthe monitor(s) is sited within the boundaries ofthe parent CBSA and is one ofthe following site types: population exposure, maximumconcentration, source-oriented, general background, or regional transport. An S02 monitor at an NCore station may satisfy minimum monitoring requirements ifthat monitor is located within a CBSA with minimallyrequired monitors consistent with Appendix D,

### 4.4. In

### 2012, the EPA's Office ofAir Quality Planning and Standards updated the population weighted emission index (PWEO 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 these latest calculations.


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### Nitrogen Dioxide (NOz) Monitoring Requirements 40 CFRPart58, AppendixD,4.3 Ambient air monitoring network design criteria for N02 are found in Section4.3 ofAppendix D to 40 CFR Part 58

. Three types ofN02 monitoring are required: near-road, area-wide, and Regional Administrator (RA-40). These types of NOz monitoring are described in sections 4

.3

.2,4.3

.3, and 4.3

.4, respectively

. The EPA approved the selection ofthe South DeKalb site, AQS #13-089-0002, 

### in fulfillment ofthe area-wide NOz monitoring requirement for the Atlanta CBSA in 2013. Atthis time, no monitors have been preliminarily orotherwise identified by the regional office orGA EPD to meet the requirements for the RA-40 sites. There is no deficiency with this requirement. The EPA approved the first near-road N02 site to be located at GeorgiaTech along the 1-7511

-85 connector contingent upon all applicable siting criteria being met. That site is installed and fully operational. Because ofits size, the Atlanta CBSA is required tohave an additional site. The EPA bas received the state's draft addendum and has preliminarily agreed on the location ofthe second site adjacent to the NCore collocated lead (Pb) monitors

. The EPAbelieves this is a unique opportunity to have a near-road N02 site close to an NCore site. Once the addendum is finalized, it mustbe posted for a 30 day public inspection period and subsequently submitted to The EPA Region 4, along with any comments, for fmal approval. The EPA will continue to work with your agency as needed to select and approve the second near-road N02 site as expeditiously as possible. 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 may be modified in 2016

. The N02 near-road monitoring requirements may change for CBSAs with a populations between 500,000 and 1,000,000 people, such as the GA CBSAs listed above

. 

### Carbon Monoxide (CO) Monitoring Requirements 40 CFR,Part58, Appendix D, 4.2 Ambient air monit oring network design criteria for CO are found in Section4.2 ofAppendix 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 NOz monitor. CBSAs with populations over2.5 million people are required by 40 CFR §58

. 13 to operate a near-road CO monitor byJanuary 1, 2015

. This requirement is met for the Atlanta CBSA by the CO monitor at the Georgia Tech (AQS # 13-121-0056) near -road site. 

### 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 wholly 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 of the GA EPD Web site where this information is available for these areas. The state is meeting 

### 4the AQI reporting requirements. The EPA also recognizes that the GA EPD provides this service to other areas across the state, and that the Chattanooga-Hamilton County Air Pollution Control Bureau provides this service for the Chattanooga MSA. 

### Monitoring Network ChangesProposed by 

### GAEPD In its 2013 Network Plan, the state listed in Section 1.7 additional changes being proposed in the network as well as listing the changes that have occurred as a result oftheEPA's approval in 2012. Those changes listed in your plan that were approved last year havebeen verified. The changes to the S02, N02, CO, Pb and PM2.5 networks listed in section 1.7 ofyour 2014 plan are approved. While we granted a waiver inresponse to last year's plan to discontinue Pb monitoring at the Gerdau Ameristeel facility in Bartow County based on the historical data record, this waiver mustberenewed at the time of each five year network assessment or upon learning ofprocess changes at the facility that may increase the emissions. 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. 

### Ifthe GAEPD is operating these monitors as FEMs, they shouldbe incorporated into· the state's ambient air monitoring network as an approved monitoring method for PM2.s and the associated mass data shouldbereported to parametercode 88101 in the EPA's Air Quality System (AQS). At this time, the SouthDeKalb NCore site, AQS #13-089-0002, and the Albany site, AQS #13-095-0007, have BAM 1020s operating as regulatory FEMs and the associated mass data are being reported correctly. Only PM2.s monitors incorporated into the state's ambient air monitoring network and reporting data to AQS will be taken into consideration ifthe PM2.s grant funds are reallocated in FY15 orFY16. 

### 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 the EPA's Office ofAir Quality Planning and Standards on October 30, 2009. It currently meets all requirements. Due to changes in the PM2.5 rule listed in the Federal Register published on Tuesday, January 15, 2013, the EPA revoked the requirement for conducting PMJ0.2.5 speciation at NCore sites. The GAEPD does not have to conduct PM10.2.5 speciation at the NCore site as stated in section 2.4 ofAppendix C. 

### Chemical Speciation Network (CSN) The EPAhas been conducting an assessment ofthe Chemical Speciation Network (CSN) in an effortto optimize the network and create a network that is sustainable going forward. As a result ofthis assessment, the EPA is defunding a number ofmonitoring sites, eliminating the CSN

### PMz.s mass measurement, reducing the frequency ofcarbon blanks, reducing sample frequency at some monitoring sites, and reducing the number oficepacks in shipment during the cooler months ofthe year. CSN monitors in the state will be affected at both the Athens and Douglas (General Coffee) sites, 13-059- 0002 and 13-069-0002, respectively due to defunding. The state will also be affected at all funded CSN sites by the elimination ofthe PM2.s mass measurement, the reduction ofcarbon blank frequency, and the reduction in icepacks. The CSN PM2.s mass measurement is recommended for elimination in October2014 and all otherchanges are recommended to take place in January 2015. Final changes to the CSN in Georgia should be reflected in the Network Plan due July 1, 2015, including sites where the EPD has decided to continue funding on their own. 

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### Other Concerns Site evaluation comments are listed in Section 6.0 on Pages 30-32 ofthe 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 infonnation in its Network Plan

. As most ofthese sites are used in regulatory decision-making, we understand that GA EPDjudiciouslytries 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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