Mr. Keith Bentley 

Chief 

Air Protection Branch 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA30303-8960 

l\D~ jl __ l 20\4 

Environmental Protection Division 

Georgia Department of Natural Resources 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 

Dear Mr. Bentley: 

Thank you for submitting the state of Georgia's 2014 annual ambient air monitoring network plan 

(Network Plan) received July 1, 2014. 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 (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 of the 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 of the provision 

to establish a second near-road nitrogen dioxide (N02) site in the Atlanta core based statistical area 

(CBSA). We have enclosed our analysis of your Network 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 of the 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 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. 

Sincerely, 

Director 

=:~ ~· 

Air, Pesticides and Toxics Management Division 

Enclosure 

Internet Addrass (URL) • http://www.epa.gov 

Racyclad/Racyclabla • Printed with Vegetable 08 Based Inks on Recycled Paper (Minimum 30% Poslconsumer) 

CY 2014 State of Georgia 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 on the 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 

matter less 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 of Management 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 of Georgia. 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 and Populations 

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 CFR Part 58, 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 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 National Ambient Air Quality Standard (NAAQS) (0.063ppm 

after truncation). The official design value for the 2011-2013 period is 0.062 parts per million (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 of the NAAQS and could potentially be 

above that after this ozone season ending on October 31, 2014. We will reevaluate this situation in 2015 

and continue working with your agency and the South Carolina Department of Health and 
Environmental Control to determine whether exploratory ozone monitoring is warranted and/or feasible 

in South Carolina just north of the 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 Part 58, 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 of each network of manual PMw 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 to 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, 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. 

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

continuous PM2.s monitoring network described in the 2014 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 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 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. 

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 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 by January 1, 2015. 

Lead (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. Last year, 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 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-TSP or PbPMJO." 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 that Pb 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 of the design criteria of 40 CFR Part 58. 

Sulfur Dioxide (S02) Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.4 

Ambient air monitoring network design criteria for SOz 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 SOz 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-oriented, general background, or regional transport. An S02 monitor at 

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

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

In 2012, the EPA's Office of Air 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. 

3 
Nitrogen Dioxide (NOz) 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 (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 of the South DeKalb site, AQS #13-089-0002, in fulfillment of the 

area-wide NOz monitoring requirement for the Atlanta CBSA in 2013. At this time, no monitors have 

been preliminarily or otherwise identified by the regional office or GA 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 Georgia Tech along the 1-7511-85 

connector contingent upon all applicable siting criteria being met. That site is installed and fully 

operational. Because of its size, the Atlanta CBSA is required to have an additional site. The EPA bas 

received the state's draft addendum and has preliminarily agreed on the location of the second site 

adjacent to the NCore collocated lead (Pb) monitors. The EPA believes this is a unique opportunity to 

have a near-road N02 site close to an NCore site. Once the addendum is finalized, it must be 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 of Appendix 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 of the 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, 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 NOz monitor. CBSAs with populations over 2.5 million people are 

required by 40 CFR §58.13 to operate a near-road CO monitor by January 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 

4 
the 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 Changes Proposed by GA EPD 

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 of the EPA's approval in 2012. 

Those changes listed in your plan that were approved last year have been verified. The changes to the 

S02, N02, CO, Pb and PM2.5 networks listed in section 1.7 of your 2014 plan are approved. While we 

granted a waiver in response 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 must be renewed at the time of 

each five year network assessment or upon learning of process 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. If the GA EPD is operating these monitors as FEMs, they 

should be incorporated into· the state's ambient air monitoring network as an approved monitoring 

method for PM2.s and the associated mass data should be reported to parameter code 88101 in the EPA's 

Air Quality System (AQS). At this time, the South DeKalb 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 if the PM2.s grant funds 

are reallocated in FY15 or FY16. 

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 of Air 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 GA EPD does not have to conduct PM10.2.5 speciation at the NCore site as 

stated in section 2.4 of Appendix C. 

Chemical Speciation Network (CSN) 

The EPA has been conducting an assessment of the Chemical Speciation Network (CSN) in an effort to 

optimize the network and create a network that is sustainable going forward. As a result of this 

assessment, the EPA is defunding a number of monitoring sites, eliminating the CSN PMz.s mass 

measurement, reducing the frequency of carbon blanks, reducing sample frequency at some monitoring 

sites, and reducing the number of icepacks in shipment during the cooler months of the 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 of the PM2.s mass measurement, the reduction of carbon blank frequency, and 

the reduction in icepacks. The CSN PM2.s mass measurement is recommended for elimination in 

October 2014 and all other changes 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. 

5 
Other Concerns 

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 infonnation in its Network Plan. As most of these sites 

are used in regulatory decision-making, we understand that GA 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. 

6