UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION4 Mr. Gary Rikard Executive Director Mississippi Department
of Environmental Quality P.O. Box 2261 Jackson, Mississippi 39225-2261 DearMr.Rikard: ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 OCT 0 6 2015 Thank youfor submitting the 2016 Ambient Air Monitoring Network Plan (Network Plan) for the state of Mississippi dated June 9, 2015. The annual Network Plan is required by 40 Code of Federal Regulations (CFR) §58.10. The Network Plan describes the ambient air monitoring network operated throughout the state by the Mississippi Department
of Environmental Quality (MDEQ). Federal regulations require that the Network Plan be made available
tothe public for review and commentfor a period of 30 days. The coverletter submitted with the MDEQ Network Plan indicated that the Network Plan wasavailable onthe MDEQ website from May 1-31, 2015 for public review and that MDEQ did notreceive anycommentsfrom the public regarding the plan. The U.S. Environmental Protection Agency Region

4 has reviewed the MDEQ Network Plan and approvesthe plan for the 2016 calendar year.A summaryof commentshas been included for review and consideration. Region

4 staff areavailable
todiscuss the commentsand provide anyadditional feedback that maybe helpful. The EPA Region

4 appreciates MDEQ's efforts tomonitor air pollution and promote healthy air quality in Mississippi.

If there are any questions
orconcerns, please feel free tocontact Gregg Worley
at (404) 562-9141
orDonnette Sturdivant

at (404) 562-9431. Enclosure cc:Mr.Michael Jordan, Chief, Air Quality Monitoring Division Sincerely, **g......-~·** Beverly H.Baniste Director Air, Pesticides and Toxics Management Division Mississippi Department
of Environmental Quality Internet Address (URL)

• http://www.epa.gov Recycled/Recyclable

•Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

# CY 2015 State of Mississippi Ambient Air Monitoring Network Plan U.S. EPA Region

4 Comments and Recommendations The U.S. Environmental Protection Agency Region

4 reviewed the Mississippi Department
of Environmental Quality (MDEQ) annual Air Monitoring Network Plan (Network Plan). Ambient air monitoring rules are found in 40 CFR Part 58, which include regulatory requirements regarding network plans, data certification, and minimum monitoring requirements. 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.s), 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 area (CBSA) boundaries

as defined by the U.S. Office of Management and Budget, population estimates from the U.S. Census Bureau effective July 1, 2014, and historical ambient air monitoring data. Minimum monitoring requirements
for 03, PM2.s, and PMto only apply to metropolitan statistical areas (MSAs), which are a subset of CBSAs. Mississippi's four MSAs and respective population estimates from the U.S. Census Bureau are shown in Table
1. Table 1: July 1, 2014 Population Estimates for Mississippi MSAs MSA
Population Est. ' GulfpOrUBlloxi-Pascagoula,



# : M:s Hattiesburg, MS

148,656 Memphis, TN-MS-AR
1,343,230 

# Comments and recommendations

are provided
in the following sections and are based on EPA Region 4's review ofMDEQ's Network Plan and comparison

to minimum monitoring requirements outlined
in 40 CFR Part 58. 

# General Comments In the Overview section on Page
3 of the Network Plan, the MDEQ Quality Management Plan (QMP)
is noted to be current with an approval date of April 23, 2009. During

a recent technical systems audit (TSA), an approval letter dated August 13, 2014 for an updated QMP was provided
to the Science and Ecosystem Division (SESD) auditors. The Overview also indicates that the current criteria pollutant quality assurance project plan (QAPP) has an approval date of October

1, 2006. EPA recommends that QAPPs be updated every five years to ensure that current monitoring practices and quality assurance procedures are adequately documented. EPA recommends that MDEQ contact SESD for additional information related to updating the QAPP. The Network Plan indicates that the state used 2010 Census population data in determining whether the monitoring sites meet minimum monitoring requirements
for criteria pollutants
in the MDEQ monitoring network. EPA Region

4 used 2014 Census population estimates (Table

1 above) to evaluate minimum monitoring requirements
for each site. Although the estimates are slightly higher than the2010 population data, the results arethe same--minimum monitoring requirements have been metfor each pollutant. When updating the Network Plan for 2016, EPA recommends that Mississippi usethe most recently available data from the U.S. Census Bureau. The Network Plan includes various photos for each monitoring site in the monitoring network. The photos clearly depict site features such asshelters, monitoring equipment, and neighboring structures adjacent
toeach site. As perthe regulations,

it is recommended that more descriptive language verifying specific characteristics
for each site be included. Examples
of more descriptive language include: •Dateonwhich monitoring sites wereevaluated
to verify that siting criteria are being met •Date geographical coordinates wereverified for each site •Actual distances from neighboring structuressuch astrees, fences, etc. Inthe network design tables on Pages 7-9, minimum monitoring requirements listed for 03 and PM2.s for somesites including Waveland and Hernando appeartobe inaccurately reported and do notcorrelate with site information included
in the Site Discussion provided on Pages 4-5. Additionally,
for minimum monitoring requirements

of anMSA such asthe Memphis, TN-MS-AR MSA,
it would be helpful to include

acolumn
in the table toshow which monitors contribute

to meeting the requirements and in what states they arelocated. Monitoring Network Changes Proposed by MDEQ MDEQ does not propose any changes
tothe current monitoring network
in the Network Plan. Air Quality Index (AQI) Reporting 40 CFR Part 58.50 Air Quality Index (AQI) reporting

is required
in MSAs with populations over350,000. The GulfportBiloxi-Pascagoula,
MS, Jackson, MS and Memphis, TN-MS-AR MSAs are required
to report AQis. The Network Plan includes

alink on Page
3 directing userstothe MDEQ web site where AQI information

is available. This satisfies the AQI reporting requirements. National Core (NCore) Monitoring Network 40 CFR Part 58, Appendix
D, 3.0 MDEQ currently operatesthe Jackson NCore site located
at232 E. Woodrow Wilson Drive, in Jackson, MS. The site replaces

aformer site and has been in operation since July 1, 2013. This location

is approximately onemile from the former location nearthe University
of Mississippi Medical Center. Monitored parametersinclude 03, S02, CO, nitric oxides, federal reference method (FRM) and federal equivalent method (FEM) PM2.s, PM10-2.s, speciated PM2.s, and meteorological data. The site meets NCore monitoring requirements. OJ Monitoring Requirements 40 CFR Part 58, Appendix
D, 4.1, Table D-2 MDEQ

is required
to operatetwo03 monitors
in each of the Gulfport-Biloxi-Pascagoula

and Memphis MSAs and onemonitor
in the Jackson MSA. The Gulfport-Biloxi-Pascagoula

and Jackson MSAs meet this requirement.

A memorandum

of agreement (MOA) between the statesof Mississippi, Arkansas, Tennessee, and the Shelby County Health Department allows Mississippi

tomeetthe 03 requirement forthe Memphis, TN-MS-AR MSA with the single 03 monitor
in DeSoto County, MS. The 03 network described
in the Network Plan meets the minimum monitoring requirements. 

### CO Monitoring Requirements 40 CFR Part 58, Appendix
D, 4.2 MDEQ operates one CO monitor
at the Jackson NCore site. No additional CO monitors are required
in the network. 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. These types are described
in sections 4.3.2, 4.3.3 and 4.3.4, respectively. The Memphis, TN-MS-AR CBSA,
is the only area in Mississippi currently required
to have
a near-road or an area-wide N02 monitoring site because

it is the only CBSA with
a population greater than 1,000,000 people. For the Memphis, TN-MS-AR CBSA, the requirement for near-road N02 monitoring is being met by a site (Air Quality System (AQS) 47-157-0100) operated by the Memphis/Shelby County Health Department

in Memphis, TN. Additionally,
the Marion site (AQS 05-035-0005)

in Arkansas fulfills the area-wide N02 monitoring requirement for the Memphis, TN-MS-AR CBSA. No other CBSA in Mississippi

is required
to have area-wide N02 monitoring

or near-road N02 monitoring at this time. The Jackson, MS CBSA
is required
to operate

a near-road N02 monitor by January

1, 2017. Ambient air monitoring network design criteria for Regional Administrator required N02 monitoring, often referred to as RA-40 monitoring, are found in Section 4.3.4 of Appendix

D to 40 CFR Part 58. This section states that "the Regional Administrators,

in collaboration with States, must require

a minimum
of forty additional N02 monitoring stations nationwide

in any area, inside or outside of CBSAs, above the minimum monitoring requirements, with
a primary focus on siting these monitors
in locations
to protect susceptible and vulnerable populations. The Regional Administrators, working with States, may also consider additional factors ... to require monitors beyond the minimum network requirement." The EPA Region

4 previously identified the N02 monitor
at the Pascagoula site (AQS 28-059-0006)

to serve as a Regional Administrator required N02 monitor intended
to help protect susceptible and vulnerable populations. The EPA requires the monitor type for this monitor
to be changed from special purpose monitor (SPM) to State and Local Air Monitoring Station (SLAMS) retroactive

to January

1, 2014. The full list of N02 monitors identified by the Regional Administrators
can be found at http://www .epa. gov/ttnamti
1/s vpop.html.

### 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 of 

### 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) ... " S02 monitor(s) should be sited within CBSA boundaries and be of the following site type(s): 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 that is required
to have
a monitor under Appendix D, 

### 4.4. MDEQ's S02 monitors are at the Jackson NCore (AQS 

### 28-049-0020) and the Pascagoula (AQS 

### 28-059-0006) monitoring sites. S02 PWEI monitoring

is only required
in the Memphis, TN-MS-AR CBSA. As outlined
in the MOA between MDEQ, Memphis-Shelby County, and Arkansas, this requirement

is being met by the Memphis-Shelby County Health Department

at its Memphis NCore site. The S02 monitoring network design proposed
in the Network Plan meets the minimum requirements

of 

### 40 CFR Part 

### 58. EPA finalized the S02 Data Requirements Rule (DRR) on August 

### 10, 2015. This rule requires characterization

of the air quality near sources with S02 emissions greater than 

### 2,000 tons per year by conducting ambient air monitoring
or modeling. We encourage your agency to begin having conversations with affected sources in your state to agree upon an approach for meeting the DRR requirements.
By January 

### 15,2016, MDEQ must submit to EPA Region



### 4 a list of sources around which S02 air quality must be characterized. For sources that MDEQ decides to evaluate using ambient air monitoring, new site proposals must be included
in next year's 

### 2016 Network Plan. The location of these 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, 4.7.3 40 CFR Part 58, Appendix
D, 3(b) Lead monitoring requirements
are found in 

### 40 CFR Part 

### 58, Appendix
D, 

### 4.5. This states that "At a minimum, there must be one source-oriented SLAMS 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 ... " There are currently no stationary Pb sources in Mississippi requiring ambient air lead monitoring. Furthermore,


### 40 CFR Part 

### 58, Appendix D, 3(b) requires that "NCore sites in CBSAs with populations of 

### 500,000 people (as determined

in the latest census) or greater shall measure Pb either as Pb-TSP or Pb-PM10." MDEQ monitors lead at the NCore site in Jackson (AQS 

### 28-049-0019). EPA Region



### 4 has determined that the Pb monitoring network described
in the Network Plan meets all design criteria of 

### 40 CFR Part 

### 58. 1 SOz 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. http://www3.epa.gov/airguality/sulfurdioxide/pdfs/S02MonitoringT

AD.pdf

# Minimum PMto Monitoring Requirements 40 CFR Part 58, Appendix
D, 3.3.1 40 CFR Part 58, Appendix
D, Table D-4 The State of Mississippi's current PM1o monitoring network meets the minimum requirements found in 40 CFR Part 58, Appendix
D, Table D-4 for all MSAs. All PM10 collocation requirements
for manual methods found in 40 CFR Part 58, Appendix
A, Section 3.3.1 are also being met. Fifteen percent of each network of manual PM10 methods (at least one site) must be collocated. MDEQ will meet this requirement
by having both regular and collocated FRM PM10 samplers
at the relocated NCore site in the Jackson MSA (AQS 28-049-0020). 

# Minimum **P~b.s** 

# Monitoring Requirements 40 CFR Part 58, Appendix
A, 3.2.5 40 CFR Part 58, Appendix
D, Table D-5 The following MSAs are required
to have one PM2.s monitor: Gulfport-Biloxi-Pascagoula,

MS; Hattiesburg, MS, and Jackson, MS. The Memphis, TN-MS-AR MSA is required
to have two PM2.s monitors. MDEQ's MOA with Arkansas and Memphis-Shelby County, Tennessee allows Mississippi

to meet the PM2.s requirements
for the Memphis, TN-MS-AR MSA with the single 

# PMz.s monitor. That monitor

is in DeSoto County, MS. MDEQ's PM2.s monitoring network
as described
in the Network Plan meets the minimum requirements found in 40 CFR Part 58, Appendix D, Table D-5 for all MSA's. 

# PM2.s Continuous Monitoring Requirements 40 CFR Part 58, Appendix
D, 4.7.2 Regulatory requirements
for continuous 

# PMz.s monitoring require that
" ... 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 (Approved Regional Method) monitors, unless at least one of the required FRMIFEM/ ARM monitors

is itself

a continuous FRM or ARM monitor
in which case no collocation requirements applies." These minimum continuous PM2.s monitoring requirements
are being met in all MSAs. 

# PM2.s Continuous Federal Equivalent Methods 40 CFR

§ 

# 58.10(e) As part of the recent revisions
to the PM2.s national ambient air quality standards (NAAQS), the EPA created new procedures for handling data collected using continuous PM2.s FEMs. These procedures are found at 40 CFR §58.10(e).

If an agency can demonstrate that the FEM data are not sufficiently comparable

to collocated FRM data, then the monitoring agency may request that the FEM data not be used in comparison

to the NAAQSs. The current plan indicates that MDEQ
is not operating any continuous FEM samplers
in its network. Any future requests for exclusion of data from NAAQS comparisons will need to be submitted

to EPA for approval
in future network plans.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 stateshall install and operate
atleast onePMz

.ssite tomonitor for regional background and atleast onePMz.s site tomonitor for regional transport." The Grenada PMz.s monitor (AQS 28-043-0001)

is identified

asa background monitor and the Hernando PMz.s monitor (AQS 28-033-0002)

is identified

asthe transportmonitor. Therefore, MDEQ has satisfied the requirements

of the 40 CFR Part58 for background and transport sites. Monitoring Requirements
for Multi-State CBSAs 40 CFR Part 58 Appendix
D, 2(e) As previously discussed, MDEQ has anMOA with the statesof Arkansas and Tennessee and the Memphis/Shelby County Health Department for sharing responsibility

tomeetthe minimum monitoring requirements

in the Memphis, TN-MS-AR CBSA and MSA. The EPA's review of the Network Plan found that the monitoring

in the CBSA and/or MSA meetsthe minimum requirements found in 40 CFR Part 58, Appendix
D, 2(e).