Executive Director 

Mississippi Department of 

Environmental Quality 

P.O. Box 2261 

Jackson, Mississippi 39225-2261 

Dear Mr. Rikard: 

Thank you for 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 to the public for review and 

comment for a period of 30 days. The cover letter submitted with the MDEQ Network Plan indicated 

that the Network Plan was available on the MDEQ website from May 1-31, 2015 for public review and 

that MDEQ did not receive any comments from the public regarding the plan. 

The U.S. Environmental Protection Agency Region 4 has reviewed the MDEQ Network Plan and 

approves the plan for the 2016 calendar year. A summary of comments has been included for review and 

consideration. Region 4 staff are available to discuss the comments and provide any additional feedback 

that may be helpful. 

The EPA Region 4 appreciates MDEQ's efforts to monitor air pollution and promote healthy air quality 

in Mississippi. If there are any questions or concerns, please feel free to contact Gregg Worley at (404) 

562-9141 or Donnette 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) 

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 the 
• Date on which monitoring sites were evaluated to verify that siting criteria are being met 

• Date geographical coordinates were verified for each site 

• Actual distances from neighboring structures such as trees, fences, etc. 

In the network design tables on Pages 7-9, minimum monitoring requirements listed for 03 and PM2.s 

for some sites including Waveland and Hernando appear to be inaccurately reported and do not correlate 

with site information included in the Site Discussion provided on Pages 4-5. Additionally, for minimum 

monitoring requirements of an MSA such as the Memphis, TN-MS-AR MSA, it would be helpful to 

include a column in the table to show which monitors contribute to meeting the requirements and in 

what states they are located. 

Monitoring Network Changes Proposed by MDEQ 

MDEQ does not propose any changes to the 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 over 350,000. The GulfportBiloxi-Pascagoula, MS, Jackson, MS and Memphis, TN-MS-AR MSAs are required to report AQis. 

The Network Plan includes a link on Page 3 directing users to the 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 operates the Jackson NCore site located at 232 E. Woodrow Wilson Drive, in Jackson, 

MS. The site replaces a former site and has been in operation since July 1, 2013. This location is 

approximately one mile from the former location near the University of Mississippi Medical Center. 

Monitored parameters include 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 operate two 03 monitors in each of the Gulfport-Biloxi-Pascagoula and Memphis 

MSAs and one monitor in the Jackson MSA. The Gulfport-Biloxi-Pascagoula and Jackson MSAs meet 

this requirement. A memorandum of agreement (MOA) between the states of Mississippi, Arkansas, 

Tennessee, and the Shelby County Health Department allows Mississippi to meet the 03 requirement for 
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. 
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 Document1• 

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 
requirement by having both 

egu

p

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. 
Monitoring Requirements for Multi-State CBSAs 

40 CFR Part 58 Appendix D, 2(e) 

As previously discussed, MDEQ has an MOA with the states of Arkansas and Tennessee and the 

Memphis/Shelby County Health Department for sharing responsibility to meet the 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 meets the minimum requirements found in 40 CFR 

Part 58, Appendix D, 2(e).