UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION

4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 MEMORANDUM TO:

R. Scott Davis, Chief Air Planning Branch

1. FROM: Gregg M. Worley, Chief bCXJ **>'I\·~** Air Toxics

& Monitoring Branch DATE: August

8, 2014 SUBJECT: Data Completeness

for Certain Georgia Areas The following areas in Georgia have invalid design values for particulate matter less than

2

. 5 microns (PM2.s) for the 2011-2013 design value period but may have valid 2012-2014 design values once 2014 data is certified
by the state: Augusta, Columbus, Savannah, Valdosta, and Washington County. The 2011-2013 design values for these areas are invalid due to incomplete data during this time period resulting primarily from the January 9-10, 20 11, winter storm that encompassed large portions

of north and central Georgia causing power outages affecting monitoring sites and the state's laboratory (see Appendix

A for
a map showing snow and ice accumulation across the state). The Georgia Environmental Protection Division (GEPD) laboratory

is located

in northeast Atlanta

in Norcross, Georgia (Gwinnett County). This laboratory provides the PM2.s gravimetric weighing service for GEPD's PM2.s ambient
air monitoring program

. Most PM2.s filter samples across the state were affected from January

9 through February 23, 2011. The actual number
of missed sampling days due to the ice storm varies by monitoring site, because
all sites are not on the same sampling frequency. This can range from

8 to 45 missed samples per monitor. The impact of the storm on the laboratory

is illustrated

by the amount
of data invalidated

by GEPD
in the first quarter versus the second quarter
of 2011.
In the first quarter
of 2011 when the storm occurred, GEPD flagged 650 out of 1371 total samples across the state (47.4%)

in AQS for laboratory error. In the second quarter
of 2011, GEPD flagged one of 1367 total samples across the state (0.00073%)

in AQS for laboratory error. GEPD included the following information

on the impacts
of the storm
in a draft technical analysis provided

to Region

4
: "It is important

to note that all of the Georgia monitors, except for South DeKalb. have incomplete data for the first quarter
of 2011. This was due to circumstances

out of EPD's control that resulted from

a snow and ice storm from January

9 through 11, 2011. The storm caused problems with the power and environmental control systems for the EPD Laboratory which lost power on and off during the following week. The systems were brought back on line by Friday, January
14; however, the weighing rooms could not be stabilized until February

2. twenty four days after the storm began.
In order to meet federal ambient monitor sampling Internet Address (UAL)

• http://www.epa.gov Racyclad/Racyclabla

• Printed wfth Vegetable

00 Based Inks on Recycled Paper (Minimum 30% Postconsumel)deadlines, both pre-and post-sample weighing had to be conducted during this period.

Furthermore, samples could not have been prepared or taken through the preparation process at

another laboratory (commercial, federal, state or academic) and still meet federal sampling

requirements." While GEPD was able to open a large portion of the laboratory shortly after the storm , the state

indicated in its report that the temperature and humidity of the PM2.s gravimetric weigh lab was not able

to be stabilized until February 2, 2011. After reviewing the number of days GEPD invalidated samples ,

the EPA Region 4 believes the weigh lab was experienc i ng temperature and humidity control issues

through February 23. Temperature and humidity control ranges are among parameters ident i fied as

"critical criteria" in the federa l reference method for PM 2 .s found in 40 CFR Part 50, Appendix L.

Accordingly, when filters are weighed outside of these allowable ranges, the associated data should be

considered invalid for regula t ory purposes unless there is a compelling reason and justification for n ot

doing so . These issues affected sample preparation (i.e., pre-weighs) and analysis (i . e., post-weighs)

through February 23 for all si t es in the state except the South DeKalb site which has a continuous

federal equivalent method monitor . GEPD, as part of their normal quality assurance procedures,

invalidated the data from January 9 through February 23, 2011, that was impacted by the s torm and

entered " null codes" for these data in AQS . PM 2 . s data for the second, third, and fourth quarters of 2011

is complete for many areas, including Augusta, Columbus, Savannah, Valdosta, and Washington

County. While the majority of the data issues for the 2011-2013 design value period were due to the 2011 winter

storm, several sites across the state, including the Columbus , Savannah, and Valdosta areas , experienc e d

add i tional data completeness issues in 2012. There are no data completeness issues in 2013 for the

Augu s ta, Co l umbus, Savannah, Valdosta, or Washington County areas. GEPD invalidated an unusually

high percentage of PM2 . s data from several sites in 2012 be c ause of damage to the PM2.s filters. Upon

discussing this with GEPD, EPA understands that s everal factor s may have contributed to this high rate

of invalidat i on due to filter damage, including sample handling procedures (GEPD was freezing its

PM 2 j fil t ers before they were used , which is not common), site operator procedures, a change in the

national manufacturer of PM2 . s filters i n 2012 , and the acceptance criter i a establi s hed by the GEPD for

filter damage . In July 2013, GEPD contacted EPA's O ffi ce of Air Quality Planning & Standards about

the filter damage issue that it experienced at sev e ral s ites across their network in 2012 and the

procedures that it is using to minimize filter damage during shipping and handling . GEPD adopted a

number of corrective actions that appear to have greatly mitigated this problem at most sites in 2013 to

present. As you are aware, GEPD is the only agency in Georgia w i th an ambient air monitoring program. There

are no local agencies to take on managing remote sites in the network. In some areas where mon i to ri ng

i s conducted but may not be federally required, GEPD may experience other issues affecting data

completeness. It is possible that changes in the shipping and handling procedures incorporated in other

areas are not as effective in minimizing filter damage in these more remote locations. Also, it may take

longer on occasion in identifying and troub l eshooting problems with these mon i tors due to the

availabil i ty of personnel. Further discussion with GEPD may be warranted to jointly figure out a long

term solution f or the data issues plaguing a few of the s e sites or perhaps officially making them nonregulatory monitors in those areas .
Despite the data completeness issues identified above, many areas in Georgia were able to have valid

2011 - 2013 design values computed in accordance with the data handli n g convent i ons outlined in 40

CFR Part 50 Appendix N . However, it was not pos s ible to use these data handling conventions tocalculatevalid2011-2013designvaluesforthefollowingareas:Albany,Atlanta,Augusta,Brunswick,Columbus,Savannah,Valdosta,andWashingtonCounty.Thoseareashadlessthan50%completenessinthefirstquarterof2011andtherefore,donotmeetthedatahandlingrequirementsin40CFRPart58,AppendixN4.1(c)(ii)whichstipulatesgreaterthan50%completenessisrequiredinallquartersofthethreeyeardesignvalueperiodinordertoconductdatasubstitution.AlthoughtheAugusta,Columbus,Savannah,Valdosta,andWashingtonCountyareashaveinvalid2011-2013designvalues,theAirToxics&MonitoringBranchbelievesthattheseareaswilllikelyhavevalid2012-2014designvaluesonceGEPDcertifiescomplete,quality-assureddataforthe2014calendaryearbecauseamajorityofthedatacompletenessissuesfortheseareasisassociatedwiththe2011winterstormdiscussedabove.Furthermore,basedonthechangestothefilterhandlingproceduresmentionedaboveandtheimproveddatacompletenesspercentagesin2013,EPAhasnoreasontobelieveatthistimethatthe2014datawillbeincomplete.Letusknowifthereisanyotherinformationneededbyyouoryourstaff.