Chief 

Air Division 

Alabama Department of Environmental Management 

1400 Coliseum Boulevard 

Montgomery, Alabama 36130- 1463 

Dear Mr. Gore: 

Thank you for submitting the State of Alabama's annual ambient air monitoring network 

plan (Network Plan) dated July 1,2010. The Network Plan is required by 40 Code of Federal 

Regulations (CFR) 58.10. The U. S . Environmental Protection Agency (EPA) Region 4 

understands that the Alabama Department of Environmental Management (ADEM) provided the 

public a 30-day review period and that no comments were received. 

Based on our review of the Network Plan, EPA Region 4 has determined that the 

document satisfies the applicable requirements of 40 CFR Part 58. The Network Plan is 

0 approved. Comments and recommendations are enclosed. 

Thank you for your work to monitor air pollution and promote healthy air quality 

in Alabama and the nation. Please let us know of problems in meeting any of the requirements 

identified above. If you have any questions or concerns, please contact Doug Neeley at 

(404) 562-9097 or Lloyd Generette at (404) 562-9138. 

Sincerely, 

- 

dwendolp Keyes Fleming Regional Administrator 

Enclosure 6 

cc: T. Wayne Studyvin, Director 

Jefferson County Department of Health 

Daniel E. Shea, Director 

Huntsville Department of Natural Resources 

Archie Lee, SESD 

Internet Address (URL) http://www.epa.gov 

RecycledlRecyclabte .Printed wlh Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Poslconsurner) 
This document contains U.S. EPA Region 4 comments and recommendations on the State 

of Alabama's 2010 ambient monitoring network plan (Network Plan). Ambient air monitoring 

rules, which include regulatory requirements that address network plans, data certification, and 

minimum monitoring requirements, among others, 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 do not exist for carbon monoxide (CO) unless required by the establishment of a National 

Core (NCore) multi-pollutant monitoring station andlor a state implementation plan. However, new 

national ambient air quality standards (NAAQS) were promulgated this year for nitrogen dioxide (NO2) 

and sulfur dioxide (SO2) with minimum monitoring requirements effective January 1,2013. Minimum 

monitoring requirements are listed for ozone (03), particulate matter less than 2.5 microns (PM2.5), 

particulate matter less than 10 microns (PMlo), and lead (Pb). 

The minimum monitoring requirements are based on metropolitan statistical area (MSA) 

boundaries as defined by the U.S. Office of Management and Budget (OMB), July 1,2009, population 

estimates from the U.S. Census Bureau, and historical ambient air monitoring data. OMB currently 0 defines 12 MSAs in the State of Alabama. These MSAs and their respective July 1,2009, population 

estimates from the U.S. Census Bureau are shown below in Table 1. 

[ Auburn-Opelika, AL 135,883 1 

Table 1: MSAs and Populations 

MSA I Population 

Anniston-Oxford. AL 

- - ,-- - 

Florence-Muscle Shoals, AL I 144,238 

1 14.08 1 

Birmingham-Hoover, AL 

Columbus, GA-AL 

Decatur, AL Dothan. AL 

1,131,070 

292,795 

15 1,399 142.693 

Minimum Ozone Monitoring Requirements 40 CFR Part 58, Appendix D, Table D-2 

Gadsden, AL Huntsville, AL Mobile, AL 

Montgomery, AL Tuscaloosa, AL 

Region 4 has determined that an additional O3 monitor is required in the Huntsville, ? Alabama MSA. Table D-2 of Appendix D to 40 CFR Part 58 lists the requirement for two 0, 

monitors for MSAs with populations between 350,000 and 4 million when the most recent 

103,645 

406,3 16 411,721 

366,4O 1 2 10,839 
, 

pp

, 

40 CFR Part 58, Appendix D, Table D-4 

Region 4 has determined that the PMlo network outlined in the Network Plan meets the 

minimum requirements found in 40 CFR Part 58, Appendix D, Table D-4 for all MSAs. Also, 

all manual PMlo collocation requirements are met. 

The Network Plan notes that the Bessemer Hi-Volume PMlo sampler was shutdown on 

August 31,2009, and the site was razed. Following shutdown of this sampler, EPA did not 

receive a formal letter stating the reason why or justification for shutdown of this SLAMS 

sampler. 40 CFR Part 58.14(c) addresses the process that must be followed when a SLAMS 

monitor is shutdown. This process involves EPA approval of the shutdown of a SLAMS 

sampler. The sampler must have shown attainment of the PMlo NAAQS during the previous 

five years and have a probability of less than 10 percent of exceeding 80 percent of the 

applicable NAAQS during the next three years, as stated in Part 58.14(~)(1). The Bessemer 

PMlo sampler met these criteria prior to shutdown. EPA Region 4 is aware that: 

the Jefferson County Department of Health (JCDH) operated the Bessemer site under 

a lease agreement with the previous property owner. the property where the sampler was located'was sold in August 2009 and the new 

owner gave JCDH only two weeks to remove the sampler. 

3. JCDH attempted to contact the new owner of the property regarding retention of the 

sampling location but the owner refused to talk with them. 

JCDH performed a technical evaluation of the requirement to establish a new location for 

a sampler in the vicinity of the Bessemer sampler in accordance with 40 CFR Part 58 and 

concluded that a new sampling site was not needed. EPA concurs with the decision not to 

establish a new PMlo sampling location. 

The Network Plan notes that JCDH is in the process of determining a new location for the 

Tarrant, ABC PMlo site (AQS ID 01-073-6003), because the site has a new owner and is no 

longer located in ambient air. Additionally, the Network Plan notes that the new site will be operational prior to January 1,201 1. According to 40 CFR 8 58.14(~)(6), "a SLAMS monitor not 

eligible for removal under any of the criteria in paragraphs (c)(l) through (c)(5) of this section 

may be moved to a nearby location with the same scale of representation if logistical problems 

beyond the State's control make it impossible to continue operation at its current site." 

Therefore, once the State formally submits a proposed location for the site, EPA may approve 

the new site under the requirements of 40 CFR 3 58.14(~)(6), on the condition that all 

requirements of 40 CFR Part 58, Appendix E are met. 
MSAs. Also, all PM2.5 collocation requirements are met. 

PM 23 Continuous Monitoring Requirements 40 CFR Part 58, Appendix D, 4.7.2 

Regulatory requirements for continuous PM2.5 monitoring require that ". . .State, or where 

appropriate, local agencies must operate continuous PM2.5 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 FRMI 

Federal Equivalent Method (EM)/ Approved Regional Method (ARM)] monitors, unless at 

least one of the required FRMF'EMJARM monitors is itself a continuous FEM or ARM monitor 

in which case no collocation requirement applies." Region 4 has determined that the PM2.5 

continuous monitoring network outlined in the Network Plan meets the minimum requirements 

found in 40 CFR Part 58, Appendix D, 4.7.2. Also, the continuous PM2.5 collocation 

requirements are met in all MSAs. 

PMzS Background and Transport Sites 0 40 CFR Part 58, Appendix D, 4.7.3 

40 CFR Part 58, Appendix D, 4.7.3 requires that "Each State shall install and operate at 

least one PM2.5 site to monitor for regional background and at least one PM2s.site to monitor for 

regional transport." The 2010 Network Plan identifies the Sumter site (AQS # 01-1 19-0002) in 

Sumter County as a rural regional background site and the Ashland site (AQS # 01-027-0001) in 

Clay County as a regional transport site. Therefore, ADEM has satisfied the requirements of 40 

CFR Part 58 for regional background and transport sites. 

Pb Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.5 

ADEM's 2010 Network Plan identifies the Troy-Borland site (AQS # 01-109-0003) as 

the only source-oriented monitor. This monitor is located near Sanders Lead Company in Troy, 

Based upon our review, the Pb monitoring requirements in 40 CFR Part 58, Appendix D, 4.5 are 

met. 

Air Quality Index (AQI) Reporting 

AQI reporting is required in MSAs with populations over 350,000. There are 4 MSAs in 

the State of Alabama required to report an AQI: Birmingham, Huntsville, Mobile and 

e Montgomery. The State's Network Plan on page 8 contains links to the ADEM, JCDH and 
of Alabama. EPA

s Office of Air Quality Planning and Standards approved the site in a letter 

dated October 30,2009.