Department of Environmental Protection 

200 Fair Oaks Lane, 1' Floor 

Frankfort, Kentucky 40601 

Dear Mr. Lyons: 

Thank you for submitting the annual ambient air monitoring network plan (Network 

Plan) for the Commonwealth of Kentucky dated June 30,2010. The Network Plan covers 

Kentucky's ambient air monitoring network which is comprised of assets and resources managed 

by the Kentucky Division for Air Quality (KDAQ) and the Louisville Metro Air Pollution 

Control District. The Network Plan is required by 40 Code of Federal Regulations (CFR) 

358.10. 

The U.S. Environmental Protection Agency (EPA) understands that KDAQ provided a 

30-day public comment period. Comments received and KDAQ's responses are included with 

the Network Plan. 

P"11 -. Based upon our review of the Network Plan, EPA Region 4 has determined that the 

documents satisfy the applicable requirements of 40 CFR Part 58. The Network Plan is 

approved. Comments and recommendations are enclosed. 

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

in Kentucky and the nation. If you have any questions or concerns, please contact Doug Neeley 

at (404) 562-9097 or Keith Goff at (404) 562-9137. 

Sincerely, ,laa ~wendol~n Keyes Fleming 

't^ Regional Administrator 1 

Enclosure 

cc: Ms. Lauren Anderson, Director 

Louisville Metro Air Pollution Control District 

0 Ms. Stephanie B. McCarthy 

Kentucky Division for Air Quality 

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

Recycled/Recyclable 4 Printed with Vegetable Oil Based Inks on Recyded Paper (Minimum 30% Postconsumer) 
Commonwealth of Kentucky

s 2010 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 do not exist for carbon monoxide 

(CO) unless required by the establishment of a National Core (NCore) multipollutant monitoring 

station, and/or 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 1,20 13. 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 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 defines nine MSAs in the Commonwealth of Kentucky. These MSAs and the 

(1 respective July 1,2009, population estimates from the U.S. Census Bureau are shown in Table 1. 

Table 1: Metropolitan Statistical Areas and Populations 

MSA Name Population 

Cincinnati-Middletown, OH-KY-IN 2,17 1,896 

Louisville/Jefferson County, KY-IN 1,258,577 

Lexington-Fayette, KY 470,849 

Evansville. IN-KY 351.91 1 

Huntington-Ashland, WV-KY-OH 285,624 Clarksville, TN-KY 268,546 

Bowling Green, KY 120,595 Owensboro, KY 1 13,636 

Elizabethtown, KY 113,433 

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

The network described in the 2010 Network Plan meets the minimum O3 monitoring 

requirements specified by 40 CFR Part 58, Appendix D, Table D-2 for all MSAs. 
all PMlo collocation requirements for manual methods found in 40 CFR Part 58, Appendix A 

3.3.1 are currently being met. Fifteen percent of each network of manual PMlo methods (at least 

one site) must 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. 

Minimum PM25 Monitoring Requirements 

40 CFR Part 58, Appendix A 3.2.5 40 CFR Part 58, Appendix D, Table D-5 

The Commonwealth of Kentucky's current PM2.5 monitoring network meets the 

minimum requirements found in 40 CFR Part 58, Appendix D, Table D-5 for all MSAs. Also, 

all manual PM2.5 collocation requirements are currently being met. Therefore, the manual PM2.5 

monitoring network described in the 2010 Network Plan meets all of the design criteria of 40 

CFR Part 58. 

PMzJ Continuous Monitoring Requirements (3 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 Federal 

Reference Method (FRM)/Federal Equivalent Method (FEM)/Approved Regional Method 

(ARM) monitors, unless at least one of the required FRM/FEM/ARM monitors is itself a 

continuous FEM or ARM monitor in which case no collocation requirement applies." These 

minimum continuous PM2.5 monitoring requirements are currently met in all MSAs in the 

Commonwealth. Also, the continuous PM2.5 collocation requirements are currently met in all 

MSAs. Therefore, the continuous PM2.5 monitoring network described in the Network Plan 

meets all of the design criteria of 40 CFR Part 58. 

PMzs Background and Transport Sites 

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 PM2.5 site to monitor for 

regional transport." The Network Plan identifies the Grayson Lake PM2.5 site (Air Quality 

System (AQS) ID: 21-043-0500) as a background site and the Hopkinsville PM2.5 site (AQS ID: 

'0 21-047-0006) as a transport site. Therefore, KDAQ has satisfied the requirements of 40 CFR Part 58 for background and transport sites. 
Pb concentration in ambient air resulting from each Pb source which emits 1.0 or more tons per 

year (tho. 

On June 30,2009, KDAQ submitted its 2009 Network Plan along with a request that 

source-oriented Pb monitoring requirements be waived for four sources: American Electric 

Power (Louisa), NewPage Wickliffe Mill (Wickliffe), Tennessee Valley Authority (Paducah), 

and North American Stainless (Ghent). The request was based on data indicating that the 

sources will not contribute to a maximum Pb concentration in the ambient air in excess of 50 

percent of the NAAQS. On August 20,2009, EPA responded by granting the waivers. In 

addition, on September 18,2009, EPA granted a waiver to the Louisville Metro Air Pollution 

Control District of the source-oriented ambient air monitoring requirements for Louisville Gas 

and Electric's Mill Creek Station. All five of these waivers must be renewed every 5 years as 

part of the network assessment required under 40 CFR §58.10(d). 

In its August 20,2009, response to KDAQ, EPA also indicated that Pb monitoring is 

required for three sources: Calgon Carbon (Catlettsburg), Enersys (Richmond), and Superior 

Battery (Russell Springs). Subsequently, KDAQ installed and now operates a Pb monitor near (3 the Calgon Carbon facility at its Lockwood monitoring station (AQS ID: 21-019-0016). It also 

installed and now operates two Pb monitors near the Enersys facility, one of which is collocated 

at KDAQ's existing PM23 site at the Mayfield School (AQS ID: 21-151-0003). Near the 

Superior Battery facility at Salem Elementary School, KDAQ recently installed and began 

operating a Pb monitor (AQS ID is 21-207-0001 at 37.069444 "N, -84.989250 OW). 

Over the last year, EPA Region 4 conducted a review of all SLAMS Pb monitoring sites 

in the Region. Based on air modeling conducted by KDAQ, it appears that the sites near the 

Calgon Carbon and Enersys facilities may not be sited to measure the maximum Pb 

concentration in ambient air taking into account logistics and the potential for population 

exposure as required by 40 CFR Part 58, Appendix D, 4.5(a). Therefore, we are deferring the 

approval of these sites. As discussed with KDAQ air monitoring staff, EPA encourages KDAQ 

to site monitors in the modeled maximum concentration areas near the sources as soon as 

practical. We are willing to provide you assistance in siting the Pb monitors. Regarding the Pb 

monitoring site at Salem Elementary School, EPA Region 4 approves this site. 

Air Quality Index (AQI) Reporting 

40 CFR 858.50 

AQI reporting is required in MSAs with populations over 350,000 as of the last official 

U.S. census. There are three MSAs in the Commonwealth of Kentucky required to report an 0 AQI: Cincinnati-Middletown, Louisville/Jefferson County, and Lexington-Fayette. KDAQ 

meets the AQI reporting requirements. 
O3 monitors increased to two. KDAQ only operates one 03 monitor in the area. KDAQ and the 

Indiana Department of Environmental Management's (IDEM) Office of Air Quality (OAQ) 

established a memorandum of agreement (MOA) in May 2010 to collectively operate monitors 

in the MSA. As a result, the minimum monitoring requirements for the Evansville, IN-KY MSA 

are met for all criteria pollutants, including 03. A copy of the MOA is included in the KDAQ 

Network Plan. EPA Region 4 approves KDAQ's use of the MOA. 

On March 23,2010, KDAQ was notified by Northern Kentucky University that Hankins 

Hall and adjacent parking lot on its Covington Campus were scheduled to be demolished this 

summer. The Covington air monitoring station (AQS ID: 21-1 17-0007) was located in the 

parking lot and KDAQ was asked to vacate the site no later than June 11,2010. The Covington 

air monitoring station was shut down on June 1,2010. To avoid being deficient in the minimum 

monitoring requirements for the MSA, an MOA was established during May 2010 between 

KDAQ, the Hamilton County (Ohio) Department of Environmental Services, and IDEM OAQ to 

collectively operate the monitors needed to ensure that minimum monitoring requirements are 

met for all criteria pollutants. A copy of the MOA is included in the KDAQ Network Plan. 

The Covington monitoring site included an O3 monitor, a PM2.5 FRM, a continuous PM2.5 

monitor, and a PM2.5 speciation sampler. 40 CFR §58.14(c) allows the case-by-case approval of 

the discontinuation of monitor stations if the discontinuance does not compromise data collection 

needed for implementation of a NAAQS and if the requirements of 40 CFR Part 58, Appendix D 

continue to be met. Due to the redundancy of monitoring stations in the Cincinnati- Middleton, 

OH-KY-IN MSA, EPA Region 4 has determined that the monitors from the Covington site do currently not need to be relocated. Although the 03 monitor is measuring a violation the 

NAAQS, it is not the highest value monitor in the MSA and is not the design value monitor. 

EPA Region 4 approves KDAQ's use of the MOA to meet monitoring requirements. 

Also enclosed with the KDAQ Network Plan is an MOA established during 2007 

between KDAQ and the Tennessee Division of Air Pollution Control to ensure that monitoring 

requirements for PM2.5 and O3 are met in the Clarksville, TN-KY MSA. EPA Region 4 approves 

KDAQ's use of the MOA. 

National Core (NCore) Monitoring Network 

The NCore site at Cannons Lane (AQS ID: 21-11 1-0067) is operated by the Louisville 

Metro Air Pollution Control District. EPA's Office of Air Quality Planning and Standards 

approved the site on October 30,2009.