Ms. Paula Cobb Director UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960

Division ofAir Resources Management Florida Department ofEnvironmental Protection 2600 Blair Stone Road Tallahassee, Florida 32399-2400 Dear Ms
. Cobb: Thank you for submitting the state ofFlorida's 2014 annual ambient air monitoring network plan (Network Plan) dated May 2014. The Network Plan is required by 40 Code ofFederal Regulations (CFR) § 58
. 10. The Network Plan covers the ambient air monitoring network operated by the Florida Department ofEnvironmental Protection (FDEP) and the local air quality agencies in Florida
. The U
.S
. Environmental Protection Agency understands that FDEP provided the public a 30-day review period and received no comments. According to 40 CFR § 58.10(a)(2), since public inspection and comments have already been solicited, the EPA is not required to offer another comment period. The EPA approves the state's 2014 Network Plan with the exception ofthree proposed monitoring sites. The state will need to provide additional information on two proposed near-road monitoring sites, and one proposed source-oriented SOz site as described in the enclosure. Once the EPA Region 4 is in agreement with the proposed locations for these sites, the state will need to make that information available for public inspection
. Upon completion ofthe public inspection process, an addendum to the Network Plan must be submitted to the EPA Region 4 for approval. We have enclosed our analysis ofyour Network Plan and details ofourreview
. Thank you for working with us to monitor air pollution and promote clean air in Florida. Ifyou have any questions orconcerns, please contact Gregg Worley at (404) 562-9141 or Daniel Garver at (404) 562-9839
.

Enclosures (2)
cc: Mr
. Jeffery Halsey Sincerely, 

# JM**anist ~**  Director (} ' Air, Pesticides and Toxics Management Division

Director, Air Quality Division, Broward County

Internet Address (UAL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable od Based Inks on Recyded Paper (Minimum 30% Postconsumer)Mr
. H. Patrick Wong Chief, Miami-Dade County Air Quality Management Division John Shellhorn Chief, Environmental Quality Division, City ofJacksonville Mr
. Jerry Campbell, PE Director, Hillsborough County Environmental Protection Commission, Air Management Division Mr
. Peter A
. Hessling Director, Pinellas County Air Quality Division Mr
. James E
. Stormer Administrator, Palm Beach County Division ofEnvironmental Health and Engineering Services, Air Pollution Control Section Mr. David Jones Acting Director, Orange County Environmental Protection Division Air Pollution Control Program Mr
. Ray Smith Director, Collier County Pollution Control & Prevention Department Mr
. Greg Blanchard Air Quality Manager, Manatee County Environmental Management Department Mr
. John Hickey, P.E
. Manager, Sarasota County Air & Water Quality

### 2014 State ofFlorida Ambient Air Monitoring NetworkPlan U.S. EPA Region 4 Comments and Recommendations
This document contains the U.S. EPA Region 4 comments and recommendations on the state of Florida's 

### 2014 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 otherrequirements, are found 

### in

### 40 CFRPart 58. Minimum monitoring requirements for criteria pollutants are listed in 

### 40 CFR Part 58, Appendix D. Minimum monitoring requirements are listed for ozone (OJ), particulate matter less than 2.5 microns (PM2.s), particulate matter less than 10 microns (PM10), 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 ofManagement and Budget (OMB), July 1, 2013, population estimates from the U.S
. Census Bureau, andhistorical ambient air monitoring data Minimum monitoring requirements for OJ, PM2.s, PM1o, only apply to metropolitan statistical areas (MSAs), which are a subset ofCBSAs. OMB currently defmes 

### 29 CBSAs in the state ofFlorida. These CBSAs and the respective July 

### 1, 2013, population estimates from the U.S. Census Bureau are shown in Table 

### l. Table 1: Core Based Statistical Areas and July 1, 2013 Population Estimates CBSA Name CBSA Type Population Miami-Fort Lauderdale-West Palm Beach, Fl.. Metropolitan Statistical Area 5,564,635 Tampa-St. Petersburg-Clearwater, Fl.. Metropolitan Statistical Area 2,783,243 Orlando-Kissimmee-Sanford, Fl.. Metropolitan Statistical Area 2,134,411 Jacksonville, Fl.. Metropolitan Statistical Area 1,345,596 North Port-Sarasota-Bradenton, Fl.. Metropolitan Statistical Area 702,281 Cape Coral-Fort Myers, Fl.. Metropolitan Statistical Area 618,754 Lakeland-Winter Haven, FL Metropolitan Statistical Area 602,095 Deltona-Daytona Beach-Ormond Beach, FL Metropolitan Statistical Area 590,289 Palm Bay-Melbourne-Titusville, Fl.. Metropolitan Statistical Area 543,376 Pensacola-Ferry Pass-Brent, Fl.. Metropolitan Statistical Area 448,991 Port St. Lucie, Fl.. Metropolitan Statistical Area 424,107 Tallahassee, FL Metropolitan Statistical Area 367,413 Naples-Immokalee-Marco Island, Fl.. Metropolitan Statistical Area 321,520 Ocala, Fl.. Metropolitan Statistical Area 331,298 Gainesville, FL Metropolitan Statistical Area 264,275 Crestview-Fort Walton Beach-Destin, Fl.. Metropolitan Statistical Area 235,865 Panama City, Fl.. Metropolitan Statistical Area 184,715 Punta Gorda, Fl.. Metropolitan Statistical Area 159,978 Sebastian-Vero Beach, Fl.. Metropolitan Statistical Area 138,028 Homosassa Springs, Fl.. Metropolitan Statistical Area 141 ,236 The Villages, Fl.. Metropolitan Statistical Area 93,420 Sebring, Fl.. Metropolitan Statistical Area 98,786 Key West, FL Micropolitan Statistical Area 73,090 Palatka, FL Micropolitan Statistical Area 74,364 Lake City, Fl.. Micropolitan Statistical Area 67,531 Okeechobee, Fl.. Micropolitan Statistical Area 39,996 Clewiston, Fl.. Micropolitan Statistical Area 39,140Arcadia, FL Micropolitan Statistical Area 34,862 Wauchula, FL Micropolitan Statistical Area 27,731 OJ Monitoring Requirements 40 CFR Part 58, Appendix D, Table D-2 The state ofFlorida' s proposed 

### OJ monitoring network meets the minimum requirements found in 40 CFR Part 58, Appendix D
. Table D-2 for all MSAs. Additionally, the proposed 

### OJ monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58. 

### S02 MonitoringRequirements 40 CFR Part 58, Appendix D, 4.4 Ambient air monitoring network design criteria for 

### SOz are found 

### in Section 4.4 ofAppendix D to 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)
...., The S02monitoring site(s) required in each CBSA will satisfy minimum monit oring requirements ifthe monitor(s) is sited within the boundaries ofthe parent CBSA and is ofthe following site type(s): population exposure, maximum concentration, source-oriented, general background, or regional transport. An 

### SOzmonitor at an NCore station may satisfy minimum monitoring requirements ifthat monitor is located within a CBSA with required monitors under Appendix D, 4.4
. FDEP is proposing a new site in the Homosassa Springs CBSA to meet the PWEI requirement {AQS ID: 12-017-0006)
. However, the Network Plan does not include all ofthe required information about this site for approval. FDEP will need to submit an addendum to the Network Plan that contains a full proposal for this site. The addendum must include all ofthe required information for proposed sites under 40 CFR §58.1O(b). The addendum should also include supporting information about how the site location was selected, such as site photos, maps, wind roses, and information about the target source. The addendum should be made available for public inspection under40 CFR § 58.10(a)(1), and then submitted to the EPA Region 4 for approval. All other applicable CBSAs in Florida are now meeting the requirements for 

### SOz PWEI monitoring. 

### N02 Monitoring Requirements 40 CFR Part 58, Appendix D, 4.3 Ambient air monitoring network design criteria for 

### NOz are found in Section4.3 ofAppendix D to 40 CFR Part 58. Three types of

### NOz monitoring are required: near-road, area-wide, and Regional Administrator. These types of

### NOz monitoring are described 

### in sections 4.3.2, 4.3.3, and 4.3.4, respectively. Ambient air monitoring design criteria for near-road 

### NOz monitoring sites are found in section 4.3.2 ofAppendix D to 40 CFR Part 58. The requirements for near-road monitoring are currently met for the Tampa-St. Petersburg-Clearwater and Jacksonville CBSAs
. The Network Plan also includes near-road sites in the Miami-Fort Lauderdale-West Palm Beach 

### (in Broward County) and OrlandoKissimmee-Sanford CBSAs, which will meet the requirements for near-road monitoring in the respective CBSAs once the sties begin operation. Second near-road monitoring sites are required to begin operation on January 1, 2015 in the Miami-Fort Lauderdale-West Palm Beach and Tampa-St. Petersburg-Clearwater CBSAs. New sites in Miami-DadeCounty and Pinellas County are being established to meet these requirements, but the exact locations of these sites have not been finalized. Once the details ofthese sites are finalized, the state will need to submit an addendum to the Network Plan containing these site proposals
. The addendum must include all ofthe required information for proposed sites under40 CFR §58
. 10(b), and should also include additional information about the proposed near-road monitoring sites
. Section 13
.5 ofthe near-road N02 Technical Assistance Document (TAD) 1 and Table 13.1 ofthe TAD discuss important site and road parameters when evaluating a near-road site
. Using the TAD as a reference, additional information provided on near-road N02 monitoring should include, at minimum, the following information for each site:
• Proposed AQS ID • Street address and site geographical coordinates (longitude and latitude) • Target road segment description including type ofroad • Site pictures facing 4-8 directions- N, S , E, W, NE, NW, SE, SW • Probable distance between the inlet probe and the outside nearest edge ofthe target road • Probable probeheight ofthe inlet probe from ground level • Siteproperty description including property owner and feasibility ofsite access • Roadway design and configuration • Presence of any roadside structures • Nearest wind rose representative ofthe site and orientation ofthe site with respect to the predominate wind direction • Traffic data and ranking information (see Table 6-3 ofthe Technical Assistance Document), as well as the source and vintage ofthe data • Sampling and analysis method{s) for each measured parameter • Operating schedules for each monitor at the site • Monitoring objective and spatial scale ofrepresentativeness for each monitor at the site
. • MSA, CBSA, CSA or other area represented by the monitor • Discussion ofother siting criteria Once the EPA Region 4 is in agreement with the proposed near-road sites, the state will need to make the information available for public inspection. Upon completion ofthe public inspection process, the Network Plan addendum must be submitted to the EPA Region 4 for approval. We will continue to work with your agency as needed to facilitate the establishment ofthese sites as expeditiously as possible. Section 4.3.2 ofAppendix D to 40 CFR Part 58 also requires CBSAs with populations between 500,000 and 1,000,000 people to operate a near-road N02 monitor starting in January 1, 2017. Florida has five CBSAs with populations in this range: North Port-Sarasota-Bradenton, Cape Coral-Fort Myers, Lakeland

-Winter Haven, Deltona-Daytona Beach-Ormond Beach, and Palm Bay-Melbourne-Titusville. As a result ofthe 5

-year National Ambient Air Quality Standards ( NAAQS) review cycle, the N02 monitoring requirements maybe modified in 2016
. The N02 near-road monitoring requirements may change for CBSA's with a populations between 500,000 and 1,000,000 people, such as the FL CBSAs listed above
. Ambient air monitoring network design criteria for area-wide N02sites are found in section 4
.3
.3 ofAppendix D to 40 CFR Part 58. The area-wide N02 monitoring network described in the Network Plan meets the requirements ofSection 4.3.3 in all areas. These sites are summarized in Table 2
.
1 Near.road N02 Monitoring Technical Assistance Document. Office ofAir Quality Planning and Standards, U
.S
. Environmental Protection Agency, Research Triangle Park, North Carolina. EP A-454/B-12-002. June 2012
. http :1/www.epa. g

ov/ttnamti 1/files/nearroad/NearRoudTAD
.pdf. 3Table 2: Area-wide N02Monitoring Sites CBSA Name County Jacksonville Duval Miami-Fort Lauderdal e- Broward Miami Beach Orlando-Kissimmee- Orange Sanford Tampa-St. Petersburg- Pinellas Clearwater Site Name Kooker Park John ULloyd State Park Winter Park Azalea Park AQSID 12

-031-0032 12-011-8002 12

-095-2002 12- 1 03

- 0018
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 ofAppendix D to 40 CFR Part 58. Under these provisions Regional Administrators must require a minimum offorty additional N02 monitoring stations nationwide, with a primary focus on siting these monitors in locations to protect susceptible and vulnerable populations
. The EPA has previously identified the monitor at the Coral Reef site (AQS ID: 12-086-0031) in Miami-Dade County as required under Section 4
.3
.4 to protect susceptible and vulnerable populations
. The full list ofN02 monitors identified by the Regional Admin istrators can be found on the EPA's website at http://www.epa.gov/ttnamtil/svpop
.html. 

### CO Monitoring Requirements 40 CFR Part 58, Appendix D Section 4.2 Beginning January 1, 2015, CO monitoring will be required at a near-road monitoring site in CBSAs with populations greater than 2,500,000. CO monitoring will be required at a near-road monitoring site in CBSAs with populations greater than 1,000,000 beginning on January 1, 2017. The Network Plan indicates that CO monitoring is ongoing at the Hillsborough County near-road site in the Tampa-St. Petersburg-Clearwater CBSA. and will begin at the Broward County near-road site in the Miami-Fort Lauderdale-Miami Beach CBSA by January l, 2015. Therefore, the CO monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58. 

### PMto Monitoring Requirements 40 CFR Part 58, Appendix A, 3.3.1 40 CFR Part 58, Appendix D, Section 4.6 and Table D-4 The state ofFlorida's current PM1o monitoring network meets the minimum requirements found in 40 CFR Part 58, Appendix D, Table D-4 for all MSAs. Also, all PM10 collocation requirements for manual methods found in 40 CFR Part 58, Appendix A, Section 3.3.1 are currently being met. Fifteen percent of each network ofmanual PM10 methods (at least one site) must be collocated. These collocation requirements are assessed at the primary quality assurance organization (PQAO) level. The FDEP and all ofits local agencies operate under a single PQAO. The PM1o monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58. 

### PM2.s Monitoring Requirements 40 CFR Part58, Appendix A, 3.2.5 40 CFR Part58, Appendix D, Section 4.7 and TableD

-5 The state ofFlorida's current PM2.s monitoring network meets the minimum requirements found in 40 CFR Part 58, Appendix D, Table D-5 for all MSAs. Also, all PM2.s collocation requi rements found in 40 

### 4

### CFR Part 58, Appendix A, Section 3.2.5 are currently being met. Fifteen percent ofeach network of manual PM2.S methods (at least one site) must be collocated. Beginning January 1, 2015, 

### PM2
.s monitoring will be 

### required at a nearRroad monitoring site in CBSAs with populations greater than 2,500,000. PM2.s monitoring will be required at a nearRroad monitoring site in CBSAs with populations greater than 1,000,000 beginning on January 1, 2017
. The Network Plan indicates that PM2.s monitoring is ongoing at the Hillsborough County nearRroad site in the Tampa-St. PetersburgRClearwater CBSA, and will begin at the Broward County nearRroad site in the Miami-Fort LauderdaleRMiami Beach CBSAby January 1, 2015. The PM2.s monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58. PMz.s Continuous Monitoring Requirements 40 CFR Part58,Appendix D, 4.7.2 

### Regulatory requirements for continuous PM2.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 ofthis appendix. At least one required continuous analyzer in each MSA must be 

### collocated with one ofthe required FRMIFEM/ ARM [federal reference method/federal equivalent method/approved regional method] monitors, unless at least one ofthe required FRMIFEM/ ARM monitors is itselfa continuous FEM orARM monitor in which case no collocation requirement applies." These minimum continuous PM2.s monitoring requirements are currently met in the all ofthe MSAs in the state. Also, the continuous PM2.s collocation requirements are currently met in all MSAs. Therefore, the continuous PM2.s monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58. PMz.s 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.s site to monitor for regional background and at least one PM2.s site to monitor for regional transport." The Network Plan identifies the Interagency Monitoring for Protected Visual Environments (IMPROVE) PM2.s sites at the St. Mark's National Wildlife Refuge (AQS ID: 12Rl29-0001) and the Everglades National Park (AQS ID: 12R086-0030) as background sites and the IMPROVE PM2.s site at the Chassahowitzka National Wildlife Refuge (AQS ID: 12-017R9000) as a transport site. Therefore, FDEP has satisfied the requirements of40 CFR Part 58 for background and transport sites. PMz.s Continuous Federal Equivalent Methods 40 CFR § 

### 58.10(e) 

### As part ofthe recent revisions to the PM2.s 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). Ifan agency can demonstrate that the FEM data are not ofsufficient comparability to a collocated FRM, then the monitoring agency may request that the FEM data not be used in comparison to the NAAQS. In the Network Plan, FDEP has not requested that any ofits PM2.s FEMs be excluded from comparisons to the NAAQS
.

5

### PMl.s Chemical Speciation Network The EPA has been conducting an assessment ofthe PM2.5 Chemical Speciation Network (CSN) in an effort to optimize the network and cr eate a network that is sustainable going forward. As a result of this assessment, the EPA is defunding a number ofmonitoring sites, eliminating the CSN PM2.s mass measurement, reducing the frequency ofcarbon blanks, reducing sample frequency at some monitoring sites, and reducing the number oficepacks in shipment during the cooler months ofthe year. As FDEP discusses in the Network Plan, the EPA is planning to defund the Skyview site (AQS ID: 12-103- 0026). The state ofFlorida will be also be affected at all funded CSN sites by the elimination ofthe PM2.s mass measurement, the reduction ofcarbon blank frequency, and the reduction in icepacks. The CSN PM2.s mass measurement is recommended for elimination in October 2014 and all other changes are recommended to take place in January 2015
. Final changes to the CSN in the state ofFlorida should 

### be reflected in the 2015 Network Plan. 

### Pb Monitoring Requirements 40 CFR Part 58, Appendix D, 4.5 40 CFRPart 58,Appendix D, 4
.5 requires that "At a minimum, there must be one source-oriented SLAMS [state and local air monitoring station] 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 ormore tons per year. . ." Monitoring is ongoing as required near Envirofocus Technologies Inc. in Tampa, which is the only non-airport source 

### in the state that emits over 0.50 tons per year (tpy). 40 CFR Part 58,Appendix D, 3(b) requires that "NCore sites in CBSA with a population of500,000 people (as determined in the latest Census) orgreater shall also measure Pb either as Pb-TSP orPbPMto
." The Network Plan indicates that Pb-PMto sampling is ongoing at the Tampa NCore site (AQS ID: 12-057-3002) and will begin at the Broward County NCore site (AQS ID: 12-011

-0034) when the site begins operation later this year. The Pb monitoring networ k described 

### in the Network Plan meets all ofthe design criteria of40 CFR Part 58
. 

### Operating Schedules 40 CFR § 

### 58
. 12 The monitoring network proposed in the Network Plan meets the required operating schedules for all continuous analyzers and all manual Pb, PM10, PM2.s, and PMz.s Speciation Trends Network (STN) monitors. FDEPhas not proposed any changes to its operating schedules in the 2014 Network Plan. 

### Air Quality Index (AQI) Reporting 40 CFR § 

### 58.50 AQI reporting is required in MSAs with populations over 350,000. There are 12 MSAs in the state that are required to report an AQI: Miami

-Fort Lauderdale

-West Palm Beach, Tampa-St. PetersburgClearwater, Orlando-Kissimmee-Sanford, Jacksonville, North Port-Sarasota-Bradenton, Cape Coral-Fort Myers, Lakeland-Winter Haven, Palm Bay-Melbourne

-Titusville, Pensacola

-Ferry Pass-Brent, Port St. Lucie, and Tallahassee. The Networ k Plan includes a link on Page 7 to the FDEP website where this information is available. This satisfies the AQI reporting requirements.



### 6

### National Core (NCore) Monitoring Network FDEPhas designated three NCore sites: Sydney Road in Tampa (AQS 

### ID: 12-057-3002), Pine Island Road in Broward County (AQS 

### ID: 12-011-0034), and St. Mark's National Wildlife Refuge (AQS ID: 12-129-0001). These sites satisfy the requirements for NCore monitoring and have been approved by the EPA's Office ofAir Quality Planning and Standards. The St. Mark's NCore site was established in 2014 as a rural NCore site. A memo approving the St. Marks's site from the EPA's Office ofAirQuality Planning and Standards is enclosed. 

### Proposed Monitoring Network Changes In the Network Plan, FDEPhas proposed to relocate the monitors at the University ofFlorida Agricultural Research Center site in Broward County (AQS 

### ID: 12-099-0020) to the nearby NCore site when it begins operation. The EPA approves this relocation ofthe PM1o, PM2.s FRM, continuous PM2.s, PM2.s speciation, and air toxics measurements to the NCore site. FDEPhas also proposed new special purpose monitoring sites, which are summarized in Table 3. Table 3: Newly Propesed Special Purgose Monitors

CBSA Name County Site Name Parameters Tampa-St. Petersburg- Hillsborough Apollo Beach Clearwater Tampa-St. Petersburg- Hillsborough N/A Pb Clearwater Jacksonville Duval N/A Pb 

### Request for WaiverofSiting Criteria In a separate letter to the EPA Region 4 dated September 17, 2014, Orange County, Florida requested a temporary waiver of siting criteria for its new near-road site under 40 CFR Part 58, Appendix E, Section 10. Due to a long-term construction project along the Interstate 4 corridor in Orlando, the Florida Department ofTransportation (FOOT) has requested that the near-road monitoring shelterbe placed further from the road than originally planned. The 1-4 construction will begin in early 2015, and 

### will last for approximately six years. 40 CFR Part 58Appendix E Section 6.4(a) requires that near-road N02 monitoring probes "shall be 

### as near as practicable to the outside nearest edge ofthe traffic lanes ofthe target road segment; but shall not be located at a distance greater than 50 meters, in the horizontal, from the outside nearest edge ofthe traffic lanes ofthe target road segment." In order to comply with requests from FDOT, Orange County is proposing to install the site in a temporary location, approximately 60-70 meters from the nearest traffic lane, and is requesting a temporary waiver ofthe above siting criteria requirement. This site was originally approved by the EPARegion4 as part ofthe 2013 Network Plan, buthas not yetbeen installed. Under 40 CFR Part 58,Appendix E, Section 10, waivers ofsiting criteria for new sites can be granted only ifboth ofthe following criteria are met: 10.1.1 The site can be demonstrated to be as representative ofthe monitoring area as it would be ifthe siting criteria were being met. 

### 710.1.2 The monitor or probe cannot reasonably be located so as to meet the siting criteria because ofphysical constraints (e.g., inability to locate the required type ofsite the necessary distance from roadways orobstructions). While this distance from the roadway is not ideal, the EPA agrees that the temporary site will still be reasonably representative ofthe near -road environment. The EPA also agrees that due to the extensive nature ofthe construction project, which will affect almost all ofthe highest traffic count road segments in the CBSA, the probe cannot not reasonably be located within the required 50 meters ofthe nearest traffic lane at this time. Orange County has negotiated an agreement that upon the completion ofthe road construction, the FDOT construction contractor will be required to relocate the site to the originally approved location, which will be approximately 10-15 meters from the nearest traffic lane ofthe reconstructed roadway. Based on the above information, the EPA grants a temporary waiver ofthe distance to the roadway requirement for this site. Orange County has also request ed a t emporary change to the meteorological methodology used atthe site due to an overhead bridge at the temporary location, and the EPA approves this request as well. Upon completion ofthe 1-4 construction, these waivers will expire and the site must be relocated to meet the requirements of Section 6.4(a).



### 8

### 6UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 2n11 

# MAY 13 2010

Ms. Sandra F. Veazey, Chief Bureau ofAir Monitoring and Mobile Sources 2600 Blair Stone Road Tallahassee, FL 32399-2400 Dear Ms. Veazey: OFFICE OF AIR QUAUTY PLANNING AND STANDARDS



### This lettertransmits our approval ofthe Florida Department ofEnvironmental Protection's Division ofAir Resource Management proposed NCore station at the St. Marks National Wildlife Refuge site, AQS# 12-129

-0001 , as required by the Ambient AirMonitoring Regulations. According tothese rules (see 40 CFR 58.11(c)), NCore network design and changes must be approved by the Environmental Protection Agency's (EPA) Administrator
. This authority has been delegated to the Director ofthe Air Quality Assessment Division in EPA's Office ofAir Quality Planning and Standards
. In considering yourproposed NCore monitoring station, we worked with your Regional Office on a review ofyour annual monitoring networkplan and an assessment ofthe proposed location and characteristics ofthe area to be monitored
. After careful consideration ofyour proposal, we are pleased to approve this station as part ofthe NCore network. By EPA's rules (see 40 CFR 58.13), an approved NCore station is expected to be operating with all required measurements by January 1, 2011. Enclosure A provides an update on required measurements and Enclosure B provides EPA's Air 

### Quality System instructions on coding for NCore monitors and data. Please share this information wi th y our staffresponsible for the NCore station measurements and data submission
. Thank you for your program's efforts in developing the NCore station plan and establishing the site. For questions, you may contact Tim Hanley at hanlcy.tim@epa.gov and 919-541-4417, or David Shelow at**shelow.david~epagov** 

### and 919-541-3776
. Sincerely,

# ~~IJ_~L_t/ Richard A
.

# Wayl~ "" Director Air Quality Assessment Division

lntemet Address (URL) • http://www

.epa.gov Recycltdo'Recycllble •PMiedwlh Vegellblll Oil Based lnlca on RKYCied Paper**~lnmum** 25% Poalconsumer)2 Enclosures
cc: · 

### Dick Arbes

- Florida Department ofEnvironmental Protection Douglas Neeley- EPA Region 4

### Enclosure A Update on Measurements atNCore Stations The majority ofrequired measurements atNCore stations are either well established or recently improved methods for particles, gases, and meteorology. With minor exceptions, monitoring agencies have identified all ofthe PMu, gas, and meteorological measurements necessary for successful operation oftheirNCore station. However,**PM 11** **~u** mass methods have only recently become available and PM1o.:z.s speciation methods are not fully developed. This enclosure summarizes our current position on available methods for operation ofPM1o.:umass and deployment ofmethods for PM 1o- 25 speciation. 

### Measurement ofPM1o-l5

### Mass Measurement ofPM1o.:z.smass is required and can now beaccomplished with one ofseveral recently approved Federal Reference Methods (FRM) orFederal Equivalent Methods (FEM) described in the table 1below. Monitoring agencies should include one ofthese methods in their next annual monitoring network plan and have the method operational byJanuary I, 2011. An annual monitoring network plan submitted to a Regional Office next summer does not needto seek EPA Administrator approval ofa newly identified PM1o-25mass FRM or FEM, so long as the NCore station has already been approved. Manufacturer Model Method BGI.Inc. PQ200 Sampler Pair Manual Reference Method: RFPS-1208-173 Thenno-Fisher, lnc. Model 2000 PM 111-l.S Sampler Pair Manual Reference Method: RFPS-0509-175 Thenno-Fisber, Inc: Model 2025 PM 1 o-1.s Sequential Air Sampler Pair Manual Reference Method: RFPS-0509-177 Thermo-Fisher, Inc. 2000-D Dichotomous Air Sampler Manual Equivalent Method: EQPS-0509-178 Thenno-Fisber, Inc. 2025-D Dichotomous Air Sampler Manual Equivalent Method: EQPS-0509-180 Met One, Inc. BAM-1020 PM,o.:uMeasurement SysteJ!lu Automated Equivalent Method: EQPM-0709-185


### Measurement ofPM1

### o.u Speciation Per the advice ofthe Clean Air Scientific Advisory Committee's (CASAC), Ambient Air Monitoring & Methods Subcommittee (AAMMSi, PM 1o.2_, speciation is not to be implemented atNCore at this time. Our office is working with two monitoring agencies to evaluate options for PM 1 o.uspeciation methods during a pilot study over the coming year. Also, consistent with the CASAC AAMMS advice, we will be considering whatthe optimum network design should be once a specified PM 1 o.u speciation method is available for routine use. A letter and detailed comments from the subcommittee rpembers is available on the web at: http://yosemite.epa.gov/sab/sabpeople.nsfiWCbCommittees!CASAC. See: Advisory Reports for fiscal year2009.

1 Table ofPM,G-:umass methods is current as of0ctober2009. For a list ofthe latest available designated reference and equivalent methods, see the AMTIC web site at: http://www.epa.gov/ttn/amtic/criteria.html. 2 2/11/09 Consultation on Ambient Air Monitoring Issues Related to the Coarse Particle Speciation by the Clean Air Scientific Advisory Committee CCASACl Ambient Air Monitoring & Methods Subcomminee (AAMMS}.

### Enclosure B Applicability ofAQS Metadata for NCore
This enclosure provides information on the applicability ofimportant metadata when setting up NCore sites, monitor records, and submitting data associated with NCore
. This enclosure focuses on key metadata that may be most useful to data users. AQS requirements for metadata are more exhaustive than the fields listed in this enclosure and any required fields will still need to be populated, even ifnot specified below
. Fornon-required fields, monitoring agencies are encouraged to supply other metadata that may also be useful to data users. Please incorporate this information into data reporting for your approved NCore Station(s). SiteLevel: The structure ofthe AQS data base requires that a "site" be set up prior to setting up monitor records. A site record in AQS defines information about the location of a monitoring station such as the street address; latitude and longitude; and the AQS State, County, and site ID. Except for a few completely new stations, most monitoring agencies have successfully set up the appropriate site information in AQS. Ofthe available fields to populate in a Site Record, we are asking for your attention in assuring that the following fields are appropriately populated. Local Site Nqme

- Although not required, we are asking you to populate this field with a descriptive name for your NCore station. This should be consistent with the site name identified in your NCore plan and may be associated with the site name identified on your own web site oronAIRNow. This should be populated with a name that is different than your 9-digit StateCountySite AQS ID
. This wiU help incommunicating your NCore Station with data users not familiar with AQS coding structure. Ifyour agency already uses a code inthis field for youc own purposes, it is not necessary to provide a more descriptive entry. A couple ofexamples ofdescriptive names provided in NCor e plans are "Jefferson Elementary" for a site in Iowa and "AUen Park" for a site in Michigan
. Latitude andLongitude

- Ensure the correct "Horizontal Datum" is populated with the coordinates. Monitoring agencies are encouraged to validate these coordinates with commercially available GPS units and/or by reviewing publically available satellite imagery such as on GoogleTM Earth. Primarv Monitor Periods

- For PMuas a NAAQS criteria pollutant (parameter code 88101), the monitoring agency must identify which POC is the primary monitor in the "Primary Monitor Periods" screen. This is required to be populated even ifthere is only one registered POC for parametercode 88101. At this time, no other pollutants use this screen. Monitor Level: Monitorrecords are set up for each measured pollutant ormeteorological parameter being reported to AQS. Therefore, there is a many to one relationship between monitor records and a monitoring station. Please update the following fields, as necessary, for each pollutant measurement reporting to AQS from youc NCore Station. Monitor Z):pe

- Each monitor operating at an NCore Station will typically have at least two monitortypes associated with it EPA-OAQPS will be responsible for adding ''NCore" as a monitor type for NCore measurements being reported at each approved NCore Station. Note: we will also remove "Proposed NCore," where applicable. ForNCore measurements that come on-line and begin reporting after the initial round ofNCore monitor typeassociations, EPA-OAQPS will periodically review NCore Station data in AQS and add a monitor type ofNCore for any remaining required NCore measurements being reported, butnot already associated with a monitor type ofNCore. Each monitoring agency is responsible for populating a monitor type thatprovides the "Administrative Classification" ofthe monitor. ForNCore Stations, this will largely be a monitor type ofSLAMS since the majority ofNCore Stations are operated by state and local agencies. A smaUer number ofNCore Stations are operated orcoordinated with monitoring partners such as a Tribal Monitoring Program, the National Park Service, or EPA's CASlNETProgram
. In these cases, a monitor type of"TribalMonitors," ''Non-EPA Federal," or "CASlNET'' can be used. Measurement Scale

- We are requesting that you populate this field for each monitor reporting data to AQS. For Urban and Suburban NCore Stations, this will most likely be either Neighborhood Scale orUrban Scale. For Rural NCore Stations, we are expecting the use ofRegional Scale. Monitoring Objective- All Urban and Suburban monitors reponing to AQS should use "Population Exposure" as the monitoring objective
. Rural NCore stations should use the most appropriate choice between "Upwind Background," "General Background," "Regional Transport," or "Extreme Downwind
." Other Monitoring objectives may apply, but are not expected. AreaRepresented- For Urban and Suburban Stations, populate this field with the appropriate code for eitherthe CBSA orCSA, ifapplicable. ForRural Stations, this field should not be populated. Sample Frequency- A sample frequency is required to be associated with each ofthe PM measurements. Forfilter-based measurements this is typically on a schedule of"every 3nl day." However, some agencies may be operating their PM samplers on a daily schedule. Sample frequency does not need to be loaded for continuous measurements. Data Level: A few notes are provided below associated with submitting data records to AQS. Please incorporate these notes into your datareporting to AQS. PMu,Continuous Measurements- A technical note onthe use ofparameter codes for PMucontinuous methods was issued on June 1, 2006. This technical note is available onthe EPA'sAMTIC web site at:**http ~//** **www.epa.gov ttn/amtic/daramang.html.**  OnJuly 24, 2008, a memo was issued on "Implementing Continuous PMuFederal EquivalentMethod (FEMs) and Approved Regional Methods (ARMs) in State orLocal Air Monitoring Stations (SLAMS) Networks." This memo is available onthe same web site listed above. While monitoring agencies can operate eitherFEM's, ARM's (ifone is approved), or well performing non-FEMIARM PMucontinuous monitors, agencies should report their data to either 88101, ifit is an approved FEM orARM, orto 88502, assuming it is a well performing PM2...S continuous method that is not approved as a FEM orARM. EachNCore Station should have either an FEM/ ARM or well performing PMucontinuous method reporting to AQS sothatthese data can provide the high temporal resolution expected atNCore Stations for use inAQI repons and other assessments. Method Code- Each data record includes a 3-digit method code that associates detail onthe sampling and analysis method with a piece ofdata. Ofparticular note for NCore trace gas measurements ofCO, SO:t. and NOINOy, monitoring agencies should be utilizing the appropriate method code associated withthe trace gas measurements that provides a substantially improved detection limit DefaultMethod Detection Limits (MDL's) are provided for each couunonly used trace gas method in the AQS data base. Monitoring agencies can also submittheir own MDL, where applicable. Many, but not all, ofthe method codes associated with trace gas instruments have a method code in the range between 500 and 600.r

- -- AQS Metadata Location Are Multiple Does AQS Require of Expected Option(s) for NCore Notes Field Metadata Options Allowed? tbis Field? Local Site Name Site Level No No We are requesting you identify your site name in Please use a descriptive name AQS 8 digits, including 6 past the decimal place with Latitude Site Level No Yes a positive sign indicating above the equator Ensure the correct "Horizontal (+xx.xxxxxx) Datum" is populated with the Longitude Site Level No Yes 9 digits, including 6 past the decimal place with coordinates a sign (+xxx.xxxxxx) Primary Monitor Site Level No Yes, but only for Always populate for PM2.S(parameter code 88101) Periods 88101 EPA-OAQPS will update or add NCore "NCore" as a monitor type for each Monitor approvedNCore Station Monitor Type Level Yes Yes SLAMS, Tribal Monitors, Non-EPA Federal, or Monitors at each station should also identify one ofthe Monitor CASTNET Types on the left Other Monitor types such as I.MPROVE, PAMS, orTrends Speciationmay also apply No- however, we are Neighborhood Scale 500M to 4KM Expect one ofthese for monitors at Measurement Scale Monitor No requesting you Urban Scale 4 KM to 50 KM Urban or Suburban Stations Level populate this field Regional Scale 50 to hundreds KM Expected for monitors at Rural Stations Population Exposure For monitors at all Urban and Suburban NCore Stations Monitoring Monitor Yes Yes Upwind Background, General Background, Expect one ofthese for monitors at Objective Level Regional Transport, orExtreme Downwind Rural NCore Stations Other Monitoring Objectives may apply for either Urban orRural NCore Stations; however, one ofthe above should be utilized at a minimum Only one type of No- however, we are CBSA Represented Urban Stations should use one of Area Represented Monitor area (CBSA or requesting you the following Level CSA) can be listed CSA Represented perobjective populate this field Rural Stations should not populate this field I Monitor Required only Relevant sample frequencies include: PM monitoring is required at a 

### I Sample Frequency Level No for PM 1Every Day minimum frequency ofone in i 3 Every 3td day every 3td day