Ms. Paula Cobb 

Director 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION4 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303-8960 

Division of Air Resources Management 

Florida Department of Environmental Protection 

2600 Blair Stone Road 

Tallahassee, Florida 32399-2400 

Dear Ms. Cobb: 

Thank you for submitting the state of Florida's 2014 annual ambient air monitoring network plan 

(Network Plan) dated May 2014. The Network Plan is required by 40 Code of Federal Regulations 

(CFR) § 58.10. The Network Plan covers the ambient air monitoring network operated by the Florida 

Department of Environmental 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 of three 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 of the public inspection process, an addendum to the 

Network Plan must be submitted to the EPA Region 4 for approval. 

We have enclosed our analysis of your Network Plan and details of our review. Thank you for working 

with us to monitor air pollution and promote clean air in Florida. If you have any questions or concerns, 

please contact Gregg Worley at (404) 562-9141 or Daniel Garver at (404) 562-9839. 

Enclosures (2) 

cc: Mr. Jeffery Halsey 

Sincerely, JM 

Director 

anist~ (} ' 

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 of Jacksonville 

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 of Environmental 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 of Florida Ambient Air Monitoring Network Plan 

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 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 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 of Management and Budget (OMB), July 1, 2013, population estimates from 

the U.S. Census Bureau, and historical ambient air monitoring data Minimum monitoring requirements 

for OJ, PM2.s, PM1o, only apply to metropolitan statistical areas (MSAs), which are a subset of CBSAs. 

OMB currently defmes 29 CBSAs in the state of Florida. 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 39,140 
Arcadia, 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 of Florida'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 of the design criteria of 40 CFR Part 58. 

S02 Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.4 

Ambient air monitoring network design criteria for SOz are found in Section 4.4 of Appendix 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 S02 monitoring site(s) required 

in each CBSA will satisfy minimum monitoring requirements if the monitor(s) is sited within the 

boundaries of the parent CBSA and is of the following site type(s): population exposure, maximum 

concentration, source-oriented, general background, or regional transport. An SOz monitor at an NCore 

station may satisfy minimum monitoring requirements if that 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 of the 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 of the required information for proposed sites 

under 40 CFR §58.1 O(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 under 40 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 Section 4.3 of Appendix 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 of Appendix D to 40 CFR Part 58. The requirements for near-road monitoring are currently 

met for the Tampa-St. Petersburg-Clearwater and Jacksonville CBS As. 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-Dade 
County and Pinellas County are being established to meet these requirements, but the exact locations of 

these sites have not been finalized. Once the details of these sites are finalized, the state will need to 

submit an addendum to the Network Plan containing these site proposals. The addendum must include 

all of the required information for proposed sites under 40 CFR §58.10(b ), and should also include 

additional information about the proposed near-road monitoring sites. Section 13.5 of the near-road N02 

Technical Assistance Document (TAD)1 and Table 13.1 of the 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 of road 

• 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 of the target road 

• Probable probe height of the inlet probe from ground level 

• Site property description including property owner and feasibility of site access 

• Roadway design and configuration 

• Presence of any roadside structures 

• Nearest wind rose representative of the site and orientation of the site with respect to the 

predominate wind direction 

• Traffic data and ranking information (see Table 6-3 of the Technical Assistance Document), as 

well as the source and vintage of the data 

• Sampling and analysis method{s) for each measured parameter 

• Operating schedules for each monitor at the site 

• Monitoring objective and spatial scale of representativeness for each monitor at the site. 

• MSA, CBSA, CSA or other area represented by the monitor 

• Discussion of other 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 of the 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 of these sites as expeditiously as possible. 

Section 4.3.2 of Appendix 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 of the 5-year National Ambient Air Quality Standards ( NAAQS) review cycle, the N02 

monitoring requirements may be 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 N02 sites are found in 

section 4.3.3 of Appendix D to 40 CFR Part 58. The area-wide N02 monitoring network described in the 

Network Plan meets the requirements of Section 4.3.3 in all areas. These sites are summarized in 

Table 2. 

1 Near.road N02 Monitoring Technical Assistance Document. Office of Air 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. gov/ttnamt i 1/fi les/nearroad/N earRoudTAD.pdf. 

3 
Table 2: Area-wide N02 Monitoring Sites 

CBSA Name County 

Jacksonville Duval 

Miami-Fort Lauderdale- Broward 

Miami Beach 

Orlando-Kissimmee- Orange 

Sanford 

Tampa-St. Petersburg- Pinellas 

Clearwater 

Site Name 

Kooker Park 

John U Lloyd State Park 

Winter Park 

Azalea Park 

AQSID 

12-031-0032 

12-011-8002 

12-095-2002 

12- 103-0018 

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 of Appendix D to 40 CFR Part 58. 

Under these provisions Regional Administrators must require a minimum of forty 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 of N02 monitors identified by the Regional 

Administrators 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 of the design criteria of 40 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 of Florida'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 of manual 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 of its local agencies operate under a single PQAO. The PM1o monitoring network described in the 

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

PM2.s Monitoring Requirements 

40 CFR Part 58, Appendix A, 3.2.5 

40 CFR Part 58, Appendix D, Section 4. 7 and Table D-5 

The state of Florida'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 requirements found in 40 

4 
CFR Part 58, Appendix A, Section 3.2.5 are currently being met. Fifteen percent of each 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 CBSA by 

January 1, 2015. The PM2.s monitoring network described in the Network Plan meets all of the design 

criteria of 40 CFR Part 58. 

PMz.s Continuous Monitoring Requirements 

40 CFR Part 58, 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 of this appendix. At least one required continuous analyzer 

in each MSA must be collocated with one of the required FRMIFEM/ ARM [federal reference 

method/federal equivalent method/approved regional method] monitors, unless at least one of the 

required FRMIFEM/ ARM monitors is itself a continuous FEM or ARM monitor in which case no 

collocation requirement applies." These minimum continuous PM2.s monitoring requirements are 

currently met in the all of the 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 of the design criteria of 40 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 of 40 CFR Part 58 for background and transport sites. 

PMz.s Continuous Federal Equivalent Methods 

40 CFR § 58.10(e) 

As part of the 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). If an agency 

can demonstrate that the FEM data are not of sufficient 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 of its PM2.s FEMs be excluded from comparisons to the 

NAAQS. 

5 
PMl.s Chemical Speciation Network 

The EPA has been conducting an assessment of the PM2.5 Chemical Speciation Network (CSN) in an 

effort to optimize the network and create a network that is sustainable going forward. As a result of this 

assessment, the EPA is defunding a number of monitoring sites, eliminating the CSN PM2.s mass 

measurement, reducing the frequency of carbon blanks, reducing sample frequency at some monitoring 

sites, and reducing the number of icepacks in shipment during the cooler months of the year. As FDEP 

discusses in the Network Plan, the EPA is planning to defund the Skyview site (AQS ID: 12-103-

0026). The state of Florida will be also be affected at all funded CSN sites by the elimination of the 

PM2.s mass measurement, the reduction of carbon 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 of Florida should 

be reflected in the 2015 Network Plan. 

Pb Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.5 

40 CFR Part 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 or more 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 of 500,000 

people (as determined in the latest Census) or greater shall also measure Pb either as Pb-TSP or PbPMto." 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 network described in the Network Plan meets all 

of the design criteria of 40 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. FDEP has 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 Network 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 

FDEP has 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 of Air 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 of Air Quality 

Planning and Standards is enclosed. 

Proposed Monitoring Network Changes 

In the Network Plan, FDEP has proposed to relocate the monitors at the University of Florida 

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 of the PM1o, PM2.s FRM, continuous PM2.s, 

PM2.s speciation, and air toxics measurements to the NCore site. 

FDEP has 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 Waiver of Siting 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 of Transportation (FOOT) has requested that the near-road monitoring shelter be 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 58 Appendix E Section 6.4(a) requires that near-road N02 monitoring probes "shall be as 

near as practicable to the outside nearest edge of the traffic lanes of the target road segment; but shall not 

be located at a distance greater than 50 meters, in the horizontal, from the outside nearest edge of the 

traffic lanes of the 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 of the above siting criteria requirement. This site was 

originally approved by the EPA Region 4 as part of the 2013 Network Plan, but has not yet been 

installed. 

Under 40 CFR Part 58, Appendix E, Section 10, waivers of siting criteria for new sites can be granted 

only if both of the following criteria are met: 

10.1.1 The site can be demonstrated to be as representative of the monitoring area as it 

would be if the siting criteria were being met. 

7 
10.1.2 The monitor or probe cannot reasonably be located so as to meet the siting 

criteria because of physical constraints (e.g., inability to locate the required type of site 

the necessary distance from roadways or obstructions). 

While this distance from the roadway is not ideal, the EPA agrees that the temporary site will still be 

reasonably representative of the near-road environment. The EPA also agrees that due to the extensive 

nature of the construction project, which will affect almost all of the highest traffic count road segments 

in the CBSA, the probe cannot not reasonably be located within the required 50 meters of the nearest 

traffic lane at this time. 

Orange County has negotiated an agreement that upon the completion of the 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 of the reconstructed roadway. 

Based on the above information, the EPA grants a temporary waiver of the distance to the roadway 

requirement for this site. Orange County has also requested a temporary change to the meteorological 

methodology used at the site due to an overhead bridge at the temporary location, and the EPA approves 

this request as well. Upon completion of the 1-4 construction, these waivers will expire and the site must 

be relocated to meet the requirements of Section 6.4(a). 

8 

6 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 2n11 

MAY 13 2010 

Ms. Sandra F. Veazey, Chief 

Bureau of Air Monitoring and Mobile Sources 

2600 Blair Stone Road 

Tallahassee, FL 32399-2400 

Dear Ms. Veazey: 

OFFICE OF 

AIR QUAUTY PLANNING 

AND STANDARDS 

This letter transmits our approval of the Florida Department of Environmental 

Protection's Division of Air Resource Management proposed NCore station at the St. Marks 

National Wildlife Refuge site, AQS# 12-129-0001, as required by the Ambient Air Monitoring 

Regulations. According to these 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 of the Air Quality Assessment Division in 

EPA's Office of Air Quality Planning and Standards. 

In considering your proposed NCore monitoring station, we worked with your Regional 

Office on a review of your annual monitoring network plan and an assessment of the proposed 

location and characteristics of the area to be monitored. After careful consideration of your 

proposal, we are pleased to approve this station as part of the 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 with your staff responsible 

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 • PMied wlh Vegellblll Oil Based lnlca on RKYCied Paper ~lnmum 25% Poalconsumer) 
2 Enclosures 

cc: · Dick Arbes - Florida Department of Environmental Protection 

Douglas Neeley- EPA Region 4 
Enclosure A 

Update on Measurements at NCore Stations 

The majority of required measurements at NCore stations are either well established or recently improved methods for particles, gases, and meteorology. With 

minor exceptions, monitoring agencies have identified all of the PMu, gas, and meteorological measurements necessary for successful operation of their NCore 

station. However, PM11~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 of methods for PM1o-25 speciation. 

Measurement of PM1o-l5 Mass 

Measurement of PM1o.:z.s mass is required and can now be accomplished with one of several recently approved Federal Reference Methods (FRM) or Federal 

Equivalent Methods (FEM) described in the table1 below. Monitoring agencies should include one of these methods in their next annual monitoring network 

plan and have the method operational by January I, 2011. An annual monitoring network plan submitted to a Regional Office next summer does not need to seek 

EPA Administrator approval of a newly identified PM1o-25 mass 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 PM111-l.S Sampler Pair Manual Reference Method: RFPS-0509-175 

Thenno-Fisber, Inc: Model 2025 PM1o-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 of PM1o.u Speciation 

Per the advice of the Clean Air Scientific Advisory Committee's (CASAC), Ambient Air Monitoring & Methods Subcommittee (AAMMSi, PM1o.2_, speciation 

is not to be implemented at NCore at this time. Our office is working with two monitoring agencies to evaluate options for PM1o.u speciation methods during a 

pilot study over the coming year. Also, consistent with the CASAC AAMMS advice, we will be considering what the optimum network design should be once a 

specified PM1o.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 year 2009. 

1 Table ofPM,G-:umass methods is current as of0ctober2009. For a list of the 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 of AQS Metadata for NCore 

This enclosure provides information on the applicability of important 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 if not specified below. For non-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). 

Site Level: 

The structure of the 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. Of the 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 or on AIRNow. This should be populated with a 

name that is different than your 9-digit StateCountySite AQS ID. This wiU help in communicating your NCore Station with data users not familiar with AQS coding 

structure. If your agency already uses a code in this field for youc own purposes, it is not necessary to provide a more descriptive entry. 

A couple of examples of descriptive names provided in NCore plans are "Jefferson Elementary" for a site in Iowa and "AUen Park" for a site in Michigan. 

Latitude and Longitude - 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 PMu as 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 parameter code 88101. At this time, 

no other pollutants use this screen. 

Monitor Level: 

Monitor records are set up for each measured pollutant or meteorological 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 monitor types 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. For NCore measurements that come on-line and begin reporting after the initial round ofNCore monitor type 
associations, EPA-OAQPS will periodically review NCore Station data in AQS and add a monitor type ofNCore for any remaining required NCore measurements 

being reported, but not already associated with a monitor type ofNCore. 

Each monitoring agency is responsible for populating a monitor type that provides the "Administrative Classification" of the monitor. For NCore Stations, this will 

largely be a monitor type of SLAMS since the majority ofNCore Stations are operated by state and local agencies. A smaUer number ofNCore Stations are 

operated or coordinated with monitoring partners such as a Tribal Monitoring Program, the National Park Service, or EPA's CASlNET Program. In these cases, a 

monitor type of"Tribal Monitors," ''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 or Urban Scale. For Rural NCore Stations, we are expecting the use of Regional 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. 

Area Represented- For Urban and Suburban Stations, populate this field with the appropriate code for either the CBSA or CSA, if applicable. For Rural Stations, 

this field should not be populated. 

Sample Frequency- A sample frequency is required to be associated with each ofthe PM measurements. For filter-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 data reporting to AQS. 

P Mu,Continuous Measurements- A technical note on the use of parameter codes for PMu continuous methods was issued on June 1, 2006. This technical note is 

available on the EPA's AMTIC web site at: http~//www.epa.gov ttn/amtic/daramang.html. On July 24, 2008, a memo was issued on "Implementing Continuous 

PMu Federal Equivalent Method (FEMs) and Approved Regional Methods (ARMs) in State or Local Air Monitoring Stations (SLAMS) Networks." This memo is 

available on the same web site listed above. 

While monitoring agencies can operate either FEM's, ARM's (if one is approved), or well performing non-FEMIARM PMucontinuous monitors, agencies should 

report their data to either 88101, if it is an approved FEM or ARM, or to 88502, assuming it is a well performing PM2...S continuous method that is not approved as a 

FEM or ARM. Each NCore Station should have either an FEM/ ARM or well performing PMu continuous method reporting to AQS so that these data can provide 

the high temporal resolution expected at NCore Stations for use in AQI repons and other assessments. 

Method Code- Each data record includes a 3-digit method code that associates detail on the sampling and analysis method with a piece of data. Of particular note 

for NCore trace gas measurements of CO, SO:t. and NOINOy, monitoring agencies should be utilizing the appropriate method code associated with the trace gas 

measurements that provides a substantially improved detection limit Default Method Detection Limits (MDL 's) are provided for each couunonly used trace gas 

method in the AQS data base. Monitoring agencies can also submit their own MDL, where applicable. Many, but not all, of the method codes associated with trace 

gas instruments have a method code in the range between 500 and 600. 
r 

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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 approved NCore Station 

Monitor Type Level Yes Yes 

SLAMS, Tribal Monitors, Non-EPA Federal, or 

Monitors at each station should 

also identify one of the Monitor CASTNET Types on the left 

Other Monitor types such as I.MPROVE, PAMS, or Trends Speciation may also apply 

No- however, we are Neighborhood Scale 500M to 4KM Expect one of these 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 of these for monitors at 

Objective Level Regional Transport, or Extreme Downwind Rural NCore Stations 

Other Monitoring Objectives may apply for either Urban or Rural NCore Stations; 

however, one of the 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 

per objective 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 1 Every Day minimum frequency of one in i 3 Every 3td day every 3td day