Air Division Alabama Department of Environmental Management 

1400 Coliseum Boulevard 

Montgomery, Alabama 36130 

Dear Mr. Gore: 

Thank you for submitting the state of Alabama's 2015 Ambient Air Monitoring Network Plan (Network 

Plan} dated July 22, 2015. The Network Plan is required by 40 Code of Federal Regulations (CFR} 

§58.10. 

The U.S. Environmental Protection Agency understands that the Alabama Department of Environmental 

Management (ADEM) provided the public a 30-day review period for reviewing the Network Plan and 

several comments were received and forwarded to the EPA. The EPA has reviewed the Network Plan, 

the public comments, and the ADEM's response to comments. 

With this letter, the EPA is approving ADEM's Network Plan with one exception. The EPA does not 

approve the request for a national ambient air quality standard (NAAQS) exclusion for data associated 

with the PM2.s federal equivalent method (FEM) monitor at the North Birmingham site (AQS ID 01-

079-0023). After analyzing the data from monitors in the area, the EPA considers the data from the 

North Birmingham monitor to be comparable to both the annual and 24-hour PM2.s NAAQS. The 

rationale for our position is included in "Proposed Monitoring Network Changes" section of the 

enclosure. 

In the enclosure, we have provided comments on the current Network Plan as well as considerations for 

your future monitoring network. Please let us know if you have any questions about these comments. 

Thank you for your work with us to monitor air pollution and promote healthy air quality in Alabama. If 

you have any questions or concerns, please contact Gregg Worley at (404} 562-9141 or Darren Palmer at 

(404) 562-9052. 

CfJ Beverly H. Banis!;(' 

Director 

Air, Pesticides and Taxies Management Division 

Internet Address (URL) • hHp://www.epa.gov 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
Enclosure 

cc: Jonathan Stanton, Director 

Jefferson County Department of Health 

Daniel E. Shea, Director 

Huntsville Department of Natural Resources 
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 I 0 microns (PM 10}, 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's (OMB) July I, 20I4, population estimates from 

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

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

CBS As containing an urban core of 50,000 or more population. OMB currently defines 13 MSAs in the 

state of Alabama. These MSAs and the respective July 1, 2014, population estimates from the U.S. 

Census Bureau are shown in Table I. 

Table 1: Metropolitan Statistical Arens and Populations 

MSAName Population 

Anniston-Oxford-J acksonvillc, AL 115,916 

Auburn·Opetika, AL 154,255 

Binningham· Hoover, AL 1,143,772 

Columbus, GA-AL 314,005 

Daphne-Fairhope-Foley, AL 200,111 

Decatur,AL 153,084 Dothan,AL 148,095 

Florence-Muscle Shoals, AL 147,639 

Gadsden, AL 103,531 

Huntsville, AL 441,086 Mobile, AL 415,123 

Montgomery, AL 373,141 

Tuscaloosa, AL 237,761 

Proposed Monitoring Network Changes 

In its response to the Network Plan submitted by ADEM in 2014, EPA approved several changes to 

ADEM's monitoring network that have since been implemented. These changes are summarized in 

Table 2 below. 
Table 2: EPA Approved Changes from 2014 Network Plan 

AQS Site ID Pollutant Monitor Action Taken T e 

0 1-073-1003 PMw SLAMS Discontinued Low Volume PMw 01-073-1005 PM10 SLAMS Discontinued Low Volume PM111 0 1-073·6002 PM10 SLAMS Discontinued Low Volume PMw 0 1-073-6004 PMw SLAMS Discontinued Low Volume PMw 0 1-073-2059 N02, CO, PM2.s SLAMS Established Near-road N02 

01-097.0016 PMIO SLAMS Discontinued PMw Site 

EPA approved the elimination of PM10 monitoring at the Fairfield and McAdory sites listed above (AQS 

IDs 01-073-1003 and 01-073-1005, respectively) because these sites measured the lowest PM10 concentrations in the Birmingham MSA and because after their shut down the Jefferson County Department of 

Health (JCDH) would still operate more than the required number of monitors for the MSA. 

The Tarrant and Shuttlesworth sites (AQS ID 01-073-6002 and 01-073-6004) maintain regulatory PM10 

continuous monitoring. The Shuttlesworth site is the PM10 maximum concentration site for the area. The 

EPA requests that the Jefferson County Department of Health (JCDH) change the monitoring objective 

to reflect this by December 31, 2015. Finally, the EPA requires that the JCDH begin reporting the PM10 

continuous data to EPA's AirNow network effective January 1, 2016. We request that the JCDH let the 

EPA know if it will be unable to meet this deadline. 

The JCDH discontinued the PM2.s special purpose monitor at the Shuttlesworth site (AQS ID 01-073-

6004) at the end of August 2014. Forty CFR §58.20 gives agencies the flexibility to conduct short term 

monitoring, like the monitoring JCDH conducted at Shuttlesworth, without the data being used for 

regulatory decision making. The EPA understands that, while not required, the JCDH is considering 

conducting special purpose PM2 s monitori ng using a continuous, tapered element oscillating 

microbalance (TEOM) PM2..s monitor at Shuttlesworth and reporting the data to AirNow. 

It was noted in the 2014 Network Plan that Pelham High School representatives in Shelby County, 

Alabama requested that the monitor on their property (AQS ID 01-117-0006) be moved to an alternate 

location on the same property. At the time of our response last year, it was EPA's understanding that 

ADEM was working on an agreement with the school to establish power at the alternate location and 

move the monitor before the end of calendar year 2014. In this year's plan, ADEM stated that a suitable 

location was not found and that the monitor was shut down in June 2015 since it measured the lowest 

concentrations in the area. This shut down of a SLAMS monitor was not approved by the EPA as 

required in 40 CFR §58. J 4. Because this monitor has had the lowest design values of all the PM2.s 

monitors in the Birmingham MSA since the 2011-2013 period and that the minimum monitoring 

requirements for the MSA continue to be met, EPA is retroactively approving its shut down. However, 

we want to caution you that in the future you should submit shut down requests in advance

In doing so 
low concentrations since 2010 after the mineral wool production facility was shut down at the Walter 

Energy facility. This monitor meets the requirements for discontinuation per 40 CFR §58.14( c)( 1) and 

(2). Three CO monitoring sites will remain in Jefferson County (AQS 10 01-073-0023, 01-073-1 

and 01-073-2059). EPA will require the JCDH to restart CO monitoring efforts at the Shuttlesworth site 

should future CO emissions at the facility significantly increase. 

A waiver request was included in this year's plan for a NAAQS exclusion of data from the PM2.s 

continuous federal equivalent method (FEM) sampler located at the North Birmingham site (AQS ID 01-073-0023). Based on the statistical summary from EPA's FEM Comparability Assessment tool 

(attached), the FEM data are considered comparable to both the daily and annual PM2.s NAAQS. As a 

result, the EPA cannot approve the waiver request. We are willing to have further discussions with you 

about our review or to reevaluate this request once all 2015 data have been reported. 

Air Quality Index (AQI) Reporting 

40 CFR §58.50 

AQI reporting is required in MSAs with populations over 350,000. Four MSAs in Alabama are required 

to report an AQI: Huntsville, Mobile, and Montgomery. The state's Network Plan on Page 

6 contains links to the ADEM, JCOH and Huntsville Department ofNatural Resources Web sites where 

this information can be obtained. This satisfies the AQI reporting requirement for the state. 

National Core (NCore) Monitoring Network 

40 CFR Part 58, Appendix D, 3.0 

The state is required to have one NCore site. The NCore site must measure, at a minimum, PM2.s 

particle mass using continuous and integrated/filter-based samplers, speciated PM2 s, PM10-2.s particle 

mass, 03, S02, CO, NO/NOy, wind speed, wind direction, relative humidity, and ambient temperature. 

NCore sites in CBSAs with populations of 500,000 people (as determined in the latest Census) or 

greater are also required to measure Ph either as Pb-TSP or Pb-PM10. The North Birmingham site (AQS 

ID 01-073-0023) was approved as the state's NCore site by OAQPS on October 30, 2009 and currently 

meets all requirements for the state. 

03 Monitoring Requirements 

40 CFR Part 58, Appendix D, Table D-2 Region 4 has determined that the 03 monitoring network outlined in the Network Plan meets the 

minimum requirements found in 40 CFR Part 58, Appendix D, Table D-2 for all MSAs. 

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CO Monitoring Requirements 

40 CFR, Part 58, Appendix D, 4.2 

Ambient air monitoring network design criteria for CO are found in 40 CFR Part 58, Appendix D, 4.2. 

This section requires CBSAs with populations over one million to operate one CO monitor collocated 

with a near-road N02 monitor. Forty CFR §58.13(e)(2) specifically requires the monitor be operational 

by January 1, 2017. This requirement is already being met for the Birmingham CBSA by the CO 

monitor at the Arkadelphia near-road site (AQS ID 01-073-2059). CO monitoring is also a requirement 

for the NCore network and a CO monitor is located at the state's only NCore site in Birmingham (AQS 

ID 01-073-0023). 

Additionally, we have determined that the CO monitor located at the Fairfield site (AQS ID 0 1-073· 

I 003) in Jefferson County is the maximum concentration site for the Birmingham CBSA. We request 

the JCDH make this change to the monitoring objective for that monitor by December 31, 2015. 

In summary, the CO monitoring network oudincd in the Network Plan meets the minimum requirements 

for a11 CBSAs. 

N02 Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.3 

Ambient air monitoring network design criteria for N01 arc found in 40 CFR Part 58, Appendix D, 4.3. 

There are three types of required N02 monitoring: ncar-road, area-wide, and Regional Administrator. 

These types ofN02 monitoring arc described in sections 4.3.2, 4.3.3, and 4.4.4, respectively. 

The Birmingham area is the only CBSA required to operate a ncar-road N02 monitoring station in 

Alabama. The JCDH operates a N02 monitor at the Arkadelphia near-road site (AQS ID 01 -073-2059) 

to meet this requirement. The Arkadelphia ncar·road monitoring site was approved in the EPA's 

response to Alabama's 2013 Network Plan. 

The Birmingham area is the only CBSA in Alabama required to operate an area-wide NO:! monitoring 

station. The JDHC operates a N02 monitor at the North Binningham NCore site (AQS ID 01 -073-0023). 

Thus, the requirement for area-wide N02 monitoring is met. 

No monitoring in Alabama have been designated as Regional Administrator NO~ monitoring sites. There 

is no deficiency with this requirement. The full list of N02 monitors identified by the Regional 

Administrators can be found on EPA's website at http://www.epa.gov/ttnamtil /svpop.html 

All of the requirements for N02 monitoring arc met for the Binningham CBSA and no other CBSA in 

Alabama is required to monitor for N02 at this time. 
to begin having conversations with affected sources in your state to determine an agreed upon approach 

for meeting the ORR requirements. By January 15, 2016, ADEM must submit a final list of sources to 

EPA Region 4 identifying the sources in the state around which S02 air quality must be characterized. 

For sources that ADEM decides to evaluate using ambient air monitoring data, new site proposals must 

be included in the 2016 Network Plan. The location of these monitoring sites should be selected using 

the process outlined in the S02 NAAQS Designations Source-Oriented Monitoring Technical Assistance 

Document1• 

Pb Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.5 

Forty 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 [tpy] and from each airport which emits 1.0 or more tons per year ... " Monitoring is ongoing as 

required near the Sanders Lead Company in Troy, Alabama. Pb monitoring is also ongoing at the North 

Birmingham NCore site. However, we have identified one potential deficiency in the Pb source 

monitoring network. Based on the most current emissions data available, the 2011 National Emissions 

Inventory (NEI), the Anniston Army Depot emits 1. 79 tpy of Pb. Pb source monitoring waivers are 

required by 40 CFR Part 58, Appendix D, Section 4.5 and are to be renewed in each 5-year network 

assessment. There was no discussion in either the Network Plan or the network assessment regarding 

whether monitoring is appropriate at this facility or whether the state is requesting a waiver of 

monitoring requirements. The state is requested to submit an addendum to the 5-year network 

assessment by December 31, 2015, addressing these monitoring requirements for this facility. If 

compelling documentation in support of a waiver ofthe monitoring requirements cannot be provided, 

then the state will need to provide a schedule for when Pb source monitoring will be established. 

Monitoring should begin no later than December 31, 2016. We will work with your agency as necessary 

to determine the most appropriate location for ambient air monitoring around the facility. 

Other than this one potential deficiency, the Pb monitoring network described in the state's Network 

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

1 S02 NAAQS Designations Source-Oriented Monitoring Technical Assistance Document. U.S. EPA Office of Air Quality 

Planning and Standards Air Quality Assessment Division, Draft December 2013. 

http: t /www 3 .epa. gov/a irgualitvlsulfurdioxide/pdfsJS02Mon itoring TAD .pdf 

5 
PM1o Monitoring Requirements 

40 CFR Part 58, Appendix A, 3.3.1 

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

Region 4 has detennined that the PM1o monitoring network outlined in the Network Plan meets or 

exceeds the minimum requirements found in 40 CFR Part 58, Appendix 0, Table 0-4 for all MSAs. 

However, the collocation requirements for manual PM w monitors are not being fully met for all areas. 

Collocation requirements apply to each PQAO and are based on the sampling methods employed. The 

City of Huntsville's local agency will officially become its own PQAO on January 1, 2016, and must 

meet the collocation requirements separate from the state. While the Old A•rport site (AQS 10 01-089· 

0014) in Huntsville does have a collocated manual PM10 monitor, no concentration data from that 

monitor has been reported to EPA's Air Quality System. They must begin reporting these collocated 

sampling data effective January 1, 2016. Please be sure to note this change in the Network Plan to be 

submitted in 2016. 

PMz.s Monitoring Requirements 

40 CFR Part 58, Appendix A, 3.2.5 

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

Region 4 has detennined that the PM2 s monitoring network outlined in the Network Plan meets the 

minimum requirements found in 40 CFR Part 58, Appendix 0, Table 0-5 for all MSAs. The PM2 s 

collocation requirement found in 40 CFR Part 58, Appendix A, 3.2.5.2 for manual reference and 

equivalent methods collocated PM!.S monitoring is also met. 

PM2.s Ncar-road Monitoring Requirement 

40 CFR Part 58, Appendix D, 4.7.1(b)(2) 

Regulatory requirements in 40 CFR Part 58, Appendix 0 , 4. 7.1 (b )(2) require that "CBS As with a 

population of 1,000,000 or more persons, at least one PM2 s monitor, is to be collocated at a near-road 

N02 station." The PM2 s monitor at the Arkadelphia near-road site (AQS 10 0 1-073-2059) in 

Birmingham fulfills this requirement. 

PMz.s Continuous Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.7.2 

Regulatory provisions for continuous PM2 5 monitoring require that "The 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 0--5 of this appendix. At least one required continuous analyzer 

in each MSA must be collocated with one of the required 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." 
that is sustainable going forward. As a result of this assessment, the EPA de funded a number of 

monitoring sites, eliminated the CSN PM2.s mass measurement, reduced the frequency of carbon blanks, 

reduced sample frequency at some monitoring sites, and reduced the number of icepacks in shipment 

during cooler months of the year. As noted in the Network Plan, the following CSN monitoring sites in 

Alabama were defunded and have been discontinued: the Huntsville Old Airport site (AQS ID 01-089-

0014) and the Montgomery MOMS site (AQS ID 01-101-1002). 

The remaining CSN network, with sites in Birmingham and Phenix City, AL, meets the requirements 

and no other changes to the CSN network are being approved at this time. 

Photochemical Assessment Monitoring Station (PAMS) 

40 CFR Part 58, Appendix D, 5.0 

With the promulgation of a new OJ NAAQSs on October 1, 2015, the EPA also finalized changes to 

PAMS program. By June 1, 2019, the NCore site in Birmingham will be required to implement PAMS 

monitoring. While the EPA recognizes there are several implementation challenges to work through, we 

will work closely with ADEM and JCDH to minimize the burden of implementing this new monitoring 

program. At this time, however, there is no P AMS requirement for the state of Alabama. 

Other Concerns 

On Page 10 of the Network Plan the ADEM indicates that 40 CFR Part 58, Appendix E siting criteria 

are being met at all sites. However, no evidence of that was provided. Because most of these sites are 

used in regulatory decision-making, evaluating the conditions at these monitoring sites on an ongoing 

basis is critically important to ensure that the data collected are of sufficient quality. EPA requests that 

the ADEM include in next year's plan recent pictures of all sites with a statement indicating: that the 

siting criteria for each site have been evaluated, the date on which the evaluation occurred, and whether 

the sites meet or do not meet the current requirements. If sites do not meet the current requirements, the 

ADEM should include a statement on the corrections that need to be made and a schedule of when these 

corrections will be made. If you would like to see examples of how other agencies are meeting this 

requirement in the context of their annual Network Plans, we can share them with you. 

7