Mr. John S. Lyons Director UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 

# QCf l 1 

## ZUlZ

Kentucky Division for Air Quality Department ofEnvironmental Protection 200 Fair Oaks Lane, lstFloor Frankfort, Kentucky 40601 Dear Mr. Lyons: Thank you for submitting the annual ambient air monitoring network plan (Network Plan) for the Commonwealth ofKentucky dated June 29, 2012. TheNetwork Plan covers Kentucky's ambient air monitoring network which is comprised ofassets and resources managed by the Kentucky Division for Air Quality (KDAQ) and the Louisville Metro Air Pollution Control District. TheNetwork Plan is required by40 Code ofFederal Regulations (CFR) §58.10. TheU.S. Environmental Protection Agencyunderstands that KDAQ provided a 30-daypublic comment period. Commentsreceived and KDAQ's responses are included with the Network Plan. An additional public inspection period is not required. With this letter, EPA Region 4 is approving the Commonwealth ofKentucky's Network Plan with the exception ofthe N02 monitoring plans. Pending action bythe EPA Administrator, EPA Region 4 supports the selection ofN02 sites as fulfillment ofthe**area-wideN~** monitoring for the Louisville/Jefferson County and Cincinnati-Middletown corebased statistical areas and required by40 CFR Part 58, Appendix D, 4.3.3. KDAQ will need to provide additional information on near-road N02 monitoring as described in the enclosure. Once EPA Region 4 is in agreement with the proposed nearroad N02site, KDAQ will need to make the information available for public inspection. Upon completion ofthe public inspection process, EPA Region 4 will submit the N02 addendum to the Network Plan to the EPA Administrator for approval per40 CFR 58.10(a)(5). We have enclosed comments onyour Network Plan and will continue to work with your agency on the remaining portions ofthe plan that have not been approved with this letter. ·

lntemet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed**w~h** Vegetable Oil Based Inks on Recycled Paper (Minimum 30"/o Postconsumer)

# ..

Thank you for working with us to monitor air pollution and promotehealthy airquality in Kentucky. Please let us know ofany problems in meeting any ofthe requirements wehave identified. Ifyouhave any questions orconcerns, please contact DougNeeley at (404) 562-9097 or Keith Goffat (404) 562- , 9137.

Enclosure

cc: Ms. Lauren Anderson, Director

# ~Sin~:ly,J~**~_......· ~-----._)** **"-bemH.~~** Director Air, Pesticides andToxics

Management Division

Louisville Metro Air Pollution Control District Ms. Stephanie B. McCarthy Kentucky Division for Air Quality

### CY 2012 Commonwealth ofKentucky Ambient AirMonitoring Network Plan U.S. EPA Region 4 Comments and Recommendations

This document contains U.S. EPA Region 4 comments and recommendations on the Commonwealth of Kentucky's 2012 ambient air monitoringnetwork plan (Network Plan). Ambient airmonitoring rules, which include regulatory requirements that address network plans, data certification, and minimum monitoring requirements, among otherrequirements, are found in 40 CFR Part 58. Minimum monitoring requirements for criteria pollutants are listed in 40 CFR Part 58, Appendix D. New national ambient air quality standards (NAAQS) were promulgated in 2010 for nitrogen dioxide (N02) and sulfur dioxide (S02 ) with minimum monitoring requirements effective January 1, 2013. In 2011, while the NAAQS for carbon monoxide was not changed, new minimum monitoring requirements were announced and will become effective on January l, 2015. The state's plans for implementing these requirements will not have to be identified until July 1, 2014, when the 2014 Network Plan is due. Minimum monitoring requirements are listed for ozone (03), particulate matter less than 2.5 microns (PM2.s), particulate matter less than 10 microns (PMw), and lead (Ph). The minimum monitoring requirements are based on metropolitan statistical area (MSA) boundaries as defined bythe U.S. Office ofManagement and Budget (OMB), July 1, 2011, population estimates from the U.S. Census Bureau and historical ambient air monitoring data. OMB currentlydefines nine MSAs in the Commonwealth ofKentucky. These MSAs and the respectiveJuly 1, 2011, population estimates from the U.S. Census Bureau are shown inTable l.
Table 1: Metropolitan Statistical Areas and Populations

MSAName Cincinnati-Middletown. OH-KY-IN Louisville/Jefferson County, KY-IN Lexington-Fayette, KY Evansville, IN-KY Huntington-Ashland, WV-KY-OH Clarksville, TN-KY Bowling Green, KY Elizabethtown. KY Owensboro, KY


### Minimum0 3 

### Monitoring Requirements 40 CFR Part58, Appendix D, Table D-2 Population 2,138,038 1,294,849

479,244 359 879 287,599 277 701 127,607 121,771 115,333

The network described in the Network Plan meets the minimum 03 monitoringrequirements specified by40 CFR Part 58, Appendix D, Table D-2 in all areas. The 2011 Network Plan indicated the minimum monitoring requirements for 03 were not beingmet in the BowlingGreen and Elizabethtown MSAs, since the monitors in those MSAs were designated as special purpose monitors (SPMs) instead ofstate or local air monitoring stations (SLAMS) monitors. In order to meet minimum monitoringrequirements, the 2012 Network Plan indicates that the 03 monitors in both MSAs will be redesignated from SPM to SLAMS monitors.



### 1

### Minimum PM 10 

### MonitoringRequirements 40 CFRPart58, Appendix A, 3.3.1 40 CFRPart58, Appendix D, Table D-4 The Commonwealth ofKentucky's current PMto primary monitoring network meets the minimum requirements found·in

### 40 CFR Part 58, Appendix 

### 0,Table 

### 0-4 for all MSAs. Also, all PMw collocation requirements for manual methods found in

### 40 CFR Part 58, Appendix A, 

### 3.3.1 are currently beingmet. Fifteen percent ofeach network ofmanual PM 10 methods (at least one site) must be collocated. These collocation requirements are assessed at the primary quality assurance organization level. 

### :Minimum PM2.5 

### l\'lonitoring Requirements 40 CFR Part58, Appendix A, 3.2.5 40 CFR Part 58, AppendixD, Table 0-5 The Commonwealth ofKentucky's current PM2.s monitoring network meets the minimum requirements found in 

### 40 CFR Part 

### 58, Appendix 

### D, Table 

### D-5 for all MSAs. Manual PM2.s collocationrequirements are found in 

### 40 CFR Part 

### 58, Appendix A, 

### 3.2.5. These include the requirement that fifteen percent of each network ofmanual PM2 .s methods (at least one site) mustbe collocated. The manual collocation requirements for PM2.s are currentlybeingmet in the Network Plan. 

### PM2
.5 

### Continuous MonitoringRequirements 40 CFR Part58, Appendix D, 4.7.2 Regulatory requirements for continuous PM2.s monitoring require that"

...State, orwhere appropriate, local agenciesmust operate continuous PM2.s analyzers equal to at least one-half(roundup) 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 FRM/FEM/ARM monitors is itselfa continuous FEM orARM monitor in whichcase no collocation requirement applies." These minimum continuous PM2 .s monitoring requirements are currently met in all MSAs in the Commonwealth. Also, the continuous PM2
.5 collocation requirements are currently met in all MSAs. Therefore, the continuous PM2.s monitoring network described in the Network Plan meets all ofthe design criteria of

### 40 CFR Part 58. 

### Pl\'hs Background andTransport Sites 40 CFR Part58, Appendix D, 4.7.3 Forty CFR Part 58, Appendix D, 

### 4.7.3 requires that "Each State shall install and operate at least one PM2
.5 site to monitor for regional background and at least one PM2.s site to monitor for regional transport." The Network Plan identifies the Grayson Lake PM2.s site (Air Quality System (AQS) 

### 10: 21-043-0500) as a background site and the Hopkinsville PM2.s site (AQS 

### 10: 21-047-0006) as a transport site. Therefore, KDAQ has satisfied the requirements of

### 40 CFRPart 58 for background and transport sites.

2

### Pb 1\'lonitoringRequirements 40 CFR Part58, Appendix D, 4.5 The monitoring requirements for Pb are found in40 CFR Part 58, Appendix D, Section 4.5 (see 75 Federal Register 81126). Theemissions threshold for facilities near which source-oriented Pb monitoring is required is 0.5 tons peryear. Pb monitoring is also required at urban NCore sites. OnMarch 16, 2012, KDAQ started collecting data from a temporary special purpose Pb monitoring station on the Eastern Kentucky University (EKU) property in Richmond to determine if monitored levels at that site were appreciativelyhigher than at the nearbyMayfield Elementary School Pb monitor (AQS ID: 21-151-0003). Modelinghad indicated that the Mayfield Elementary School site is located outsidethe area ofmodeled maximum deposition for the Enersys facility.The EKU Pb monitoring site (AQS ID: 21-151-0005) is located approximately 195 meters from the Enersys facility and the GPS coordinates are 37.73635, -84.29169. For the March through May 2012 period, boththe EKU and Mayfield Elementary School monitors exceeded the 3-monthrolling average Pb NAAQS limit of0.15 ug/m3• Subsequently several other exceedances oftheNAAQS were monitored with Pb levels at the EKU site significantly higher than at the Mayfield Elementary School site. Because the monitored levels are significantly higher at the EKU site, EPA requests that KDAQ establish a permanent Pb monitoring site at ornear the temporary EKU site. The Pb monitoring network described in the 2012 Network Plan meets all ofthe design criteria of 40 CFRPart 58. 

### S02 Monitoring Requirements 40 CFR Part58, Appendix D, 4.4 Ambient airmonitoring network design criteria for S02 are found in section 4.4 ofAppendix D to 40 CFR Part 58. This section requires that "Thepopulation weighted emissions index (PWEI) shall be calculated by states for each corebased statistical area (CBSA)

..."As a result, the S02monitoring site(s) required in each CBSA will satisfyminimum monitoringrequirements ifthe monitor(s) is sited withintheboundaries ofthe parent CBSA and is ofthe following site types: population exposure, maximum concentration, source-oriented, general background, or 'regional transport. An S02monitor at an NCore station may satisfyminimummonitoring requirements ifthat monitor is located within a CBSA with minimally required monitors consistent with Appendix D, section4.4. EPA's Office ofAir Quality Planning and Standards (OAQPS) recently updated the Population Weighted Emission Index calculations using the latest available emissions inventory data and population estimates. Several areas in Region 4 have decreased monitoring requirements as a result ofthese new calculations. The Louisville/Jefferson County CBSA will berequired to operate one monitor instead of two. The Lexington-Fayette CBSA will not have to operate any**S~** monitors, whereas it was previously required to operate one S02monitor. The requirements did not change for the Evansville CBSAorthe Cincinnati-Middletown CBSA. The so2 network is to beoperational beginning January 1, 2013. The so2 monitoring network design outlined in your Network Plan will meet the minimum requirements under 40 CFR Part 58.

3N02 

### Monitoring Requirements 40 CFR Part 

### 58, Appendix D, 4.4 Ambient air monitoring network design criteria for NOz are found in Section4.3 ofAppendix D to 40 CFRPart 58. There are three types ofrequired NOz monitoring: near-road, area-wide, and Regional Administrator required. These types ofN02 monitoring are described in sections 4.3.2, 4.3.3, and 4.3.4, respectively. Any CBSA with a population of500,000 ormore persons is required to have a near-road NOz monitoring station that monitors expected maximum hourly concentrations near a majorroad. Any CBSA with·a population of2,500,000 ormore persons orthat has one or more roadway segments with a 250,000 orgreater annual average daily traffic count is required to have an additional near-road NOz monitoring station. TheNear-roadNOz Monitoring TechnicalAssistanceDocument (TAD) provides guidance to state andlocal agencies in selecting an appropriate near-roadNOz monitoring location. This document canbe found onthe internet at http://www.epa.gov/ttnamti 1/files/nearroad/NearRoadTAD.pdf. 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. Any CBSA with a population of 1,000,000 ormore persons is required to monitor a location ofexpected highestN02concentrations representing the neighborhood orlarger spatial scales. Ambient airmonitoring network design criteria for Regional Administrator required NOz monitoring, often referred to as RA-40 monitoring, are found in Section 4.3.4 ofAppendix D to 40 CFRPart 58. This section states that "the Regional Administrators, in collaboration with States, must require a minimum offorty additional NOz monitoring stations nationwide in any area, inside oroutside of CBSAs, above the minimum monitoring requirements, with a primary focus on siting these monitors in locations to protect susceptible and vulnerable populations. The Regional Administrators, working with States, may also consider additional factors

... to require monitors beyondthe minimum network requirement." Pending action by the EPA Administrator, EPA Region 4 supports the selection ofthe Cannons Lane N02monitoring site (AQS ID: 21-111-0067) in fulfillment ofthe area-wide NOz monitoring requirement for the Louisville/Jefferson County CBSA and the selection ofthe Northern Kentucky University NOz monitoring site (AQS ID: 21-037-3002) in fulfillment ofthe area-wide NOz monitoring requirement for the Cincinnati-Middletown CBSA. Inboth ofthese areas, the NOz monitors have already been established. We note your acknowledgement that the Lexington Primary NOz monitor (AQS ID: 21-067-0012) should be considered amongthe NOz monitors intended to help protect susceptible and vulnerable populations. As indicated by KDAQ, a near-road NOz monitor will be established and operated byLouisville Metro Air Pollution Control District (LMAPCD) for the Louisville/Jefferson County CBSA and a near-road NOz monitorwill be established and operatedbythe Southwest Ohio Air Quality Agency for the Cincinnati-Middletown CBSA. Additional information on the near-road NOz monitoring plans will need to be submitted. Section 13.5 ofthe near-road NOz TAD and Table 13.1 ofthe TAD identify important site and road parameters when evaluating a near-road site. Using the TAD as a reference, additional information provided on near-road NOz monitoring should include, at minimum, the following information for each site:

4• Proposed AQS ID • Street address and site geographical coordinates (longitude and latitude) • Targetroad segment description including type ofroad • Site pictures facing 4-8 directions- N, S, E, W, NE, NW, SE, SW • Probable distancebetween the inlet probe and the outside nearest edge ofthe target road • Sitepropertydescription including propertyowner and feasibility ofsite access • Roadway design and configuration • Presence ofany roadside structures • Nearestwindrose representative ofthe site and orientation ofthe site withrespect to the predominate wind direction • Traffic data and ranking information (seeTable 6-3 ofthe Technical Assistance Document), as well as the source and vintage ofthe data • Samplingand 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 orother arearepresentedbythe monitor • Discussion ofothersiting criteria Once EPA Region 4 is in agreement with the proposed near-road N02 site in the Louisville/Jefferson CountyCBSA, the Commonwealth will need to make the information available for public inspection. Upon completion ofthe public inspection process, EPA Region 4 will submit**theN~** addendum to the Network Plan, coveringboth the area-wide and near-road proposals, to the EPA Administrator for approval per40 CFR 58.10(a)(5). We will continue to work with your agency as needed to get the N02 sites operational as expeditiously as possible. Air Quality Index (AQn Reporting 40 CFR §58.50 AQI reporting is required in MSAs with populations over 350,000 as ofthe last official U.S. census. KDAQ is required to report an AQI for four MSAs: Cincinnati-Middletown, Louisville/Jefferson County, Lexington-Fayette, and Evansville. KDAQ meets this requirement. Monitoring Network Changes Proposed by KDAQ The Oakland air monitoring station (AQS ID: 21-227-0008) located on the premises ofthe Oakland Elementary Schoolin the Bowling Green MSA was discontinued <?n May 9, 2012, and the monitors have been relocated to Ed SpearPark located in Smith Grove, Kentucky. The Oakland air monitoring station was located in a sinkhole and flooding and safetyhavebeen a problem at the site. EPA Region 4 agreed in its 2011 Network Plan approval letter to KDAQ dated October20, 2011, that a relocation of the Oakland air monitoring station to another located in Warren County was appropriate. The new site is located approximately 3.5 kilometers from the Oakland Elementary School site. The AQS code for the new site is 21-227-0009 and the GPS coordinates are 37.04926,-86.21487. The new Ed Spear Park site began successfully collecting data on May 3, 2012. The site is designated as a SLAMS for PM2.s and has a collocated PM25 monitor. A SPM TEOM continuous PM2.s monitor is also located at the site, and the 0 3 monitor is being designated as a SLAMS monitor. EPA Region 4 approves the Ed Spear Park air monitoring station. 5

### KDAQ has removed the non-regulatory MetOnebeta attenuation method (BAM) continuous PM2.5 

### SPM from the Northern Kentucky University (NKU) airmonitoring station (AQS ID: 21-037-3002) and has installed an SPM TEOM monitor in order to maintain continuous PM2.5 

### data collection for the AQI. These changes were effective onJune 19,2012. KDAQ plans to relocate the MetOne BAM continuous PM2.5

### monitor that is removed from theNKU air monitoring station to the Pikeville air monitoring station (AQS ID: 21-095-0002). Bydoing so, the MetOne BAM monitor will be sited withtwo manual PM2.s sequential SLAMS monitors at the Pikeville air monitoring station. The SPMTEOM at the Pikeville site is being discontinued. The effective date for these changes is August 1, 2012. 

### National Core (NCore) MonitoringNetwork The NCore site at Cannons Lane (AQS ID: 21-lll-0067) is operated by the LMAPCD. EPA's OAQPS approved the site on October 30, 2009.

6