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 of Environmental Protection 

200 Fair Oaks Lane, l st Floor 

Frankfort, Kentucky 40601 

Dear Mr. Lyons: 

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

Commonwealth of Kentucky dated June 29, 2012. The Network Plan covers Kentucky's ambient air 

monitoring network which is comprised of assets and resources managed by the Kentucky Division for 

Air Quality (KDAQ) and the Louisville Metro Air Pollution Control District. The Network Plan is 

required by 40 Code of Federal Regulations (CFR) §58.10. 

The U.S. Environmental Protection Agency understands that KDAQ provided a 30-day public comment 

period. Comments received 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 of Kentucky's Network Plan with the 

exception of the N02 monitoring plans. Pending action by the EPA Administrator, EPA Region 4 

supports the selection ofN02 sites as fulfillment of the area-wideN~ monitoring for the 

Louisville/Jefferson County and Cincinnati-Middletown core based statistical areas and required by 40 

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 N02 site, KDAQ will need to make the information available for public inspection. Upon 

completion of the public inspection process, EPA Region 4 will submit the N02 addendum to the 

Network Plan to the EPA Administrator for approval per 40 CFR 58.10(a)(5). We have enclosed 

comments on your Network Plan and will continue to work with your agency on the remaining portions 

of the 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 promote healthy air quality in Kentucky. 

Please let us know of any problems in meeting any of the requirements we have identified. If you have 

any questions or concerns, please contact Doug Neeley at ( 404) 562-9097 or Keith Goff at ( 404) 562- , 

9137. 

Enclosure 

cc: Ms. Lauren Anderson, Director 

~Sin~:ly,J~ ~_......· ~-----._) "-bemH.~~ Director 

Air, Pesticides and Toxics 

Management Division 

Louisville Metro Air Pollution Control District 

Ms. Stephanie B. McCarthy 

Kentucky Division for Air Quality 
CY 2012 Commonwealth of Kentucky Ambient Air Monitoring 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 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. 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 by the U.S. Office of Management and Budget (OMB), July 1, 2011, population estimates from 

the U.S. Census Bureau and historical ambient air monitoring data. OMB currently defines nine MSAs 

in the Commonwealth of Kentucky. These MSAs and the respective July 1, 2011, population estimates 

from the U.S. Census Bureau are shown in Table 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 

Minimum 0 3 Monitoring Requirements 

40 CFR Part 58, 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 monitoring requirements specified 

by 40 CFR Part 58, Appendix D, Table D-2 in all areas. The 2011 Network Plan indicated the minimum 

monitoring requirements for 03 were not being met in the Bowling Green and Elizabethtown MSAs, 

since the monitors in those MSAs were designated as special purpose monitors (SPMs) instead of state 

or local air monitoring stations (SLAMS) monitors. In order to meet minimum monitoring requirements, 

the 2012 Network Plan indicates that the 03 monitors in both MSAs will be redesignated from SPM to 

SLAMS monitors. 

1 
Minimum PM10 Monitoring Requirements 

40 CFR Part 58, Appendix A, 3.3.1 

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

The Commonwealth of Kentucky'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 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 level. 

:Minimum PM2.5 l\'lonitoring Requirements 

40 CFR Part 58, Appendix A, 3.2.5 

40 CFR Part 58, Appendix D, Table 0-5 

The Commonwealth of Kentucky'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 collocation requirements 

are found in 40 CFR Part 58, Appendix A, 3.2.5. These include the requirement that fifteen percent of 

each network of manual PM2.s methods (at least one site) must be collocated. The manual collocation 

requirements for PM2.s are currently being met in the Network Plan. 

PM2.5 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 agenciesmust 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 FRM/FEM/ 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 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 of the design criteria of 40 CFR Part 58. 

Pl\'hs Background and Transport Sites 

40 CFR Part 58, 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 CFR Part 58 for background and 

transport sites. 

2 
Pb 1\'lonitoring Requirements 

40 CFR Part 58, Appendix D, 4.5 

The monitoring requirements for Pb are found in 40 CFR Part 58, Appendix D, Section 4.5 (see 75 

Federal Register 81126). The emissions threshold for facilities near which source-oriented Pb 

monitoring is required is 0.5 tons per year. Pb monitoring is also required at urban NCore sites. 

On March 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 appreciatively higher than at the nearby Mayfield Elementary School Pb monitor 

(AQS ID: 21-151-0003). Modeling had indicated that the Mayfield Elementary School site is located 

outside the area of modeled 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, both the EKU and Mayfield Elementary School monitors 

exceeded the 3-month rolling average Pb NAAQS limit of 0.15 ug/m3

• Subsequently several other 

exceedances of the NAAQS 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 or near the temporary EKU 

site. The Pb monitoring network described in the 2012 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 S02 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) ... "As a result, 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 types: population exposure, 

maximum concentration, source-oriented, general background, or 'regional transport. An S02 monitor at 

an NCore station may satisfy minimum monitoring requirements if that monitor is located within a 

CBSA with minimally required monitors consistent with Appendix D, section 4.4. 

EPA's Office of Air 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 of these new 

calculations. The Louisville/Jefferson County CBSA will be required 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 S02 monitor. The requirements did not change for the Evansville CBSA or the 

Cincinnati-Middletown CBSA. 

The so2 network is to be operational beginning January 1, 2013. The so2 monitoring network design 

outlined in your Network Plan will meet the minimum requirements under 40 CFR Part 58. 

3 
N02 Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.4 

Ambient air monitoring network design criteria for NOz are found in Section 4.3 of Appendix D to 40 

CFR Part 58. There are three types of required 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 of 500,000 or more persons is required to have a near-road NOz 

monitoring station that monitors expected maximum hourly concentrations near a major road. Any 

CBSA with· a population of2,500,000 or more persons or that has one or more roadway segments with a 

250,000 or greater annual average daily traffic count is required to have an additional near-road NOz 

monitoring station. The Near-road NOz Monitoring Technical Assistance Document (TAD) provides 

guidance to state and local agencies in selecting an appropriate near-road NOz monitoring location. This 

document can be found on the 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 or more persons is required 

to monitor a location of expected highest N02 concentrations representing the neighborhood or larger 

spatial scales. 

Ambient air monitoring network design criteria for Regional Administrator required NOz monitoring, 

often referred to as RA-40 monitoring, are found in Section 4.3.4 of Appendix D to 40 CFR Part 58. 

This section states that "the Regional Administrators, in collaboration with States, must require a 

minimum of forty additional NOz monitoring stations nationwide in any area, inside or outside 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 beyond the minimum network 

requirement." 

Pending action by the EPA Administrator, EPA Region 4 supports the selection of the Cannons Lane 

N02 monitoring site (AQS ID: 21-111-0067) in fulfillment of the area-wide NOz monitoring 

requirement for the Louisville/Jefferson County CBSA and the selection of the Northern Kentucky 

University NOz monitoring site (AQS ID: 21-037-3002) in fulfillment of the area-wide NOz monitoring 

requirement for the Cincinnati-Middletown CBSA. In both of these 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 among the NOz monitors intended to help protect 

susceptible and vulnerable populations. As indicated by KDAQ, a near-road NOz monitor will be 

established and operated by Louisville Metro Air Pollution Control District (LMAPCD) for the 

Louisville/Jefferson County CBSA and a near-road NOz monitor will be established and operated by the 

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 of the near-road NOz TAD 

and Table 13.1 of the 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) 

• 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 

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

• Roadway design and configuration 

• Presence of any roadside structures 

• Nearest windrose 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 EPA Region 4 is in agreement with the proposed near-road N02 site in the Louisville/Jefferson 

County CBSA, the Commonwealth will need to make the information available for public inspection. 

Upon completion of the public inspection process, EPA Region 4 will submit theN~ addendum to the 

Network Plan, covering both the area-wide and near-road proposals, to the EPA Administrator for 

approval per 40 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 of the 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 School in the Bowling Green MSA was discontinued <?n May 9, 2012, and the monitors 

have been relocated to Ed Spear Park located in Smith Grove, Kentucky. The Oakland air monitoring 

station was located in a sinkhole and flooding and safety have been a problem at the site. EPA Region 4 

agreed in its 2011 Network Plan approval letter to KDAQ dated October 20, 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 MetOne beta attenuation method (BAM) continuous PM2.

5 SPM 

from the Northern Kentucky University (NKU) air monitoring 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 on June 19,2012. 

KDAQ plans to relocate the MetOne BAM continuous PM2.5 monitor that is removed from the NKU air 

monitoring station to the Pikeville air monitoring station (AQS ID: 21-095-0002). By doing so, the 

MetOne BAM monitor will be sited with two manual PM2.s sequential SLAMS monitors at the Pikeville 

air monitoring station. The SPM TEOM at the Pikeville site is being discontinued. The effective date for 

these changes is August 1, 2012. 

National Core (NCore) Monitoring Network 

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