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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

Mr. Ron Gore 

Chief 

Air Division 

Alabama Department of 

Environmental Management 

1400 Coliseum Boulevard 

Montgomery, Alabama 36130 

Dear Mr. Gore: 

ATLANTAFEDERALCENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303-8960 

NOV 2 2 2013 

Thank you for submitting the state of Alabama's 2013 annual ambient air monitoring network plan 

(Network Plan) dated June 4, 2013. The Network Plan is required by 40 Code of Federal Regulations 

(CFR) §58.10. 

The U.S. Environmental Protection Agency Region 4 understands that the Alabama Department of 

Environmental Management provided the public a 30-day review period and no comments were 

received. 

Based upon our review ofthe Network Plan, EPA Region 4 has determined that it satisfies the 

applicable requirements of 40 CFR Part 58 and, by this letter, is approving the Network Plan. The EPA 

approves the Arkadelphia nitrogen dioxide (N02) near-road monitoring site (AQS ID: 01-073-2059) in 

fulfillment of the near-road N02 monitoring requirement for the Birmingham core based statistical area 

(CBSA). The EPA also approves the operation of an N02 monitor at the North Birmingham (AQS ID 

01-073-0023) site in fulfillment of area-wideN~ monitoring requirement for the Birmingham CBSA. 

The minimum monitoring requirements for N02, found in Section 4.3 of Appendix D to 40 CFR Part 58, 

will be met once the N02 monitor at the Arkadelphia near-road monitoring site and the N02 monitor at 

the North Birmingham site begin operating. The near-road N02 monitor is required to be operational by 

January l, 2014. 

Internet Address (URL) • h"p://www.epa.gov 

Recyled!Aecyclable • Printed w th Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
. - - . . 

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 Lloyd Generette 

at ( 404) 562-9138. 

Enclosure 

cc: Jonathan Stanton, Director 

Sincerely, 

~,.-Jeaneanne M. Gettle 

Acting Director 

Air, Pesticides and Toxics 

Management Division 

Jefferson County Department of Health 

Daniel E. Shea, Director 

Huntsville Department of Natural Resources 
CY 2013 State of Alabama Ambient Air 1\'lonitoring Network Plan 

U.S. EPA Region 4 Comments and Recommendations 

This document contains U.S. EPA Region 4 comments and recommendations on the state of 

Alabama's 2013 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 (S~). Minimum monitoring requirements for S02 became 

effective January 1, 2013. The schedule for implementing the minimum monitoring requirements 

for N02 was changed by rulemaking. In 2011, while the NAAQS for carbon monoxide was not 

changed, new minimum monitoring requirements were announced and will become effective on 

January 1, 2017. Minimum monitoring requirements are listed for ozone (03), particulate matter 

less than 2.5 microns (PM2.s), particulate matter less than 10 microns (PM10), 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, 2012, 

population estimates from the U.S. Census Bureau; and, historical ambient air monitoring data. 

Minimum monitoring requirements for 03, PM2.s, and PM10 only apply to metropolitan statistical 

areas (MSAs) which are a subset ofCBSAs containing an urban core population of50,000 or 

more. OMB currently defines 12 MSAs in the state of Alabama. These MSAs and the respective 

July 1, 2012, population estimates from the U.S. Census Bureau are shown in Table 1. 

Table 1: Metropolitan Statistical Arens and Populations 

MSA Name Population 

Anniston-Oxford-Jacksonville, AL 11 7,296 

Auburn-Opelika, AL 147,257 

Birmingham-Hoover, AL 1,136,650 

Columbus, GA-AL 310,531 

Daphne-Fairhope-Foley, AL 190,790 

Decatur,AL 154 233 

Dothan, AL 147,620 

Florence-Muscle Shoals, AL 146,988 

Gadsden, AL 104,392 

Huntsville, AL 430,734 

Mobile, AL 413,936 

Montgomery, AL 377,149 

Tuscaloosa, AL 233,389 

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Minimum Ozone Monitoring Requirements 

40 CFR Part 58, Appendix D, Table D-2 

Region 4 has detennined that the ozone 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. 

Minimum 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 D, Table D-4 for all 

MSAs. Also, all manual PM10 collocation requirements are met. fhe EPA approves the 

shutdown of all high volume PM to samplers in Jefferson County. The specific monitors approved 

for discontinuation are listed in Table 2 in the section below titled "Monitoring Network 

Changes Proposed by ADEM". At all sites except 01-073-0034, low volume PM10 samplers are 

currently operating and will continue to operate. 

Minimum 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 D, Table D-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 PM2.5 monitoring is also met. 

PM2.s Continuous Monitoring Requirements 

40 CFR Part 58, Appendix D, 4. 7.2 

Regulatory provisions for continuous PM2.s monitoring require that "The 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 FRM, 

Federal Equivalent Method (FEM), Approved Regional Method (ARM) monitors, unless at least 

one of the required FRMIFEMIARM monitors is itself a continuous FEM or ARM monitor in 

which case no collocation requirement applies." This is met in all areas with the exception of 

Gadsden (AQS ID: 01-055-0010) and Tuscaloosa (AQS ID: 01-125-0004). According to your 

plan, continuous monitors will be added at these sites in calendar year 2014 to meet this 

requirement. 

2 
PM1.s Continuous Federal Equivalent Methods 

40 CFR § 58.10(e) 

Agencies that are operating PM2.s FEM instruments in their network are now required to 

demonstrate whether those samplers should be used for regulatory decision making. Since no 

demonstration was submitted by ADEM, EPA considers any data collected using continuous 

FEMs operating for more than two years in the state to be comparable to the PM2.s NAAQS. Any 

data collected using a continuous FEM must be reported to AQS parameter code 88101. 

PMz.s Background and Transport Sites 

40 CFR Part 58, Appendix D, 4. 7.3 

40 CFR Part 58, Appendix D, 4.7.3 states that "Each state shall install and operate at least one 

PM2 s site to monitor for regional background levels and at least one PM:!.s site to monitor for 

regional transport." The 2013 Network Plan identifies Crossville (AQS ID: 01-149-1003) in 

Dekalb County as a rural background site, Ward (AQS ID: 01-119-0003) in Sumter County as a 

rural background site and Ashland (AQS ID: 01-027-0001) in Clay County as a regional 

transport site. ADEM has satisfied the requirements of 40 CFR Part 58 for regional background 

and transport sites. 

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 sourceoriented 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 Sanders Lead Co. in Troy, which is the only non-airport source in the 

state which emits over 0.50 tons per year (tpy). 

Based on 12 months of monitoring at Pryor Field (AQS ID 01-083-0005) with results less than 

50% of the NAAQS, EPA approves the shutdown of the Pryor Field site. Alabama has satisfied 

the monitoring requirement for Pryor Field under 40 CFR Part 58 Appendix D Section 4.5(a)(iii), 

and EPA grants a waiver of this monitoring requirement going forward. The Pb 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 SCh 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 

3 
that monitor is located within a CBSA with minimally required monitors consistent with 

Appendix D, 4.4. Last year, the EPA's Office of Air Quality Planning and Standards (OAQPS) 

updated the population weighted emission index (PWEn calculations using the latest available 

emissions inventory data and population estimates. The EPA acknowledges that the boundary 

recently changed in the Tuscaloosa CBSA. Based on this new infonnation, we agree that S02 

monitoring is not required in this area at this time. We approve the discontinuation of the S02 

monitor there at the end of the 2013 calendar year. The S02 monitoring network design outlined 

in the Network Plan meets the minimum requirements of 40 CFR Part 58 based on these latest 

calculations. 

Table 2: SOz Monitoring System Status 

CBSAName Monitors Required 

Birmingham-Hoover 2 

Mobile 1 

Tuscaloosa 0 

Nitrogen Dioxide (N02) Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.3 

Existing Monitors 

2 

1 

1 

Ambient air monitoring network design criteria for N02 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 4.4.4 respectively. 

Any CBSA with a population of 500,000 or more persons is required to have a near-road N~ 

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 (AADT) count is required to 

have an additional near-road N02 monitoring station. The Near-road N02 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/ttnamtil/files/nearrond/NearRondTAD.pdf. 

Ambient air monitoring network design criteria for area-wideN~ sites are found in Section 

4.4.3 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 N02 

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 Administr tors, in collaboration with 

States, must require a minimum of 40 additional N02 monitoring stations nationwide in any area, 

inside or outside of CBS As, above the minimum monitoring requirements, with a primary focus 

on siting these monitors in locations to protect susceptible and vulnerable populations. The 

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Regional Administrators, working with States, may also consider additional factors to require 

monitors beyond the minimum network requirement., 

The EPA approves the Arkadelphia N02 near-road monitoring site (AQS ID: 0 l-073-2059) in 

fulfillment of the near-road N02 monitoring requirement for the Birmingham CBSA. The EPA 

also approves the operation of an N02 monitor at the North Birmingham (AQS ID 01-073-0023) 

site, in fulfillment of area-wide N02 monitoring requirement for the Birmingham CBSA. No 

monitors have been identified by the regional office or ADEM to meet the requirements for the 

Regional Administrator required N02 monitoring sites. There is no deficiency with this 

requirement. The full list ofN02 monitors identified by the Regional Administrators can be 

found on the EPA,s website at http://www.epa.gov/ttnamtillsvpop.htrnl. 

Upon establishment and operation of the two approved N02 monitoring sites, the minimum 

monitoring requirements for N02 will be fulfilled for the Birmingham CBSA. No other CBSA in 

Alabama is currently required to monitor for N02. 

Air Quality Index (AQI) Reporting 

40 CFR §58.50 

AQI reporting is required in MSAs with populations over 350,000. There are four MSAs in the 

state of Alabama required to report an AQI: Birmingham, Huntsville, Mobile and Montgomery. 

The state's Network Plan on Page 6 contains links to the ADEM, JCDH and Huntsville 

Department of Natural Resources Web sites where this information can be obtained. This 

satisfies the AQI reporting requirement for the state. 

Monitoring Network Changes Proposed by ADEM 

ADEM proposed several monitoring network changes on pages 6 and 7 in the Network Plan. 

The following monitors are approved for discontinuation: 

Table 2: Monitors Approved for Discontinuation 

AQS SiteiD PoUutant Monitor Type Comments 

01-073-0034 High Volume PM10 SLAMS 

01-073-1003 High Volume PM10 SLAMS 

01-073-1010 High Volume PM1o SLAMS 

0 1-073-6002 High Volume PM10 SLAMS 

01-125-0010 so2 SLAMS 

01-073-0028 co SLAMS Relocated to near road 

site 

0 l-119-0002 03 SLAMS Relocated to nearby site 

01-119-0003 

01-119-0002 Continuous PM2.s SPM Relocated to nearby site 

01-119-0003 

5 
According to 40 CFR § 58.14( c), a request for discontinuation of a SLAMS monitor will be 

approved if the monitor meets any of the criteria under 40 CFR § 58.l4(c)(l) through (6). The 

requested PM10 and CO monitors meet the requirement of 40 CFR § 58.14(c)(l). The monitors 

have shown attainment of the applicable NAAQSs during the previous five years and have a 

probability of less than 10 percent of exceeding 80 percent of the NAAQS during the next three 

years. Also, the minimum monitoring requirements found in Appendix D to 40 CFR Part 58 will 

continue to be met for the respective CBSAs after these network changes are made. Therefore, 

these SLAMS monitors are approved for discontinuation. 

The Tuscaloosa S(h monitor was established in 2013 to meet the S02 PWEI monitoring 

requirement for the Tuscaloosa CBSA. OMB recently revised the CBSA boundary and, as a 

result, the CBSA is no longer required to have an S02 monitor. The EPA also agrees that the low 

concentrations recordeda t the site during 2013 indicate a very low probability of S02 

exceedances in the future. Therefore, the EPA approves the discontinuation of this SLAMS 

monitor. 

In the Network Plan, Alabama proposes to relocate Sumter County 03 and continuous PM2.s 

monitors to a nearby location in Wanl, Alabama because the lease at the previous site could not 

be renewed. The EPA approves the relocation of these monitors. 

As discussed above, the EPA Region 4 approves the Arkadelphia N02 near-road monitoring site 

(AQS ID: 01-073-2059) in fulfillment of the near-road NO! monitoring requirement for the 

Birmingham CBSA. The EPA Region 4 also approves the operation of an N(h monitor at the 

North Birmingham (AQS 10 01-073-0023) site, in fulfilbnent of area-wide N02 monitoring 

requirement for the Birmingham CBSA. 

National Core (NCore) Monitoring Network 

The state is required to have one NCore site. The North Birmingham site (AQS ID: 01-073-0023) 

was approved as the state's NCore site by OAQPS on October 30, 2009. It currently meets all 

requirements. 

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