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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 ofAlabama's 2013 annual ambient air monitoring network plan (Network Plan) dated June 4, 2013
. The Network Plan is required by40 Code ofFederal 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 of40 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 ofthe near-road N02 monitoring requirement for the Birmingham core based statistical area (CBSA). The EPA also approves the operation ofan 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 ofAppendix 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)

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Thank you for your work with us to monitor air pollution and promote healthy air quality in Alabama. If you have anyquestions orconcerns, 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 ofHealth Daniel E. Shea, Director Huntsville DepartmentofNatural Resources

### CY 2013 State ofAlabama 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 (PM 10), and lead (Pb). The minimum monitoring requirements are based on core based statistical area (CBSA) boundaries, as defined by the U.S. Office ofManagement 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 ofAlabama. 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

1Minimum 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 PM 1

### omonitoring 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 ofall high volume PMto samplers in Jefferson County. The specific monitors approved for discontinuation are listed in Table 2 in the section below titled " Monitoring Network Changes Proposed byADEM"
. At all sites except 01-073-0034, low volume PM 10 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
.scollocat ion 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, orwhere appropriate, local agencies must operatecontinuous PM2
.s analyzers equal to at least one-half (round up) 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 FRM, Federal Equivalent Method (FEM), Approved Regional Method (ARM) monitors, unless at least one ofthe required FRMIFEMIARM monitors is itselfa 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 of40 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 ofmonitoring at Pryor Field (AQS ID 01-083-0005) with results less than 50% ofthe NAAQS, EPA approves the shutdown ofthe 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 ofthis monitoring requirement going forward. The Pb monitoring network described in the Network Plan meets all ofthe design criteria of40 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 ofAppendix 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 ifthe monitor(s) is sited within the boundaries ofthe parent CBSA and is ofthe 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 3that monitor is located within a CBSA with minimally required monitors consistent with Appendix D, 4.4
. Last year, the EPA's Office ofAir 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 ofthe S02 monitor there at the end ofthe 2013 calendar year. The S02 monitoring network design outlined in the Network Plan meets the minimum requirements of40 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 ofAppendix D to 40 CFR Part 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 4.4.4 respectively. Any CBSA with a population of500,000 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 stat ion. 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/ttnamti l/files/nearrond/NearRondTAD
.pdf. Ambient air monitoring network design criteria for**area-wideN~** sites are found in Sect ion 4.4.3 ofAppendix D to 40 CFR Part 58
. Any CBSA with a population of 1,000,000 or more persons is required to monitor a location ofexpected highest N02concentrations 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 monit oring, are found in Section 4.3.4 ofAppendix 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 N02monitoring stations nationwide in any area, inside or outside ofCBSAs, above the minimum monitoring requirements, with a primary focus on siting these monitors in locations to protect susceptible and vulnerable populations
. The 4 

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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: 0l-073-2059) in fulfillment ofthe near-road N02 monitoring requirement for the Birmingham CBSA. The EPA also approves the operation ofan N02 monitor at the North Birmingham (AQS ID 01-073-0023) site, in fulfillment ofarea-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 ofthe 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 ofAlabama 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 ofNatural 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 0 1

-073

-0034 High Volume PM 1 0 SLAMS 0 1

-073

- 1003 High Volume PM 10 SLAMS 01-073

- 1010 High Volume PM 1o SLAMS 0 1

-073

-6002 High Volume PM 1 0 SLAMS 01-125

-0010 

## so2 SLAMS 01

-073

-0028 

## co SLAMS Relocated to near road site 0l-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

5According to 40 CFR § 58.14( c), a request for discontinuation ofa SLAMS monitor will be approved ifthe monitor meets any ofthe criteria under 40 CFR 

### § 58
. l4(c)(l) through (6). The requested PM10 and CO monitors meet the requirement of40 CFR § 58.14(c)(l)
. The monitors have shown attainment ofthe applicable NAAQSs during the previous five years and have a probability ofless than 10 percent ofexceeding 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 S02monitor. The EPA also agrees that the low concentrations recordeda t the site during 2013 indicate a very low probability ofS02 exceedances in the future. Therefore, the EPA approves the discontinuation ofthis 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 ofthese monitors. As discussed above, the EPA Region 4 approves the Arkadelphia N02 near-road monitoring site (AQS ID: 01-073-2059) in fulfillment ofthe near-road NO! monitoring requirement for the Birmingham CBSA. The EPA Region 4 also approves the operation ofan N(h monitor at the North Birmingham (AQS 10 01-073-0023) site, in fulfilbnent ofarea-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 st ate's NCore site by OAQPS on October 30, 2009
. 

### It currently meets all requirements.

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