Division of Air Pollution Control 

Tennessee Department of Environment and Conservation 

William R. Snodgrass Tennessee Tower 

312 Rosa L. Parks A venue, 15th Floor 

Nashville, Tennessee 37243 

Dear Mr. Stephens: 

Thank you tbr submitting the State ofTcnncssee's 2015 annual ambient air monitoring network plan 

(Network Plan) dated June 30, 2015. 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 Tennessee 

Department of Environment and Conservation (TDEC) provided the public a 30-day review period and 

three external comments were received. 

With this letter, the EPA is approving TDEC's Network Plan with the exception of two aspects. The 

EPA does not have enough intbnnation to review and approve the proposed sites for sulfur dioxide 

(SOz) near the Eastman Chemical Company facility in Kingsport or for ozone (OJ) and fine particulate 

matter (PMz.s) at the Loudon Middle School without all the requisite intbnnation required by 40 CFR 

§58.10(b). The needed infonnation is discussed further in the attachment. Upon completion of the state's 

public inspection process, an addendum to the Network Plan containing final proposals for these sites 

must be submitted to the EPA for approval. 

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. 

Thank you for working with us to monitor air pollution and promote healthy air quality in Tennessee. 

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 Gregg Worley at (404) 562-9141 or Sara Waterson at 

(404) 562-9061. 

~·J\ .~ q~~ 

Beverly H. Banister 

Director 

Air, Pesticides and Toxics Management Division 

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

Recycled/Recyclable • Printed with Vegetable OU Based Inks on Recycled Paper (Min mum 30•;, Postconsumer) 
Chattanooga-Hamilton County Air Pollution Control Bureau 

Mr. John Finke, Director 

Nashville I Davidson County Metro Public 

Department Pollution Control Division 
than 10 microns (PM to), 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 (OMB), July 1, 2014, population estimates from 

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

for OJ, PM2.s, and PM10, only apply to metropolitan statistical areas (MSAs), which are a subset of 

CBSAs. OMB currently defines 26 CBSAs in the state ofTennessee. These CBSAs and the respective 

July 1, 2014, population estimates from the U.S. Census Bureau are shown in Table I. 

Table 1: Core Based Statistical Areas and July 1, 2014 Population Estimates 

CBSAName CBSA Type Population . 

Nashville-Davidson--Murfreesboro--Franklin, TN Metropolitan Statistical Area 1,792,649 

Memphis, TN-MS-AR Metropolitan Statistical Area 1,343,230. 

Knoxville, TN Metropolitan Statistical Area 857,585 

Chattanooga, TN-GA Metropolitan Statistical Area 544,559 .. 

Kingsport-Bristol-Bristol, TN-VA Metropolitan Statistical Area 308,079 

Clarksville, TN-KY Metropolitan Statistical Area 278,353 

Johnson City, TN Metropolitan Statistical Area 201,091 

Jackson, TN Metropolitan Statistical Area 130,225 

Cleveland, TN Metropolitan Statistical Area 119,705 

Morristown, TN Metropolitan Statistical Area 115,713 

Cookeville, TN Micropolitan Statistical Area 107,761 

Tullahoma-Manchester, TN Micropolitan Statistical Area 101,344 

Sevierville, Tr-1 Micropolitan Statistical Area 95,110 . 

Greeneville, TN Micropolitan Statistical Area 68,335 

Crossville, TN Micropolitan Statistical Area 57,985 

Athens, TN Micropolitan Statistical Area 52,626 

Shelbyville,TN Micropolitan Statistical Area 46,627 

La~enceburg,TN Micropolitan Statistical Area 42,274 

McMinnville, TN Micropolitan Statistical Area 39,969 

Dyersburg, TN Micropolitan Statistical Area 37,935 

Union City, TN-KY Micropolitan Statistical Area 37,206 

Newport, TN Micropolitan Statistical Area 35,374 

Martin, TN Micropolitan Statistical Area 34,373 

Dayton, TN Micropolitan Statistical Area 32,641 

Paris, TN Micropolitan Statistical Area 32,204 

Lewisburg, TN Micropolitan Statistical Area 31,269 
CFR Part 58 will continue to be met for the respective MSAs after the approved monitors are 

discontinued or relocated. 

Monitors proposed for relocation, change in sampling frequency, or monitor start-up and the EPA's 

determination are summarized in Table 3. 

Table 3: Proposed Changes in Monitoring 

Agency AQS ID Site Name 

TDEC 47-125-1009 Clarksville 

TDEC 47- 105-0108 

TDEC TBD 

Montgomery 

County 

Loudon Pope 

Proposed Site(s) in 

Sullivan County sol nonattainment 

area 

Pollutant Type 

SLAMS 

SLAMS so SLAMS 

Comments 

Pending: The monitor 

will be placed on the 

ground near the existing 

location that the elevated 

platfonn occupies. If a 

suitable location is not 

available in the 

immediate area of the 

platfonn, TDEC proposes 

to relocate the site as 

close as possible to the 

existing location. Once a 

new location is chosen, 

and upon completion of 

the state's public 

inspection process, the 

state will need to submit 

to EPA an addendum to 

the Network Plan 

containing the final site 

ro osal. 

Additional information 

needed for approval: 

proposed to be relocated 

to the fonner Loudon 

Middle School location 

and restarted there. TDEC 

is required to submit a 

network plan addendum 

with a complete proposal 

for this site. 

Additional information 

needed for approval: 

TDEC has proposed new 

SLAMS sites to 

characterize the 

maximum concentrations 

in the Sullivan County 
The network described in the 2015 Network Plan meets the minimum OJ monitoring requirements 

specified by 40 CFR Part 58, Appendix D, Table D-2 in all areas. Additionally, the proposed 03 

monitoring network described in the Network Plan meets all of the design criteria of 40 CFR Part 58. 

TD EC proposed the Loudon Pope 03 site (A QS # 4 7 -I 05-0 I 08) be relocated to the former Loudon 

Middle School location. This is proposed to be completed at the end of the current 2015 monitoring 

season (November 1, 2015 or later) in conjunction with the installation of the new S02 monitoring site 

in Kingsport, TN. TDEC stated that the site installation/relocation is delayed because of issues involved 

in selection of a new S02 site in Sullivan County. Additional information is required for approval of the 

relocation to the Loudon Middle School site. Once the details of the site proposal are finalized, the state 

will need to submit an addendum to the Network Plan. The addendum must include all of the required 

information for proposed sites under40 CFR §58.10(b). The addendum should also include TDEC's 

rationale for the location of the new proposed site, and supporting information about how the site 

location was selected such as site photos, maps, wind roses, etc. We note the 2015 Network Plan states 

the Loudon Pope 03 SLAMS monitoring frequency is 1 in 3 days. Please correct the sampling frequency 

to an hourly monitoring frequency in the 2016 Network Plan. 

The Network Plan states that Chattanooga continues to search for an appropriate new location for the 

Eastside Utility District OJ monitor (AQS # 47-065-4003). We recommend that Chattanooga consult 

with SESD prior to moving the monitor from the existing location in order to meet siting requirements 

in Appendix E. Please note that as soon as Chattanooga identifies a candidate site, the proposed 

revisions to the network, including the identification of monitors to be discontinued or relocated, must 

be submitted to the EPA for approval. 

We note that Nashville has listed the Hillwood High School monitor (AQS # 47-037-0026) as a PM2.s 

monitor. Please correct this to an OJ monitor in the 2016 Network Plan. 

Minimum CO Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.2 

Ambient air monitoring network design criteria for CO are found in Section 4.2 of Appendix D to 

40 CFR Part 58. This section requires CBSAs with populations over one million but less than 2.5 

million to operate one CO monitor collocated with a near-road N02 monitor, by January I, 2017. This 

requirement is met for the Nashville-Davidson-Murfreesboro-Franklin CBSA by the CO monitor 

operating at the Near-road site (AQS # 47-037-0040) and for the Memphis CBSA by the CO monitor 

operating at the Southwest TN Community College site (AQS # 47-157-0100). Therefore, the proposed 

CO monitoring network described in the Network Plan meets all of the design criteria of 40 CFR Part 

58. 
that it is currently meeting the requirements for PWEI required monitors stipulated in 40 CFR 58 

Subpart G, Appendix D to Part 58 as there is no regulatory S02 monitor operating in the KingsportBristol, TN-VA CBSA. Tennessee will meet the requirement once a proposed site in the KingsportBristol, TN-VA CBSA becomes operational. 

TDEC has proposed to establish new S02 monitoring to characterize the maximum S02 concentrations 

in the Sullivan County S02 nonattainment area, but the exact location of the appropriate monitoring has 

not been finalized. Establishment of the new site(s) will take meteorological data and modeled emissions 

impacts into consideration. Once the details of the site(s) are finalized, the state will need to submit an 

addendum to the Network Plan containing the site proposal(s). The addendum must include all of the 

required information for proposed site(s) under40 CFR §58.10(b). The addendum should also include 

TDEC's rationale for selecting the proposed site(s), any monitoring or air modeling data that TDEC 

used to select the site(s), and supporting information, such as site photos, maps, wind roses, and 

information about the target sources. Specifically, supporting information should include, at minimum, 

the following information: 

• Proposed AQS ID 

• Street and site geographical coordinates (longitude and latitude) 

• Map of the area, including the target source 

• Site photos 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 road 

• Probable probe height of the inlet probe from ground level 

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

• Nearest wind rose representative of the site and orientation of the site with respect to the 

predominate wind direction 

• 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, including distances to any nearby trees or obstructions 

Once TDEC develops an S02 monitoring proposal, the state will need to make the information available for public inspection. Upon completion of the public inspection process, the Network Plan addendum 

must be submitted to EPA Region 4 for approval. We will continue to work with your agency as needed to facilitate the establishment of these site(s) as expeditiously as possible. 

EPA finalized the S02 Data Requirements Rule (ORR) on August 10, 2015. This rule will require 

characterization of the air quality near sources with S02 emissions greater than 2,000 tons per year by 

conducting ambient air monitoring or modeling. We encourage your agency to begin having 

conversations with affected sources in your state to determine an agreed upon approach for meeting the 
Minimum PM2.s Monitoring Requirements 

40 CFR Part 58, Appendix A, 3.2.5 

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

The state of Tennessee's PM2.5 monitoring network meets the minimum requirements found in 40 CFR 

Part 58, Appendix D, Table D-5 for all MSAs. All manual PM2.s collocation requirements found in 40 

CFR Part 58, Appendix A, 3.2.5 are also being met. Fifteen percent of each network of manual PM2.s 

methods (at least one site) must be collocated. Additionally, according to Appendix A, 3.2.5.3, 80 

percent of collocated monitors should be deployed at sites with annual mean concentrations within +/-

20 percent of the NAAQS. The PM2.s monitoring network described in the 2015 Network Plan meets all 

ofthe design criteria of 40 CFR Part 58. 

We note that TDEC's Network Plan lists the monitoring objective for AQS # 47-105-0108-88101-1 as 

"max 03 concentration"; however, this is a PM2.s monitor and AQS lists the monitoring objective as 

"population exposure." Please update the monitoring objective in the 2016 Network Plan. 

TDEC proposed to place the Clarksville PM2.5 monitoring site (AQS # 47-125-1009) on the ground near 

the existing elevated platform the monitor now occupies within the next calendar year due to safety 

concerns. Tennessee noted that if a suitable location is not available in the immediate area, site 

relocation will be requested. Ground placement of the monitor would require adherence to 40 CFR Part 

58, Appendix E, 2 Horizontal and Vertical Placement: "the probe or at least 80 percent of the monitoring 

path must be located between 2 and 15 meters above ground level for ... neighborhood or larger spatial 

scale ... PM2.s." Also, the picture of the current site provided in TDEC's Network Plan shows multiple 

obstructions, which are avoided with use of the platform. When choosing a new location for the monitor, 

TDEC should refer to 40 CFR Part 58, Appendix E, 4.a: "buildings or other obstacles ... can act to 

restrict airflow for any pollutant. To avoid this interference, the probe, inlet, or at least 90 percent of the 

monitoring path must have unrestricted airflow and be located away from obstacles. The distance from 

the obstacle to the probe, inlet, or monitoring path must be at least twice the height that the obstacle 

protrudes above the probe, inlet, or monitoring path." 40 CFR Part 58, Appendix E, 4.b goes on to state 

"a probe, inlet, or monitoring path must have unrestricted airflow in an arc of at least 180 degrees. This 

arc must include the prominent wind direction for the season of the greatest pollutant concentration 

potential." We request that TDEC submit a site proposal addendum to EPA for approval prior to moving 

the monitor from the existing platform. 

TDEC noted a number of sites are a candidate for a FEM continuous monitor. Please indicate in future 

network plans which monitors are expected to be changed in the proposed revisions section. 

We understand that transportation authorities in Chattanooga are considering roadwork along Siskin 

Drive next to where the PM2.ssite is located (AQS # 47-065-4002). The project will likely require 

widening Siskin Drive and may require using some of property on which the monitoring site sits. The 
collocation requirement applies." These minimum continuous PM2.s monitoring requirements are 

currently met in all of the MSAs in the state. Also. the continuous PM2.s collocation requirements are 

currently met in all MSAs. Therefore, the continuous PM:u monitoring network described in the 2015 

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

We note two PM2.s continuous monitors have incorrect sampling frequencies listed in the local network 

plans. The sampling frequency for the Lockeland Elementary site in Nashville (AQS # 47-037-0023) is 

listed as 1 in 6 days and the sampling frequency for the Shelby Farms NCore site in Shelby-Memphis 

{AQS # 47-157-0075) is listed as 1 in 3 days. Please update the sampling frequencies in the 2016 

Network Plan. 

PM2.s Background and Transport Sites 

40 CFR Part 58, Appendix D, 4.7.3 

40 CFR Part 58, Appendix D, 4.7.3 requires that "each State shall install and operate at least one PM2.s 

site to monitor for regional background and at least one PM2.s site to monitor for regional transport." 

The following sites were identified in AQS as background (Table 4) and transport sites (see Table 5). 

The PM2 s background and transport sites are not clearly discussed in TDEC's Network Plan, and varies 

slightly from the AQS monitoring objectives noted below. In the 2016 Network Plan, please provide a 

table that clearly states the PM2.s background and transport sites. 

Table 4. PM2.s Background Sites 

AQSID County Name CBSA Short Name Parameter Monitoring Objective 

Descrietion 

47-009-0101 Blount Knoxville, TN Acceptable PM2 s GENERAVBACKGROUND 

AQI & Speciation 

Mass 

47-065-1011 Hamilton Chattanooga, TN-GA PMl.s - Local GENERAUBACKGROUND 

Conditions 

47-099-0002 Lawrence Lawrenceburg, TN PM2.s - Local UPWIND BACKGROUND 

Conditions 

47-099-0002 Lawrence Lawrenceburg, TN Acceptable PM25 UPWIND BACKGROUND 

AQI & Speciation 

Mass 

47-163-1007 Sullivan Kingsport-Bristol- PM1 s Raw Data UPWIND BACKGROUND 

Bristol, TN-VA 

Table 5. PM2.s Trans2ort Sites 

AQSID County Name CBSA Short Name Parameter Monitoring Objective 

Descrie tion 

4 7-009-0 10 I Blount Knoxville, TN PM2.s Raw Data REGIONAL TRANSPORT 
the parameter names were provided in addition to the site descriptions. Please provide the parameter 

name in the 2016 Network Plan.