### Mr. Brian Accardo Director UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 SAMNUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA GEORGIA 30303-8960 

### September 11, 2012

Division ofAir Resources Management Florida Department ofEnvironmental Protection 2600 Blair Stone Road Tallahassee, Florida 32399-2400
DearMr. Accardo: Thank you for submitting the state ofFlorida's 2012 Annual Ambient Air Monitoring Network Plan (Network Plan) dated May 2012. TheNetwork Plan is required by40 Code ofFederal Regulations (CFR) 

### § 58.10. TheNetwork Plan covers the ambient air monitoring network operated bythe Florida Department ofEnvironmental Protection and its local agencies. The U.S. Environmental Protection Agency Region 4 understands that the FDEP and its local agencies provided the public a 30-dayreview period and received no comments. According to 40 CFR 

### § 58.10(a)(2), since public inspection and comments have alreadybeen solicited, the EPA is not required to offer another comment period. With this letter, EPA Region 4 is approving the Network Plan with the exception ofN02 monitoring. The state will need to provide additional information on N02 monitoring as described in the enclosure. Once EPA Region 4 is in agreement with the proposed area-wide and near-road N02 sites, the state 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). Wehave enclosed comments on yourNetwork Plan and will continue to work with your agency on the remainingportions ofthe plan that have not been approved with this letter. Thank you for working with us to monitor air pollution and promote clean air in Florida. Ifyou have any questions or concerns, please contact DougNeeley at ( 404) 562-9097 or Daniel Garver at (404) 562- 9839.

# Si**~c9,~~** Beverly H. Banister Director Air, Pesticides and Toxics

Management Division

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)FY 2012 State ofFlorida Ambient AirMonitoring Network Plan U.S. EPA Region 4 Comments and Recommendations

This document contains U.S. EPA Region 4 comments and

.oocommendations on the state ofFlorida's 2012 ambient airmonitoring network plan (Network Plan). Ambient air monitoring 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. Minimum monitoring requirements are listed for ozone (03), particulate matter less than 2.5 microns (PM2

.s), particulate matter less than 10 microns (PMw), nitrogen dioxide (N02), sulfur dioxide (S02), carbon monoxide (CO), and lead (Pb). Theminimum monitoring requirements are based on core based statistical area (CBSA) 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 airmonitoring data. Minimum monitoring requirements for 03, PM2
. 5, PM 10, only apply to metropolitan statistical areas (MSAs), which are a subset ofCBSAs

. OMB currently defines 30 CBSAs 

### inthe state ofFlorida. These CBSAs and therespective July 1, 2011, population estimates from the U.S. Census Bureau are shown in Table 1.
Table 1: Core Based Statistical Areas and July 1, 2011 Population Estimates

CBSA Name CBSA Type Population Miami-Fort Lauderdale-Pompano Beach, FL Metropolitan Statistical Area 5,670,125 Tampa-St. Petersburg-Clearwater, FL Metropolitan Statistical Area 2,824,724 Orlando-Kissimmee-Sanford, FL Metropolitan Statistical Area 2,171,360 Jacksonville, FL Metropolitan Statistical Area 1,360,251 North Port-Bradenton-Sarasota, FL Metropolitan Statistical Area 709,355 Cape Coral-Fort Myers, FL Metropolitan Statistical Area 631,330 Lakeland-WinterHaven, FL Metropolitan Statistical Area 609,492 PalmBay-Melbourne-Titusville, FL Metropolitan Statistical Area 543,566 Deltona-Daytona Beach-OrmondBeach, FL Metropolitan Statistical Area 494,804 Pensacola-FerryPass-Brent, FL Metropolitan Statistical Area 453,218 Port St. Lucie, FL Metropolitan Statistical Area 427,874 Tallahassee, FL Metropolitan Statistical Area 369,758 Ocala, FL Metropolitan Statistical Area 332,529 Naples-Marco Island, FL Metropolitan Statistical Area 328,134 Gainesville, FL Metropolitan Statistical Area 266,369 Crestview-FortWalton Beach-Destin, FL Metropolitan Statistical Area 183,482 Panama City-Lynn Haven-Panama CityBeach, FL Metropolitan Statistical Area 169,856 Punta Gorda, FL Metropolitan Statistical Area 160,511 Homosassa Springs, FL Micropolitan Statistical Area 140,031 Sebastian-Vero Beach, FL Metropolitan Statistical Area 138,894 Sebring, FL Micropolitan Statistical Area 98,630 The Villages, FL Micropolitan Statistical Area 97,756 Palm Coast, FL Metropolitan Statistical Area 97,376 Palatka, FL Micropolitan Statistical Area 74,041 KeyWest,FL Micropolitan Statistical Area 73,873 Lake City, FL Micropolitan Statistical Area 67,485 

### 1Okeechobee, FL Micropolitan Statistical Area 40,140 Clewiston, FL Micropolitan Statistical Area 39,089 Arcadia, FL Micropolitan Statistical Area 34,894 Wauchula, FL Micropolitan Statistical Area 27,887


### Ozone Monitoring Requirements 40 CFR Part 58, Appendix D, Table D-2 The state ofFlorida's proposed 03 monitoring network meets the minimum requirements found in 40 CFR Part 58, Appendix D, Table D-2 for all MSAs. Additionally, the proposed 03 monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58. Sulfur Dioxide (S02) 

### Monitoring Requirements 40 CFR Part 58, Appendix 

### D, 4.4 Ambient air monitoring network design criteria for SOz 

### are found in Section 4.4 ofAppendix D to 40 CFR Part 58. This section requires that "Thepopulation weighted emissions index (PWEn shall be calculated by states for each core based statistical area (CBSA)

..." The S02monitoring 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 type(s): population exposure, maximum concentration, source-oriented, general background, orregional transport. An S02monitor at an NCore stationmay satisfy**mi~mum** 

### monitoring requirements ifthat monitor is located within a CBSA with required monitors under Appendix D, 4.4.
EPA recentlyrecalculated the PWEI values for all CBSAs based on 2011 population estimates and 2009 emissions data. As a result, the minimum monitoring requirements for the Tampa-St. PetersburgClearwater CBSA changed from two required monitors to one. None ofthe other PWEI-based minimum monitoring requirements changed for Florida CBSAs as a result ofthese revised calculations.
To meet the S02 monitoringrequirements, FDEP is proposing new S02 sites in the North PortBradenton-Sarasota, Lakeland-Winter Haven, and Homosassa Springs CBSAs. FDEP is requested to submit full site proposals for these sites once the locations and other details are finalized. The S02 network is required to be operational beginning January 1, 2013. The S02 monitoring network design proposed in the Network Plan meets the minimum requirements of40 CFR Part 58. Nitrogen Dioxide (N02) 

### Monitoring Requirements 40 CFR Part 58, Appendix D, 4.4 Ambient air monitoring network design criteria for N02are found in Section 4.3 ofAppendix D to 40 CFRPart 58. There are three types ofrequired NOz

### monitoring: near-road, area-wide, and Regional Administratorrequired. These types ofNOz 

### 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 N02 monitoring station that monitors expected maximum hourly concentrations near a majorroad. Any CBSA with a population of2,500,000 ormore persons orthat has one ormoreroadway segments with a 250,000 orgreater annual average daily traffic (AADT) count is required to have an additional near-road 2

### N02 monitoring station. TheNear-roadN02 Monitoring TechnicalAssistanceDocument (TAD) provides guidance to state and local agencies in selecting an appropriate near-road N02monitoring location. This document can be found onthe internet at http://www.epa.gov/ttnamti1/files/nearroad/NearRoadTAD.pdf. Ambient air monitoring network design criteria for area-wide N02sites 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 highest N02concentrations representing the neighborhood orlarger spatial scales. Ambient airmonitoring network design criteria for Regional Administrator required N02monitoring, often referred to as RA-40 monitoring, are found in Section 4.3.4 ofAppendix D to 40 CFR Part 58. This section states, "the Regional Administrators, in collaboration with states, must require a minimum offorty additional N02monitoring stations nationwide in any area, inside oroutside ofCBSAs, above the minimum monitoring requirements, with a primary focus on siting these monitors in locations to protect susceptible and vulnerable populations. TheRegional Administrators, working with states, may also consider additional factors

... to require monitors beyond the minimum network requirement." The state will need to provide EPA with an addendum to its network plan containing additional information onits N02 monitoring plans. This addendum must identify which site in each CBSA with a population of 1,000,000 ormore will beused to meet the area-wide monitoring requirement. EPA also requests that FDEP include a recommendation ofany additional existing sites that are sited to protect susceptible and vulnerable populations. The addendum should also include additional information about theproposed near-road monitoring sites. Section 13.5 ofthe near-road N02TAD and Table 13.1 ofthe TAD discuss important site and road parameters when evaluating a near-road site. Using the TAD as a reference, additional information provided on near-road**N~** 

### monitoring should include, at minimum, the following information for each site: • Proposed AQS ID • Street address and site geographical coordinates (longitude and latitude) • Target road segment description including type ofroad • Site pictures facing 4-8 directions- N, S, E, W, NE, NW, SE, SW • Probable distance between the inletprobe and the outside nearest edge ofthe target road • Site property description including property owner and feasibility ofsite access • Roadway design and configuration • Presence ofanyroadside structures • Nearest windrose representative ofthe site and orientation ofthe site with respect to the predominate wind direction • Traffic data and ranking information (see Table 6-3 ofthe Technical Assistance Document), as well as the source and vintage ofthe data • Sampling and 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 area represented bythe monitor • Discussion ofother siting criteria 

### 3Once EPA Region 4 is 

### in agreement with the proposed near-road, area-wide, and Regional Administrator required N02 sites, the state 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, covering both 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 site(s) operational as expeditiously as possible. 

### PM10 Monitoring Requirements 40 CFR Part58, Appendix A, 3.3.1 40 CFR Part58, Appendix D, Table D-4 The state ofFlorida's current PM10 monitoring network meets the minimumrequirements found in 40 CFR Part 58, Appendix D, Table D-4 for all MSAs. Also, all PM10 collocation requirements for manual methods found in40 CFR Part 58, Appendix A, Section 3.3.1 are currentlybeingmet. Fifteen percent of each network ofmanual PM10 methods (at least one site) mustbe collocated. These collocation requirements are assessed at the primary quality assurance organization (PQAO) level. The state of Florida and all ofits local agencies operate under a single PQAO (FDEP). The PM10 monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58. 

### PM2.s Monitoring Requirements 40 CFRPart58, Appendix A, 3.2.5 40 CFR Part 58, Appendix D, Table D-5 The state ofFlorida's current PM2.s monitoring network meets theminimum requirements found in 40 CFR Part 58, Appendix D, Table D-5 for all MSAs. Also, all PM2.s collocation requirements found in 40 CFR Part 58, Appendix A, Section 3.2.5 are currentlybeingmet. Fifteen percent ofeach network of manual PM2.s methods (at least one site) mustbe collocated. The PM2.s monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58. 

### PM2.s Continuous Monitoring Requirements 40 CFR Part 58, Appendix D, 4.7.2 Regulatory requirements for continuous PM2.s monitoringrequire that "

...State, orwhere appropriate, local agencies must operate continuous PM2.s analyzers equal to at least one-half(roundup) the minimumrequired sites listed in Table D-5 ofthis appendix. At least onerequired continuous analyzer in each MSAmustbe collocated with one ofthe required FRMIFEM/ARM [Approved Regional Method] monitors, unless at least one ofthe required FRM/FEM/ ARM monitors is itselfa continuous FEM orARM monitor inwhich case no collocation requirement applies." These minimum continuous PM2.s monitoringrequirements are currentlymet inthe all ofthe MSAs inthe state. Also, the continuous PM2.s collocation requirements are currentlymet in all MSAs. Therefore, the continuous PM2 .s monitoringnetwork described 

### in theNetwork Planmeets all ofthe design criteria of40 CFR Part 58.



### 4

### PM2.s Background and Transport Sites 40 CFRPart58, 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
. 5 site to monitor for regional background and at least one PM2.s site to monitor for regional transport." TheNetwork Plan identifies the Interagency Monitoring for Protected Visual Environments (IMPROVE) PM2.s sites at the St. Mark's National Wildlife Refuge (AQS ID: 12-129-0001) and the Everglades National Park (AQS ID: 12-086-0030) as background sites and the IMPROVE PM2
. 5 site at the ChassahowitzkaNational Wildlife Refuge (AQS ID: 12-017-9000) as a transport site. Therefore, FDEP has satisfied the requirements of40 CFR Part 58 for background and transport sites. 

### Lead (Pb) Monitoring Requirements 40 CFRPart58, Appendix D, 4.5
40 CFR Part 58, Appendix D, 4.5 requires that "At a minimum, there must be one source-oriented SLAMS [State and Local AirMonitoring Station] site located to measure the maximum Ph concentration in ambient airresulting from each non-airport Pb source which emits 0.50 ormore tons peryear and from each airport which emits 1.0 ormore tons per year..." Monitoring is ongoing as required near Envirofocus Technologies Inc. inTampa, which is the onlynon-airport source in the state that emits over0.50 tons peryear (tpy). 40 CFR Part 58, Appendix D, 3(b) requires that "NCore sites in CBSA with a population of500,000 people (as determined inthe latest Census) orgreater shall also measure Pb either as Pb-TSP orPbPMw." This monitoring was required to begin December 27, 2011. TheNetwork Plan indicates that Pb

### PMw sampling is ongoing at the TampaNCore site (AQS ID: 12-057-3002) and will begin at the Broward CountyNCore site (AQS ID: 12-011-0034) when the site begins operation laterthis year. In a separate letter dated July20, 2012, FDEP requested that EPA consider revised emissions data for the Daytona Beach International Airport in Daytona Beach, Florida. Pb monitoring was required near this source because the 2008 National Emissions Inventory indicated that the source emitted greater than 1.0 tpy ofPb. EPAhas reviewed this revised emissions calculations submitted byFDEP, and concurs that the actual Pb emissions from this source are below 1.0 tpy. Therefore, ambient air monitoring is not required at this source. The Pb monitoring network described inthe Network Plan meets all ofthe design criteria of40 CFR Part 58. 

### Operating Schedules 40 CFR 

### § 58.12 Themonitoring network proposed in the Network Plan meets the required operating schedules for all continuous analyzers and all manual Pb, PM2.s. 

### PMw, PM10-2.s, and PM2.s Speciation Trends Network (STN) monitors. The sampling frequency ofthe two STN samplers at sites AQS ID: 12-011-0034 and AQS ID: 12-057-3002 is listed as 1-in-6 days, but FDEP has stated that this is a typographical error and that the sites will continue to operate on a 1-in-3 days schedule as required by40 CFR 

### § 58.12(d)(3).



### 5

### Air Quality Index (AQI) Reporting 40 CFR 

### § 58.50 AQI reporting is required in MSAs with populations over 350,000. There are 12 MSAs in the state of Floridarequired to report an AQI: Miami-Fort Lauderdale-Pompano Beach, Tampa-St. PetersburgClearwater, Orlando-Kissimmee, Jacksonville, Bradenton-Sarasota-Venice, Cape Coral-Fort Myers, Lakeland-Winter Haven, Palm Bay-Melbourne-Titusville, Deltona-Daytona Beach-Ormond Beach, Pensacola-Ferry Pass-Brent, Port St. Lucie, and Tallahassee. TheNetwork Plan includes a link on Page 7 to the FDEP website where this information is available. This satisfies the AQI reporting requirements. 

### MonitoringNetworkChanges Proposed by

### FDEP
In the Network plan FDEP has proposed to discontinue monitoring at one site, the West Sample Road N02 site in Broward County (AQS ID: 12-011-0031). This network modification will coincide with the installation ofa new 

### NOz monitoring site at the Broward County nearroad site. According to 40 CFR 

### § 58.14(c), a request for discontinuation ofa SLAMS monitor will be approved ifthe monitormeets any

·ofthe criteriaunder40 CFR 

### § 58.14(c)(1) through (6). Therequested

### NOz monitormeets the requirement of40 CFR 

### § 58.14(c)(1). Themonitorhas shown attainment ofthe

### NOz NAAQS during the previous five years and has a probability ofless than 10 percent ofexceeding 80percent ofthe applicable NAAQS during the next three years. Also, the

### NOz minimum monitoring requirements found inAppendix D to 40 CFR Part 58 will continue to bemet for the Miami-Fort Lauderdale-Pompano Beach CBSA afterthis network change is made. Therefore, this SLAMS monitoris approved for discontinuation.
FDEP has also proposed several new SLAMS sites in the Network Plan. EPA requests that these sites be submitted for final approval once site locations have been secured. 

### National Core (NCore) MonitoringNetwork
FDEP has designated two NCore sites, AQS ID: 12-057-3002 and AQS ID: 12-011-0034, inthe Network Plan. These sites satisfythe requirement for NCoremonitoring and havebeen approved bythe EPA's Office ofAir Quality Planning and Standards.



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