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 of Air Resources Management 

Florida Department of Environmental Protection 

2600 Blair Stone Road 

Tallahassee, Florida 32399-2400 

Dear Mr. Accardo: 

Thank you for submitting the state of Florida's 2012 Annual Ambient Air Monitoring Network Plan 

(Network Plan) dated May 2012. The Network Plan is required by 40 Code of Federal Regulations 

(CFR) § 58.10. The Network Plan covers the ambient air monitoring network operated by the Florida 

Department of Environmental 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-day review period and received no comments. According to 40 CFR § 

58.1 0( a)(2), since public inspection and comments have already been 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 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. 

Thank you for working with us to monitor air pollution and promote clean air in Florida. If you have any 

questions or concerns, please contact Doug Neeley 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 of Florida Ambient Air Monitoring Network Plan 

U.S. EPA Region 4 Comments and Recommendations 

This document contains U.S. EPA Region 4 comments and.oocommendations on the state of Florida'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. 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 ). 

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, 2011, population estimates from 

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

for 03, PM2.5, PM10, only apply to metropolitan statistical areas (MSAs), which are a subset ofCBSAs. 

OMB currently defines 30 CBSAs in the state of Florida. These CBSAs and the respective 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-Winter Haven, FL Metropolitan Statistical Area 609,492 

Palm Bay-Melbourne-Titusville, FL Metropolitan Statistical Area 543,566 

Deltona-Daytona Beach-Ormond Beach, FL Metropolitan Statistical Area 494,804 

Pensacola-Ferry Pass-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-Fort Walton Beach-Destin, FL Metropolitan Statistical Area 183,482 

Panama City-Lynn Haven-Panama City Beach, 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 

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Okeechobee, 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 of Florida'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 of the design criteria of 40 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 of Appendix D to 40 

CFR Part 58. This section requires that "The population weighted emissions index (PWEn shall be 

calculated by states for each core based statistical area (CBSA) ... " 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 type(s): population exposure, maximum 

concentration, source-oriented, general background, or regional transport. An S02 monitor at an NCore 

station may satisfy mi~mum monitoring requirements if that monitor is located within a CBSA with 

required monitors under Appendix D, 4.4. 

EPA recently recalculated 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 of the other PWEI-based minimum 

monitoring requirements changed for Florida CBSAs as a result of these revised calculations. 

To meet the S02 monitoring requirements, 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 of 40 CFR Part 58. 

Nitrogen Dioxide (N02) Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.4 

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 ofNOz 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 N02 

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

CBSA with a population of 2,500,000 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 

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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 N02 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 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, "the Regional Administrators, in collaboration with states, must require a minimum 

of forty 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 Regional 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 on its N02 monitoring plans. This addendum must identify which site in each CBSA with a 

population of 1,000,000 or more will be used to meet the area-wide monitoring requirement. EPA also 

requests that FDEP include a recommendation of any additional existing sites that are sited to protect 

susceptible and vulnerable populations. 

The addendum should also include additional information about the proposed near-road monitoring 

sites. Section 13.5 of the near-road N02 TAD and Table 13.1 of the 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 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 

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Once 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 of the 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 per 40 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 Part 58, Appendix A, 3.3.1 

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

The state of Florida's current PM10 monitoring network meets the minimum requirements found in 40 

CFR Part 58, Appendix D, Table D-4 for all MSAs. Also, all PM10 collocation requirements for manual 

methods found in 40 CFR Part 58, Appendix A, Section 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 (PQAO) level. The state of 

Florida and all of its local agencies operate under a single PQAO (FDEP). The PM10 monitoring 

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

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 Florida's current PM2.s monitoring network meets the minimum 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 currently being met. Fifteen percent of each network of 

manual PM2.s methods (at least one site) must be collocated. The PM2.s monitoring network described in 

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

PM2.s 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 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 FRMIFEM/ARM [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 the all of the MSAs in the state. Also, the continuous 

PM2.s 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. 

4 
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.

5 

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

The Network 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 Chassahowitzka National Wildlife Refuge (AQS ID: 12-017-9000) as a transport site. Therefore, 

FDEP has satisfied the requirements of 40 CFR Part 58 for background and transport sites. 

Lead (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 source-oriented 

SLAMS [State and Local Air Monitoring Station] site located to measure the maximum Ph 

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 Envirofocus Technologies Inc. in Tampa, which is the only non-airport source in the state 

that emits over 0.50 tons per year (tpy). 

40 CFR Part 58, Appendix D, 3(b) requires that "NCore sites in CBSA with a population of500,000 

people (as determined in the latest Census) or greater shall also measure Pb either as Pb-TSP or PbPMw." This monitoring was required to begin December 27, 2011. The Network Plan indicates that PbPMw sampling is ongoing at the Tampa NCore site (AQS ID: 12-057-3002) and will begin at the 

Broward County NCore site (AQS ID: 12-011-0034) when the site begins operation later this year. 

In a separate letter dated July 20, 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. EPA has reviewed this revised emissions calculations submitted by FDEP, 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 in the Network Plan meets all of the design criteria of 40 CFR 

Part 58. 

Operating Schedules 

40 CFR § 58.12 

The monitoring 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 of the 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 by 40 CFR § 58.12(d)(3). 

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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 

Florida required 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. The Network Plan includes a link on Page 

7 to the FDEP website where this information is available. This satisfies the AQI reporting 

requirements. 

Monitoring Network Changes 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 of a new NOz monitoring site at the Broward County near road site. 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 § 58.14(c)(1) through (6). The requested NOz monitor meets the 

requirement of 40 CFR § 58.14(c)(1). The monitor has shown attainment of the NOz NAAQS during the 

previous five years and has a probability ofless than 10 percent of exceeding 80 percent of the 

applicable NAAQS during the next three years. Also, the NOz minimum monitoring requirements found 

in Appendix D to 40 CFR Part 58 will continue to be met for the Miami-Fort Lauderdale-Pompano 

Beach CBSA after this network change is made. Therefore, this SLAMS monitor is 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) Monitoring Network 

FDEP has designated two NCore sites, AQS ID: 12-057-3002 and AQS ID: 12-011-0034, in the 

Network Plan. These sites satisfy the requirement for NCore monitoring and have been approved by the 

EPA's Office of Air Quality Planning and Standards. 

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