Tennessee Department 

of Environmental Conservtion 

401 Church Street 9' Floor, L & C Annex 

Nashville, Tennessee 37243- 1 53 1 

Dear Mr. Step ns: pi b: .Thank you for submitting the State of Tennessee's 201 1 annual ambient air monitoring network plan 

(Network Plan), dated July 1,201 1. The Network Plan is required by 40 Code of Federal Regulations 

(CFR) $58.10 and covers the networks operated by the Tennessee Department of Environment and 

Conservation's Division of Air Pollution. Control and the local air pollution control agencies in 

Tennessee. The local agencies covered by this Network Plan include: the Knox County Health 

Department's Department of Air Quality Management, Chattanooga-Hamilton County's Air Pollution 

Control Bureau the Memphis/Shelby County Health Department's Air Pollution Control Program, and 

the Nashville Metropolitan Health Department's Division of Air Pollution Control. 

The U.S. Environmental Protection Agency Region 4 understands that TDEC provided the public a 30- 

day review period. Public comments were received fiom two commenters regarding the Network Plan. 

One commenter, a citizen, supported the Network Plan. The other commenter, EPA Region 4, provided 

technical comments which were addressed in full by Tennessee in its final submittal. 

Based upon our review of the Network Plan, EPA Region 4 has determined that the plan satisfies the 

applicable requirements of 40 CFR Part 58. The Network Plan is approved. Comments and 

recommendations on the document are enclosed. 

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

and the nation. If you have any questions or concerns, please contact Doug Neeley at (404) 562-9097 or 

Stacy Harder at (404) 562-9042. 

Sincerely, 

Gwendolyn Keyes Fleming . 

Regional Administrator 

Enclosures 

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

RecycledlRecyclable Printed wlth Vegetable 011 Based Inks on Recycled Paper (Minrmum 30% Postconsumer) 
Department of Air Quality Management 

Mr. Rob Raney, PE 

Director, Nashville1 Davidson Co. Metro Health Department Division of Air Pollution Control 

Mr. Robert Rogers 

Manager, Memphis-Shelby County Health Department 

Air Pollution Control Section 
q

, 

g 

q

, 

g 

requirements for criteria pollutants are listed in 40 CFR Part 58, Appendix D. Minimum monitoring 

requirements do not exist for carbon monoxide (CO) unless required by the establishment of a National 

Core (NCore) multipollutant monitoring station, andlor a state implementation plan. However, new 

national ambient air quality standards (NAAQS) were promulgated in 201 0 for nitrogen dioxide (NO2) 

and sulfur dioxide (SO2) with minimum monitoring requirements effective January 1,20 13. Monitoring 

requirements for NO2 will be addressed in 2012 Network Plans. Additional information pertaining to 

NO2 and a technical assistance document can be found at: http://www.epa.nov/tt~~/amtic/nearroad.html. 

Minimum monitoring requirements are listed for ozone (03), particulate matter less than 2.5 microns 

(PM2.5), particulate matter less than 10 microns (PMlo), lead (Pb), and SO2. 

The minimum monitoring requirements are based on metropolitan statistical area (MSA) boundaries as 

defined by the US. Office of Management and Budget (OMB), July 1,2009, population estimates fiom 

the U.S. Census Bureau and historical ambient air monitoring data. OMB currently defines 10 MSAs in 

the State of Tennessee. These MSAs and the respective July 1,2009, population estimates from the US. 

Census Bureau are shown in Table 1. 

Table 1: Tennessee Metropolitan Statistical Areas and Populations , 

MSA Name Population Chattanooga, TN-GA 524,303 

Clarksville. TN-KY 268.546 

Cleveland. TN 1 13.358 

Jackson, TN 113,629 

Johnson City, TN 197,381 

Kingsport-Bristol-Bristol, TN-VA 305,629 

Knoxville. TN 699.247 

Memphis, TN-MS-AR 1,304,926 

Morristown. TN 137.612 

Minimum O3 Monitoring ~e~uirements 40 CFR Part 58, Appendix D, Table D-2 The network described in the 201 1 Network Plan meets the minimum O3 monitoring requirements 

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

The Network Plan states that Chattanooga-Hamilton County plans to relocate the Eastside Utility 

District O3 monitor (AQS 47-065-4003) before the start of the 2012 ozone season due to continued 

difficulty in accessing the site. Please note that as soon as a new site is selected, revisions to the 

network, including discontinuation or relocation of a monitor, must be formally submitted to EPA for 

approval. 
40 CFR Part 58, Appendix A 3.3.1 

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

The State of Tennessee's current PMlo primary monitoring network meets the minimum requirements 

for all areas. All PMlo collocation requirements for manual methods found in 40 CFR Part 58, Appendix 

A 3.3.1 are currently being met. Fifteen percent of each network of manual PMlo methods (at least one 

site) must be collocated. Also, the sites with collocated monitors should be among those measuring 

annual mean concentrations in the highest 25 percent of the network. These collocation requirements are 

assessed at the primary quality assurance organization (PQAO) level. The State of Tennessee and all of 

its local agencies operate under a single PQAO (TDEC) for manual PMlo sampling. 

The Network Plan states that Tennessee will evaluate the possibility of discontinuing the Jackson PMlo 

site (AQS 47-1 13-0003) by the end of 201 1. Per 40 CFR Part 58, Appendix D, Table D-4, based on a 

population of less than 250,000 and low concentrations, the Jackson MSA is not currently required to 

monitor for PMlo. EPA is approving the discontinuation of this monitor, should Tennessee choose to 

shutdown the site. 

On July 12,201 1, EPA received a request from Knox County to discontinue PMlo monitoring at the 

Davanna Street site (AQS 47-093-101 3) and receive a waiver for all PMlo monitoring requirements of 

40 CFR Part 58. Ambient air monitoring criteria for PMlo are found at 40 CFR Part 58, Appendix D 4.6 

and Table D-4. This section requires that, at a minimum, there must be one-two PMlo SLAMS located to 

measure a middle or neighborhood scale in low concentration areas with populations of 500,000 to 

1,000,000. EPA has reviewed this information and is disapproving Knox County's request to 

discontinue PMlo monitoring at this site because the site is needed to meet the minimum monitoring 

requirements described above. We suggest that Knox County replace its manual PMlo sampler with a 

continuous sampler, which would allow them to discontinue collocation at this site and conserve 

resources. Note that the Tennessee PQAO is required to meet PMlo collocation requirements as a whole, 

as described above. 

Minimum PMzes 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 current PM2.5 monitoring network meets the minimum requirements found in 

40 CFR Part 58, Appendix D, Table D-5 for all MSAs. 

Also, all manual PM2.5 collocation requirements found in 40 CFR Part 58, Appendix A 3.2.5 are 

currently being met. Fifteen percent of each network of manual PM2.5 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 +I- 20 percent of the NAAQS. The PM2.5 
local agencies must operate continuous PM2.5 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 FRMJFEWARM [federal reference 

methodlfederal equivalent method lapproved 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 PM2.5 monitoring requirements are 

currently met in all of the MSAs in the State. Also, the continuous PM2.5 collocation requirements are 

currently met in all MSAs. Therefore, the continuous PM2.5 monitoring network described in the 201 1 

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

PM2.5 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 PM2.5 site to monitor for regional transport." 

The 201 1 Network Plan identifies sites in Blount County (AQS 47-009-0101) and Hamilton County 

(AQS 47-065-0031,47-065-1011) as regional transport sites, and sites in Blount County (AQS 47-009- 

0101) and Sullivan County (AQS 47-163-3003,47-163-1007) as regional background sites, as well as 

several others located in non-MSNcore based statistical area (CBSA) areas. Therefore, TDEC has 

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

Pb Monitoring Requirements 

40 CFR Part 58, Appendix D 4.5 

EPA recently revised the monitoring requirements for lead found at 40 CFR Part 58, Appendix D 

Section 4.5 (see 75 Federal ~egister 81 126). These revisions reduced the emissions threshold for 

facilities near which source-oriented Pb monitoring is required from 1.0 tons per year (tpy) to .0.5 tpy. 

The rule also removed population based monitoring requirements for Pb, and replaced them with a 

requirement to monitor for Pb at urban NCore sites. 

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 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.. ." Currently, there is existing 

monitoring required near two sources in Tennessee: Exide Technologies in Bristol and Gerdau 

Ameristeel in Knoxville. 

The State of Tennessee has requested that EPA consider revised emissions data related to sourceoriented Pb monitoring requirements. Tennessee has submitted information indicating that the actual Pb 

emissions from the following sources are below 0.50 tpy: 
SO2 Monitoring Requirements 

40 CFR Part 58, Appendix D 4.4 

Ambient air monitoring network design criteria for SO2 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 SO2 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. A SO2 monitor at a 

National Core (NCore) station may satisfy minimum monitoring requirements if that monitor is located 

within a CBSA with minimally required monitors consistent with Appendix D 4.4. 

Tennessee has requested to use the Look Rock NCore monitoring site's SO2 monitor to meet the PWEI 

requirement of one SO2 monitor for the Knoxville CBSA. However, because this site is not urban in 

nature and because only one SO2 monitor is required in the Knoxville CBSA, EPA recommends that 

Tennessee establish a population exposure or maximum concentration site in order to satisfy the 

minimum SO2 monitoring requirements for this area. 

Tennessee is required to operate one SO2 monitor in the Kingsport CBSA. Currently, there is a sourceoriented SO2 monitor operated by the Tennessee Eastrnan facility at the Ross N. Robinson School. 

Tennessee has requested permission to use this monitor to satisfy the minimum SO2 monitoring 

requirements for the Kingsport CBSA. Region 4 is in consultation with the Office of Air Quality 

Planning and Standards (OAQPS) regarding the request and will provide a response when it becomes 

available. 

Air Quality. Index (AQI) Reporting 40 CFR 5 58.50 

AQI reporting is required for MSAs with populations of 350,000 or more according to the July 1,2000 

U.S. Census. There are four MSAs in the State of Tennessee that meet this criterion: Chattanooga, 

Tennessee-Georgia; Knoxville, Tennessee; Memphis, Tennessee-Mississippi-Arkansas; and NashvilleDavidson-Murfkeesboro, Tennessee. The Network Plan indicates that AQI reporting is occurring in each 

of these MSAs. Currently, TDEC is also voluntarily providing AQI reporting for the Kingsport-Johnson 

City-Bristol, Bristol, ~ehessee-~irginia combined statistical aiea, and the Clarksville-Montgomery 

County combined statistical area. The State's actions satisfy the AQI reporting requirements. 
The Look Rock NCore site (AQS 47-009-0101) is designated as a rural site located at high altitude in 

Great Smoky Mountain National Park and is being operated as a collaborative effort between the 

National Park Service (NPS), the Tennessee Valley Authority (TVA), TDEC and EPA. This monitoring 

site has been in operation for a number of years and is currently collecting several compounds. Since the 

Look Rock NCore site is not part of the official national NCore network, the parameters monitored and 

operatioaal procedures do not need to adhere directly to those specified in 40 CFR Part 58. The 

functionality, parameters to be monitored, and operational guidelines of the Look Rock site will be 

based on the data needs of NPS, TVA, TDEC, EPA Region 4 and OAQPS. These collaborators are 

expected to work together to define and provide the operational resources needed and to determine how 

long the site will operate. 

Memoranda of Agreement (MOA) with Neighboring States Finally, Tennessee and Kentucky have a monitoring memorandum of agreement (MOA) with regard to 

O3 and continuous PM2.5 monitoring. In addition, Tennessee, Arkansas and Mississippi have a MOA 

regarding monitoring of PMlo, PMz.5 and 03. Previous correspondence between TDEC and EPA 

indicated that the State would pursue a MOA with the Commonwealth of Virginia governing the 

monitoring responsibilities in the Bristol, Tennessee/Bristol, Viidnia area. If and when it enters into a 

MOA with the Commonwealth, TDEC should update its Network Plan to reflect that change.