Mr. Sean Alteri Director UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 

### October 30, 2014

Kentucky Division for Air Quality Department ofEnvironmental Protection 200 Fair Oaks Lane, 1st Floor Frankfort, Kentucky 40601
DearMr. Alteri:
Thank you for submitting the annual ambient air monitoring network plan (Network Plan) for the Commonwealth ofKentucky dated June 30, 2014. The Network Plan covers Kentucky's ambient air monitoring network which is comprised ofassets and resources managedby the Kentucky Division for Air Quality (KDAQ) and the Louisville Metro AirPollution Control District (LMAPCD). The Network Plan is required by 40 Code ofFederal Regulations (CFR) §58.10.
The U.S

. Environmental Protection Agency understands that KDAQ provided a 30-day public comment period during which no comments were received. An additional public inspection period is not required.
With this letter, the EPA Region 4 is approving the Commonwealth ofKentucky's Network Plan provided the following changes are made:
Werequest that LMAPCD change the monitor type ofits Southwick Community Center (Air Quality System (AQS) ID: 21-111-0043) and Watson Lane (AQS ID: 21-111-0051) Met One beta attenuation method (BAM) continuous PMz.s monitors to state and local air monitoring station (SLAMS) monitors in the Network Plan and in AQS, and to continue to report the data collected bythese monitors to the AQS parameter code 88101. Wedo not approve the LMAPCD request that data from the monitors notbe considered for comparison to the PMz

.s national ambient air quality standards (NAAQS). We have determined that data from the BAM monitors at Southwick Community Center and Watson Lane are eligible for comparison with the NAAQS.

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed wKh Vegetable OR Based Inks on Recycled Paper (Minimum 30% Postconsumer)We have enclosed comments on your Network Plan. Thank you for working with us to monitor air pollution and promote healthy air quality in Kentucky. Please let us know ofany problems in meeting any ofthe requirements we have identified. Ifyou have any questions or concerns, please contact Gregg Worley at (404) 562-9141 or Keith Goffat (404) 562-9137.

Enclosure

cc: Mr. Keith Talley Director, Louisville Metro AirPollution Control District
Ms. Stacie L. Masters Sincerely, 

# 7 PbY

# 4 If·

# 7---nX:..verly H. Banister 

# bDirector Air, Pesticides and Toxics Management Division

Acting Manager, Kentucky Division for Air Quality

### CY 2014 Commonwealth ofKentucky Ambient Air Monitoring Network Plan The U.S. EPA Region 4 Comments and Recommendations

This document contains the U.S. EPA Region4 comments and recommendations on the Commonwealth ofKentucky's 2014 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 otherrequirements, are found in40 CFR Part 58. Minimum monitoring requirements for criteria pollutants are listed in40 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 (PM10), nitrogen dioxide (N02), sulfur dioxide (S02), carbon monoxide (CO), and lead (Ph).
The minimum monitoring requirements are based on metropolitan statistical area (MSA) boundaries as defined bythe U.S. Office ofManagement and Budget (OMB), July 1, 2013, population estimates from the U.S. Census Bureau and historical ambient air monitoring data. OMB currently defines nine MSAs in the Commonwealth ofKentucky. These MSAs and the respective July 1, 2013, population estimates from the U.S. Census Bureau are shown inTable 1.

Table 1: Metropolitan Statistical Areas andPopulations MSAName Cincinnati-Middletown, OH-KY-IN Louisville/Jefferson County, KY-IN Lexington-Fayette, KY Huntington-Ashland, WV-KY-OH Evansville, IN-KY Clarksville, TN-KY Bowling Green, KY Elizabethtown, KY Owensboro, KY



### Minimum 

### 03MonitoringRequirements 40 CFRPart58, Appendix D, TableD-2 Population 2,137,406 1,262,261

489,435 364,101 314,280 272,579 163,536 151,465 116,401

Thenetwork described in the NetworkPlanmeets the minimum 03 monitoring requirements specified by40 CFR Part 58, Appendix D, TableD-2 in all areas. 

### Minimum PMto MonitoringRequirements 40 CFRPart58, Appendix A, 3.3.1 40 CFRPart58, Appendix D, TableD-4
The Commonwealth ofKentucky's current PM10 primary monitoring network meets the minimum requirements found in 40 CFR Part 58, Appendix D, TableD-4 for all MSAs. Also, all PM10 collocation requirements for manual methods found in40 CFRPart 58, Appendix A, 3.3.1 are currentlybeing met. Fifteenpercent ofeach network ofmanual PM10 methods (at least one site) must be collocated. These collocationrequirements are assessed at the primary quality assurance organizationlevel.

### Minimum PMz.s Monitoring Requirements 40 

### CFRPart58, 

### Appendix A, 3.2.5 40 

### CFRPart58, 

### Appendix D,

### Table D-5
The Commonwealth ofKentucky's current PMz.s monitoring network meets the minimumrequirements found in 40 CFR Part 58, Appendix D, Table D-5 for all MSAs. Manual PMz

.s collocation requirements are found in 40 CFR Part 58, Appendix A, 3.2

.5. These include the requirement that fifteen percent of each network ofmanual reference and equivalent methods (at least one site) mustbe collocated. The manual collocation requirements for PMz.s are currently being met in the NetworkPlan

. 

### PMz.s Continuous Monitoring Requirements 40 

### CFRPart58, 

### Appendix D,4.7.2 Regulatory requirements for continuous PMz.s monitoring require that"

...State, or where appropriate, local agencies must operate continuous PMz

.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 mustbe collocated with one ofthe required FRMIFEM/ARM [federal reference method/federal equivalent method/approved regional method] monitors, unless at least one ofthe required FRMIFEM/ ARM monitors is itselfa continuous FEM orARM monitor in which case no collocationrequirement applies." These minimum continuous PMz.s monitoring requirements are currently met in all MSAs in the Commonwealth. Also, the continuous PMz.s collocationrequirements are currently met in all MSAs. Therefore, the continuous PMz.s monitoring network described in the NetworkPlan meets all ofthe design criteria of40 CFR Part 58.


### PMz.s Background andTransportSites 40 

### CFRPart58, 

### Appendix D,4.7.3 Forty CFR Part 58, Appendix D, 4.7.3 requires that "Each State shall install and operate at least one PMz.s site to monitor for regional background and at least one PMz

.s site to monitor for regional transport

." The Network Plan identifies the Grayson Lake PMz

.s site (Air Quality System (AQS) ID: 21- 043-0500) as a background site and the Hopkinsville PMz.s site (AQS ID: 21-047-0006) as a transport site. Therefore, KDAQ has satisfied the requirements of40 CFR Part 58 for background and transport sites

. 

### Pb MonitoringRequirements 40 

### CFRPart58, 

### Appendix D, 4.5
The monitoringrequirements for Pb are found in 40 CFR Part 58, Appendix D, Section4.5 (see 75 Federal Register 81126). The emissions threshold for facilities near which source-oriented Pb monitoring is required is 0.5 tons per year
. Pb monitoring is also required at urbanNCore sites. ThePb monitoring network described in the 2014 Network Planmeets all ofthe design criteria of40 CFR Part 58. During March 2012, KDAQ started collecting datafrom a temporary special purpose Pb monitoring station onthe Eastern Kentucky University (EKU) property in Richmond to compare with datafrom the Mayfield Elementary School Pb monitor (AQS ID: 21-151-0003). Modelinghad indicated that the temporary monitor onthe EKU property is located in the area ofmodeled maximum ambient concentration for the nearby Enersys facility, while the Mayfield Elementary School monitor is not. Datafrom the EKU Pb monitoring site (AQS ID: 21-151-0005) has indicated Pb levels are significantlyhigher than at the Mayfield School monitoring site. KDAQ intends to establish a permanent Pb monitoring site at EKU but has delayed the process until Enersys completes improvements ofits control system. Preliminary modeling indicates minimal spatial shift in the area ofmaximum deposition. The permanent site at EKU will include collocated high volume Pb samplers and will bedesignated as a state and local air monitoring station (SLAMS) monitor site. KDAQ will submit a formal site proposal to the EPA after logistical factors have been determined for the EKU site. KDAQ also requests permission to discontinue the collocated Pb sampler at Mayfield Elementary School once the permanent collocated EKU site is established and will continue monitoring with the primary Pb sampler at the Mayfield Elementary School site. TheEPA approves the discontinuation ofthe collocated Pb monitor at Mayfield Elementary School after the permanent collocated site is established at EKU.
In 2009, the Superior Battery facility in Russell Springs was identified by emission inventory data and KDAQ modeling to have Pb emissions greaterthan 0.5 tons per year. During July 2010, operation ofthe SalemElementary Pb monitoring station (AQS ID: 21-207-0001) inRussell Springs began. As allowed by40 CFR Part 58, Appendix D, Section4.5(a)(ii), the EPA may waive the requirement ifthe state can demonstrate the Pb source will not contribute to a maximum lead concentration in ambient air in excess of50 percent ofthe NAAQS (based onhistorical data, modeling, or other means). The Salem Elementary monitoring stationhas operated since July 2010 with no violation ofthe Pb NAAQS and the monitoring data collected at the site indicate Superior Battery does not contribute to a maximumPb concentration in excess of50 percent ofthe NAAQS. Inthe Network Plan, KDAQ has proposed to discontinue the SalemElementaryPb monitoring station onDecember 31, 2014. Based on ourreview, the EPA Region 4 approves a waiver ofthe source-oriented monitoring requirement near the Superior Batteryfacility. This waiver shouldbe renewed as part ofeach five year network assessment orupon learning ofprocess changes at the facility that may increase the Pb emissions or ambient concentrations.


### S02MonitoringRequirements 40 CFRPart58, Appendix D, 4.4
Ambient air monitoring network design criteriafor S02 are found in section4.4 ofAppendix D to 40 CFR Part 58. This sectionrequires that "Thepopulation weighted emissions index (PWEI) shall be calculated by states for each core based statistical area (CBSA)

..." As a result, 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 identified as one ofthe following site types: population exposure, maximumconcentration, source-oriented, general background, orregional transport. An S02 monitor at an NCore station may satisfy minimum monitoring requirements ifthat monitor is located within a CBSA with minimally required monitors consistent with Appendix D, section4.4. The S02 monitoring network design outlined in the Network Plan meets the minimumrequirements of40 CFR Part 58.


### N02MonitoringRequirements 40 CFRPart58, Appendix D, 4.4
Ambient air monitoring network design criteriafor N02 are found in Section4.3 ofAppendix D to 40 CFR Part 58. Three types ofN02monitoring are required: near-road, area-wide, and Regional Administrator. These types ofN02 monitoring are described in sections 4.3.2, 4.3.3, and 4.3.4, respectively.
Ambient air monitoring design criteria for near-road N02monitoring sites are found in section4.3.2 of Appendix D to 40 CFR Part 58. A near-road N02 monitor is operated byLouisville Metro AirPollution


### 3Control District (LMAPCD) for the Louisville/Jefferson County CBSA at the Durrett Lane monitoring site (AQS ID: 21-111-0075) and a near-road N02 monitor is operated bythe Southwest Ohio Air Quality Agency for the Cincinnati-Middletown CBSA. CBSA's with populations between 500,000 and 1,000,000 are currently required to operate a near-road N02 monitoring site starting in January 1, 2017. A new N02 monitoring rule is expected to be promulgated in 2016. The new rule may change the requirements for CBSAs ofthis size.
Ambient air monitoring network design criteria for area-wide NOz sites are found in Section4.3.3 of Appendix D to 40 CFR Part 58. The Cannons Lane NOz monitoring site (AQS ID: 21-111-0067) is used in fulfillment ofthe area-wide NOz monitoring requirement for the Louisville/Jefferson County CBSA and the Northern Kentucky University NOzmonitoring site (AQS ID: 21-037-3002) is used in fulfillment ofthe area-wide NOz monitoring requirement for the Cincinnati-Middletown CBSA.
Ambient air monitoring network design criteria for Regional Administratorrequired NOz monitoring, often referred to as RA-40 monitoring, are found in section 4.3.4 ofAppendix D to 40 CFRPart 58. Under these provisions Regional Administrators must require a minimum offorty additional NOz monitoring stations nationwide, with a primary focus on siting these monitors in locations to protect susceptible and vulnerable populations. As part oflast year's Network Planreview, Region 4 selected the Lexington Primary NOz monitor (AQS ID: 21-067-0012) as a location for an RA-40 NOz monitoring site.
Air Quality Index (AQI) Reporting 40 CFR §58.50 AQIreporting is required in MSAs with populations over 350,000 as ofthe last official U.S. census. KDAQ is required to report an AQI for four MSAs: Cincinnati-Middletown, Louisville/Jefferson County, Lexington-Fayette, and Huntington-Ashland. KDAQ meets this requirement. MonitoringNetwork Changes Proposed by KDAQ
LMAPCD has requested that datafrom the Met Onebeta attenuation method (BAM) continuous PMz.s special purpose monitors (SPM) from the Southwick Community Center (AQS ID: 21-111-0043) and Watson Lane (AQS ID: 21-111-0051) air monitoring stations notbe considered for comparisonto the PMz.s NAAQS. The BAMcontinuous monitors, which are federal equivalent method (FEM) monitors, have been operated for longer than two years. Datafrom SPMs are eligible for comparison to the NAAQS aftertwo years ofoperation. Revisions were made to the monitoring rules onJanuary 15, 2013, to include the provisions in 40 CFRPart 58.10(b)(l3) and 58.ll(e) allowing a monitoring agency to request that data from PMz.s continuous FEMs notbe used for comparison to the NAAQS ifthe data are not ofsufficient quality when compared to a collocated federal reference method (FRM) monitor. The EPAhas determined, however, that comparability with a collocated FRM at the Southwick Community Center and Watson Lane air monitoring stations cannotbe established at this time due to the data quality issues thathave led to invalidation ofthe FRM data collected at the sites during 2012 and prior years. Since the continuous FEM monitors represent the onlypotentially valid, regulatory PMz.s data collected in Jefferson County during 2012, the EPA is not approving LMAPCD's request. Wehave determined that data from the BAM monitors at Southwick Community Center and WatsonLane are eligible for comparison with the PMz

.s NAAQS. LMAPCD is required to change the monitor type ofthese monitors to SLAMS in its subsequent networkplans and in AQS, and to continue to report the data collectedby the monitors to the AQS parameter code 88101.



### 4KDAQ intends to replace the BAM continuous PM2.s non-regulatory SPMfrom the Pikeville Primary air monitoring station (AQS ID: 21-195-0002) with a tapered element oscillating microbalance (TEOM) continuous SPMbyJuly 31,2014. The BAM monitorbegan operation on August 1, 2012. KDAQ intends to discontinue the special purpose S02 monitor at the Hopkinsville air monitoring station (AQS ID: 21-047-0006) on October 31, 2014. The monitor was originally established as a PWEI monitor onMarch 1, 2012. However, updated datasets show that a PWEI monitor is not required in the MSA. The EPA approves the discontinuation ofthe monitor. KDAQ plans to discontinue sampling for carbonyls at the Ashland Primary air monitoring station (AQS ID: 21-019-0017) and at the Lexington Primary air monitoring station (AQS ID: 21-067-0012) on December 31,2014, as a cost-saving measure. The EPA's approval is not required for this change. KDAQ plans to establish a 

### PMw SPM at the Bloodworth air monitoring station (AQS ID: 21-139-0004). 

### PMw filters will be sent to ERG for metals analysis, following gravimetric analysis by KDAQ. The Bloodworth site is located downwind ofCalvert City, which is an area ofconcern for air toxics. The Bloodworth site is currently equipped with a VOC sampler and a meteorological station. KDAQ requests permission to shut down the Calvert CityElementary air monitoring site (AQS ID: 21- 157-0018) which is equipped with a Xontech VOC sampler, a 

### PMw SPM, and a meteorological tower. Filters from the 

### PMw sampler are submitted to ERG for metals analysis. Equipment from the shutdown site will bemoved to other sites in the network. The PMto sampler will be used at the Bloodworth site while the meteorological equipment and shelterwill beused at the Hopkinsville site. TheXontech VOC sampler will beused as a spare for other sites. Shut down is expected to occur on September 30, 2014. EPA approval is notrequired for changes to SPMs, but we acknowledge this change. KDAQ intends to discontinue the VOC SPM at the Lazy Daz air monitoring site (AQS ID: 21-157- 0019) onDecember 31, 2014, as a cost-saving measure. TheAtmos (AQS ID: 21-157-0016), Bloodworth (AQS ID: 21-139-0004), andTVA collocated (AQS ID: 21-157-0014) sites will continue to collect VOC samples in the Calvert City area. The EPA's approval is notrequired for changes to SPMs.
PM2.s Chemical Speciation Network
TheEPAhas been conducting an assessment ofthe Chemical Speciation Network (CSN) in an effort to optimize the network and create a network that is sustainable going forward. As a result ofthis assessment, the EPA is defunding a numberofmonitoring sites, eliminating the CSNPM2.s mass measurement, reducing the frequency ofcarbonblanks, reducing sample frequency at some monitoring sites, and reducing the numberoficepacks in shipment during the coolermonths ofthe year. As KDAQ discusses in the Network Plan, a preliminary list oflow-value PM2.s speciation sites to be defunded by the EPA includes all three ofKDAQ's speciation sites: Grayson Lake (AQS ID: 21-043-0500), Ashland Primary (AQS ID: 21-019-0017), and Lexington Primary (AQS ID: 21-067-0012). KDAQ indicates that it intends to re-evaluate the future ofthe PM2.s speciation network once final decisions have been made bythe EPA, but it is unlikely they will be able to support PM2.s speciation sampling without federal funding. Thedefunding is recommended to take place in January 2015. Final changes to the CSN in the Commonwealth ofKentucky shouldbereflected in the 2015 NetworkPlan. National Core (NCore) MonitoringNetwork
The NCore site at Cannons Lane (AQS ID: 21-111-0067) is operated bythe LMAPCD. EPA's OAQPS approved the site onOctober 30, 2009. 

### 5