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 of Environmental Protection 

200 Fair Oaks Lane, 1st Floor 

Frankfort, Kentucky 40601 

Dear Mr. Alteri: 

Thank you for submitting the annual ambient air monitoring network plan (Network Plan) for the 

Commonwealth of Kentucky dated June 30, 2014. The Network Plan covers Kentucky's ambient air 

monitoring network which is comprised of assets and resources managed by the Kentucky Division for 

Air Quality (KDAQ) and the Louisville Metro Air Pollution Control District (LMAPCD). The Network 

Plan is required by 40 Code of Federal 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 of Kentucky's Network Plan 

provided the following changes are made: 

We request that LMAPCD change the monitor type of its 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 by these monitors to the AQS parameter code 88101. We do not approve the LMAPCD 

request that data from the monitors not be 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 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 Keith Goff at (404) 562-9137. 

Enclosure 

cc: Mr. Keith Talley 

Director, Louisville Metro Air Pollution 

Control District 

Ms. Stacie L. Masters 

Sincerely, 

7 PbY 4 If· 7---nX:..verly H. Banister 

b Director 

Air, Pesticides and Toxics Management Division 

Acting Manager, Kentucky Division for Air Quality 
CY 2014 Commonwealth of Kentucky Ambient Air Monitoring Network Plan 

The U.S. EPA Region 4 Comments and Recommendations 

This document contains the U.S. EPA Region 4 comments and recommendations on the Commonwealth 

of Kentucky'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 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 (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 by the U.S. Office of Management 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 of Kentucky. These MSAs and the respective July 1, 2013, population estimates 

from the U.S. Census Bureau are shown in Table 1. 

Table 1: Metropolitan Statistical Areas and Populations 

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 03 Monitoring Requirements 

40 CFR Part 58, Appendix D, Table D-2 

Population 

2,137,406 

1,262,261 

489,435 

364,101 

314,280 

272,579 

163,536 

151,465 

116,401 

The network described in the Network Plan meets the minimum 03 monitoring requirements specified 

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

Minimum PMto Monitoring Requirements 

40 CFR Part 58, Appendix A, 3.3.1 

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

The Commonwealth of Kentucky's current PM10 primary 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, 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 level. 
Minimum PMz.s Monitoring Requirements 

40 CFR Part 58, Appendix A, 3.2.5 

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

The Commonwealth of Kentucky's current PMz.s monitoring network meets the minimum requirements 

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 of manual reference and equivalent methods (at least one site) must be collocated. The 

manual collocation requirements for PMz.s are currently being met in the Network Plan. 

PMz.s Continuous Monitoring Requirements 

40 CFR Part 58, 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 of this appendix. At least one required continuous analyzer 

in each MSA must be collocated with one of the required FRMIFEM/ARM [federal reference 

method/federal equivalent method/approved regional method] monitors, unless at least one of the 

required FRMIFEM/ ARM monitors is itself a continuous FEM or ARM monitor in which case no 

collocation requirement applies." These minimum continuous PMz.s monitoring requirements are 

currently met in all MSAs in the Commonwealth. Also, the continuous PMz.s collocation requirements 

are currently met in all MSAs. Therefore, the continuous PMz.s monitoring network described in the 

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

PMz.s Background and Transport Sites 

40 CFR Part 58, 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 of 40 CFR Part 58 for background and transport 

sites. 

Pb Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.5 

The monitoring requirements for Pb are found in 40 CFR Part 58, Appendix D, Section 4.5 (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 urban NCore sites. The Pb 

monitoring network described in the 2014 Network Plan meets all of the design criteria of 40 CFR 

Part 58. 

During March 2012, KDAQ started collecting data from a temporary special purpose Pb monitoring 

station on the Eastern Kentucky University (EKU) property in Richmond to compare with data from the 

Mayfield Elementary School Pb monitor (AQS ID: 21-151-0003). Modeling had indicated that the 

temporary monitor on the EKU property is located in the area of modeled maximum ambient 

concentration for the nearby Enersys facility, while the Mayfield Elementary School monitor is not. 

Data from the EKU Pb monitoring site (AQS ID: 21-151-0005) has indicated Pb levels are significantly 
higher 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 of its control 

system. Preliminary modeling indicates minimal spatial shift in the area of maximum deposition. The 

permanent site at EKU will include collocated high volume Pb samplers and will be designated 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. The EPA approves the discontinuation of the 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 greater than 0.5 tons per year. During July 2010, operation of the 

Salem Elementary Pb monitoring station (AQS ID: 21-207-0001) in Russell Springs began. As allowed 

by 40 CFR Part 58, Appendix D, Section 4.5(a)(ii), the EPA may waive the requirement if the state can 

demonstrate the Pb source will not contribute to a maximum lead concentration in ambient air in excess 

of 50 percent of the NAAQS (based on historical data, modeling, or other means). The Salem 

Elementary monitoring station has operated since July 2010 with no violation of the Pb NAAQS and the 

monitoring data collected at the site indicate Superior Battery does not contribute to a maximum Pb 

concentration in excess of 50 percent of the NAAQS. In the Network Plan, KDAQ has proposed to 

discontinue the Salem Elementary Pb monitoring station on December 31, 2014. Based on our review, 

the EPA Region 4 approves a waiver of the source-oriented monitoring requirement near the Superior 

Battery facility. This waiver should be renewed as part of each five year network assessment or upon 

learning of process changes at the facility that may increase the Pb emissions or ambient concentrations. 

S02 Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.4 

Ambient air monitoring network design criteria for S02 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 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 identified as one of the following site types: population 

exposure, maximum concentration, source-oriented, general background, or regional transport. An S02 

monitor at an NCore station may satisfy minimum monitoring requirements if that monitor is located 

within a CBSA with minimally required monitors consistent with Appendix D, section 4.4. The S02 

monitoring network design outlined in the Network Plan meets the minimum requirements of 40 CFR 

Part 58. 

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. Three types of N02 monitoring are required: near-road, area-wide, and Regional 

Administrator. These types of N02 monitoring are described in sections 4.3.2, 4.3.3, and 4.3.4, 

respectively. 

Ambient air monitoring design criteria for near-road N02 monitoring sites are found in section 4.3.2 of 

Appendix D to 40 CFR Part 58. A near-road N02 monitor is operated by Louisville Metro Air Pollution 

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Control 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 by the 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 CBS As of this size. 

Ambient air monitoring network design criteria for area-wide NOz sites are found in Section 4.3.3 of 

Appendix D to 40 CFR Part 58. The Cannons Lane NOz monitoring site (AQS ID: 21-111-0067) is used 

in fulfillment of the 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 of the area-wide NOz monitoring requirement for the Cincinnati-Middletown CBSA. 

Ambient air monitoring network design criteria for Regional Administrator required NOz monitoring, 

often referred to as RA-40 monitoring, are found in section 4.3.4 of Appendix D to 40 CFR Part 58. 

Under these provisions Regional Administrators must require a minimum of forty additional NOz 

monitoring stations nationwide, with a primary focus on siting these monitors in locations to protect 

susceptible and vulnerable populations. As part of last year's Network Plan review, 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 

AQI reporting is required in MSAs with populations over 350,000 as of the 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. 

Monitoring Network Changes Proposed by KDAQ 

LMAPCD has requested that data from the Met One beta 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 not be considered for comparison to the 

PMz.s NAAQS. The BAM continuous monitors, which are federal equivalent method (FEM) monitors, 

have been operated for longer than two years. Data from SPMs are eligible for comparison to the 

NAAQS after two years of operation. Revisions were made to the monitoring rules on January 15, 2013, 

to include the provisions in 40 CFR Part 58.10(b)(l3) and 58.ll(e) allowing a monitoring agency to 

request that data from PMz.s continuous FEMs not be used for comparison to the NAAQS if the data are 

not of sufficient quality when compared to a collocated federal reference method (FRM) monitor. The 

EPA has determined, however, that comparability with a collocated FRM at the Southwick Community 

Center and Watson Lane air monitoring stations cannot be established at this time due to the data quality 

issues that have led to invalidation of the FRM data collected at the sites during 2012 and prior years. 

Since the continuous FEM monitors represent the only potentially valid, regulatory PMz.s data collected 

in Jefferson County during 2012, the EPA is not approving LMAPCD's request. We have determined 

that data from the BAM monitors at Southwick Community Center and Watson Lane are eligible for 

comparison with the PMz.s NAAQS. LMAPCD is required to change the monitor type of these monitors 

to SLAMS in its subsequent network plans and in AQS, and to continue to report the data collected by 

the monitors to the AQS parameter code 88101. 

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KDAQ intends to replace the BAM continuous PM2.s non-regulatory SPM from the Pikeville Primary 

air monitoring station (AQS ID: 21-195-0002) with a tapered element oscillating microbalance (TEOM) 

continuous SPM by July 31,2014. The BAM monitor began 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 on March 1, 2012. However, updated datasets show that a PWEI monitor is not required in the 

MSA. The EPA approves the discontinuation of the 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 of Calvert City, which is an area of concern 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 City Elementary 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 be moved to other sites in the network. The PMto sampler will be used at the Bloodworth site 

while the meteorological equipment and shelter will be used at the Hopkinsville site. The Xontech VOC 

sampler will be used as a spare for other sites. Shut down is expected to occur on September 30, 2014. 

EPA approval is not required 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) on December 31, 2014, as a cost-saving measure. The Atmos (AQS ID: 21-157-0016), 

Bloodworth (AQS ID: 21-139-0004), and TVA collocated (AQS ID: 21-157-0014) sites will continue to 

collect VOC samples in the Calvert City area. The EPA's approval is not required for changes to SPMs. 

PM2.s Chemical Speciation Network 

The EPA has been conducting an assessment of the Chemical Speciation Network (CSN) in an effort to 

optimize the network and create a network that is sustainable going forward. As a result of this 

assessment, the EPA is defunding a number of monitoring sites, eliminating the CSN PM2.s mass 

measurement, reducing the frequency of carbon blanks, reducing sample frequency at some monitoring 

sites, and reducing the number of icepacks in shipment during the cooler months of the year. As KDAQ 

discusses in the Network Plan, a preliminary list of low-value PM2.s speciation sites to be defunded by 

the EPA includes all three of KDAQ'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 of the PM2.s speciation network once final decisions have been made 

by the EPA, but it is unlikely they will be able to support PM2.s speciation sampling without federal 

funding. The defunding is recommended to take place in January 2015. Final changes to the CSN in the 

Commonwealth of Kentucky should be reflected in the 2015 Network Plan. 

National Core (NCore) Monitoring Network 

The NCore site at Cannons Lane (AQS ID: 21-111-0067) is operated by the LMAPCD. EPA's OAQPS 

approved the site on October 30, 2009. 

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