UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303·8960 

NOV 0 6 2013 

Ms. Myra Reece 

Chief, Bureau of Air Quality Control 

South Carolina Department of Health and 

Environmental Control 

2600 Bull Street 

Columbia, South Carolina 29201 

Dear Ms. Reece: 

Thank you for submitting the State of South Carolina's 2013 annual ambient air monitoring network 

plan (Network Plan) dated July 3, 2013. The Network Plan is required by 40 Code of Federal 

Regulations §58.10. 

The U.S. Environmental Protection Agency Region 4 understands that South Carolina Department of 

Health and Environmental Control (SC DHEC) provided the public a 30-day review period for its draft 

Network Plan. Comments on the draft plan were submitted by three stakeholders and the final Network 

Plan includes the SC DHEC response to these comments. 

With this letter, the EPA Region 4 is approving the Network Plan provided that following changes are 

made: 

1. Ozone (OJ) and sulfur dioxide (802) monitoring sites need to be established in the Myrtle 

Beach-Conway-North Myrtle Beach, SC-NC metropolitan statistical area (MSA). 

2. The proposed discontinuation of the 03 monitor at the Clemson site (AQS ID 45-072-0002) 

in the Greenville-Anderson-Mauldin MSA is not approved. The EPA would be willing to 

consider approving the discontinuation of a different ozone monitoring site in the MSA to 

help meet the stated goal of conserving resources. 

3. The designations for the S02 monitoring sites in three MSAs needs to be switched from 

special purpose monitor (SPM) to state and local air monitoring station (SLAMS). 

4. Air Quality Index reporting for the Myrtle Beach-Conway-North Myrtle Beach, SC-NC 

MSA needs to be initiated once an 03 monitoring site is established. 

S. The designation for the nitrogen dioxide (NOz) monitor at the Greenville Employment 

Security Commission site (AQS ID 045-045-0015) needs to be changed from SPM to 

SLAMS. The EPA Region 4 has selected Greenville ESC to be among the Regional 

Administrator required N02 monitoring sites intended to help protect susceptible and 

vulnerable populations. 

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

Recyled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled P<~per (Minimum 30% Postconsumer) 
Details regarding the basis for the changes summarized above are provided in the enclosed comments 

regarding the Network Plan. 

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

Carolina. If you have any questions or concerns, please contact Gregg Worley at (404) 562-9141 or 

David McNeal at (404) 562-9102. 

~~d'reaneanne M% . Gettle 

Acting Director 

Enclosure 

cc: Laura Ackerman, SESD 

Lynorae Benjaman, APB 

Mr. Robert Brown 

Division Director, Air Planning Development 

and Outreach, SC DHEC 

Mr. Scott Reynolds 

Air, Pesticides and Toxics 

Management Division 

Director, Division of Air Quality Analysis, SC DHEC 

Mr. Thomas Flynn 

Manager, Air Data Analysis and Support Section, SC DHEC 

The Honorable William Harris 

Chief of the Catawba Indian Nation 

Darin Steen, Environmental Services Director 

Catawba Indian Nation 
CY 2013 State of South Carolina 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 state of South 

Carolina's 2013 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 (PM to), 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, 2012, population estimates from 

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

for 0 3, PM2.5, PM10, only apply to metropolitan statistical areas (MSAs), which are a subset ofCBSAs. 

OMB currently defines 10 MSAs in the state of South Carolina. These MSAs and the respective July 1, 

2012, population estimates from the U.S. Census Bureau are shown in Table 1. 

Table 1: Metropolitan Statistical Areas and Populations 

MSAName 

Charlotte-Gastonia-Concord NC-SC 

Greenville-Anderson-Mauldin, SC 

Columbia, SC 

Charleston-North Charleston-Summerville, SC 

Augusta-Richmond County, GA-SC 

Myrtle Beach-Conway-North Myrtle Beach, SC-NC 

Spartanburg, SC 

Florence, SC 

Hilton Head Island-Bluffion-Beaufort, SC 

Sumter, SC 

Minimum 03 Monitoring Requirements 

40 CFR part 58, appendix D, table D-2 

Population 

2,296,569 

842,853 

784,745 

697,439 

575,898 

394,542 

316,997 

206,087 

193,882 

108,052 

Region 4 has detennined that the ozone monitoring network outlined in the Network Plan meets the 

minimum requirements found in 40 CFR part 58, appendix D, table D-2 for nine of the MSAs in South 

Carolina. Due to changes that OMB made to MSA boundaries in February of2013, Brunswick County, 

North Carolina has been added to the Myrtle Beach-Conway-North Myrtle Beach, SC-NC MSA. This 

change has triggered the requirement for an ozone monitor in the MSA, and the 2013 Network Plan 

indicates that the SC Department of Health and Environmental Control (SC DHEC) has entered into 

discussions with North Carolina and other stakeholders to identify an appropriate location for a new 

monitoring site. Once a suitable monitoring location is identified, infonnation regarding the site can be 

provided either as an amendment to the current Network Plan or in next year's Network Plan. 

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The Network Plan includes a proposal to discontinue 03 monitoring at the Clemson site (AQS ID 45-

072-0002). At this time we do not approve the proposal. Please see the section of this letter titled 

"Proposed Monitoring Network Changes" for further discussion regarding this issue. 

Minimum PM to Monitoring Requirements 

40 CFR part 58, appendix A, 3.3.1 

40 CFR part 58, appendix D, table D-4 

Region 4 has determined that the PM10 monitoring network outlined in the Network Plan meets or 

exceeds the minimum requirements found in 40 CFR part 58, appendix 0, table 0-4 for all MSAs. Also, 

all manual PM1o collocation requirements are met. 

Minimum PMz.s Monitoring Requirements 

40 CFR part 58, appendix A, 3.2.5 

40 CFR part 58, appendix D, table D·S 

Region 4 has determined that the PM2..s monitoring network outlined in the Network Plan meets or 

exceeds the minimum requirements found in 40 CFR part 58, appendix D, table 0-5 for all MSAs. Also, 

all PMz.s collocation requirements are met. 

Pl\'lz.s Continuous 1\'lonitoring Requirements 

40 CFR part 58, appendix D, 4. 7.2 

Regulatory provisions for continuous PM25 monitoring require that 'The State, or where appropriate, 

local agencies must operate continuous PM2.s analyzers equal to at least one-half(round up) of 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 FRMIFEMI ARM [Federal Reference 

Method/Federal Equivalent Method/Approved Regional Method] monitors, unless at least one of the 

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

collocation requirement applies." After review of the Network Plan, Region 4 has determined that the 

proposed PM2.s continuous monitoring network meets or exceeds the minimum requirements in all of 

the MSAs in the state. Also, the continuous PM2.5 collocation requirements are met in all MSAs. 

The Network Plan includes a request that data from the continuous PM2.s monitor at the Greenville 

Employment Security (ESC) site (AQS ID 045-045-00 15) not be used for comparison to the national 

ambient air quality standards (NAAQS). This request is made under provisions in 40 CFR 58.ll(e) and 

the Network Plan includes data demonstrating that, under performance criteria in 40 CFR part 53, Table 

C-4, the monitor at the Greenville ESC can be excluded for NAAQS reporting purposes. Therefore, the 

request for the continuous PM2.s monitor at the Greenville ESC site is acceptable. Please update the 

monitor type to "Non-Regulatory" in the Air Quality System (AQS). 

PMz.s Background and Transport Sites 

40 CFR part 58, appendix D, 4. 7.3 

40 CFR part 58, appendix 0, 4.7.3 requires that "Each State shall install and operate at least one PM2 5 

site to monitor for regional background levels and nt least one PM2.s site to monitor for regional 

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transport." The 2013 Network Plan identifies Ashton {AQS ID 45-029-0002) in Colleton County as a 

regional background site and Chesterfield {AQS ID 45-025-0001) in Chesterfield County as a regional 

transport site. Therefore, SC DHEC has satisfied the requirements of 40 CFR part 58 for regional 

background and transport sites. 

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 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 ... " 

Although South Carolina has no sources that exceed the thresholds for Pb monitoring, the Johnson 

Control Battery Group conducts source-based ambient Pb monitoring at three sites around the Florence 

Recycling Center in Florence, South Carolina. The company is conducting this monitoring under terms 

of a settlement agreement reached with several petitioners who commented on the construction permit 

for the facility. Locations for the monitoring sites were selected based upon an agreement between the 

company and the stakeholders. 

40 CFR part 58, appendix D, 3(b) requires that "NCore sites in CBSAs with a population of500,000 

people (as determined in the latest Census) or greater shall also measure Pb either as Pb-TSP or PbPM10." The Network Plan indicates that a Ph sampler is located at the Parklane NCore site (AQS ID 45-

079-0007). 

The Pb 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 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 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. Based upon PWEis 

calculated using the latest population estimates and emission inventory data, the minimum number of 

monitors required for the CBSAs in South Carolina is summarized in Table 2. 

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Table 2: S02 Monitoring System Status 

SLAMS Existing 

CBSAName required SLAMS 

Au;_usta-Richmond County, GA-SC 1 1 

Charleston-North Charleston-Summerville, SC 

Charlotte-Gastonia-Concord NC-SC 2 

Columbia, SC 1 

Greenville-Anderson-Mauldin. SC 0 

Myrtle Bench-Conway-North Myrtle Beach, SC-NC 0 

Based upon the infonnation summarized above, three additional SLAMS will be needed in order to 

satisfy the minimum S02 monitoring requirements for the CBSAs in South Carolina Both the CharlotteGastonia-Concord and Greenville-Anderson-Mauldin CBSAs have existing S02 monitoring sites whose 

designation can be changed from SPM to SLAMS to meet the minimum monitoring requirements. In the 

Charlotte-Gastonia-Concord CBSA, the existing monitor is located at the York site (AQS ID 45-091-

0006) and in the Greenville-Anderson-Mauldin CBSA, the existing monitor is located at the Greenville 

ESC site (AQS ID 45-045-00t 5). 

Due to changes that OMB made to MSA boundaries, Brunswick County, North Carolina has been added 

to the Myrtle Beach-Conway-North Myrtle Beach, SC-NC MSA. This change has triggered the 

requirement for an S02 monitor in the MSA and the 2013 Network Plan indicates that SC DHEC has 

entered into discussions with North Carolina and other stakeholders to identify an appropriate location 

for a new monitoring site. Once a suitable monitoring location is identified, information regarding the 

site can be provided either as an amendment to the current Network Plan or in next year's Network Plan. 

One additional comment that we have regarding S02 monitoring involves the designation for the 

monitor at the Jenkins Avenue Fire Station site (AQS ID 45-019-0046) in the Charleston-North 

Charleston CBSA. In our comments on last year's Network Plan, we indicated that the designation for 

one of the two S02 sites in the CBSA should be changed from SPM to SLAMS in order to meet the 

minimum monitoring requirements in 40 CFR part 58. Although the Network Plan submitted July 3 

identifies both of the S02 sites in the CBSA as SPMs, the monitor at the Jenkins Avenue site is 

designated as a SLAMS in EPA's AQS. Therefore, the monitor designation in the Network Plan should 

be revised so that it is consistent with the information in AQS. This can either be done as a correction to 

this year's plan or in next year's plan. 

N02 Monitoring Requirements 

40 CFR part 58, appendix D, 4.3 

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 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 N02 monitoring sites are found in section 4.3.2 of 

appendix D to 40 CFR part 58. Any CBSA with a population of 500,000 or more persons is required to 

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have a near-road N<h site that monitors expected maximum hourly concentrations near a major road. 

Any CBSA with a population of2,500,000 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 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/tiles/nearroad/NearRoadTAD.pdt: The requirement for near-road 

monitoring in the Charlotte-Gastonia-Concord NC-SC CBSA will be met using a site operated by 

Mecklenburg County's Land Use and Environmental Services Agency (MCLUESA) in Charlotte, North 

Carolina. MCLUESA is presently working to establish the Charlotte near-road N02 monitoring site. No 

other CBSA in South Carolina is currently required to have near-road N02 monitoring. By January, 1 

2017, South Carolina CBSA's with populations over 500,000 will be required to operate near-road N02 

monitoring. 

Ambient air monitoring network design criteria for area-wide ND! 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. The Garinger High School (AQS ID 37-119-0041) currently operated by MCLUESA will 

be used for fulfilling the area-wide N02 monitoring requirement for the Charlotte-Gastonia-Concord 

NC-SC CBS A. No other CBSA in South Carolina is required to have area-wide N02 monitoring. 

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 that "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." 

As part of our review oflast year's Network Plan and through correspondence with SC DHEC, Region 4 

selected the Greenville ESC site (AQS ID 450-045-0015) as one of the locations for a Regional 

Administrator required N02 monitor to help protect susceptible and vulnerable populations. The full list 

ofN02 monitors identified by EPA's Regional Administrators can be found on EPA's website at 

http://www .epa. gov/ttnam ti 1 /svpop. html. 

This selection of the Greenville ESC site is mentioned in this year's plan, but the designation for the 

N02 monitor at the Greenville ESC is still identified as an SPM in the Network Plan. This designation 

needs to be switched from SPM to SLAMS in order for it to operate as a Regional Administrator 

required N02 monitor. 

Air Quality Index (AQI) Reporting 

40 CFR §58.50 

AQI reporting is required in MSAs with populations over 350,000. There are four MSAs in the state of 

South Carolina required to report an AQI: Greenville-Anderson-Mauldin, Columbia, Charleston-North 

Charleston, and Myrtle Beach-Conway-North Myrtle Beach. The Network Plan on Page 3 indicates that 

5 
the daily AQI for all of these areas except Myrtle Beach-Conway-North Myrtle Beach is available on 

EPA's AIRNow web site. Prior to the addition of Brunswick County, North Carolina to the Myrtle 

Beach-Conway-North Myrtle Beach. the population for the MSA did not exceed the threshold for AQI 

reporting. As discussed previously in our comments, 03 and S02 monitors will need to be added to the 

MSA in order to satisfy the minimum requirement in 40 CFR part 58. Once these monitors are installed 

and operating, AQI reporting should also be provided for the Myrtle Beach-Conway-North Myrtle 

Beach MSA. 

Proposed Monitoring Network Changes 

SC DHEC has proposed seven monitoring network changes which are summarized in Table 3. 

Table 3: Proposed Monitoring Network Changes 

AQS ID Pollutant Type Comments 

45-019-0049 PMu continuous SPM Editorial correction 

45-083-0011 PM2J continuous SPM Editorial correction 

45-091-0006 so1 SLAMS Change designation 

45-045-0015 co SLAMS Discontinue monitoring 

45-072-0002 03 SLAMS Discontinue monitoring 

45-029-0002 PM2.s SPM Ch.ange ·designation 

45-073-0001 PM2s SLAMS Change designation 

The first two changes listed in Table 3 are being made to correct errors in a previous Network Plan. The 

continuous PM25 monitors at the Charleston Public Works (CPW) site (AQS ID 45-019-0049) and the 

T.K. Gregg site (AQS ID 45-083-0011) have been in operation since 2008 but were incorrectly deleted 

from a previous Network Plan. Since the proposed changes for the Charleston CPW and the T.K. Gregg 

sites are being made so the Network Plan will reflect the monitors currently in operation, the changes are 

acceptable. 

The Network Plan proposes to switch the designation for the S02 monitor at the York site (AQS ID 45-

091-0006) from SLAMS to SPM. The rationale for this change is that calculations performed during the 

review of last year's Network Plan indicated that the minimum monitoring requirements for the 

Charlotte-Gastonia-Concord MSA could be met without an S02 SLAMS at the York site. However, 

based upon calculations using the latest population and emission inventory data, an S02 SLAMS at the 

York site will be needed in order to meet the minimum monitoring requirements for the CharlotteGastonia-Concord MSA. Therefore, the proposed change in the designation for the S02 monitor at the 

York site is not acceptable. 

The Network Plan indicates that CO monitor was discontinued at the Greenville ESC site (AQS ID 450-

045-0015) in July 2012. 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 CO monitor meets the requirement of 40 CFR § 58.14(c)(l). The monitor has shown 

attainment of the CO NAAQS during the previous five years and has a probability of less than 10 

percent of exceeding 80 percent of the applicable NAAQS during the next three years. Also, since the 

CO monitor at this site is not needed in order to meet the minimum monitoring requirements under 40 

CFR part 58, the monitor shutdown is acceptable. 

6 
The Network Plan proposes to discontinue 03 monitoring at the Clemson site (AQS ID 45-072-0002) in 

Pickens County in order to redirect limited resources to program priorities. The Greenville-AndersonMauldin MSA includes Greenville, Anderson, Laurens, and Pickens Counties and under 40 CFR part 58, 

two 0 3 monitors are required in the MSA. Currently, there are five 0 3 monitors in operation in the MSA. 

These include the Clemson site which has been in operation since 1979 and four newer sites which were 

established between 2008 and 2010. These newer sites are the Big Creek (AQS ID 45-007-0005) site in 

Anderson County, Famoda Farms (AQS ID 45-045-1 003) and Hillcrest Middle School sites (AQS ID 

45-045-0016) in Greenville County, and the WolfCreek site (AQS ID 45-077-0003) in Pickens County. 

The Network Plan states that, based upon an evaluation of the data from the 0 3 sites in the GreenvilleAnderson-Mauldin MSA, SC DHEC has concluded that the WolfCreek site is a more appropriate site 

than the Clemson site for representing 03 concentrations in the portion of the MSA where the sites are 

located. Based upon our review of 03 concentration data from the two sites, we do not agree with the 

proposal to shut down the Clemson site. The basis for this decision is that the available data show that 

peak 0 3 concentrations are consistently higher at the Clemson site than they are at the WolfCreek site, 

and the Clemson site is representative of a more densely populated area than the area represented by the 

WolfCreek site. Below is a summary of several comparisons between the monitoring results at the two 

sites which show that 03 concentrations are higher at the Clemson site: 

1. During 2011 and 2012, the Clemson site had either the highest or second highest 0 3 design 

value in the Greenville-Anderson-Mauldin MSA. Since two 03 monitoring sites are required 

in the MSA, it will be difficult to justify shutting down the Clemson site unless there are at 

least two other sites in the MSA that have a higher design value than the Clemson site. 

2. During 2012, the 03 concentrations used for calculating design values (i.e., the fourth max 

concentration) were significantly higher at the Clemson site [0.068 parts per million {ppm)] 

than they were at the WolfCreek site (0.062 ppm). 

3. During the years when monitoring data are available for both the Clemson and WolfCreek 

sites (2010- 2012), there were three days during which the OJ concentrations exceeded the 

NAAQS at the Clemson site while there were no days when the 0 3 concentrations at the 

WolfCreek site exceeded the NAAQS. · 

4. Figure 3 in the Network Plan shows that the 03 con_centrations at the Clemson site are 

consistently higher than the concentrations at the WolfCreek site. Figure 3 is a graph of the 

highest 8-hour OJ concentrations for the years 201 0 through 2012. This graph demonstrates 

that for three of the four months with the highest OJ concentrations, the concentrations at the 

Clemson site were higher than at the WolfCreek site. 

5. Figure 4 is a graph ofthe diurnal one-hour OJ concentrations for the June through August 

period during 2011 and 2012. This graph demonstrates, that for the peak OJ hours during the 

day, concentrations were higher at the Clemson site than they were at the WolfCreek site. 

Although the information summarized above shows that, based upon the data currently available, the 

WolfCreek site is not a suitable replacement for the Clemson site, we do understand that operating five 

monitors in an MSA where only two sites are required imposes a resource burden on the SC DHEC. 

7 
In order to reduce this resource burden, we would be willing to consider a request to shutdown another 

site in the MSA that is of lower value than the Clemson site. 

The Network Plan proposes to change the designation for the continuous PM2.s monitor at the Aston site 

(AQS ID 45-083-0011) from SPM to SLAMS to reflect the fact that the monitor is used for satisfying 

the requirement for a regional background site. This change is acceptable. 

The Network Plan proposes to change the designation for the continuous PM2.s monitor at the Long 

Creek (AQS ID 45-073-0001) site from SLAMS to SPM due to inadequate performance ofthe FEM that 

was installed in order to replace a FRM at the site. Since a PM2.s SLAMS is not needed at the Long 

Creek site in order to meet the minimum monitoring requirements under 40 CFR part 58, the proposed 

change in monitoring designation is acceptable. 

National Core (NCore) Monitoring Network 

40 CFR part 58, appendix D, 3 

A requirement that each state operate at least one NCore site is found in section 3 of appendix D. The 

SC DHEC proposed Parklane (AQS ID 45-079-00047) as an NCore site in its 2009 Network Plan. 

EPA's Office of Air Quality Planning and Standards granted approval for this site in a letter dated 

October 30, 2009. Following this approval, Pb monitoring was added to the site in 2010. No additional 

changes are proposed for the site in the 2013 Network Plan. 

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