Mr. Justin Green Director UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303·8960 October 29, 2015 Division of Air Resources Management Florida Department
of Environmental Protection 2600 Blair Stone Road Tallahassee, Florida 32399-2400 Dear Mr

. Green: Thank you for submitting the State of Florida's 2015 annual ambient air monitoring network plan (Network Plan) dated May 2015. 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 (FDEP) and the local air quality agencies
in Florida. The U

. S. Environmental Protection Agency Region

4 understands that FDEP provided the public

a 30- day review period and received no comments

. According

to 40 CFR
§ 58.10(a)(2), since public inspection and comments have already been solicited, the EPA is not required
to offer another comment period. The EPA approves the State's 2015 Network Plan with the exception of the proposals for three monitoring sites

. As we have discussed, once you have all the information needed for full evaluation of these proposed sites (two near-road monitoring sites and one source-oriented S02 site) we will review and respond
to your request as discussed
in the enclosure. After we have reached an agreement with the proposed locations for these sites, the state will need to make that information available for public inspection

. Upon completion
of the public inspection process, an addendum

to the Network Plan will need to be submitted
to the EPA Region

4 for approval. We have enclosed comments
on the Network Plan and details of our review. 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 Gregg Worley at (404) 562-9141
or Daniel Garver at (404) 562-9839

. Sincerely, iE£ **J.t~ ~**  /1-"ir Air, Pesticides and Toxics Management Division Enclosure

Internet Address (URL)

• http://www.epa.gov Recycled/Recyclable

• Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30 % Postconsumer)cc: Mr. Jeffery Hal s ey Director , Air Quality Division, Broward County

Ms . Malli k a Muthiah Chief, Miami-Dade County Air Quality Management Division

Ms. Melissa Long Chief, Environmental Quali t y Division, City of Jacksonv ill e

Mr. Jerry Campbell, PE Director, Hillsborough County Environmental Protection Commission, Air Management Division

Mr. Ajaya Satyal Director, Pinellas County Air Quality Division

Mr. Laxmana Tallam Palm Beach County Divi s ion of Environmental Health and Engineering Services,

Air P o ll u tion Contro l Section

Ms . Renee Parker Environmental Program s Supervisor, Orange County Env i ronmental Protect i on Division Air

Pollution Control Program

Mr. Ray Smith

D i rector, Collier County Pollution Control & Prevention Department

Mr . Gre g Blanchard
Air Quality Manager, Manatee County Environmental Management Department

Mr. John Hickey, P.E . Manager, Sarasota County A i r & Water Quality

Ms . Laura Ackennan EPA Reg i on 4 SESD2015 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 recommendations

on the state of Florida's 2015 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 (OJ), particulate matter less than 2.5 microns (PM2.s), particulate matter less than 10 microns (PMto), nitrogen dioxide (N02), sulfur dioxide (SOz), carbon monoxide (CO), and lead (Pb). The minimum monitoring requirements
are based on core based statistical area (CBSA) boundaries

as defmed by the U.S

. Office of Management and Budget (OMB), July 1, 2014, population estimates from the U.S. Census Bureau, and historical ambient air monitoring data. Minimum monitoring requirements for OJ, PM2.s, and PM to, only apply to metropolitan statistical areas (MSAs), which are a subset of CBSAs. OMB currently defines 29 CBSAs
in the state of Florida. These CBSAs and the respective July 1, 2014, population estimates from the U.S. Census Bureau are shown in Table I. Table
1: Core Based Statistical Areas and July 1, 2014 Population Estimates CBSA Name

CBSA Type Population Miami-Fort Lauderdale-West Palm Beach, FL Metropolitan Statistical Area 5,929,819 Tampa-St

. Petersburg-Clearwater,

FL Metropolitan Statistical Area 2,915,582 Orlando-Kissimmee-Sanford,

FL Metropolitan Statistical Area 2,321,418 Jacksonville, FL Metropolitan Statistical Area 1,419.127 North Port-Sarasota-Bradenton,

FL Metropolitan Statistical Area 748,708 Cape Coral-Fort Myers, FL Metropolitan Statistical Area 679,513 Lakeland- Winter Haven, FL Metropolitan Statistical Area 634,638 Deltona-Daytona Beach-Ormond Beach, FL Metropolitan Statistical Area 609,939 Palm Bay-Melbourne-Titusville,

FL Metropolitan Statistical Area 556,885 Pensacola-Ferry Pass-Brent, FL Metropolitan Statistical Area 474,081 Port St. Lucie, FL Metropolitan Statistical Area 444,420 Tallahassee, FL Metropolitan Statistical Area 375,751 Ocala, FL Metropolitan Statistical Area 339,167 Naples-Immokalee-Marco Island, FL Metropolitan Statistical Area 348,777 Gainesville,
FL Metropolitan Statistical Area 273,377 Crestview-Fort Walton Beach-Destin,
FL Metropolitan Statistical Area 258,042 Panama City, FL Metropolitan Statistical Area 194,929 Punta Gorda

, FL Metropolitan Statistical Area 168,474 Homosassa Springs, FL Metropolitan Statistical Area 139,377 Sebastian-Vera Beach, FL Metropolitan Statistical Area 144,755 Sebring, FL Metropolitan Statistical Area 98,236 The Villages, FL Metropolitan Statistical Area 114,350 Palatka, FL Micropolitan Statistical Area 72.143 3Key Wes t, FL. Lake Ci t y, FL Okeechobee, FL. Clewiston, FL. Arcadia, FL Wauchula, FL Proposed Monitoring Network Changes

40 CFR § 58.10(b), 58.14 Micropolitan Statistical Area 77,136 Micropolitan Statistical Area 67,857

M i cropolitan Statistica l Area 39 , 149 Micropolitan Statistical Area 38,505 Micropolitan Statistical Area 35,012 Micropolitan Statistical Are a 27,469

In the Network Plan, FDEP has proposed several new monitoring sites. The Daniela Banu NCore site in

Broward County, the St. Marks NCore site, and the Orlando 1-4 near-road site have been approved by

EPA in previous Ne t work Plans. The remainder of the Network Plan changes will require FDEP to

submit additional information before they can be approved. FDEP is requesting to submit final proposals

for these proposed network additions or discontinuations that include all of the information required for

approval by 40 CFR §58.10(b) or §58.14, as applicable. Once EPA Region 4 and FDEP are in

agreement about the details o f these sites, the proposals should be submitted as an addendum to the 2015

Network Plan or as part of the 2016 plan, and should be made available for public inspection before

submittal to EPA for approvaL The following three proposed sites must begin operating in order for the

FDEP monitoring network to meet minimum requirements : the MDX near-road site in Miami-Dade

County, the Sawgrass Lake Parkway near-road site in Pinellas County, and the source-oriented S02 site

near the Duke Energy Crystal River Steam Plant in Citrus County. A summary of the monitoring

network changes proposed by **FDEP ~**  and EPA's responses are provided in Table 2.

Table 2: Proposed Monitoring Network Changes CBSAName Coun ty Site Name A Q SID Pollutants EPA Action

Miami-Fort Miami-Dade MDX Near Road 1 2-086-0035 N01 . co Additional

Lauderdale- West i nformation

Palm Beach required for

a rov a l

Tampa-S t. Pinellas Sawgrass Lake Parkway 12 -1 03-0027 N02, CO, Black Additional

Petersburg- Near Ro a d Ca r bon info r mat i on

Clearwater required for

a roval

Homosassa Springs Citrus Power Line Road - j 2 - 0 17-0006 so2 Additional

source - or i en t ed site near information

Du k e Energy Cry s ta l required for

River Sream Plant a pp roval

Orlando- Orange 1-4 Near Road 1 2 - 095 - 0009 N01.co. Site proposal

K i ss i mmee - Continuous previously

San f ord PMzs . approv e d

Meteorolo gy

Miami-Fort Broward Daniela Banu NCore 12 - 011 - 0034 Additional Site proposal

la uderdale-West NCore-required previously

Palm Beach parameters, Air approved

Toxics

4CBSA Name Tampa

- St. Petersburg

Clearwater Tampa

- St. Petersburg

Clearwater Jacksonville Miam
i- Fort Lauderdale

- West Palm Beach Miam
i- Fort Lauderdale

- West Palm Bea c h M i am i- Fort Lauderdale

- West Palm Beach Coun ty Hillsborough Hillsborough Duval Broward Palm Beach Palm Beach

S i te Name Apollo Beach TBD TBD UF Agricultural Research Center Royal Palm Lamstein Lane

A Q SID Pollutants TBD TBD

Pb TBD

Pb 12 - 011

- 1002 Continuous PM25 12 - 099

- 0009
OJ

, PM 2. s TBD

EPA Action Additional information required for a roval Additional information required for a

· - roval Additional information required for a roval Discontinuation, move to NCore. Change a roved. Proposed

to move site to Lamstien Lane, additional information required for a roval Proposed

to relocate from Royal Palm, additional information required for approval FDEP has also proposed
to change the monitoring objective for several PM2.s and OJ sites in its network from population exposure
to high concentration

. EPA understands that FDEP is making these changes in conjunction with its network assessment, and has identified these sites as high concentration based on analysis of several factors including historical data, local emissions, and meteorology. EPA approves the monitoring objective changes proposed
in the Network Plan. 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, PM 10 , PM2.s

. and PM2.s Speciation Trends Network (STN) monitors

. FDEP has not proposed any changes
to its operating schedules

in the Network Plan

. Air Quality Index (AQI) Reporting 40 CFR

§ 58.50

5AQI reporting is required in MSAs with populations over 350,000 . There are 12 MSAs i n the state that

are required to report an AQI : Miami-Fort Lauderdale - West Palm Beach, Tampa-St. Pe t ersburgC learwater, Orlando-Kissimmee-Sanford , Jacksonville, North Port-Sarasota-Bradenton , Cape Coral-Fort

Myers, Lakeland-Winter Haven, Deltona-Daytona Beach-Ormond Beach, Palm Bay-MelbourneTitusville, Pensacola-Ferry Pass-Brent, Port St. Lucie, and Tallahassee. The Network P l an includes a

link on Page 10 to the FDEP website where this information is available . The AQI report i ng

requirements are currently being met. National Core (NCore) Monitoring Network

40 CFR Part 58 Appendix D, 3.0 FDEP has d esignated three NCore s i tes: Sydney Road in Tampa (AQS ID : 12-057 - 300 2) , Daniela Banu

in Broward County (AQS ID: 12 - 011-0034). and St. Marks National Wildlife Refuge (AQS ID : 12-129-

0001). These sites satisfy the requirements for NCore monitoring and have been approved b y the EPA's

Office of Air Quality Planning and S t andards . The St. Marks NCore site was established i n 2014 as a

rural NCore site .
03 ,.1 ;,, ; , uirements

4 0 ppendix D, Table D - 2

The st m c nf Florida's proposed 0 3 monitoring network meets the minimum req u irem en ts found in 40

CFR P n· · \ r p · dix D, Table D-2 for all MSAs. Additionally, the proposed 03 monitoring network

des r. work Plan meets all of the design criteria of 40 CFR Part 58 .

CO Monitoring Requirements

40 CFR J>art 58, Appendix D, 4.2 Beginning January 1, 2015, CO mon i toring was required at near-road moni t ori n g sites in CBSAs with

populations greater than 2,500,000 . CO monitoring will be required at a near-road monitoring s ite in

C BS As with populations greater than 1,000,000 beg i nning on January 1 , 2017. The Network Plan

indicates that CO monitoring is ongoing at the Hill s borough County near-road site in the Tampa-St.

Petersburg · Clearwater CBSA, and the Brow a rd County near-road site in the Miami-Fort LauderdaleMiami Beach CBSA. Therefore, the CO monitoring network descr i bed in the Network Plan meets a ll of

the design criteria of 40 CFR Part 58.

N02 Monitoring Requirements

40 CFR Part 58, Appendix D, 4.3 Ambient air monitoring network des i gn cr i teria for N02 are found i n S e c t ion 4 . 3 of Ap p endix D to 40

CFR Part 58. Three type s of N02 monitoring are req u ired : near-road , area - wide, and Reg i onal
Administrator. The s e types of N0 2 monitoring are described in se c t ions 4.3.2 , 4.3.3, a n d 4.3 . 4,

respectively. Ambient air monitoring design cri t eria for near-road N02 monitoring sites are found in section 4.3 . 2 of

Appendix D to 40 CFR Part 58 . Near-road monitoring stations are currently operati n g in the following

6CBSAs

: Tampa-St. Petersburg-Clearwater

(in Hillsborough County), Miami-Fort Lauderdale-West Palm Beach (in Broward County), and Jacksonville

. The Network Plan also includes proposed near-road sites in the following CBSAs: Tampa-St. Petersburg-Clearwater

(in Pinellas County), Miami-Fort Lauderdale-West Palm Beach (in Miami-Dade County}, and Orlando-Kissimmee-Sanford

(in Orange County). The Orlando near-road site was previously approved
as part of the 2014 Network Plan. Second near-road monitoring sites were required to begin operation on January

1, 2015 in the MiamiFort Lauderdale-West Palm Beach and Tampa-St. Petersburg-Clearwater CBSAs. New sites in MiamiDade County and Pinellas County are proposed
in the Network Plan to meet these requirements, but more information about these sites is required for approval. Once the details of these sites are finalized, the state will need to submit an addendum

to the Network Plan containing these site proposals. The addendum must include all of the required information for proposed sites under 40 CFR §58

. 1 O(b ), and should also include additional information about the proposed near-road monitoring sites

. Section
13

. 5 of the near-road N02 Technical Assistance Document (TAD)

1 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 NOz 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 • Probable probe height of the inlet probe from ground level • Site property description including property owner and feasibility
of site access • Roadway design and configuration • Presence of any roadside structures • Nearest wind rose 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 • Other evidence that siting criteria are being met, including measurements

to any nearby obstructions
or trees. Once EPA Region

4 is in agreement with the proposed near-road sites, the state will need to make the information available for public inspection. Upon completion
of the public inspection process, the Network Plan addendum will need to be submitted
to EPA Region

4 for approval. We will continue
to 1 Near-road N02 Monitoring Technical Assistance Document. Office of Air Quality Planning and Standards,

U

. S. Environmental Protection Agency, Research Triangle Park, North Carolina. EPA-454/B-12-002

. June 2012

. http :1/www

. epa

. gov/ttna mt

i lift les/nearroad/NearRoadT AD.pd

f. 7work with your agency as needed to facilitate the establishment of these sites as expeditiously as

possible . Section 4.3 . 2 of Appendix D to 40 CFR Part 58 also requires CBSAs with populations between 500,000

and 1,000,000 people to operate a near - road NOz monitor starting in January 1, 2017 . Florida has five

CBSAs with populations in this range: North Port - Sarasota - Bradenton, Cape Coral · Fort Myers,

Lake l and-Winter Haven, Deltona-Daytona Beach-Ormond Beach, and Palm Bay - Melbourne-Titusville.

As a result of the 5-year NAAQS rev i ew cycle, the NOz monitoring requirements may be modified in

2016. The N02 near-road monitoring requirements may change for CBSAs with populations between

500,000 and 1,000,000 people, such as the Florida CBSAs listed above .

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. The area-wide NOz monitoring network described in the Network Plan

meets the requirements of Section 4.3.3 in all areas. These sites are summarized in Table 3.

Table 3: Area-wide NOz Monitoring Sites
CBSA Name County Jacksonville Duval Miami-Fort Lauderdale- Broward
Miami Beach Orlando - KissimmeeSanfo r d Tampa-St. PetersburgClearwater Orange Pinellas Site Name Kooker Park John U Lloyd State Park Winter Park Azalea Park AQSID

1 2-031 - 0032 12-0 I 1-8002

12 - 095-2002 12-103 - 00 18

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 40 additional NOz

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

susceptible and vulnerable populations. EPA and FDEP have previously identified the monitor at the

Coral Reef site (AQS ID: 12-086-0031) in Miami-Dade County as required under Section 4.3.4 . The full

list of NOz monitors identified by the Regional Administrators can be found on EPA's website at

http://www .epa.gov /ttnamti 1/<; vpo p .html.

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 (PWEI) 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 SOz monitor at an NCore

station may satisfy minimum monitoring requirements if that monitor is located within a CBSA with

required monitors under Appendix D, 4.4 . 8FDEPisproposinganewsiteintheHomosassaSpringsCBSAtomeetthePWEIrequirement(AQSID:12-017-0006).However,theNetworkPlandoesnotincludealloftherequiredinformationaboutthissiteforapproval.FDEPwillneedtosubmitanaddendumtotheNetworkPlanthatcontainsafullproposalforthissite.Theaddendummustincludealloftherequiredinformationforproposedsitesunder40CFR§58.10(b).Theaddendumshouldalsoincludesupportinginformationabouthowthesitelocationwasselected,suchassitephotos,maps,windroses,andinformationaboutthetargetsourceincludinganyairmodelingthatwasconductedtoinformthesiteselection.Theaddendumshouldbemadeavailableforpublicinspectionunder40CFR§58.10(a)(l),andthensubmittedtoEPARegion4forapproval.AllotherapplicableCBSAsinFloridaarenowmeetingtherequirementsforS02PWEImonitoring.EPAfinalizedtheS02DataRequirementsRule(DRR)(see80FederalRegister,No.162)onAugust,21,2015.ThisrulewillrequirecharacterizationoftheairqualitynearsourceswithS02emissionsgreaterthan2,000tonsperyearbyconductingambientairmonitoringormodeling.WeencourageyouragencytobeginhavingconversationswithaffectedsourcesinyourstatetodetermineanagreeduponapproachformeetingtheDRRrequirements.ByJanuary15,2016,FDEPmustsubmitafinallisttoEPARegion4identifyingthesourcesinthestatearoundwhichS02airqualitymustbecharacterized.ForsourcesthatFDEPdecidestoevaluateusingambientairmonitoring,newsiteproposalsmustbeincludedinthe2016NetworkPlan.ThelocationofthesemonitoringsitesshouldbeselectedusingtheprocessoutlinedintheS02NAAQSDesignationsSource-OrientedMonitoringTechnicalAssistanceDocument2.PbMonitoring Requirements40CFRPart58,AppendixD,4.540CFRPart58,AppendixD,4.5requiresthat"Ataminimum,theremustbeonesource-orientedSLAMS[stateandlocalairmonitoringstation}sitelocatedtomeasurethemaximumPbconcentrationinambientairresultingfromeachnon-airportPbsourcewhichemits0.50ormoretonsperyearandfromeachairportwhichemits1.0ormoretonsperyear..."MonitoringisongoingasrequirednearEnvirofocusTechnologiesInc.inTampa.FDEPhasalsosubmittedrevisedPbemissionsforonefacilitythathademissionsgreaterthan0.5tonsperyearinthe2011NationalEmissionsInventory:IFFChemicalHoldings,Inc.inJacksonville.EPAacceptstheserevisedemissionscalculations,andagreesthattheactualPbemissionsfromthissourcearebelow0.5tonsperyear.Therefore,Pbmonitoringisnotrequirednearthissource.40CFRPart58,AppendixD,3(b)requiresthat"NCoresitesinCBSAwithapopulationof500,000people(asdeterminedinthelatestCensus)orgreatershallalsomeasurePbeitherasPb-TSPorPbPMJO."TheNetworkPlanindicatesthatPb-PMwsamplingisongoingattheTampaNCoresite(AQSID:12-057-3002)andwillbeginattheBrowardCountyNCoresite(AQSID:12-011-0034)soon.ThePbmonitoringnetworkdescribedintheNetworkPlanmeetsallofthedesigncriteriaof40CFRPart58.2S02NAAQSDesignationsSource-OrientedMonitoringTechnicalAssistanceDocument.U.S.EPAOfficeofAirQualityPlanningandStandardsAirQualityAssessmentDivision,DraftDecember2013.hnp:1/www3.epa.gov/airquaIity/sulfurdioxide/pdfs/SO2MonitoringTAD.pdf9PMto Monitoring Requirements

40 CFR Part 58, Appendix A, 3.3.1

40 CFR Part 58, Appendix D, 4 . 6 and Table D-4

The st a te of Florida's PMw monitoring network meets the minimum requirements found in 40 CFR Part

58, Appendix D, Table D-4 for all MSAs. Also, all PM to collocation requirements for manual methods

found in 40 CFR Part 58, Appendix A, Section 3.3 . 1 are be i ng met. Fifteen percent of each netwo r k of

manual PM to methods (at least one site) must be collocated. These collocation requireme n ts are asse s sed

at the primary quality assurance organization (PQAO) level. The s t ate of Florida and all of its local

agencies operate under a single PQAO (FDEP). The PM to monitoring network described in the Network

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

PMz.s Monitoring Requirements

40 CFR Part 58, Appendix A, 3.2.5

40 CFR Part 58, Appendix D, 4. 7 and Table D-5

The state of Florida's 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 being met. F i fteen percent of each network of manual PM2 . s methods

(at least one site) must be co ll ocated. Beginning January 1, 2015, PM 2 . s monitoring is required at near · road monitoring sites in CBS As with

populat i ons greater than 2,500 , 000 . PM 2 . s monitoring will be r e quired at a near - road monitoring site in

CBS As with populations greater than 1,000,000 beginning on January 1, 2017. The Network Plan

i ndicates that PM2 . s monitoring is ongoing at the Hill s borough County near-road site in the Tampa-St. Petersburg-Clearwater CBSA , and a t the Broward County near-road site in the Miami-Fort LauderdaleMiami Beach CBSA . 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, Append i x D, 4. 7.2 Regulatory requirements f or continuous PM 2 .s monitoring require that .. ... State, or where appropriate ,

local agencies mu st opera t e continuous PM2 .s analy z ers 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 mu s t be collocated with one of the required FRMIFEM/ARM [ feder a l reference
method/federal equivalent method/approved regional method] monitors, unless at least one of the

required FR MIFE M/ ARM monitors is i t self a continuous FEM or ARM monitor in which case no

collocation requirement applies : · These minimum continuous PM2 . s monitoring requirements are met in

the all of the MSAs in the state . Al s o, the continuous PM 2 . s collocation re q uir e ment s are met in all

MSAs . Therefore, the continuous PM 2. s monitoring network de s cribed in the Network Plan meets all of

the design criteria of 40 CFR Part 58 .
PM2.s Background and Transport Sites

40 CFR Part 58, Appendix D , 4. 7.3 1040 CFR Part 58, Appendix D, 4.7.3 requires that "each state shall install and operate at least one PM2.s site to monitor for regional background and at least one PMz.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.s 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. **P~b.s** Continuous Federal Equivalent Methods 40 CFR
§ 58.10(e) EPA regulations contain provisions for handling data collected using continuous PM2

. s FEMs. These procedures are found at 40 CFR
§ 58

. 1 0( e)
. If an agency can demonstrate that the FEM data are not of sufficient comparability

to a collocated FRM

, then the monitoring agency may request that the FEM data not be used in comparison

to the NAAQS.
In the Network Plan, FDEP has requested
to maintain the NAAQS exclusion for its continuous PMz

. s FEMs operated
at two Palm Beach County sites (AQS IDs: 12 - 099-0008 and 12-099-0009). EPA has reviewed the information submitted
in the Network Plan, and approves these monitors for exclusion from NAAQS comparisons. PM2.s Chemical Speciation Network EPA conducted
an assessment
of the PM2.s 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, EPA defunded

a number of monitoring sites, and at all sites eliminated the CSN PM25 mass measurement, reduced the frequency
of carbon blanks, reduced sample frequency

at some monitoring sites, and reduced the number of icepacks
in shipment during the cooler months of the year

. As FDEP discusses
in the Network Plan, EPA defunded the Skyview site (AQS ID: 12-103-0026)

as of January 2015

. In addition, all of the state's CSN sites were impacted by the elimination
of the PMz.s mass measurement, the reduction of carbon blank frequency, and the reduction
in icepacks

. Request for Waiver of Siting Criteria On Page 38 of the Network Plan, FDEP requests

a waiver of the monitor siting criteria for the Woodlawn PM10 site in St. Petersburg. The site has been operating
in its current location since 1992. Recent improvements

at the park where the site is located included the planting of trees that resulted
in the monitor no longer meeting siting criteria. Given the information and rationale provided by FDEP, EPA is open to considering this request for a waiver

. However, more information will be needed for approval. Specifically, FDEP needs to identify which requirements

in 40 CFR Part 58, Appendix

E the site does not meet and thus are being requested by the state to be waived. Also, FDEP must provide current measurements

or data, in the form of the relevant siting criteria requirements (e.g., measurements

to trees or obstructions, etc.). llUnder 40 CFR Part 58, Appendix E, Section 10, waivers of siting criteria for new sites can be granted if

e i ther of the following criteria are met:

10 . 1.1 The site can be demonstrated to be as representative of the monitoring area as it

would be if the siting criteria were being met.

1 0 . 1 . 2 The monitor or probe cannot reasonably be located so as to meet the siting

criteria because of physical constraints (e.g., inability to locate the required type of site

the necessary distance from roadways or obstructions) .

The additional information requested above may be submitted in a separate letter, or in an addendum to

the 2015 Network Plan. 1 2