Frankfort. Kentucky 4060 I 

Dear Mr. Altcri: 

Thank you for submitting the Annual Ambient Air Monitoring Network Plan (Network Plan) for the 

Commonwealth of Kentucky dated July I. 2015. The Network Plan covers Kentuckis 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 (EPA) Region 4 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: 

• 24-hour particulate matter less than 10 microns (PMw) samples should be taken from midnight to 

midnight local standard time 

• The monitor type of the Baskett OJ (AQS ID: 21-101-0014) site should be changed from a 

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

• Submission of addendum/monitoring siting criteria for a lead (Ph) site near AK Steel 

• Siting for the Ashland Primary site (AQS 10: 21-0 19-00 17) needs to be resolved 

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 Katie Walther at (404) 562-9110. 

Enclosure 

cc: Mr. Keith Talley 

incerely. 

9\f:$; ~ 

ever H. Banister 

Director 

Air, Pesticides and Toxics Management Division 

Director, Louisville Metro Air Pollution Control District 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 

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matter less than 10 microns (PMw), 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, 2014, population estimates from 

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

for OJ, PM2.s. and PMto only apply to metropolitan statistical areas (MSAs), which are a subset of 

CBSAs. OMB currently defines 25 CBSAs in the Commonwealth of Kentucky. These CBSAs and the 

respective July 1, 2014, population estimates from the U.S. Census Bureau are shown in Table 1. 

Table 1: Core Based Statistical Areas and July 1, 2014 Population Estimates 

CBSA Name CBSA Type Population 

Cincinnati, OH-KY-IN Metropolitan Statistical Area 2,149,449 

Louisville/Jefferson County, KY-IN Metropolitan Statistical Area 1,269,702 Lexington-Fayette, KY Metropolitan Statistical Area 494,189 Huntington-Ashland, WV-KY-OH Metropolitan Statistical Area 363,325 

Evansville, IN-KY Metropolitan Statistical Area 315,162 

Clarksville, TN-KY Metropolitan Statistical Area 278,353 

Bowling Green, KY Metropolitan Statistical Area 165,732 

Elizabethtown-Fort Knox, KY Metropolitan Statistical Area 151,585 

London, KY Micropolitan Statistical Area 127,316 

Owensboro, KY Metropolitan Statistical Area 116,506 

Richmond-Berea, KY Micropolitan Statistical Area 104,166 

Paducah, KY -IL Micropolitan Statistical Area 97,820 Frankfort, KY Micropolitan Statistical Area 71,768 

Somerset, KY Micropolitan Statistical Area 63,825 

Danville, KY Micropolitan Statistical Area 54,151 

Glasgow, KY Micropolitan Statistical Area 53,138 

Madisonville, KY Micropolitan Statistical Area 46,376 Mount Sterling, KY Micropolitan Statistical Area 45,967 Bardstown, KY Micropolitan Statistical Area 44,812 Murray, KY Micropolitan Statistical Area 38,282 Mayfield, KY Micropolitan Statistical Area 37,618 

Union City, TN-KY Micropolitan Statistical Area 37,206 

Middlesborough, KY Micropolitan Statistical Area 27,778 

Campbellsville, KY Micropolitan Statistical Area 25,257 

Maysville, KY Micropolitan Statistical Area 17,166 

Monitoring Network Changes 
Kentucky Division for Air Quality (KDAQ) has requested to discontinue the meteorological station at 

the Shepherdsville air monitoring station (AQS ID: 21-029-0006) and establish a meteorological station 

at the Buckner air monitoring station (AQS ID: 21-185-0004), which is downwind of the Louisville 

metropolitan area. The EPA's approval is not required for changes to these meteorological stations, but 

we acknowledge these changes. 

Louisville Metro Air Pollution Control District (LMAPCD) has requested to make the following 

changes: to replace the PM2.s continuous TEOM at Bates Elementary (AQS ID: 21-111-0027) with a 

non-FEM continuous PM2.s BAM for reporting of the AQI; to replace the primary PM to TEOM at 

Southwick Community Center (AQS ID: 21-111-0043) with a continuous FEM PM to BAM and to 

discontinue operation of the collocated continuous PM to TEOM, which is not needed for network 

completeness; and to replace the continuous PMto TEOM at Watson Lane (AQS ID: 21-111-0051) with 

a continuous FEM PM 10 BAM. The EPA approves these changes. 

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 to, PM2.s, and PM2.s Speciation Trends Network (STN) 

monitors. KDAQ has not proposed any changes to their operating schedules in the Network Plan with 

the exception of potentially altering the sample collection for 24-hour PMto samples as discussed below. 

In the 2015 Kentucky Ambient Air Monitoring Five-Year Network Assessment (Network Assessment), 

KDAQ notes that 24-hour PM to samples are collected between midnight-midnight local time, in 

observance of Daylight Savings. KDAQ points out that there is a contradiction in the CFR regarding the 

use of local time versus local standard time. 40 CFR 50, Appendix K defines a "Daily Value for PM10" 

as "the 24-hour average concentration of PM to calculated or measured from midnight to midnight (local 

time)." Meanwhile, 40 CFR 58.12 states that "a 24-hour sample must be taken from midnight to 

midnight (local standard time) in order to ensure national consistency." KDAQ is considering changing 

its operating procedures so that samples are collected on local standard but will discuss potential 

implications with the EPA Region 4. The EPA Region 4 has reached out to the EPA's Office of Air 

Quality Planning and Standards (OAQPS) and received clarification regarding the matter (see 

https://www .federalregister.gov /articles/2007/06/12/07-220 1/ambient -air -monitoring-regulationscorrecting-and-other-amendments#p-77). We agree KDAQ should change its operating procedures so 

that samples are collected on local standard time. 

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, Louisville/Jefferson County, Lexington1992. Based on 2012-2014 data, the Baskett site has the highest OJ design value (0.074 ppm) of any 

monitor in the Evansville area. Section 4.1 of Appendix D requires that "Within an 03 network, at least 

one OJ site for each MSA, or CSA if multiple MSAs are involved, must be designed to record the 

maximum concentration for that particular metropolitan area." In order to meet this requirement, KDAQ 

is required to change the monitor type of the Baskett OJ site to a SLAMS, and designate the monitoring 

objective as highest concentration. 

Also in reference to the above requirement in Section 4.1 of Appendix D, in the Network Assessment, 

KDAQ included the maximum concentration ozone site for each MSA as designated in AQS. KDAQ 

noted that three MSAs did not have a maximum concentration ozone site identified in AQS: 

Elizabethtown-Fort Knox, KY; Huntington-Ashland, WV-KY-OH; and Bowling Green, KY. KDAQ has identified potential maximum concentration sites for each of these MSAs and has stated that they will 

discuss these changes with other involved agencies (Ohio and West Virginia for the Huntington-Ashland 

MSA and the National Parks Service for the Bowling Green MSA) prior to making any changes in AQS. However, the table on page 7 in the Network Assessment and AQS indicate that the Ed Spear Park site 

(AQS ID: 21-227-0009) is the maximum concentration site for the Bowling Green MSA. The 

Clarksville, TN-KY MSA seems to be missing a maximum concentration site though based on the 

Network Assessment and the Network Plan. AQS indicates that the Cadiz CASTNET site (AQS ID: 21-

221-9991) is the highest concentration site in this MSA, which is an EPA monitor. Additionally, the 

Lexington Primary site (AQS ID: 21-067-0012) is listed in the Network Assessment as the maximum 

concentration site for the Lexington-Fayette MSA; however, this is not indicated in the Network Plan or 

in AQS. The EPA recommends KDAQ update their monitoring objectives for all ozone sites to include a 

maximum concentration monitoring objective where appropriate. Any maximum concentration sites 

should be designated as SLAMS monitor types. The EPA also recommends KDAQ add a discussion 

about the CASTNET monitor as it was not reflected in the Network Plan. These changes should be 

reflected in the 2016 Network Plan. 

The EPA also notes that KDAQ identifies the Hopkinsville OJ site in Clarksville (AQS ID: 21-047-

0006) as a SLAMS monitor type, however the monitor type is listed as Other in AQS. Please change this 

monitor type to a SLAMS in AQS. 

CO Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.2 

Ambient air monitoring network design criteria for CO are found in Section 4.2 of Appendix D to 40 

CFR Part 58. CBSAs with a population over one million are required to operate one CO monitor 

collocated with a near-road N02 monitor by January 1, 2017 as indicated in 40 CFR §58.13(e)(2). This 

requirement is already being met for the Cincinnati CBSA through a Memorandum of Agreement 

(MOA) with Ohio. The near-road site is located in Ohio and is operated by the Southwest Ohio Air 

Quality Agency (AQS ID: 39-061-0048). This requirement is also already being met for the 
Louisville/Jefferson County CBSA by the CO monitor currently operating at the Durrett Lane near-road 

site (AQS ID: 21-111-0075). 

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

Administrator. These types of NOz monitoring are described in Sections 4.3.2, 4.3.3, and 4.3.4, 

respectively. 

Ambient air monitoring design criteria for near-road NOz 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 LMAPCD for the 

Louisville/Jefferson County CBSA at the Durrett Lane monitoring site (AQS ID: 21-111-0075) and a 

near-road NOz monitor is operated by the Southwest Ohio Air Quality Agency (AQS ID: 39-061-0048) 

for the Cincinnati CBSA. CBSA's with populations between 500,000 and 1,000,000 are currently 

required to operate a near-road NOz monitoring site starting in January 1, 2017. A new NOz monitoring 

mle is expected to be promulgated in 2016. The new rule may change the requirements for CBSAs of 

this size. Under current regulations, if the Lexington-Fayette MSA reaches a population of 500,000, the 

MSA will be required to have a near-road site. The population estimate as of July l , 2014, is 494,189. 

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. Any CBSA with a population of 1,000,000 or more persons is required 

to monitor a location of expected highest N02 concentration representing the neighborhood or larger 

spatial scales. The Cannons Lane NOz monitor (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 (NKU) NOz monitor (AQS ID: 21-037 -3002) is used in fulfillment of the areawide NOz monitoring requirement for the Cincinnati CBSA. 

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. 

Under these provisions Regional Administrators must require a minimum of forty additional N02 

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

susceptible and vulnerable populations. Region 4 has previously designated the Lexington Primary NOz 

monitor (AQS ID: 21 067 0012) as a RA-40 NOz monitoring site. The full list of NOz monitors 

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

htlp;//www3.epu.gov/ttnamtil /wpop. hi ml. 

SOz Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.4 
monitors are PWEI based monitors. Please update the 2016 Network Plan with the appropriate PWEI monitor designations. 

The EPA fmalized the SOz Data Requirements Rule (ORR) on August 10, 2015. This rule will require 

characterization of the air quality near sources with SOz emissions greater than 2,000 tons per year by 

conducting ambient air monitoring or modeling. We encourage your agency to begin having 

conversations with affected sources in the Commonwealth of Kentucky to determine an agreed upon 

approach for meeting the DRR requirements. By January 15, 2016, KDAQ must submit a final list of 

sources to the EPA Region 4 identifying the sources in the Commonwealth around which S02 air quality 

must be characterized. For sources that KDAQ decides to evaluate using ambient air monitoring, new 

site proposals must be included in the 2016 Network Plan. The location of these monitoring sites should 

be selected using the process outlined in the SOz NAAQS Designations Source-Oriented Monitoring 

Technical Assistance Document1• 

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. The 

emissions threshold for facilities near which source-oriented Pb monitoring is required is 0.5 tons per 

year (tpy). Pb monitoring is also required at urban NCore sites. Monitoring is ongoing as required near 

the Enersys Inc. facility in Madison County. Based on the Network Assessment, Pb monitoring is 

required to be established near the AK Steel West Works facility in Boyd County. As soon as Kentucky 

identifies a candidate site, the proposed revisions to the network must be submitted to the EPA for 

approval. Once the details of the site proposal are finalized, the Commonwealth will need to submit an 

addendum to the Network Plan. The addendum must include all of the required information for proposed 

sites under40 CFR §58.10(b). The addendum should also include KDAQ's rationale for the location of 

the new proposed site, and supporting information about how the site location was selected such as site 

photos, maps, wind roses, etc. 

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 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 

1 S02 NAAQS Designations Source-Oriented Monitoring Technical Assistance Document. U.S. EPA Office of Air Quality 

Planning and Standards Air Quality Assessment Division, Draft December 2013. 

http://www3.epa.gov/airuuality/!>ulfurdio:\ idc/pdfs/S02Mnnit(lringTAD.pdf 
EKU but has delayed the process until Enersys completes improvements of their 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. The existing SPM monitor at EKU was 

converted to a SLAMS monitor on January l , 2015, and the EPA approves this change. According to the 

Network Assessment, KDAQ has installed new fencing at the EKU site and is preparing to build a 

second deck for the collocated sampler. KDAQ must submit a site proposal to the EPA for the proposed 

changes to the EKU site before additional modifications are made to the site. KDAQ previously 

requested 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 approved the discontinuation of the collocated Pb 

monitor at Mayfield Elementary School after the permanent collocated site is established at EKU. 

The Network Assessment includes a renewal of the waiver from the Requirements of 40 CFR 58, 

Appendix D: Lead Network Design Criteria in Appendix B of the document. The waiver indicates that 

KDAQ identified ten sources with Pb emissions over 0.50 tpy in KY-EIS. KDAQ submitted a modeling 

demonstration and requested a waiver from monitoring for eight of those sources. The remaining two 

sources are the Enersys, Inc. facility which is currently being monitored for Pb emissions and the AK 

Steel West Works facility, which KDAQ recommends Pb monitoring be established in the proximity of 

maximum ambient air impact. The renewal of these waivers will be discussed in the Network 

Assessment response letter. 

The waivers 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. In the 2013 

Network Plan, KDAQ proposed discontinuation of the Lockwood Pb monitoring station and submitted a 

formal request to the EPA on September 17,2013, and the EPA Region 4 approved the waiver of the 

source-oriented monitoring requirement near the Calgon Carbon facility. In the 2014 Network Plan, 

KDAQ proposed to discontinue the Salem Elementary Pb monitoring station on December 31, 2014, and 

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

Battery facility. Of the two monitoring stations that were shutdown, only the Calgon Carbon facility is 

included in the renewal of the waiver since the emissions are listed as 0.68 tpy. The emissions from the 

Superior Battery facility are below 0.50 tpy at 0.0285 tpy and no monitoring is currently required. 

PM to 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 does meet the minimum 

requirements found in 40 CFR Part 58, Appendix D, Table D-4 for all MSAs. 
PM2.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 PM2.s monitoring network meets the minimum requirements 

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

Manual PM2.s collocation requirements are found in 40 CFR Part 58, Appendix A, Section 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 PM2.s are currently being 

met in the Network Plan. 

PM2.s Near-Road Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.7.1(b)(2) 

Regulatory requirements in 40 CFR Part 58, Appendix D, Section 4.7.1 (b) (2) require that "CBSAs with 

a population of 1,000,000 or more persons, at least one PM2.s monitor is to be collocated at a near-road 

N02 station." PM2.s near-road monitoring is required in the Cincinnati CBSA and the 

Louisville/ I efferson County CBSA. This requirement is being met for the Cincinnati CBSA through a 

Memorandum of Agreement (MOA) with Ohio. The near-road site is located in Ohio and is operated by 

the Southwest Ohio Air Quality Agency (AQS ID: 39-061-0048). This requirement is being met for the 

Louisville/Jefferson County CBSA by the Durrett Lane Near-Road Site (AQS ID: 21-111-0075) which 

has a PM2.s monitor. 

PMl.s Continuous Monitoring Requirements 

40 CFR Part 58, Appendix D, 4.7.2 

Regulatory requirements for continuous PM2.s monitoring require that" ... State, or where appropriate, 

local agencies must operate continuous PM2.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 PM2.s monitoring requirements are 

currently met in all MSAs in the Commonwealth. Also, the continuous PM2.s collocation requirements 

are currently met in all MSAs. Therefore, the continuous PM2.s monitoring network described in the 

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

PMl.s Background and Transport Sites 

40 CFR Part 58, Appendix D, 4.7.3 
Forty CFR Part 58, Appendix D, Section 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 PM2.s site to monitor for regional 

transport." The Network Plan identifies the Grayson Lake PM2.s site (AQS ID: 21-043-0500) as a 

background site and the Hopkinsville PM2.s site (AQS ID: 21-047-0006) as a regional transport site. 

Therefore, KDAQ has satisfied the requirements of 40 CFR Part 58 for background and transport sites. 

PM2.s Chemical Speciation Network (CSN) 

40 CFR Part 58, Appendix D, 4.7.4 

The EPA conducted an assessment of the 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 defunded 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 discussed in the 2014 Network Plan, a 

preliminary list of low-value PM2.s speciation sites to be defunded by the EPA included 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). According to the Network Assessment, KDAQ 

discontinued PM2.s speciation sampling in December 2014 after being notified of the loss of federal 

funding. PM2.s speciation monitoring is still taking place at the Cannons Lane NCore site (AQS ID: 21-

111-0067) in the Louisville/Jefferson County CBSA. 

Photochemical Assessment Monitoring Stations (PAMS) 

40 CFR Part 58, Appendix D, 5.0 

With the recent passage of a new ozone NAAQS on October 1, 2015, the EPA finalized changes to 

PAMS. By June 1, 2019, the NCore site in Louisville/Jefferson County will be required to implement 

P AMS monitoring. While the EPA realizes there are several implementation challenges to work 

through, we will work closely with KDAQ and LMAPCD to minimize the burden of implementing this 

new monitoring program. At this time, however, the P AMS requirement is being met in the 

Commonwealth of Kentucky. 

Memoranda of Agreement (MOA) with Neighboring States 

Kentucky, Ohio, and Indiana have an MOA addressing PM2.s. PMw, OJ, N02, CO, and S02 monitoring 

in the Cincinnati, OH-KY-IN MSA. Kentucky and Indiana have an MOA addressing PM2.s, PMto, OJ, 

N02, CO, and S02 monitoring in the Evansville, IN-KY MSA. Kentucky and Tennessee have an MOA 

addressing PM2.s and OJ monitoring in the Clarksville, TN-KY MSA. The other two MSAs that contain 

neighboring states are the LouisviiJe/Jefferson County, KY-IN MSA and the Huntington-Ashland, WVKY-OH MSA. The Network Plan does not contain MOAs for either of these MSAs. If at some time in 

the future KDAQ chooses to enter into an MOA with the neighboring states in these MSAs, the Network 
work with KDAQ to come up with a solution to the siting criteria problems at the Ashland Primary site.