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Are Louisville’s air quality cops looking the other way?

Metro Louisville has applied to be removed from federal non-attainment status for particulate matter pollution. Badwater looks at the air monitoring network and the air data produced.

Vehicular exhaust particles are found to be most responsible for small-sized airborne PM air pollution in urban areas.

In general, the evaluation of most of these studies shows that the smaller the size of PM the higher the toxicity through mechanisms of oxidative stress and inflammation.

J Environ Sci Health C Environ Carcinog Ecotoxicol Rev. 2008 Oct-Dec;26(4):339-62.

Airborne particulate matter and human health: toxicological assessment and importance of size and composition of particles for oxidative damage and carcinogenic mechanisms.

Valavanidis A, Fiotakis K, Vlachogianni T.


Department of Chemistry, University of Athens, University Campus Zogafou, Athens, Greece.


On February 3, 2012 a public hearing will be held in the Board Room of the Louisville Metro Air Pollution Control Board starting at  10:00 a.m. 850 Barret Avenue, Louisville, KY

The hearing is a required public notification and comment step for the Kentucky Division of Air Quality application to federal EPA to delist the Louisville and Southern Indiana area from its non-attainment status for violations of the NAAQS - National Ambient Air Quality Standards for PM 2.5 fine particulate matter.

PM - particulate matter

Fine particulates smaller than 2.5 μm (micro-meters) in diameter get deep into the lungs and are implicated in health risks for populations exposed day in and day out. 

Regulations established in the NAAQS require urban areas to keep 2.5 μm particle concentrations below 15 μgrams/cubic meter. Imagine a box that measures one meter on each side. Inside that box, the weight of fine air particles smaller than 2.5 micrometers in diameter or less, must not exceed in weight, 15 micrograms.


This measure says nothing about the total  number of ultrafine air particles having less diameter. You could have fewer but heavier particles or many lighter particles below the 15 μg/m3 limit.

The total number of particles has been investigated as a health risk:

“Atmospheric nanoparticles are one of the air pollutants which are currently not regulated through air quality standards in any developing or developed megacities.

Up to ∼85% of total particle number (ToN) concentrations in polluted urban environments originates from road vehicles.2 More than 80% of ToN concentrations in atmospheric urban environments reside in the ultrafine size range (i.e., <100 nm in diameter) that contribute almost negligibly to particle mass concentrations.3

The particle size range below 300 nm (referred here as nanoparticles) constitute over 99% of ToN concentrations in

urban environments.2

Kumar, P.,  Gujar, B,  Nagpure, A., Harrison, R., Preliminary Estimates of Nanoparticle Number Emissions from Road Vehicles in Megacity Delhi and Associated Health Impacts, Environ. Sci. & Technol. 2011, 45, 5514–5521.

Thus EPAs,  15 μgrams/cubic meter limit aimed at fine particulates does not measure the total number of nanoparticles  in a sample and misses measuring important health data that could trigger action.

Air monitoring site selection

EPA has promulgated rules for state air monitoring site selection. They seem  deliberately designed to allow location of ambient monitors away from the locations where the highest pollution concentrations  and greatest numbers of people come together creating high daily exposure.

Louisville’s air monitoring network locations information is posted on the APCD website and I visited each of five Jefferson County locations that measure particulate matter to see the siting conditions.

These sites are:

West End

Southwick Community Center

3621 Southern Avenue

South End

Wyandotte Park,

1032 Beecher Avenue

Southwest County

Watson Lane School,

7201 Watson Lane

Central Highlands

Bowman Field

2730 Cannons Lane

Rural outside Gene Snyder

Bates Elementary,

7601 Bardstown Road

See Map at right and at:   <http://www.louisvilleky.gov/APCD/Monitoring/MonitoringSites.htm>

Four sites are located away from the influence of major particle emissions sources such as highways and industrial sources. They were in park-like settings surrounded by woodsy areas and with little traffic volume. The exception was Watson Lane Elementary site which sits in the shadow of the towering plume of stack emissions from Mill Creek generating unit in the far south corner of Jefferson County.

In the brief time I was in the area, subjectively the atmosphere felt unhealthy and I felt sorry for the residents living their lives in the gloom below the stacks. So the question is--does the three year average data that APCD claims supports its application for redesignation, have any meaning except to the regulators?

Three year annual averaging

After the particulate air data is gathered away from the heavy pollution areas in the city, the impact of high individual measurements is blunted by averaging the data. The data is averaged over 24 hour periods to knock off the peaks, then the daily averages are compiled into a monthly average, then the monthly averages into a yearly average, and finally compliance with the NAAQS particulate standard is based on a three year annual average.

The mathematical averaging allows lots of days of way high particulate levels that are nullified by good day readings. It seems like a way to circumvent public health protection in order to keep the door open to more dirty growth without suffering EPA mandated controls on more power plants, automobiles  and industries.

This Map is posted on the APCD website at:


The following is from:  Ambient Air Monitoring Work plan For National Core (NCore) Monitoring Station filed and online from the APCD

APCD has five different instruments that collect fine particulate matter at the Cannons Lane data station. See details on the APCD website.

“The  manual particulate samplers will be placed on a wooden deck behind the sampling shelter. The height of the inlets of the particulate samplers will vary between 2-3 meters. The inlets for the continuous particulate samplers will be placed on the roof of the air monitoring shelter with the sample inlets being 2 meters above the roof (4 meters above ground). The control units will be located inside the temperature controlled shelter.”

National Core (NCore) multi-pollutant monitoring stations-- Establish an NCore multi-pollutant monitoring station in Eastern Jefferson County at 2730 Cannons Lane. The location meets the objective for an NCore site and meets urban scale criteria for PM2.5, PM10, Ozone, and NOx. It meets neighborhood scale criteria for Carbon Monoxide.

PM2.5     Filter Method       inlet height--2.4 meters above ground 

Federal Reference Method   utilizing gravimetric analysis.

PM2.5     TEOM  Method    inlet height--4.6 meters above ground

Tapered Element Oscillating Microbalance  utilizing gravimetric analysis

PM10-2.5   AEM                 inlet height--4.6 meters above ground

Automated Equivalent Method  utilizing Beta Attenuation.

PM2.5  Speciation              inlet height--2.2 meters above ground

Multi-species manual collection method  utilizing thermal optical, ion chromatography, gravimetric, and X-ray fluorescence analyses.

The primary purpose of speciation sampling is to study transport and formation of the secondary aerosols which make up a substantial portion of PM2.5 mass. Sulfates and nitrates are the predominant

species of concern. Integrating these measurements with trace level SO2, trace level NOY, PM2.5/PMcoarse, and enhanced meteorological measurements will provide a more complete and accurate assessment of secondary aerosol formation in the Louisville Metro Area.

PM2.5    Carbon Speciation   inlet height--2.4 meters above ground

Multi-species manual collection method  utilizing thermal optical and gravimetric analyses.