Sr 47

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

I o REGION IX

PRO 75 Hawthorne Street

San Francisco CA 94105-3901

MAY 0 82014

Mr. Samir Sheikh, Director of Strategies and Incentives

San Joaquin Valley Air Pollution Control District

1990 East Gettysburg Avenue

Fresno, California 93726-0244

Dear Mr. Sheikh:

Thank you for your submission ofthe San Joaquin Valley Air Pollution Control District’s

(SJVAPCD’s) Annual Air Monitoring Network Plan in June 2013. We have reviewed the

submitted document based on the requirements set forth in 40 CFR Part 58. Based on the

information provided in the plan, EPA approves all portions of the network plan except those

specifically identified below.

Please note that we cannot approve portions of the annual network plan for which the

information in the plan does not demonstrate compliance with the requirements as specified in 40

CFR 58.10 and the associated appendices. EPA Region 9 also cannot approve portions of the

plan for which the EPA Administrator has not delegated approval authority to the regional

offices. Accordingly, the first enclosure (A. Annual Monitoring Network Plan Items where EPA

is Not Taking Action) provides a listing of specific items of your agency’s annual monitoring

network plan where EPA is not taking action. The second enclosure (B. Additional Items

Requiring Attention) is a listing of additional items in the plan that EPA wishes to bring to your

agency’s attention for consideration in future plans.

The third enclosure (C. Annual Monitoring Network Plan Items that EPA is Disapproving)

describes the one requirement EPA is disapproving in the SJV monitoring network: the

requirement for a maximum ozone concentration monitor in the Bakersfield Metropolitan

Statistical Area (MSA). EPA will continue to work with the California Air Resources Board

(CARB) and the SJVAPCD to resolve this issue.

The fourth enclosure (D. Annual Monitoring Network Plan Checklist) is the checklist EPA used

to review your plan for all items that are required to be included in the annual network plan along

with our assessment of whether the plan submitted by your agency addresses those requirements.

The fiflh enclosure (E. Region 9 Near-roadNO2Plan Review Checklist) is the checklist EPA

used to review those elements of your annual monitoring network plan that deal specifically with

near-road NO2monitoring. The sixth enclosure (F. EPA Supplemental Response to Comments)

provides additional information and clarification regarding the EPA requirements that are the

subject of the public comments submitted to SJVAPCD.

Pnnwd o,i Recycled Paper
The first three enclosures highlight a subset of the more extensive list of items reviewed in the

fourth and fifth enclosures. All comments conveyed via this letter (and enclosures) should be

addressed (through corrections within the plan, additional information being included, or

discussion) in future annual monitoring network plans. If you have any questions regarding this

letter or the enclosed comments, please feel free to contact me at (415) 947-4534 or Elfego Felix

at (415) 947-4141.

Sincerely,

//4 /

Meredith Kurpius, Manager’

Air Quality Analysis Office

Enclosures:

A. Annual Monitoring Network Plan Items where EPA is Not Taking Action

B. Additional Items Requiring Attention

C. Annual Monitoring Network Plan Items that EPA is Disapproving

D. Annual Monitoring Network Plan Checklist

E. Region 9 Near-road N02 Plan Review Checklists:

El. Region 9 Near-road N02 Plan Review Checklist — Fresno

E2. Region 9 Near-road NO2 Plan Review Checklist — Bakersfield

F. Supplemental Response to Comments

cc: Errol Villegas, SJVAPCD

Michael Carrerra, SJVAPCD

Jon Klassen, SJVAPCD

Nathan Trevino, SJVAPCD

Sylvia Vanderspek, California Air Resources Board

Gayle Sweigert, California Air Resources Board
A. Annual Monitoring Network Plan Items where EPA is Not Taking Action

We are not acting on the portions of annual network plans where either EPA Region 9 lacks the

authority to approve specific items of the plan, or where it is not clear whether a requirement has

been met.

Per 40 CFR 58.11(c), NCore, PAMS, and SIN network design and changes are

subject to approval of the EPA Administrator. Therefore, we are not acting on these

items, including the following:

o Unspecified changes for the Fresno-Garland NCore site noted in the detailed

site table

o Unspecified change to the NMHC measurements at Parlier that were listed in

the detailed site table

o Bakersfield-Muni as the replacement PAMS site for Bakersfield Golden

• System modifications (e.g., site closures or moves) are subject to approval per 40

CFR 5 8.14(c). Information provided in the plan was insufficient for EPA to approve

the system modifications listed in the plan per the applicable requirement. Therefore,

we are not acting on the following items as part of this year’s annual network plan:

o Discontinuing of PM10 and PM2.5monitoring at the Bakersfield-Muni site

o Closing the Stockton-Wagner/Holt PM10 site

o Consolidating of the Madera-Pump site into the Madera-City site

o Consolidating the Fresno-Pacific site into the Fresno-Drummond site

o EPA is also not acting on any system modifications listed in the plan (see Row

16) as anticipated in the next 18 months, including:

Unspecified changes for the ozone monitor at Arvin-DiGiorgio noted

in the detailed site table

Unspecified changes for the PM2.5monitor at Bakersfield-Planz noted

in the detailed site table

• Plans for establishing near-road NO2monitoring are required for submittal as part of

the Annual Monitoring Network Plan per 40 CFR 58. 10(a)(5). Information provided

was insufficient for EPA to approve the proposed plan for establishing a near-road

NO2monitor in the Fresno and Bakersfield CBSAs per the applicable requirements.

Assuming that the final site is accurately characterized by the information provided

and meets all of the applicable 40 CFR Part 58 criteria, we expect that we will be able

to approve the District’s NO2near-roadway Fresno site selection. The level of detail

provided for the currently proposed Bakersfield site does not adequately justify

selection for EPA approval at this time. Therefore, we are not acting on this portion

of the Annual Monitoring Network Plan. The District will need to resubmit a plan

that includes missing information highlighted in this checklist to receive EPA

approval for a proposed Fresno and Bakersfield sites. The re-submitted plan should

go through a minimum 30 day public inspection period prior to re-submittal to EPA.

See enclosure D (D. Region 9 Near-road iVO 2Plan review checklist) for more

information.
• EPA identified items in your agency’s annual network plan where it was not clear

whether a requirement was being met. Therefore, we are not acting on the following

items:

Item Checklist Row Issue

Identification of maximum 57 Insufficient information to judge in some

concentration ozone monitor in instances (no in one instance — see

each MSA Enclosure C).

One PM25 site in an area of 66 Insufficient information to judge in some

maximum concentration in each instances

MSA

Minimum number of PM10 sites 71 Incorrect

Sampling season for ozone 51 Incomplete

Sampling schedule for PM2.5 52 Incomplete / Insufficient information to

(and indicate seasonal judge

sampling)

Sampling schedule for PM10 53 Insufficient information to judge

Minimum monitoring 60 Not meeting the requirement

requirements met for RA4O

NO2

NO2plan for RA4O sites 9 Not meeting the requirement

submitted by 7/1/20 12

NO2RA4O sites operational by 10 Insufficient information to judge

1/1/2013

SPMs operating FEMs > 24 25 Insufficient information to judge

months are comparable to the

NAAQS

Identification of sites suitable 18 Insufficient information to judge

and not suitable for comparison

to the annual NAAQS

Designation of a primary 38 Insufficient information to judge

monitor

NO2plan for near-road sites 1 1 Insufficient information to judge

submitted by 7/1/20 13

Designation of any Pb monitors 20 Incomplete

as source-oriented or nonsource-oriented

Sampling schedule for Pb 54 Insufficient information to judge

Minimum monitoring 72 Insufficient information to judge

requirements met for PM102 .5

mass

Sampling schedule for PM102 .5 55 Insufficient information to judge

PM2.5Chemical Speciation 70 Insufficient information to judge

requirements for official STN
sites

Minimum monitoring 68 Insufficient information to judge

requirements for continuous

PM2.5

Documentation of how the 26 Insufficient information to judge

agency provides for review of

changes to a PM2.5network that

impacts the location of a

violating monitor

Precision / Accuracy reports 28 Incomplete / Insufficient information to

submitted to AQS judge

Annual data certification 29 Incomplete / Insufficient information to

submitted judge

Sampling and analysis 15 Incomplete / Incorrect

method(s) for each measured

parameter

Scale of representativeness for 17 Incorrect / Incomplete

each monitor

Method code for each monitor 43 Incomplete / Incorrect

Agreements between agencies 44 Insufficient information to judge

that share monitoring

responsibilities for a MSA

Start date for each monitor 45 Incomplete

Monitor type for each monitor 46 Incomplete / Incorrect

Monitoring objective for each 47 Incomplete / Incorrect

monitor

Site type for each monitor 48 Incomplete / Incorrect

Instrument parameter code for 49 Incomplete / Incorrect

each monitor

Frequency of flow rate 30 and 31 Incomplete / Incorrect

verification for manual and

automated PM monitors

Frequency of flow rate 32 Insufficient information to judge

verification for manual and

automated Pb monitors

Frequency of one-point QC 33 Incomplete

check for gaseous monitors

Date of last Amual 34 Incomplete / Incorrect

Performance Evaluation

Dates of last two semi-annual 35 Incomplete / Incorrect

flow rate audits for PM

monitors

Dates of last two semi-annual 36 Insufficient information to judge

flow rate audits for Pb monitors

Distance between collocated 39 Incomplete / Insufficient information to

monitors judge
PM125 Collocation 42 Insufficient information to judge

Distance of site from nearest 73 Incomplete! Insufficient information to

road judge

Traffic count of nearest road 74 Incomplete / Insufficient information to

judge

Groundcover 75 Incorrect

Probe height 76 Incomplete! Insufficient information to

judge

Distance from supporting 77 Not meeting the requirement in some

structure instances: insufficient information to judge

in other instances.

Distance from obstructions on 78 Not meeting the requirement in one

the roof instances! Incomplete

Distance from obstructions not 79 Insufficient information to judge!

on the roof Incomplete

Distance from trees 80 Incomplete ! Insufficient information to

judge

Distance to furnace or 8 1 Incomplete! Insufficient information to

incinerator flue judge

Unrestricted airflow 82 Not meeting the requirement in one

instance; insufficient information to judge in

other instances

Probe material 83 Incomplete! Incorrect

Residence time 84 Incomplete

Additional information for each of these items may be found for the row listed in column 2. in

the fourth enclosure (D. Annual Monitoring NeRi’ork Plan Checklist,).
B. Additional Items Requiring Attention

System Modifications:

o Please continue to work with EPA to request and receive approvals for system

modifications in accordance with the criteria in 40 CFR 58.14.

o In your next plan, please discuss your future plans for a Type 3 PAMS site in the

Bakersfield MSA.

o In your next plan, please confirm that the GRIMM 180, previously operating at the

Corcoran site, has been closed and is no longer being operated at any site.

o Page 32 of your plan states that in order to meet the requirement in 40 CFR 58.10 (c),

the District notifies and seeks public comment on planned changes to the PM25

network through the Annual Network Plan process. In addition, for unanticipated

changes that occur outside of the ANP timeframe, the District posts a public notice in

papers and a description ofthe changes on the website and seeks public comment.

This process should have applied to the changes at Bakersfield-Muni in February

2013. Please clarify this section in future plans to include how the District intends to

handle all future changes to the PM2.5network.

• Porterville PM25 inconsistencies:

o Table 5 in your plan (page 10) lists the PM2.5monitor at Porterville as non-regulatory.

Per information in your approved 2011 ANP, this monitor is an FEM and started on

March 8, 2010 and was expected to produce regulatory data after it had been

operating for greater than two years. EPA considers all SPMs operating FRM or FEM

monitors for greater than 24 months to be regulatory. Please indicate that the

Porterville FEM is now considered regulatory, or work with EPA to justify keeping it

as non-regulatory.

o Table 17 lists the Porterville PM25 monitor as a non-FEM, although it is listed as an

FEM in Appendix A, and was previously approved as an FEM in your 2011 plan.

Please clarify what type of monitor has operated at this site throughout the period

since the site started in March 2010. Please note that even though this site is an SPM,

ifthe FEM operated for longer than 24 months, the data is considered regulatory, and

if violating, the closure of that monitor without approval could impact future planning

actions.

• Monitoring Objectives: Table 8b lists ozone SPMs at Tranquillity, Sequoia-Ash

Mountain and Sequoia-Lower Kaweah and the monitoring objective is listed as

timely/public.

o Since Tranquillity has been operating an FEM since 2009, its data are considered

comparable to the NAAQS, and the monitoring objective should also include

NAAQS comparison (standards/strategy).

o National Park Service monitors: The Sequoia-Ash Mountain ozone monitor is part of

the CASTNET network, and is considered a regulatory site. Therefore, the monitoring

objective should include NAAQS comparison (standards/strategy). Ifthe Sequoia

Lower Kaweah monitor is an FEM it may also be comparable to the NAAQS ifthe

other requirements of 40 CFR Part 58 are being met.
• Minimum Monitoring Requirements:

o Table 11 states that pending exceptional events are excluded from the highest

concentrations used to determine the minimum monitoring requirement for PM10.

Data that is not yet concurred upon for exclusion due to an exceptional event should

not be excluded from the design value calculation. In future plans, please include two

design values for minimum monitoring requirement tables: one that excludes

concurred-upon exceptional event days and one that includes all exceptional events.

o All MSAs are required to have continuous PM2.5monitoring. In your next ANP,

please clarify which monitors are meeting the requirements of 40 CFR 58 Appendix

D 4.7.2, and ensure that they have a monitor type of SLAMS.

o Possible typos:

• Table 7 in your plan lists six ozone SLAMS in the Bakersfield MSA, but Table 8a

lists seven. Please correct table 7 in your next plan.

• Please note that the Stockton MSA only has two SLAMS sites for PM25,but table

15 lists three.

o Please consider adding the following clarifications to Tables 11 and 15 in your next

plan:

Table 15 counts multiple monitors at the Modesto- 14th St site towards the

minimum monitoring requirements. The number of SLAMS sites in Table 15

should only refer to the number of sites in the MSA, not the number of regulatory

monitors.

• Since these tables show a column for both the number of SLAMS sites and SPM

sites, please clarify that only the SLAMS sites can be counted towards the

minimum number of monitors required.

• Also, clarifying that a site could be counted in both the SLAMS and SPM

columns would be helpful (e.g. ifthere was a SLAMS monitor and a SPM

monitor at the same site).

• Design Values for Sampling Frequency:

o In future plans please include the most recent design values for all PM2.5and PM10

sites. This information is needed to determine the sampling frequency for PM10 and

PM2.5monitors, as described in 40 CFR 58.12.

• SPMs:

o All SLAMS and any SPMs operating FRM or FEM monitors for longer than 24

months should have a monitor objective of NAAQS comparison (standards/strategy)

to indicate that the data are comparable to the NAAQS. including the PM25 FEM

BAM at the Clovis site.

o Previous plans included footnotes to indicate which SPM were running FEMs and

would be expected to be regulatory after 24 months. Please continue to include these

clarifications in future plans.

o Please consider changing longstanding SPMs producing regulatory data to SLAMS

(including Tranquillity 03, Hanford PM2.5).Due to planning implications, even

though these monitors are SPMs, closing these sites without EPA approval may

impact future planning actions since they are collecting regulatory data and are

currently or previously violating. If you wish to retain the SPM monitor type for any
of the sites operating FRM or FEM monitors for >24 months, please include a

justification in your next plan.

• Future AQS Changes: EPA is implementing changes to AQS fields of monitor type and

network affiliation. Please ensure that all your monitors are consistent with these changes

and include the updated information for monitor type and network affiliation(s) in your

next plan.

• Detailed site table recommendations:

o Some information is inconsistent between the body of the plan and the detailed site

tables in Appendix B.

o Please note clearly whether an item in the table is not applicable (or, for example,

cases where there are no trees) by using entries of “nla” or “none”, rather than leaving

the field blank.

o PM10 FRM and FEM monitors are required to be reported in standard conditions

(parameter code 81102). You can also report the PM10 data in local conditions

(85101), but please indicate in the detailed site table that it is one data stream from

the same monitor. One option would be to list both parameter codes under the column

for the single monitor.

o Please clarify the following for the Fresno-Garland NCore site in your next plan to

demonstrate that the site is meeting NCore requirements:

• This site is missing most of the detailed site information. Please work with CARE

before the next plan to fill in the missing information.

• Is the PM2.5monitor (POCs 1 and 5) listed on page B-13 for required PM2.5

speciation as an STN monitor?

• Please clarify which monitors are the PM102 .5pair (and collocated pair if

applicable).

• Please clarify whether the SO2and CO monitors are trace level instruments.

• NCore sites are required to measure NO concentrations. Please confirm that there

is an NO monitor operating at the site, and include the information for this

monitor in the detailed site table.

• Note that the PMcoarse collocation requirement is determined for the national

network and not by PQAO and the Fresno-Garland site is required to have

collocated PMcoarse monitors. Please clarify in your next plan if this information is

included in the SJV or CARB ANP.

• The entries for the SO2monitor in the detailed site table appear to be one row off

after the row for “distance from obstructions not on the roof’.

o The first page of the site table for Stockton Hazelton lists a FRM and an FEM, but the

remaining pages of the detailed site information only list an FEM.

o The Visalia —Church site lists NO as a parameter, but not NO2.Please confirm the

correct parameter in your next plan.

o The information about the PM monitors at Bakersfield-Muni is inconsistent. For

example, the site table on page B-38 lists the PM2.5monitor as an FEM, and the

detailed table on page B-39 lists it as a non-FEM. However, page B-39 also lists the

method code as 170, which is for an FEM PM25 BAM 1020. In your next plan, please

ensure that the entries in various parts of the plan for this and other sites are
consistent.

o In future plans. please include units and the source of data (including the year) for

your listed traffic counts.

o While monitor objective, instrument type and monitor type and operation duration

can provide valuable information about whether a monitor is comparable to the

NAAQS, sometimes the information presented in the plan is inconsistent. Please

include a specific statement about whether a PM25 monitor is comparable to the

NAAQS, and make that consistent with monitor objective. One possibility would he a

new line in the detailed site table. If a monitor is not comparable to the NAAQS,

please include the justification and EPA approval information, if applicable (e.g. for

exclusions based on 58.11(e) or 58.30).
C. Annual Monitoring Network Plan Items that EPA is Disapproving

Due to the closure and lack of approved replacement for the ozone monitor at Arvin Bear

Mountain Road (AQS ID 06-029-500 1), the requirement for a maximum ozone concentration

monitor in the Bakersfield Metropolitan Statistical Area (MSA) is not currently being met. EPA

is therefore disapproving the 40 CFR 58 Appendix D 4.1(b) network requirement in this MSA.

CARE and the SJVAPCD should continue working with EPA to resolve this issue. A

replacement, once approved by EPA under 40 CFR 58.14, can be used as the basis for approval

of the 40 CFR 58 Appendix D 4.1(b) requirement in future annual network plan actions.
D. ANNUAL MONITORING NETWORK PLAN CHECKLIST

(Updated 11/26/2013)

Year: 2013

Agency: San Joaquin Valley Air Quality Management District (SJVAPCD)40 CFR 58. l0(a)(1) requires that each Annual Network Plan (ANP) include information regarding the following types of monitors: SLAMSmonitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, SIN stations, State speciation stations, SPM

stations. and/or, in serious, severe and extreme ozone nonattainment areas. PAMS stations, and SPM monitoring stations.

40 CFR 58.10(a)(1) further directs that. “The plan shall include a statement of purposes for each monitor and evidence that siting and operation of

each monitor meets the requirements of appendices A. C, D. and E of this part. where applicable.” On this basis. review of the ANPs is based on the

requirements listed in 58.10 along with those in Appendices A, C. D, and E.EPA Region 9 will not take action to approve or disapprove any item for which Part 58 grants approval authority to the Administrator rather than theRegional Administrators, but we will do a check to see if the required information is included and correct. The items requiring approval by theAdministrator are: PAMS, NCore. and Speciation (STN/CSN).Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requirements, nor do its

contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welcomecomments on its contents and structure.
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

Submit plan by July Is 58.10 (a)(l) Yes Yes

2. Statement of purpose for each monitor 58.10 (aXi) Yes Yes

Appendix A

3. 30-day public comment I inspection period 5 58.10 (a)( I), Yes Yes

58.10 (a)(2) Appendix G and H

4. Modifications to SLAMS network — case when we 58.10 (a)(2) Yes Incomplete! Site closure of PM10 and PM25 SLAMS at

are not approving actual system modifications (i.e.. 58.10(e) Pages 39-41, incorrect Bakerstield-Muni were not approved. EPA will

we will do it outside the ANP process 6) Appendix B and C continue to work with the District to get additional

information since the infonEation included in the

plan for this request does not demonstrate that the

criteria in 58.14 were met.

Potential future modifications (not approved as part

. of this ANP process):

Closing Stockton-Wagner!Holt (PM10)Consolidating Madera-Pump to Madera-City

Consolidating Fresno-Pacific to Fresno-Drummond

See item #16 in this checklist for other potential

future system modifications

5. Modifications to SLAMS network—case when we 58.10 (a)(2) No No

are approving actual system modifications per 58.10 (b)(5)

58.14(c)

58.14

58.10(e)

(c)

6. Does plan include documentation (e.g., attached Yes Yes Site relocation: Fresno-First St to Fresno-Garland

approval letter) for system modifications that have Appendix Fbeen approved since last ANP approval?

Response options: NA (Not Applicable). Yes, No. Incomplete. Incorrect. The responses “Incomplete” and “lncorrect” assume that some information has been provided. 2 To the best of our knowledge.

Assuming the information is correct

Response options: NA (Not Applicable) — [reasoni. Yes, No, Insufficient to Judge.

The affected state or local agency must document the process for obtaining public comment and include any comments received through the public notification process within

their submitted plan.

See 58.14(c)
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

7. NCore site operational (by 1/1/201 I) 58.10 (a)(3) Yes Yes Fresno-Garland

8. Pb site for 0.5- 1.0 tpy sources operational (by 58.10 (a)(4) NA NA

12/27/2011)

9. NO plan for area-wide and RA4O sites submitted 58.10 (a)(5) No No In future plans. please speci which monitors in

by 7/1(2012 Pages 33-35 each CBSA fulfills the RA4O requirement. We

anticipate for the District to designate at least two of

the NO2 monitors in vulnerable/susceptible areas as

V meeting the RA4O requirement. See related itern#

None

60.

of the CBSAs in the District currently meet

the population threshold for required area-wide NO2monitors. See related item #59.

10. NO2area-wide and RA4O sites operational by 58.10 (a)(5) No Insufficient See notes for item #9.59 and 60..

1/1/20 13 information to

judge

11. NO2plan for near-road sites submitted by 7/1/2013 58.10 (a)(5) Yes • Yes for Fresno See attached near-road plan checklists.

. Insufficient Information was included for two of the four sites

information to that funding was provided to construct. Plans for all

judge for four sites are not due per the CFR until July 2016.

Bakersfield however. EPA expects to continue to work on the

siting of these monitors with the District.

12. SO2 sites operational (by 1/1/20 13) 58.10 (a)(6) Yes Yes Only required at NCore

and 58.13(d) Pages 35-36

13. AQS site identification number for each site 58.10 (b)(l) Yes Yes

Appendix B

14. Location of each site: street address and geographic 58.10 (b)(2) Yes Yes

coordinates Appendix B

15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes Incomplete! Fresno Garland: PM25 FRMs should be gravimetric,

parameter Appendix B incorrect analysis method missing for PM25 FEM.

Arvin-DiGiorgio: missing O instrument model.

Bakersfield California Aye: PM5 FRMs should be

Bakersfield-Muni:

gravimetric.

conflicting information about

whether continuous PM25 monitor is a FEM.

Manteca: analysis method missing for PM25 andSequoia-LowerPM10.

Kaweah: analysis method missing
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

for ozone.Visalia-Church: missing instrument and analysis

method for NO2.

16. Any proposals to remove or move a monitoring 58.10 (b)(5) Yes Incomplete Please clarify what the anticipated changes are for

station within a period of 18 months following plan Pages 39-41. the 03, CO, NO2,and all PM25 monitors at thesubmittal Appendix B Fresno-Garland site.

Please clarify the expected change for NMHC

(PAMS) listed for Parlier in Appendix B

Please clarify the expected change for 03 listed for

Arvin-Di Giorgio in Appendix B.

Please clarify what changes are expected for the

Bakersfield-Planz monitor noted in Appendix B.Please clarify whether there are any expectedchanges for PM10 at Bakersfield-California Ave(also note - there are current site upgrades that have

reduced instrumentation temporarily at this site).

Appendix B includes the PM instruments at the

Bakersfield-Muni site without any indication of

expected changes referring to the removal of all PMmonitors from this site.Continue to work with EPA to request approval for

the closure of the Stockton-Wagner/Holt PM10 site.

17. Scale of representativeness for each monitor as 58.l0(b)(6); Yes Incorrect! Fresno-Garland: Since urban scale (4 km—SO kin)

defined in Appendix D App D Appendix B incomplete is not a typical scale for PM10.please explain the

area around this site and justify the use of urban

scale for PM10 at this site. See 40 CFR 58, App. D

section 4.6.

Bakersfield-California Aye: please include scale for

the non-FEM PM2.5monitors in future plans.

4
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3mcet

Flag if the req? 4

incorrect 2?

Tracy-Airport: It is unclear whether a site that isneighborhood scale can have the objective ofregional transport. Please clarify or correct the scaleor monitor objective to be consistent with each other

for next year’s plan.

Visalia-Church: scale is missing for NO

18. Identification of sites suitable and sites not suitable 58.10 (b)(7) No Insufficient Please include a statement in your next year’s plan

for comparison to the annual PM2.5NAAQS as Pages 25-3 3 information to whether or not all of your sites are comparable to the

described in Part 58.30 judge Annual PM25 NAAQS as described in 40 CFR

58.30.

19. MSA, CBSA, CSA or other area represented by the 58.10 (b)(8) Yes Yes

monitor Pages 6-7 and

Appendix B

20. Designation of any Pb monitors as either source- 58.10 (b)(9) Yes Incomplete The required non-source oriented Pb monitor

oriented or non-source-oriented Pages 36-3 7 and required at the Fresno-NCore site is discussed on

Appendix B pages 36-37, but the information about the monitor

is missing from the detailed site tables in Appendix

B. Please include this information in next year’s

plan.

21. Any source-oriented Pb site for which a waiver has 58.10 (b)( 10) na na

been granted by EPA RA

22. Any Pb monitor for which a waiver has been 58.10 (b)(1 1) na na

requested or granted by EPA RA for use of Pb-PM 10

in lieu of Pb-TSP

23. Identification of required NO2 monitors as either 58.10 (b)(12) na na No area-wide sites are required. In future plans, as

near-road or area-wide your near-road sites are approved and become

operational, please identify them clearly as nearroad.

24. Identification of any PM25 FEMs and/or ARMs not 58.10 (b)(l3) No na No request was made to exclude PM25 FEM data

eligible to be compared to the NAAQS (Note 1: 58.1 1 (e) from comparison to the NAAQS at SLAMS or atmust include required data assessment.) (Note 2: SPM sites that have been operating longer than 24

Required SLAMS must monitor PM25 with months. Therefore, EPA assumes that all FEMs at

NAAQS-cornparable monitor at the required sample SLAMS or at SPMs operating longer than 24

frequency.) months are comparable to the NAAQS.

25. For SPMs listed as non-regulatory, note the start 5 8.20(c) No Insufficient Please ensure that next year’s plan clearly states that

Date of FRM.’FEM/ARM at SPM. If> 24 months, information to all PM25 SPMs operating FEMs for longer than 24

5
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4incorrect 2?

and monitor is eligible for comparison to the judge months are comparable to the NAAQS. or submit

NAAQS per 58. I I (e) and 58.30, the agency must the information justifying that it is not NAAQS

supply information that App A. C or E requirements comparable. See Row 47 for additional information.were not met.

26. Document how states and local agencies provide for 58.10 (c) Yes Insufficient in next year’s plan. please submit the documentation

the review of changes to a PM- monitoring Page 32 information to of how the process outlined on page 32 was

network that impact the location ofa violating PM- 5 judge followed for any recent PM- monitor changes,monitor. including, but not limited to. the closure of PM25

monitors at Bakerstield-Muni and the temporary

closure of PM, 5monitors at Bakersfield-California.

27. Does the plan include a request for approval for and 58.1 1 (a) (2) No na

alternative to appendix A requirements for SPMsoperating a FRM!FEM!ARM which also meets

appendix E?

28. Precision!Accuracy reports submitted to AQS 58.16(a); Yes Incomplete! The ANP should note the required schedule for AQS

App A. 1.3 Page 41 Insufficient data submission — which is 90 days after the end of

and 5.1.1 information to each quarter. Please include this information in your

judge next ANP.

29. Annual data certification submitted 58.15 Yes Incomplete! In your next ANP, please describe the certification

App. A 1.3 Page 41 Insufficient ofthe data from all District and CARB operated

information to sites that are included in your ANP. including the

judge required certification date of May 1.

30. Frequency of flow rate verification for manual PM App A 3.3.2 Yes Incomplete! Fresno-Drummond: the flow verification for the

samplers audit Appendix B incorrect PM25 FEM should be listed under the automated

Bakersfield-California

analyzers

Aye: the flow verification

information is missing for the collocated PM10

Bakersfield-Muni:

monitor

the flow verification information

is missing for the PM monitors

Corcoran: the flow verification information is

, missing for the PM25 monitor

Stockton-l-lazelton: flow verification information

provided appears to be incorrect and seems to be

6
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4incorrect 2?

confused with the semi-annual flow audit

information

31. Frequency of flow rate verification for automated App A 3.2.3 Yes Incomplete! Clovis-Villa: the PM25 Therrno-2025i should be

PM analyzers audit Appendix B incorrect listed as a manual sampler

Fresno-Garland: flow verification is missing for

automated PM25 and PM10 monitors

Bakersfield-Muni: the flow verification information

is missing for the PM monitorsHanford: the flow verification information is

missing for the PM10 FEM monitorStockton-Hazelton: flow verification infoniation

provided appears to be incorrect and seems to be

confused with the semi-annual flow audit

information

32. Frequency of one-point flow rate verification for Pb App A No Insufficient Information for the Pb monitor at Fresno-Garland

samplers audit 3.3.4.1 information to was not included in Appendix B

judge

33. Frequency of one-point QC check (gaseous) App. A 3.2.1 Yes Incomplete Bakersfield-Muni: the one-point QC check

Appendix B information was missing for the gaseous monitors

Sequoia-Ash Mountain and Sequoia-Lower

Kaweah: the one-point QC check information was

missing for the ozone monitors

Visalia-Church: the one-point QC check information

was missing for the NO2 monitor

34. Date of last Annual Performance Evaluation App. A 3.2.2 Yes Incomplete! Fresno-Garland: The most recent annual PE

(gaseous) Appendix B incorrect information for the 03 monitor is listed as

9/22/20 10, before the site was operating. while all

the other gaseous criteria pollutants have annual PEs

listed in April 2012. Please confirm that all gaseous

criteria monitors have annual PE’s performed in

2013 in your next plan.

7
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

Visalia-Church: the Annual PE information was

missing for the NO2 monitor

35. Dates of last two semi-annual flow rate audits for App A. 3.2.4 Yes Incomplete.’ Most sites have one flow audit listed per year

PM monitors and 3.3.3 Appendix B incorrect (sometimes 2010 and 2012. sometimes 2011 and

2012). or the information is missing. For future

plans. please include the dates of the two

semiannual flow rate audits for the calendar year

preceding the plan submittal. For example. for yourplan due by July 1. 2014, please include the dates

for the two semiannual flow rate audits performed in

.

Fresno-Garland:

2013.

note the information for the PM25

FEM is mistakenly listed under the annual PE for

gaseous pollutants

36. Dates of last two semi-annual flow rate audits for Pb App A No Insufficient Information for the Pb monitor at Fresno-Garland

monitors 3.3.4.1 information to was not included in Appendix B 

judge

37. PM2.5collocation App A 3.2.5 NA NA The requirement for collocation is for the PQAO

and is addressed in the CARE ANP.

38. Designation ofa primary monitor if there is more iVeedto Yes Insufficient For any sites with more than one FRM!FEM!ARM

than one monitor for a pollutant at a site. determine information to for a pollutant at a site, please note which is

collOCation judge considered the primary monitor. For example. this

information is not clear for the following sites:

Clovis. Bakersfield-California Ave. Bakersfield

M uni. Corcoran, Stockton-Hazelton. Modesto-I 411

St.

39. Distance between collocated monitors (Note: waiver .4pp..-l Yes Incomplete / In some cases, collocation distances are missing. It

request or the date of previous waiver approval must 3.2.5.6 and Insufficient is also often unclear which monitors at a site arebe included if the distance deviates from 3.2.6.3 information to primary, which are collocated monitors for QArequirement.) judge purposes as required by 40 CFR Part 58 Appendix

A, and which are extra monitors not intended forQA collocation. In your next ANP, please clarify thepurpose of each monitor (primary. QA Collocated or

extra) and include collocated distance information

for sites that have more than one FRM/FEM monitor

of the same pollutant, including at Clovis-Villa,Fresno-Drummond, Fresno-Garland, Bakersfield8
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4incorrect 2?

California Aye, Bakersfield-Muni. Corcoran,

Stockton-Hazelton. Tracy-Airport. and Modesto- 14111

St. While to distance requirement for collocated

monitors applies only to a monitor pair that is

intended for QA (a primary monitor and QA

collocated monitor), the distances between all PMinstruments at a site is important to determine

whether there is a possibility of obstruction or flow

interferences, especially for hi-volume samplers.

40. Manual PM10 method collocation met? (note: App A 3.3.1 NA NA The requirement for collocation is for the PQAO

continuous PM10 does not have this requirement) Page and is addressed in the CARB ANP.

41. Pbcollocation AppA NA NA Notrequired

3.3.4.3

42. PM1025 collocation (note: only applies to Fresno App A 3.3.6 No Insufficient Note that the PM102 .5collocation requirement is

and Phoenix NCore sites) information to determined for the national network and not by

judge PQAO and the Fresno-Garland site is required to

have collocated PM10,5monitors. Please clarify in

your next plan if this information is included in the

SJV or CARB ANP.

43. Instrument/monitoring method code for each App C Yes Incomplete! The method codes are missing or incorrect for the

monitor: is it reported properly? Is it reported 2.4.1.2 Appendix B incorrect following instruments: PM10 FEM at Fresno

correctly (i.e., appropriate method code for Garland, PM75 FRM at Fresno-Pacific, 03 FEM atregulatory monitors)? Arvin-DiGiorgio, PM75 FRM at Bakersfield-Planz,

PM25 monitors at Bakersfield-Muni, PM, 5 FEM at

Porterville, PM2.5monitors at Sequoia-Ash Mtn, and

NO7 monitor at Visalia-Church.

44. For agencies that share monitoring responsibilities App D 2(e) No Insufficient Kern County (Bakersfield MSA) is split between

in an MSA/CSA: does each affected State or local information to SJVAPCD and Eastern Kern APCD jurisdictions.

agency meet full monitoring requirements or is judge Currently, all minimum monitoring requirements foran agreement between the affected agencies and the the Bakersfield MSA are met by the SJVAPCD andEPA Regional Administrator in place? CARB monitors in the valley portion of Kern

County. In your next ANP, please consider

including a footnote, like the one for Table 7, on

Tables I I and 15, indicating that these are showing

the requirements for PM10 and PM25 are met withmonitors in the Valley portion of Kern County

alone.

9
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4incorrect 2?

Visalia-Porterville MSA — The maximum

concentration site for O in the Visalia-Porterville

MSA is a NPS-operated, regulatory CASTNET

monitor. Please work with EPA and NPS todetermine if an agreement is needed to indicate that

the requirements for monitoring in this MSA are met

by more than one agency, and include the

information in next year’s ANP.

45. Start date for each monitor Required to Yes Incomplete Include start dates for all monitors. The following

determine if Appendix B sites had missing start dates for at least some

other req. monitors: Fresno-Garland. Bakersfield-Planz.(e.g., mm # Bakersfield-California Ave. Edison. Oildale.

and col bc) Corcoran. Merced-Coffee, Stockton-Hazelton,

are met Modestol4th St, and Visalia-Church.

In your next plan, please clarify (perhaps in the site

description or a footnote to the detailed site table)when regulatory PM25 monitoring began at the

Corcoran site. The detailed site table in Appendix Bcurrently lists September 2012 as the start date for

the PM25 monitor currently operating at the site,however, previous plans indicate that regulatorymonitoring for PM25 started at the site in October

1996.

46. Instrument monitor type for each monitor Required to Yes Incomplete,’ Bakersfield-California Aye: PM10 collocated

determine if Appendix B incorrect instrument should be a SLAMS, not other: monitor

other req. Pages 23-25, 30-32 type is missing for NO2

(e.g., mm #

and colboc) Bakersfield-Muni: Monitor type for PM instrumentsare met should be SLAMS. The 201 1 Plan clearly identifies

the Bakersfield-Muni site as an intendedreplacement for the Bakersfield-Golden site whichwere all SLAMS. Conversion of a SLAMS to SPM

can only occur with approval from EPA’s Regional

Administrator — see 40 CFR 58.20 (a):

The monitoring agency may designate a monitor as

an SPM after January 1, 2007 only’ if it is a new

monitor. i.e., a SLAMS monitor that is not included

10
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3nicet

Flag if the req’? 4

incorrect 2?

in the currently applicable monitoring plan or. for a

monitor included in the monitoring plan prior to

January 1. 2007. if the Regional Administrator has

approved the discontinuation of the monitor as a

SLAMS site.

Since EPA has not approved closure of theBakersfield Muni SLAMS, the PM monitors should

remain listed as SLAMS until closure is officially

approved by EPA.

For all SPMs operating FRM or FEM monitors forlonger than two years, please consider switching the

monitor type to SLAMS, especially for any monitors

violating the NAAQS, since they would require

approval for shutdown (includes PM25 monitors atTranquillity, Hanford, Madera-City, Merced-Coffee.and Porterville, and PM10 monitors at Hanford,

Manteca and Tracy-Airport.and 03 monitor at

Monitor

Tranquillity).

type is not consistent for some PM

monitors between the text of the plan and the tables

in Appendix B (e.g. Madera-City PM25).

All required parameters for PAMS and NCore sites

should have a monitor type of SLAMS, not SPM.

Please refer to recent AQS memos for changes to

the monitor type and network affiliation fields.

47. Monitoring objective for each instrument App D 1 .1 Yes Incomplete! The three monitoring objectives as described in 40

58.10 (b)(6) Pages 15-36 and incorrect CFR 58 App D 1.1 are to provide air pollution data

Appendix B to the public in a timely manner. NAAQS

comparison and research support. Highestconcentration is a site type, not a monitoringobjective (e.g. the ozone monitor at Oildale).

Many monitors that are collecting regulatory data inSJV, including all SLAMS as well as SPMs that

11
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

operate FRM or FEM monitors for longer than 24months, do not include NAAQS comparison as a

monitoring objective (listed as standards/strategy in

your plan). Please make any necessary changes to

the monitoring objectives for your next plan to

clearly indicate which monitors are comparable to

the NAAQS, including, but not limited to

FRM;FEM monitors at Clovis. Fresno-Garland.Tranquillity. Bakersfield-Planz. BakersfieldCalifornia-Ave. Edison, Oildale. Shafter. Corcoran.Hanford. Madera-City. Merced-Coffee, Stockton

1-lazelton. Tracy-Airport, Modestol4th St. Turlock.

Porterville. See Row 25 for more infonnation.

Monitoring objectives should not be “unknown”.

“other” or “not specified” please add theappropriate monitor objective to monitors at the

Bakersfield-California-Ave. Fresno-Garland.

Edison. Oildale. and Visalia-Church sites in yournext ANP.

Required PAMS and NCore parameters should also

not have a monitoring objective of “other” or

“unknown”. Please confinn that the monitoringobjectives are consistent with the networkaffiliation, other sites in the area and observed

concentrations (e.g. should CO and NO2be max

precursor emissions impact, which is usually amonitoring objective for downwind max ozoneThesites).

Sequoia-Lower Kaweah ozone site is not a

CASTNET site. Please work with EPA before your

next plan to determine whether this site objectiveshould be NAAQS comparison.

48. Site type for each instrument App D 1.1.1 Yes Incomplete’ Fresno-Garland: NCore is not a site type.

Pages 15-36 and incorrect

Appendix B Consider including max ozone concentration site

12
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #5. provided 3meet

Flag if the req? 4incorrect 2?

type for the ozone monitors at Clovis, Fresno

Drummond, Fresno-Garland and Oildale.

Consider including highest concentration site typefor the PM monitors at Corcoran, Madera-City,

The site type should be consistent between monitorsofthe same pollutant at a site (e.g. PM25 at Clovis).

Site types for monitors intended to fulfill QA

collocation requirements in 40 CFR 58 Appendix Ashould have a site type of “quality assurance”.

Site type was not included for some monitors at the

following sites: Bakersfield-California Aye,Modesto- 14th St, and Visalia-Church.

49. Instrument parameter code for each instrument Required to Yes Incomplete! Parameter code is listed as “TBD (85101 or 81 102)”

determine if Appendix B incorrect for PM10 FEM at Fresno-Garland. Required PM10other req. SLAMS must be reported as 81102 (they may(e.g., mm # additionally be reported as 85101).and colloc)are met The parameter code for the PM10 FEM at Madera

City and Manteca must be 81 102 (data may also bereported as 85101).

The parameter code is missing for PM25 at

Tranquillity and some ofthe monitors at VisaliaChurch.

50. Instrument parameter occurrence code for each Required to Yes Yes

instrument determine if Appendix B

other req.(e.g., mm #and colloc)are met

SI. Sampling season for ozone (note: date of waiver 58.10 (b)(4) Yes Incomplete Ozone sampling season is missing for Bakersfield

approval must be included if the sampling season App D, 4.1(i) Appendix B California Ave site.deviates from requirement)

52. Sampling schedule for PM25 - applies to year-round 58.10 (b)(4) Yes Incomplete! In your next ANP, please include the most recent

IL1—,
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

and seasonal sampling schedules (note: date of 58.12(d) Appendix B Insufficient design value at each site to provide sufficient

waiver approval must be included if the sampling App D 4.7 information to information to determine whether the sampling

season deviates from requirement) EPA judge frequency at each site is appropriate.

fi owc hart

Sampling season is not included for the PM, 5

monitors at Madera-City and Bakersfield-M uni.

Please note that any’ monitors operating on a

seasonal schedule require approval from EPA (e.g.

Bakersfield-Muni FRM). Documentation of these

approvals should be included with the ANPs.

53. Sampling schedule for PM10 58.10 (b)(4) Yes Insufficient In your next ANP, please include the most recent

58.12(e) Appendix B information to design value at each site to provide sufficient

App D 4.6 judge information to determine whether the sampling

frequency at each site is appropriate.

54. Sampling schedule for Pb 58.10 (b)(4) No Insufficient Information for the Pb monitor at Fresno-Garland

58.12(b) information to was not included in Appendix B

AppD4.5 judge

55. Sampling schedule for PM1.25 58.10 (b)(4) Yes Insufficient Not clear which monitors were intended for PM102 ,5

58.12(f) Appendix B information to

App D4.8 judge

56. Minimum # ofinonitors for Os [Note: should be App D. 4.1(a) Yes Yes

supported by’ MSA ID, MSA population. DV, # and

monitors, and # required monitors] (see footnote) 7 Table D-2

57. identification ofmax. conc. 03 monitor(s) App D 4.1 incomplete Yes for the Fresno For maximum concentration sites, please ensure in

(b) MSA your next ANP that the site types and other

information in the main body of the plan

No for Bakersfield consistently identify which sites in a MSA are

MSA; considered maximum concentration sites.

Insufficient Due to the closure and unresolved approval for ainformation to replacement site for the long-standing design value

judge for the ozone monitor at Arvin-Bear Mountain Blvd (06-

Hanford-Corcoran, 029-500 1), the requirement for a maximum ozoneMadera. Merced. concentration monitor in the Bakersfield MSA is not

Only monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements. In addition, ozone monitors that do not meet

traffic count/distance requireillerils to be neighborhood scale (40 CFR 58 Appendix E. Table E-l) cannot be counted towards minimum monitoring requirements.

14
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

Stockton. Modesto currently met.

and VisaliaPorterville MSAs Each MSA is required to have a high concentration

monitor. In your next ANP, please note which sites

in the following MSAs are high concentration sites:

Hanford-Corcoran, Madera. Merced. Stockton.

Modesto, and Visalia-Porterville MSAs.

Also, since Fresno-Drummond and Fresno-Garlandcould be considered high concentration sites givenrecent measured concentrations, please consideradding maximum ozone concentration as a site type.

58. Minimum monitoring requirements met for near- App D 4.3.2 NA NA None required by 2014

road NO2(2014 start date)

59. Minimum monitoring requirements met for area- App D 4.3.3 NA NA None required. See related items #9 and 10.

wide NO2

60. Minimum monitoring requirements met for RA-40 App D 4.3.4 No No EPA previously requested SJV to identi’ two sites

NO2 as RA40 NO, sites. The District and EPA

preliminarily agreed that the Parlier and replacement

PAMS site in Arvin would be these sites. Since the

PAMS replacement site in Arvin is delayed, EPA

then suggested that the Bakersfield-Muni site serveas one of the two RA4O sites temporarily until theArvin NO2 monitor is reestablished. Please include

this information in your next ANP.

61. Minimum monitoring requirements met for SO2 App D 4.4 NA NA None required

[Note: Only monitors considered to be required

SLAMs are eligible to be counted towards meeting

minimum monitoring requirements.]

62. Minimum monitoring requirements met for Pb App D 4.5 Yes Yes NCore site has TSP-Pb

[Note: Only monitors considered to be required 58.13(a)

SLAMs are eligible to be counted towards meeting

minimum monitoring requirements.]

63. Minimum # of monitors for PM25 [Note 1: should App D, Yes Yes Please note that the Stockton MSA only has two

be supported by MSA ID. MSA population, DV, # 4.7.1(a) and Pages 25-32 SLAMS sites for PM25,but Table 15 on page 26

monitors, and # required monitors] [Note 2: Only Table D-5 lists three.monitors considered to be required SLAMs areeligible to be counted towards meeting minimum

15
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

monitoring requireinents.1

64. Optional PM25 Network Clarifications: Provide a Need to na na

list of required sites if it does not include all assess several

SLAMS. [Note: default will assume all SLAMS are requirementsconsidered required sites.]

65. Required PM25 sites represent area-wide air quality App D Yes Yes

4.7.1(b) Pages 25-32. and

Appendix B

66. For PM25.is at least one site at neighborhood or App D Yes Yes for the Fresno For your next ANP, a site type of highest

larger scale in an area of expected maximum 4.7. l(b)( 1) Pages 25-32, and and Hanford- concentration should be added to the Bakersfieldconcentration Appendix B Corcoran MSAs California Ave and Bakersfield-Planz PM25

monitors to indicate that they fulfill this requirement

Incomplete / for the Bakersfield MSA, since the high

Incorrect! concentration monitors at Bakersfield-Muni have

Insufficient been removed.

information to

judge for the EPA suggests including an evaluation of the data

Bakersfield. from Bakersfield-Muni in the 2015 Network

Madera. Merced, Assessment to deterniine ifthe concentrationsStockton, Modesto observed are reflective of significant sources in the

and Visalia- emissions inventory that are not currently

Porterville MSAs characterized by the existing monitoring network.

The Madera-City monitor should be listed as high

concentration in your next ANP to meet this

requirement for the Madera MSA.

Based on 2012 design values, the Merced-Coffee

PM, 5monitor should be the max concentration sitefor the Merced MSA rather than Merced M St. If the

max concentration site shifts year to year, please list

both as the high concentration sites.

In your next ANP, please use the most recent DVs

to select a max concentration site for the Stockton

MSA. and include highest concentration as the site

type for the appropriate site. If the maxconcentration site shifts year to ‘ear, please list both

16
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

as the high concentration sites.

The Turlocl. monitor is not listed as high

concentration, but based on 2012 DVs should be

listed as such in your next ANP to meet this

requirement for the Modesto MSA. If the max

concentration site shifts year to year, please list bothas the high concentration sites.

In your next ANP, please use the most recent DVs

to select a max concentration site for the Visalia

Porterville MSA. and include highest concentration

as the site type for the appropriate site.

67. If additional SLAMS PM25 required, is there a site App D Yes Yes

in an area of poor air quality 4.7.1(b)(2) Pages 25-32

68. Minimum monitoring requirements for continuous App D 4.7.2 No Insufficient All MSAs are required to have continuous PM25

25 information to monitoring. This requirement can be met by FEM or

judge non-FEM monitors, and although not demonstrated

in the plan, it is likely that the requirement is met. In

your next ANP. please evaluate how therequirements of 40 CFR 58 Appendix D 4.7.2 applyto each of your MSAs, and clarify which monitors

are intended to meet this requirement. Lastly. toindicate that they are meeting this requirement.

please ensure that the identified monitors have amonitor type of SLAMS.

69. Requirements for PM2.5background and transport App D 4.7.3 na na This is a statewide requirement and is expected to be

sites discussed in the CARB network plan

70. Are PM2 Chemical Speciation requirements met App D 4.7.4 No Insufficient Please list any required CSN!STN sites in the San

for official STN sites? information to Joaquin Valley in your next ANP.

judge

71. Minimum # of monitors for PM10 App D, 4.6 Yes Incorrect Flagged exceptional events and data from temporary

(a) and Table Pages 20-25 sites such as Bakersfield-Muni should not be

D-4 excluded from the data used to determine the

required number of PM10 monitors. Please include

all 2013 data in the evaluation of maximumconcentration for each MSA for your next ANP.

17
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

Given 2012 data alone, the monitors required for the

Bakersfield MSA should be 2-4. rather than 1-2.

Since there are two monitors in the MSA the

requirement is still being met.

72. Minimum monitoring requirements met for PM105 App D 1.8 Yes Insufficient It is unclear which monitors at the Fresno-Garland

mass Page 37 and information to site are intended to meet the PM102 .5requirement for

Appendix B judge NCore

73. Distance of site from nearest road App E 6 Yes Incomplete / Distance to nearest roadway is missing for the

Appendix B insufficient Fresno-Garland and Lebec sites.

information to

judge For your next ANP, consider whether the PM10 and

PM75 sites at Modesto14th Street should be

considered micro- or middle-scale due to thedistance to the roadway. or consider moving the

monitors further from the roadway if the space at the

site allows.

It is unclear whether the distance from the road for

the neighborhood-scale 03, CO. NO7,PM10 and

PM25 monitors at Turlock meet the required

minimum distance from the road as described in 40

CFR Appendix E: please evaluate and clarify this in

your next ANP.

74. Traffic count of nearest road App E Yes Incomplete / Traffic counts missing for the following sites:

Appendix B insufficient Fresno-Garland, Tranquillity. Maricopa. Shafter,

information to Madera-City. Madera-Pump Yard. Merced-Coffee.

judge Manteca. Stockton Wagner/Holt. Porterville.

75. Groundcover App E 3(a) Yes Incorrect Roof is not an appropriate groundcover: please

Appendix B correct this for Fresno-Garland, Fresno-Pacific.

Bakersfield-California Aye, Hanford. Stockton

Hazelton. ModestoI4th St and Visalia-Church in

your next ANP. Note that ARB is similarly revising

groundcover listings for their QA site reports.

76. Probe height App E 2 Yes Incomplete! Probe height is missing for some monitors at the

Appendix B insufficient following sites: Fresno-Garland. Arvin-DiGiorgio,

information to Bakersfield-Planz, Bakersfield-California Ave.

judge Bakersfield-Muni, Edison, Oildale. Corcoran.

Stockton-Hazelton. Modestol4th St. and Visalia

18
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

Church.

77. Distance from supporting structure App E 2 Yes No The minimum horizontal and vertical distance from

Appendix B a supporting structure for PM10 and PM25 monitors

should be 2 meters. Please evaluate whether thatsiting requirement can be met for PM monitors at

the following sites that are less than 2 m from the

supporting structure: Clovis, Huron, Madera-City.

Manteca, Stockton-Wagner!HoIt, and Sequoia-Ash

TheMountain.

minimum horizontal and vertical distance from

a supporting structure for O monitors should be 1

meter. Please evaluate whether that sitingrequirement can be met for PM monitors at the

following sites that are less than 1 m from thesupporting structure: Madera-City.This distance was not provided for the followingsites: Fresno-Drummond, Fresno-Garland,

Tranquillity, Bakersfield-California-Aye,

Bakersfield-Planz, Bakersfield-Muni, Edison,Lebec, Maricopa, Oildale, Shafter, Corcoran,

Hanford, Madera-Pump Yard, Merced-Coffee,

Merced-M St. Stockton-Hazelton. Tracy-Airport,Modesto14th St, Turlock, Porterville, SequoiaLower Kaweah, and Visalia-Church. Please include

a distance in your next year’s plan or indicate that it

is not applicable (both for horizontal or vertical

distances).

78. Distance from obstructions on roof App E 4(b) Yes No! Incomplete The plan lists an on-roof obstruction 0.5 meters

Appendix B away from the PM10 instrument at the Fresno

Drummond site. The minimum distance allowed by

40 CFR 58 Appendix E between PM monitors and

an obstruction on the roof is 2 meters. Please workwith EPA to address this siting issue, and note it in

your next ANP.

This information was missing or unclear for most
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

sites in the plan. Please include this information in

your next ANP. or use an entry of “none” to clearly

indicate the instances where there are no

obstructions.

79. Distance from obstructions not on roof App E 4(a) Yes Insufficient The following sites listed obstructions not on the

Appendix B information to roof Clovis, Fresno-Drummond, Fresno-Garland,

judge /lncomplete Fresno-Sky Park, Madera-City. Manteca, TracyAirport. and Porterville. In order to demonstrate

whether these obstructions cause a siting issue,

please include in future ANPs the height of the

obstruction above the inlet of each monitor, as well

as a discussion of whether it meets the criteria in 40CFR 58 Appendix E 4(a) for not causing asignificant obstruction.

This information was missing or unclear for most

sites in the plan. Please include this information in

your next ANP, or use an entry of “none” to clearly

indicate the instances where there are no

obstructions.

80. Distance from trees App E 5 Yes Incomplete! Information about distance to trees is missing for the

Appendix B insufficient following sites: Clovis (PM25),Fresno-Drummond

information to (PM25).Fresno-Garland (PM ), Parlier (03, NO2)

judge Arvin-DiGiorgio (O). Bakersfield-Muni (all

monitors). Lebec (PM25).Maricopa (03). Shafter

(all monitors). Hanford (all monitors). Merced-M St(PM monitors). Porterville (O and PM25).In yournext plan. include any distances for trees at these

sites, or clearly indicate that there are no trees.

The distance to trees for all monitors at the

Stockton-Hazelton site is listed as zero meters. In

your next plan, please clarit,’ if there are trees

adjacent to the monitors or no trees.

For your next ANP, please re-evaluate the distance

and potential obstruction due to the tree at the

Edison site and confirm that this site meets the

20
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

criteria in 40 CFR 58 Appendix E § 4 and 5.

81. Distance to furnace or incinerator flue App E 3(b) Yes Incomplete! The distance to any nearby flues is missing for some

Appendix B Insufficient monitors at the following sites: Clovis, Fresno

information to Drummond, Fresno-Garland. Bakersfield-M uni.

judge Lebec, Maricopa, Corcoran, Hanford, Madera-Pump

Yard, Merced-Coffee, Stockton-Wagner/Holt,Tracy-Airport, and Porterville.

In your next ANP, please either include a distance

for all monitors or indicate that there is not a flueclose to any of the monitor inlets.

82. Unrestricted airflow App E, 4(a) Yes No PM instruments should have at least 270 degrees of

and 4(b) Appendix B unobstructed flow. The PM10 monitor at Fresno

Drummond has an unobstructed airflow of 260

degrees. Please work with EPA to address this siting

issue before your next ANP.

The amount of unrestricted airflow is missing for the

PM, 5 FEM monitor and PM10 monitor at Fresno

Garland, the collocated PM10 monitor at

Bakersfield-California Ave. all of the monitors at

Bakersfield-Muni, the PM10 FEM monitor at

Hanford, and the 03 monitor at Sequoia-Lower

Kaweah. Please include this information in nextvears ANP.

83. Probe material (if applicable) App E 9 Yes Incomplete! Probe material was not provided for the reactive

Appendix B incorrect gaseous monitors at Bakersfield-Muni and for NO,

at Visalia-Church.

This probe material requirement only applies to the

reactive gases and not PM monitors or met.

However. EPA notes that the probe material isincorrectly listed as Teflon for PM10,PM, 5or

meteorology instruments at the following sites:

Fresno-Garland, Bakersfield-Planz, BakersfieldCalifornia Ave. Oildale, Corcoran, Manteca,

Stockton-Hazelton, Tracy-Airport. Modesto-I 4hh1 s,Sequoia-Ash Mountain, and Visalia-Church.

21
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4incorrect 2?

84, Residence time (if applicable) App E 9 Yes Incomplete Residence time was missing for the 03 monitOr at

Appendix B ModestoI4th St.

72
E.1 Region 9 Near-road NO2 Plan review checklistChecklist Version date: October 23, 201 3

Agency: San Joaquin Valley Air Pollution Control DistrictCBSA: Fresno

This checklist is intended to clarify those elements that EPA will be looking for during the review of proposed near-road NO2 monitoring

sites. Please note that this checklist summarizes near-road NO2site requirements of 40 CFR Part 58, but does not substitute for thoserequirements, nor do its contents provide a binding determination of compliance with those requirements. The checklist is subject to revision

in the future and we welcome comments on its contents and structure.WhiteKey:

= meets the requirement.

Yellow = does not meet or cannot judge the requirement — action requested in next year’s plan or outside the ANP process.

meets the requirement but action requested to improve next year’s plan.
COMPLETENESS CHECK: Based on 40 CFR 58 requirements.

Network Plan requirements (40 CFR 58.10)-

No. Near-road N02 plan requirement Citation Info Requirement Notes

submitted? 1 met? 2

If yes, page

#s.

A plan (submitted by July 1, 2013) for 40 CFR Incomplete — Insufficient to Plan submitted to EPA on June 25, 2013.establishing near-road N02 monitoring 58.10(a)(5) Appendix E judge.

site(s) Assuming that the final site is accurately

characterized by the information provided and

meets all of the applicable 40 CFR Part 58criteria, we expect that we will be able to

approve the District’s NO2near-roadway

Fresno site selection. The District will need to

resubmit a plan that includes missinginformation highlighted in this checklist to

receive EPA approval. The re-submitted planshould go through a minimum 30 day public

inspection period prior to re-submittal to

EPA.

2 Evidence of public comment on proposed 40 CFR Incomplete — Insufficient to See item 1.

site(s), no changes subsequent to proposal, 58.10(a)(2) Appendix 0 judge.

and submittal of any received comments

3 Anticipated operation start date 40 CFR No Insufficient to Please include this information in the final

58.10(a)(5) judge. submittal.

4 AQS site identification number 40 CFR No Insufficient to Please include this information in the final

58.1 0(b)( 1) judge. submittal if available.

5 Location (street address & geographical 40 CFR Incomplete Insufficient to Please include geographical coordinates in the

coordinates) 58.10(b)(2) Pg. E-19 judge. final submittal.

address only

1 Response options: N/A (Not Applicable), Yes, No, Incomplete, Incorrect. The responses “Incomplete” and “Incorrect” assume that some information has been

2

provided.

Response options: N/A (Not Applicable) — [reason], Yes, No, Insufficient to Judge. Assumes information submitted is correct.

7
6 Sampling and analysis method (method 40 CFR No Insufficient to Please include this information in the final

code) 58.lO(b)(3) judge. submittal.

7 Operation Schedule (Season & sampling 40 CFR No Insufficient to Please include this information in the final

frequency) 58.1 0(b)(4) judge. submittal.

8 Any proposal to remove or move the 40 CFR No Insufficient to Please include this information in the final

monitor within a period of 18 months 58.1 0(b)(5) judge. submittal.

following plan submittal

9 Monitoring objective & spatial scale of 40 CFR Yes, Pg. E- Yes

representativeness 58.l0(b)(6) 17

10 CBSA represented by the monitor 40 CFR Yes, Pg. E-8 Yes

58. 10(b)(8)

Network Design requirements (40 CFR 58, Appendix D, Section 4.3.2)

1 1 CBSA population & year 40 CFR 58, Yes, Table Yes

App.D 4, Pg. 8

4.3.2(a)

document)

(main

12 Maximum AADT counts & year for the 40 CFR 58, Yes, Pg. E- Yes

CBSA(s) App.D 10 & E-24-

4.3.2(a) 25

13 Correct # of required near-road N02 40 CFR 58, Yes, Pg. E-1 Yes

monitors for the CBSA(s)

4.3.2(a)

App.D

14 Were all road segments within the CBSA 40 CFR 58, Yes, Pg. E- Yes

ranked by AADT? App.D 24-25

4.3.2(a)( 1)

15 Discussion of how fleet mix is considered 40 CFR 58, Yes, Pg. E- Yes

App.D 2-3, E-10, E4.3.2(a)(l) 24-25

16 Discussion of how roadway design is 40 CFR 58, Yes, Pg. E-4 Yes

considered App.D to E-7

4.3.2(a)(l) (general), E

8, E-12-14

(Fresno)

17 Discussion of how congestion is 40 CFR 58, Incomplete, Insufficient to Table I on Pg. E-lO only provides congestion

3
considered App.D Pg E-4 judge. metric for the 8th FE-AADT ranked segment.

4.3.2(a)(1) (general); Please provide a consistent congestion

pages E-9, comparison metric for all top FE AADT RankE-10, E-24- sites considered. Sections 5.6 & 5.7 of the25 Near-road NO2 Monitoring TAD provide

guidance on obtaining congestions metrics.

18 Discussion of how terrain is considered 40 CFR 58, Yes, Pg E-7 Yes

App.D (general); E4.3.2(a)(1) 16

19 Discussion of how meteorology is 40 CFR 58, Yes, Pg E-7 Yes

considered App.D (general);

4.3.2(a)(l)

(Fresno)E15-16

20 After abovefactors considered, fmultiple 40 CFR 58, Yes, Pg E-7, Yes

candidate sites where max concentrations App.D E-8

expected: Discussion of how population 4.3.2(a)(l) (general);

exposure is considered?

21 Where the site proposed is the 7” in the 40 CFR 58, N/A N/A Currently only one required site in Fresno

CBSA. Discussion of differing factors App.D CBSA.

compared to first site (i.e. fleet mix; 4.3.2(a)(1)

congestion; terrain; geographic area within

CBSA; or different route, interstate, or

freeway designation).

Siting criteria requirements (40 CFR 58, Appendix E)

22 Distance from target road segment as near 40 CFR 58, Incomplete, Insufficient to The District acknowledges on page E- 17 their

as practicable (TAD recommendation is App.E Pg. E-17, E- judge focused efforts on locations that can handle anwithin 20 meters) & no more than 50 6.4(a) 21 air monitoring site within 20 meters and pagemeters? E-21 states that the site will be as close to the

freeway as practicable.

Please confirm the final estimated distance

from the targeted road with the final plan

submittal.

23 Vertical inlet placement between 27 40 CFR 58, Incomplete, Insufficient to The District notes it “will place the probe as

4
meters? App.E 2 Pg. E-18 judge. close to the 2 meter height

as possible,” see page E-18.

Please confirm the final estimated probe

height with the final plan submittal.

24 Probe distance from supporting structures 40 CFR 58, No Insufficient to Please include this information in the final

is at least 1 meter away vertically or App.E 2 judge. submittal.

horizontally?

25 Is air flow unobstructed between the probe 40 CFR 58, No Insufficient to Please include this information in the final

and the outside nearest edge of the targeted App.E 4(d) judge. submittal.

road segment?

SUPPORTING/ADDITIONAL INFfl1MAT1ON: Based on Near-road NO2 monitoring TAD and experience.

Check (Yes, No, N/A, Comments

IfInsufficient)

yes, page #s.

If top FE-AADT segment not selected, is adequate justification Yes, Pg. E-12 EPA’s Google Earth exploration of

provided for higher ranks not selected? the top three FE AADT rank

segments that were not selected isconsistent with the District’s

reasoning for not being able to

select a final site within these

It

segments.

would be helpful for the District

to clarify whether any property

owner outreach was done (and if so,

the outcome) for the top three FE

AADT ranked segments for which

a final site selection was not

presented.

If similar top FE-AADT candidate sites available, was most Insufficient to See Item 17.

congested segment selected? judge

Is candidate site selected downwind of target road segment? N/A Prevailing winds parallel to road

5
therefore either side of the road was

considered. (page E- 15)

Are wind roses included to show predominant wind patterns? Yes, Page E- 15

Are physical attributes (roadway design, roadside structures, or Yes See Items 16-19

terrain) desirable according to Table 4-2 of the Near-road NO2TAD

(see below)?If physical attributes (roadway design, roadside structures, or terrain) N/A

NOT desirable according to Table 4-2 of the Near-road NO2 TAD,

are they TYPICAL for the area?

Was population exposure correctly considered as an additional factor Yes See Item 20.

AFTER consideration of primary factors (FE-AADT, congestion,roadway design, terrain, meteorology) and IF multiple maxconcentration candidate sites identified?Will this be a multi-pollutant site? If so, list additional parameters Insufficient to The District references theirplanned in Comments. judge consideration for accommodation

of a PM2.5in the future (see page E

Recommend

2).

clarifying other

planned pollutants that will be

installed at site.

Does agency ensure candidate selection is NOT in a “unique” Yes, Pg. E-6location? (See Near-road NO2 TAD section 13.2 included below)

6
Table 4-2. Summary of physical considerations for candidate near-road sites.

Physical Site Impact on Site Desirable L.east Desirable Potential Information

Component Selection Attributes Attributes Sources

Roadway Feasibility of At-grade or Deep cut- Field reconnaissance;

design or monitor nearly at-grade sections/significant satelliteconfiguration placements; with immediate ly below grade; imagery

affects pollutant surrounding significantly above

transport and terrain, grade (fill or

dispersion. bridge); above

grade (bridge).

Roadside Feasibility of present other Presence of sound Field reconnaissance;

Structures monitor than low (<2 m walls, mature (high satellite

placement; in and thick) imagery

affects pollutant height) vegetation,

transport and vegetation or obstructive

dispersion. safety features buildings.

such as 

guardrails.

Terrain Affects pollutant Flat or gentle Along mountain Field reconnaissance;

dispersion, local terrain, within a ridges or peaks, digital

atmospheric valley, or along a hillsides, or other elevation models and

stability, road grade. naturally vegetation

windswept areas. files; satellite imagery.

Meteorology Affects pollutant Relative Strongly Local data; National

transport and downwind predominant Oceanic and

dispersion. locations; winds upwind positions. Atmospheric

from road to Administration’s

monitor. (NOAA’s) National

Service

Weather

(NWS); EPA’s Air

SystemQuality

(AQS).

7
13.2 Unique Locations and Background Source Influences

In the evaluation process, state and local air agencies may encounter situations where certain

road segments of interest have characteristics that make the location a unique near-road location

that has elevated pollutant concentrations. In such cases, the pollutant concentrations are not

representative of other near-road locations across the CBSA. The unique characteristics of these

locations could be due to the close proximity of a substantial stationary source, non-road mobilesources, or roadway design features (such as tunnel entrances and exits or toll plazas). In

situations where a state or local air agency has a choice between road segments that otherwise

have similar potential for peak N02 concentrations, the air agencies should place a higher weight

on sites that are most influenced by typical roadway activity rather than those that are heavily

influenced by unique sources or features. This approach increases the probability that the chosen

site can represent a larger population exposure within and across CBSAs.

The EPA recognizes that state and local air agencies will likely have a good understanding of

whether candidate near-road N02 monitoring sites have unique characteristics that do or do not

represent the CBSA that those sites are within. The EPA encourages state and local air agencies

to use their local knowledge in site selection and to engage the EPA Regional staff for assistance

in evaluating such a situation as necessary.

8
E.2 Region 9 Near-road NO2 Plan review checklistChecklist Version date: October 23, 2013

Agency: San Joaquin Valley Air Pollution Control District

CBSA: Bakersfield

This checklist is intended to clarify those elements that EPA will be looking for during the review of proposed near-road NO2 monitoringsites. Please note that this checklist summarizes near-road NO2site requirements of 40 CFR Part 58, but does not substitute for thoserequirements, nor do its contents provide a binding determination of compliance with those requirements. The checklist is subject to revisionin the future and we welcome comments on its contents and structure.WhiteKey:

= meets the requirement.

Yellow does not meet or cannot judge the requirement — action requested in next year’s plan or outside the ANP process.

= meets the requirement but action requested to improve next year’s plan.
COMPLETENESS CHECK: Based on 40 CFR 58 requirements.

Network Plan requirements (40 CFR 58.10)-

No. Near-road N02 plan requirement Citation Info Requirement Notes

submitted? 1 met? 2If yes, page#s.

A plan (submitted by July 1, 2013) for 40 CFR Incomplete — Insufficient to Plan submitted to EPA on June 25, 2013.establishing near-road N02 monitoring 58.10(a)(5) Appendix D judge

site(s) The District will need to resubmit a plan that

includes missing information highlighted in

this checklist to receive EPA approval for aproposed Bakersfield site. The level of detail

provided for the currently proposed

Bakersfield site does not adequately justify

selection for EPA approval at this time. The

re-submitted plan should go through a

minimum 30 day public inspection periodprior to re-submittal to EPA.

2 Evidence of public comment on proposed 40 CFR Incomplete — Insufficient to See item 1.

site(s), no changes subsequent to proposal, 58.10(a)(2) Appendix 0 judge.and submittal of any received comments

3 Anticipated operation start date 40 CFR No Insufficient to Please include this information in the final

58.l0(a)(5) judge. submittal.

4 AQS site identification number 40 CFR No Insufficient to Please include this information in the final

58.1 0(b)( 1) judge. submittal if available.

5 Location (street address & geographical 40 CFR Incomplete, Insufficient to Please include geographical coordinates in the

coordinates) 58.10(b)(2) Pg. D-18 judge. final submittal.

address only

6 Sampling and analysis method (method 40 CFR No Insufficient to Please include this information in the final

code) 58.l0(b)(3) judge. submittal.

1 Response options: N/A (Not Applicable), Yes, No, Incomplete, Incorrect. The responses “Incomplete” and “Incorrect” assume that some information has been2

provided.

Response options: N/A (Not Applicable) — [reason], Yes, No, Insufficient to Judge. Assumes information submitted is correct.
7 Operation Schedule (Season & sampling

frequency)

40 CFR No Insufficient to Please include this information in the final

58. 1 0(b)(4) judge. submittal.

8 Any proposal to remove or move the 40 CFR No Insufficient to Please include this information in the final

monitor within a period of 18 months 58.l0(b)(5) judge. submittal.following plan submittal

9 Monitoring objective & spatial scale of 40 CFR Yes Yes

representativeness 58.1 0(b)(6)

10 CBSA represented by the monitor 40 CFR Yes, P.g D-8 Yes

58. lO(b)(8)

Network Design requirements (40 CFR 58, Appendix D, Section 4.3.2)

I I CBSA population & year 40 CFR 58, Yes Table 4, Yes

App.D page 8

4.3.2(a)

12 Maximum AADT counts & year for the 40 CFR 58, Yes — pages Yes

CBSA(s) App.D D-l0 and D

4.3.2(a) 22-23

13 Correct # of required near-road N02 40 CFR 58, Yes — page Yes

monitors for the CBSA(s) App.D D-l

4.3.2(a)

14 Were all road segments within the CBSA 40 CFR 58, Yes — pages Yes

ranked by AADT? App.D D-l0 and D

4.3.2(a)(l) 22-23

15 Discussion of how fleet mix is considered 40 CFR 58, Yes — pages Insufficient to There is a difference of approximately

App.D D-2,3, D-10 judge. 173,000 FE-AADT counts between the top4.3.2(a)(l) and D-22-23 Bakersfield trafficked segment and the Oil

Junction (Pg. D- 10) proposed segment for

. selection. The proposed Oil Junction segment

ranks at approximately 55% among maximum

calculated FE-AADT.In Section 3.6 (Pg. D-18), the District

discusses correspondence with potential

property owners for segments 7 and 9. It is

unclear whether any outreach was conducted

3
by the District for segments ranking higher

than segment 7.

EPA’s used Google Earth to survey the list of

top ranking FE-AADT segments presented bythe District and found several parcels within

the top segments where a candidate site

appeared potentially feasible. In the top

ranking segment for example, EPA found thatthe Kern County Mental Health Services &

TrafficSchoolEasy.com parking lots would beworth further exploration. Also in the top

segment, the KBAK TV satellite field

appeared worthy of further investigation. In

the third ranking FE-AADT segment, EPA

found that the Travel Lodge parking lot and

Auto Planet back-lot area could also be worth

further exploring.

Given the level of detail provided in the plan

as justification for elimination of top FE

AADT segments and paired with our survey

and finding of potential candidate locationswithin the top three FE-AADT segments,

EPA recommends that a more thorough

search be conducted and documented by the

District to find a potential site higher in FEAADT. While EPA understands that agencies

are faced with a variety ofsafety and

logistical factors to consider that make siteselection a challenge, we feel that such asignificant difference in FE-AADT between

the proposed site and the top segments

warrants further documentation of why no

4
higher ranking candidate sites were deemed

acceptable. EPA encourages the District toconduct property owner outreach for potential

siting locations within the top six segments

prior to considering these unacceptable for a

near-road site. To further assist with propertyowner outreach, EPA for example hasobserved some agencies partner with

interested community groups that have been

able to help find willing property owners.

EPA is also available to help the Districtfurther identify potentially feasible locations

within the higher ranking FE-AADT

segments.

16 Discussion of how roadway design is 40 CFR 58, Incomplete, Insufficient to In pages D-11 through 15 the District includes

considered App.D Pages D-4 to judge. “descriptions of the top 10 road segments and

4.3.2(a)(l) D-7 the reasons why they were acceptable or

(general), unacceptable for site consideration.” Thepages D-8 to District lists road grade issues,

11 (Bfkld), trees/vegetation, and sound wall obstructions

D- 11-15 among reasons for unacceptable sites within

(segments) the top ranking FE-AADT segments. These

unacceptable site attributes are qualitatively

described by the District.

Section 7 of the TAD discusses Physical

Considerations for Candidate Near-road

Monitoring Sites. Specifically, Table 7-1 of

the TAD (also included as Table 4-2 below)

characterizes these physical considerations as“desirable” and “least desirable” attributes forcandidate near-road sites. The table orexample specifies “deep cut

sections/significantly below grade;

5
significantly above grade (fill or bridge);

above grade (bridge)” as least desirable

attributes for roadway design or

After conductingconfiguration.

a survey of the top segments

(see Item 15 Notes) and considering theinformation presented in the plan relating to

roadway design issues, EPA felt that the

elimination of top segments based on

roadway design as a factor primarily was not

sufficiently justified. While the TAD presents

guidance on the desirability of physicalconsiderations for candidate near-road sites, itdoes not recommend that top segments bedeemed unacceptable for investigationprimarily based on these physical attributes.As an example, EPA has witnessed agencies

that have been able to work with willing

property owners to remove obstructing trees.

Furthermore, as currently characterized in the

District’s plan, it is unclear what the extent of

the roadway design issues are since these are

mostly described in a qualitative manner.

Figure 7-1 of the TAD suggests that

depending on the distance to the road there isa relative desirability of various roadwaydesigns to consider when selecting acandidate locations. EPA encourages theDistrict to revisit roadway design as a factor

in their candidate site selection and is

available to work with the District to helpidentify potentially locations within the higher

ranking FE-AADT segments where relative

6
desirability of roadway design can be

reconsidered.

17 Discussion of how congestion is 40 CFR 58, Incomplete, Insufficient to Table 1 on Pg. D-l0 only provides congestion

considered App.D D-4, D-9 judge. metric for the 2nd and 8th FE-AADT ranked

4.3.2(a)(1) segments. Please provide a consistent

congestion comparison metric for all top FE

AADT Rank sites considered. Sections 5.6 &

5.7 of the Near-road NO2 Monitoring TAD

provide guidance on obtaining congestions

metrics.

18 Discussion of how terrain is considered 40 CFR 58, Yes, D-7, D- Yes

App.D 16

4.3 .2(a)( 1)

19 Discussion of how meteorology is 40 CFR 58, Yes, D-7, Yes

considered App.D D15-16

4.3.2(a)( 1)

20 After abovefactors considered, fmultiple 40 CFR 58, Incomplete, Insufficient to Page D-18 of the plan describes the District’s

candidate sites where max concentrations App.D D-7, D-8, D- judge consideration of “population exposure as one

expected: Discussion of how population 4.3.2(a)(1) 14, D-17, D- of the criteria that should be considered

exposure is considered? 18 during the site selection if you have multiple

acceptable sites in the same road segment.”

The District notes that “only one landowner in

segment 9 was willing to negotiate a lease”and further discussion of consideration of

population exposure for the proposed segment

was not found.

From a Google Earth survey, EPA noted that

the Oil Junction segment proposed for

selection did not appear to be in one of the

more populated areas of Bakersfield whencompared to others sections along the 99 that

run through the more populated urban center.

7
EPA recommends reexamination of this factor

after revisiting items 15-1 7above andpotentially finding new candidates locations

ranking higher in FE-AADT.

21 Where the site proposed is the 2’’ in the 40 CFR 58, N/A N/A Currently only one required site in

CBSA. Discussion of differing factors App.D Bakersfield CBSA.

compared to first site (i.e. fleet mix; 4.3.2(a)(l)

congestion; terrain; geographic area withinCBSA; or different route, interstate, orfreeway designation).

Siting criteria requirements (40 CFR 58, Appendix E)

22 Distance from target road segment as near 40 CFR 58, Incomplete, Insufficient to The District acknowledges on page D-1 7 their

as practicable (TAD recommendation is App.E pages D-7, judge focused efforts on locations that can handle anwithin 20 meters) & no more than 50 6.4(a) D-17-18, 19 air monitoring site within 20 meters and pagemeters? E191 states that the site will be as close to the

freeway as practicable.Please confirm the final estimated distancefrom the targeted road with the final plan

submittal.

23 Vertical inlet placement between 2-7 40 CFR 58, Incomplete, Insufficient to The District notes it “will place the probe as

meters? App.E 2 pages D-7, judge. close to the 2 meter height

D-17-18 as possible,” see page D-18.

Please confirm the final estimated probe

height with the final plan submittal.

24 Probe distance from supporting structures 40 CFR 58, No Insufficient to Please include this information in the final

is at least 1 meter away vertically or App.E 2 judge. submittal.

horizontally?

25 Is air flow unobstructed between the probe 40 CFR 58, Incomplete, Insufficient to Please clarify air flow is unobstructed for

and the outside nearest edge of the targeted App.E 4(d) pages D- judge. final site selection after reexamining the

road segment? 1 1&12, D- checklist items above.

20

8
SUPPORTING/ADDITIONAL INFORMATION: Based on Near-road NO2monitoring TAD and experience.

Check (Yes, No, N/A, Comments - IfInsufficient) yes, page #s.If top FE-AADT segment not selected, is adequate justification Insufficient to See Items 15 & 16 above.

provided for higher ranks not selected? judgeIf similar top FE-AADT candidate sites available, was most Insufficient to See Item 17.congested segment selected? judgeIs candidate site selected downwind of target road segment? N/A Item should be revisited after

further top segment exploration.

Are wind roses included to show predominant wind patterns? Yes, Pg. D- 16

Are physical attributes (roadway design, roadside structures, or Insufficient to See item 16.

terrain) desirable according to Table 4-2 of the Near-road NO2 TAD judge

(see below)?

If physical attributes (roadway design, roadside structures, or terrain) Insufficient to See item 16. This would be another

NOT desirable according to Table 4-2 of the Near-road NO2 TAD, judge factor worth exploring by the

are they TYPICAL for the area? District.Was population exposure correctly considered as an additional factor Insufficient to See item 20.

AFTER consideration of primary factors (FE-AADT, congestion, judge

roadway design, terrain, meteorology) and IF multiple maxconcentration candidate sites identified?

Will this be a multi-pollutant site? If so, list additional parameters Insufficient to The District references their

planned in Comments. judge consideration for accommodation

of a PM2.5in the future (see page D

Recommend clarifying

2).

other

planned pollutants that will be

installed at site.

Does agency ensure candidate selection is NOT in a “unique” Yes, Pg.D-6 The selection of non-unique site islocation? (See Near-road NO2 TAD section 13.2 included below) listed as a consideration on pageD

6.

9
Table 4-2. Summary of physical considerations for candidate near-road sites.

Physical Site Impact on Site Desirable Least Desirable Potential Information

Component Selection Attributes Attributes Sources

Roadway Feasibility of At-grade or Deep cut- Field reconnaissance;

design or monitor nearly at-grade sections/significant satellite

configuration placements; with immediate ly below grade; imagery

affects pollutant surrounding significantly above

transport and terrain, grade (fill or

dispersion. bridge); above

grade (bridge).

Roadside Feasibility of present other Presence of sound Field reconnaissance;

Structures monitor than low (<2 m walls, mature (high satellite

placement; in and thick) imageryaffects pollutant height) vegetation,

transport and vegetation or obstructive

dispersion. safety features buildings.

such as

guard ra i Is.

Terrain Affects pollutant Flat or gentle Along mountain Field reconnaissance;

dispersion, local terrain, within a ridges or peaks, digital

atmospheric valley, or along a hillsides, or other elevation models and

stability, road grade. naturally vegetation

windswept areas. files; satellite imagery.

Meteorology Affects pollutant Relative Strongly Local data; National

transport and downwind predominant Oceanic anddispersion. locations; winds upwind positions. Atmospheric

from road to Administration’s

monitor. (NOAA’s) National

Service

Weather

(NWS); EPA’s Air

System

Quality

(AQS).

10
13.2 Unique Locations and Background Source Influences

In the evaluation process, state and local air agencies may encounter situations where certain

road segments of interest have characteristics that make the location a unique near-road location

that has elevated pollutant concentrations. In such cases, the pollutant concentrations are not

representative of other near-road locations across the CI3SA. The unique characteristics of these

locations could be due to the close proximity of a substantial stationary source, non-road mobile

sources, or roadway design features (such as tunnel entrances and exits or toll plazas). Insituations where a state or local air agency has a choice between road segments that otherwise

have similar potential for peak N02 concentrations, the air agencies should place a higher weight

on sites that are most influenced by typical roadway activity rather than those that are heavily

influenced by unique sources or features. This approach increases the probability that the chosen

site can represent a larger population exposure within and across CBSAs.

The EPA recognizes that state and local air agencies will likely have a good understanding of

whether candidate near-road N02 monitoring sites have unique characteristics that do or do notrepresent the CBSA that those sites are within. The EPA encourages state and local air agencies

to use their local knowledge in site selection and to engage the EPA Regional staff for assistance

in evaluating such a situation as necessary.

11
F. Supplemental Response to Comments

SJVAPCD received comments on its 2013 Annual Monitoring Network Plan from Earthjustice

on behalf of the Central Valley Air Quality Coalition, Greenaction, and the Coalition for Clean

Air. The District included its responses to these comments in its network plan submittal to EPA.

EPA has reviewed the comments and responses and wishes to clarify a few points regarding EPA

guidance and requirements that are relevant to these comments.

Comment: SJVAPCD should ‘provide more detailed information about its decision-making

process with respect to monitoring site closures and consolidations.”

Supplemental response: EPA requires that monitoring agencies request EPA approval for

system modifications to SLAMS monitors using the criteria set forth in 40 CFR 58.14. This

process should also be used for any previously violating monitor producing regulatory data (even

those that are not SLAMS) since the lack of an EPA approval in those cases may jeopardize

future EPA actions. This process can occur through the Annual Network Plan submittal and

approval process, or outside of that process through separate correspondence between a

monitoring agency and EPA. Ifthe agency requests and receives EPA approval outside of the

network plan process, the request and EPA’s approval must be included in the following Annual

Network Plan.

EPA understands that monitoring agencies are continually evaluating their networks to manage

resources effectively, ensure that sites continue to meet existing and new EPA requirements as

air quality levels or census information changes, and respond to logistical challenges outside of

their control. We appreciate the fact that the SJVAPCD includes preliminary information in their

Annual Network Plans that indicate system modifications that they are considering, but are not

yet ready to request approval for or implement. In these cases, the district may not have all the

information needed for a request, but we encourage the district to work with EPA early in their

system modification process to ensure that all necessary information is included with the request

when the district is ready to move forward with the modification.

Comment: “Although the District describes the Plan requirements in the introduction, the

criteria behind those requirements are not fully explained.”

Supplemental Response: Most of the EPA requirements and guidance on network design and

the characteristics of monitoring objective, site type and spatial scale of representativeness are

set forth in 40 CFR Part 58, Appendix D. Section 1.1 of Appendix D lists three basic monitoring

objectives of monitoring networks: public reporting, support for NAAQS compliance and

research support. Section 1.1.1 lists the variety of site types that are needed to meet these

objectives. Section 1.2 describes spatial scales of representativeness. These three qualities of a

monitor are interdependent, and the classification of the monitor by its type and spatial scale of

representativeness is critical in determining whether the monitoring data is appropriate for

meeting a particular monitoring objective (Section 1.2(e)). Section 4 describes details of the

relationship between the monitoring objective, site type and scale of representativeness of a

monitor for each pollutant.
Comment: “The District states that the l3akersfield-Muni PM25 and PM10 monitors met

the criteria for a move under 40 CFR Part 58; however the District did not request or receive

approval from the Regional Administrator as required under 40 CFR Part 58.14(b) prior to

shutting down the monitors. Additionally, the District argued that the PM25 and PM10 monitors

should be moved due to activities in the area, such as street sweeping and disking of an open

field, that altered air quality near the monitors such that the monitors’ data would not capture

‘ambient air’ in the Valley. This rationale suggests that the District is operating under a

definition of ambient air that differs from the definition found in 40 CFR 50.1(e).

Supplemental Response: The general criteria for siting a PM2.5network to meet monitoring

objectives for regulatory PM2.5 SLAMS monitors are described in 40 CFR 58 Appendix D

Section 4.7. More specifically, Section 4.7.1 (b) states:

The required monitoring stations or sites must be sited to represent area—wide air quality.

These sites can include sites collocated at PAIVIS. These monitoring stations will typically

he cit neighborhood or urban—scale; however, micro—or middle—scale PM2.5monitoring

sites that represent many such locations throughout a metropolitan area are considered

to represent area-wide air quality.

Therefore a regulatory monitor at any area-wide site, regardless of the specific scale of the site, is

appropriate for comparison to both the annual and 24-hour PM2.5NAAQS and could therefore be

appropriate to meet the monitoring objective of demonstrating compliance with the NAAQS.

Since PM10 concentrations are often more localized and source-specific, the monitoring network

design criteria are different than for PM2.5and can include any scale of representativeness.

depending on the circumstances (see 40 CFR Part 58 Appendix D Section 4.6 (b).

In addition to the pollutant-specific network design criteria described above, the general

requirements in 40 CFR Part 58 Appendix D Section 1 also states that monitoring agencies

should evaluate whether the network appropriately characterizes the air quality in an area to

ensure adequate demonstration of compliance with the NAAQS. This may include characterizing

peak air pollution levels or pollution levels near specific sources, in addition to characterizing

levels in populated areas or transport (40 CFR Part 58 Appendix D Section 1.1.1). This

evaluation of network design is expected in an agency’s five-year network assessment and

should consider many types of available information, including short term air quality studies, and

whether significant sources in the emissions inventory of an area are adequately represented.

Comment: “The District cites the California Regional Particulate Air Quality Study

(CRPAQS’) as the basis for the PM monitoring system. It also notes that the CRPAQS final

report compiling key data and analysis of particulates in the region was ‘expected to be

completed in June 2012.’ Has that report been completed? How did it influence system design?

If the report is complete, please make it available so that the public can use it to evaluate the

District’s monitoring approach more fully.”

Supplemental Response: A comprehensive evaluation of the design of each required

monitoring network is included in the Five-year Network Assessment (40 CFR 58.10(d)), the
next of which is due in July 2015. EPA expects that any research or information cited as the

basis for a network meeting the monitoring objectives defined by 40 CFR 58 Appendix D would

be included in these assessments.