Mr. DannyNevarez UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION6 1445 ROSS AVENUE, SUITE 1200 DALLAS TX 75202-2733


# FEB 032015

Deputy Director, Air Quality Division Environmental Health Department City ofAlbuquerque P.O. Box 1293 Albuquerque, NM 87103
DearMr. Nevarez: Thank you foryour correspondence submittingthe CityofAlbuquerque's (COA) 2014 Annual Monitoring Network Plan (network plan). The U.S. Environmental Protection Agency (EPA) has completed its analysis ofthe COA's 2014 network plan to ensure it meets therequirements of 40 CFR Part 58 and its appendices that confer approval authority onthe Regional Administrator, which is delegated to the Associate Directorfor Air.
We appreciate your cooperation and workto submit your 2014 network plan. Thenetwork review process presents an opportunityfor the EPA and the COA to collaborate onthe ambient air monitoring network design. See 40 CFR Part 58 App. D, 1.1.2. I am pleased to informyou that your 2014 network plan is approved in accordance with 40 CFR §58.10. Details ofourreview on your ambient air monitoring network are provided inthe enclosure.
EPA appreciates the COA's use oftherevised Metropolitan Statistical Area definitions and 2013 population estimates from the U.S Census Bureau. Welook forward to our continued collaborations withthe COA on its 2015 ambient airmonitoring network. Ifyouhave any questions, please contact me at (214) 665-3102, oryour staffmay contactMs. MariaMartinez, Air Quality Analysis Section Chief, of my staffat (214) 665-2230. ·

MarkHansen Acting Associate Director for Air Programs

Enclosure

InternetAddress (URL) • http://www.epa.gov/region6 Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled PaperCity ofAlbuquerque (COA) Environmental Health Department 2014 Annual Ambient Air Monitoring Network Plan Technical Comments The Environmental Protection Agency (EPA) has reviewed your 2014 Annual Ambient AirMonitoring Network Plan (network plan). The comments below reflect EPA's efforts in collaboration with the COA to maintain an accurate and efficient ambient air monitoring network. General Comments
EPA notes that there are discrepancies includingbut not limited to sampling methods, monitoring objectives and spatial scales between the 2014 networkplan and the EPA's national air monitoring database, Air Quality System (AQS). In addition, pleasebe consistent and identify the Parameter Occurrence Code (POC) in Table 1 ofthe network plan. Please review this information and provide a list ofproposed changes needed to either the networkplan, AQS, and/or other documents in orderto resolve these discrepancies and potential inaccuracies. Seethe narrative below for any additional details regarding the network plan. Explanatory textregarding the meteorological conditions isnotrequired in the network plan as identified in 40 CFR 58.11. This was previously noted in EPA's 2013 annual network review response to the COA. Please reflect this change in the COA 2015 network plan. However, consideration and impact with adjoining areas and meteorological conditions canbe incorporated into the 2015 five year network assessment. According to the network plan, Table I0 reflects the 2013 network before the changesproposed. We note that Table 10 appears to reflect the network after the proposed changes in the current network plan. Please clarify and make sure to reflect the correctinformation in the COA 2015 network plan. According to AQS, the COA ceased monitoring for ozone (03) at the Taylor Ranch (AQS #35-001-0027) and 03, particulate matter of 10 microns or less (PMw) and particulatematter of 2.5 microns or less (PMzs) at the 2ZH North Valley (AQS #35-001-1013) sites onApril4, 2014. Timeline In orderto reflect the timely implementation ofnetwork efficiencies, pleasepropose a timeline ofthe approved changes in the COA network to the EPARegion 6 Air QualityAnalysis Section Chiefwithin 30 days ofthe receipt ofthis letter. Please also include any requested information and clarifications. 03Network According to 40 CFRPart 58, App. D, 4.1 and Table D-2, two 03 monitors are required inMetropolitan Statistical Areas (MSA) greater than 350,000 populationwith the mostrecent 3-yeardesignvalue (DV) concentrations greater than or equal to 85% ofany 03 National Ambient Air Quality Standards (NAAQS). Forthe Albuquerque MSA, two 03 State and Local AirMonitoring Station (SLAMS) sites are required based onthe 2013 U.S. Census population estimates of902,797 and the 2013 DV of 72 parts perbillion (ppb) at the 2ZF Foothills site (AQS #35-001-1012). Atthis time, the two required SLAMS 03 sites are the 2ZF Foothills site to record themaximum concentration and the National Core (NCore) 2ZM Del Norte site (AQS #35-001-0023) to demonstrate compliance with NCore requirements to monitorfor 03. See 40 CFR Part 58, App. D 4.1 (b) and 40 CFRPart 58, App. D 3(b)respectively.Currentlythere are seven 03 sites in the Albuquerque MSA; the COA operates five 03 SLAMS sites in Bernalillo County and the New Mexico Environment Department (NMED) operates two 03 sites, one each in Sandoval and Valencia Counties. Therefore, therequest to discontinue the 03 monitors at the 2ZN SE Heights site (AQS #35-001-0024) and the 2ZW Westside site (AQS #35-002-0032) is approved. The discontinuance ofthe 03 monitors will not compromisethe data collection needed for implementation ofthe 03 NAAQS, and the 40 CFR Part 58, App. D ambient airmonitoring requirements will continue to bemet. • The COA will need to enter an end date for the 03 monitors at the 2ZN SE Heights and 2ZW Westside sites in AQS. • Pleaseprovide an anticipated date ofdiscontinuation for these monitors and notify EPA Region 6 whenthe monitors have·been discontinued and an end date has been entered into AQS. • Please reflect this information in the COA 2015 network plan. Please note that based on the preliminary 2014 03 DVs, the DV at the 2ZF Foothills site is 68 ppb while thepreliminaryDV for the NMED 03 monitor at the Los Lunas site (AQS #35-061-0008) is 69 ppb.
Partic11late Matter (PM) The COA identifies PMmonitors in Table 1 that are notreported to AQS. In Table 1, pleaseidentify which monitors are reported to the Air Quality Index (AQI) and notAQS orremove this information from Table 1 and only discuss inthepollutant specific narrative. In addition, pleaseprovide the Parameter Code for the PM10-2.s in theTable 1 footnote. Please reflect these changes in the COA 2015 network plan.
PMz.s Network According to 40 CFR Part 58, App. D, 4.7.1 and Table D-5, one PM2.s monitoris required in MSA8' greater than 500,000 population with the most recent 3-yearDV concentrations less than 85% ofany PM2.s NAAQS. For the Albuquerque MSA, one PM2.s SLAMS site is required based on the 2013 U.S. Census population of902,797 and the 24-hrPM2.s DV of20 J.Lg/m3 (57% ofthe 24-hrPM2.s NAAQS, 35 J.Lg/m3) at the 2ZM Del Norte site. Currentlythere are three SLAMS PM2.s sites in the Albuquerque MSA operatedbythe COA in Bernalillo County. Therefore, therequest to discontinue the PM2.s monitor at the 2ZN SE Heights site is approved. The discontinuance ofthe PM2.s monitor will not compromise the data collection needed for implementation ofthe PM2.s NAAQS, and the 40 CFRPart 58, App. D ambient air monitoring requirements will continue to be met. • The COA will need to enter .an end date for the PM2.s monitorinAQS at this site. • We note that the COA has stated that the 2ZN SE Heights site will be closedwith the discontinuance ofthe 03 and PM2.s monitors. • Pleaseprovide an anticipated date ofdiscontinuation for this monitor and notify EPA Region 6 when the monitorhas been discontinued and an end date hasbeen entered into AQS. • Please reflect this information inthe COA 2015 network plan. The COA states in the network planthat it operates three additional PM2.s continuous monitors for AQI and includes 2ZF, 2ZN and 2ZV. According to AQS, the COA is operatingthree SLAMS sites using continuous Federal Equivalent Method (FEM) PM2.s beta attenuation monitor (BAM) 1020s. Please clarify, bysite name and AQS Site ID number, whichthree additional sites are for AQI. Since the COA is reporting the continuous FEM PM2.s data as Parameter Code 88101 in AQS, reporting PM2.s data as 2Parameter Code 88502 is not required. According to AQS, the Parameter Code 88502 for the 2ZV South Valley site (AQS #35-001-0029) does nothave an end date. Please verify that the COA has ceased reporting data as 88502 for the PM2.s SLAMS sites and entered end dates in AQS. Please reflect this information in the COA 2015 network plan.
Wenote thatthe COA is also operating a PM2.s BAM 1020 at the 2ZF Foothills site that is not in AQS. According to the network plan, the COA uses the monitor for the AQI purposes only. EPA Region 6 looks forward to reviewing the 2015 COA FiveYear Network Assessment evaluation ofthe PM2.s network for the Albuquerque MSA.
PM10 Network Currently, the COA operates three PM10 monitors at the 2ZS Jefferson site (AQS #35-001-0026): two manual Federal Reference Method (FRM) PM10monitors and a continuous FEM tapered element oscillating microbalance (TEOM) sampler. To meetthe 15% PM10 collocationrequirements of 40 CFR, Part 58, App. A, 3.3.1, the COArequires one collocated site. Therequest to discontinue the manual FRM PM10 (POC-2) and use the existing continuous FEM TEOM PM10 (POC-3) sampler as the collocated monitor at the 2ZS Jefferson site is approved. Since collocation for thePM10 manual method is not required to be the samemethod, the continuous TEOM operated in conjunction with the manual (FRM) meets the collocationrequirement. See 40 CFR 58, App. A, 3.3.1. According to 40 CFR Part 58, App. D, 4.6 and TableD-4, two to four PM10 SLAMS sites are required in MSAs greater than 500,000 populationwithmedium concentrations exceeding 80% ofthe PM10 NAAQS. The COA operates three PM10 SLAMS sites and havereported exceedances or elevated PM10 concentrations for review byEPA. The 2013 24-hr DVbased on data not flagged for review is 128 J.lg/m3 (83% ofthe 24-hrPM10NAAQS, !50 J.lg/m3) at the 2ZS Jefferson site. At this time, the COA is meetingthe minimum requirements for PM10 SLAMS sites; any change in the approximate number of stations perMSA will be determined after EPA review ofthe reported elevated PM10 concentrations. According to the COA, the 2013 DV is 105.7 J.lg/m3• We recommend that the COAre-evaluate the process to calculate a DV for PM10. According to thePM10 SIP Development Guidelines, US EPA450/2-86-001, the DVis based on the number ofobservations; itis not automaticallythe 3rd highest concentration. See PM10 SIP Development Guidelines, Table 6-1. In addition, the 2ZS Jefferson site is referred to as 2ZS Singerin Table 4. Pleasereflect this information inthe COA 2015 network plan.·
We note that the COA is also operating a PM10 TEOM at the 2ZWWestside site that does not meef siting criteria and is not in AQS. According to the networkplan, the COA uses this monitor for AQI, to issue health advisories and that the datais being archived to characterize the PM backgroundpriorto its anticipated development. EPA Region 6 looks forward to reviewing the 2015 COA Five YearNetwork Assessment evaluation ofthe PM10 network for the Albuquerque MSA. Carbon Monoxide (CO)
On September 29,2014, the COA notified EPA that thehigh-sensitivity CO monitor at the 2ZV South Valley site was replaced with another COmonitor. In addition, Table 1 identifies the operating schedule

. ofthis CO monitor as continuous seasonal. Accordingto the narrative inthe network plan, the CO monitor operates year round. Please review this information and reflect these changes in the COA 2015 network plan. 

## r

3