Mr. Danny Nevarez 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION6 

1445 ROSS AVENUE, SUITE 1200 

DALLAS TX 75202-2733 

FEB 0 3 2015 

Deputy Director, Air Quality Division 

Environmental Health Department 

City of Albuquerque 

P.O. Box 1293 

Albuquerque, NM 87103 

Dear Mr. Nevarez: 

Thank you for your correspondence submitting the City of Albuquerque's ( COA) 2014 Annual 

Monitoring Network Plan (network plan). The U.S. Environmental Protection Agency (EPA) has 

completed its analysis of the CO A's 2014 network plan to ensure it meets the requirements of 

40 CFR Part 58 and its appendices that confer approval authority on the Regional Administrator, which 

is delegated to the Associate Director for Air. 

We appreciate your cooperation and work to submit your 2014 network plan. The network review 

process presents an opportunity for the EPA and the COA to collaborate on the ambient air monitoring 

network design. See 40 CFR Part 58 App. D, 1.1.2. I am pleased to inform you that your 2014 network 

plan is approved in accordance with 40 CFR §58.1 0. Details of our review on your ambient air 

monitoring network are provided in the enclosure. 

EPA appreciates the CO A's use of the revised Metropolitan Statistical Area definitions and 2013 

population estimates from the U.S Census Bureau. We look forward to our continued collaborations 

with the COA on its 2015 ambient air monitoring network. If you have any questions, please contact me 

at (214) 665-3102, or your staff may contact Ms. Maria Martinez, Air Quality Analysis Section Chief, of 

my staff at (214) 665-2230. · 

Mark Hansen 

Acting Associate Director for Air Programs 

Enclosure 

Internet Address (URL) • http://www.epa.gov/region6 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
City of Albuquerque (COA) Environmental Health Department 

2014 Annual Ambient Air Monitoring Network Plan Technical Comments 

The Environmental Protection Agency (EPA) has reviewed your 2014 Annual Ambient Air Monitoring 

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 including but not limited to sampling methods, monitoring 

objectives and spatial scales between the 2014 network plan and the EPA's national air monitoring 

database, Air Quality System (AQS). In addition, please be consistent and identify the Parameter 

Occurrence Code (POC) in Table 1 of the network plan. Please review this information and provide a 

list of proposed changes needed to either the network plan, AQS, and/or other documents in order to 

resolve these discrepancies and potential inaccuracies. See the narrative below for any additional details 

regarding the network plan. 

Explanatory text regarding the meteorological conditions is not required 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 can be incorporated into the 2015 five year 

network assessment. 

According to the network plan, Table I 0 reflects the 2013 network before the changes proposed. 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 correct information 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 particulate matter of 

2.5 microns or less (PMzs) at the 2ZH North Valley (AQS #35-001-1013) sites on April4, 2014. 

Timeline 

In order to reflect the timely implementation of network efficiencies, please propose a timeline of the 

approved changes in the COA network to the EPA Region 6 Air Quality Analysis Section Chief within 

30 days of the receipt of this letter. Please also include any requested information and clarifications. 

03Network 

According to 40 CFR Part 58, App. D, 4.1 and Table D-2, two 03 monitors are required in Metropolitan 

Statistical Areas (MSA) greater than 350,000 population with the most recent 3-yeardesign value (DV) 

concentrations greater than or equal to 85% of any 03 National Ambient Air Quality Standards 

(NAAQS). For the Albuquerque MSA, two 03 State and Local Air Monitoring Station (SLAMS) sites 

are required based on the 2013 U.S. Census population estimates of902,797 and the 2013 DV of 

72 parts per billion (ppb) at the 2ZF Foothills site (AQS #35-001-1 012). At this time, the two required 

SLAMS 03 sites are the 2ZF Foothills site to record the maximum concentration and the National Core 

(NCore) 2ZM Del Norte site (AQS #35-001-0023) to demonstrate compliance with NCore requirements 

to monitor for 03. See 40 CFR Part 58, App. D 4.1 (b) and 40 CFR Part 58, App. D 3(b) respectively. 
Currently there 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, the request 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 of the 03 monitors will not compromise the data collection needed for 

implementation of the 03 NAAQS, and the 40 CFR Part 58, App. D ambient air monitoring 

requirements will continue to be met. 

• The COA will need to enter an end date for the 03 monitors at the 2ZN SE Heights and 2ZW 

Westside sites in AQS. 

• Please provide an anticipated date of discontinuation for these monitors and notify EPA Region 6 

when the 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 

the preliminary DV for the NMED 03 monitor at the Los Lunas site (AQS #35-061-0008) is 69 ppb. 

Partic11late Matter (PM) 

The COA identifies PM monitors in Table 1 that are not reported to AQS. In Table 1, please identify 

which monitors are reported to the Air Quality Index (AQI) and not AQS or remove this information 

from Table 1 and only discuss in the pollutant specific narrative. In addition, please provide the 

Parameter Code for the PM10-2.s in the Table 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 monitor is required in MSA8' 

greater than 500,000 population with the most recent 3-year DV concentrations less than 85% of any 

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-hr PM2.s DV of20 J.Lg/m3 (57% of the 24-hr PM2.s NAAQS, 

35 J.Lg/m3

) at the 2ZM Del Norte site. 

Currently there are three SLAMS PM2.s sites in the Albuquerque MSA operated by the COA in 

Bernalillo County. Therefore, the request to discontinue the PM2.s monitor at the 2ZN SE Heights site is 

approved. The discontinuance of the PM2.s monitor will not compromise the data collection needed for 

implementation of the PM2.s NAAQS, and the 40 CFR Part 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 monitor in AQS at this site. 

• We note that the COA has stated that the 2ZN SE Heights site will be closed with the 

discontinuance of the 03 and PM2.s monitors. 

• Please provide an anticipated date of discontinuation for this monitor and notify EPA Region 6 

when the monitor has been discontinued and an end date has been entered into AQS. 

• Please reflect this information in the COA 2015 network plan. 

The COA states in the network plan that it operates three additional PM2.s continuous monitors for AQI 

and includes 2ZF, 2ZN and 2ZV. According to AQS, the COA is operating three SLAMS sites using 

continuous Federal Equivalent Method (FEM) PM2.s beta attenuation monitor (BAM) 1020s. Please 

clarify, by site name and AQS Site ID number, which three 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 

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Parameter Code 88502 is not required. According to AQS, the Parameter Code 88502 for the 2ZV South 

Valley site (AQS #35-001-0029) does not have 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. 

We note that the 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 FiveY ear Network Assessment evaluation of the 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 meet the 15% PM10 collocation requirements of 

40 CFR, Part 58, App. A, 3.3.1, the COA requires one collocated site. The request 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 the PM10 manual method 

is not required to be the same method, the continuous TEOM operated in conjunction with the manual 

(FRM) meets the collocation requirement. See 40 CFR 58, App. A, 3.3.1. 

According to 40 CFR Part 58, App. D, 4.6 and Table D-4, two to four PM10 SLAMS sites are required in 

MSAs greater than 500,000 population with medium concentrations exceeding 80% of the PM10 

NAAQS. The COA operates three PM10 SLAMS sites and have reported exceedances or elevated PM10 

concentrations for review by EPA. The 2013 24-hr DV based on data not flagged for review is 

128 J.lg/m3 (83% of the 24-hr PM10NAAQS, !50 J.lg/m3

) at the 2ZS Jefferson site. At this time, the COA 

is meeting the minimum requirements for PM10 SLAMS sites; any change in the approximate number of 

stations per MSA will be determined after EPA review of the reported elevated PM10 concentrations. 

According to the COA, the 2013 DV is 105.7 J.lg/m3• We recommend that the COA re-evaluate the 

process to calculate a DV for PM10. According to the PM10 SIP Development Guidelines, US EPA450/2-86-001, the DVis based on the number of observations; it is not automatically the 3rd highest 

concentration. See PM10 SIP Development Guidelines, Table 6-1. In addition, the 2ZS Jefferson site is 

referred to as 2ZS Singer in Table 4. Please reflect this information in the COA 2015 network plan.· 

We note that the COA is also operating a PM10 TEOM at the 2ZW Westside site that does not meef 

siting criteria and is not in AQS. According to the network plan, the COA uses this monitor for AQI, to 

issue health advisories and that the data is being archived to characterize the PM background prior to its 

anticipated development. EPA Region 6 looks forward to reviewing the 2015 COA Five Year Network 

Assessment evaluation of the PM 10 network for the Albuquerque MSA. 

Carbon Monoxide (CO) 

On September 29,2014, the COA notified EPA that the high-sensitivity CO monitor at the 2ZV South 

Valley site was replaced with another CO monitor. In addition, Table 1 identifies the operating schedule . 

of this CO monitor as continuous seasonal. According to the narrative in the network plan, the CO 

monitor operates year round. Please review this information and reflect these changes in the COA 2015 

network plan. r 

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