UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

March 1 2013

Eric Massey, Director

Air Quality Division

Arizona Department of Environmental Quality

1110 W. Washington St. 

Phoenix, Arizona 85007

Dear Mr. Massey:

Thank you for your submission of the Arizona Department of Environmental Quality’s 

(ADEQ’s) State of Arizona Air Monitoring Network Plan for the Year 2012 in August 2012. 

Based on the information provided in the plan, EPA approves all portions of the network plan 

except those specifically identified below. With this plan approval, we also formally approve the 

following system modification: the addition of an ADEQ operated PM10 State and Local Air 

Monitoring Station (SLAMS) at the Miami Golf Course site (AQS ID: 04-007-8000). 

Annual network plans are important documents for regulatory purposes (e.g., State 

Implementation Plans, designations and redesignations) and public information, in addition to 

the myriad uses by the air districts. EPA is revising the review process for annual network plans 

to specifically check and document the comprehensive set of items that are required to be 

included in the annual network plans per 40 CFR 58.10 in a consistent manner. We have created 

a checklist that lists all these items and have included it as Attachment A. While the items in the 

checklist are required by EPA regulations, we acknowledge that we have not specifically 

requested some of this information in previous annual network plan reviews. We recognize that 

your plan may not have all the items that we have currently identified and hope to work with you 

on the inclusion of these items in future plans. To facilitate these changes, EPA has provided 

detailed feedback in the checklist where information should be included or revised in next year’s 

plan. 

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

information in the plan is insufficient to judge whether the requirement has been met, or for 

which the information, as described, does not meet 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 approval authority. Accordingly, we are not acting on the 

specific portions of your agency’s annual network plan listed in Attachment B.

In addition to the checklist and list of specific plan elements where EPA Region 9 is not taking 

action, enclosed are additional detailed comments on the plan (Attachment C). All of the 

comments in Attachments A, B, and C should be addressed in next year’s network plan. If you 
have any questions regarding this letter or the enclosed comments, please feel free to contact me 

at (415) 972-3851 or Michael Flagg at (415) 972-3372.

Sincerely,

/s/

Matthew Lakin, Manager

Air Quality Analysis Office

Enclosures:

A. Annual Air Monitoring Network Plan Checklist

B. Elements where EPA is Not Taking Action

C. Additional Detailed Comments

cc: Theresa Rigney, ADEQ
Attachment B: Annual Air 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 EPA has determined that a requirement is 

either not met or information in the plan is insufficient to judge whether the requirement has 

been met.

 NCore, PAMS, STN, and the plan for NO2 monitoring require EPA Administrator 

approval. Per 40 CFR 58.11(c), NCore, PAMS, and STN network design and changes are 

subject to approval of the EPA Administrator and per 40 CFR 58.10(a)(5) plans for 

establishing NO2 monitoring sites are submitted to the EPA Administrator for action. 

Therefore, we are not acting on these items.

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

58.14(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:

 Relocation of the Prescott College AQD O3 monitor 

 Shutdown of the Miami Ridgeline SO2 monitor

 New SLAMS SO2 sites at Jones Ranch and Miami Townsite 

 EPA identified items in you agency’s annual network plan where a requirement was not 

being met or information in the plan was insufficient to judge whether the requirement 

was being met based on 40 CFR 58.10 and the associated appendices. Therefore, we are 

not acting on of the following items:
Item Checklist Row 

(Attachment A)

Issue

PM2.5 sampling frequency 45 Not meeting requirement in some instances

PM10 collocation 34 Not meeting requirement

PM10 sampling frequency 46 Not meeting requirement in some instances

Ozone season waiver 44 Insufficient information to judge

Distance from roadway 62 Not meeting requirement in some instances

Distance from trees 69 Not meeting requirement in some instances

PM2.5 background/transport 

sites

58 Insufficient information to judge

Date of last annual PE 29 Insufficient information to judge 

Date of last two semi-annual 

PM flow audits

30 Insufficient information to judge

Date of last two semi-annual 

Pb flow audits

31 Insufficient information to judge

Identification of PM2.5 sites 

comparable to annual 

NAAQS

17 Insufficient information to judge 

Distance from supporting 

structure

66 Insufficient information to judge & not

meeting requirement in one instance

Distance from obstructions 

on roof

67 Insufficient information to judge

Distance from obstructions 

not on roof

68 Insufficient information to judge

Distance to furnace or 

incinerator flue

70 Insufficient information to judge

Instrument POC 43 Insufficient information to judge

Instrument parameter code 42 Insufficient information to judge

PM10-2.5 collocation 36 Insufficient information to judge

Additional information for each of these items is in included in Attachment A.
Attachment C: Additional Detailed Comments

 Per 40 CFR 58 Appendix D, section (2)(e), the EPA Regional Administrator and state or 

local agencies ... “may divide the overall MSA/CSA monitoring responsibilities and 

requirements among the various agencies to achieve an effective network design. Full 

monitoring requirements apply separately to each affected State or local agency in the 

absence of an agreement between the affected agencies and the EPA Regional 

Administrator.” For future plans, please state if an agreement has been made to share 

network design responsibilities for any MSAs in your jurisdiction and attach 

documentation.

 While the monitor types for most monitors in the plan are appropriate, the collocated 

monitors at Nogales Post Office (PM2.5), Payson Wells (PM10), and Globe Highway (Pb) 

should be correctly designated as “QA collocated” monitor types in future network plans.

 MSAs identified in the plan only require one O3 monitor per MSA, therefore the sites 

located in these areas are de-facto maximum concentration sites. These sites should be 

designated as highest concentration site types in future network plans in order to clearly 

demonstrate that the networks meet the requirement of identifying a maximum 

concentration O3 monitor in the required MSAs.

 MSAs identified in the plan only require one PM2.5 monitor per MSA, therefore the sites 

located in these areas are de-facto maximum concentration sites. These sites should be 

designated as population exposure and highest concentration site types in future network 

plans in order to clearly demonstrate that the networks meet the requirement of 

identifying a maximum concentration PM2.5 monitor in the required MSAs.