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 Arizo na Air Monitoring Network Plan f or t he Year 2012 in August 2012

. Based on the information provided in the plan, EPA approves all portions of the network plan except thos e specifically identified below. With this plan approval, we also formally approve the following system modification: the addition of an ADEQ operated PM 10 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 a nnual 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 incl uded 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 requir ements 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 youhave 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, ADEQAttachment B : Annual Air Monitorin g Network P lan I tems where EPA is N ot Taking

Action

We are not acting on the portions of annual network plan s 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 NO 2 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 NO 2 monitoring sites are submitted to the EPA Admin istrator 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 modification s 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 O 3 monitor

 Shutdown of the Miami Ridgeline SO 2 monitor

 New SLAMS S O 2 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

PM 2.5 sampling frequency 45 Not meeting requirement in some instances

PM 10 collocation 34 Not meeting requirement

PM 10 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

PM 2.5 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 PM 2.5 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

PM 10

- 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 plan s, 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 Po st Office (PM 2.5 ), Payson Wells (PM 10 ), 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 O 3 monitor per MSA, therefore the sites

located in these a reas 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 O 3 mon itor in the required MSAs.

 MSAs identified in the plan only require one PM 2.5 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 concent ration site types in future network plans in order to clearly demonstrate that the networks meet the requirement of identifying a maximum concentration PM 2.5 monitor in the required MSAs.