UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

DEC 1 1 2013 

Mr. Larry Allen 

Air Pollution Control Officer 

San Luis Obispo County Air Pollution Control District 

3433 Roberto Court 

San Luis Obispo, California 93401 

Dear Mr. Allen: 

Thank you for your submission of San Luis Obispo County Air Pollution Control District's 

(SLOAPCD's) 2013 Ambient Air Monitoring Network Plan in July 2013. We have reviewed the 

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

infonnation 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 

infonnation 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 

5 8.10 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. 

The third enclosure (C. Annual Monitoring Network Plan Checklist) is the checklist EPA used to 

review your plan for overall 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 first two enclosures highlight a subset of the more extensive list of items reviewed in the 

third enclosure. All comments conveyed via this letter (and enclosures) should be addressed 

(through corrections within the plan, additional information being included, or discussion) in 

next year's annual monitoring network plan. 

Printed on Recycled Papu 
If you have any questions regarding this letter or the enclosed comments, please feel free to 

contact me at (415) 947-4534 or Dena Vallano at (415) 972-3134. 

Enclosures: 

Sincerely, 

--f/1~ k_ ·_ Meredith Kurpius, Manage~­ Air Quality Analysis Office 

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

B. Additional Items Requiring Attention 

C. Annual Monitoring Network Plan Checklist 

cc: Karl Tupper, SLOAPCD 

Karen Brooks, SLOAPCD 

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 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. 

• EPA identified items in your agency's annual monitoring 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 the following items: 

Item Checklist Row Issue 

(Attachment A) 

Instrument parameter code for 49 Not meeting requirement in some instances 

each instrument 

Monitoring objective for each 47 Not meeting requirement in some instances 

instrument 

Traffic count of nearest road 74 Insufficient information to judge 

PM2.s collocation 37 Insufficient information to judge 

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

the third enclosure (C. Annual Monitoring Network Plan Checklist). 
B. Additional Items Requiring Attention 

• [Item 43]: 

o The Mesa2 S02 monitor instrument model is listed as API TlOOU with method 

code 009 instead of method code 100. Assuming this is a typo, please correct in 

next year's plan. 

o Nipomo Regional Park N02 monitor listed as API 200, but doesn't specify which 

model200. Please clarify in next year's plan. 

• [Item 44] 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. 

• [Items 52-53] If there is no seasonal sampling or alteration from expected sampling 

frequency, then the "current sampling frequency" and the "calculated sampling 

frequency" should be the same. Please clarify in next year's plan. 

• [Item 74] Traffic counts from sites listing AADT information from 2006 or earlier (Paso 

Robles, San Luis Obispo, Morro Bay, and Nipomo Regional Park) should be updated in 

next year's plan if possible. If updated information is not available, please state why 

and/or when new data are anticipated. 
C. ANNUAL MONITORING NETWORK PLAN CHECKLIST 

(Updated ll/26/20 13) 

Year: 2013 

Agency: San Luis Obispo County APCD 

40 CFR 58.10(a)(l) requires that each Annual Network Plan (ANP) include information regarding the following types o

monitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, SlN stations, S

stations, and/or, in serious, severe and extreme ozone nonattainment areas, P AMS stations, and SPM monitoring station

40 CFR 58.10(a)(l) further directs that, "The plan shall include a statement of purposes for each monitor and evidence t

each monitor meets the requirements of appendices A, C, D, and E of this part, where applicable." On this basis, review 

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 

Regional Administrators, but we will do a check to see if the required information is included and correct. The items req

Administrator are: P AMS, NCore, and Speciation (SlN/CSN). 

Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those 

contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in 

comments on its contents and structure. 

Key: 

White = meets the requirement. 

Yellow= requirement is not met, or information is insufficient to make a determination. Action requested in next year'

process. (items listed in Enclosure A) 

Preen I =item requires attention in order to improve next year's plan (items listed in Enclosure B) 
Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if 

incorrect2? 

the req?4 

58.10 (a)(l) Yes, cover letter Yes 

ch monitor 58. 10 (a)(1) Yes, p 4-9 Yes 

spection period' 58.JO(a)(1 ), Yes, cover letter Yes 

58.10 (a)(2) 

etwork - case when we 58.10 (a)(2) Yes, p 3, 9 Yes 

tem modifications (i.e., 58.10(e) 

NP process6) 

etwork- case when we 58.10 (a)(2) N/A NIA See Item 4 

 modifications per 58.10 (b )(5) 

58. IO(e) 

58.14 (c) 

tation (e.g., attached N/A NIA There were no system modifications approved since 

modifications that have last ANP approval. 

NP approval? 

1/112011) 58.10 (a)(3) N/A NIA SLO County does not have a required NCore site. 

es operational (by 58.10 (a)(4) N/A N/A SLO County does not have any Pb sources in the 

county and therefore is not required to have any Pb 

sites. 

 RA40 sites submitted by 58.10 (a)(5) NIA N/A SLO County does not have a requirement for N02 

area-wide monitoring or RA40 monitoring. 

ites operational by 58.10 (a)(5) N/A NIA See Item 9 

s submitted by 711 /2013 58.10 (a)(5) NIA N/A SLO County does not have a requirement for N02 

near-road monitoring. 

1120 13) 58.10 (a)(6) N/A N/A SLO County does not have a requirement for S02 

and 58.13(d) near-road monitoring. 

able), Yes, No, Incomplete, Incorrect. The responses "Incomplete" and "Incorrect" assume that some information has been provided. 

t 

able)-[reason], Yes, No, Insufficient to Judge. 

must document the process for obtaining public comment and include any comments received through the public notification process within 

2 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrect2? 

13. AQS site identification number for each site 58.10 (b)(1) Yes Yes 

App C - detailed 

site info 

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

coordinates App C - detailed 

site info 

15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes Yes Combination of 

parameter App C - detailed method code pro

site info 

16. Any proposals to remove or move a monitoring 58.10 (b)(5) Yes Yes See note for Item 

station within a period of 18 months following plan 

submittal 

17. Scale of representativeness for each monitor as 58.10(b )(6); Yes Yes 

defined in Appendix D AppD pp 4-9; App Cdetailed site info 

18. Identification of sites suitable and sites not suitable 58.10 (b)(7) Yes Yes 

for comparison to the annual PM2.5 NAAQS as p 8; App Cdescribed in Part 58.30 detailed site info 

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

monitor 

20. Designation of any Pb monitors as either source- 58.10 (b)(9) N/A N/A 

oriented or non-source-oriented 

21. Any source-oriented Pb site for which a waiver has 58.10 (b)(IO) N/A N/A 

been granted by EPA RA 

22. Any Pb monitor for which a waiver has been 58.10 (b)(l1) N/A N/A 

requested or granted by EPA RA for use ofPb-PM10 

in lieu of Pb-TSP 

23. Identification of required N02 monitors as either 58.10 (b)(l2) N/A N/A SLO County do

near-road or area-wide area-wide moni

24. Identification of any PM2.5 FEMs and/or ARMs not 58.10 (b)(13) Yes, p 8; App C- Yes All PM2.5 FEM

eligible to be compared to the NAAQS (Note 1: must 58.11 (e) detailed site info NAAQS 

include required data assessment.) (Note 2: Required 

SLAMS must monitor PM2.5 with NAAOScomparable monitor at the required sample 

frequency.) 

25. For SPMs listed as non-regulatory, note the start 58.20(c) N/A N/A SLO County do

Date ofFRM/FEM/ARM at SPM. If> 24 months, 
Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if 

incorrect2? 

the req?4 

omparison to the 

8.30, the agency must 

p A, C orE requirements 

ocal agencies provide for 58.10 (c) Yes, p 9 Yes 

PM25 monitoring network 

 violating PM2.5 monitor. 

uest for approval for and 58.11 (a)(2) N/A N/A SLO County does not have any SPMs. 

quirements for SPMs 

M which also meets 

submitted to AQS 58.16(a); Yes, p 10 Yes 

App A, 1.3 

and 5.1.1 

bmitted 58.15 Yes, p 10 Yes 

App. A 1.3 

fication for manual PM App A 3.3.2 N/A N/A 

fication for automated App A 3.2.3 Yes Yes 

App C - detailed 

! site info 

w rate verification for Ph AppA N/A N/A 

3.3 .4.1 

 check (gaseous) App. A 3.2. 1 Yes Yes 

App C - detailed I 

site info I 

mance Evaluation App. A 3.2.2 Yes Yes I I 

Cover letter and 

App C -detailed 

site info 

ual flow rate audits for App A, 3.2.4 Yes Yes 

and 3.3.3 Cover letter and 

App C - detailed 

site info 

ual flow rate audits for Ph AppA N/A N/A 

3.3.4.1 I 

App A 3.2.5 No NA SLO ispart of the ARB PQAO, and relies on the 

4 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrece? 

App B, Table B-1 entire PQAO net

requirements. It 

this requirement 

on a network doc

(SLO does not cu

monitors.) 

38. Designation of a primary monitor if there is more Need to N/A N/A 

than one monitor for a pollutant at a site. determine 

collocation 

39. Distance between collocated monitors (Note: waiver App.A N/A N/A 

request or the date of previous waiver approval must 3.2.5.6 and 

be included if the distance deviates from 3.2.6.3 

requirement.) 

40. Manual PM10 method collocation met? (note: AppA 3.3.1 N/A N/A 

continuous PM10 does not have this requirement) 

41. Pb collocation AppA N/A N/A 

3.3.4.3 

42. PM10•2.5 collocation (note: only applies to Fresno and App A 3.3.6 N/A N/A 

Phoenix NCore sites) 

43. Instrument/monitoring method code for each App c 2.4.12 Yes Ye8 in most cases, The Mes82 802 

monitor: is it reported properly? Is it reported App c -detailed incorrect in certain API TlOOU with 

correctly (ie., appropriate method! code for site info cases. See notes. code 100. AsslUIW

regulatory monitors)? next year's plan. 

Nipomo Regiona

200-which mo

plan. 

44. For agencies that share monitoring responsibilities in AppD2(e) Yes, p4 Insufficient to 

an MSA/CSA: does each affected State or local judge 

agency meet full monitoring requirements or is 

an agreement between the affected agencies and the 

EPA Regi~nal Administrator in place? 

45. Start date for each monitor Required to Yes Yes 

determine if App C - detailed 

other req. site info 

(e.g., min# 

and colloc) 

are met 
Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrect2? 

 each monitor Required to Yes Yes 

determine if App C - detailed 

other req. site info 

(e.g., min# 

and colloc) 

are met 

ch instrument App D 1.1 Yes; incomplete Yes in most cases; All SLAMS that collect data with FRM or FEMs can 

58.10 (b){6) for PM I 0 at CARB no for PMIO at be compared to the NAAQS and therefore must 

sites CARB sites include the objective of "NAAQS"- note that it is 

App C - detailed acceptable to have more than one objective. 

site info 

nt App D 1.1.1 Yes Yes 

App C - detailed I 

site info I 

for each instrument Required to Yes in most cases; Yes in most cases; The parameter code for PM10 at the CARB sites is 

determine if incorrect for PM I 0 no for PM I 0 at listed as 8510 I. The only acceptable PM10 parameter 1 

other req. at CARB sites CARB sites code for SLAMS is 81102. Please correct in next 

(e.g., min # App C - detailed year's plan. 

and colloc) site info 

are met I I 

rence code for each Required to Yes Yes 

determine if App C - detailed 

other req. site info 

(e.g., min# 

and colloc) 

are met 

(note: date of waiver 58.10 (b)(4) Yes Yes 

if the sampling season App D, 4.l(i) App C - detailed 

 site info 

5 - applies to year-round 58.10 (bX4> Yes-see Yes Note: if there is no seasoniil sampling or alteration 

dules (note: date of 58.12(d) clarification in from expected sampling frequency, then the "current 

cluded if llhe sampling AppD4.7 notes sampling frequency'' and the "calculated sampling 

ement) EPA App C- detailed frequency'' should be the same. 

flowchart site info 

0 58.10 (bX4) Yes - see Yes Note: if there is no seasonal sampling or alteration 

58.12(e) clarification in from expected sampling frequency, then the "current 

AppD4.6 notes sampling frequency" and the "calculated sampling 

App C - detailed frequency" should be the same. 

6 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted? 1 1f information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrect2? 

site infio 

54. Sampling schedule for Pb 58.10 (b)(4) N/A NIA 

58.l2(b) 

App 04.5 

55. Sampling schedule for PM10_2_5 58.10 (b)(4) N/A N/A 

58.12(f) 

App 04.8 

56. Minimum# of monitors for 0 3 [Note: should be App 0, 4.1(a) Yes Yes 

supported by MSA ID, MSA population, DV, # and App A, Table A-1 

monitors, and # required monitors] (seefootnote)7 Table 0-2 

57. Identification of max. cone. 0 3 monitor(s) App 0 4.1 (b) Yes Yes 

App C, C-15 

58. Minimum monitoring requirements met for near- App 0 4.3.2 N!A NIA SLO County do

road N02 (20 14 start date) near road monit

59. Minimum monitoring requirements met for area- App 0 4.3.3 N/A N/A SLO County do

wideN02 area-wide monit

60. Minimum monitoring requirements met for RA-40 App 0 4.3.4 NIA N/A SLO County do

N02 RA40 monitorin

61. Minimum monitoring requirements met for S02 App 0 4.4 Yes Yes 

[Note: Only monitors considered to be required App A, A-3 

SLAMs are eligible to be counted towards meeting 

minimum monitoring requirements.] 

62. Minimum monitoring requirements met for Pb AppD4.5 Yes Yes SLO County do

[Note: Only monitors considered to be required 58.1 3(a) App A, A-4 monitoring. 

SLAMs are eligible to be counted towards meeting 

minimum monitoring requirements.] 

63. Minimum# of monitors for PM2.5 [Note 1: should be AppD, Yes, Yes 

supported by MSA ID, MSA population, OV, # 4.7.1(a) and App A, A-1 

monitors, and# required monitors] [Note 2: Only Table D-5 

monitors considered to be required SLAMs are 

eligible to be counted towards meeting minimum 

monitoring requirements.l 

64. Optional PM2.5 Network Clarifications: Provide a list Need to N/A NIA 

of required sites if it does not include all SLAMS. assess several 

----- --

7 Only monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements. In addition, 

traffic count/distance requirements to be neighborhood scale (40 CFR 58 Appendix E, Table E-1) cannot be counted towards minimum monito
Citation Was the info Does the Notes 

within 40 submitted?' If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrece? 

ll SLAMS are requirements 

nt area-wide air quality AppD Yes Yes 

4.7.l(b) See site type info 

in pp. 4-9 and App 

c 

e at neighborhood or AppD Yes Yes 

pected maximum 4. 7.1 (b)( 1) See site type info 

in pp. 4-9 and App 

C (C-7) 

required, is there a site in _AppD N/A N/A Only one PM2.5 site is required. 

4.7. 1(b)(2) 

rements for continuous AppD4.7.2 Yes Yes 

Aoo A, A-2 

kground and transport App D 4.7.3 N/A N/A- State 

Requirement 

tion requirements met for App D 4.7.4 N/A N/A There are no CSN sites in SLO County. 

 PM10 AppD, 4.6 Yes Yes 

(a) and Table AppA, A-2 

D-4 

rements met for PM10.2.5 AppD4.8 N/A N/A This requirement only applies to NCore sites and 

there are no required NCore sites in SLO County. 

st road AppE6 Yes Yes 

App C - detailed 

site info 

d AppE Yes Insufficient to Traffic counts from sites listing AADT information 

App C - detailed judge from 2006 or earlier (Paso Robles, San Luis Obispo, 

site info Morro Bay, and Nipomo Regional Park) should be 

updated in next year's plan if possible. If updated 

information is not available, please state why and/or 

when new data are anticipated. 

App E 3(a) Yes Yes I App C - detailed I 

site info 

AppE2 Yes Yes 

App C - detailed 

8 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted? 1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrect2? 

site info 

77. Distance from supporting structure AppE2 Yes Yes 

App C - detailed 

site info 

78. Distance from obstructions on roof App E 4(b) Yes Yes 

App C - detailed 

site info 

79. Distance from obstructions not on roof App E 4(a) Yes Yes 

App C - detailed 

site info 

80. Distance from trees AppE5 Yes Yes 

App C - detailed 

site info 

81. Distance to furnace or incinerator flue App E 3(b) Yes Yes 

App C - detailed 

site info 

82. Unrestricted airflow App E, 4(a) Yes Yes 

and 4(b) App C - detailed 

site info 

83. Probe material (if applicable) AppE9 Yes Yes 

App C - detailed 

site info 

84. Residence time (if applicable) AppE9 Yes Yes 

App C- detailed 

site info 

----- 
 Network Plan 

he S/LIT agency during the public comment period? No. 

ons. 

ents substantive? 

es? 

r determination if any comments were considered not substantive: 

 to the substantive comments? 

esponse adequate? 

ments require separate EPA response (i.e., agency response wasn't adequate)? 

annual network plan that received substantive comments approvable after consideration of comments? 

ationale: 

10