UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 1445 ROSS AVENUE, SUITE 1200 DALLAS, TX 75202-2733

Mr. Richard Goodyear Chief, Air Quality Bureau New Mexico Environment Department 525 Camino de los Marquez, Suite 1 SantaFe, NM 87505 DearMr. Goodyear: 

# APR 14 2015

Thankyou for your correspondence submittingthe New Mexico Environment Department's (NMED) 2014 Annual Monitoring Network Plan (networkplan). The U.S. Environmental Protection Agency (EPA) has completed its analysis oftheNMED's 2014 network planto ensure itmeets those requirements of40 CFRPart 58. The authority for the approval ofthe networkplanis delegated to the Associate Directorfor 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 NMED to collaborate on the ambient air monitoring network design. See 40 CFRPart 58 App. D, 1.1.2. The EPA has reviewed your plan, including the proposed ozone and particulate mattermonitor changes to the NMED Ambient Air MonitoringNetwork. I am pleased to inform you that the NMED's 2014 network plan is approved in accordance with 40.GFR §58.10, with exception ofthe particulate matter of2.5 microns or less (PMz.s) network conversion and the manual particulate matter of 10 microns orless (PM10) Federal Reference Method (FRM) conversion. EPA will re-evaluate this requestupon submittal ofthe 5-Year Network Assessment. Details ofourreview on the NMED's ambient air monitoring network are provided in the enclosure. Welook forward to our continued collaborative work with the NMED onits 2015 ambient air monitoring network. Please ensure the 5-YearNetwork Assessment addresses bothplanning and monitoring aspects. Ifyou have any questions, please contact me at (214) 665-7548 oryour staffmay contact Ms. Kara Allen ofmy staffat (214) 665-7333. Sincerely yours, 

# /lfJ;jJ

Mark Hansen Acting Associate Director for AirPrograms Enclosure

cc: Rita Bates, Chief, Planning Section New Mexico Environment Department (with Enclosure)

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 10D"A. Recycled Paper (40% Postconsumer)New Mexico Environment Department (NMED) · 2014 Annual Ambient AirMonitoring Network Plan Technical Comments The Environmental Protection Agency (EPA) has reviewed your 2014 Annual Ambient AirMonitoring Network Plan (network plan) and our comments are providedbelow. In addition to the network plan, EPA's review includes additional information provided bythe NMED as identifiedbelow. General Comments
EPA notes that there are discrepancies including, butnot limited to the site names, site addresses, sampling methods, monitoring objectives and spatial scales betweenthe 2014 network plan, Appendix E network elements (Table 1 ), and the EPA's national air monitoring database, Air Quality System (AQS). Pleasereview this information and provide a list ofproposed changes needed to either the network plan, AQS, and/or other documents in order to resolve these discrepancies and potential inaccuracies for sites and monitors that are operating. Specificallyfor Table 1, we note that the NMED does not identifY the sites appropriately for the Farmington, Albuquerque and Las Cruces Metropolitan Statistical Areas (MSA). Pleaseprovide the MSA information and include core-based statistical areas (CBSAs) ifrequired by40 CFRPart 58, but do not include the micropolitan areas inthe network plan. Furthermore, please do not list monitors and/or sites that have been discontinued. Monitors are not officiallydiscontinued nntil end dates have been entered into AQS. See the narrativebelow for any additional details regarding the 2014 network plan. Particulate Matter (PM) Network Atthis time, we cannot approve the particulate matter of2.5 microns orless (PM2.s) network conversion · to the continuous PM2.s Federal EquivalentMethod (FEM) beta-attenuation monitors 1020 (BAM) and the manual particulate matter of 10 microns orless (PM10) Federal Reference Method (FRM) conversion- · to the continuous FEM BAMs. Inworking with the NMED, we note the following network modification issues: concerns regarding the timeliness ofdiscontinuing monitors and sites, monitors being discontinued ormodifications madewithout EPA approval, the wrong monitors being shut down, sites not meeting the siting criteria for existing orprior to monitor/site deployment, and notidentifying collocation requirements for the continuous PM2.s FEM BAM network.
Werecommend that the NMED include an extensive review ofthe PM2.s and PM10 networks after consideration offactors including,-but not limited to the historical PM data quality assessments, the

· location ofcurrent PM design value-(DV) determining sites, and regulatory data needs per

40 CFRPart 58, App. A, D and E as part ofthe 5-YearNetwork Assessment. We stronglyrecommend the NMED establish a phased approached for the PM2.s network equipment conversion,and the manual PM10 FRM network conversion to ensure monitoring objectives and collocationrequirements are continuallymet. To determine the PM10 DVs, please use the reference document PM10 SIP Development Guidelines, US EPA-450/2-86-001 to determine the PM10 DVs. See PM10 SIP Development Guidelines,· Table 6-1.
EPA Region 6 will re-evaluate these requests afterthe NMED provides the requested information for the PM network in the 5-Year Network Assessment. We look forward to working with theNMED on the further evaluation ofthese potential changes. Please see the narrative below for any additional details regarding the 2014 network plan.TheNMED is required to operate one PMz.s regional background site and one PMz.s regional transport site. See 40 CFR 58, App. D, 4.7.3. Pleaseidentifythese two sites inAQS, the 2015 network plan and the 5-YearNetwork Assessment. PMz.s Collocation The NMED has identified the 6Q Las Cruces site (AQS #35-013-0025) for PMz.s collocation and stated that the PMz.s FRM will bereplaced with a PMz.s FEM at this site. Inorder to meet the collocation requirements the following informationmustbe addressed: • For each FRM orFEMhave 15% ofthe monitors collocated. See 40 CFR 58, App. A, 3.2.5. • The first collocated monitorfor a PMz.s FEM, mustbe a designated FRM monitor. See 40 CFR 58, App. A, 3.2.5. • In addition, 80% ofthe collocated monitors should be deployed at sites with annual average or daily concentrations estimated within plus orminus 20% ofthe applicable NAAQS. Ifthere are no sites within the plus orminus 20% ofthe applicable NAAQS, 60% ofthe collocated sites shouldbe deployed at sites among the highest 25% within the network. See 40 CFR 58, App. A, 3.2.5.3. The NMED needs to review the number ofsites requested and identify that each designated FRM or FEM ismeeting 15% collocation. Based on the PMz.s NAAQS, the Las Cruces site has historically reported low concentrations. The expected area for maximum concentrations would be located inthe southern DonaAna County area near the Mexico and Texas borders including the 6ZM Desert View (AQS #35-013-0021) or 6CM Anthony site (AQS #35-013-0016). Weremind NMED that the above t.YPe ofevaluation in demonstrating that collocationrequirements will continue to bemet is expected byEPAto be submitted along withrequests for all PM network changes and modifications. This evaluationincludes both the manual FRM and continuousFEM PMz.s monitors. See 40 CFR 58, App. A, 3.2.5. Pleaseinclude the evaluation for the current PMz.s collocation and continuation of collocation during the PMz.s network conversion process inthe 2015 5-Y ear Network Assessment. PM10 Collocation The operation ofthe manual PM10 FRMwith a continuous PM10FEM at the 6CM Anthony site meets the 15% collocationrequirements of40 CFR Part 58, App. D, 3.3.1. Since collocation for the PM10 manual method is notrequired to be the same method, the continuous PM10 FEM operated in conjunction with the manual FRMmeets the collocation requirement. See 40 CFR 58, App. A, 3.3.1. It is the NMED's responsibilityto ensure the collocationrequirements of40 CFR Part 58 are continually met. Please include a review ofthePM1o collocationrequirements withthe NMED'sproposed conversion process from the manual PM10 FRMs to the continuous FEM BAMs in the 5-YearNetwork Assessment. Special Purpose Monitors (SPM) In the 2014 network plan, the NMED identifies monitors at multiple sites for a change inthe monitor type from State and Local AirMonitoring Station (SLAMS) to SPM. Werecommend the NMED review the entire network,MSAs and sites to ensure all monitors are identified appropriately and make sureto reflect this information inthe 2015 network plan and 5-Year Network Assessment. Please see the narrative below for any additional details regarding the 2014 network plan. Monitors We recommend that the NMEDkeep any auxiliary/discontinued monitors for potential future use including use as backup monitors within the network. We look forward to working withthe NMED on 2the future ambient air network and the adequacy ofthe monitors' siting inthe 5-YearNetwork Assessment. Timeline Pleaseprovide any requested information and clarifications to the EPA Region 6 Air Quality Analysis Section Chiefwithin 30 days ofthe receipt ofthis letter. This does not include items identified as part of the 5-Year Network Assessment. Albuquerque MSA Ozone (03) Network Currently there are seven OJ sites in the Albuquerque MSA; the NMED operates two 03 sites, one each in Sandoval and Valencia Counties and the City ofAlbuquerque (COA) operates five 03 SLAMS sites iu Bernalillo County. According to 40 CPRPart 58, App. D, 4.1 and Table D-2, two ·oJ monitors are required iu MSA greater than 350,000 population with the mostrecent 3-year DV concentrations greater than orequal to 85% ofany03 National Ambient Air Quality Standard (NAAQS). Forthe Albuquerque MSA, two 03 SLAMS sites are required based on the 2013 U.S. Census population estimates of902,797 and the 2013 DV of72 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 the maximum concentration and the National Core (NCore) 2ZM Del Norte site (AQS #35-001-0023) to demonstrate compliance with NCore 03 monitoring requirements. 

### See 40 CPRPart 58, App. D 4.1 (b) and 40 CPRPart 58, App. D 3(b), respectively. Please note that based on thepreliminary 2014 03 DVs, the DV at the 2LL Los Lunas site (AQS #35-061-0008) is 69 ppb while the preliminaryDV for the COA 03 monitor at the 2ZF Foothills site is 67 ppb and the 2ZM Del Norte site is 68ppb. Based·onthis information, werecommend that the 2LL Los Lunas siteremain withthe SLAMS monitortype. In addition, the continued operation ofthe 03 monitor at the 2ZJ Bernalillo site (AQS #35-043-1001) is notrequired to meetminimum network requirements. TheNMED has requested to continue samplingto bettercharacterize the air shed. Please explain orprovide the data analysis review in the 5-Year Network Assessment. 

### PMz.s Network Currently, there are three SLAMS PMz.s sites inthe Albuquerque MSA operatedbythe COAin Bernalillo County. Accordingto 40 CPR Part 58, App. D, 4.7.1 and Table D-5, onePMz.s monitor is required inMSAs greater than 500,000 population with the mostrecent 3-yearDV concentrations less than 85% ofanyPMz.s NAAQS. Forthe Albuquerque MSA, one PMz.s SLAMS site is required based onthe 2013 U.S. Censuspopulation of902,797 and the 2013 24-hrPMz.s DV of20 flg/m3 (57% ofthe 24-hrPMz.s NAAQS, 35 [lg/m3) at the COA operated 2ZM Del Norte site.
Inthe 2014 network plan, the NMED requests to add a PMz.s FEM BAM to the 2ZJ Bernalillo site. The NMED has requested to continue samplingto characterize growth patterns in Sandoval County. Historical PMz.s concentrations ofthe monitors inBernalillo County are extremely low; the 2013 PMz.s DV is 6.7 [lg/m3 (56% ofthe annual PMz.s NAAQS, 12 flg/m3) and the 24 houris 20 [lg/m3 (57% ofthe 24-hrPMz.s NAAQS, 35 flg/m3). The operation ofthe PMz.s FEMBAM is notrequired to meet theminimum network requirements. Please explain the timeline and the data analysis review inthe 5-YearNetwork Assessment.

3PMto Network Currently, there are three PM10 monitors in the Albuquerque MSA operatedbythe COA in Bernalillo County. According to the NMED letter dated November 26,2014 and AQS, the NMED discontinued the manual PM10 monitor on November 26, 2014 at the 2U Bernalillo site (AQS #35-043-0001). Wenote that with the discontinuation ofthe PM10monitor, all monitoring has ceased at 2U Bernalillo site. Please confirm that the 2U Bernalillo site will be closed with the discontinuance ofthe

### PMwmonitor and reflect this informationinthe 2015 network plan. According to40 CFR Part 58, App. D, 4.6 and Table D-4, two to four PM10 SLAMS sites are required in MSAs greaterthan 500,000 population with medium concentrations exceeding 80% ofthe

### PMw

·NAAQS. The 2013 24-hr DV based on data not flagged would yield a DV of 128 J.Lg/m3

(83% ofthe 24-hr

### PMw NAAQS, 150 J.Lg/m3) at the COA operated 2ZS**Jeffe~son** site. Atthis time, the Albuquerque MSA is meeting the minimumrequirements for the number ofPM10 SLAMS sites.
In the 2014 network plan, the NMED requests to add a PM10 FEM BAM to the 2ZJ Bernalillo site. The NMED has requested to sampleto better characterize growth patterns in Sandoval County. The operation ofthe PMto FEM BAM is notrequired to meet the minimum network requirements. Please explain the data analysis review inthe 5-YearNetwork Assessment. Las Cruces MSA 6ZG Sunland Park site (AQS #35-013-0017) Therequest to discontinue the 

### 03 monitor at the 6ZG Sunland Park site is approved based onthe NMED's technical analysis provided onMarch 28,2014 that described the conditions and circumstances at the sitethat could bias the .data and notrepresent ambient air. The discontinuance ofthe 

### 03 monitor will not compromise the data collection needed for implementation ofthe 

### 03 NAAQS and the 40 CFRPart 58, App. D ambient air monitoringrequirements. • TheNMED will need to enter an end date.forthe 

### 03 monitor in AQS at the 6ZG Sunland Park ·Site. • Please notify EPA Region 6 when the monitorhas been discontinued and an end date has been entered into AQS. • Please reflect this informationin the 2015 network plan. According to AQS, the NMED discontinued the monitors for PMto and PMz.s at the site onJune 6, 2014. Wenote that withthe discontinuation ofthe 

### 03 monitor, all monitoring has ceased at 6ZG Sunland Park site:.Please confirm that the 6ZG Sunland Park site will be closed with the discontinuance ofthe 

### 03 monitor and reflect this informationinthe 2015 network plan. 6ZN Santa Teresa site (AQS#35-013-0022) According to the 2014 network plan, theNMED proposes the following changes atthis site: • change in spatial scale from background to urban for the 

### 03 and nitrogen dioxide (NOz) monitors due to industrial changes inthe area • to upgrade the continuous PMz.s tapered element oscillating microbalance (TEOM) samplerto a continuous PMz.s FEM BAM • to pursue looking into locations that wouldbemore optimal for PMz.s monitoring The request to change the spatial scale from background to urban for the 

### 03 and NOz monitors due to industrial changes inthe area is approved. 4According to the NMED letter dated December 8, 2014 and AQS, the NMED discontinued the PMz.s TEOM sampler on December 5, 2014 at this site. In addition, onDecember 15, 2014, the NMED provided an electronic letter stating that the 6ZN SantaTeresa site does not meeting siting criteria for particulate matter and wouldbeginrelocation efforts for the shelter, 03 monitor and

### NOz monitor. We look forward to working with the NMED onthe evaluation ofthe 6ZN SantaTeresa site and relocation efforts. Since the PMz.s network conversion to the continuous PMz.s FEM BAM is not approved and the NMED has identified concerns at the site, EPA cannot approve therequest in the 2014 networkplan to operate thePMz.s FEM BAM at this site. Please see the related PM network comment above regarding the PMz.s network conversion. 6CMAnthony site According to the 2014 network plan, the NMED requests to replace the manual PM10 FRM at the 6CM Anthony site with a continuous PM10 FEM BAM and continue operating a continuous PM10 FEM TEOM. Therequest to add a continuous PM10 FEMBaM at the 6CM Anthony site is approved. The request to discontinue the manual PM10 FRM is not approved. Please see the related PMnetwork comment above regarding the manual PM10 FRMnetwork conversion. Bykeeping the manual PMw FRM at the 6CMAnthony siteas the primarymonitor, the NMED canperform a technical analysis and comparison with the PM10 FEM BAM in an area that experiences elevated ambient air concentrations to see thepotential impacts in the area. EPA Region 6 will re-evaluate therequest to discontinue the manual PM10 FRM after the NMED provides this analysis. • TheNMED will needto designate the FRM as theprimarymonitor and enter the necessary information for the collocated monitor inAQS. • Pleasereflect this information inthe 2015 networkplan.
In addition, the NMED maywant to re-evaluate the appropriateness ofkeeping thePM10 FEM TEOM monitor atthe 6CM Anthony site to ensure optimal use ofresources. Please provide the monitoring data analysis and a rationale for either continued operation ordecommissioning ofthe PM10 FEM TEOM at the 6CM Anthony site. Anyrequest for a system modificationunder 40 CFR § 58.14(c) should be submittedto EPA Region 6 for concurrence. Accordingto the NMED letter dated October 10, 2014 and AQS, theNMED discontinued the PMz.s TEOM sampler on October 10,2014 at the 6CM Anthony site. In addition, the letter stated that EPA Region 6 staffhad concurred with the NMED's reason for the sampler data notbeing included as part.of SLAMS network and for it not having an EPA designation. Weremind NMED that network modifications mustbe fully explained with supporting information andrationale. Please clarify and provide theNMED's explanation. Please note any data collected from a monitorin the NMED's network that is federally funded orreported to AQS musthave a monitor type designation and the resulting data will be subject to EPA oversight. 6ZM Desert View site TheNMED provided a tentative timeline for the construction and demolition ofthe DesertView Elementary Schools adjacent to the 6ZM Desert View site. Please note that itis the NMED's responsibilityto monitor the site and area and prevent anyissues during construction; the construction activities are human made activities and will notbe considered.an exceptional event.

56ZK Chaparral site (AQS #35-013-0020) According to the 2014 network plan, the NMED proposes the following at this site: • continue OJ sampling due to the growing community, to characterize the air shed and background concentrations · • change inmonitor type designation from SLAMS to SPM for the OJ monitor To understand the NMED's requests regarding OJ sampling, please explain orprovidethe data analysis review in the 5-YearNetwork Assessment. PM10 Network Currently, the NMED operates five PM10 SLAMS sites in the Las Cruces MSA whichhavereported multiple exceedances or elevated PM10 concentrations for review by EPA. According to 40 CFR Part 58, App. D, 4.6 and Table D-4, zero to one PM10 SLAMS sites are required in MSAs greater than 100,000 population with medium concentrations exceeding 80% ofthe PM10 NAAQS. Based on the PM10 SIP Development Guidelines, the 2013 24-hrDV based on data not flagged for review is 144 f.!g/mJ (96% ofthe 24-hrPM10NAAQS, ISO !J.g/mJ) at the 6ZM Desert View site. At this time, the Las CrucesMSA is meeting the minimumrequirements for the number ofPM10 SLAMS sites. Therequests toreplace the continuous PM10 FEM TEOMs with the continuous PM10 FEM BAMs are approved at the following sites: 6ZLHolman Road (AQS #35-013-0019), 6ZK Chaparral, 6ZM Desert View and 6WMWest Mesa (AQS #35-013-0024). Since these sites have measured ambient concentrations ofPM10 exceeding the 24-hrNAAQS from 2011 to 2013, we do not approve the change in monitortype from SLAMS to SPM. In addition, all ofthese monitors report similar elevated concentrations. Werecommend that the NMED review the PM10 network inDona Ana Countyto ensure optimal use ofresources and equipment after consideration offactors including, but not limited to the historical PM10 data quality assessments, the location ofcurrent PM10 DV sites, and theirregulatory data needs per40 CFRPart 58, App. A, D and E as part ofthe 2015 5-YearNetwork Assessment. SantaFeMSA 3SFA Santa Fe Airport site (AQS #35-049-0021) Since the PM2.s network conversion to the continuous PM2.s FEM BAM is not approved, therequest to add a continuous 

### PMz.s FEM BAM atthis site is not approved. Please seethe related PMnetwork comment above regarding the 

### PMz.s network conversion. · 3HMRunnels site (AQS #35-049-0020) According to the NMED letter dated October 10,2014 and AQS, the NMED discontinued the

### PMz.s TEOM sampler and the 

### PMz.s FRM monitors onJune 11,2014 at this site. In addition, the PM10 FRM Parameter Occurrence Code (POC)-1 and POC-2 monitors at the 3HM Runnels site were approved for discontinuation inthe 2013 annual network review response letter from the EPA Region 6 dated February 19,2014. According to AQS, the PM10 POC I and POC 2 monitors do not have end dates. The NMED has notprovided a letter oremail to document that the monitorhas been discontinued. Please see the related PM network comment above regarding PM10 collocation at the 6CM Anthony site. • The NMED will need to enter end dat.es for the PM10 monitors at the 3HM Runnels site inAQS. • Please notify EPA Region 6 when the monitors havebeen discontinued and end dates havebeen. entered into AQS. • Pleasereflect this information inthe 2015 network plan.

6We note that with the discontinuation ofthe PM10 monitors, all monitoringhas ceased at the 3HM Runnels site. Please confirm that the 3HM Runnels site will be closed with the discontinuance of the PM10 monitors and reflect this information in the 2015 network plan. Farmington MSA 12B Bloomfield site (AQS #35-045-0009) Therequest to add a continuous PM10 FEM BAM as an SPM at the 12B Bloomfield site is approved. Since the PM2.s network conversion to the continuous PM2.s FEM BAM is not approved, therequest to operatethe PMz.s FEM BAM at this site is not approved. Please see the related PM networkcomment above regarding the PM2.s network conversion. 1FO Farmington site (AQS #35-045-0019) Sincethe PM2.s network conversion to the continuous PMz.s FEM BAM is not approved, the request to discontinue the PM2.s POC 1 and POC 2 FRMs at this site is not approved at this time. Please see the related PM network comment above regarding the PM2.s network conversion and the PMz.s collocation comment above. According to AQS, the manual PM10 FRMmonitor was discontinued onMay 15,2014. The 2014 network plan documented that the site did measure one exceedance onMay 16, 2013 due to a high wind event. Wenote that the NMED has flagged the exceedance in AQS. 1NLNavajo Lake site (AQS #35-045-0018) According to the NMED letter dated October 10,2014,the 2014 networkplan and AQS, the NMED discontinued the PM2.s TEOM sampler on May 15,2014 at this site. 5ZS Hobbs Jefferson site (AQS #35-025-0008) According to the 2014 network plan, the NMED proposes the following at this site: • to continue 03and 

### NOz sampling to characterize increase pollutant trends • change in monitor type designation from SLAMS to SPM for the 03 monitor
To understand the NMED's requests regarding 03 and

### NOz sampling, please explain orprovide the data analysis review for the pollutant trends inthe 5-YearNetwork Assessment.
PM Network According to the NMED letter dated October 24, 2014 and AQS, theNMED discontinued the manual PM10 sampler onJune 11,2014 and the PM2.s TEOM sampler on September 3, 2014 at this site. The letter also stated that the NMED would start operating a PM10 FEM TEOM sampler on October 23,2014. We informed NMED through separate communication on October 30,2014, that the operation ofthe PM10 FEM TEOM at the SZS Hobbs Jefferson site had not been approved. Itis the NMED's responsibility to follow the 40 CFRPart 58 requirements and obtain approval prior to a system modification. The request in the 2014 network plan to replace the manual PM10 FRM sampler with a continuous PM10 FEM TEOM sampler is not approved. Please see the related PM network comment above regarding the manual PM10 network conversion. In addition, historical concentrations ofthe PM10 concentrations have been low within the 24hour standard since 2005. EPA Region 6 will re-evaluate these requests after NMED provides therequested information for the PM10 network inthe 5-Year Network Assessment.



### 7In addition, the PMz.s POC-3 monitor does not have an end date in AQS and therefore, has notbeen officially discontinued. • The NMED will need to enter an end date for the PMz.s monitor at the 5ZS Hobbs Jefferson site inAQS. • Please notify EPA Region 6 when the monitorhas been discontinued and an end date has been entered into AQS. • Please reflect this information in the 2015 network plan. EPA Region 6 understands that the NMED has evaluated the PMz.s and PM10 network for compliance in meeting siting criteria with 40 CFR Part 58, App. E and noted concerns for the 5ZS Hobbs Jefferson sjte. Pleaseprovideupdates regarding steps the NMED has taken to maintain compliance with siting criteria and/or updates regarding steps that the NMED has taken to either verify orbringthe site into compliance with the siting criteria of40 CFR 58, App. E. Since the NMED has noted concerns with the siting criteria and the PM2.s network conversionto the continuous PMz.s FEM BAM is not approved, the request to operate a continuous PMz.s FEM BAM as an SPM at this site is not approved. Please seethe related PM network comment above regarding the PM2.s network conversion.·EPA Region 6 will re-evaluate theserequests after NMED provides requested information for the PM network and the siting criteria.
SOz Atthis time, we do not approve the request to add an S02 monitor at the 5ZS Hobbs Jefferson site or any sites to the NMED S02 networkuntil the Data Requirements Rule for the 1-Hour S02 Primary NAAQS has been finalized. However, in anticipation ofthe finalized rule, we look forward to the NMED's re-evaluation ofthe S02 network in the 5-YearNetwork Assessment. 5ZR Carlsbad site (AQS #35-015-1005) According to the 2014 network plan, the NMED proposes the following at this site: • continue OJ and N02 sampling to characterize increase pollutant trends • change in monitor type designation from SLAMS to SPM for the N02 monitor • to upgrade the continuous PM2.sTEOM sampler to a continuous PM2.s FEM BAM as an SPM To understand the NMED's requests regarding OJ and N02 sampling, please explain orprovidethe data analysis review for the pollutanttrends in the 5-YearNetwork Assessment. Since the PM2.s network conversion to the continuous PMz.s FEM BAMis not approved, the request to upgrade the continuous PMz.s TEOM samplerto a continuous PM2.s FEM BAM at this site is not approved. Please see the related PM network comment above regarding the PM2.s network conversion. 3ZD Taos site (AQS #35-055-0005)
EPA Region 6 understands that the NMED has evaluated the PM2.s network for compliance inmeeting siting criteria with 40 CFR Part 58, App. E and noted concernsforthe 3ZD Taos site. Pleaseprovide updates regarding steps the NMED has taken to maintain compliance with siting criteria and/or updates regarding steps that the NMED has taken to either verify orbringthe site into compliance with the siting criteria of40 CFR 58, App. E. Sincethe NMED has noted concerns withthe siting criteria and the PM2.s network conversion to the continuous PM2.s FEM BAM is not approved, the request to operate a continuous PM2.s FEM BAM as an SPM at the this site is not approved. Please see therelated PM

8network comment above regarding the PM2.s network conversion. EPA Region 6 will re-evaluate these requests afterNMED provides requested informationfor the PM network and the siting criteria. According tothe NMED letter dated October 10,2014 and AQS, the NMED discontinued the PM10. FRM sampler on July 21, 2014 at the 3ZD Taos site. 7T llur1ey Smelter site (AQS #35-017-1003)

· The request to discontinue the S02 monitor at the 7T Hurley Smelter site is approved. The Hurley

Smelter, a copper ore smelter that was part ofthe Chino Mine-Hurley Facility located in Hurley, New Mexico, was**dismantle~,** and its stacks were removed in July 2006. The Chino Mine-Hurley Facility modified its Title V and New Source Review (NSR) permits to remove all the equipment associated with the former Hurley Smelter; therevised permit was issued onMay23, 2007. EPA's final approval ofthe Grant County S02 Limited Maintenance Plan for the second 10-yearmaintenance period was effective on September 16, 2014. The S02 maintenance planno longerrequires the operation ofan S02 monitor at the 7T Hurley Smelter site. The discontinuance ofthe S02 monitor will not compromisethe data collection needed for implementation ofthe S02 NAAQS, and the 40 CPRPart 58, Appendix D ambient airmonitoring requirements will continue to bemet. • TheNMED will need to enter an end date for the S02 monitor at the 7T Hurley Smelter site in AQS. • Please notifY EPA Region 6 when the monitor has been discontinued and end dates havebeen entered into AQS. • Pleasereflect this information inthe 2015 network plan. We note through separate communication on January 9, 12 and 14,2015 that the NMED discontinued monitoring for S02 on January 9, 2015 before EPA approval. Please note that itis the NMED's responsibility to follow the 40 CPR Part 58 requirements and obtain approval prior to a system modification. Themonitor subsequently collected data as of 12:22 pm on January 13,2015. According to the NMED letters dated October 24,2014 and November 26,2014 and AQS, the NMED discontinued the manual PM10 monitor on October 23,2014 and the OJ monitor on November 19, 2014 at this site. We note thatwith the discontinuation ofthe S02monitor, all monitoring has now ceased at 7T Hurley Smelter site. Please confirm that the 7T Hurley Smelter site will be closed with the discontinuance ofthe S02monitor and reflect this information inthe 2015 network plan. 7E DemingAirport site (AQS #35-029-0003) The request to discontinue the N02 monitor atthe 7E DemingAirport site is approved due to historically low concentrations. The discontinuance ofthe N02 monitor will not compromise the data collection needed for implementation ofthe N02NAAQS, and the 40 CPRPart 58, Appendix D ambient air monitoring requirements will continue to be met. • The NMED will need to enter an end date for the N02 monitor at the 7E Deming Airport site in AQS. • Please notifY EPA Region 6 when the monitor has been discontinued and end dates havebeen entered into AQS. • Pleasereflect this information in the 2015 network plan.

9Also, according to the NMED letter dated November 26,2014 and AQS, the NMED discontinued the 

### 03 monitor onNovember.20, 2014 at the 7E Deming Airport site. · The request to replace the continuous PM10 FEMTEOM with the continuous PM10 FEM BAMis approved at the 7E DemingAirport site. Since this site has measured ambient concentrations ofPM10 exceeding the 24-hrNAAQS during 2011 to 2013, we do not approve the change inmonitor type from SLAMS to SPM. EPA supports the continued operation ofthe 

### PMw monitor at the 7E DemingAirport site to cover the Demingmicropolitan statistical area. According to the NMED letter dated October 10,2014 and AQS, the NMED discontinued the primary and collocated manual PM10 monitors on October7, 2014 at the 7D Deming site (AQS #35-029-0001). 2015 Network Reviews Pleaseinclude the information identified in the comments above inthe 5-YearNetwork Assessment. We look forward to working with the NMED onthe 2015 5-YearNetwork Assessment to address the following specific areas ofconcern: • Areas ofNew Mexico including the northwest, southwest, Albuquerque MSA and the El Paso CBSA and notjust specific sites • New PSD permit applications inthe Permian Basin • PMz.s requirements 

### • PMw requirements • Network sitingissues • SOz monitoring Information regarding the micropolitan and CBSAs can be includedin the 5-YearNetwork Assessment. Forthe latest estimated population available from the United States Census Bureau, please referto the revised county definitions for MSAs released bythe US Census Bureau on February 28, 2013. See 75 FR 37246-37252 (June 28, 2010). The U.S. Census Bureauhas included the revised MSA definitions intheir updated population estimates. In addition, any consideration and impact with adjoining areas and meteorological conditions can be incorporated into the 5-Year Network Assessment. Please make sure to address all ofthe NMED's monitoring and types ofmonitoring 

### inthe 5-Year Network Assessment. EPARegion 6 looks forward to reviewing the 5-Year Network Assessment's full evaluation ofthe PM networks.

10