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 

Santa Fe, NM 87505 

Dear Mr. Goodyear: 

APR 14 2015 

Thank you for your correspondence submitting the New Mexico Environment Department's (NMED) 

2014 Annual Monitoring Network Plan (network plan). The U.S. Environmental Protection Agency 

(EPA) has completed its analysis of the NMED's 2014 network plan to ensure it meets those 

requirements of 40 CFR Part 58. The authority for the approval of the network plan 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 NMED to collaborate on the ambient air monitoring 

network design. See 40 CFR Part 58 App. D, 1.1.2. The EPA has reviewed your plan, including the 

proposed ozone and particulate matter monitor changes to the NMED Ambient Air Monitoring Network. 

I am pleased to inform you that the NMED's 2014 network plan is approved in accordance with 

40 .GFR §58.10, with exception of the particulate matter of2.5 microns or less (PMz.s) network 

conversion and the manual particulate matter of 10 microns or less (PM10) Federal Reference Method 

(FRM) conversion. EPA will re-evaluate this request upon submittal of the 5-Year Network Assessment. 

Details of our review on the NMED's ambient air monitoring network are provided in the enclosure. 

We look forward to our continued collaborative work with the NMED on its 2015 ambient air 

monitoring network. Please ensure the 5-Year Network Assessment addresses both planning and 

monitoring aspects. If you have any questions, please contact me at (214) 665-7548 or your staff may 

contact Ms. Kara Allen of my staff at (214) 665-7333. 

Sincerely yours, 

/lfJ;jJ 

Mark Hansen 

Acting Associate Director for Air Programs 

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 Air Monitoring Network Plan Technical Comments 

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

Network Plan (network plan) and our comments are provided below. In addition to the network plan, 

EPA's review includes additional information provided by the NMED as identified below. 

General Comments 

EPA notes that there are discrepancies including, but not limited to the site names, site addresses, 

sampling methods, monitoring objectives and spatial scales between the 2014 network plan, Appendix E 

network elements (Table 1 ), and the EPA's national air monitoring database, Air Quality System (AQS). 

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 for sites 

and monitors that are operating. 

Specifically for Table 1, we note that the NMED does not identifY the sites appropriately for the 

Farmington, Albuquerque and Las Cruces Metropolitan Statistical Areas (MSA). Please provide the 

MSA information and include core-based statistical areas (CBSAs) if required by 40 CFR Part 58, but 

do not include the micropolitan areas in the network plan. Furthermore, please do not list monitors 

and/or sites that have been discontinued. Monitors are not officially discontinued nntil end dates have 

been entered into AQS. See the narrative below for any additional details regarding the 2014 network 

plan. 

Particulate Matter (PM) Network 

At this time, we cannot approve the particulate matter of2.5 microns or less (PM2.s) network conversion · 

to the continuous PM2.s Federal Equivalent Method (FEM) beta-attenuation monitors 1020 (BAM) and 

the manual particulate matter of 10 microns or less (PM10) Federal Reference Method (FRM) conversion- · 

to the continuous FEM BAMs. In working with the NMED, we note the following network modification 

issues: concerns regarding the timeliness of discontinuing monitors and sites, monitors being 

discontinued or modifications made without EPA approval, the wrong monitors being shut down, sites 

not meeting the siting criteria for existing or prior to monitor/site deployment, and not identifying 

collocation requirements for the continuous PM2.s FEM BAM network. 

We recommend that the NMED include an extensive review of the PM2.s and PM10 networks after 

consideration of factors including, -but not limited to the historical PM data quality assessments, the 

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

40 CFR Part 58, App. A, D and E as part of the 5-Year Network Assessment. We strongly recommend 

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 collocation requirements are 

continually met. 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 after the NMED provides the requested information for the 

PM network in the 5-Year Network Assessment. We look forward to working with the NMED on the 

further evaluation of these potential changes. Please see the narrative below for any additional details 

regarding the 2014 network plan. 
The NMED 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. Please identify these two sites in AQS, the 2015 network plan and 

the 5-Year Network 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 be replaced with a PMz.s FEM at this site. In order to meet the collocation 

requirements the following information must be addressed: 

• For each FRM or FEM have 15% ofthe monitors collocated. See 40 CFR 58, App. A, 3.2.5. 

• The first collocated monitor for a PMz.s FEM, must be a designated FRM monitor. 

See 40 CFR 58, App. A, 3.2.5. 

• In addition, 80% of the collocated monitors should be deployed at sites with annual average or 

daily concentrations estimated within plus or minus 20% of the applicable NAAQS. If there are 

no sites within the plus or minus 20% ofthe applicable NAAQS, 60% of the collocated sites 

should be 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 of sites requested and identify that each designated FRM or 

FEM is meeting 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 in the 

southern Dona Ana 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). We remind NMED 

that the above t.YPe of evaluation in demonstrating that collocation requirements will continue to be met 

is expected by EPA to be submitted along with requests for all PM network changes and modifications. 

This evaluation includes both the manual FRM and continuousFEM PMz.s monitors. See 40 CFR 58, 

App. A, 3 .2.5. Please include the evaluation for the current PMz.s collocation and continuation of 

collocation during the PMz.s network conversion process in the 2015 5-Y ear Network Assessment. 

PM10 Collocation 

The operation of the manual PM10 FRM with a continuous PM10 FEM at the 6CM Anthony site meets 

the 15% collocation requirements of 40 CFR Part 58, App. D, 3.3.1. Since collocation for the PM10 

manual method is not required to be the same method, the continuous PM10 FEM operated in 

conjunction with the manual FRM meets the collocation requirement. See 40 CFR 58, App. A, 3.3.1. It 

is the NMED's responsibility to ensure the collocation requirements of 40 CFR Part 58 are continually 

met. Please include a review ofthe PM1o collocation requirements with the NMED's proposed 

conversion process from the manual PM10 FRMs to the continuous FEM BAMs in the 5-Year Network 

Assessment. 

Special Purpose Monitors (SPM) 

In the 2014 network plan, the NMED identifies monitors at multiple sites for a change in the monitor 

type from State and Local Air Monitoring Station (SLAMS) to SPM. We recommend the NMED review 

the entire network, MSAs and sites to ensure all monitors are identified appropriately and make sure to 

reflect this information in the 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 NMED keep any auxiliary/discontinued monitors for potential future use 

including use as backup monitors within the network. We look forward to working with the NMED on 

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the future ambient air network and the adequacy of the monitors' siting in the 5-Year Network 

Assessment. 

Timeline 

Please provide any requested information and clarifications to the EPA Region 6 Air Quality Analysis 

Section Chief within 30 days of the receipt of this 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 of Albuquerque (COA) operates five 03 SLAMS sites 

iu Bernalillo County. According to 40 CPR Part 58, App. D, 4.1 and Table D-2, two ·oJ monitors are 

required iu MSA greater than 350,000 population with the most recent 3-year DV concentrations greater 

than or equal to 85% of any 03 National Ambient Air Quality Standard (NAAQS). For the 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 per billion (ppb) at the 2ZF Foothills site (AQS #35-001-1012). 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 03 monitoring requirements. See 40 CPR Part 58, App. D 4.1 (b) and 

40 CPR Part 58, App. D 3(b ), respectively. 

Please note that based on the preliminary 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 68 ppb. Based· on this information, we recommend that the 

2LL Los Lunas site remain with the SLAMS monitor type. In addition, the continued operation of the 03 

monitor at the 2ZJ Bernalillo site (AQS #35-043-1001) is not required to meet minimum network 

requirements. The NMED has requested to continue sampling to better characterize the air shed. Please 

explain or provide the data analysis review in the 5-Year Network Assessment. 

PMz.s Network 

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

Bernalillo County. According to 40 CPR Part 58, App. D, 4.7.1 and Table D-5, one PMz.s monitor is 

required in MSAs greater than 500,000 population with the most recent 3-year DV concentrations less 

than 85% of any PMz.s NAAQS. For the Albuquerque MSA, one PMz.s SLAMS site is required based 

on the 2013 U.S. Census population of902,797 and the 2013 24-hr PMz.s DV of20 flg/m3 (57% of the 

24-hr PMz.s NAAQS, 35 [lg/m3) at the COA operated 2ZM Del Norte site. 

In the 2014 network plan, the NMED requests to add a PMz.s FEM BAM to the 2ZJ Bernalillo site. The 

NMED has requested to continue sampling to characterize growth patterns in Sandoval County. 

Historical PMz.s concentrations of the monitors in Bernalillo County are extremely low; the 2013 PMz.s 

DV is 6.7 [lg/m3 (56% of the annual PMz.s NAAQS, 12 flg/m3

) and the 24 hour is 20 [lg/m3 

(57% of the 24-hr PMz.s NAAQS, 35 flg/m3). The operation of the PMz.s FEMBAM is not required to 

meet the minimum network requirements. Please explain the timeline and the data analysis review in the 

5-Year Network Assessment. 

3 
PMto Network 

Currently, there are three PM10 monitors in the Albuquerque MSA operated by the 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). We note 

that with the discontinuation of the PM10 monitor, all monitoring has ceased at 2U Bernalillo site. Please 

confirm that the 2U Bernalillo site will be closed with the discontinuance ofthe PMw monitor and 

reflect this information in the 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 greater than 500,000 population with medium concentrations exceeding 80% of the 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. At this time, the 

Albuquerque MSA is meeting the minimum requirements 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 sample to better characterize growth patterns in Sandoval County. The 

operation of the PMto FEM BAM is not required to meet the minimum network requirements. Please 

explain the data analysis review in the 5-Year Network Assessment. 

Las Cruces MSA 

6ZG Sunland Park site (AQS #35-013-0017) 

The request to discontinue the 03 monitor at the 6ZG Sunland Park site is approved based on the 

NMED's technical analysis provided on March 28,2014 that described the conditions and circumstances 

at the site that could bias the .data and not represent ambient air. The discontinuance of the 03 monitor 

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. 

• The NMED will need to enter an end date.for the 03 monitor in AQS at the 6ZG Sunland Park 

·Site. 

• Please 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 2015 network plan. 

According to AQS, the NMED discontinued the monitors for PMto and PMz.s at the site on June 6, 2014. 

We note that with the discontinuation of the 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 of the 03 

monitor and reflect this information in the 2015 network plan. 

6ZN Santa Teresa site (AQS #35-013-0022) 

According to the 2014 network plan, the NMED proposes the following changes at this site: 

• change in spatial scale from background to urban for the 03 and nitrogen dioxide (NOz) monitors 

due to industrial changes in the area 

• to upgrade the continuous PMz.s tapered element oscillating microbalance (TEOM) sampler to a 

continuous PMz.s FEM BAM 

• to pursue looking into locations that would be more 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 in the area is approved. 

4 
According 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, on December 15, 2014, the NMED 

provided an electronic letter stating that the 6ZN Santa Teresa site does not meeting siting criteria for 

particulate matter and would begin relocation efforts for the shelter, 03 monitor and NOz monitor. We 

look forward to working with the NMED on the evaluation of the 6ZN Santa Teresa 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 the request in the 2014 network plan to operate 

the PMz.s FEM BAM at this site. Please see the related PM network comment above regarding the PMz.s 

network conversion. 

6CM Anthony 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. The request to add a continuous PM10 FEM BaM at the 6CM Anthony site is approved. The 

request to discontinue the manual PM10 FRM is not approved. Please see the related PM network 

comment above regarding the manual PM10 FRM network conversion. By keeping the manual PMw 

FRM at the 6CM Anthony site as the primary monitor, the NMED can perform a technical analysis and 

comparison with the PM10 FEM BAM in an area that experiences elevated ambient air concentrations to 

see the potential impacts in the area. EPA Region 6 will re-evaluate the request to discontinue the 

manual PM10 FRM after the NMED provides this analysis. 

• The NMED will need to designate the FRM as the primary monitor and enter the necessary 

information for the collocated monitor in AQS. 

• Please reflect this information in the 2015 network plan. 

In addition, the NMED may want to re-evaluate the appropriateness of keeping the PM10 FEM TEOM 

monitor at the 6CM Anthony site to ensure optimal use of resources. Please provide the monitoring data 

analysis and a rationale for either continued operation or decommissioning of the PM10 FEM TEOM at 

the 6CM Anthony site. Any request for a system modification under 40 CFR § 58.14(c) should be 

submitted to EPA Region 6 for concurrence. 

According to the NMED letter dated October 10, 2014 and AQS, the NMED discontinued the PMz.s 

TEOM sampler on October 10,2014 at the 6CM Anthony site. In addition, the letter stated that EPA 

Region 6 staff had concurred with the NMED' s reason for the sampler data not being included as part .of 

SLAMS network and for it not having an EPA designation. We remind NMED that network 

modifications must be fully explained with supporting information and rationale. Please clarify and 

provide theNMED's explanation. Please note any data collected from a monitor in the NMED's 

network that is federally funded or reported to AQS must have a monitor type designation and the 

resulting data will be subject to EPA oversight. 

6ZM Desert View site 

The NMED provided a tentative timeline for the construction and demolition of the Desert View 

Elementary Schools adjacent to the 6ZM Desert View site. Please note that it is the NMED's 

responsibility to monitor the site and area and prevent any issues during construction; the construction 

activities are human made activities and will not be considered.an exceptional event. 

5 
6ZK 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 in monitor type designation from SLAMS to SPM for the OJ monitor 

To understand the NMED's requests regarding OJ sampling, please explain or provide the data analysis 

review in the 5-YearN etwork Assessment. 

PM10 Network 

Currently, the NMED operates five PM10 SLAMS sites in the Las Cruces MSA which have reported 

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% of the PM10 NAAQS. 

Based on the PM10 SIP Development Guidelines, the 2013 24-hr DV based on data not flagged for 

review is 144 f.!g/mJ (96% of the 24-hr PM10 NAAQS, ISO !J.g/mJ) at the 6ZM Desert View site. At this 

time, the Las CrucesMSA is meeting the minimum requirements for the number ofPM10 SLAMS sites. 

The requests to replace the continuous PM10 FEM TEOMs with the continuous PM10 FEM BAMs are 

approved at the following sites: 6ZL Holman Road (AQS #35-013-0019), 6ZK Chaparral, 6ZM Desert 

View and 6WM West Mesa (AQS #35-013-0024). Since these sites have measured ambient 

concentrations ofPM10 exceeding the 24-hr NAAQS from 2011 to 2013, we do not approve the change 

in monitor type from SLAMS to SPM. In addition, all of these monitors report similar elevated 

concentrations. We recommend that the NMED review the PM10 network in Dona Ana County to ensure 

optimal use of resources and equipment after consideration of factors including, but not limited to the 

historical PM10 data quality assessments, the location of current PM10 DV sites, and their regulatory data 

needs per 40 CFR Part 58, App. A, D and E as part of the 2015 5-Year Network 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, the request to 

add a continuous PMz.s FEM BAM at this site is not approved. Please see the related PM network 

comment above regarding the PMz.s network conversion. · 

3HM Runnels 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 on June 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 in the 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 not provided a letter or email to document that the monitor has 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 in AQS. 

• Please notify EPA Region 6 when the monitors have been discontinued and end dates have been. 

entered into AQS. 

• Please reflect this information in the 2015 network plan. 

6 
We note that with the discontinuation of the PM10 monitors, all monitoring has 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) 

The request 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, the request to 

operate the 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) 

Since the 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 FRM monitor was discontinued on May 15,2014. 

The 2014 network plan documented that the site did measure one exceedance on May 16, 2013 due to a 

high wind event. We note that the NMED has flagged the exceedance in AQS. 

1NL Navajo Lake site (AQS #35-045-0018) 

According to the NMED letter dated October 10,2014, the 2014 network plan 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 03 and 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 or provide the data 

analysis review for the pollutant trends in the 5-Year Network Assessment. 

PM Network 

According to the NMED letter dated October 24, 2014 and AQS, the NMED discontinued the manual 

PM10 sampler on June 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 of the PM10 FEM TEOM at the SZS Hobbs Jefferson site had not been approved. It is the 

NMED's responsibility to follow the 40 CFR Part 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 of the PM10 

concentrations have been low within the 24 hour standard since 2005. EPA Region 6 will re-evaluate 

these requests after NMED provides the requested information for the PM10 network in the 5-Year 

Network Assessment. 

7 
In addition, the PMz.s POC-3 monitor does not have an end date in AQS and therefore, has not been 

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 monitor has 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. Please provide 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 or bring the site into 

compliance with the siting criteria of 40 CFR 58, App. E. Since the NMED has noted concerns with the 

siting criteria and the PM2.s network conversion to 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 see the 

related PM network comment above regarding the PM2.s network conversion.· EPA Region 6 will 

re-evaluate these requests after NMED provides requested information for the PM network and the 

siting criteria. 

SOz 

At this 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 network until the Data Requirements Rule for the 1-Hour S02 Primary NAAQS 

has been finalized. However, in anticipation of the finalized rule, we look forward to the NMED's 

re-evaluation of the S02 network in the 5-Year Network 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.s TEOM sampler to a continuous PM2.s FEM BAM as an SPM 

To understand the NMED's requests regarding OJ and N02 sampling, please explain or provide the data 

analysis review for the pollutant trends in the 5-Year Network Assessment. Since the PM2.s network 

conversion to the continuous PMz.s FEM BAM is not approved, the request to upgrade the continuous 

PMz.s TEOM sampler to 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 in meeting 

siting criteria with 40 CFR Part 58, App. E and noted concerns for the 3ZD Taos site. Please provide 

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 or bring the site into compliance with the siting 

criteria of 40 CFR 58, App. E. Since the NMED has noted concerns with the 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 the related PM 

8 
network comment above regarding the PM2.s network conversion. EPA Region 6 will re-evaluate these 

requests after NMED provides requested information for the PM network and the siting criteria. 

According to the 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 of the 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; the revised permit was issued on May 23, 2007. EPA's final approval 

of the Grant County S02 Limited Maintenance Plan for the second 10-year maintenance period was 

effective on September 16, 2014. The S02 maintenance plan no longer requires the operation of an S02 

monitor at the 7T Hurley Smelter site. The discontinuance of the S02 monitor will not compromise the 

data collection needed for implementation of the S02 NAAQS, and the 40 CPR Part 58, Appendix D 

ambient air monitoring requirements will continue to be met. 

• The NMED 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 have been 

entered into AQS. 

• Please reflect this information in the 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 it is the NMED' s 

responsibility to follow the 40 CPR Part 58 requirements and obtain approval prior to a system 

modification. The monitor 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 that with the discontinuation ofthe S02 monitor, all monitoring has now ceased at 

7T Hurley Smelter site. Please confirm that the 7T Hurley Smelter site will be closed with the 

discontinuance of the S02 monitor and reflect this information in the 2015 network plan. 

7E Deming Airport site (AQS #35-029-0003) 

The request to discontinue the N02 monitor at the 7E Deming Airport site is approved due to historically 

low concentrations. The discontinuance of the N02 monitor will not compromise the data collection 

needed for implementation of the N02 NAAQS, and the 40 CPR Part 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 have been 

entered into AQS. 

• Please reflect this information in the 2015 network plan. 

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Also, according to the NMED letter dated November 26,2014 and AQS, the NMED discontinued the 03 

monitor on November.20, 2014 at the 7E Deming Airport site. · 

The request to replace the continuous PM10 FEM TEOM with the continuous PM10 FEM BAM is 

approved at the 7E Deming Airport site. Since this site has measured ambient concentrations ofPM10 

exceeding the 24-hr NAAQS during 2011 to 2013, we do not approve the change in monitor type from 

SLAMS to SPM. EPA supports the continued operation of the PMw monitor at the 7E Deming Airport 

site to cover the Deming micropolitan statistical area. According to the NMED letter dated 

October 10,2014 and AQS, the NMED discontinued the primary and collocated manual PM10 monitors 

on October 7, 2014 at the 7D Deming site (AQS #35-029-0001). 

2015 Network Reviews 

Please include the information identified in the comments above in the 5-Year Network Assessment. We 

look forward to working with the NMED on the 2015 5-YearNetwork Assessment to address the 

following specific areas of concern: 

• Areas of New Mexico including the northwest, southwest, Albuquerque MSA and the El Paso 

CBSA and not just specific sites 

• New PSD permit applications in the Permian Basin 

• PMz.s requirements 

• PMw requirements 

• Network siting issues 

• SOz monitoring 

Information regarding the micropolitan and CBS As can be included in the 5-Year Network Assessment. 

For the latest estimated population available from the United States Census Bureau, please refer to the 

revised county definitions for MSAs released by the US Census Bureau on February 28, 2013. 

See 75 FR 37246-37252 (June 28, 2010). The U.S. Census Bureau has included the revised MSA 

definitions in their 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 of the NMED' s monitoring and types of monitoring in the 5-Year 

Network Assessment. EPA Region 6 looks forward to reviewing the 5-Year Network Assessment's full 

evaluation of the PM networks. 

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