UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX
75 Hawthorne Street San Francisco, CA 94105

April 19, 2013

Ms. Karen Magliano, Manager Air Quality Data Branch Planning and Technical Support Division

California Air Resources Board

P.O. Box 2815 Sacramento, California 95812

Dear M s

. Magliano :

In the State of California twelve districts plus the California Air Resources Board (CARB) submit annual network plans in accordance with 40 CFR 58.10

. The plans that were submitted by the following local agencies in California in 2012 have been approved:

 Bay Area Air Quality Management District,

 Great Basin Unified Air Pollution Control District,

 Imperial County Air Pollution Control District,

 Monterey Bay Unified Air Pollution Control District,

 North Coast Unified Air Pollution Control District,

 Sacramento Metro politan Air Quality Management District,

 San Diego County Air Pollution Control District,

 San Luis Obispo County Air Pollution Control District,

 Santa Barbara County Air Pollution Control District,

 South Coast Air Quality Management District, and

 Ventura County Air Pollution Control District. We have provided specific comments on the plans we received from local agencies through separate

letters

. We appreciate your efforts in preparing the “2012 Annual Monitoring Report for Small Districts

in California

, ” submitted by CARB in June 2012. Based on the information provided in the plan, EPA approves all portions of the network plan except those speci fically identified in Attachments A and B

, for which no action is being taken at this time

. San Joaquin Valley Unified Air Pollution Control District did not submit an annual network plan for 2012 and therefore we are not acting on the network plan for

the San Joaquin Valley at this time.

Please note that we cannot approve portions of th e annual network plan for which the information in the plan is insufficient to judge whether the requirement has been met, or for which the information , as described, does not meet the requirements as specified in 40 CFR 58.10 and the associated appendices.

EPA Region 9 also cannot approve portions of the plan for which the EPA Administrator has approval authority. Accordingly, we are not acting on the specific portion s of your agency’s annual network planlisted in Attachment B . Some annual network plans submitted by local agencies include d CARB sites.

Missing or deficient information for CARB sites in local agency plans was addressed in the approval

letters for each l ocal agency. For convenience, we are providing a synthesized list of these issues in

Attachment C. In addition to the checklist (Attachment A) and list of specific plan elements where EPA Region 9 is not taking action (Attachments B and C) , enclosed are additional detailed comments on “2012 Annual Monitoring Report for Small Districts in California” (Attachment D ).

EPA Region 9 identified specific annual network plan requirements that were not addressed in any plan

submitted in 2012. Thes e include requirements that apply to the State or multiple jurisdictions, as well as for areas for which no plan was received ( i.e. , San Joaquin Valley). These issues are listed in

Attachment E. Due to the closure and lack of approved replacement for the o zone monitor at Arvin Bear Mountain Road, the State of California does not currently meet the requirement for a maximum ozone

concentration monitor in the Bakersfield Metropolitan Statistical Area ( MSA ) . We therefore disapprove

the 40 CFR 58 Appendix D 4.1 (b ) network requirement in that instance.

EPA will continue to work with CARB and the San Joaquin Valley Air Pollution Control District (SJVAPCD) to resolve this issue prior to ozone data in the Bakersfield MSA being considered for a regulatory action. C ARB and SJVAPCD are making efforts to find an adequate replacement for the previous Arvin Bear Mountain Road site. EPA appreciates CARB ’s attempts to work with the Arvin

Edison Water Storage District to return to the original site, and SJVAPCD’s recent Req uest for Proposals for an ozone saturation study to evaluate ozone gradients in the area. With respect to SJVAPCD’s study, EPA hopes to work closely with CARB and SJVAPCD in the study design and implementation, which could help inform the choice of an adeq uate replacement site for Arvin Bear

Mountain Road

. A replacement, once approved by EPA under 40 CFR 58.14, can be used as the basis for approval of the 40 CFR 58 Appendix D 4.1(b) requirement in future annual network plan actions.

All of the comments in Attachments A , B, C , D, and E should be addressed in next year’s network plan s

. If you have any questions regarding this letter or the enclosed comments, please feel free to contact me at (415) 972

- 3851 or Meredith Kurpius at (415) 947

- 4 5 34

.

Since rely,

/s/

Matthew Lakin, Manager Air Quality Analysis Office

Enclosure s : A. Annual Air Monitoring Network Plan Checklist

B. Elements where EPA is Not Taking Action

C. Elements Related to CARB Sites in Local Agency Plans W here EPA i s N ot Taking A ction

D. Additional Detailed Comments

E. Elements Not Represented in Any 2012 Annual Network Plans

cc: Ken Stroud, CARB Mike Miguel, CARBAttachment B : Annual Air Monitoring Network Plan Items where EPA is N ot Taking Action

We are not acting on the porti ons 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.

 System modifications (e.g., site closures or moves) are subject to approval per 40 CFR 58.14(c). Information provided in the plan was insufficient for EPA to approve the system modifications listed in the plan per the applicable requirement. Therefo re, we are not acting on the following items as part of this year’s annual network plan:

o Chico site relocation

o Placerville site relocation

o Fresno

- 1 st Street site relocation

o Discontinuation of PM10 at Mojave

- Poole

o Discontinuation of PM10 at Canebrake

o Discontinuation of ozone at Truckee

o Discontinuation of NOx at Grass Valley

o Fort Bragg site relocation

 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 whet her 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

(Attachment A) Issue

PM2.5 sampling schedule 45 Not meeting requirement

PM2.5 and PM10 co

- location 32, 34 Not meeting requirement

Method code for each monitor 37 Not meeting requirement Instrument parameter code 42 Not meeting requirement Sampling season for ozone

– waivers not submitted 44 Not meeting requirement

Sampling schedule for PM10 46 Insufficient to judge Instrument monitor type 39 Insufficient to judge

PM co

- location distance 33 Insufficient to judge

Residence time 73 Not meeting requirement for 3 cases Probe height 65 Not meeting requirement in 3 cases

Distance from trees 69 Not meeting requirement in 2 cases

Probe material 72 Insufficient to judge Distance from supporting

structures 66 Insufficient to judge

Distance from obstructions on

roof 67 Insufficient to judgeDistance to furnace or

incinerator flue 70 Insufficient to judge

Start date for each monitor 38 Not meeting requirement Monitoring objective for each

instrument 40 Not meeting requirement

Additional information for each of these items is in included in Attachment A.Attachment C : Elements Re lated to CARB Sites in Local A gency Plans where EPA is N ot Taking

A cti on

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.

 System modifications (e.g., site closures or moves) are subject to approval per 40 CFR58.14(c). Information provided in the plan was in sufficient for EPA to approve the following system modification listed in the plan per the applicable requirement: relocation of the Calexico Ethel SLAMS site. Therefore, we are not taking action on this item as part of this year’s annual network plan.

 EPA identified items related to CARB sites in annual network plan submitted by local agencies 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 ass ociated appendices. Therefore, we are not acting on the following items:

Item Checklist Row

(Attachment A) Issue

Distance from trees Imperial 69 Not meeting requirement in one instance

PM 2.5 sampling frequency Imperial 45 Insufficient information to judge

PM 10 sampling frequency Imperial 46 Insufficient information to judge Scale of representation Imperial 16 Insufficient information to judge

PM 2.5 collocation /Operating

schedule Imperial 32 /14 Insufficient information to judge

Date of last two semi

- annual

PM flow audits Imperial 30 Insufficient information to judge

Distance between collocated

monitors Imperial 33 Insufficient information to judge

Distance from obstructions not

on roof Imperial 68 Insufficient information to judge

Distance f

rom furnace or

incinerator flue Imperial 70 Insufficient information to judge

Parameter code Imperial 42 Insufficient information to judge Site type Imperial 41 Insufficient information to judge in some

instances

Method code Imperial 37 Insufficient information to judge Monitoring objective Imperial 40 Insufficient information to judge Monitor type Imperial 39 Insufficient information to judge in some

instances Statement of purpose Imperial 2 Insufficient information to judge

Pb collocation Imperial 35 Insufficient information to judge Designation of Pb monitors as Imperial 16 Insufficient information to judgesource

- oriented

Date of last two semi

- annual

Pb flow audits Imperial 31 Insufficient information to judge

Sampling Schedule for PM 2.5 Sacramento 45 Insufficient information to judge Sampling Schedule for PM 10 Sacramento 46 Insufficient information to judge

PM 2.5 expected maximum

concentration site identified as population exposure Sacramento 55 Insufficient information to judge

Site type for each instrument Sacramento 41 Insufficient information to judge Monitoring objective for each

instrument Sacramento 40 Insufficient information to judge

Date of last Annual

Performance Evaluation (gaseous) Sacramento 29 Insufficient information to judge in some

instances

Dates of last two semi

- annual

flow rate audits for PM

monitors Sacramento 30 Insufficient information to judge in some

instances

Scale of representativeness for

each monitor Sacramento 16 Insufficient information to judge in some

instances Frequency of flow rate

verification for manual and automated PM samplers audit Santa Barbara

25

- 26 Insufficient information to judge for CARB

sites within the Santa Barbara County APCD annual network plan Frequency of one

- point QC check (gaseous) Santa Barbara

28 Insufficient information to judge for CARB

sites within the Santa Barbara County APCD annual network plan

Date of last Annual

Performance Evaluation (gaseous) Santa Barbara

29 Insufficient information to judge for CARB

sites within the Santa Barbara County APCD annual network plan

Dates of last two semi

- annual

flow rate audits for PM

monitors Santa Barbara

30 Insufficient information to judge for CARB

sites within the Santa Barbara County APCD annual network plan

S cale of representativeness San Luis Obispo

62 Insufficient information to judge for Paso

Robles site.

In addition, the following comments were made in EPA’s Sacramento Metro AQMD annual network plan approval letter :

 The site description on page 53 lists the Sacramento

- T Street site as middle scale for all pollutants. Please clarify why this is the case, or change the site description and spatial scales as appropriate.

 The PM 2.5 speciation monitor at the Sacramento

- T Street site is listed as an SPM ( Appe ndix B, page 55 ), but EPA’s website list s this as a CSN site . Please clarify this in your 2013 network plan.Attachment D : 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

agr eement 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.

 [Item 2] Statement of Purpose for Each Monitor: The purpose listed in Appendix D does not match Table 3. It appears that “purpose” in Appendix D is actually monitor type (see item 39).

 [Item 9] There are no requirements for NO2 area

- wide or RA40 monitors in the areas represented in the plan for small districts. It would be useful to add a statement in the plan

similar to that for NO2 near

- road on p. 22 of plan that indicates that there are also no requirements for NO2 area

- wide or RA40.

 [Item 16] Scale of representati veness for each monitor as defined in Appendix D:

o Scale is provided in Section 4, Table 4 and also in Appendix D. The information in Appendix D is incomplete.

o Based on the road distance/count at both the Barstow and Roseville sites, neither can be

conside red a neighborhood scale site for ozone (see 40 CFR 58, Appendix E, Table E

- 1). Both should be changed to a middle scale sites and removed from the minimum monitoring requirements.

 [Item 18] MSA: Since this ANP covers much of the State, it would be helpfu l if the paragraph in

Section 3 on MSAs listed all the MSAs in the State and then referenced which ones were addressed in this plan. It would also be very helpful to identify any areas in the plan that are not part of a Metropolitan Statistical Area

– othe rwise the minimum monitoring requirement tables create the perception that some areas covered in the plan were left off when in fact they are simply not in a Metropolitan Statistical Area. This can be figured out from Table 3

, but a simple listing in the t ext in Section 3 would add a lot of clarity.

 [Items 25 and 25] Flow rate verification for PM samplers: Does CARB do the flow rate audits for all the local districts? If not, how is it verified that these are being done on the schedule listed in the plan? Please clarify how this information is verified if it is not directly obtained by CARB.

 [Item 28] Frequency of one

- point QC check (gaseous): The plan indicates that all gaseous monitors have precision checks every two weeks. It would be surprising if this was universal among all sites in the plan since many agencies conduct automated nightly checks. Is it verified that these are done at this frequency?

 [Items 32 and 34] It would be helpful to list the PM2.5 and PM10 co

- located sites. [Item 42] Site type:

o Something similar to site type is provided, although it is labeled as “Federal Monitoring Purpose.” While many of the Federal site types are provided, the list is not complete. Please either replace “Federal Monitoring Purpose” with “Site Type” (as defin ed in 40 CFR 58, App. D 1.1.1) and add the additional categories (in particular, “population exposure” is an important site type that is not included) or add a note that “Federal Monitoring Purpose” is equivalent to “Site Type” and add the additional categ ories to the “Monitoring Purpose.”

o The relationship between Federal Monitoring Purposes for Tables 3 and 4 is unclear. The purposes listed do not match. In addition, the codes do not always match between the plans (e.g., Chico is not listed as “High Concen tration” in both Tables).

 [Item 43] The following sites listed multiple instruments of the same parameter under the same

POC:

o Lancaster PM10

o Trona PM10

o PM2.5 at Grass Valley (if the BAM is non

- regulatory this is ok)

o PM2.5 at Truckee

o PM2.5 at Portola (if the BAM is non

- regulatory this is ok)

 [Item 49] Minimum monitoring requirements for ozone should not include any ozone sites that do not meet traffic count/distance requirements to be considered neighborhood scale (see 40 CFR 58, Appendix E, Table E

- 1) (i .e., Lancaster, Barstow, and Roseville

– N. Sunrise)

.

 [Item 54] Required PM2.5 sites represent community

- wide air quality: Numerous sites are listed as neighborhood scale (i.e., representing community

- level air quality) and “Gnrl” which is population repr esentation. Further, all areas in the plan have more than the required number of total PM2.5 instruments and so presumably this requirement is being met. However it cannot be determined which sites are considered required and it would be helpful for future plans to

address this.

 [Item 55] For PM2.5, is at least one site in a population

- oriented area of expected maximum

concentration ?: This requirement is per MSA and this plan does not include all information from

each MSA

, so this review is not comprehensi ve. Based on the review of the information in this plan

, one site was identified that should be labeled as high (or max.) concentration: Chico (060070002). EPA’s review did not identify any additional issues.

 [Item 59] The areas represented in the plan do not include any STN sites. It would be helpful to

state this.

 [Item 61] The areas represented in the plan do not include any PM10

- 2.5 sites. It would be helpful to state this.

 [Item 62] Distance of site from nearest road:

o Lancaster, Barstow, and Rosevil le

– N. Sunrise are too close for the ozone monitors to beconsidered neighborhood scale. Lancaster is listed appropriately as middle scale but

Barstow and Roseville

– N. Sunrise need to be changed. All should be removed from the minimum monitoring counts.

o West Sacramento

- 15 th St: distance to road listed as 3500m

– please double

- check this.

 [Item 64] Many of the detailed site reports list “roof” as the groundcover. A roof is not typically considered a groundcover. Please provide a description of the groundcover adjacent to the building on which the monitors are placed.Attachment E

. Elements N ot R epresented in A ny 2012 California A nnual N etwork P lans

[Item s 49

- 50] Minimum ozone monitoring requirements for the Bakersfield MSA. T he ozone monitoring site at Arvin

- Bear Mountain Boulevard was forced to close in October 2010 due to the loss of the lease. Historically, that site measured the highest ozone concentrations in the San Joaquin Valley. Because ozone concentrations measured at C ARB's new Arvin

- DiGiorgio site are significantly lower than those measured at Arvin

- Bear Mountain, this new site may not constitute an approvable, adequate replacement site under applicable Federal regulations (40 CFR 58.14). The lack of a representati ve replacement design value ozone site in SJV could jeopardize our ability to make determinations of whether there were NAAQS violations (e.g. clean data findings or redesignations to attainment).

[Item s 4

- 5] Modifications to SLAMS network: Network modifi cations are subject to the requirements of 40 CFR § 58.14 and require approval by EPA

. EPA and CARB have established a process for proceeding with site closures and relocations in a way that avoids data completeness problems

. Fo llowing this process is critical for all site changes, especially for

closures of high concentration sites, crucial in determining compliance with the NAAQS

. Also,

the State of California’s Air Monitoring Technical Advisory Committee (AMTAC) document

“Site Relocation and Parallel Monitoring Guidelines” (June 1997) may inform the process for these system modifications. Ongoing network modifications , including recent actions in the San Joaquin Valley , should follow the process established by EPA and CARB.

[Item 58] Background and t ransport PM2.5 sites: This requirement applies to the entire state. The universe of sites provided in this plan does not include PM2.5 background or transport sites but they likely exist elsewhere in the state. A state

- level overview is necessary to addres s state

- level requirements.

The following topics are addressed i n most plans but would benefit from a state

- level overview since the requirements either apply at the state level or involve multiple jurisdictions:

 Minimum monitoring requirements

 Co

- locatio n requirements

 NCore requirements

 STN requirements

 Transport and background sites