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 

Santa Fe, NM 87505 

Dear Mr. Goodyear: 

FEB 1 9 2014 

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

2013 Annual Monitoring Network Plan. The U.S. Environmental Protection Agency (EPA) has 

completed its analysis of the NMED's 2013 Annual Monitoring Network Plan to ensure it meets those 

requirements of 40 CFR Part 58 and its appendices that confer approval authority on the Regional 

Administrator, now delegated to the Associate Director for Air. 

We appreciate your cooperation and work to submit your 2013 network plan. The network assessment 

process presents an opportunity for the EPA and the NMED to collaborate on the 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 your 2013 ambient air monitoring network plan is approved in 

accordance with 40 CFR §58.1 0. Details regarding our review of your air monitoring network are 

provided in the enclosure. 

We look forward to our continued collaborative work with the NMED on your 2014 ambient air 

monitoring network plan. If you have any questions, please contact me at (214) 665-3102, or your staff 

may contact Ms. Maria Martinez, Air Quality Analysis Section Chief, of my staff at (214) 665-2230. 

Enclosure 

cc: Rita Bates, Chief, Planning Section 

Sincerely yours, 

Thomas H. Diggs 

Associate Director for Air 

New Mexico Environment Department (with Enclosure) 

Recycled/Recyclable • Printed wHh Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer) 
New Mexico Environment Department (NMED) 

2013 Annual Ambient Air Monitoring Network Plan Technical Comments 

The Environmental Protection Agency (EPA) has reviewed your 2013 Annual Ambient Air Monitoring 

Network Plan and our comments are provided below. In addition to the network plan, EPA's review 

includes additional information provided by NMED. In order to reconcile all proposed network changes 

and as required by 40 CFR 58.14, system modifications need to be submitted to EPA in writing for 

approval. NMED will need to formally submit the network changes for all items marked below as 

· "Confirmation Needed" in this document. 

Monitor Approvals 

The request to discontinue the 0 3 monitors at the 7E Deming Airport site (Air Quality System, AQS 

#35-029-0003) and the 7T Hurley Smelter site (AQS #35-017-1003) are approved due to historical low 

concentrations of the 0 3 data. The discontinuance of the 0 3 monitors will not compromise the data 

collection needed for implementation of the 03 National Ambient Air Quality Standards (NAAQS) and 

the 40 CFR Part 58, App. D ambient air monitoring requirements. 

Network Evaluation- Confirmation Needed 

BP A recommends that NMED proceed on the following actions that NMED has indicated it wants to 

pursue: 

• The use of a Special Purpose Monitor (SPM) classification for the 03 monitor at the 2ZJ 

Bernalillo site (AQS #35-043-1001). 

• The discontinuation for 03 monitoring at the 5ZS Hobbs Jefferson site (AQS #35-025-0008). 

The Hobbs Jefferson 0 3 monitor is not required nor is it needed to continue since the 5ZR 

Carlsbad site (AQS #35-015-1005) 0 3 monitor covers the southeast New Mexico area. 

Recommendation 

The continued operation of the 03 monitor at the 2LL Los Lunas site (AQS #35-061-0008) is not 

required to meet minimum network requirements. In EPA's preliminary review of the monitoring data, it 

appears that the discontinuance of the 0 3 monitor at the Los Lunas site would not compromise the data 

collection needed for implementation of the 03 NAAQS and the 40 CFR Part 58, App. D ambient air 

monitoring requirements. NMED may want to re-evaluate the appropriateness of the 0 3 monitor to 

ensure optimal use of resources. Please provide the monitoring data analysis and a rationale for either 

continued operation or decommissioning of the 0 3 monitor at the Los Lunas site. Any request for a 

system modification under 40 CFR § 58.14(c) should be submitted to EPA Region 6 for concurrence. 

Particulate Matter (PM): 

PMz.s Monitor Approvals 

Since 2007, several ofNMED's PM25 monitors have been collecting ambient concentrations below the 

NAAQS. For the continuous PMz.s network, NMED proposes to discontinue the tapered element 

oscillating microbalance (TEOM) samplers at 3HM Santa Fe Runnels (AQS #35-049-0020), Hobbs 

Jefferson, Carlsbad, 1NL Navajo Lake (AQS #35-045-0018) and Los Lunas sites. For the Federal 

Reference Method (FRM) PMz.s network, NMED proposes to discontinue the FRM samplers at the 
Santa Fe Runnels site due to historically low concentrations. The requests to discontinue the PMz.s 

monitors are approved due to historically low concentrations. We conclude that the discontinuance of 

the PM2.s monitors will not compromise the data collection needed for implementation of the PMz.s 

NAAQS and the 40 CFR Part 58, App. D ambient air monitoring requirements. 

PM2.5 Network Evaluation- Confirmation Needed 

EPA recommends that NMED proceed on the following actions that NMED has indicated it wants to 

pursue: 

• The discontinuation ofPM2.5 monitoring at the lFO Farmington site (AQS #35-045-0019). 

• The relocation and operation of the PMz.s equipment from the Farmington site to the lZB 

Bloomfield site (AQS #35-045-0009). 

• The addition ofPM2_5 monitoring as an SPM at the 2ZJ Bernalillo site. 

• The operation of an existing beta attenuation monitor (BAM) 1020 for PM2.s monitoring as an 

SPM at the Hobbs Jefferson site. It is our understanding that the BAM 1020 has been operating 

at this site. 

• The discontinuation of the PM25 TEOM sampler at the 6CM Anthony site (AQS #35-013-0016). 

• The discontinuation of the PM25 TEOM sampler at the 6ZN Santa Teresa site (AQS #35-013-

0022). 

PM2.s Recommendation 

NMED plans to discontinue the PMz.s TEOM and operate a PMz.s BAM 1020 at the Hobbs Jefferson 

site. In EPA's preliminary review of the monitoring data, it appears that the discontinuance of the PMz.s 

FRM monitor at the Hobbs Jefferson site will not compromise the data collection needed for 

implementation of the PMz.s NAAQS and the 40 CFR Part 58, App. D ambient air monitoring 

requirements. The PMz.s FRM at the Hobbs Jefferson site has historically reported low values. The 2012 

annual design value (DV) is 7.6 micrograms per cubic meter (!-lg/m3

) and the 2012 24-hour DV is 

17!-lg/m3

• The 2012 design values are not exceeding 80% of the PM2.5.annual and 24-hour NAAQS of 

1211g/m3 and 35!-lg/m3

, respectively. NMED may want to re-evaluate the appropriateness of the PM25 

FRM monitor to ensure optimal use of resources. Please provide the monitoring data analysis and a 

rationale for either continued operation or decommissioning of the PM2.s FRM monitor at the Hobbs 

Jefferson site. Any request for a system modification under 40 CFR § 58.14(c) should be submitted to 

EPA Region 6 for concurrence. 

PM10 Monitor Approvals 

The request to discontinue the PM10 monitors at the Hurley Smelter, Santa Fe Runnels and 3ZD Taos 

(AQS #35"-055-0005) sites is approved due to historically low concentrations. The discontinuance of the 

PM10 monitors will not compromise the data collection needed for implementation of the PM10 NAAQS 

and the 40 CFR Part 58, App. D ambient air monitoring requirements. 

The request to discontinue the collocated PMw monitors at the the7D Deming site (AQS#35-029-0001) 

is approved. There are two PM10 ambient air monitoring sites in the Deming micropolitan statistical area 

with the Deming and Deming Airport sites operating within a 3 mile radius. According to the 2012 US 

Census population estimates, the Deming micropolitan statistical area is approximately 25,041. The 

discontinuance of the collocated PM10 monitors will not compromise the data collection needed for 

implementation of the PM10 NAAQS and the 40 CFR Part 58, App. D ambient air monitoring 
requirements. EPA supports the continued operation of the PM10 monitor at the Deming Airport site to 

cover the area. 

It is our understanding that on September 20, 2013, the PM10 TEOM sampler at the 6WM West Mesa 

site (AQS #35-013-0024) failed. Subsequently, the PM2.s TEOM sampler from the Los Lunas site was 

relocated and operational at the West Mesa site on October 2, 2013 for PM10 monitoring as previously 

approved by EPA. Please include this change in the 2014 network plan. 

PM10 Collocation 

According to the network plan, NMED proposes to move PM10 monitoring collocation to the Sunland 

Park site (AQS #35-013-0017). Please note that collocation for the PM10 manual method is not required 

to be the same method. This means that a continuous monitor operated in conjunction with the manual 

method (FRM) meets the collocation requirement. See 40 CPR 58, App. A, 3.3.l(b). Based on the 

network plan, NMED will have a maximum of five PM10 FRM manual sites; therefore, NMED is 

required to have only one site for collocation. NMED operates an FRM manual monitor and TEOM 

continuous monitor at the Anthony site to meet the 15% cpllocation requirements of 40 CPR Part 58, 

App. D, 3.3.1. Therefore, an additional PM10 collocation site is not required and not necessary at the 

Sunland Park site. 

In addition, the collocation for PM10 is only required for manual methods (FRM). Collocation is not 

required for PM10 continuous monitoring which includes the BAM 1020 so please do not operate two 

PM10 BAM 1020s at one site. 

PM1o Network Evaluation- Conf"rrmation Needed 

EPA recommends that NMED proceed on the following actions that NMED has indicated it wants to 

pursue: 

• The discontinuation ofPM10 monitoring at the Farmington site. 

• The relocation and operation of the PM10 equipment from the Farmington site to the Bloomfield 

site as an SPM. 

• The discontinuation ofPM10 monitoring at the 2U Bernalillo site (AQS #35-043-0001). 

• The relocation and operation of the PM10 sequential FRM sampler from the 2U Bernalillo site to 

the 2ZJ Bernalillo site as an SPM. 

PM Conversion- Conf"rrmation Needed 

NMED outlines a conversion plan to begin shifting from sequential PM2.5 and PM10 FRM sampling and 

continuous TEOM PM10 monitors to continuous Federal Equivalent Method (FEM) sampling in 2013 

using the BAM 1 020 instruments. We cannot approve the entire network conversion at this time because 

of outstanding questions. Subsequent to the network plan submittal, NMED identified network changes 

and specific sites and equipment to upgrade to the BAM 1020 samplers. Please clarity the PM25 and 

PM10 sites NMED requests to upgrade before proceeding further. We appreciate the work and effort of 

the NMED to upgrade the PM network and look forward to your response. 

During the conversion process to the continuous network, we would prefer to see the existing PM2.

5 and 

PM10 FRMS sites' operated in conjunction with the BAM 1020s to verify data quality until the BAM 

1 020s are stabilized. Since the PM2.s BAM 1 020s are FEMs, any data collected with them needs to be 

reported as Parameter Code 88101 in AQS. 
Sunland Park site. (AQS #35-013-0017): 

According to the network plan, NMED proposes the following changes: 

• move the collocation sites for PM25 from the Farmington site to the Sunland Park site 

• move the collocation site for PM10 from the Deming site to the Sunland Park site 

• deploy and operate a BAM 1020 at the Sunland Park site for PM2.s monitoring 

• discontinuation of the PM25 TEOM at the Sunland Park site. 

During the June 2012 Technical Systems Audit (TSA), EPA informed NMED of siting issues for the 

Sunland Park site and documented the review in the TSA report dated December 5, 2012. Since the 

TSA, EPA has been working with NMED to address our concerns. On December 16, 2013, NMED 

provided a separate technical analysis that may affect the operational status of the Sunland Park site, the 

pollutants being monitored at the site (03, PM25 and PM10) and alternate sites for collocation and 

equipment changes. This may also affect NMED's operation of the Las Cruces site, 6ZM Desert View 

(AQS #35-013-0021) and PJYh.s monitoring at the Farmington site. At this time, EPA cannot approve the 

changes requested in the network plan for Sunland Park. We further recommend that no changes take 

place at the Las Cruces site, Desert View site and the PM2.s monitoring at the Farmington site until a 

resolution is reached on the future of the Sunland Park site. We look forward to working with NMED on 

the further evaluation of these potential changes. · 

Timeline: 

In order to reflect the timely implementation of network efficiencies, please propose a timeline of the 

approved changes for sites and monitors in the NMED network to the EPA Region 6 Air Quality 

Analysis Section Chief within 60 days of the receipt of this letter. Please include the "Confirmation 

Needed" information with the timeline.