UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX
75 Hawthorne Street San Francisco, CA 94105

March 1, 2013

Mr. Larry Greene

Air Pollution Control Officer

Sacramento Metro politan Air Quality Management District

777 12 th Street Sacramento, California 95814

Dear Mr. Greene :

Thank you for your submission of the Sacramento Metropolitan Air Quality Management
District’s ( SM AQMD’s) Annual Monitoring Network Plan in July 2012

. Based on the information provided in the plan, EPA approves all portions of the network plan except those specifically identified below.

Annual network plans are important documents for regulatory purposes (e.g., State Implementation Plans, designations and redesignations ) and public information, in addition to the myriad uses by the air districts. EPA is r evising the review process for annual network plans to specifically check and document the comprehensive set of items that are required to be included in the annual network plans per 40 CFR 58.10 in a consistent manner. We have created

a checklist that lis ts all these items and have included it as Attachment A. W hile the items in the checklist are required by EPA regulations , we acknowledge that we have not specifically requested some of this information in previous annual network plan reviews . We recognize that your plan may not have all the items that we have currently identified and hope to work with you on the inclusion of these items in future plans. To facilitate these changes, EPA has provided

detailed feedback in the checklist where inf ormation should be included or revised in next year’s plan.

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 infor mation , 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 portions of your agency ’s annual network plan listed in Attachment B.

In addition to the checklist and list of specific plan elements where EPA Region 9 is not taking

action

, enclosed are additional detailed comments on the plan (Attachment C ). All of the

comments in Attachments A , B, and C should be addressed in next year’s network plan. If youhave any questions regarding this letter or the enclosed comments, please feel free to contact me

at (415) 972

- 3851 or Kate Hoag at (415) 972

- 3970

.

Sincerely,

/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. Additional Detailed Comments

cc: Brigette Tollstrup, SMAQMD John Ching

, SM AQMD Karen Magliano, CARBAttachment B : Annual Air Monitoring Network P lan I tems where EPA is N ot Taking

Action

We are not acting on the portions of annual network plan s 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.

 NCore, PAMS, STN, and the plan for NO 2 monitoring require EPA Administrator

a pproval . Per 40 CFR 58.11(c), NCore, PAMS, and STN network design and changes are subject to approval of the EPA Administrator and per 40 CFR 58.10(a)(5) plans for establishing NO 2 monitoring sites are submitted to the EPA Administrator for action.

Therefo re, we are not acting on these items.

 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. Therefore, we are not acting on the following items as part of this year’s annual network plan :

o Discontinue non

- required speciated VOC measurement at Elk

- Grove

- Bruceville

Rd PAMS site ( fulfilled at Folsom and Sac

- Del Paso Manor)

o Del Paso Manor: PM 10 - Pb

o Del Paso Manor: Replace non

- FEM PM 2.5 w ith FEM PM 2.5 , move non

- FEM

PM 2.5 to Sloughhouse Rd

o Del Paso Manor: Shut down nephelometer from special study

o Evaluating closing Sacramento

– Goldenland Court, redundant for PAMS and not

the hi ghest for any criteria pollutant. Would still meet min monitoring req

o North Highlands

- Blackfoot way: evaluating shutting down PM 10 , changing to

seasonal for O 3 , CO

o Sacramento Health Dept

– Stockton Blvd: will submit a request to terminate

PM 10 TEOM (unus eable due to wintertime negative bias) and PM 2.5 FRM (redundant w Sacramento

- T S treet)

o Replace E

- BAM at sloughhouse SPM with non

- FEM BAM from Del Paso Manor

 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 whether the requirement was being met based on 40 CFR 58.10 and the associated appendices. Therefore, we are not acting on of the following items:

Item Checklist Row

(Attachment A) Issue

Instrument parameter code for

each instrument for PM 10 FRM/FEM 42 Not meeting requirement

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

PM 2.5 expected maximum

concentration site identified as population exposure 55 Insufficient information to judge

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

instrument 40 Insufficient information to judge

Distance from obstructions not

on roof 68 Insufficient information to judge in some

instances

Date of last Annual

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

instances

Dates of last two semi

- annual

flow rate audits for PM

monitors 30 Insufficient information to judge in some

instances

Dates of last two semi

- annual

flow rate audits for Pb

monitors 31 Insufficient information to judge in some

instances

Scale of representativeness for

each monitor 16 Insufficient informat ion to judge in some

instances Instrument/monitoring method

code for each monitor 37 Insufficient information to judge in some

instances Sampling Schedule for PM 10

- 2.5 48 Insufficient information to judge

Additional information for each of these items is in included in Attachment A.Attachment C : 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 requiremen ts among the various agencies to achieve an effective network design. Full monitoring requirements apply separately to each affected State or local agency in the absence of an agreement between the affected agencies and th e 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.

 When providing future plans for public comment, please include information (your agency’s submittal and EPA’s approval) pertaining to any modifications that were approved in the data year covered by the plan (e.g. 2012 changes for the plan submitted in 2012.)

 The plan notes that the requirement for an area

- wide NO 2 site per 40 CFR 58.10(a)(5) is met by one of the NO2 sites required for the PAMS network (page 14). In future plans, please clarify which of the two PAMS NO 2 sites is meeting this requirement.

 The site description on page 53 lists the Sacramento

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

 Sacramento

- Goldenland Court and Sacramento Health Dept

- Stockton Blvd sites both

have two PM 10 monitors. Please include the distance between the PM 10 monitors in the detailed site table, even if the monitor type for one is not “QA collocated”.

 Please update the description in the table on page 11 for the Sloughhouse Rd site to

match the information in the detailed site table on page 49

.

 The PM 2.5 speciation monitor at the Sacramento

- T Street site is listed as an SPM ( Appendix B, page 55 ), but EPA’s website list s this as a CSN site

. Please clarify this in your 2013 network plan.