UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

April 18, 2013

Dr. Matt Miyasato, Deputy Executive Officer 

Science and Technology Advancement 

South Coast Air Quality Management District 

21865 Copley Drive 

Diamond Bar, California 91765-4178 

Dear Dr. Miyasato:

Thank you for your submission of the South Coast Air Quality Management District’s 2012

Annual Air Quality 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 revising 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 lists all these items and have included it as Attachment A. While 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 information should be included or revised in next year’s 

plan.

Please note that we cannot approve portions of the 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 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 either in a resubmitted 2012 network 

plan or in next year’s network plan. 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) 947-4534.

Sincerely,

/s/

Matthew Lakin, Manager

Air Quality Analysis Office

Enclosures:

A. Annual Air Monitoring Network Plan Checklist

B. Elements where EPA is Not Taking Action

C. Additional Detailed Comments

cc: Jason Low, South Coast Air Quality Management District

Rene Burmudez, South Coast Air Quality Management District

Karen Magliano, California Air Resources Board
Attachment B: Annual Air Monitoring Network Plan Items where EPA is Not Taking 

Action

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 information in the plan is insufficient to judge 

whether the requirement has been met.

 NCore, PAMS, STN, and the plan for NO2 monitoring require EPA Administrator 

approval. 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 NO2 monitoring sites are submitted to the EPA Administrator for action.

Therefore, 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 

following system modifications listed in the plan per the applicable requirement: near 

road NO2 monitoring site selection, Van Nuys Pb Airport closure, and South Long Beach 

relocation. Therefore, we are not acting on these items as part of this year’s annual 

network plan.

 EPA identified items in your agency’s annual network plan where information in the plan 

was insufficient to judge whether the requirement was being met based on 40 CFR 58.10 and 

the associated appendices. However, this lack of information may be addressed later, and 

does not necessarily reflect upon the adequacy of the air monitoring network to perform its 

required functions. Therefore, we are not acting on of the following items:

Item Checklist Row 

(Attachment A) Issue

PM10 expected maximum 

concentration site

60 Insufficient information to judge for 

Coachella Valley Air Basin

Distance from trees 69 Insufficient information to judge for some 

cases

Pb site for 0.5-1.0 tpy sources 8 Insufficient information to judge

Designation of any Pb 

monitors as either sourceoriented or non-sourceoriented

19 Insufficient information to judge

Instrument/monitoring method 

code for each monitor

37 Insufficient information to judge

Instrument parameter code for 

each instrument

42 Insufficient information to judge

Scale of representativeness 16 Insufficient information to judge

Sampling schedule for PM2.5 45 Insufficient information to judge for some 

cases

PM2.5 co-location 32 Insufficient information to judge
Identification of sites suitable 

and sites not suitable for 

comparison to the annual 

PM2.5 NAAQS

17 Insufficient information to judge for some 

monitors

Frequency of one-point flow 

rate verification for Pb 

samplers audit

27 Insufficient information to judge for some 

sites

Annual data certification 

submitted

24 Insufficient information to judge

Site type for each instrument 41 Insufficient information to judge

Sampling schedule for PM10 46 Insufficient information to judge

Distance of site from nearest 

road

62 Insufficient information to judge for some 

cases

Traffic count of nearest road 63 Insufficient information to judge for some 

cases

Distance from obstructions not 

on roof

68 Insufficient information to judge for some 

cases

Pb co-location 35 Insufficient information to judge for highest 

site

Distance between co-located 

monitors

33 Insufficient information to judge for some 

sites

Monitoring objective for each 

instrument

40 Insufficient information to judge

Instrument monitor type for 

each monitor

39 Insufficient information to judge

Frequency of flow rate 

verification for manual PM 

samplers audit

25 Insufficient information to judge for one site

Dates of last two semi-annual 

flow rate audits for PM 

monitors

30 Insufficient information to judge for a few 

sites

Dates of last two semi-annual 

flow rate audits for Pb 

monitors

31 Insufficient information to judge for a few 

sites

Instrument parameter 

occurrence code for each 

instrument

43 Insufficient information to judge for a few 

cases

Document how states and 

local agencies provide for the 

review of changes to a PM2.5 

monitoring network that 

impact the location of a 

violating PM2.5 monitor.

22 Insufficient information to judge

Precision/Accuracy reports 

submitted to AQS

23 Insufficient information to judge
Sampling schedule for PM10-

2.5

48 Insufficient information to judge

Minimum monitoring 

requirements met for PM10-

2.5 mass

61 Insufficient information to judge

Probe height 65 Insufficient information to judge for one 

case

Unrestricted airflow 71 Insufficient information to judge for one 

case

Probe material (if applicable) 72 Insufficient information to judge for one 

case

Residence time (if applicable) 73 Insufficient information to judge for one 

case

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 

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 agreement 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] It would be helpful to clarify the Statement of Purpose for each monitor (item 

#2). Tables 3-4 have a heading that indicates that the information includes “Monitoring 

Purpose.” The information that is given is actually site type. The site type could be used 

with the monitoring objective to define the Statement of Purpose but the current network 

plan conflates these various terms, which have specific CFR definitions (see EPA’s May 

2012 ANP memo).

 [Item 13] The following errors were identified for sampling and analysis method(s):

o Lake Elsinore: Start date listed for analysis method for NO2.

o Reseda: Analysis method for PM2.5 non-FEM BAM should be "beta attenuation" 

- see Riverside – Magnolia

o W. LA: There is a TSP sampler that is listed as "Tisch" for 

instrument/manufacturer/model and ICPMS for analysis method - is this Pb? It is 

not clear what pollutant is being measured due to the incomplete pollutant 

description and sampling and analysis method information.

 [Item 18] Identification as an area as an MSA (versus CSA or other) was missing for the 

following sites: ATSF, Closet World (Quemetco), Long Beach (North), Rehrig, 

Uddeholm, Upland

 [Item 38] Start date is missing for some parameters at the Long Beach (North) site.

 [Items 49 and 53] For ozone and PM2.5, the minimum monitoring requirements are 

based on the design value site’s proximity to the NAAQS. It would be helpful for the 

plan to include the design value site, along with the current design value, for each of 

these pollutants.

 [Item 49] Ozone monitors that are middle and micro-scale sites due to proximity to 

roadways (i.e., LAX Hastings, Pomona, and West LA) are not suitable for comparison to 

the NAAQS and should therefore not be included in minimum monitoring numbers. 

Please note this in the ozone minimum monitoring tables and in the detailed site tables.

 [Item 53] PM2.5 minimum monitoring requirements are listed per PQAO but these are 

specified in the CFR to be per MSA – please correct this. It is unclear whether the PM2.5 
FEMs are being operated as primary monitors or as solely additional monitors where 

FRMs are being operated. Due to this, it is difficult to crosswalk between minimum 

monitoring requirements and numbers of filter-based and continuous FEM monitors. It 

would be helpful to have a table that combines some of the information from Tables 3 

and 4 that focuses solely on PM2.5. Adding sampling frequency to such a table, along 

with the officially co-located monitors would also be extremely helpful for a network as 

extensive as South Coast’s PM2.5 network.

 [Item 55]The CFR requires that for PM2.5, there is at least one site in a populationoriented area of expected maximum concentration. It is assumed that sites listed in Table 

3 as population exposure, high concentration sites are intended to meet this requirement. 

Please review this list to ensure that this is the intention of your agency

 [Item 56] The CFR requires that If >1 SLAMS PM2.5 is required, there is a site in an 

area of poor air quality. In the current plan, EPA has determined that all of the South 

Coast Air Basin is in non-attainment for PM2.5 so most of the sites are in an area of poor 

air quality. It would be useful for future plans to include a statement to this effect.

 [Item 57] There is one co-located BAM (it’s not specified whether it’s FEM or not) listed 

in Table 4. The table for continuous PM2.5 monitoring (page 15) lists one non-FEM 

BAM for co-location. It is not clear what the footnotes mean. Continuous monitors are 

required to be co-located with both FRM and other FEM samplers and must consider 

method codes.

 [Item 59] It would be useful for official CSN sites (i.e., Rubidoux and LA North Main) to 

be identified in future annual network plans.

 [Item 60] The number of PM10 monitors listed in the PM10 minimum monitor table 

(page 14) has a total of 21 monitors listed when SCAQMD operates 25. This should be 

corrected in future plans.

 [Item 66] The detailed site report for Indio uses a colon instead of a period for the 

measurement of the distance from the supporting structure – this is presumably a typo.

 Although EPA Region 9 is not taking action on the NO2 portions of the plans this year, 

for next year, please identify sites fulfilling the NO2 area-wide and RA40 requirements.