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 201 2

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. 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 re views . 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 wher e information 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 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 acti ng 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 co mments 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 theenclosed comments, please feel free to contact me at ( 415) 972

- 3851 or Meredith Kurpius at

(415) 947

- 4 5 34

.

Sincerely,

/s/

Matthew Lakin, Manager Air Quality Analysis Office

Enclosure s : A. Annual Air M onitoring 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 BoardAttachment 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 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 approval . Per 40 CFR 58.11(c), NCore, PAMS, and STN network design and changes are subject to approval of the EPA Admin istrator and per 40 CFR 58.10(a)(5) plans for establishing NO 2 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 pe r 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 Lo ng 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 bein g 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 a cting on of the following items :

Item Checklist Row

(Attachment A) Issue

PM 10 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 source

oriented or non

- source

oriented 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 judgeIdentification 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 judgeSampling 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
Res idence 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 affec ted 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 jurisdic tion 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 actua lly 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 follow ing 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 sample r 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

the se 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 nu mbers. 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 wheth er the PM2.5FEMs 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 monito rs. 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 n etwork as
extensive as South Coast’s PM2.5 network.

 [Item 55]The CFR requires that f or PM2.5, there is at least one site in a population

oriented area of expected maximum concentration. It is assumed that sites listed in Table 3 as population exposure, hi gh 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 o ne 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 lis ted 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 repor t for Indio uses a colon instead of a period for the

measurement of the d istance from the supporting structure

– this is presumably a typo.

 Although EPA Region 9 is not taking action on the NO 2 portions of the plans this year, for next year, please identify sites fulfilling the NO 2 area

- wide and RA40 requirements.