UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX

75 Hawthorne Street San Francisco, CA 94105

November 1
, 2010

Mr. Scott Nester Planning Director San Joaquin Valley Air Pollution Control District 1990 E. Gettysburg Avenue Fresno, CA 93726

- 0244

Dear Mr. Nester:

Thank you for your submission of San Joaquin Valley Unified Air Pollution Control
District’s (SJVUAPCD) 2009 Ambient Air Monitoring Network Plan. We have reviewed the submitted document and have found that it meets the minimum requirements set forth under 40 CFR Part 58.10. While this letter serves as official approval of the annual network plan, it does not constitute approval of the system modifications that are proposed in the plan for the future. We will continue to work with your district to review system changes as they proceed.

We also want to thank you for your timely submission of the SJVUAPCD’s 2010 Monitoring Network Assessment Report, as required under 40 CFR Part 58.10. We recognize that preparing the network assessment was a significant project and we appreciate your effort. We plan on providing feedback to all agencies on network assessme nts during the winter 2011.

Enclosed, please find our comments on the plan. If you have 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

Air Division

Enclosure

cc: Jaime Contreas, SJVUAPCDComments on 2009 Data Year Network Plan for San Joaquin Valley Unified APC D

Please update next year’s annual network plan to reflect the following comments:

1. Table 7 on Page 17 lists the PAMS sites in the SJV. In your next network plan, please

confirm whether there was a Type 2 (maximum precursor emissions) site operating in the Bakersfield MSA during the 2010 ozone season.

2. Given the listed population and concentration of PM 10 for the Merced MSA in Table 10 (page 20), the required number of monitors sho uld be 0

- 1, rather than 0. See 40 CFR Part 58, Appendix D.

3. Non

- FEM BAMs , SPMs, or other non

- regulatory monitors should not be classified as SLAMS monitors nor counted toward meeting minimum monitoring requirements (Table 10). See 40 CFR Part 58, Appendix D.

4. Please ensure that only FRM and FEM monitors with an objective of standards comparison are counted towards fulfilling the monitoring requirements in T able 10 , as per 40 CFR Part 58, Appendix D

. For example, the PM 2.5 monitors in Clovis, Corcoran,

Tur lock and Tranquility, and the PM 10 monitors in Bakersfield

- Muni, Madera and Tracy appear to be needed to produc e the total number of monitors in T able 10, but their objective is listed a s “timely/public” only.

5. Please ensure that the numbers of PM 2.5 mo nitors are consistent between T ables 10 and

11 for the Hanford/Corcoran and Madera MSAs.

6. Please clarify which samplers in T ables 11 and 12 are non

- FEMs and which are FEMs.

7. Table 11 lists the Monitoring Objective as only “Timely/public” for the PM 2.5 and PM 10 FEM

- BAMs and the PM 10 TEOM s . If monitors designated as SLAMS are FRM/FEM monitor types and meet siting requirements, the data produced is considered comparable to the NAAQS . In a memo dated July 24, 2008 , EPA has provided technical guidance on impleme nting continuous PM 2.5 FEM monitors as SLAMS. This memo stated that agencies can operate a continuous FEM particulate monitor alongside a filter

- based FRM

as an SPM for the purposes of evaluating the method for a tr ia l period during which the

data need no t be included for design value calculations . Th e field evaluation period generally lasts 12 months, however, up to 24 months is allowed. Also, the primary filter

based FRM must remain operational at the site for the entire evaluation period. A ny continu ous FEM particulate SPMs that have operated longer than 24 months are comparable to the NAAQS. Please revise the Monitoring Objectives in Table 12 as necessary to reflect this. The memo described above can be found at : http://www.epa.gov/ttn/airs/airsaqs/memos/Use%20of%20PM2.5%20FEMS%20and%20 ARMs%20in%20SLAMS%20Network.pdf

. 8. Page 27 outlines the PM collocation requirements that apply t o PQAOs. Table 11 on page 23 lists the PM 10 FRM at Corcoran as being collocated , but the detailed site information tables in Appendix B for Corcoran and other monitors are unclear about what monitor pairs are collocated. Please specifically state which PM 2.5 or PM 10 sites in the

SJVUAPCD are meeting a collocation requirement , and change the monitor type in Appendix B to “QA Collocated” rather than SLAMS

. 9. The general process for soliciting public comments on the Annual Monitoring Network

Plan is described o n page 28. For future plans, please also submit the specific dates of the public comment period and specify whether or not any comments were received. See

40 CFR Part 58.1010. Pages 28 and 34 discuss that the district is evaluating discontinuing CO monitor ing at the

Fresno

- Drummond, Fresno

- Skypark and Turlock sites. Since EPA is currently reviewing the CO NAAQS, please consider as part of your evaluation that the CO monitoring requirements may change

. 11. Page 30 states that there are no required monitors for SO 2 to comply with Appendix D. In future network plans, please revise this section to reflect changed requirements due to the recent NAAQS revisions.

12. The discussion of approved PM 10

- 2.5 monitoring methods for NCore on page 32 should be updated . See the we bsite at http://www.epa.gov/ttnamti1/files/ambient/criteria/reference

equivalent

- methods

- list.pdf for information about approved PM 10

- 2.5 reference and equivalent methods.

13. Page 34 states that with the addition of the Porterville and Manteca sites all monitoring requirements are met. Please clarify which pollutant requirements are being met by each

site and when these sites will be operational.

14. Proposed Changes (pages 37

- 40)

a. W hen the District has completed its evaluation of all proposed changes, please submit any request with the appropriate documentation to EPA Region 9 for approval.

b. Please confirm whether or not the Bakersfield

- Mun i site, replacing the

Bakersfield

- Golden site, will have the same monitors that were located at the

Golden site.

c. The FEM

- Bam at Tranquility is discussed on page 37 as an SPM for research purposes, not regulatory purposes. EPA allows for FEMs to be run on a test basis for 24 months. After that amount of time, the data from this monitor may be considered comparable to the NAAQS. See comment 7 above for details.

15. Monitoring Site Descriptions

– Appendix A

a. Page A

- 3 discusses the temporary relocation of Hanfor d monitoring instruments

to Corcoran. Please state in next year’s plan if the PM 10 monitor was returned to

Hanford or if it remains at Corcoran, and specify what time periods each

instrument was operated at each location

. b. The Ash Mountain site description on page A

- 12 does not include the FRM PM2.5 monitor listed in Table 12 on page 26. Also, please clarify why the NPS

PM 2.5 FRM at Ash Mountain is not comparable to the NAAQS.

c. Page A

- 11: Please confirm whether SJVUAPCD or CARB operates the Visalia

Church site.

16. Detailed Site Information

– Appendix B Some of the detailed site information tables are incomplete. For future network plans,

p lease ensure that tables are completely filled out for every site. Also, please include all applicable information for ea ch monitor and add the following information to the table

for every monitor , as per 40 CFR Part 58 :

a. Monitor type (SLAMS/SPM /QA Collocated etc.) for all monitors including NO 2 and CO monitors.

b. List FRM/FEM/non

- FEM and method code for particulate monitors.

c. List POC for each monitor or indicate which monitor is the primary monitor for

sites with more than one PM 2.5 or PM 10 monitor.

d. Will there by changes within the next 18 months? (Y/N)