ssosr42UNITEDSTATESENVIRONMENTALPROTECTIONAGENCYREGIONIX‘kpo’75HawthorneStreetSanFranN4R,,fd1-39O1Ms.KarenMagliano,ManagerAirQualityDataBranchPlanningandTechnicalSupportDivisionCaliforniaAirResourcesBoardP.O.Box2815Sacramento,California95812DearMs.Magliano:IntheStateofCalifornia,twelvedistrictsplustheCaliforniaAirResourcesBoard(ARB)submitannualmonitoringnetworkplansinaccordancewith40CFR58.10.EPAreceivedplansfor2013from:•BayAreaAirQualityManagementDistrict,•GreatBasinUnifiedAirPollutionControlDistrict,•ImperialCountyAirPollutionControlDistrict,•MontereyBayUnifiedAirPollutionControlDistrict,•NorthCoastUnifiedAirPollutionControlDistrict,•SacramentoMetropolitanAirQualityManagementDistrict,•SanDiegoCountyAirPollutionControlDistrict,•SanJoaquinValleyAirPollutionControlDistrict,•SanLuisObispoCountyAirPollutionControlDistrict,•SantaBarbaraCountyAirPollutionControlDistrict,•SouthCoastAirQualityManagementDistrict,and•VenturaCountyAirPollutionControlDistrictEPAhasreviewedandapprovedalloftheplanslistedabovewiththeexceptionofGreatBasinUnifiedAirPollutionControlDistrict,SanJoaquinValleyAirPollutionControlDistrict,andSouthCoastAirQualityManagementDistrict.EPAhasprovidedspecificcommentsontheplanswereceivedfromlocalagenciesthroughseparateletters,andhavecopiedARBonourresponsestoallplanssubmittedbyCaliforniaagencies.Weanticipatecompletingreviewofthethreeremainingplansshortlyandwillforwardanyadditionalcomments.PleaserefertotheseresponsesforadditionalcommentspertinenttoARB‘Snetwork.Weappreciateyoureffortsinpreparingthe“AnnualMonitoringNetworkReportforTwenty-ThreeDistrictsinCalifornia,”submittedbyARBinSeptember2013.Wehavereviewedthesubmitteddocumentbasedontherequirementssetforthunder40CFR58.Basedontheinformationprovidedintheplan,EPAapprovesallportionsofthisnetworkplanexceptthosespecificallyidentifiedbelow.SomeannualnetworkplanssubmittedbylocalagenciesincludedARBsites.MissingordeficientinformationforARBsitesinlocalagencyplanswasaddressedintheapprovallettersforeachlocalagency.Forconvenience,weareprovidingasynthesizedlistoftheseissuesinEnclosureB.ElementsRelatedtoARBSitesinLocalAgencyPlansWhereEPAisNotTakingAction.PleasenotethatwecannotapproveportionsoftheannualnetworkplanforwhichtheinformationinthePrintedonRecycledPaperplanisinsufficienttojudgewhethertherequirementhasbeenmet,orforwhichtheinformation,asdescribed,doesnotmeettherequirementsasspecifiedin40CFR58.10andtheassociatedappendices.EPARegion9alsocannotapproveportionsoftheplanforwhichtheEPAAdministratorhasnotdelegatedapprovalauthoritytotheregionaloffices.Accordingly,thefirstenclosure(A.AnnualMonitoringNetworkPlanItemswhereEPAisNotTakingAction)providesalistingofspecificitemsofthe“AnnualMonitoringNetworkReportforTwenty-ThreeDistrictsinCalifornia”whereEPAisnottakingaction.ItemswhereEPAisnottakingactionrelatedtoARBsitesmentionedinlocalagencyplansreviewedthusfararelistedinEnclosureB.ElementsRelatedtoARBSitesinLocalAgencyPlansWhereEPAisNotTakingAction.Thethirdenclosure(C.AdditionalItemsRequiringAttention)isalistingofadditionalitemsintheplanthatEPAwishestobringtoyouragencsattentionbasedonthe“AnnualMonitoringNetworkReportforTwenty-ThreeDistrictsinCalifornia.”Thefourthenclosure(D.AnnualMonitoringNetworkPlanChecklist)isthechecklistEPAusedtoreviewyourplanforoverallitemsthatarerequiredtobeincludedintheannualnetworkplanalongwithourassessmentofwhethertheplansubmittedbyyouragencyaddressesthoserequirements.Thefirstandthirdenclosureshighlightasubsetofthemoreextensivelistofitemsreviewedinthefourthenclosure.Allcommentsconveyedviathisletter(andenclosures)shouldbeaddressed(throughcorrectionswithintheplan,additionalinformationbeingincluded,ordiscussion)innextyear’sannualmonitoringnetworkplan.Ifyouhaveanyquestionsregardingthisletterortheenclosedcomments,pleasefeelfreetocontactmeat(415)947-4534orGwenYoshimuraat(415)947-4134.Sincerely,MeredithKurpius,ManagerAirQualityAnalysisOfficeEnclosures:A.AnnualMonitoringNetworkPlanItemswhereEPAisNotTakingActionB.ElementsRelatedtoARBSitesinLocalAgencyPlansWhereEPAisNotTakingActionC.AdditionalItemsRequiringAttentionD.AnnualMonitoringNetworkPlanChecklistcc:KenStroud,ARBMikeMiguel,ARBA.AnnualMonitoringNetworkPlanItemswhereEPAisNotTakingActionWearenotactingontheportionsofannualnetworkplanswhereeitherEPARegion9lackstheauthoritytoapprovespecificitemsoftheplan,orEPAhasdeterminedthatarequirementiseithernotmetorinformationintheplanisinsufficienttojudgewhethertherequirementhasbeenmet.•Per40CFR58.11(c),NCoreandSTNnetworkdesignandchangesaresubjecttoapprovaloftheEPAAdministrator.Therefore,whilethisinformationisrequiredtobeprovidedintheplan,wearenotactingontheseitems.•Systemmodifications(e.g.,siteclosuresormoves)aresubjecttoapprovalper40CFR58.14(c).InformationprovidedintheplanwasinsufficientforEPAtoapprovethesystemmodificationslistedintheplanpertheapplicablerequirement.Therefore,wearenotactingonthefollowingitemsaspartofthisyear’sannualnetworkplan:—DiscontinuationofozonemonitoringatAuburn-CDewitt;newozonemonitoringatAuburn-AtwoodStreetsite—NewTahoeCitysite—RedBluffmonitoringconsolidation•EPAidentifieditemsinyouragency’sannualnetworkplanwherearequirementwasnotbeingmetorinformationintheplanwasinsufficienttojudgewhethertherequirementwasbeingmetbasedon40CFR58.10andtheassociatedappendices.Therefore,wearenotactingonthefollowingitems:ItemChecklistRowIssueMaximumconcentration0357Notmeetingrequirementtoidentifysitesinmonitor(s)someinstancesPM25collocation37Notmeetingrequirementinsomeinstances,insufficientinformationtojudgeinotherinstancesPM2.5samplingschedule52NotmeetingrequirementinsomeinstancesManualPM10method40NotmeetingrequirementcollocationPM10samplingschedule53InsufficientinformationtojudgePM2.5siteatneighborhoodor66Notmeetingrequirementtoidentifytheselargerscaleinanareaofsitesinsomeinstancesexpectedmaximumconcentration.STNsites70InsufficientinformationtojudgeDesignationofaprimary38NotmeetingrequirementmonitorDistancebetweencollocated39NotmeetingrequirementmonitorsInstrumentmonitortype46IncorrectinsomeinstancesSitetypeforeachinstrument48IncorrectinsomeinstancesIdentificationofsitesnot18InsufficientinformationtojudgeinsomesuitableforcomparisontotheinstancesannualPM2.5NAAQSModifications

to SLAMS

4

Not meeting requirement

for PM 10 network— not approving

discontinuation

for four monitors Document

now
the agency

26 Insufficient information

to judge provides

for review

of changes to the PM 2 , 5 monitoring network Monitoring objective

47 Incorrect

in some instances Instrument parameter

50 Incorrect

in one instance occurrence

code Minimum monitoring

for

72 Insufficient information

to judge P1v1 102 . 5 Distance

from road

73 Insufficient information

to judge Traffic count

74 Insufficient information

to judge Groundcover

75 Insufficient information

to judge Probe height

76 Insufficient information

to judge Distance

from supporting

77 Insufficient information

to judge structure Distance

from obstructions

on

78 Insufficient information

to judge roof Distance

from obstructions

not

79 Insufficient information

to judge on roof Distance

from trees

80 Insufficient information

to judge Distance

to furnace/flue

81 Insufficient information

to judge Unrestricted

airflow

82 Insufficient information

to judge Probe material

83 Insufficient information

to judge Residence

time

84 Insufficient information

to judge Additional information

for each

of these items may

be found

for the row listed

in colunm

2, in the fourth enclosure

(D. Annual Monitoring Network

Plan Checklist).AttachmentB:ElementsRelatedtoARBSitesinLocalAgencyPlanswhereEPAisNotTakingActionWearenotactingontheportionsofannualnetworkplanswhereeitherEPARegion9lackstheauthoritytoapprovespecificitemsoftheplan,orEPAhasdeterminedthatarequirementiseithernotmetorinformationintheplanisinsufficienttojudgewhethertherequirementhasbeenmet.Systemmodifications(e.g.,siteclosuresormoves)aresubjecttoapprovalper40CFR58.14(c).InformationprovidedintheplansbelowwasinsufficientforEPAtoapprovethesystemmodificationslistedintheplanpertheapplicablerequirement.Therefore,wearenotactingonthefollowingitemsaspartofthisyear’sannualnetworkplan:—RelocationofCalexicoEthel•EPAidentifieditemsinthefollowingannualmonitoringnetworkplanswherearequirementwasnotbeingmetorinformationintheplanwasinsufficienttojudgewhethertherequirementwasbeingmetbasedon40CFR58.10andtheassociatedappendices.Therefore,wearenotactingon-thefollowingitems:ItemChecklistRowIssuePM2.5samplingfrequencyImperial,52NotmeetingrequirementinoneinstanceDistancefromtreesImperial,80NotmeetingrequirementinoneinstancePM10samplingfrequencyImperial,53InsufficientinformationtojudgeDesignationofprimaryImperial,38InsufficientinformationtojudgemonitorDateoflastPEauditImperial,34InsufficientinformationtojudgeinsomeinstancesDistancefromfurnaceorImperial,81InsufficientinformationtojudgeincineratorflueDocumenthowagencywillImperial,26InsufficientinformationtojudgeprovideforthereviewofchangestoPM2•5networkParametercodeImperial,49IncorrectinformationinsomeinstancesScaleofrepresentationImperial,17InsufficientinformationtojudgeorincorrectinsomeinstancesSitetypeImperial,48IncorrectinformationinsomeinstancesMethodcodeImperial,43InsufficientinformationtojudgeMonitoringobjectiveImperial,47InsufficientinformationtojudgeStatementofpurposeImperial,2InsufficientinformationtojudgeStartdateImperial,45InsufficientinformationtojudgeinsomeinstancesPbmonitoringrequirementsImperial,62InsufficientinformationtojudgePbcollocationImperial,41InsufficientinformationtojudgePM2.5collocationImperial,37InsufficientinformationtojudgePM10collocationImperial,40InsufficientinformationtojudgeInstrumentparametercodeSanLuisObispo,Notmeetingrequirementinsomeforeachinstrument49instancesMonitoring objective

for

San Luis Obispo,

Not meeting requirement

in some each instrument

47
instances Traffic count

of nearest

road

San Luis Obispo, Insufficient information

to judge 74 PM 2 . 5 collocation

San Luis Obispo, Insufficient infonnation

to judge 37 Scale

of representativeness

Santa Barbara,

17 Insufficient information

to judge PM 2 . 5 collocation

Santa Barbara,

37 Insufficient information

to judge In addition,

the following comments

were made

in EPA’s annual network

plan approval
letters

for the following agencies: Imperial:

• [Row

6] If any system modifications

are approved between

this plan
and the next, please attach any associated documentation

to next year’s plan. • [Row

76] The probe heights

in the “station details”

do not match

the heights above ground

in the “site survey reports”

for Calexico

Ethel. • [Row

77] The distance

from supporting structures

in the “station details”

do not match

the heights above platform

in the “site survey reports”

for Calexico

Ethel. San Luis Obispo: • [Item

74] Traffic counts
from sites listing AADT information

from 2006

or earlier (Paso Robles, San Luis Obispo) should

be updated

in next year’s
plan

if possible.

if updated information

is not available,
please

state why and/or when new data

are anticipated. Santa Barbara: • [Item
43]:— The CO,

3 monitor

at Santa Barbara

is listed

as method

code

593 instead

of 093. Assuming

this

is

a typo, please correct

in next year’s plan.— The CO,

1 monitor

at Santa Maria listed

as TAPI T300u
with method

code
067 instead

of 093. Assuming

this

is

a typo, please correct

in next year’s plan. Sacramento

Metro: • [Item

2] All monitors
should
have

a clear purpose

for continuing operation.

We recommend

for the District

to evaluate

in particular

the purpose

of continuing

to operate

SPM parameters

for extended periods

of time such

as those listed

on p.50 that have been operating

as SPM since 1979.

In addition

to reviewing

your network

when developing

the annual network
plans,

we recommend
utilizing

the 5-year Network Assessment

to assess

the purpose

of all monitoring

and make adjustments

as needed. • [Item

15] Please clarify

the term ‘Pre-FEM”

listed

in Sacramento-T

Street’s Detailed

Site Information

table.

If this

is meant

to indicate

a monitor

that

is not

an FEMJFRM/ARM,

please consider switching

to the term “other”. • [Item

38] The

T St. site lists two PM 2 . 5 SLAIVIS monitors.
Please
label

the primary monitor.C.AdditionalItemsRequiringAttention•[Item4]EPAnotesthatthenewPlacerCountyAPCD,TahoeCitysiteisproposedtohavearegulatoryozonemonitorandanon-regulatoryPM2.5monitorandwillbefundedwithoutfederalfunds.EPAencouragesARBtocontinueworkingwithPlaceronthis,andtoconsultwithEPA.•[Item4]EPAalsoasksARBtocontinuecoordinatingwithEPAastheRedBluffchangesmoveforward.•[Item18]Pleaserevisethedescriptionoftherequirementtobettermatch58.30.4058.30statesthatPM2.5datathatarerepresentativeofarea-wideairqualityarecomparabletotheannual.inadditiontoneighborhoodorurbanscalesites,area-widealsoincludesmicro-ormiddle-scalesiteswhentheycollectivelyidentifyalargerregionoflocalizedhighambientPM2.5concentrations.•[Item29]Pleaseincludethedatetheannualdatacertificationwassubmittedmostrecently,andtheexpectedsubmittaldatefortheupcomingyear.•[Item44]ARB’sPQAOcoversMSAsthatoverlapwithBayAreaAQMDandSouthCoastAQMD.InsituationswhereARBreliesonanotheragency’snetworktomeetminimummonitoringrequirements,anagreementshouldexistbetweentheagencies.•[Item49]Pleaseclarifywhy,inTable3andTable4,PM2.5islistedas88101and88501inthecolumnheaders.Notethat88501cannotbecomparedtothefederalNAAQS.IftherearesomePM2.5monitorslistedinthetablethatonlyreportas88501,theseshouldbecalledout.EPAmustapproveanyPM2.5FRM,FEMorARIvImonitorsasnon-regulatorybeforetheyaresubmittedtoAQSunderthe88501parametercode.Also,pleaseclarifywhetheranyofthe88501monitorsareusedforAQIreporting.•[Item56,63,68,71]PleaseensurethattheDVusedtodeterminetheminimummonitoringrequirementsineachMSAincludesallexceptionalevents.Ifpreferred,aDVwithandwithoutexceptionaleventsmaybeprovided.•[Item56]PleaseexplainwhyEchoSummit,Cool,andSufferButtesarenotlistedasozonemonitorscountedtowardsminimummonitoringrequirements.•[Item63]ThedesignvalueusedtodetermineminimummonitoringrequirementsforPM2.5SLAMSshouldbeselectedbylookingatallregulatorySPMandSLAMSmonitordata,notjustthoseintheSLAMSnetwork.•[Item69jPleaseensurethatsitesthatarebeingusedtofulfillthestatewiderequirementforPM2.5backgroundandtransportsitesareidentifiedassuchinthenetworkplantablesandinAQS.• [Item

73] Please revisit

and clarify

in next year’s
plan whether

the NO 2 monitor
listed

for the

T St. site (p.60) should

be labeled

as Middle
scale. This appears

to be inconsistent

with

the Statement

of Purpose which states
that the monitor “measures representative concentration

in urban area” which might

be more

in line with

a neighborhood

or urban scale. Recommend adding

a footnote explaining

the Middle

scale selection

for this monitor

if the case

is that

it should remain

as such.

### D. ANNUAL MONITORING NETWORK PLAN CHECKLIST (Updated 11/26/2013)

Year: Submitted September 2013 Agency: California Air Resources Board (ARB)

40 CFR 58.10(a)(1) requires that each Annual Network Plan (ANP) include information regarding the following types of monitors: SLAMS monitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, STN stations, State speciation stations, SPM stations, and/or, in serious, severe and extreme ozone nonattainment areas, PAMS stations, and SPM monitoring stations.

40 CFR 58.10(a)(1) further directs that, “The plan shall include a statement of purposes for each monitor and evidence that siting and operation of each monitor meets the requirements of appendices A, C, D, and E of this part, where applicable.” On this basis, review of the ANPs is based on the requirements listed in 58.10 along with those in Appendices A, C, D, and E.

EPA Region 9 will not take action to approve or disapprove any item for which Part 58 grants approval authority to the Administrator rather than the Regional Administrators, but we will do a check to see if the required information is included and correct. The items requiring approval by the Administrator are: PAMS, NCore, and Speciation (STN/CSN).

Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requirements, nor do its
contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welcome
comments on its contents and structure.

Key:

White

= 

### meets the requirement.
Yellow

= 

### requirement is not met, or information is insufficient to make a determination. Action requested in next year’s plan or outside the ANP
process. (items listed in Enclosure A)
Green

= 

### item requires attention m order to improve next year’s plan (items listed m Enclosure B)

1

### ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3 meet Flag if the req? 4

incorrect 2

?

Submit pian by July 1St 58.10 (a)(1) Yes No 

### Plan submitted September 13, 2013. We recognize

that last year, data certification conflicted with

submission of the network plan and that ARB

continues to work toward meeting this deadline.

2. Statement of 

### purpose for each monitor 58.10 (a)(1) Yes, pp 11-16 Yes

3. 30-day public comment / inspection period 5 58.10 (a)(1), Yes Yes No comments received.

58.10 (a)(2)

4. Modifications to SLAMS network

— case when we 58.10 (a)(2) Yes, pg 47-50 Yes; no in some Previously approved:

are not approving actual system modifications (i.e., 58.10(e) instances

- Closure of 03 at Calexico-East (060250006)

we will do it outside the ANP process 6 )

- Relocation of Chico-Manzanita site (060070002) to Chico-East (060070008)

- Relocation of NCore from Fresno15t St

. (060190008) to Fresno-Garland (060190011)

- Relocation of Portola-Nevada St site (060631009) to Portola-Gulling St (060631010). Please include the approval

information for this relocation in your next plan.

EPA acknowledges that several sites listed in Table

13 have switched from PM1O HiVol monitors to
PM1O continuous instruments. As these remain

FRMIFEM at the same locations, no formal EPA approval is required, however, EPA appreciates the

Response options: NA (Not Applicable), Yes, No, Incomplete, Incorrect. The responses “Incomplete” and “Incorrect” assume that some information has been provided.

2 To the best of our knowledge.

Assuming the information is correct options: NA (Not Applicable)

— [reason], Yes, No, Insufficient to Judge.

The affected state or local agency must document the process for obtaining public comment and include any comments received through the public notification process within

their submitted plan.

6 See 58. 14(c)



### 2

### ANP requirement Citation Was the info Does the Notes
within 40 submitted? 1 If information

CFR 58 yes, page #s. provided 3 meet Flag if the req? 4
incorrect 2

?

inclusion of 

### this information in the 

### plan.

EPA further notes that ARB clarified in an email sent February 12, 2014, that four sites listed in Table 13,

pg 48, discontinued their PM1O hivol instruments (Santa Maria on 4/30/2009, Moj ave-Poole on 6/30/2011, Paso Robles on 7/30/2009, and San Luis Obispo on 3/31/2011) and started running continuous
instruments. However, the continuous instruments only reported as 85101 (which is not comparable to the federal NAAQS) until May/Jun 2013 when they additionally started reporting as 81102 (comparable

to the NAAQS). EPA will work with ARB to fill in
the missing 81102 data, so that there is a continuous
data record of federally regulatory PM 10 data at these sites. Without such backfllling, closure requests will be necessary.

Additional information is required for EPA to be able

to approve the discontinuation of ozone monitoring at Auburn-C Dewitt and the new ozone site at AuburnAtwood Street. Please coordinate with EPA to submit
this start up/shutdown request.

EPA notes that the new Placer County APCD, Tahoe City site is proposed to have a regulatory ozone monitor and a non-regulatory PM2.5 monitor and
will be funded without federal funds. EPA

encourages ARB to continue working with Placer on this, and to consult with EPA.

EPA also asks ARB to continue coordinating with

EPA as the Red Bluff changes move forward.

ARB clarified via email on February 12, 2014, that
Bakersfield-California Street PMIO HiVol monitors

are only temporarily not operating due to site



### 3

### ANP requirement Citation Was the info Does the Notes 

### within 40. submitted?’ If information

CFR 58 yes, page #s. provided 3 meet

Flag if the req? 4

incorrect 2

? renovations. A continuous PM1O started on Dec 3,
2013. When the site reopens in April/May 2014, the

HiVol PMIO 

### will be collected again.

ARB also clarified that the Fresno-Garland NCore
site shut down its 

### FRM PM1O monitor but continued

to collect 81102 data 

### with their continuous

instrument at the site. Shut down of the single

instrument therefore did not constitute a network

modification requiring EPA approval.

5. Modifications to SLAMS network

— case when we 58.10 (a)(2) NA NA EPA is not approving 

### any system modifications 

### with

are approving actual system modifications per 58.10 

### (bX5) this plan. 58.14(c) 58.10(e)

58.14 (c)

6. Does plan include documentation (e.g., attached Yes, in some Yes EPA notes that EPA sent a letter approving the approval letter) for system modifications that have instances Fresno First Street/Fresno Garland NCore change on been approved since last ANP approval? March 7, 2013.

7. NCore site operational 

### (by 1/1/2011) 58.10 (a)(3) NA, pg 33 NA ARB operates the Fresno-Garland NCore site (originally the Fresno First Street site), however, the
site is not covered in this plan as it is within the SN jurisdiction.

The remaining six California NCore stations 

### are addressed in other plans.
8. Pb site for 0.5-1.0 tpy sources operational 

### (by 58.10 (a)(4) NA, pg 32 NA There are no Pb sources that require monitoring in 12/27/2011) the areas covered by the plan.

Please include a more detailed assessment of Pb

sources in your 2015 network assessment.

9. NO 2 plan for area-wide and RA4O sites submitted by 58.10 (a)(5) NA, pg 29-30 NA The required monitors within California 

### all fall 7/1/20 12 within areas covered by other annual network plans.

The information provided on pgs 29-3 0 nicely
summarize the overall requirements in CA.
10. NO 2 area-wide and RA4O sites operational by 58.10 (a)(5) NA, pg 29-30 NA See Row 9 comment. 1/1/20 13



### 4

### ANP requirement Citation 

### Was
the info Does the Notes

within 40 submitted? 1 If information

CFR 58 yes, page #s. provided 3 meet

Flag if the req? 4

incorrect 2

? 11. NO 2 plan for near-road sites submitted by 7/1/2013 

### 58.10 (a)(5) NA, pg 29-30 NA The required near-roadway monitors within California all 

### fall within areas covered by other
annual network plans.

12. SO 2 sites operational 

### (by 1/1/2013) 58.10 (a)(6) NA, pg 31 NA The required SO 2 monitors within California all fall and 58.13(d) within 

### areas covered by other annual network plans.

. Pg 31 provides a 

### summary of the requirements and applicability to California. 13. AQS site identification number for each site 58.10 (b)(1) Yes, Tables 3 and 4 Yes Information was provided for monitors within the (pg 15-11, 19-24) areas covered by this plan. 14. Location of each site: street address and geographic 58.10 (b)(2) Yes, Tables 3 and 4 Yes Information was provided for monitors within the coordinates (pg 15-11, 19-24) 

### areas covered by this plan. 

### 15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes, Tables 3 and 4 Yes Information was provided for monitors within the parameter (pg 15-11, 19-24) areas covered by this plan. 16. Any proposals to remove or move a monitoring 58.10 (b)(5) Yes, Section 10, pg Yes station within a period of 18 months following plan 47-50 submittal

17. Scale of representativeness for each monitor as 

### 58.10(b)(6); Yes, Tables 3 and 4 Yes Information was provided for monitors within the defined in Appendix D App D (pg 15-11, 19-24) areas covered by this plan. 18. Identification of sites suitable and sites not suitable 58.10 (b)(7) Yes, but Insufficient to Section 9.1 of the plan states that all PM 2

. 5 FRM for comparison to the annual PM 2

. 5 NAAQS as incomplete. Pg 45. judge in some monitors in California are comparable to the annual described in Part 58.30 instances NAAQS, but no statement is made for the PM 2

. 5
FEMs. Please include this information in future plans.

Please revise the description of the requirement to better match 58.30. 40 58.30 states that PM 2

. 5 data
that are representative of area-wide air quality are comparable to the annual. In addition to neighborhood or urban scale sites, area-wide also
includes micro- or middle-scale sites when they collectively identify a larger region of localized high
ambient PM 2

. 5 concentrations.

Note: Any FEMs that you’d like to request EPA to



### 5

### ANP requirement Citation Was the info Does the Notes



### within 40 submitted? 1 If information

CFR 58 yes, page #s. provided 3 meet Flag if the req? 4

incorrect 2

?

exclude data from comparison to the NAAQS per 58.11(e) are handled in a separate process, as discussed in Row 24.

19. MSA, CBSA, CSA or other area represented by the 58.10 (b)(8) Yes, Tables 3 and 4 Yes Information was provided for monitors within the

monitor (pg 15-11, 19-24) areas covered by this plan.

20. Designation of any Pb monitors as either source- 58.10 

### (bX9) NA NA No Pb monitors are covered in this plan.

oriented or non-source-oriented

21. Any source-oriented Pb site for which a waiver has 58.10 (b)( 10) NA NA No Pb monitors are covered in this plan.

been granted by EPA RA

22. Any Pb monitor for which a waiver has been 58.10 (b)(1 1) NA NA No Pb monitors are covered in this plan. requested or granted by EPA RA for use of Pb-PM 10

in lieu of Pb-TSP

23. Identification of required NO 2 monitors as either 58.10 (b)(12) NA NA No required N02 monitors are covered in this plan.

near-road or area-wide

24. Identification of any PM 2

. 5 FEMs and/or ARMs not 58.10 (b)(13) NA NA No PM 2

. 5 FEMs included in this plan were identified eligible to be compared to the NAAQS (Note 1: must 58. 11 (e) for a waiver.

include required data assessment.) (Note 2: Required

SLAMS must monitor PM 2

. 5 with NAAQS comparable monitor at the required sample frequency.)

25. For SPMs listed as non-regulatory, note the start 58.20(c) Yes, Tables 3 and 4 Yes Since Table 3 does not include any monitor types of

Date of FRM/FEMJARM at SPM. If> 24 months, (pg 15-11, 19-24) “Non-regulatory,” all FRMIFEMs covered by this

and monitor is eligible for comparison to the plan are presumed to be regulatory.
NAAQS per 58.11 (e) and 58.30, the agency must supply information that App A, C or E requirements

were not met.
26. Document how states and local agencies provide for 58.10 (c) Yes, Section 9.2 pg Insufficient to Please include a description of the process for

the review of changes to a PM 2

. 5 monitoring network 45. judge obtaining public comment, per 58.10(c).

that impact the location of a violating PM 2

. 5 monitor.

27. Does the plan include a request for approval for and 58.11 (a) (2) NA NA No such request included

alternative to appendix A requirements for SPMs operating a FRMJFEM/ARM which also meets appendix E?

28. Precision/Accuracy reports submitted to AQS 58.16(a); Yes, pg 39 Yes App A, 1.3

and 5.1.1



### 6

### ANP requirement Citation Was the info Does the Notes 

### within

40 submitted?’ If information

CFR 58 yes, page #s. provided 3 meet

Flag if the req? 4 

### incorrect 2

?

29. Annual data certification submitted 58.15 Yes, pg 39 Yes Please include the date the certification was App. A 1.3 submitted most recently, and the expected submittal

V date for the upcoming year. 30. Frequency of flow rate verification for manual PM App A 3.3.2 Yes, pg 39 Yes One-point flow rate verification checks once every samplers audit month for filter-based. QMB staff verify during
audits and address any issues through an AQDA. 31. Frequency of flow rate verification for automated App A 3.2.3 Yes, pg 39 Yes One-point flow rate verification checks twice every PM analyzers audit month for automated. QMB staff verify during audits
and address any issues through an AQDA. 32. Frequency of one-point flow rate verification for Pb App A 3.3.4.1 NA NA No Pb monitors included in the area covered by the samplers audit plan. 33. Frequency of one-point QC check (gaseous) App. A 3.2.1 Yes, pg 39 Yes “.

. .precision checks are conducted nightly at ARB
and some district operated sites, and weekly or bi weekly at other district sites.” These data are analyzed by QMB staff. 34. Date of last Annual Performance Evaluation App. A 3.2.2 Yes, Table 11 pg Yes (gaseous) 40 35. Dates of last two semi-annual flow rate audits for PM App A, 3.2.4 Yes, Table 11 pg Yes monitors

V and 3.3.3 40 36. Dates of last two semi-annual flow rate audits for Pb App A 3.3.4.1 NA NA No Pb monitors included in the area covered by the

V monitors

. plan. 37. PM 2

. 5 collocation App A 3.2.5 Yes, but incorrect. Yes for some Table 9 The number of required collocated monitors Pg 34-35. methods, no for requirements for PM 2

. 5 FRM methods 117, 118, and other methods (see 145 appear to be correct, however, it is not possible notes) to tell if the collocated monitors meet 40CFR58 Appendix A section 3.2.5.2 requirements related to

. collocation at monitors of certain DV ranges. DVs

must be provided for this to be determined.

Table 10 Collocation requirements for continuous
PM 2

. 5 FEM and the accompanying text recognizes
that not all continuous collocation requirements are being met for methods 170, 181, and 195. Also, note

V that collocation requirements are based on the number of primary monitors using each method code. Monitors used to fulfill continuous collocation



### 7

### ANP
requirement Citation Was the info Does the Notes 

### within

40 submitted? 1 If information

CFR 58 yes, page #s. provided 3 meet

Flag if the req? 4

incorrect 2

? requirements should have the continuous instrument designated as the primary instrument. In AQS, this

does not appear to be the case for El Rio, Modesto,
Fresno, or Thousand Oaks. Merced is listed as the 5 th

site meeting the FEM/FRM collocation requirement.

It is unclear which Merced site this is intended to be,

and neither site appears to be collocated based on AQS information. (Merced-Coffee (06-047-0003) is

listed in AQS as POC3 SPM continuous (170) instrument, but is not collocated. Merced-M Street (06-047-25 10) is listed in AQS as POC1 SLAMS

filter (118) instrument, and is not collocated.)

The plan states that ARB is working to meet the

collocation requirement for continuous PM 2

. 5 FEM.

38. Designation of a primary monitor if there is more Need to No No Information not submitted in plan.

than one monitor for a pollutant at a site. determine

collocation

39. Distance between collocated monitors (Note: waiver App. A No No hiformation not submitted in plan.

request or the date of previous waiver approval must 3.2.5.6 and

be included if the distance deviates from 3.2.6.3 requirement.)

40. Manual PM 10 method collocation met? (note: App A 3.3.1 Yes, pg 36 No As stated in the plan, ARB is working toward

continuous PM 10 does not have this requirement) fulfilling this requirement.

41. Pb collocation App A 3.3.4.3 NA NA No Pb monitors included in the area covered by the plan.

42. PM 102

. 5 collocation (note: only applies to Fresno and App A 3.3.6 NA NA Fresno NCore information covered by SN plan; not

Phoenix NCore sites) addressed in this plan.

43. Insirumentlmonitoring method code for each App C 2.4.1.2 Yes. Table 4, pg Yes

monitor: is it reported properly? Is it reported 19-24 correctly (i.e., appropriate method code for regulatory monitors)?

44. For agencies that share monitoring responsibilities in App D 2(e) No No ARB’s PQAO covers MSAs that overlap with Bay

an MSA/CSA: does each affected State or local Area AQM]) and South Coast AQMD. In situations

agency meet full monitoring requirements or is where ARB relies on another agency’s network to

an agreement between the affected agencies and the meet minimum monitoring requirements, an



### 8

### ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1 If information

CFR 58 yes, page #s. provided 3 meet

Flag if the req? 4

incorrect 2

?
EPA Regional Administrator in place 9 agreement should exist between the agencies



# : ARE & BAAQMD Overlapping MSAs

- Santa Rosa (Sonoma County)

- Vallej 0-Fairfield (Solano County)

ARE & SCAQMD Overlapping MSAs:

- Los Angeles-Long Beach-Anaheim (Los

I Angeles, Orange Counties).

. - Riverside-San Bernardino-Ontario
(Riverside, San Bernardino Counties)



### 45. Start date for each monitor Required to Yes. Table 4, pg Yes determine if 19-24.
other req. (e.g., miii #

‘ and colloc)

are met

46. Instrument monitor type for each monitor Required to Yes. Table 3, pg Yes, but incorrect If non-FRM/FEM continuous instruments are not determine if 11 -16 in some instances required, they should not be listed as SLAMS. For

other req. example, Grass Valley (06-057-0005), Truckee-Fire (e.g., mm # Station (06-057-1001), Chester (06-063-1007), and colloc) Portola (06-063-1009), Quincy (06-063-1006) nonare met FEM PM 2

. 5 monitors do not appear to be required and

therefore should not be listed as SLAMS. 47. Monitoring objective for each instrument App D 1.1 Yes. Table 3, pg Yes, but incorrect All sites collecting regulatory information should list
58.10 (b)(6) 1 1-16 in some instances “NAAQS comparison” as an objective. Sites may
have multiple monitoring objectives. Please correct in future plans.

48. Site type for each instrument App D 1.1.1 Yes. Table 3, pg Yes, but incorrect Sites being used to fulfill background, transport, or 1 1-16, and pg 37. in some instances maximum concentration (site type of highest concentration) sites should have corresponding site types listed in both the network plan and in AQS. See

Rows 57, 66 and 69 for additional comments. 49. Instrument parameter code for each instrument Required to Yes. Table 3, pg Yes Please clarify why PM 2

. 5 lists 88101 and 88501. Note determine if 1 1-16 & Table 4, that 88501 cannot be compared to the federal



### 9

### ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1 If information

CFR 58 yes, page #s. provided 3 meet Flag if the req? 4

incorrect 2

?

other req. pg 19-24. NAAQS. If there are some PM 2

. 5 monitors listed in (e.g., mm # the table that only report as 88501, these should be
and colloc) called out. EPA must approve any PM 2

. 5 FRM, FEM

are met or ARM monitors as non-regulatory before they are submitted to AQS under the 88501 parameter code. Also, please clarify whether any of the 88501

monitors are used for AQI reporting.

50. Instrument parameter occurrence code for each Required to Yes. Table 4, pg Yes, incorrect in Believe PM 10 at Redding-Health Department (06-
instrument determine if 19-24 one instance 089-0004) should be POC2, not POC 1.
other req. (e.g., mm #

and colloc)

are met
51. Sampling season for ozone (note: date of waiver 58.10 (b)(4) Yes. pg 43. Yes Seasonal for Cool, Echo Summit, Jerseydale, Sutter approval must be included if the sampling season App D, 4.1(i) Buttes, White Cloud (waiver approval for these five
deviates from requirement) was attached), and Tuscan Buttes (approved via

email May 2, 2013).

52. Sampling schedule for PM 2

. 5

- applies to year-round 58.10 (b)(4) Yes. Table 12. Pg No in some The design values for PM 2

. 5 filter based sites are and seasonal sampling schedules (note: date of 58.12(d) 42-43 instances needed to correctly assess the sampling frequency. In
waiver approval must be included if the sampling App D 4.7 future plans, please provide a column in table 12 that

season deviates from requirement) EPA lists annual and 24-hour design values for the filter

flowchart based PM 2

. 5 sites. Currently there are a number of

FRMs that are operating on 1:6 day sampling

schedules and are not collocated with a continuous

instrument. ARB and EPA continue to work to address sampling frequency issues in ARB’s
network.

53. Sampling schedule for PM 10 58.10 (b)(4) Yes, but Insufficient to 1:6 sampling for PM 10 is only allowed if the ratio of 58.12(e) incomplete. Pg 42 judge the concentration to the standard is below 0.8 or App D 4.6 above 1.4

— concentration information was not provided to determine if this requirement is being

met.
54. Sampling schedule for Pb 58.10 (b)(4) NA NA 58.12(b) App D 4.5

55. Sampling schedule for PM 102

. 5 58.10 (b)(4) NA NA



### 10

### Citation

within 

### 40
CFR 58 Was the info
submitted?’ If

yes, page #s. Flag if
incorrect 2

? Does the
information provided

3 meet the req? 4

7 Onlymonitors considered to be required SLAMS 

### are eligible to be counted towards meeting minimum monitoring requirements. In addition, ozone monitors 

### that do not meet 

### traffic countldistance requirements to be neighborhood scale (40 CFR 58 Appendix E, Table E-1) cannot be counted towards minimum monitoring requirements. 

### irement Notes

3 I. 58.12(f) App D 4.8

ote: should be App I), 4.1(a) Yes. Appendix B, Yes Please ensure that the DV used to determine the supported by MSA ID, MSA population, DV, # 

### and pg 59. minimum monitoring requirements in each MSA monitors, 

### and # required monitors] (see footnote) 7 Table D-2 includes all exceptional events. If preferred, a DV with and without exceptional events may be provided.

Please explain why Echo Summit, Cool, 

### and Sutter

. 

### Buttes are not listed. Identification of max. conc. 03 monitor(s) App D 4.1 (bI 

### Yes. Table 3, pg Yes; 

### no in some There should be at least one maximum concentration
I 1-16; Appendix Fl instances site for each relevant MSA (there may also be more
pg 59. than one, if the highest site varies from year to year).
At a minimum, one would expect the DV site listed

on pg 59 to be listed as the maximum concentration
site for the MSA. For the Chico MSA, pg 59 

### lists
Paradise as the DV site; for Redding, Shasta Lake is listed as the DV site; for Yuba City, Yuba CityAlmond is listed as the DV site. Table 3 lists Paradise



### as highest concentration but lists the other 

### two sites

as “General.” In 

### future plans, please ensure that this requirement is met. Minimum monitoring requirements met for near-road App D 4.3.2 NA, pg 29-30 NA Sites not included in 

### this plan. NO 2 (2014 

### start date)
Minimum monitoring requirements met for area- App D 4.3.3 NA, pg 29-30 NA Sites not included in 

### this plan.

met for RA-40 App D 4.3.4 NA, pg 29-30 NA Sites not included in 

### this plan. NO 2

Minimum monitoring requirements met for 

### SO 2 App D 4.4 NA, pg 31 NA Sites not included in this plan. [Note: Only monitors considered to be required SLAMs 

### are eligible to be counted towards meeting 

### minimum monitoring requirements.]
Minimum monitoring requirements met for Pb [Note: App D 4.5 NA NA Sites not included in 

### this nian. 62.1



### 11

### ANP requirement Citation Was the info Does the Notes

V 

### within 40 submitted? 1 If information

CFR 58 yes, page #s. provided 3 meet

V 

### Flag if the req? 4

incorrect 2

?
Only monitors considered to be required SLAMs are 58.13(a) eligible to be counted towards meeting 

### minimum monitoring requirements.]

63. Minimum # of monitors for PM 2

. 5 [Note I: should be App D, Yes, pg 60 Yes The design value used to determine minimum supported by MSA ID, MSA population, DV, # 4.7.1 (a) 

### and monitoring requirements for PM 2

. 5 SLAMS should be
monitors, 

### and # required monitors] [Note 2: Only Table D-5 selected by looking at all regulatory SPM 

### and

monitors considered to be required SLAMs are SLAMS monitor data, not just those in the SLAMS eligible to be counted towards meeting 

### minimum network monitoring requirements.]

V

VVVV

V Please ensure that the DV used to determme the

minimum monitormg requirements in each MSA also

mcludes all exceptional events If preferred a DV

with and without exceptional events may be

• V V provided.

64. Optional PM 2

. 5 Nehvork Clarifications: Provide a list Need to NA NA

of required sites if it does not include all SLAMS. assess several

V [Note: default 

### will assume all SLAMS are considered requirements

- V required sites.] V

65. Required PM 2

. 5 sites represent area-wide 

### air quality App D Yes. Table 4 pg 19- Yes All PM 2

. 5 monitors listed in Table 4 are at 4.7.1(b) 24. neighborhood or larger scale.

66. For PM 2

. 5

, is at least one site at neighborhood or App D Yes. pg 37; table 3, Yes; no in some There should be at least one area-wide site identified larger scale in an area of expected maximum 4.7.1 (b)( 1) pg 1 1-16. instances, as maximum concentration site for each relevant

concentration MSA. For the Chico MSA, pg 60 lists Chico-East as the DV site; for Redding the Redding-Health Dept is

listed as the DV site; for Yuba City, Yuba CityAlmond is listed as the DV site. While Chico is listed

on pg 37 as a maximum-concentration site, none of

these sites are listed as highest concentration site

types in Table 3.

67. If additional SLAMS PM 2

. 5 required, is there a site in App D Yes. pg 60, Tables NA The MSAs 

### with more 

### than one PM2.5 instrument

an area of poor air quality 4.7.1(b)(2) 3 and 4 required are Bakersfield, Lost Angeles-Long Beach

### Anaheim, Riverside-San Bernardino-Ontario, 

### and

Sacramento-Arden Arcade-Roseville. All these areas

are covered by separate plans submitted by local

V agencies 

### and so are not covered in 

### this plan.

68. 

### Minimum monitoring requirements for continuous App D 4.7.2 Yes, pg 61 Yes Please ensure that the DV used to determine the



### 12

### ANP requirement Citation Was the info Does the Notes

‘ 

### within

40 submitted?’ If information

CFR 58 yes, page #s. provided 3 meet

Flag if the req? 4

incorrect 2

? PM 2

. 5 I minimum monitoring requirements in each MSA also

. includes all exceptional events. If preferred, a DV with and without exceptional events may be provided.

Note: Other pians (such as South Coast AQMD’s plan) must be referenced for more information about

some of the specific monitors listed. 69. Requirements for PM 2

. 5 background and transport App D 4.7.3 Yes. pg 37; table 3 Yes Per the comment in Row 48, please ensure that sites (pg 1 1-16) background and transport sites are identified as such in Table 3 as well as in AQS.

Several sites listed in Table 3 (pg 11-16) are identified as “General!Background.” No site is listed .4 as a transport site for PM2.5 in Table 3. Roseville, which

is identified as one of two transport sites on pg 4 37 and is included in Table 3, is listed there as “General,” not as Transport. 70. Are PM 2

. 5 Chemical Speciation requirements met for App 1) 4.7.4 No. Insuiiicien( The plan does not discuss STN sites. In future plans official SIN sites? information please provide an overview of the sites for California,
and specifics on any sites that fall within the area covered by this plan (such as Chico-East and Portola). 71. Minimum # of monitors for PM 10 App D, 4.6 Yes, pg 62 Yes Please ensure that the DV used to determine the (a) and Table minimum monitoring requirements in each MSA also D-4 includes all exceptional events. If preferred, a DV with and without exceptional events may be provided.

72. Minimum monitoring requirements met for PM 102

. 5 App D 4.X No Insuflicient While the plan discusses the Fresno NCore site, it
mass information does not specifically provide information on PM 102 .s 73. Distance of site from nearest road App E 6 No

— pg 18 Insufficient Not included in this plan information 74. Traffic count of nearest road App E No

— pg 18 Insufficient Not included in this plan information 75. Groundcover App E 3(a) No

— pg 18 Insufficient Not included in this plan



### 13

### ANP requirement Citation Was the info Does the Notes 

### within 40 submitted? 1 If information

CFR 58 yes, page #s. provided 3 meet

Flag if the req? 4

incorrect 2

? information

76. Probe height App E 2 No

— pg 18 Insufficient Not included in this plan

information

77. Distance from supporting structure App E 2 No

— pg 18 Insufficient Not included in this plan

information

78. Distance from obstructions on roof App E 4(b) No

— pg 18 Insufficient Not included in this plan

information

79. Distance from obstructions not on roof App E 4(a) No

— pg 18 Insufficient Not included in this plan

information

80. Distance from trees App E S No

— pg 18 Insufficient Not included in this plan

information

81. Distance to furnace or incinerator flue App E 3(b) No

— pg 18 Insufficient Not included in this plan

information

82. Unrestricted airflow App E, 4(a) No

— pg 18 Insufficient Not included in this plan

and 4(b) information

83. Probe material (if applicable) App E 9 No

— pg 18 Insufficient Not included in this plan

information

84. Residence time (if applicable) App E 9 No

— pg 18 Insufficient Not included in this plan

information

Public Comments on Annual Network Plan 

### Were comments submitted to the S/LIT agency 

### during the public comment period?

If no, skip the remaining questions.

If yes:

. No.



### Were any of the comments substantive?

o If yes, which ones?

o Explain basis for determination if 

### any comments were considered not substantive:

• Did the agency respond to the substantive comments?

o If yes, was the response adequate?

• Do the substantive comments require separate EPA response (i.e., agency response wasn’t adequate)?



### • Are the sections of the annual network plan that received substantive comments approvable after consideration of comments?

o If yes, provide rationale:

14