Ms. Karen Magliano, ManagerAir Quality Data BranchPlanning and Technical Support Division

California Air Resources Board

P.O. Box 2815

Sacramento, California 95812

Dear Ms. Magliano:

In the State of California, twelve districts plus the California Air Resources Board (ARB) submit annual

monitoring network plans in accordance with 40 CFR 58.10. EPA received plans for 2013 from:

• Bay Area Air Quality Management District,• Great Basin Unified Air Pollution Control District,• Imperial County Air Pollution Control District,

• Monterey Bay Unified Air Pollution Control District,• North Coast Unified Air Pollution Control District,• Sacramento Metropolitan Air Quality Management District,• San Diego County Air Pollution Control District,

• San Joaquin Valley Air Pollution Control District,• San Luis Obispo County Air Pollution Control District,• Santa Barbara County Air Pollution Control District,• South Coast Air Quality Management District, and• Ventura County Air Pollution Control District

EPA has reviewed and approved all ofthe plans listed above with the exception of Great Basin UnifiedAir Pollution Control District, San Joaquin Valley Air Pollution Control District, and South Coast Air

Quality Management District. EPA has provided specific comments on the plans we received from local

agencies through separate letters, and have copied ARB on our responses to all plans submitted byCalifornia agencies. We anticipate completing review ofthe three remaining plans shortly and will forwardany additional comments. Please refer to these responses for additional comments pertinent to ARB‘S

network.

We appreciate your efforts in preparing the “Annual Monitoring Network Report for Twenty-Three

Districts in California,” submitted by ARB in September 2013. We have reviewed the submitted

document based on the requirements set forth under 40 CFR 58. Based on the information provided in

the plan, EPA approves all portions ofthis network plan except those specifically identified below.

Some annual network plans submitted by local agencies included ARB sites. Missing or deficient

information for ARB sites in local agency plans was addressed in the approval letters for each localagency. For convenience, we are providing a synthesized list ofthese issues in Enclosure B. Elements

Related to ARB Sites in Local Agency Plans Where EPA is Not Taking Action.

Please note that we cannot approve portions ofthe annual network plan for which the information in the

Printed on Recycled Paper
Where EPA is Not Taking Action. The third enclosure (C. Additional Items Requiring Attention) is a

listing of additional items in the plan that EPA wishes to bring to your agencs attention based on the“Annual Monitoring Network Report for Twenty-Three Districts in California.”

The fourth enclosure (D. Annual Monitoring Network Plan Checklist) is the checklist EPA used to

review your plan for overall items that are required to be included in the annual network plan along with

our assessment of whether the plan submitted by your agency addresses those requirements.

The first and third enclosures highlight a subset ofthe more extensive list ofitems reviewed in the fourth

enclosure. All comments conveyed via this letter (and enclosures) should be addressed (through

corrections within the plan, additional information being included, or discussion) in next year’s annual

monitoring network plan. If you have any questions regarding this letter or the enclosed comments,

please feel free to contact me at (415) 947-4534 or Gwen Yoshimura at (415) 947-4134.

Sincerely,

Meredith Kurpius, Manager

Air Quality Analysis Office

Enclosures:

A. Annual Monitoring Network Plan Items where EPA is Not Taking Action

B. Elements Related to ARB Sites in Local Agency Plans Where EPA is Not Taking Action

C. Additional Items Requiring Attention

D. Annual Monitoring Network Plan Checklist

cc: Ken Stroud, ARB

Mike Miguel, ARB
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 ofthis year’s annual network plan: — Discontinuation of ozone monitoring at Auburn-C Dewitt; new ozone monitoring at

Auburn-Atwood Street site — New Tahoe City site — Red Bluffmonitoring consolidation

• EPA identified items in your 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 the

following items:

Item Checklist Row Issue

Maximum concentration 03 57 Not meeting requirement to identify sites inmonitor(s) some instances

PM25 collocation 37 Not meeting requirement in some instances,

insufficient information to judge in other

instances

PM2.5sampling schedule 52 Not meeting requirement in some instances

Manual PM10 method 40 Not meeting requirement

collocation

PM10 sampling schedule 53 Insufficient information to judgePM2.5site at neighborhood or 66 Not meeting requirement to identify these

larger scale in an area of sites in some instances

expected maximum

concentration

.STN sites 70 Insufficient information to judge

Designation of a primary 38 Not meeting requirement

monitorDistance between collocated 39 Not meeting requirement

monitorsInstrument monitor type 46 Incorrect in some instances

Site type for each instrument 48 Incorrect in some instances

Identification ofsites not 18 Insufficient information to judge in some

suitable for comparison to the instances

annual PM2.5NAAQS
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 judgeUnrestricted airflow 82 Insufficient information to judge

Probe material 83 Insufficient information to judge

Residence time 84 Insufficient information to judgeAdditional information for each ofthese items may be found for the row listed in colunm 2, in the fourth

enclosure (D. Annual Monitoring Network Plan Checklist).
Information provided in the plans below 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 ofthis year’s annual network plan: — Relocation of Calexico Ethel

• EPA identified items in the following annual monitoring network plans where a requirement was

not being met or information in the plan was insufficient to judge whether the requirement wasbeing met based on 40 CFR 58.10 and the associated appendices. Therefore, we are not acting on

- the following items:

Item Checklist Row Issue

PM2.5sampling frequency Imperial, 52 Not meeting requirement in one

instance

Distance from trees Imperial, 80 Not meeting requirement in one

instance

PM10 sampling frequency Imperial, 53 Insufficient information to judge

Designation ofprimary Imperial, 38 Insufficient information to judge

monitorDate oflast PE audit Imperial, 34 Insufficient information to judge in

some instances

Distance from furnace or Imperial, 81 Insufficient information to judge

incinerator flue

Document how agency will Imperial, 26 Insufficient information to judge

provide for the review of

changes to PM2•5network

Parameter code Imperial, 49 Incorrect information in some instances

Scale ofrepresentation Imperial, 17 Insufficient information to judge or

incorrect in some instances

Site type Imperial, 48 Incorrect information in some instances

Method code Imperial, 43 Insufficient information to judgeMonitoring objective Imperial, 47 Insufficient information to judge

Statement ofpurpose Imperial, 2 Insufficient information to judge

Start date Imperial, 45 Insufficient information to judge in

some instances

Pb monitoring requirements Imperial, 62 Insufficient information to judgePb collocation Imperial, 41 Insufficient information to judge

PM2.5collocation Imperial, 37 Insufficient information to judge

PM10 collocation Imperial, 40 Insufficient information to judge

Instrument parameter code San Luis Obispo, Not meeting requirement in some

for each instrument 49 instances
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. ifupdated 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 oftime 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. Ifthis 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 PM2.5SLAIVIS monitors. Please label the primary monitor.
forward.

• [Item 18] Please revise the description ofthe requirement to better match 58.30. 40 58.30 states

that PM2.5data 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-scalesites when they collectively identify a larger region oflocalized high ambient PM2.5

concentrations.

• [Item 29] Please include the date the annual data certification was submitted most recently, and

the expected submittal date for the upcoming year.

• [Item 44] ARB’s PQAO covers MSAs that overlap with Bay Area AQMD and South Coast

AQMD. In situations where ARB relies on another agency’s network to meet minimummonitoring requirements, an agreement should exist between the agencies.

• [Item 49] Please clarify why, in Table 3 and Table 4, PM2.5is listed as 88101 and 88501 in the

column headers. Note that 88501 cannot be compared to the federal NAAQS. Ifthere are some

PM2.5monitors listed in the table that only report as 88501, these should be called out. EPA must

approve any PM2.5FRM, FEM or ARIvI monitors as non-regulatory before they are submitted to

AQS under the 88501 parameter code. Also, please clarify whether any ofthe 88501 monitors

are used for AQI reporting.

• [Item 56, 63, 68, 71] Please ensure that the DV used to determine the minimum monitoring

requirements in each MSA includes all exceptional events. Ifpreferred, a DV with and without

exceptional events may be provided.

• [Item 56] Please explain why Echo Summit, Cool, and Suffer Buttes are not listed as ozone

monitors counted towards minimum monitoring requirements.

• [Item 63] The design value used to determine minimum monitoring requirements for PM2.5

SLAMS should be selected by looking at all regulatory SPM and SLAMS monitor data, not just

those in the SLAMS network.

• [Item 69j Please ensure that sites that are being used to fulfill the statewide requirement for

PM2.5background and transport sites are identified as such in the network plan tables and in

AQS.

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 o

monitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, STN stations, St

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 t

each monitor meets the requirements of appendices A, C, D, and E ofthis part, where applicable.” On this basis, review 

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 A

Regional Administrators, but we will do a check to see ifthe required information is included and correct. The items req

Administrator are: PAMS, NCore, and Speciation (STN/CSN).

Please note that this checklist summarizes many ofthe requirements of 40 CFR Part 58, but does not substitute for those 

contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in t

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 

process. (items listed in Enclosure A)

Green = item requires attention m order to improve next year’s plan (items listed m Enclosure B)
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

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

that last year, dat

submission ofthe 

continues to wor

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 re

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 appro

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

we will do it outside the ANP process 6) - Relocat

(060070

- Relocat

. (060190

(060190

- Relocat

(06063

(060631

informa

plan.

EPA acknowledg

13 have switched 

PM1O continuou

FRMIFEM at the 

approval is requi

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

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 pu

their submitted plan.

6 See 58. 14(c)
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

inclusion ofthis 

EPA further not

February 12, 20

pg 48, discontin

(Santa Maria on 

6/30/2011, Paso 

Obispo on 3/31/

instruments. Ho

only reported as 

the federal NAA

additionally star

to the NAAQS). 

the missing 811

data record of fe

these sites. With

will be necessar

Additional infor

to approve the d

Auburn-C Dewi

Atwood Street. 

this start up/shu

EPA notes that t

City site is prop

monitor and a n

will be funded w

encourages ARB 

this, and to cons

EPA also asks A

EPA as the Red 

ARB clarified v

Bakersfield-Cal

are only tempor
ANP requirement Citation Was the info Does the Notes

within 40. submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

renovations. A co

2013. When the 

HiVol PMIO wil

ARB also clarifie

site shut down its 

to collect 81102 

instrument at the 

instrument theref

modification req

5. Modifications to SLAMS network — case when we 58.10 (a)(2) NA NA EPA is not appro

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 E

approval letter) for system modifications that have instances Fresno First Stre

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 th

(originally the Fr

site is not covere

jurisdiction.

The remaining si

addressed in othe

8. Pb site for 0.5-1.0 tpy sources operational (by 58.10 (a)(4) NA, pg 32 NA There are no Pb 

12/27/2011) the areas covered 

Please include a 

sources in your 2

9. NO2plan for area-wide and RA4O sites submitted by 58.10 (a)(5) NA, pg 29-30 NA The required mo

7/1/20 12 within areas cove

The information 

summarize the o

10. NO2area-wide and RA4O sites operational by 58.10 (a)(5) NA, pg 29-30 NA See Row 9 comm

1/1/20 13
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

11. NO2plan for near-road sites submitted by 7/1/2013 58.10 (a)(5) NA, pg 29-30 NA The required ne

California all fa

annual network 

12. SO2sites operational (by 1/1/2013) 58.10 (a)(6) NA, pg 31 NA The required SO2

and 58.13(d) within areas cov

.

Pg 31 provides 

applicability to 

13. AQS site identification number for each site 58.10 (b)(1) Yes, Tables 3 and 4 Yes Information was 

(pg 15-11, 19-24) areas covered by 

14. Location of each site: street address and geographic 58.10 (b)(2) Yes, Tables 3 and 4 Yes Information was 

coordinates (pg 15-11, 19-24) areas covered by 

15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes, Tables 3 and 4 Yes Information was 

parameter (pg 15-11, 19-24) areas covered by 

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 ofrepresentativeness for each monitor as 58.10(b)(6); Yes, Tables 3 and 4 Yes Information was 

defined in Appendix D App D (pg 15-11, 19-24) areas covered by 

18. Identification ofsites suitable and sites not suitable 58.10 (b)(7) Yes, but Insufficient to Section 9.1 ofth

for comparison to the annual PM2.5NAAQS as incomplete. Pg 45. judge in some monitors in Cali

described in Part 58.30 instances NAAQS, but no 

FEMs. Please in

plans.

Please revise the 

better match 58

that are represen

comparable to th

neighborhood o

includes micro- 

collectively iden

ambient PM2.5c

Note: Any FEM
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

exclude data from 

58.11(e) are hand

discussed in Row 

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

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

20. Designation of any Pb monitors as either source- 58.10 (bX9) NA NA No Pb monitors a

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 a

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 a

requested or granted by EPA RA for use ofPb-PM 10

in lieu ofPb-TSP

23. Identification ofrequired NO2monitors as either 58.10 (b)(12) NA NA No required N02 

near-road or area-wide

24. Identification of any PM2.5FEMs and/or ARMs not 58.10 (b)(13) NA NA No PM2.5FEMs 

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 PM2.5with 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 do

Date ofFRM/FEMJARM at SPM. If> 24 months, (pg 15-11, 19-24) “Non-regulatory,

and monitor is eligible for comparison to the plan are presume

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 

the review of changes to a PM2.5monitoring network 45. judge obtaining public 

that impact the location of a violating PM2.5monitor.

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

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
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

29. Annual data certification submitted 58.15 Yes, pg 39 Yes Please include t

App. A 1.3 submitted most 

V

date for the upc

30. Frequency of flow rate verification for manual PM App A 3.3.2 Yes, pg 39 Yes One-point flow 

samplers audit month for filter-

audits and addre

31. Frequency of flow rate verification for automated App A 3.2.3 Yes, pg 39 Yes One-point flow 

PM analyzers audit month for autom

and address any 

32. Frequency of one-point flow rate verification for Pb App A 3.3.4.1 NA NA No Pb monitors 

samplers audit plan.

33. Frequency of one-point QC check (gaseous) App. A 3.2.1 Yes, pg 39 Yes “. . .precision ch

and some distric

weekly at other 

analyzed by QM

34. Date oflast Annual Performance Evaluation App. A 3.2.2 Yes, Table 11 pg Yes

(gaseous) 40

35. Dates oflast 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 oflast two semi-annual flow rate audits for Pb App A 3.3.4.1 NA NA No Pb monitors 

monitors V

.

plan.

37. PM2.5collocation App A 3.2.5 Yes, but incorrect. Yes for some Table 9 The num

Pg 34-35. methods, no for requirements fo

other methods (see 145 appear to be 

notes) to tell ifthe coll

Appendix A sec

.

collocation at m

must be provide

Table 10 Colloc

PM2.5FEM and 

that not all conti

being met for m

V

that collocation 

number of prima

Monitors used to 
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

requirements sho

designated as the 

does not appear t

Fresno, or Thous

site meeting the F

It is unclear whic

and neither site a

AQS information

listed in AQS as 

instrument, but is 

(06-047-25 10) is 

filter (118) instru

The plan states th

collocation requi

38. Designation of a primary monitor ifthere is more Need to No No Information not 

than one monitor for a pollutant at a site. determine

collocation

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

request or the date of previous waiver approval must 3.2.5.6 and

be included ifthe distance deviates from 3.2.6.3

requirement.)

40. Manual PM10 method collocation met? (note: App A 3.3.1 Yes, pg 36 No As stated in the p

continuous PM10 does not have this requirement) fulfilling this req

41. Pb collocation App A 3.3.4.3 NA NA No Pb monitors 

plan.

42. PM102 .5collocation (note: only applies to Fresno and App A 3.3.6 NA NA Fresno NCore in

Phoenix NCore sites) addressed in this 

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 co

an MSA/CSA: does each affected State or local Area AQM]) and 

agency meet full monitoring requirements or is where ARB relie

an agreement between the affected agencies and the meet minimum m
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

EPA Regional Administrator in place 9 agreement shoul

: ARE & BAAQM

- Santa R

- Vallej 0

ARE & SCAQM

-

Los An

I Angele

. - Riversi

(Rivers

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 

determine if 11 -16 in some instances required, they sh

other req. example, Grass 

(e.g., mm # Station (06-057-

and colloc) Portola (06-063

are met FEM PM2.5mon

therefore should 

47. Monitoring objective for each instrument App D 1.1 Yes. Table 3, pg Yes, but incorrect All sites collecti

58.10 (b)(6) 1 1-16 in some instances “NAAQS comp

have multiple m

future plans.

48. Site type for each instrument App D 1.1.1 Yes. Table 3, pg Yes, but incorrect Sites being used 

1 1-16, and pg 37. in some instances maximum conce

concentration) s

types listed in b

Rows 57, 66 an

49. Instrument parameter code for each instrument Required to Yes. Table 3, pg Yes Please clarify w

determine if 1 1-16 & Table 4, that 88501 cann
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

other req. pg 19-24. NAAQS. Ifthere 

(e.g., mm # the table that onl

and colloc) called out. EPA m

are met or ARM monitor

submitted to AQS 

Also, please clari

monitors are used 

50. Instrument parameter occurrence code for each Required to Yes. Table 4, pg Yes, incorrect in Believe PM10 at R

instrument determine if 19-24 one instance 089-0004) should 

other req.

(e.g., mm #

and colloc)

are met

51. Sampling season for ozone (note: date ofwaiver 58.10 (b)(4) Yes. pg 43. Yes Seasonal for Coo

approval must be included ifthe sampling season App D, 4.1(i) Buttes, White Cl

deviates from requirement) was attached), an

email May 2, 20

52. Sampling schedule for PM2.5- applies to year-round 58.10 (b)(4) Yes. Table 12. Pg No in some The design value

and seasonal sampling schedules (note: date of 58.12(d) 42-43 instances needed to correct

waiver approval must be included ifthe sampling App D 4.7 future plans, plea

season deviates from requirement) EPA lists annual and 2

flowchart based PM2.5sites

FRMs that are op

schedules and ar

instrument. ARB 

address sampling 

network.

53. Sampling schedule for PM10 58.10 (b)(4) Yes, but Insufficient to 1:6 sampling for 

58.12(e) incomplete. Pg 42 judge the concentration 

App D 4.6 above 1.4 — conc

provided to deter

met.

54. Sampling schedule for Pb 58.10 (b)(4) NA NA

58.12(b)

App D 4.5

55. Sampling schedule for PM102 .5 58.10 (b)(4) NA NA
Citation

within 40

CFR 58

Was the info

submitted?’ If

yes, page #s.

Flag if

incorrect 2?

Does the

information

provided 3meet

the req? 4

7Onlymonitors considered to be required SLAMS are eligible to be counted towards meeting minimum monitoring requirements. In addition, o

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

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 th

supported by MSA ID, MSA population, DV, # and pg 59. minimum monit

monitors, and # required monitors] (see footnote) 7 Table D-2 includes all exce

with and withou

provided.

Please explain w

. Buttes are not li

Identification of max. conc. 03 monitor(s) App D 4.1 (bI Yes. Table 3, pg Yes; no in some There should be 

I 1-16; Appendix Fl instances site for each rele

pg 59. than one, ifthe h

At a minimum, 

on pg 59 to be li

site for the MSA

Paradise as the D

listed as the DV 

Almond is listed 

as highest conce

as “General.” In 

requirement is m

Minimum monitoring requirements met for near-road App D 4.3.2 NA, pg 29-30 NA Sites not include

NO2(2014 start date)

Minimum monitoring requirements met for area- App D 4.3.3 NA, pg 29-30 NA Sites not include

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

NO2

Minimum monitoring requirements met for SO2 App D 4.4 NA, pg 31 NA Sites not include

[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 include

62.1
ANP requirement Citation Was the info Does the Notes

V within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

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 PM2.5[Note I: should be App D, Yes, pg 60 Yes The design value 

supported by MSA ID, MSA population, DV, # 4.7.1 (a) and monitoring requir

monitors, and # required monitors] [Note 2: Only Table D-5 selected by looki

monitors considered to be required SLAMs are SLAMS monitor 

eligible to be counted towards meeting minimum network

monitoring requirements.] V

VVVV

V

Please ensure tha

minimum monito

mcludes all excep

with and without 

• V V

provided.

64. Optional PM2.5Nehvork Clarifications: Provide a list Need to NA NA

ofrequired sites ifit does not include all SLAMS. assess several 

[Note: default will assume all SLAMS are considered requirements - 

required sites.] V

65. Required PM2.5sites represent area-wide air quality App D Yes. Table 4 pg 19- Yes All PM2.5monito

4.7.1(b) 24. neighborhood or 

66. For PM2.5,is at least one site at neighborhood or App D Yes. pg 37; table 3, Yes; no in some There should be 

larger scale in an area of expected maximum 4.7.1 (b)( 1) pg 1 1-16. instances, as maximum con

concentration MSA. For the Ch

the DV site; for R

listed as the DV 

Almond is listed 

on pg 37 as a ma

these sites are lis

types in Table 3.

67. If additional SLAMS PM2.5required, is there a site in App D Yes. pg 60, Tables NA The MSAs with 

an area ofpoor air quality 4.7.1(b)(2) 3 and 4 required are Bak

Anaheim, Rivers

Sacramento-Arde

are covered by se

V

agencies and so a

68. Minimum monitoring requirements for continuous App D 4.7.2 Yes, pg 61 Yes Please ensure tha
ANP requirement Citation Was the info Does the Notes

‘ within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

PM2.5 I minimum monit

. includes all exce

with and withou

provided.

Note: Other pia

plan) must be re

some ofthe spe

69. Requirements for PM2.5background and transport App D 4.7.3 Yes. pg 37; table 3 Yes Per the commen

sites (pg 1 1-16) background and 

in Table 3 as we

Several sites list

identified as “G

.4 as a transport sit

which

is identifi

4 37 and is includ

“General,” not a

70. Are PM2.5Chemical Speciation requirements met for App 1) 4.7.4 No. Insuiiicien( The plan does n

official SIN sites? information please provide a

and specifics on 

covered by this 

Portola).

71. Minimum # ofmonitors for PM10 App D, 4.6 Yes, pg 62 Yes Please ensure th

(a) and Table minimum monit

D-4 includes all exce

with and withou

provided.

72. Minimum monitoring requirements met for PM102 .5 App D 4.X No Insuflicient While the plan d

mass information does not specific

73. Distance of site from nearest road App E 6 No — pg 18 Insufficient Not included in 

information

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

information

75. Groundcover App E 3(a) No — pg 18 Insufficient Not included in 
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

information

76. Probe height App E 2 No — pg 18 Insufficient Not included in th

information

77. Distance from supporting structure App E 2 No — pg 18 Insufficient Not included in th

information

78. Distance from obstructions on roof App E 4(b) No — pg 18 Insufficient Not included in th

information

79. Distance from obstructions not on roof App E 4(a) No — pg 18 Insufficient Not included in th

information

80. Distance from trees App E S No — pg 18 Insufficient Not included in t

information

81. Distance to furnace or incinerator flue App E 3(b) No — pg 18 Insufficient Not included in th

information

82. Unrestricted airflow App E, 4(a) No — pg 18 Insufficient Not included in t

and 4(b) information

83. Probe material (if applicable) App E 9 No — pg 18 Insufficient Not included in t

information

84. Residence time (if applicable) App E 9 No — pg 18 Insufficient Not included in t

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 ofthe 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 ofthe annual network plan that received substantive comments approvable after consideration o

o If yes, provide rationale: