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 the

### enclosed 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 Board

### 1 Attachment A : Annual Air Monitoring Network P lan C hecklist

Year: 2012 Agency : South Coast AQMD

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 speciati on stations, SPM stations, and/or, in serious, severe and extreme ozone nonattainment areas, PAMS stations, and SPM monitor ing 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 applicab le. ” 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 R egion 9 will not take action to approve or disapprove any item for which Part 58 grants approval authority to the Admin istrator rather than the Regional Administrators, but we will do a check to see if the required information is included and correct. The items requiri ng approval by the Administrator are: PAMS, NC ore, Speciation (STN/CSN), and NO2 requirements including ne ar road, area

- wide, and RA40

. Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requ irements, 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 and no action requested Yellow = does not meet or cannot judge the requirement

– action requested in next year’s plan or outside the ANP process Green = meets the requirement but action requested to improve next year’s plan

### 2

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

1. Submit plan by July 1 st 58.10 (a)(1) Yes

– submitted 7/13/2012 per cover letter and email. Yes

– network plan

was submitted, although it was 12 days late. 2. Statement of purpose for each monitor 58.10 (a)(1) Yes with some incorrect information Pages 19

- 20 (Tables 3

- 4) Incorrect: Some information does not match detailed site reports Yes Tables 3

- 4 have a heading that indicates that the information includes “Monitoring Purpose.” The information that is given is act ually 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). Note: Detailed site reports list “monitor objective” which should really be “site type” 3. 30

- day public comment / inspection period 5 58.10 (a)(1), 58.10 (a)(2) Yes

Page 1 Yes

4. M odifications to SLAMS network

– case when we are not approving actual system modifications (i.e., we will do it outside the ANP process 6 ) 58.10 (a)(2) 58.10(e) Yes

Pages 10

- 13 Yes Does not constitute approval of changes

5. M odifications to SLAMS network

– case when we are approving actual system modifications per 58.14(c) 58.10 (a)(2) 58.10 (b)(5) 58.10(e) 58.14 (c) N/A N/A Not judging modifications per 58.14 since not enough information was provided.

6. Does plan include documentation (e.g., attached approval letter) for system modifications that have been approved since last ANP approval? Yes Page 1 Yes No new sites or sites closed in 2012 so no documentation for system modification needed.

7. NCore site operational ( by 1/1/2011 ) 58.10 (a)(3) Yes Page 9 Yes

1 Response options: Yes, No, Incomplete, Incorrect. The responses “Incomplete” and “Incorrect” assume that some information has been provided.
2 To the best of our knowledge.
3 Assuming the information is correct
4 Response options: NA (Not Applicable)

– [r eason], Yes, No, Insufficient to Judge.
5 The affected state or local agency must document the process for obtaining public comment and include any comments received t hrough the public notification process within their submitted plan.
6 See 58.14(c)

### 3

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

8. Pb site for 0.5

- 1.0 tpy sources operational ( by 12/27/2011 ) 58.10 (a)(4) I ncomplete Page 5 Incomplete It’s not clear which requirements the particular sites are meeting (e.g., area

- wide, > 1tpy, 0.5

- 1 tpy) so the information is insufficient to judge the requirement. 9. NO2 plan for area

- wide and RA40 sites submitted by 7/1/2012 58.10 (a)(5) No N/A

– HQ approval EPA did not request RA40 sites prior to ANP due date. 10. NO2 plan for near

- road sites submitted by 7/1/2012 58.10 (a)(5) N o

– incomplete Pages 10

- 12 N/A

– HQ approval Information was not detailed enough to approve the required NO2 near

- road sites. A separate plan, outside the ANP process will be required to fulfill this req. 11. AQS site identification number for each site 58.10 (b)(1) Yes Page 17 (Table 1) Plus App B

– under “Detailed Site Information” Yes

12. Location of each site: street address and geographic coordinates 58.10 (b)(2) Yes App B

– under “Detailed Site Information” Yes

13. Sampling and analysis method(s) for each measured parameter 58.10 (b)(3) Yes for most cases. There are few cases where incorrect or incomplete information was provided in the detailed site tables

– these are listed in the notes. App B

– under “Detailed Site Information” Yes

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

- Reseda: Analysis method for PM2.5 non

- FEM BAM should be "beta attenuation"

- see Riverside

– Magnolia

- W. LA: There is a TSP sampler that is listed as "Tisch" for instrument/manufacturer/model and ICPMS for a nalysis 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.

14. Operating schedule for each monitor (see items 44

- 48 ) 58.10 (b)(4) Y es App B

– under “Detailed Site Information” Insufficient to

judge for PM2.5 and PM10 See items 45 and 46 of this checklist.

15. Any proposals to remove or move a monitoring 58.10 (b)(5) Yes Yes App B has 18 month timeframe

### 4

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

station within a period of 18 months following plan submittal Page 10 ; App B

– under “Detailed Site Information” 16. S cale of representativeness for each monitor as defined in Appendix D 58.10(b)(6); App D Yes in most cases.

Incomplete information for the sites listed in the
notes. Page 18 (Table 2); App B

– under “Detailed Site Information” Yes in most cases.

There some cases listed in the notes where the information provided is insufficient to judge the requirement. - LAX Hastings : Middle scale is listed for O3 but

middle scale is not typically an appropria te scale for O3 (see 40 CFR 58, App. D, Section 4.1(c)).

- Long Beach (North): See LAX Hastings for O 3

. PM10 listed as middle scale i n detailed site sheet but micro

- scale i n Table 2. PM2.5 manual monitor listed as neighborhood scale but PM2.5 FEM BAM listed as middle scale for the same site

– these should be the same scale

. Perris: Neighborhood scale is listed for ozone. T raffic counts and distance are given for arterial road

- which is closest

- but not for fwy 215 which is also very close. Scale for ozone may not be appropriate given distance to fwy 215, which has 79,617 AADT. Distance to fwy 215 would have to be >100m.

- Pico Rivera: ANP says traffic count is given for arterial road but not for San Gabriel Pkwy . Given proximity to San Gabriel Pkwy., distance and traffic count are needed to judge appropriateness of ozone scale.

- Pomona: see comment for LAX Hastings.

- Riverside: NO2 listed as US in Table 2 but NS in App. B.

- Rubidoux: Are the non

- N C ore CO and NO2 instrument s closer to the road? If both CO instruments have same source mix then they should have the same scale.

- W. LA: The TSP pollutant analyzed by ICPMS appears to be Pb but scale for Pb is not given in Table 2. 17. Identification of sites suitable and sites not suitable 58.10 (b)(7) Yes for most cases. Yes for most cases.

- Anaheim: Even when FEM BAMS are co

- located

### 5

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

for comparison to the annual PM2.5 NAAQS as described in Part 58.30 In correct information for the sites listed in the
notes. Page 7 ; App B

– under “Detailed Site Information” Incorrect

information should be corrected. with a primary manual sampler, these data could

potentially be used for comparison to the annual NAAQS if the primary monitor is down since FEM BAM data would be automat ically substituted. Recommend changing App B tables to Yes for FEM BAMS with a footnote indicating that regulatory data is collected by the manual sampler unless the manual sampler has missing data. Also, suggest N/A for SASS samplers.

- Azusa: suggest “N/A ” instead of “no” for VOC.

- Banning: suggest “N/A” instead of “no” for non

FEM BAM.

- Burbank: See Anaheim note and also note incorrect FRM frequency listed.

- Lake Elsinore: see Banning.

- Long Beach (North): See Anaheim

- South Long Beach: See Anaheim

- LA Ma in: See Anaheim. Also suggest NA for PM10 rather than “no.”

- Rubidoux: suggest “N/A” instead of “no” for PM10 BAM.

- W. LA: suggest “N/A” instead of “no” for TSP. 18. MSA, CBSA, CSA or other area represented by the monitor 58.10 (b)(8) Yes for most cases. There are a few instances of incomplete information listed in the notes. Yes for most cases.

Incomplete information should be completed. - ATSF: Identify area as MSA (vs. CSA or other

type of area)

– see Anaheim for example.

- Closet World (Quemetco): same a s ATSF.

- Long Beach (North): same as ATSF.

- Rehrig: same as ATSF

- Uddeholm: same as ATSF

- Upland: same as ATSF 19. D esignation of any Pb monitors as either source

oriented or non

- source

- oriented 58.10 (b)(9) No Insufficient to judge It’s not clear which requirements the particular

sites are meeting (e.g., area

- wide, > 1tpy, 0.5

- 1 tpy). 20. Any source

- oriented Pb site for which a waiver has been granted by EPA RA 58.10 (b)(10) NA NA

21. Any Pb monitor for which a waiver has been requested or granted by EPA RA for us of Pb

- PM10 58.10 (b)(11) NA NA

### 6

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

in lieu of Pb

- TSP 22. Document how states and local agencies provide for the review of changes to a PM2.5 monitoring network that impact the location o f a violating PM2.5 monitor. 58.10 (c) No Insufficient to judge This information wa s not provided.

23. Precision/Accuracy reports submitted to AQS 58.16(a); App A , 1.3 and 5.1.1 No Insufficient to judge This information was not provided.

24. Annual data certification submitted 58.15 App. A 1.3 No Insufficient to judge This information was not provided.

25. Frequency of flow rate verification for manual PM samplers audit App A 3.3.2 Yes for most cases. Incorrect information for one site (see notes). App B

– under “Detailed Site Information” Yes for most sites.

Correct incorrect information. - Lake Elsinore: PM10 TEOM should be NA for

this.

26. Frequency of flow rate verification for automated PM analyzers audit App A 3.2.3 Yes Yes

27. Frequency of one

- point flow rate verification for Pb samplers audit App A 3.3.4.1 Yes for some

cases, incomplete for cases listed in the notes. App B

– under “Detailed Site Information” Yes for cases

where information was complete. Insufficient to judge for incomplete informatio n. - Closet World (Quemetco): the frequency of the

flow rate verification was not provided. For ATSF this information was given under “manual PM samplers ”

.

- South Long Beach: see Closet World.

- Rehrig: see Closet World

.

- Van Nuys Airport: See Closet World. 28. Frequency of one

- point QC check (gaseous) App. A 3.2.1 Yes App B

– under “Detailed Site Information” Yes

29. Date of last Annual Performance Evaluation (gaseous) App. A 3.2.2 Yes Yes 30. Dates of last two semi

- annual flow rate audits for PM monitors App A

, 3.2.4 and 3.3.3 Yes for most cases.

Incomplete information given for cases listed in
notes. App B

– under Yes for cases

where information was complete. Insufficient to judge for incomplete Note that flow audits > 7 mos. apart (e.g.,

Anaheim , Banning , Big Bear , Burbank , Compton

, Crestline , Indio, etc. ) will not be accepted by AQS as valid and could therefore impact certification documentation (i.e., P/A reports)

### 7

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

“Detailed Site Information” information.

- Mira Loma: Flow rate audits given as NA for 3 PM2.5 instruments

- one of these started in 2012 but the others started in 2005 and should have 2 audit dates.

- Riverside: Why is one date for PM10 given as NA?

- W. LA: Not sure if TSP monitor is for PM or Pb but either way, the information is not given. 31. Dates of last two semi

- annual flow rate audits for Pb monitors App A 3.3.4.1 Yes for most cases.

Incomplete / incorrect information given for cases listed in
notes. App B

– under “Detailed Site Information” Yes for cases

where information was complete. Ins ufficient to judge for incomplete information. Note that flow audits > 7 mos. apart (e.g., South

Long Beach) will not be accepted by AQS as valid and could therefore impact certification documentation (i.e., P/A reports)

- Rehrig (Exide): listed as schedul ed but with a start date of 11/07, there should have been previous flow audits.

- Van Nuys Airport: dates of semi

- annual flow audits not given.

- W. LA: Not sure if TSP monitor is for PM or Pb but either way, the information is not given. 32. PM2.5 co

- location App A 3.2.5 Incomplete Page 15 Insufficient to

judge See Attachment B of the 2012 ANP memo. There

are 20 FRMs and 3 co

- located monitors according to Table 3 (meets 15% co

- location) but method code is needed to determine if they are all the same method code. There are no FEMs designated as primary monitors. Each MSA should have one continuous monitor

co

- located with an FRM

– App. B tables indicate that multiple continuous monitors are co

- located with FRMs but this should be reflected in the co

location t ables.

Co

- located sites should also be verified in the ANP of meeting the requirement that 80% of the co

located monitors are located at sites with PM2.5 concentrations within 20% of NAAQS?

### 8

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

33. Distance between co

- l ocated monitors App. A 3.2.5.6 Yes for most cases.

Incomplete / incorrect information given for cases listed in
notes. App B

– under “Detailed Site Information” Yes for cases

where information
was comp lete. Insufficient to judge for cases listed in notes

. - Long Beach (North): The PM10 monitors have

different co

- location distances even though they are presumably co

- located with each other. PM2.5 monitors have a co

- location distance of 46m

- is that correct?

- South Long Beach: PM2.5 monitors list a co

location distance of 1.5 m, which is only allowed if flow rates are <200 lpm

– please note if this is the case.

- Palm Springs

– the PM10 SSI has a c

- location distance listed as 2.1 m but the PM10 TEOM has a

co

- location distance listed as NA, even though they are presumably co

- located

.

- Rehrig: Distances between the 3 Pb TSP monitors should be given.

- Rubidoux: Co

- lo cated monitors are listed as 1 m (FEMs) and 1.5 m (FRMs) apart which is only ok with flow rates <200 l/m

. 34. Manual PM10 method co

- location met? (note: continuous PM10 does not have this requirement) App A 3.3.1 Yes Page 3 Yes 21 manual monitors = 3.15 co

- located monitors. SCAQMD has 4. 35. Pb co

- location App A 3.3.4.3 Yes for #

N for highest site Page 4 Yes for #;

insufficient to judge for highest site. 15 sites = 2.25 sites. SCAQMD has 4. It is not

identified which is highest site so it cannot be determined if that part of the requirement is met.

36. PM10

- 2.5 co

- location (note: only applies to Fresno and Phoenix NCore sites) App A 3.3.6 NA NA

37. Instrument/monitoring method code for each monitor: is it reported properly? Is it reported correctly (i.e., appropriate method code for regulatory monitors)? App C 2.4.1.2 Incomplete information in almost all cases. App B

– under “Detailed Site Info rmation” Insufficient to

judge. Method code not provided for most monitors. For

example:

- Anaheim: CO, NO2, O3, PM10 manual, speciation, and PM2.5 manual

- ATSF: Pb

- Azusa: PM10

- SSI, PM2.5 RAAS. Could put "multiple" for metals, carbonyls, etc.

- Banning: NO2, O3, PM10

- Big Bear: PM2.5 FRM

- Burbank: PM10

- SSI, PM2.5 RAAS, and PAMs

### 9

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

and toxics . Also note that pollutant type for cont. PM10 (method code 079) is listed as “TEOM”

– add “PM10” to title for pollutant.

- Closet World (Quemetco): Pb

- Compton: all pollu tants

- Costa Mesa: all pollutants

- Crestline: ozone and PM10

- Fontana: all pollutants

- Glendora: O3, NO2, CO

- Indio: O 3 and all PM except the PM

- 10 TEOM

- La Habra: all pollutants

- Lake Elsinore: O3, NO2, CO

- LAX Hastings: all pollutants

- stopped listing mi ss ing method codes at LAX Hastings

. 38. Start date for each monitor Required to determine if other req. (e.g., min # and co

- lo) are
met Yes

App B

– under “Detailed Site Information” Yes

- Long Beach (North): S tart dates missing for PM instruments, ARB Toxics 910, and PM2.5 FEM BAM.

39. Instrument monitor type for each monitor Required to determine if other req. (e.g., min # and co

- lo) are
met Incorrect

App B

– under “Detailed Site Information” Insufficient to

judge App B “Detailed Site Information” has a no field

for ‘monitor type’ but monitor type information is given under the field of ‘site type’. See 2012 ANP memo, Attachment D

40. Monitoring objective for each instrument App D 1.1 58.10 (b)(6) Incorrect

Tables 3

- 4 App B

– under “Detailed Site Information” Insufficient to

judge App B “Detailed Site Information” has a field for

"monitor objective" that actually lists EPA site type s

. Information in Tables 3

- 4 listed as “monitor purpose” (which is really site type) information appears to be “monitor objective” in the App B tables. There are inconsistencies between the information provided in Tables 3

- 4 and App B “monitor objective.” Table 2 has information for “monitor objective” but this does not match EPA’s

### 10

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

definition of monitor objective and is also different from the information provided under App B tables under the field of “monitor objective”. See 2012 ANP memo, Attachment D 41. Site type for each instrument App D 1.1.1 Incorrect App B

– under “Detailed Site Information” Insufficient to

judge App B “Detailed Site Information” has a field for

" site type " that lists monitor type

. See 2012 ANP memo, Attachment D

42. Instrument parameter code for each instrument Required to determine if other req. (e.g., min # and co

- lo) are
met Incomplete

App B

– under “Detailed Site Information” Insufficient to

judge Parameter code not provided for any monitors.

43. Instrument parameter occurrence code for each instrument Required to determine if other req. (e.g., min # and co

- lo) are
met Yes for most cases.

Incomplete / incorrect information given for cases listed in
notes. App B

– under “Detailed Site Information” Yes for cases

where information was complete. Insufficient to judge for incomplete / incorrect information. - POC not provided for all monitors (e.g., Anaheim

PM10 manual ).

- Rehrig: Incorrect POCs given. All 3 monitors are listed as POC 1 but each is actually a different POC.

- Riverside: Incorrect POCs given. The 2 monitors are listed as POC 1 but each is actually a different POC.

- Rubidoux: Numerous pollutants with of the same parameter have the same parameter occurrence code

- these should be different. 44. Sampling season for ozone (note: date of waiver approval must be included if the sampling season deviates from requirement) App D, 4.1(i) Yes App B

– under “Detailed Site Information” Yes

45. Sampling schedule for PM2.5

- applies to year

- round and seasonal sampling schedules (note: date of waiver approval must be included if the sampling season deviates from requirement) 58.12(d) App D 4.7 Yes for schedule

No for DV and continuous monitors Page 21 App B

– under “Detailed Site Insufficient to

judge at sites that are not operated at 1:1 Requirement is for 1:1 sampling if DV is within

5% of NAAQS at required sites. Need to know DV site(s) and c onc. to judge whether sites should be at 1:1. Also, it should be noted if any of these sites are co

located with cont. FEM to make it 1:1 or if there are any cont. FEM sites not co

- located with FRM

### 11

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

Information” as primary.

- Burbank and Mira Loma PM2.5 manual samplers listed as 1: 3 sampling frequency but AQS shows 1:1. 46. Sampling schedule for PM10 58.12(e) App D 4.6 Y es for schedule

N o for justification of schedule Page 3 App B

– under “Detailed Site Information” Insufficient to

judge. The site that represents the max. concentration for

the area is required to operate on the schedule prescribed by 58.12 Figure 1. There is no information to justify the sampling schedule per 58.12

– a comp arison to Fig. 1 is needed for max. concentration sites.

47. Sampling schedule for Pb 58.12(b) App D 4.5 Yes

App B

– under “Detailed Site Information” Yes

48. Sampling schedule for PM10

- 2.5 58.12(f) App D 4.8 Incomplete

Page 9 App B

– under “Detailed Site Information” Insufficient to

judge There is not enough information in either the

background on NCore (page 9) or the detailed site descriptions to determine which instruments are being used for the PM10

- 2.5 measurements. Therefore, neither the compatibility of the instruments nor the adequa cy of the sampling schedule can be determined. Recommend addressing PM10

- 2.5 under NCore section of plan. 49. Minimum # of monitors for O3 [Note: should be supported by MSA ID, MSA population, DV, # monitors, and # required monitors] App D, 4.1 (a) and Table D

- 2 Y es on min # O3,

except for incorrect inclusion of middle

- scale sites N o on DV information Page 13 Yes ANP includes note that DV>85% but actual DV should be included with a DV site identified. Requirement can be determined to be met since both areas are required to have the most number per population that could be required per CFR.

Note that sites that are too close to roadways that

are middle and micro

- scale sites (i.e., LAX Hastings, Pomona, and West LA) are not suitable for comparison to the NAA QS and should therefore not be included in minimum monitoring numbers.

### 12

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

50. Identification of max. conc. O3 monitor(s) App D 4.1 (b) Yes

– sites are identified as “highest concentration” sites Table 2 App B

– under “Detailed Site Information” Yes

51. Minimum monitoring requirements met for SO2 App D 4.4 Yes Page 14 Yes

52. Minimum monitoring requirements met for Pb App D 4.5 58.13(a) Yes

Pages 14

- 15 Yes

53. Minimum # of monitors for PM2.5 [Note: should be supported by MSA ID, MSA population, DV, # monitors, and # required monitors] App D

, 4.7.1(a) and Table D

- 5 Incorrect

information is given on min # PM2.5 N o on DV information Page 15 Yes

– they have

many more than would be required

even u nder the most stringent scenario The table is given per PQAO but the minimum

monitoring requirements for PM2.5 are per CBSA. See note for 67 re. DV #. ANP needs to include a statement (e.g., footnote) that all cont. FEMs are co

- located with manual samplers . Otherwise a new table should be made that combines total FRM/FEM monitors. 54. Required PM2.5 sites represent community

- wide air quality App D 4.7.1(b) Yes

Table 2 Table 3 Yes Please note in future plans: All the manual PM2.5 instruments are neighborhood scale (Table 2) and population exposure (Table 3), thus representing community

- wide air quality 55. For PM2.5, is at least one site in a population

- oriented area of expected maximum concentration App D 4.7.1(b)(1) Yes

Table 3 Yes Please note in future plans: Multiple sites are listed as population exposure and high concentration. 56. If >1 SLAMS PM2.5 required, is there a site in an area of poor air quality App D 4.7.1(b)(2) No Yes Please note in future plans: 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. 57. Minimum monitoring requirements for continuous PM2.5 App D 4.7.2 Yes for total number Incomplete information for co

location, including continuous instruments Table 4 Yes for total

number

– they have many more than would be required even under the most stringent scenario. Insufficient to There is one co

- located BAM (it’s not specified

whether it’s FEM or not) listed in Table 4. The table for continuous PM2.5 monitoring (page 15) lists one non

- FEM BAM for co

- location. It is not clear what the footnotes mean. Continuous monitors are required to be co

- located with both FRM and other FEM samplers. See Attachment B of 2012 AN P memo.

### 13

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

Page 15 judge for co

location. 58. Requirements for PM2.5 background and transport sites App D 4.7.3 NA

– State

- level requirement N/A

– State

- level

requirement 59. Are PM2.5 Chemical Speciation requirements met for official STN sites? App D 4.7.4 Yes for # Pages 8 and 16 Sampling frequency found in App B “Detailed Site Information” Yes Official CSN sites should be identified in ANP as Rubidoux and LA N. Main (both sites operating at 1:3).

60. Minimum # of monitors for PM10 App D , 4.6 (a) and Table D

- 4 Incomplete

information

- concentration and site info needed. Page 14 Insufficient to

judge for Coachella Valley Incorrect information for total monitors ANP includes note that one MSA is med.

concentration and the other MSA is high concentration. The max concentration value for the DV site, with the DV site identified, should be included. Requirement for LA MSA can be determined to be met since the are a h as enough sites to satisfy the most stringent number of sites per Table D

- 4. The requirement for the Coachella Valley cannot be judged at this time since a site may be required in the Southern Coachella Valley as the DV site. The minimum monitoring table for PM10 on page 14 says there are a total of 21 PM10 monitors when there are actually 25 regulatory monitors operated by SCAQMD

– please correct in next year’s plan. 61. Minimum monitoring requirements met for PM10

- 2.5

mass App D 4.8 No Insufficient to judge See item 48.

62. Distance of site from nearest road App E 6 Yes for most cases. Incomplete information given for cases listed in
notes. App B

– under “Detailed Site Information” Yes for cases

where information was complete. Insufficient to judge for incomplete information. The following roads are not the closest to the

monitoring sites but are close enough to potentially influence measurements and so distance and traffic counts should be listed:

- Anaheim

- I

- 5

- Azusa

- I

- 210

- Banning

- I

- 10

- Burbank

- I

- 5

### 14

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

- Compton

- I

- 5

- Perris

- I

- 215

- Pico Rivera

- San Gabriel Pkwy

- Rubidoux

- 60

Long Beach (North): The distance to the road is given as 8

- 55 m. Some microscale pollutants have more specific allowable ranges. The distance to the road for the near

- road pollutants should be given. 63. Traffic count of nearest road App E Yes for most cases. Incomplete information given for cases listed in
notes. App B

– under “Detailed Site Information” Yes for cases

where information was complete. Insufficient to judge for incomplete information. See comments for 85.

64. Groundcover App E 3(a) Yes Yes 65. Probe height App E 2 Yes all but one case. Incorrect information given for case listed in
notes. App B

– under “Detailed Site Information” Yes for cases

except that in
notes. Insufficient to judge for incorrect information. - Upland: "All year" listed as probe height for

BAM PM2 .5 non

- FEM

.

66. Distance from supporting structure App E 2 Yes Yes In some cases (e.g., Indio), a colon is used in place of a period (?). 67. Distance from obstructions on roof App E 4(b) Yes Yes 68. Distance from obstructions not on roof App E 4(a) Incomplete information for cases where obstacle was present. App B

– under “Detailed Site Insufficient to

judge for cases where an obstacle

was present. Need height above obstacle, in addition to distance

to obstacle, to judge whether this requirement is met (e.g., Anaheim, Long Beach (North), Mission Viejo PM, Reseda).

### 15

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

Information” 69. Distance from trees App E 5 Yes Yes except those cases listed in
notes. Crestline is critical to address. - Anaheim: CO, NO2, O3, PM2.5 BAM, and PM10

BAM are all within 6m of a tree

– if it’s the trunk of a palm (seen in a picture) then make a note

.

- Crestline: all pollutants are within 10m of trees

– for ozone this site is the DV site for the SC Basin and it is critical to fix this.

- La Habra: site description indicates trees within 3m but pictures suggest that they are below the height of the probe. If this is the case, note how much below they are.

- Long Beach (North): All pollutants within 10 m of trees (6 m). See above notes.

- Pasadena: All pollutants within 10 m of trees (6 m). See above notes. 70. Distance to furnace or incinerator flue App E 3(b) Yes Yes 71. Unrestricted airflow App E , 4(a) and 4(b) Yes all but one

case. Incorrect information given for case listed in
notes. App B

– under “Detailed Site Information” Yes for cases

except that in notes. Insufficient to judge for incorrect information. - Redlands: "Teflon" listed for PM10 , which is th e

probe material rather than whether there is unrestricted airflow

.

72. Probe material (if applicable) App E 9 Yes all but one case. Incorrect information given for case listed in
notes. App B

– under “Detailed Site Information” Yes for cases

except that in notes. Insufficient to judge for incorrect information. - Temecula: Probe material is listed as “N/A” for

ozone but needs to be given.

73. Residence time (if applicable) App E 9 Yes all but one case. Incorrect information given for case listed in Yes for cases

except that in notes. Insufficient to judge for - LA (Main): Residence time for NCore CO and

NO2 listed as NA.

### 16

ANP requirement Citation within 40 CFR 58 Was the info

submitted? 1 

### If yes, page #s

. Flag if in correct 2 

### ? Does the

information provided 3 

### meet the req ? 4 

### Notes

notes. App B

– under “Detailed Site Information” incorrect

information.

74. 75. Not required as part of plan but good to check 76. For SPMs listed as non

- regulatory, note the start Date of FRM/FEM/ARM at SPM. If > 24 months, agency must supplyinformation that App A, C or E requirements were not met. 58.20(c)

– (e) NA No PM2.5 SPMs

77. 78.



### Public Comments on Annual Network Plan Were comments submitted to the S/L/T agency during the public comment period? Yes. One set of comments was submitted jointly by Breathe California, Communities for a Better Environment, and Natural Resou rces Defense Council.

If no, skip the remaini ng questions. If yes:

 Were any of the comments substantive? Yes

o If yes, which ones? The comments were primarily concerned with monitoring pollution near heavily

- trafficked areas. The substantive comments related to the ambient air monitoring network are th ose regarding PM2.5 and NO2 near

- road monitoring.

o Explain basis for determination if any comments were considered not substantive: Comments that were not related to the ambient air monitoring network (e.g., planning issues such as the “black box”) were not considered substantive for the annual monitoring network plan.

 Did the agency respond to the substantive comments?

o If yes, was the response adequate? Yes

 Do the substantive comments require separate EPA response (i.e., agency response wasn’t adequate)? No

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

### 17

o If yes, provide rationale: Yes. The comments did not provide compelling information to alter the current or proposed near

- road monitoring networks.

General Notes

 The pictures and maps are very helpful and informative.

### Attachment 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 judge

### Identification of sites suitable

and sites not suitable for comparison to the annual PM2.5 NAAQS 17 Insufficient information to judge for some monitors

Frequency of one

- point flow rate verification for Pb samplers audit 27 Insufficient information to judge for some sites

Annual data certification submitted 24 Insufficient information to judge

Site type for each instrument 41 Insufficient information to judge Sampling schedule for PM10 46 Insufficient information to judge Distance of site from nearest road 62 Insufficient information to judge for some

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

cases Distance from obstructions not on roof 68 Insufficient information to judge for some

cases Pb co

- location 35 Insufficient information to judge for highest site Distance between co

- located monitors 33 Insufficient information to judge for some sites Monitoring objective for each instrument 40 Insufficient information to judge

Instrument monitor type for each monitor 39 Insufficient information to judge

Frequency of flow rate verification for manual PM samplers audit 25 Insufficient information to judge for one site

Dates of last two semi

- annual flow rate audits for PM monitors 30 Insufficient information to judge for a few sites

Dates of last two semi

- annual flow rate audits for Pb monitors 31 Insufficient information to judge for a few sites

Instrument parameter occurrence code for each instrument 43 Insufficient information to judge for a few

cases

Document how states and local agencies provide for the review of changes to a PM2.5 monitoring network that impact the location of a violating PM2.5 monitor

. 22 Insufficient information to judge

Precision/Accuracy reports submitted to AQS 23 Insufficient information to judge

### Sampling schedule for PM10

-

2.5 48 Insufficient information to judge

Minimum monitoring requirements met for PM10

- 2.5 mass 61 Insufficient information to judge

Probe height 65 Insufficient information to judge for one

case Unrestricted airflow 71 Insufficient information to judge for one

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

case 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 PM2.5

### FEMs are being operated as primary monitors or as solely additional monitors where

FRMs are being operated. Due to this, it is difficult to crosswalk between minimum monitoring requirements and numbers of filter

- based and continuous FEM 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.