UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6

1445 ROSS AVENUE, SUITE '200

DALLAS TX 75202-2733

JAN 1 3 lulL

Ms. Mary Lou Leonard

Director, Environmental Health Department

City ofAlbuquerque

Post Office Box 1293

Albuquerque, New Mexico 87103

Dear Ms. Leonard:

Thank you for providing your correspondence for the City of Albuquerque's 2011 Annual

Monitoring Neh-york Plan. The U.S. Environmental Protection Agency (EPA) has completed its

analysis ofthe City of Albuquerque's 2011 Annual Monitoring Network Plan to ensure it meets

those requirements of 40 CFR Part 58 and its appendices that confer approval authority on the

Regional Administrator.

We appreciate your cooperation and work to submit your 2011 network plan. The EPA has

reviewed the proposed monitor designation changes to the City of Albuquerque Monitoring

Network, and I am pleased to infonn you that your 2011 network plan is approved. The network

assessment process presents an opportunity for the EPA and the City ofAlbuquerque to

collaborate on air monitoring network design. See 40 CFR Part 58 App. D, 1.1.2. Details

regarding our review of your air monitoring network are provided in the enclosure.

We look forward to our continued collaborative work with the City of Albuquerque on your

2012 ambient air monitoring network plan. If you have any questions, please contact me at

(214) 665-2100, or your staffmay contact Ms. Maria Martinez ofmy staff at (214) 665-2230.

A en z

Regional Administrator

\

Enclosure

Inlllfnet Addres$ (URLj • http:ltwww.epa.gov/regIOl16

Recycled/Recyclable. Printed with vegEllabfe 011 Ba$4Kllnks on 100% Recycled Paper, Process Chlorine Free
Technical Comments on the City ofAlbuquerque 2011 Annual Network Plan

Change Approvals:

Particulate Matter (PM)

We confinn that the PMlO monitor at the 2ZV South Valley site (Air Quality

System, AQS #35-001-0029) now meets the siting criteria and has been designated as

Stale or Local Air Monitoring Slations (SLAMS) as ofJanuary 1,2011 in AQS. Please

note any PMIO data collected at this site is now used for compliance with the PMlO

National Ambient Air Quality Stlndards (NAAQS).

According to the network plan, the PMI0 monitor at the 2ZH Nonh Valley site

(AQS #35-001-1013) does not meet siting criteria due 10 local minor sources. See 40

CFR Pan 58, App. E, 3(a). The City of Albuquerque is in the process of getting the site

into compliance with the siting requirements. In addition, the 2ZW Westside site (AQS

#35-001-0032) is a special purpose monitor intended to characterize the background prior

10 anticipated development. Therefore, Region 6 will not use the dala from Ihese PM 10

monitors for compliance with the PMIO NAAQS. Please note in AQS that the 2ZH

North Valley site PM 10 monitor is not meeting the requirements of 40 CFR Part 58, App

E.

Network Assessments:

Carbon Monoxide (CO)

The current CO network for the City ofAlbuquerque exceeds the minimum

requirements with four monitors. See 40 CFR Part 58, App. D, 4.2. The CO monitor at

the 2ZH North Valley site (AQS #35-00 I-I 0 13) has the second lowest design value. The

City ofAlbuquerque may want to re-evaluate the CO monitor at this site. Any request

for a system modi.fication under 40 CFR § 58.14(c) should be submitted in writing to

EPA Region 6.

PM

We note that the City of Albuquerque operates PM 10 gravimetric monitors at the

2ZM Del Norte site (AQS #35-001-0023) and the 2ZS Singer (AQS #35-001-0026) to

meet the requirements of 40 CFR Part 58, App. D, 4.6. Funhennore based on our

assessment, the City ofAlbuquerque operates primary and secondary PM I0 gravimetric

monitors at the 2ZS Singer site (AQS #35-001-0026) to meet the 15% collocation

requirements. See 40 CFR Part 58, App. A, 3.3.1.

According to the network plan, the City ofAlbuquerque plans to operate PMIO

tapered element oscillating microbalance (TEOM) monitors at the 2ZH North Valley site

(AQS #35-001-1013), the 2ZS Singer site (AQS #35-001-0026), the 2ZV South Valley
2

site (AQS #35-001-0029), and the 2ZW Westside site (AQS #35-001-0032) as nonregulatory. The City of Albuquerque wishes to use the PMl adata for the Air Quality

Index. We have no objections if you have confidence with the data quality.

Requests for Additional Information:

Please provide a written response for the following issues to the EPA Region 6 Air

Quality Analysis Section Chief within 45 days of the date of this letter.

PM

Please provide the Region an explanation ofthe objective for collocating and

operating a PMIO gravimetric monitor at the 2ZH North Valley site (AQS #35-001-1013)

if the site does not meet siting criteria.

Lead (Pb)

According to Tables I and lA, the Pb monitor at the 2ZM Del Norte site (AQS

#35-001-0023) is listed as operating as continuous seasonal; this NeeTe Pb monitor must

be operated all year at a l-in-6 day sampling frequency. See 40 CFR §58.12(b) and Part

58, App. D, 2(e). We request that you revise Tables 1 and lA accordingly. In addition,

the spatial scale for the NCore Pb monitor is designated as regional scale instead of

neighborhood scale, as are the remaining NCore monitor neighborhood designations at

the 2ZM Del Norte site. We request that you designate the NCore Pb monitor as

neighborhood scale. See 40 CFR Part 58, App. D, 4.5(b) and (d).

In this network plan, the City ofAlbuquerque also references that the NCore Pb

monitor is to be installed at the 2ZV South Valley site (AQS #35-001-0029), pending

EPA agreement. From email correspondence, Region 6 understands that the City of

Albuquerque subsequently decided to operate the Pb monitor at the 2ZM Del Norte site

(AQS #35-001-0023). We request that you correct the reference to the NCore Pb monitor

being installed at the 2ZV South Valley site and confirm the location ofthe Neore Pb

monitor.

General Comments

The network plan's Appendix states that the lead sampler was pending 20 II grant

funding. Funding issues are discussed during the grant process; however, funding will be

made available for the required Pb monitor.