UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

OCT 31 2011 

Mr. Larry Greene 

Air Pollution Control Officer 

Sacramento Metro Air Quality Management District 

777 12th Street 

Sacramento, California 95814 

Dear Mr. Greene: 

Thank you for your submission of the Sacramento Metropolitan Air Quality Management District’s 

2011 Annual Monitoring Network Plan. We have reviewed the submitted document and have found that 

it meets the minimum requirements set forth under 40 CFR Part 58.10. 

While this letter serves as official approval of the annual network plan, it does not constitute approval of 

system modifications mentioned in the plan, specifically at the Goldenlands Court, North Highlands, and 

Stockton Boulevard sites. We will continue to work with your district to review system changes when 

we receive the official requests. 

Enclosed, please find our comments on the plan. If you have any questions regarding this letter or the 

enclosed comments, please feel free to contact me at (415) 972-3851 or Kate Hoag at (415) 972-3970. 

 Sincerely, 

 

/s/ 

 

 Matthew Lakin, Manager 

 Air Quality Analysis Office 

 Air Division 

Enclosure 

cc: Brigette Tollstrup, SMAQMD 

John Ching, SMAQMD 

Karen Magliano, ARB 
Comments on the Sacramento Metropolitan AQMD 2011 Network Plan 

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

1. The minimum number of PM10 monitors is based on concentration, rather than the 

number of exceedances, per Table D-4 in 40 CFR Part 58 Appendix D. Table 4 on page 

9 lists the correct minimum number of PM10 monitors as 2-4, but the Design Value 

columns should reflect the 24-hour PM10 ambient concentration as stated in Thable D-4 

of 40 CFR 58 Appendix D. For example, the maximum concentration over a three year 

period within the MSA could be used. 

2. The non-source oriented neighborhood scale Pb monitor requirement described in 

footnote 7 on page 9 has been replaced by the requirement to have the Pb monitoring at 

NCore sites, which was correctly described on page 10. 

3. Site names for the Stockton Boulevard / Sacramento Health Department site are not 

consistent (see pages 6 and 11). 

4. The table on page 6 should list the PM2.5 instrument at Sloughhouse as an E-BAM. 

5. Appendix B – Detailed Site Information 

a. We recommend that you include the POC, method code and pollutant code as 

entered in AQS and FRM/FEM status for all monitors to ensure that these 

descriptors are consistent with the monitor description and describe more fully 

how minimum monitoring requirements are met. For example, the Met One 

BAM 1020 with a VSSC inlet at your sites are listed as method code 731 and as a 

non-FEM. However, the list of designated methods (found here: 

http://www.epa.gov/ttnamti1/files/ambient/criteria/reference-equivalent-methodslist.pdf) lists this monitor as an FEM with a method code of 170. 

b. Monitors that are non-regulatory due to the instrument’s non-FEM status or due to 

siting issues should not be considered a SLAMS site type. If the continuous 

PM2.5 monitors are non-FEMs, then the site type should be changed from 

SLAMS, even if the site type is SLAMS for the filter-based monitors at the same 

station. 

c. The description of the Sloughhouse site on page 59 should indicate that it is 

located southeast of Downtown Sacramento, rather than southwest. 

d. We recognize your efforts to modify one of your high ozone sites, Sloughhouse, 

to meet siting requirements and therefore switch the site type to a SLAMS. 

Please note that if you intend to keep operating Sloughhouse as a seasonal site, 

you need to request a waiver to operate fewer months than the ozone season, 

which in California is the full year. 

e. The network modification to the PM2.5 E-BAM at Sloughhouse indicated in the 

table on page 61 should be described in the section covering proposed 

modifications to the network in Section 4.