Mr. Eddie Terrill UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 1445 ROSS AVENUE, SUITE 1200 DALLAS TX 75202-2733



# SEP 1 52015 Director, Air Quality Division Oklahoma Department ofEnvironmental Quality Post Office Box 1677 Oklahoma City, Oklahoma 73101-1677 DearMr. Terrill: Thankyou for your correspondence submitting the OklahomaDepartment ofEnvironmental Qualitis (ODEQ) Fiscal Year (FY) 2016 Annual Monitoring Network Plan, and also for the previously submitted FY2015 Annual MonitoringNetwork Plan. The U.S. Environmental Protection Agency (EPA) Region 6 has completed 

### its review and analysis ofthese successive Annual Monitoring Network Plans to ensure they meetthe requirements of40 Code ofFederal Regulations (CPR) Part 58 and its appendices that confer approval authority onthe Regional Administrator, now delegated to the Associate Director for Air. We appreciate your cooperation and work to submit the FY2015 and FY2016 network plans. The network assessment processpresents an opportunity for EPA Region 6 andthe ODEQ to collaborate on the air monitoring network design. See 40 CFR Part 58 Appendix D, Section 1.1.2. EPA has reviewed the plans, including the informationfor near-road monitoring and the status ofchanges for the ODEQ Ambient AirMonitoring Network. I am pleasedto informyou that your FY2015 and FY201 6 ambient airmonitoring network plans are approved in accordance with40 CPR §58.10. Details ofourreview ofyour air monitoring network are provided in the technical comments enclosure. We lookforward to our continued collaborative work with the ODEQ on your FY2017 ambient air monitoring network plan. Ifyou have anyquestions, please contact me at (214) 665-7548, or your staff may contact Ms. Fran Verhalen, Air Quality Analysis Section Chief, at (214) 665-2172. 

# s::e'f1A /**I~** Mark Hansen Associate Directorfor Air Programs Enclosure

InternetAddress (URL) • http:/lwww.epa.gov/regioo6 Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer. ProcessChlorine Free Recycled PaperTechnical Comments on the ODEQ FY2015 and FY2016 Annual Air Monitoring NetworkPlan

The U.S. Environmental ProtectionAgency (EPA)has reviewed ODEQ's FY2015 AirMonitoring Network Plan and FY 2016 Annual Network Plan. Ourtechnical comments are provided below.

General Comments We appreciate ODEQ's annual airmonitoring network review for ODEQ's fiscal years 2015 and 2016, and acknowledge ODEQ's finding that ''All AQD [ODEQ's Air Quality Division] sites and monitors conform to 40 CFR, Subchapter C, Part 58 Appendix A, Appendix C

... , andAppendices D & E". We requestthat the ODEQ continue to include an assessment ofits plan's conformance with 40 CFR 58 and its appendices in next year's review, and references to the CFRfor network changes. For future plans, at the time the annual monitoring network planproposal becomes available for public review, we would appreciate ifyou would send a web link for the proposal by email to Ms. Frances Verhalen at verhalen.frances@epa.gov and to Ms. Ellen Belk atbelk.ellen@epa.gov. Also, for future annual air monitoringnetworkplan submittals, we would appreciate ifyou would send an electronic version ofthe plan in addition to the hardcopy. Electronic versions may be sentto Ms. Verhalen and to Ms. Belk atthe email addresses above.

Ozone 

### (Ol) Monitoring The ODEQ ozone networkprovides valuable monitoring information. The ODEQ is meeting the minimum requirements and operating an adequate ozone network of 17 sites. Currently, five sites are required, two apiece in Oklahoma City and Tulsa and one in Lawton. Oklahoma City contains four additional monitors and Tulsathree additional monitors. Both areas currentlyhave 8·hourozone design values below the 2008 75 parts per billionNational Ambient Air Quality Standard. The remainder ofthe ozone network consists ofa regional background ozone site inwestern Oklahoma, a regional transport ozone site in southeastern Oklahoma, and the 3 ozone Special Purpose Monitors (SPMs) that operate no more than 2 consecutive years at a time along the Red River to help measure the extent ofozone pollution transpOrt from the north Texas area. The EPA Region 6 acknowledges that no changes were made to the Oklahoma ozone network in eitherthe ODEQ FY2015 Air MonitoringNetwork Plan or the ODEQ FY2016 Air MonitoringNetwork Plan.

Lead (Pb) Monitoring A proposal is included in the latest network planto add a Pbmonitor in Sapulpa (Air Quality System (AQS) Site ID: 40·037·0146) at a site locationto be determined inthe Tulsa MSA. We agree with the ODEQthat this Pb monitor needs to be added to the network at Sapulpa. Toxics Release Inventory data for Saint-Gobain ContainersInc. at 1000 N. Mission St. in Sapulpa, OKindicates Pb emissions exceed the 0.50 tons per yearthreshold to require source-oriented monitoring. Please keep us apprised ofefforts

1to find a specific monitoring site and submitthe appropriate monitoring site request for EPA review and approval. Please review 40 CFR 58.13(b) for applicable milestones. We note that ODEQ'srequest to remove the Ph monitor at Oklahoma Christian University (AQS Site ID: 40-109-1037) and add a Pb monitor at Peoria, Tulsa (AQS Site ID:40-143-1127) was previously acknowledged in our letter dated May 13, 2014 in response to the 2013 Annual MonitoringNetwork Plan under the headingLeadPb Monitoring, "We

... approve the relocation ofthe SavannaPb collocated monitor to the Tulsa (NCore) monitoring site in order to continue to meet the Pb monitoring collocation requirement". (NCore means theNational Core multipollutant monitoring stations.)

Sulfur Dioxide (S02)Monitoring The ODEQ operates a network ofseven 

### SOz State or Local AirMonitoring Stations (SLAMS) sites and is meeting the network design requirements for 

### SOz monitoring according to the Population Weighted Emissions Index. See 40 CFR 58 Appendix D Section4.4. Nitrogen Dioxide (N02) Monitoring As requested inthe ODEQ FY2015 Air Monitoring Network Plan, EPARegion 6 acknowledges the addition ofthe

### NOz monitor atthe Seiling site (AQS Site ID: 40-043-0860) as a Special Purpose Monitor (SPM) in northwest Oklahomato measure regional background concentrations 

### ofNOz. See 40 CFR58.20. The ODEQ is meeting the minimum requirements for its 

### NOz monitoring network design. See 40 CFR 58 Appendix D Section 4.3. We note that ODEQ'srequest to remove the

### NOz monitor at Oklahoma Christian University (AQS Site ID: 40-109-1037) was previously acknowledged in our letter dated May 13,2014inresponse to the 2013 Annual Monitoring Network Plan underthe heading Near-RoadN02 andOther Monitoring, "EPA Region 6 approves the relocation ofthe existing

### NOz monitor from the Oklahoma Christian University monitoring site

...to the near-road

### NOz site (AQS Site ID: 40-109-0097)".

Carbon Monoxide (CO) Monitoring The EPA Region 6 acknowledges that no changes were made to the Oklahoma CO network in either the ODEQ FY2015 AirMonitoringNetwork Planor the ODEQ FY2016 Air MonitoringNetwork Plan. The ODEQ is meeting the minimum requirements for its CO monitoring networkdesign. See 40 CFR 58 Appendix D Section 4.2.

Particulate Matter (PM) Monitoring Also, in the FY2015 Air Monitoring Network Plan, the ODEQ recommended changes in the operating schedules in Table 2 RecommendedChanges to OperatingSchedules onpage 9 for PM monitors attwo sites (AQS Site IDs: 40-143-1127 and40-143-1110). The EPA approves the requested changes to operating schedules from a daily operating schedule to a 1-in-3 day operating schedule. See 40 CFRPart 58.12(e).
2As requested in the ODEQ FY2016 Air MonitoringNetwork Plan, EPA Region 6 approves the discontinuation ofthe IMPROVE monitor at the Ellis County WMA Arnett site (AQS Site ID: 40-045- 0980). See 40 CPR 58.14. See also EPA'sIMPROVEProtocolAssessment dated 5/7/2015. 

### Particulate Matterof2.5 

### Microns orLess (PM2.s) The EPA has reviewed the information inthe PM2.s section ofODEQ'splan and finds it meets the minimum requirements for its PM2.s monitoring network design. See 40 CFR 58 Appendix D Section 4.7. The ODEQ currently operates manual Federal reference method (FRM) PM2.s samplers at 4 sites, with an additional one planned to be deployed at the near road site (a total of5 monitoring sites). Collocation requirements for the FRM monitors are met atthe Peoria, Tulsa, monitoring site (AQS Site ID: 40-143- 1127). The ODEQ currently operates continuous Federal equivalent method (FEM) PM2.s monitors at 8 sites, and plans to upgrade the tapered element oscillating microbalance (TEOM) at the 40-043-0860 to an FEM sampler. The ODEQ meets collocationrequirements for continuous FEMs at the 40-12I-0415 monitoring site. The EPA approves there-designation ofthecontinuous monitor (AQS Site ID: 40-121- 0415) to the primary SLAMS, and there-designation ofthe FRM as the collocated sampler (AQS Site ID: 40-121-0415-8810I-1). The schedule change for the AQS Site ID: 40-121-0415 site, to operate on a 1 in 6 day schedule, is approved in accordance with 40 CFR 58.12(d)(ii). The waiver request for the AQS Site ID: 40-143-I127 site for locating the monitor more than4 meters from its collocated monitor, submitted in accordance with 40 CFR 58 Appendix A 3.2.5.6, is approved. The ODEQ network meets collocationrequirements. See 40 CFR58 App. D. 4.7.2. In Table I (both years), we note the FEM is identified as being the collocated monitor at the NCORE site (AQS Site ID: 40-143-1127). A continuous monitorcannotact as the collocated monitor for quality assurance purposes. There appears to be a discrepancy betweenthe Table I and the text. The ODEQ clarified this discrepancy in an email dated September 1, 2015. Please make a correction in Table I in the 2016-2017 report. The EPA has reviewedthe information inthe PM2.s Background and Transport Monitoring section of the ODEQ's plan and finds that the planmeets siting and operationrequirements. 

### ParticulateMatter of 10 Microns orMore (PMto) The ODEQ is meeting the minimum requirements for its PMto monitoring network design. See 40 CFR 58 Appendix D Section 4.6. Inthe ODEQ FY2015 AnnualNetwork Review, the ODEQ requests to add a continuous FEM PMto sampler to the Oklahoma City site at Oklahoma ChristianUniversity (AQS Site ID: 40-109-1037) and a continuous PMto sampler in western Oklahomato aid intracking ofdust events in conjunction withtheir health advisory program. The EPA acknowledges the addition and siting ofa continuous FEMmonitor at AQS Site ID: 40-109-1037 Location and the addition ofa western Oklahoma continuous FEM PM10 3

### monitor (AQS Site ID: 40-043-0860). Also, the EPA Region 6wishes to further discuss with the ODEQ the purpose ofthe manual PM1o monitor atthe Oklahoma ChristianUniversity site. In the FY2015 Air Monitoring Network Plan, the ODEQrequested to relocate the PM monitor from Burneyville (AQS Site ID: 40-085-0300) to the Memorial Drive, Healdton site (AQS Site ID: 40·019- 0297) (SPM). The EPA approves this requestto add a PM monitor atthe Healdton site. See 40 CPRPart 58.14. Priorapproval from EPA is not neededfor discontinuance ofan SPM site. See 40 CPR 58.20(f). For PM1o monitoring at the Muskogee site (AQS Site ID: 40-101-0161), the EPA Region 6would like to discuss reasons for PM10 monitoring at the site. Forthe Muskogee site, AQS shows datacompleteness below 75% for 3rd 

### and 4tb quarters of2014, howeverourrecords do not show adata loss notification. We would like to clarify 

### the reasons for a discrepancy in

### the data. [We note that AQS shows an R&P 2025 PM10 gravimetric SPM monitor operated at the Muskogee site (AQS Site ID: 40-101-0161) since January 1, 2011. The ODEQ's annual networkreview found that sampling stopped in October 2012. However, AQS shows data from this site until November4, 2012. Please clarify the dates and make appropriate updates so the annual networkreview is consistent with AQS.]

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