Mr. Eddie Terrill 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGIONS 

1445 ROSS AVENUE, SUITE 1200 

DALLAS TX 75202-2733 

SEP 1 5 2015 

Director, Air Quality Division 

Oklahoma Department of Environmental 

Quality 

Post Office Box 1677 

Oklahoma City, Oklahoma 73101-1677 

Dear Mr. Terrill: 

Thank you for your correspondence submitting the Oklahoma Department of Environmental Qualitis 

(ODEQ) Fiscal Year (FY) 2016 Annual Monitoring Network Plan, and also for the previously submitted 

FY2015 Annual Monitoring Network Plan. The U.S. Environmental Protection Agency (EPA) Region 6 

has completed its review and analysis of these successive Annual Monitoring Network Plans to ensure 

they meet the requirements of 40 Code of Federal Regulations (CPR) Part 58 and its appendices that 

confer approval authority on the Regional Administrator, now delegated to the Associate Director for 

Air. 

We appreciate your cooperation and work to submit the FY20 15 and FY20 16 network plans. The 

network assessment process presents an opportunity for EPA Region 6 and the 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 information for near-road monitoring and the status of changes for the ODEQ 

Ambient Air Monitoring Network. 

I am pleased to inform you that your FY20 15 and FY20 1 6 ambient air monitoring network plans are 

approved in accordance with 40 CPR §58.1 0. Details of our review of your air monitoring network are 

provided in the technical comments enclosure. 

We look forward to our continued collaborative work with the ODEQ on your FY2017 ambient air 

monitoring network plan. If you have any questions, 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 Director for Air Programs 

Enclosure 

Internet Address (URL) • http:/lwww.epa.gov/regioo6 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper 
Technical Comments on the ODEQ FY2015 and FY2016 Annual Air Monitoring Network Plan 

The U.S. Environmental Protection Agency (EPA) has reviewed ODEQ's FY2015 Air Monitoring 

Network Plan and FY 2016 Annual Network Plan. Our technical comments are provided below. 

General Comments 

We appreciate ODEQ's annual air monitoring 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 ... , and Appendices D & E". We 

request that the ODEQ continue to include an assessment of its plan's conformance with 40 CFR 58 and 

its appendices in next year's review, and references to the CFR for network changes. 

For future plans, at the time the annual monitoring network plan proposal becomes available for public 

review, we would appreciate if you would send a web link for the proposal by email to Ms. Frances 

Verhalen at verhalen.frances@epa.gov and to Ms. Ellen Belk at belk.ellen@epa.gov. 

Also, for future annual air monitoring network plan submittals, we would appreciate if you would send 

an electronic version of the plan in addition to the hardcopy. Electronic versions may be sent to 

Ms. Verhalen and to Ms. Belk at the email addresses above. 

Ozone (Ol) Monitoring 

The ODEQ ozone network provides 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 Tulsa three additional monitors. Both areas currently have 8·hour ozone design 

values below the 2008 75 parts per billion National Ambient Air Quality Standard. The remainder of the 

ozone network consists of a regional background ozone site in western 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 of ozone 

pollution transpOrt from the north Texas area. The EPA Region 6 acknowledges that no changes were 

made to the Oklahoma ozone network in either the ODEQ FY2015 Air Monitoring Network Plan or the 

ODEQ FY2016 Air Monitoring Network Plan. 

Lead (Pb) Monitoring 

A proposal is included in the latest network plan to add a Pb monitor in Sapulpa (Air Quality System 

(AQS) Site ID: 40·037·0146) at a site location to be determined in the Tulsa MSA. We agree with the 

ODEQ that this Pb monitor needs to be added to the network at Sapulpa. Toxics Release Inventory data 

for Saint-Gobain Containers Inc. at 1000 N. Mission St. in Sapulpa, OK indicates Pb emissions exceed 

the 0.50 tons per year threshold to require source-oriented monitoring. Please keep us apprised of efforts 

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to find a specific monitoring site and submit the appropriate monitoring site request for EPA review and 

approval. Please review 40 CFR 58.13(b) for applicable milestones. 

We note that ODEQ's request 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 Monitoring Network 

Plan under the heading Lead Pb Monitoring, "We ... approve the relocation of the Savanna Pb 

collocated monitor to the Tulsa (NCore) monitoring site in order to continue to meet the Pb monitoring 

collocation requirement". (NCore means the National Core multipollutant monitoring stations.) 

Sulfur Dioxide (S02) Monitoring 

The ODEQ operates a network of seven SOz State or Local Air Monitoring 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 Section 4.4. 

Nitrogen Dioxide (N02) Monitoring 

As requested in the ODEQ FY2015 Air Monitoring Network Plan, EPA Region 6 acknowledges the 

addition of the NOz monitor at the Seiling site (AQS Site ID: 40-043-0860) as a Special Purpose 

Monitor (SPM) in northwest Oklahoma to measure regional background concentrations ofNOz. See 40 

CFR 58.20. 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's request to remove the NOz monitor at Oklahoma Christian University (AQS Site 

ID: 40-109-1037) was previously acknowledged in our letter dated May 13,2014 in response to the 

2013 Annual Monitoring Network Plan under the heading Near-Road N02 and Other Monitoring, "EPA 

Region 6 approves the relocation of the 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 Air Monitoring Network Plan or the ODEQ FY2016 Air Monitoring Network Plan. 

The ODEQ is meeting the minimum requirements for its CO monitoring network design. See 40 CFR 58 

Appendix D Section 4.2. 

Particulate Matter (PM) Monitoring 

Also, in the FY20 15 Air Monitoring Network Plan, the ODEQ recommended changes in the operating 

schedules in Table 2 Recommended Changes to Operating Schedules on page 9 for PM monitors at two 

sites (AQS Site IDs: 40-143-1127 and 40-143-1110). The EPA approves the requested changes to 

operating schedules from a daily operating schedule to a 1-in-3 day operating schedule. See 40 CFR Part 

58.12(e). 

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As requested in the ODEQ FY2016 Air Monitoring Network Plan, EPA Region 6 approves the 

discontinuation of the IMPROVE monitor at the Ellis County WMA Arnett site (AQS Site ID: 40-045-

0980). See 40 CPR 58.14. See also EPA's IMPROVE Protocol Assessment dated 5/7/2015. 

Particulate Matter of 2.5 Microns or Less (PM2.s) 

The EPA has reviewed the information in the PM2.s section ofODEQ's plan 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 of 5 monitoring sites). Collocation 

requirements for the FRM monitors are met at the 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 collocation requirements for continuous FEMs at the 40-12I-0415 

monitoring site. The EPA approves there-designation ofthe continuous monitor (AQS Site ID: 40-121-

0415) to the primary SLAMS, and there-designation of the 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 than 4 meters 

from its collocated monitor, submitted in accordance with 40 CFR 58 Appendix A 3.2.5.6, is 

approved. The ODEQ network meets collocation requirements. See 40 CFR 58 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 monitor cannot act as the collocated monitor for quality 

assurance purposes. There appears to be a discrepancy between the 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 reviewed the information in the PM2.s Background and Transport Monitoring section of 

the ODEQ's plan and finds that the plan meets siting and operation requirements. 

Particulate Matter of 10 Microns or More (PMto) 

The ODEQ is meeting the minimum requirements for its PM to monitoring network design. See 40 CFR 

58 Appendix D Section 4.6. 

In the ODEQ FY2015 Annual Network Review, the ODEQ requests to add a continuous FEM PMto 

sampler to the Oklahoma City site at Oklahoma Christian University (AQS Site ID: 40-109-1037) and a 

continuous PM to sampler in western Oklahoma to aid in tracking of dust events in conjunction with their 

health advisory program. The EPA acknowledges the addition and siting of a continuous FEM monitor 

at AQS Site ID: 40-109-1037 Location and the addition of a western Oklahoma continuous FEM PM10 

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monitor (AQS Site ID: 40-043-0860). Also, the EPA Region 6 wishes to further discuss with the ODEQ 

the purpose of the manual PM1o monitor at the Oklahoma Christian University site. 

In the FY2015 Air Monitoring Network Plan, the ODEQ requested to relocate the PM monitor from 

Burneyville (AQS Site ID: 40-085-0300) to the Memorial Drive, Healdton site (AQS Site ID: 40·0 19-

0297) (SPM). The EPA approves this request to add a PM monitor at the Healdton site. See 40 CPR Part 

58.14. Prior approval from EPA is not needed for discontinuance of an SPM site. See 40 CPR 58.20(f). 

For PM1o monitoring at the Muskogee site (AQS Site ID: 40-101-0161), the EPA Region 6 would like to 

discuss reasons for PM10 monitoring at the site. For the Muskogee site, AQS shows data completeness 

below 75% for 3rd and 4tb quarters of2014, however our records do not show a data 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 network review found that sampling stopped in October 2012. 

However, AQS shows data from this site until November 4, 2012. Please clarify the dates and make 

appropriate updates so the annual network review is consistent with AQS.] 

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