UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1445 ROSS AVENUE, SUITE 1200 DALLAS, TX 75202-2733 

### JAN 1 2 2011

Ms. Peggy M. Hatch Secretary 

### Louisiana Department ofEnvironmental Quality Post Office Box 4301 Baton Rouge, LA 70821 DearMs. Hatch: The U.S. Environmental Protection Agency (EPA) Region 6 has completed its analysis ofthe Louisiana Department ofEnvironmental Quality (LDEQ) 2010 Annual Air Monitoring Network Plan to ensure it meets those requirements of40 CFR Part 58 and its appendices that conferapproval authorityon the Regional Administrator. We appreciate your cooperation and work to prepare and submit your 2010 annual network plan for review. EPA approves your network plan, in accordance with 40 CFR § 58.10 and § 58.14. Technical comments are addressed in the enclosure. We look forward to working with LDEQ on the implementation ofthe future, revised ozone National Ambient Air Quality Standards (NAAQS) monitoring regulations as well as finalized nitrogen dioxide, sulfur dioxide and lead AAQS monitoring regulations. New requirements in monitoring may need to beaddressed in your 2011 annual network plan, along with your schedule for operation. Ifyou have any questions, please contact me at (214) 665-2100, or your staffmay contact Ms. Maria Martinez ofmy staffat (214) 665-2230.

EnclosureTechnical Comments on LDEQ 2010 Annual AirMonitoringNetwork Plan 

### Photochemical AssessmentMonitoring Stations (PAMS): Region 6 has reviewed and approves your PAMS plan for Baton Rougeduring 2010 (Table C). Yourrequested PAMS changes apply

# '0 the Baton Rouge, Louisiana, area at the Dutchtown (AQS Site l.D. #22-005-0004) monitoring site and include a sampling frequency change to fourthree-hour canister samples every three days (from the currentdaily sampling frequency conducted in the months ofJune through August) and the removal ofhourly Total Non-Methane Organic Carbon monitoring which was inadvertently included in your 2009 annual networkreview plan. With these changes, we believe PAMS monitoring will continue to satisfy minimum requirements. Your requested PAMS modifications will also be forwarded to the Office ofAir Quality Planning and Standards for the requisite Administratorreview and approval. See 40 CFR § 58.1 I(c) and 40 CFR § 58.14(a). 

### Additional Comments: Forclarification purposes, it is recommended that "mixing height" be listed as the parameter for the upper air meteorological data requirement at the Capitol site (AQS #22-033-0009), instead ofcloudheight. 

### In Table B, the StationType for the Dutchtown ozone and Nitrogen Oxide monitors should be listed as PAMS, to beconsistentwith yourTable C. 

### S02: The PortAllen (22-121-0001) and Chalmette Vista (22-087-0007) monitoring sites in West Baton Rouge and SaintBernard Parishes, respectively, are projectedby the Office ofAir Quality Planning and Standards to exceed the I-hour S02 National Ambient Air Quality Standard (NAAQS); the Port Allen S02 monitoring site must continue monitoring and we recommend continued Chalmette Vista S02 monitoring. 

### Ozone:We also approve the relocation ofthe Chalmette High School ozone site in St. Bernard Parish (AQS #22-087-0009) [0 Meraux within the same parish (AQS #22-087-0004) as stipulated in your September28,2010,30 day public notice. PM: The New Orleans Metropolitan Statistical Area (MSA) does not show any State and Local AirMonitoring Station (SLAMS) PM2.5 collocated sites. Please note that LDEQ shouldhave 15% ofthe SLAMS PM2.5 primary monitors collocated in each MSA according to 40 CFR 58, App. A, 3.2.5. The collocated PM2.5 secondary monitors must have the same sampling methods as PM2.5 primary monitors. Additionally, the required

### SLAMS PM2.5 primary monitors must operate at least on a l-in-3 day sampling schedule. The Regional Administratormay favorably consider arequest for a sampling frequency reduction to l-in-6 day ifthe design value ofthe primary PM2.5 monitor is well within the NAAQS by collocating continuous PM2.5 monitors at the monitoring site. Please checkthe sampling frequency ofyour PM2.5 SLAMS monitor operating at lhe Marrero site (AQS Site I.D. #22-051-2001). See

### 40 CFR § 58.12. Table B in your net\vorkplan must identify ifyourPM2.5 continuous monitors are TEOM or BAM 1020 (Federal EquivaleotMethod orFEM). See

### 40 CFR § 58.10(b)(3). The LDEQ networkplan has proposed several PM2.5 samplers as special purpose monitors. Note thatthese monitors have to be in addition to the minimum SLAMS PM2.5 monitoring sites, and mustmeet the requirements of 40 CFR 

### § 58.20. Pb: All Ph monitoring sites shouldbe identified as Pb NAAQS comparable. Accordingly, please modify yournet\vork assessment Table B, to properly address that yourPb monitoring sites are NAAQS comparable and eliminate the "* 

### "symbol for the following Pb monitoring sites: the Capital site (AQS Site I.D. #22-033-0009), the Baker LSP site (AQS Site 

### J.D. #22-033-0009) and LaPlace site (AQS Site 

### J.D. #22-095-0003). This request includes the elimination ofwhat appears to be acorresponding footnote for these Pb monitoring sites: "Not comparablebecause less than 3 years ofdata", See40 

### CFRPart §58.1O(4). Pleasereview the final Pb reconsideration monitoringregulations signed bytbe Administratoron December 14,2010, forthe new Pb monitoring requirements that shouldbe addressed in yourJuly 1, 2011, annual network review plan.