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

Dear Ms. Hatch:

The U.S. Environmental Protection Agency (EPA) Region 6 has completed its

analysis ofthe Louisiana Department of Environmental Quality (LDEQ) 2010 Annual

Air 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 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 be addressed in your 2011

annual network plan, along with your schedule for operation.

If you have any questions, please contact me at (214) 665-2100, or your staff may

contact Ms. Maria Martinez ofmy staffat (214) 665-2230.

Enclosure
Technical Comments on LDEQ 2010 Annual Air Monitoring Network Plan

Photochemical Assessment Monitoring Stations (PAMS):

Region 6 has reviewed and approves your PAMS plan for Baton Rouge during

2010 (Table C). Your requested 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 four three-hour canister samples every three days (from the

current daily sampling frequency conducted in the months ofJune through August) and

the removal of hourly Total Non-Methane Organic Carbon monitoring which was

inadvertently included in your 2009 annual network review 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 of Air Quality

Planning and Standards for the requisite Administrator review and approval. See 40 CFR

§ 58.1 I(c) and 40 CFR § 58.14(a).

Additional Comments:

For clarification 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 of cloud height.

In Table B, the Station Type for the Dutchtown ozone and Nitrogen Oxide

monitors should be listed as PAMS, to be consistent with your Table C.

S02:

The Port Allen (22-121-0001) and Chalmette Vista (22-087-0007) monitoring

sites in West Baton Rouge and Saint Bernard Parishes, respectively, are projected by the

Office of Air 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 September 28,2010,30 day public notice.

PM:

The New Orleans Metropolitan Statistical Area (MSA) does not show any State

and Local Air Monitoring Station (SLAMS) PM2.5 collocated sites. Please note that

LDEQ should have 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 Administrator may favorably consider a request 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 check the sampling frequency of your 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\vork plan must identify if your PM2.5 continuous monitors

are TEOM or BAM 1020 (Federal Equivaleot Method or FEM). See 40 CFR §

58.10(b)(3).

The LDEQ network plan has proposed several PM2.5 samplers as special purpose

monitors. Note that these monitors have to be in addition to the minimum SLAMS

PM2.5 monitoring sites, and must meet the requirements of 40 CFR § 58.20.

Pb:

All Ph monitoring sites should be identified as Pb NAAQS comparable.

Accordingly, please modify your net\vork assessment Table B, to properly address that

your Pb 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 of what appears to be a corresponding footnote for

these Pb monitoring sites: "Not comparable because less than 3 years ofdata", See 40

CFR Part §58.1O(4).

Please review the final Pb reconsideration monitoring regulations signed by tbe

Administrator on December 14,2010, for the new Pb monitoring requirements that

should be addressed in your July 1, 2011, annual network review plan.