UNITEDSTATESENVIRONMENTALPROTECTIONAGENCYREGIONIX75HawthorneStreetSanOfec\s1o•z«(jf394105·3901Mr.RichardL.MartinAirPollutionControlOfficerNorthCoastUnifiedAirQualityManagementDistrict2300MyrtleAvenueEureka,California95501DearMr.Martin:ThankyouforyoursubmissionoftheNorthCoastUnifiedAirQualityManagementDistrict's(NCU's)AirMonitoringNetworkPlan2013inJune2013.Wehavereviewedthesubmitteddocumentbasedontherequirementssetforthunder40CFR58.Basedontheinformationprovidedintheplan,EPAapprovesallportionsofthenetworkplanexceptthosespecificallyidentifiedbelow.Withthisplanapproval,wealsoformallyapprovethefollowingsystemmodifications:shutdownofEurekaIStreetstationinaccordancewith40CFR58.14(c)(1),andconversionofJacobstoSLAMSforPM10andPM2.s·ThesechangesaredescribedinthenetworkplanandadditionalinformationwasprovidedtoEPAbyNCUinaJuly15,2013letter,September26,2013emailandSeptember30,2013letter.Pleaseincludethesedocumentsandanyassociatedattachmentsinnextyear'sannualnetworkplan.EPAfurthernotesthattheadditionofaFEMPM10instrumenttotheCrescentCity,DelNorteCountysitewas describedinthenetworkplanandaseparatelettersenttoEPAonApril25,2013.NCUhassinceclarifiedthatitsplanswerealteredanditnowintendstoinstallaSPMFEMPM2.s/non-FEMPMtoGRIMM180instrumentatCrescentCity.EPAisnotrequiredtoapprovenewSPMs,thereforetheCrescentCitysystemmodificationdoesnotneedtobeapproved.Pleaseincludethisnetworkclarificationinnextyear'splan.NCU'sSeptember16,2013emailalsoindicatesthatanychangestothePM10FRMat880Northcrest,CrescentCity,willbeaddressedinaseparatefuturerequest.Wethankyouforyourcorrespondenceandlookforwardtoworkingthroughanyfuturenetworkmodificationswithyou.Pleasenotethatwecannotapproveportionsoftheannualnetworkplanforwhichtheinformationintheplanisinsufficienttojudgewhethertherequirementhasbeenmet,orforwhichtheinformation,asdescribed,doesnotmeettherequirementsasspecifiedin40CFR58.10andtheassociatedappendices.EPARegion9alsocannotapproveportionsoftheplanforwhichtheEPAAdministratorhasnotdelegatedapprovalauthoritytotheregionaloffices.Accordingly,thefirstenclosure(A.AnnualMonitoringNetworkPlanItemswhereEPAisNotTakingAction)providesalistingofspecificitemsofyouragency'sannualmonitoringnetworkplanwhereEPAisnottakingaction.Thesecondenclosure(B.AdditionalItemsRequiringAttention)isalistingofadditionalitemsintheplanthatEPAwishestobringtoyouragency'sattention.Printl'donRl'cyclt'dPapt'rThe third enclosure

(C. Annual Monitoring Network Plan Checklist)

is the checklist EPA used
to review your plan for overall items that are required

to be included

in the annual network plan along with our assessment

of whether
the plan

. submitteP,:by

your agency addresses those requirements. The first two enclosures highlight

a subset

of the more extensive

list of items reviewed

in the third enclosure.

All comments conveyed

via this letter (and enclosures) should
be addressed (through corrections within the plan, additional information being included,

or discussion)

in next year's annual monitoring network plan.

If you have any questions regarding
this letter
or the enclosed comments, please feel free to contact
me at (415) 947-4534

or Gwen Yoshimura

at (415) 947-4134. Enclosures:

Sincerely, **4~**

**~**

. Meredith Kurpius, **Man~** Air Quality Analysis Office A. Annual Monitoring Network Plan Items where EPA

is Not Taking Action B. Additional Items Requiring Attention C. Annual Monitoring Network Plan Checklist cc: Wendy Caruso, NCU Gayle Sweigert, California

Air Resources BoardA. Annual Monitoring Network Plan Items where EPA

is Not Taking Action We are not acting
on the portions

of annual network plans where either EPA Region

9 lacks the authority

to approve specific items
of the plan,
or EPA has determined

that

a requirement

is either not met or information

in the plan

is insufficient

to judge whether
the requirement

has been met. • EPA identified items

in your agency's annual monitoring network plan where

a requirement

was not being met or information

in the plan was insufficient

to judge whether
the requirement

was being met based
on 40 CFR 58.10 and the associated appendices. Therefore,

we are not acting
on the following items: Item

Checklist Row Issue Identification

and justification

18, 24, 25 Not meeting requirement for PM2.s FEMs not comparable

to the NAAQS Sampling schedule

for PM2.s

52

Not meeting requirement Dates oflast two semi-annual

35 Insufficient

to judge flow rate audits for PM monitors PM2.s collocation

37 Insufficient information

to judge Manual PM
to collocation

40 Insufficient information

to judge Additional information

for each of these items may be found for the row listed

in column

2, in the third enclosure

(C. Annual Monitoring Network Plan Checklist).B. Additional Items Requiring Attention • [Row 30] EPA recommends basing frequency

of flow rate verifications

on the required calendar time-frame,

as opposed

to doing

it by the number

of sample runs. For PM
10 high-volume
filter based instruments,

this would

be once every three months

(as opposed to every

15 sampling runs). This would ensure that despite any missed sampling days, the flow rate verifications would
be carried out in accordance
with EPA guidance. • [Row 37] NCU's statement

on pages

13 and 16 of the plan, ''No collocation ofSPM monitors

is required,"

is not correct. Unless SPMs are non-regulatory

or are expected

to run for

a short period

of time only, collocation

is required

as they are eligible

for comparison

to the NAAQS. • [Row 48] EPA incorrectly identified ''population oriented"

as
a site type in last year's response letter. NCU was correct that

it should
be ''population exposure"

to match AQS and Appendix

D. • [Row 57] While NCU does not have any required ozone sites, EPA recommends considering whether your network contains

a max ozone monitor with your next network plan,
or during your 5-year Network Assessment. • [Row 66] While NCU does not have any required PM2

. s sites, EPA recommends considering whether your network contains

a max concentration monitor

at
a neighborhood

or larger scale with your next network plan,
or during your 5-year Network Assessment.

### C. ANNUAL MONITORING NETWORK PLAN CHECKLIST (Updated 11/26/2013)

Year: 2013 Agency: North Coast Unified AQMD (NCU)

40 CFR 58.1 O(a)(1) requires that each Annual 

### Network Plan (ANP) include information regarding the following types of monitors: SLAMS monitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, S1N stations, State speciation stations, SPM stations, and/or, in serious, severe and extreme ozone nonattainment areas, 

## P AMS stations, and SPM monitoring stations.
40 CFR 58.10(a)(1) further directs that, "The plan shall include a statement of purposes for each monitor and evidence that siting and operation of each monitor meets the requirements of appendices A, C, 

### D, and E of this part, where applicable." On this basis, review of the ANPs is based on the requirements listed in 58.10 along with those in Appendices 

### A, C, 

### D, and E.

EPA Region 

## 9 will not take action to approve or disapprove any item for which Part 58 grants approval authority to the Administrator rather than the Regional Administrators, but we 

## Will do a check to 

### see if the required information is included and correct. The items requiring approval by the Administrator are: P AMS, NCore, and Speciation (S1N/CSN).

Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requirements, nor do its contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welcome comments on its contents and structure.
Key: White = meets the requirement. Yellow= requirement is not met, or information is insufficient to make a determination. Action requested in next year's plan or outside the ANP ,...,-----. process. (items listed in Enclosure A) lGI' een 

# I =item requires attention in order to improve next year's plan (items listed in Enclosure B)



## 1

## ANP requirement Citation Was the info Does the Notes 

## within40 submitted? 1 

## If 

## information CFR58 yes, page #s. provided 3 

## meet Flag if 

## thereq? 4 

## incorrecf?
1. Submit plan by July 1st 58.10 (a)(1) Yes Yes Submitted June 28, 2013 2

. Statement of purpose for each monitor 58.10 (a)(1) Yes Yes

3. 30-day public comment 

### I inspection period) 58

. 10 (a)(1), Yes Yes Attached public notices. No public comments were 58.10 (a)(2) received, per email sent 6/28/2013.
4. Modifications to SLAMS network- case when we 58.10 (a)(2) Yes,pg 16 Yes While we encourage agencies to inform us of such

are not approving actual system modifications (i.e., 58.10(e) changes, EPA is not required to approve changes to a

we 

### will do it outside the ANP process 6 ) non-violating, non-required SPM such as the SPM PM 2 

### .s sampler at Jacobs. EPA also 

### is not required to approve new SPMs. EPA 

### will work with NCU on any future changes to their network, such as

**placem~t** of new SLAMs PM 2 • 5 monitors.
5. Modifications to SLAMS network- case when we 58.10 (a)(2) Yes, pg 16 Yes We are approving the shutdown ofEureka I street,

are approving actual system modifications per 58.10 (b)(5) and the change of Jacobs to SLAMS for PM 10 and
58

. 14(c) 58.10(e) PM 2 

### .s. As of a September 16, 2013 communication, 58.14 (c) we also understand that NCU no longer intends to deploy a FEM PM 10 instrument at Crescent City (as described in the network plan and a separate April 25, 2013 letter 

### to EPA), and instead 

### will place an SPM instrument at Crescent City. This network modification therefore no longer requires EPA approval, as installation of a SPM does not require EPA approval. We encourage you to continue keeping EPA and ARB informed of any such network changes.
6. Does plan include documentation (e.g., attached NA NA No mods approved since last ANP. Included letter approval letter) for system modifications that have requesting PM 10 changes

.

1 Response options : NA (Not Applicable), Yes, No, Incomplete, Incorrect. The responses "Incomplete" and "Incorrecf' assume that some information 

### has been provided.

2 To the best of our knowledge. 3 Assuming the information is correct 4 Response options : NA (Not Applicable)- [reason], Yes, No, Insufficient to Judge.

. 5 The affected state or local agency must document the process for obtaining public comment and include any comments received through the public notification process within
their submitted plan. 6 See 58.14(c) 

## 2 I

## ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If 

## information

- CFRS8 yes, page #s. provided 3 

## meet Flag if 

## the req? 4 

## incorrecr? been approved since last ANP approval? 7. NCore site operational (by 1/112011) 58.10 (a)(3) NA NA No NCore site required. 8. Pb site for 0.5-1.0 tpy sources operational (by 58.10 (a)(4) NA NA No Pb site required. 12127/2011)

I 9. N0 2 plan for area-wide and RA40 sites submitted by 58.10 (a)(5) NA NA No N0 2 sites required. 7/1/2012 10. N0 2 area-wide and RA40 sites operational by 58.10 (a)(5) NA NA No N0 2 sites required 111/2013 11. N0 2 plan for near-road sites submitted by 7/112013 58.10 (a)(5) NA NA No N0 2 sites required. 12. so2 sites operational (by 1/1/2013) 58.10 (a)(6) NA NA No S0 2 sites required. and 58.13(d) 13. AQS site identification number for each site 58.10 (b)(l) Yes, pgs 18-27 Yes 14. Location of each site: street address and geographic 58.10 (b)(2) Yes, pgs 18-27 Yes coordinates 15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes, pgs 18-27 Yes parameter 16. Any proposals to remove or move a monitoring 58.10 (b)(5) Yes,pg 16 Yes station within a period of 18 months following plan submittal 17. Scale of representativeness for each monitor as 58.10(b)(6); Yes, pgs 18-27 Yes defined in Appendix D AppD 18. Identification of sites suitable and sites not suitable 58.10 (b)(7) Incorrect Yes NCU is operating an FEM GRIMM at both for comparison to the annual PM 2

. 5 NAAQS as Humboldt Hill (pg 22-23) and Weaverville (pg 24- described in Part 58.30 25). They ID them as not comparable to the annual PM 2 

### .s NAAQS in the detailed site information tables, and on pg 13 state that these instruments "are nonregulatory and their data is not expected to meet the FRM similarity requirements which would enable them to be used for in national comparison." As discussed in Row 24 and Row 25 below, such a statement must be accompanied by additional information in order for EPA to determine whether it is appropriate to consider these instruments not comparable to the NAAQS. Until such information is provided, EPA will consider these data valid for comparison to the NAAQS. 19. MSA, CBSA, CSA or other area represented by the 58.10 (b)(8) Yes, pgs 18-27 Yes



## 3

## ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

## If information I 

## CFR58 yes, page #s. provided 3 

## meet I 

## Flag if 

## the req? 4 

## incorrecr?
monitor 20. Designation of any Ph monitors as either source- 58.10 (b)(9) NA NA No Ph monitors required

. oriented or non-source-oriented 21. Any source-oriented Ph site for which a waiver 

### has 58.10 (b)(IO) NA NA No Ph monitors required. been

**~ted** by EPA RA 22. Any Ph monitor for which a waiver has been 58.10 (b)(11) NA NA No Ph monitors required. requested or granted by EPA RA for use ofPb-PM 10 in lieu ofPb-TSP 23. Identification of required N0 2 monitors as either 58.10 (b)(12) NA NA No N0 2 monitors required. near-road or area-wide 24. Identification of any PM 2

_ 5 FEMs and/or ARMs not 58.10 (b)(l3) Incomplete No See comment in Row 18. No associated data eligible to be compared to the NAAQS (Note 1: must 58.11 (e) assessment was provided, therefore, this requirement include required data assessment.) (Note 2: Required was not fully met. SLAMS must monitor PM 2

. 5 with NAAOScomparable monitor at the required sample frequency.) 25. For SPMs listed as non-regulatory, note the start 58.20(c) Incomplete No See comment in Row 18. Both Humboldt Hill and
Date ofFRM!FEM/ARM at SPM. If> 24 months, Weaverville PM 2

. 5 GRIMMs are SPMs. While start and monitor is eligible for comparison to the dates were provided and these instruments were NAAQS per 58.11 (e) and 58.30, the agency must called non-regulatory on pg 13, information was not supply information that App A, C or E requirements provided showing that App. A, C or E were not met.

were not met. Unless information is provided and approved showing these monitors should be considered nonregulatory, the data will be considered regulatory.

All other criteria pollutant SPMs are listed as being

run for NAAQS comparison.
26. Document how states and local agencies provide for 58.10 (c) Yes,pg 16 Yes the review of changes to a PM 2 

### .s monitoring network that impact the location of a violating PM 2 

### .s monitor. 27. Does the plan include a request for approval for and 58.11 (a)(2) NA NA The plan did not request such an approval. alternative to appendix A requirements for SPMs operating a FRMIFEM/ ARM which also meets appendix.E? 28. Precision/ Accuracy reports submitted to AQS 58.16(a); Yes,pg 17 Yes AppA, 1.3 and 5.1.1

--- -- - - - - - - - - - 

### 4

## ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If 

## information CFR58 yes, page #s. provided 3 

## meet Flag if 

## thereq? 4 

## incorrec;r? 29. Annual data certification submitted 58.15 Yes,pg 17 Yes ARB 

### has submitted data certification; NCU 

### will take App. A 1.3 over 

### this responsibility starting in 2013. 30. Frequency of flow rate verification for manual PM AppA3.3.2 Yes, pg 18-27 Yes Recommend basing frequency of flow rate samplers audit verifications on the required calendar time-frame, as opposed to doing it by# sample runs. For PMIO 

### hivol filter based instruments, this would 

### be once every three months (as opposed to every 15 sampling runs). 31. Frequency of flow rate verification for automated AppA3.2.3 Yes, pg 18-27 Yes PM analyzers audit 32. Frequency of one-point flow tate verification for Ph AppA NA NA No Pb instruments. samplers audit 3.3.4.1 33. Frequency of one-point QC check (gaseous) App.A3.2.1 Yes, pg 18-27 Yes 34. Date of last Annual Performance Evaluation App.A3.2.2 Yes Yes (gaseous) 35. Dates of last two semi-annual flow rate audits for App A, 3.2.4 No 

### ? - insufficient info Did not include this information in the plan. Please PM monitors and 3.3.3 to judge whether include dates in subsequent plans. requirement is met 36. Dates oflast two semi-annual flow rate audits for Pb AppA NA NA No Pb instruments. monitors 3.3.4.1 37. PM2

. s collocation App A 3.2.5 Incomplete

- pg 16 NA NCU is part of the ARB PQAO
, and relies on the entire PQAO network to satisfy collocation requirements. It is ARB's responsibility to show that this requirement is met. ARB is currently working

on a network document that should address this. (NCU does not currently have any collocated monitors

. ) Note: NCU's statement, "No collocation ofSPM monitors is required," pg 16 and 13, is not correct. Unless SPMs are non-regulatory, collocation is required as they are eligible for comparison to the NAAQS. 38. Designation of a primary monitor 

### if there 

### is more Need 

### to NA NA NCU does not have more than one monitor for a than one monitor for a pollutant at a site. determine pollutantat a site at this time. collocation 39. Distance between collocated monitors (Note: waiver App.A NA NA No collocated monitors in NCU network. request or the date of previous waiver approval must 3.2.5.6 and be included 

### if the distance deviates from 3.2.6.3 requirement)



### 5

### ANP requirement Citation Was t h e info Does t h e Notes within 4 0 submitted? 1 

### If in fo rm ation CF R 58 

## yes, page 

## #s. provided 3 

### meet Flag if the req? 4 

### incorrecr? 40. Manual PM 10 method collocation met? (note: App A 3.3.1 No, not discussed NA NCU is part of the ARB PQAO, and relies on the continuous PM 10 does not have this requirement) in plan. entire PQAO network to satisfy collocation requirements. It is ARB's responsibility to show that this requirement is met. ARB is currently working

on a network document that should address this. (NCU does not currently have any collocated monitors.) 41. Pb collocation AppA NA NA No Ph monitors 3.3.4.3 42. PM 10
.. 2 

### .s collocation (note: only applies to Fresno and AppA3

. 3.6 NA NA Phoenix NCo r e sites) 43. Instrument/monitoring method code for each App C 2.4.1.2 Yes, pgs 18-27 Yes monitor: 

### is it reported properly? Is it reported correctly (i.e., appropriate method code for regulatory monitors)? 44. F or agencies that share monitoring responsibilities in App D2(e) NA NA

an MSNCSA: does each affected State or local i agency meet full monitoring requirements or 

### is i an agreemen t between the affected agenc i es and the

I EPA Regional Administrator in place? 45. Start date for each monitor Required to Yes, pgs 18-27 Yes determine i f otherreq. (e.g., min# and colloc) I are met 46. Instrument monitor type for each monitor Required to Yes Yes determine 

### if otherreq. (e.g., min# and coiloc)

are met 47. Monitoring objective for each instrument AppD 

### 1.1 Yes, pgs 18-27 Yes 58.10 CbX6) 48. Site type for each instrument App D 

### 1.1.1 Yes, but incorrect Yes EPA incorrectly identified "population oriented" as a in some instances site type in last year's response letter. NCU was correct that it should be "population exposure." 49

. Instrument parameter code for each instrument Required t o Y e s, pgs 1 8

- 27 Yes 

### 6

## ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If 

## information CFRS8 yes, page #s. provided 3 

## meet Flag if 

## the req? 4 

## incorrecr? determine 

### if otherreq. (e.g., min# and colloc)

are met 

# so. Instrument parameter occurrence code for each, Required to Yes Yes instrument determine 

### if otherreq. (e.g., min# and colloc)

are met 51. Sampling season for ozone (note: date of waiver 58.10 (b)(4) Yes Yes approval must be included 

### if the sampling season App D, 4.1(i) ' 

### deviates from requirement) 52. Sampling schedule for PM 2

. 5
- 

### applies to year-round 58.10 (b)(4) Yes, but incorrect

- No Jacobs is listed as running an FRM. Per 40CFR58, it and seasonal sampling schedules (note: date of 58.12(d) pg 19 should be sampling at a I :3 sampling frequency, or waiver approval must be included if the sampling AppD4.7 be collocated with a continuous instrument. season deviates from requirement) EPA flowchart 53. Sampling schedule for PM 10 

### 58.10 (b)(4) Yes Yes 58.12(e) AppD4.6 54. Sampling schedule for Pb 58.10 (b)(4) NA NA 58.12(b) App04.5 55. Sampling schedule for PM 10

.. 2 

### .s 58.10 (b)(4) NA NA 58.12(f) AppD4.8 56. Minimum# of monitors for 0 3 

### [Note: should be App D, 4.1(a) Yes Yes No ozone monitors required. supported by MSA ID, MSA population, DV, # and monitors, and# required monitorsJ (see footnote) 7 

### TableD-2 57. Identification of max. cone

. 0 3 

### monitor(s) AppD4.1 (b) NA NA While NCU does not have any required ozone sites, EPA recommends considering whether your network

- --- - '---------

- - 

### contains a max <!_zone monitor with your next

7 

### Only monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements. 

### In addition, ozone monitors that do not meet traffic count/distance requirements to be neighborhood scale ( 40 CFR 58 Appendix E, Table E-1) cannot be counted towards minimum monitoring requirements. 

## 7

## ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If 

## information

I



## . CFR58 yes, page #s • provided 3 

## meet Flag if 

## the req? 4 

## incorrecf? network plan, or during your 5-year Network Assessment. 58. Minimum monitoring requirements met for near- AppD4.3.2 Yes Yes No required N0 2 sites. road N0 2 (2014 start date) 59. Minimum monitoring requirements met for area-

**~ppD4.3.3** 

### Yes Yes No required N0 2 sites. wideN0 2 60. Minimum monitoring requirements met for RA-40 AppD4.3.4 Yes Yes No required N0 2 sites. N02 61. Minimum monitoring requirements met for

**S~** 

### AppD4.4 Yes Yes No required S0 2 sites [Note: Only monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements.] 62. Minimum monitoring requirements met for Pb AppD4.5 Yes Yes No required Pb sites. [Note: Only monitors considered to be required 58.13(a) SLAMs are eligible to be counted towards meeting minimum monitoring requirements.] 63. Minimum # of monitors for PM 2 .s [Note 1: should be

. AppD, Yes Yes No required PM 2

. 5 

### sites. Running 1 SLAMs. supported by MSA ID, MSA population, DV, # 4.7.1(a) and monitors, and# required monitors] [Note 2: Only TableD-5 monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements.] 

### 64. Optional PM 2

. 5 

### Network Clarifications: Provide a list Need to NA NA Did not do. Do not have any required PM 2

. 5 

### sites per of required sites if 

### it does not include all 

### SLAMS. assess several regulation or plans. [Note: default will assume all 

### SLAMS are requirements considered required sites.] 65. Required PM 2

. 5 

### sites represent area-wide air 

### quality AppD NA NA No required PM 2

. 5 

### sites. Jacobs and Humboldt Hill 

### 4.7.1(b) are listed as neighborhood scale, 66. For PM 2

_ 5 , 

### is at least one site at neighborhood or AppD NA NA While NCU does not have any required PMu sites, larger scale in an area of expected maximum 4.7.l(b)(l) EPA recommends considering whether your network concentration contains a max concentration monitor at a neighborhood or larger scale with your next network plan, or during your 5-year Network Assessment. 67. If additional SLAMS PM 2 .s required, is there a site in AppD NA NA No required PM 2

. 5 

### sites. NCU has one SLAMS

an area of poor air 

### quality 4.7.1(b)(2) PM2.s monitor

. 68. Minimum monitoring requirements for continuous AppD4.7

. 2 Yes Yes No required continuous PM 2 .s instruments. PM2.s

----- --- 

## 8

## ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If 

## information CFR58 yes, page #s. provided 3 

## meet Flag if 

## the req? 4 

## incorrecf? 69. Requirements for 

### PM 2 

### .s background and transport AppD4.7.3 NA NA No required PM 2 

### .s sites. sites 70. Are PM 2 

### .s Chemical Speciation requirements met for AppD4.7.4 NA NA No STN sites in NCU

. . official STN sites? 71. Minimum # 

### of monitors for PM 10 

### AppD,4.6 Yes Yes All3 counties are nonattainment for the state PM 10 

### (a) and Table standard. Each county therefore 

### has 1 SLAMS PM 10 

### D-4 monitor. There are no PM10 monitors required under federal requirements or plans. 

### 72. Minimum monitoring requirements met for PMu>. 2 

### .s AppD4.8 Yes Yes No PM 1 

### a- 2 

### .s monitors required. mass 73. Distance of site from nearest road AppE6 Yes, pg 18-27 Yes 74. Traffic count of nearest road AppE Yes, pg 18-27 Yes 75. Groundcover AppE 3(a) Yes, pg 18-27 Yes 76. Probe height AppE2 Yes, pg 18-27 Yes 77. Distance from supporting structure AppE2 Yes, pg 18-27 Yes 78. Distance from obstructions on roof AppE4(b) Yes, pg 18-27 Yes 79

. Distance from obstructions not on roof AppE4(a) Yes, pg 18-27 Yes Recommend noting how high the obstacle is above the probe in addition to distance. 80. Distance from trees AppE5 Yes, pg 18-27 Yes 81. Distance to furnace or incinerator flue AppE

. 3(b) Yes, pg 18-27 Yes 82. Unrestricted airflow AppE, 4(a) Yes, pg 18-27 Yes and4@ ' 

### 83. Probe material 

### (if applicable) AppE9 Yes, pg 18-27 Yes 84. Residence time 

### (if applicable) AppE9 Yes, pg 18-27 Yes



## 9

### Public Comments on Annual Network Plan Were comments submitted to the S/L/T agency during the public comment period? No. If no, skip the

· remaining questions. If yes:
• Were any of the comments substantive?

o 

### If yes, which ones? )

o Explain basis for determination if any comments were considered not substantive:

• Did the agency respond to the substantive comments?

o If yes, was the response adequate?

• Do the substantive comments require separate EPA response (i.e., agency response w.asn't adequate)?

• Are the sections of the annual network plan that received substantive

- comments approvable after consideration of comments?

o If yes, provide rationale:

10