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... £xl!cu/il't! Director TEXAS COMMrSSION ON ENVIRONMENTAL QUAUTY f'mltf'ding Texas**h~" R~JlJdny**  l1ud Prt.'n7Jting M,I/ul;ol1 January 31, 2011
Maria L. Martinez Chief, Air Quality Analysis Section (PD-Q) United States Environmental ProtectionAgency (EPA) Region 6 1445 RossAvenue, Suite 1200 Dallas, 

### TX 75202-2733 RE: AmbientAirMonitoring Requests DearMs. Martinez: Over the past few months, EPA has made several requests ofthe Texas Commission on Environmental Quality (TCEQ) related to topics that came up through the air quality monitoring Annual Network Review (ANR), F"we Year Network Assessment, and Technical Systems Audit (TSA). This letter provides information to satisfy several of those requests. As specified in the December 22, 2010 letter from EPA Regional Administrator 

### AI Armendariz to TCEQ Executive Director Mark R. Vickety, P.G., the remaining issues 

### will be addressed byMarch 31, 2011. At this time, the following responses are available for EPA requests related to the 2010 ANR:

• The required one ton per year source-oriented lead monitoring sites have been established.

• Nitrogen Oxide (NO) and NOxis monitored as required atvarious locations (see enclosed

### revised ANRAppendix B).

• Speciatedvolatile organiccompound (VOC) and totalnon-methane organic carbon monitoring is being conducted as required at the Channelviewsite and carbonyl monitoring is beingconducted as required at the Clinton Drive site (see enclosedrevisedANRAppendix B).

• Meteorological monitoring for Photochemical Assessment Monitoring Stations (PAMS) and National Core (NCORE) sites is being conducted as required (see enclosed revisedANRAppendix B).

• The Sabine Pass andJefferson County Airport sites will be listed inthe 2011 A.'lR as ozone Special Purpose Monitors (SPMs). We are still evaluating options for addressing EPA's requestrelatedto the Wallisville ozone monitor.

P,(). Box Clmr: 512·239·lfH.iO Intemetaddress.: \\""".lr£q.stale.L\.wiMaria L. Martinez January 31, 2011 Page 2

• The 31 sites identified during the TSA as having some access limitations have 

### been confirmed as measuring ambient air for general air quality as 

### they are currently configured. This designation would require additional review should theuse of

### the site 

### be revisedto 

### be considered a sourceorientedmonitor. The majority of EPA requests related to the Five Year Network Assessment wiD 

### be addressed through the 2011 ANR. Ifany information is available about these requests before thattime, we will provide itunderseparatecover. The enclosed document titled "Implementation Plan for Technical System Audit Fmdings" describes actions TCEQ.is planning to take to address the recommendations in 

### the TSA and proposed timeframes for those actions. Generally, the TSA report did not specify deadlines for implementation of the recommendations. However, EPA specifically requested a response regarding the elevation ofmolybdenum converters at NCORE sites. We have experienced a delay in completion ofthis work, but expect to meet all NCORE requirements, includingthe molybdenum converter elevation, by April 2011. The TSA report 

### also Inchided an addendum related to the monitoring station in Dish, Texas. 

### In this addendum, EPArecommends that somevegetation

### be cleared or

### theinlet 

### be raised to provide a clearer pathway from the sampling inlet to the source(s). TCEQ 

### has reviewed this situation and, taken in balancewith other considerations, 

### has decided not to alter the sampling configuration at the Dish site until a fun year of data is availablefor review. Ifyou have any questions concerning the informationprovided here, please contact me at (512) 239-2953 or Matthew R. Baker, P.E., Assistant Director, Field Operations SupportDivision at (s12) 239-1091. Sincerely,

DavidW. Bower, P.G., Director FieldOperations Support Division Texas Commission on Environmental QualityImplementation !'lan forTechnical Systems Aucfrt Findings January 28, 2011

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# '~ Notify EPAwhich federal TCEo. is using EQL-071o-192. 1/31/2011 equivalent method (FEM) will be used for 2010 and newer pb data. Conduct pb performance evaluations.

A single operator Is Insufficient for EI Paso. Recommend filling the vacant operator position as soon as possible. Update personnel changes In the TSA checklist. Oarlfy OA/OC procedures for non-contlnuous data (i.e., lead). Revlew the networttto promote efficiency and minimize required time for protocol implementation In orderto minimize data loss. Conduct pb field blanks at least once every quarter «LOLl. Review and revise all TCEo. SOPs everytwo years. Replace the traUer at Keller. Plug the area around the vertical pipe supporting inlet sampling linesto prevent airflow. Check for standards certificates regularly to ensure copies for all standards used are present. Update site documents, such as pictures, and longitude/latitude locations, on a relWlar basis. Implement manifold maintenance. TCEo. has begun conductingthese evaluations using audit strips made bythe Houston Lab. EPA has Indicated tlley will begin supplying strips for these evaluations In February 2011. When the EPA strips are available, they will be used. To address current needs, TCEo. has expanded the use of contracted operator services in EI Paso.

TCEo. will submit an updated TSA checklist to reflect personnel changes. TCEo. will submit an updatedTSA checklist to darlfythe OA/o.C procedures for non-<:ontlnuous data, Indudlng lead. As part ofthe 2011 ANR, TCEo. will review the networkto promote effldency and minimize data loss.

TCEo. will develop an SOP to support collection and analysis offield blanks on a quarterly basis. TCEQ will develop a schedule for bl-annual review of SOPs bythe end of FY11. TCEo. will replace the trailer at Keller bythe end of FV11. TCEo. will address sampling line airflow issues at all sites in 2011.
TCEo.will revise SOPs as necessaryto better ensure copies for all current standards used at a site are present in 2011. TCEo. will revise SOPS to ensurethat site documentation Is updated and malrrtalned on a regular basis In 2011. TCEo. will revise SOPs to ensure that manifold maintenance occurs regularly In 2011. 1/31/2011

1/31/2011

4/1/2011 4/1/2011 7/1/2011

9/1/2011
9/1/2011
9/1/2011 12/31/2011

12/31/2011

12/31/2011

12/31/2011
Clean all sites routinely. TCEo. will revise SOPs to ensure routine cleanings in 2011. 12/31/2011