Bryan W. ~h':M. Ph,D.. Clwinnan

Buddr Gaff-la.. ('omm':isiv'k'r'

Carl~ R'Uh;n5trin. CommLtrioflt'r

Hark It V'h:~kltrr. PX... £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 Protection Agency (EPA)

Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

RE: Ambient Air Monitoring Requests

Dear Ms. 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 by March 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 NOx is monitored as required at various locations (see

enclosed revised ANRAppendix B).

• Speciated volatile organic compound (VOC) and total non-methane organic

carbon monitoring is being conducted as required at the Channelview site and

carbonyl monitoring is being conducted as required at the Clinton Drive site (see

enclosed revised ANR Appendix B).

• Meteorological monitoring for Photochemical Assessment Monitoring Stations

(PAMS) and National Core (NCORE) sites is being conducted as required (see

enclosed revised ANR Appendix B).

• The Sabine Pass and Jefferson County Airport sites will be listed in the 2011 A.'lR

as ozone Special Purpose Monitors (SPMs). We are still evaluating options for

addressing EPA's request related to the Wallisville ozone monitor.

P,(). Box Clmr: 512·239·lfH.iO Intemet address.: \\""".lr£q.stale.L\.wi
Maria 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

the use ofthe site be revised to be considered a source oriented monitor.

The majority of EPA requests related to the Five Year Network Assessment wiD be

addressed through the 2011 ANR. If any information is available about these requests

before that time, we will provide it underseparate cover.

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 of molybdenum converters at

NCORE sites. We have experienced a delay in completion of this work, but expect to

meet all NCORE requirements, including the 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 some vegetation be cleared orthe inlet

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

has reviewed this situation and, taken in balance with other considerations, has decided

not to alter the sampling configuration at the Dish site until a fun year of data is

available for review.

If you have any questions concerning the information provided here, please contact me

at (512) 239-2953 or Matthew R. Baker, P.E., Assistant Director, Field Operations

Support Division at (s12) 239-1091.

Sincerely,

DavidW. Bower, P.G., Director

Field Operations Support Division

Texas Commission on Environmental Quality
Implementation !'lan for Technical Systems Aucfrt Findings

January 28, 2011

pE:":"P2~:::'~~':-:'_,,,,-'_':-:'-:;,,:;:::-"_-:-:-:-,,_'_':_:-+.J'fO$fOS=:-,:-: ...-:o,o~iR_es_PClt-:-~'-..:;-:':-:-:";~":':--,'"",:_l;,;,:_'d'"",",:"__.:..' ,:,;,_.,_.__",,"~,:;,u:~~_ "-+u '~ Notify EPA which 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 networtt to promote

efficiency and minimize required

time for protocol

implementation In order to

minimize data loss.

Conduct pb field blanks at least

once every quarter «LOLl.

Review and revise all TCEo. SOPs

every two years.

Replace the traUer at Keller.

Plug the area around the vertical

pipe supporting inlet sampling

lines to prevent air flow.

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 conducting these evaluations using audit

strips made by the 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 updated TSA checklist to darlfy the

OA/o.C procedures for non-<:ontlnuous data, Indudlng lead.

As part of the 2011 ANR, TCEo. will review the network to

promote effldency and minimize data loss.

TCEo. will develop an SOP to support collection and analysis

of field blanks on a quarterly basis.

TCEQ will develop a schedule for bl-annual review of SOPs

by the end of FY11.

TCEo. will replace the trailer at Keller by the end of FV11.

TCEo. will address sampling line air flow issues at all sites in

2011.

TCEo.will revise SOPs as necessary to better ensure copies

for all current standards used at a site are present in 2011.

TCEo. will revise SOPS to ensure that 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