UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

NOV 01 2011

Samir Sheikh, Director of Strategies and Incentives 

San Joaquin Valley Air Pollution Control District 

1990 E. Gettysburg Avenue 

Fresno, CA 93726-0244 

 

Dear Mr. Sheikh: 

Thank you for your submission of the San Joaquin Valley Air Pollution Control District’s 2011 

(SJVAPCD) Annual Air Quality Monitoring Network Plan. We have reviewed the submitted document 

and have found that the plan contains the information required by our regulations set forth under 40 CFR 

§58.10. We have also reviewed comments submitted during the public comment period held by 

SJVAPCD and have determined that the current PM2.5 network, as described in the annual network plan, 

including the plans to replace the Bakersfield-Golden PM2.5 monitor, meets or exceeds current EPA 

minimum monitoring requirements for PM2.5 set forth under 40 CFR 58, Appendix D, Section 4.7.1. 

While this letter serves as official approval of the annual network plan, it does not constitute approval of 

the system modifications that are proposed in the plan for the future. In particular we note the 

following three issues in your network need to be resolved in the upcoming year: the relocation of the 

high concentration ozone monitor from the former Arvin-Bear Mountain Road site, the relocation of the 

high concentration PM2.5 monitor from the former Bakersfield-Golden site, and the relocation of the 

PM10 monitor from the Corcoran site. We realize that some site relocations are necessary due to 

circumstances beyond SJVAPCD’s or the California Air Resource Board’s (CARB’s) control. 

However, since these three sites are high concentration sites crucial in determining compliance with the 

NAAQS, these issues should be resolved in a way that avoids data completeness problems. Also, please 

note that system modifications are subject to the requirements of 40 CFR § 58.14. 
We will schedule a meeting with you and your staff to discuss these issues and will continue to work 

with SJVAPCD and CARB to review system changes as they proceed. If you have any questions 

regarding this letter, please feel free to contact me at (415) 972-3851 or Kate Hoag at (415) 972-3970. 

 Sincerely, 

 /s/ 

 Matthew Lakin, Manager 

 Air Quality Analysis Office 

 Air Division 

Enclosure 

cc: Morgan Lambert, SJVAPCD 

Karen Magliano, CARB 
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Comments on the San Joaquin Valley APCD 2011 Network Plan 

Please update next year’s annual network plan to reflect the following comments: 

1. Consider listing the monitor method code and pollutant code and POC used in 

AQS, in addition to the FEM status to future plans to provide more information 

about how minimum monitoring requirements are met. 

2. Minimum Ozone Monitoring Requirements 

a. Table 6 lists six ozone SLAMS for operating within the Fresno MSA, where 

Table 7a only lists five. Please clarify so that Tables 6, 7a and 7b are 

consistent. 

b. Clovis and Ash Mountain sites should also be listed as high concentration 

for ozone. 

3. Minimum PM10 Monitoring Requirements 

a. Footnote 4 on Table 10 should indicate that there is one temporary 

continuous PM10 monitor in addition to the two FRMs in the Bakersfield 

MSA at the Oildale and Bakersfield-California sites. This could be also 

resolved by indicating one SPM in the Bakersfield MSA and moving the 

footnote to that column. 

b. Concentrations used to obtain minimum monitoring required should not 

exclude pending exceptional event requests. 

c. For future plans please list the start date of FEMs considered as SPMs to 

ensure they are still within their “burn-in” period per EPA’s 2008 

guidance. This includes the monitors at Fresno-First Street, Hanford and 

Corcoran. 

d. All SLAMS should have “comparison to standards” as one of the 

monitoring objectives. For example, the PM10 monitor at Madera-City is 

listed as a SLAMS but the only monitoring objectives are Research 

Support and Timely/Public. 

e. Table 10 lists one PM10 SLAMS and one PM10 SPM at Madera, but there is 

only one PM10 monitor at the Madera-City site. Please clarify. 

f. There are two PM10 SPMs in the Stockton MSA, but Table 10 only lists 

one. Please clarify. 

g. Tables 10, 11a, 11b, and Table 12 should be consistent, for example, Table 

10 and 12 list 6 PM10 SPMs, but Table 11b only lists 1 PM10 SPM. 

h. Consider listing the monitor method code and pollutant code and POC 

used in AQS, in addition to the FEM status to future plans to provide more 

information about how minimum monitoring requirements are met. 

4. Minimum PM2.5 Monitoring Requirements 

a. The Clovis PM2.5 SLAMS should list “comparison to standards” as a 

monitoring objectives since it is a SLAMS. This includes the monitors at 

Corcoran, Stockton-Hazelton, Modesto-14th St, and Turlock. 

b. The PM2.5 non-FEMs at Fresno-First Street , Bakersfield-California 

Avenue, and Visalia-Church Street should be in Table 15b as a SPMs 

rather than in Table 15a as SLAMS. 
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c. The Corcoran site has both a FRM and a FEM PM2.5 monitor, but Tables 14 

and 16 list only one SLAMS at Corcoran. 

d. Madera-City PM2.5 FEM is listed as a SLAMS in Tables 14 and 16, but it is 

listed as an SPM in Table 15b. 

e. The footnote of Table 16 says that a PM2.5 FEM replaced the PM2.5 FRM at 

Stockton-Hazelton, but table 15a does not list Standards as a monitoring 

objective. Please indicate whether there is a third monitor at this site. 

Please address the same question for Modesto-14th St. 

f. Please confirm that the PM2.5 monitor at Sequoia National Park-Ash 

Mountain is not an FEM, including the monitor description. 

g. Footnote 2 in Table 16 should apply to all PM2.5 FEM SPMs. 

h. Consider listing the monitor method code and pollutant code and POC 

used in AQS, in addition to the FEM status to future plans to provide more 

information about how minimum monitoring requirements are met. 

5. Page 30 states that no public comments were received, however SJVAPCD 

responds to the comments from NRDC in Appendix C. Please ensure these 

statements are consistent for future plans. 

6. Page 34 incorrectly lists the emission limit for source–oriented lead monitoring 

as 1.0 tpy. The threshold in the final rule is 0.5 tpy for non-airport sources and 

1.0 tpy for airports, except for those airports included in a special study which 

are listed in the rule. 

7. Please confirm that the addition of the NH3 denuders to the NOx instruments still 

meets FRM/FEM specifications. 

8. The non-FEM PM2.5 monitoring at the Bakersfield-Muni site cannot be a 

replacement for the SLAMS PM2.5 monitoring at Bakersfield-Golden.