Bryan W. Shaw, Ph.D., Chairman

Buddy Garcia, Commissioner

Carlos Rubinstein, Commissioner

Mark R. Vickery, P.G., Executive Director

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Protecting Texas by Reducing andPreventing Pollution

March 31, 2011

AI Armendariz, Ph.D.

Regional Administrator

United States Environmental Protection Agency

Region 6

1445 Ross Avenue, Suite 1200

Dallas, Texas 75202-2733

Re: Ambient Air Monitoring Requests

Dear Dr. Armendariz:

Thank you for your December 23, 2010 letter approving our 2010 Annual Air

Monitoring Network Plan. In that letter you requested that we resolve several issues

before submittal ofthe 2011 Network Review. To facilitate resolution ofthose issues,

you requested that we submit a response for your review by March 31, 2011. The

enclosed document describes our response to these issues: These responses should

serve as the basis for further dialog between our staffs.

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

at (512) 239-5105, or your staff may contact David Bower, Director of our Field

Operations Support Division, at (512) 239-2953.

Enclosure

P.O. Box 13087 Austin, Texas 78711-3087 512-239-1000 Internet address: www.tceq.state.tx.us

printed on recycled paper using soy-based ink
Requests Re: 2010 Annual Network Review (ANR)

Per 12/23/2010 Letter

En"iron01e~taIPr6~~~i()rt : :

:Texasi COnlrrtissiorl:onEn"ircjnmeritalQual i~y{TCEG),)" 'I", .1"'.'; Target'

Agency{EpjqReqa~st:::. , '. Response. ,....,. " ·i' ":.

., .... :.. i . ..... ' completion

Particulate Matter Topics

Bayway Drive and South Padre TCEQ was under the impression that EPA approved 1-in-6 12/31/2011

Island to sample on a 1-in-3 day day frequency at these sites through the 2007 and 2006

frequency ANRs, respectively. TCEQ will replace these filter-based

samplers with continuous samplers.

Continued Particulate Matter 2.5 TCEQ will continue operation of this sampler. Completed

(PM2.5) sampling at Fort Worth

Northwest

Continued PM2.5 sampling at TCEQ will continue operation ofthis sampler. Completed

San Antonio Calaveras

Install a collocated PM monitor TCEQ will install a collocated sampler at San Antonio 12/31/2011

in the San Antonio Metropolitan Calaveras.

Statistical Area (MSA).

Continued PM2.5 sampling at TCEQ will replace the filter-based sampler with a 12/31/2011

Austin Audubon. continuous sampler.

Install a collocated PM monitor TCEQ will install a collocated sampler at Austin Audubon in 12/31/2011

in the Austin MSA. 201l.

Clarify plans for changes at PM TCEQ will clarify these plans in the 2011 ANR. 7/1/2011

monitors in Corpus.

Evaluate entire PM2.5 network. TCEQ will include an evaluation of the PM2.5 network in 7/1/2011

the 2011 ANR.

Identify a regional PM2.5 TCEQ will use the Karnack site as a regional PM2.5 Completed

background site. background site.

Addition of PM samplers in EL Due to other demands, TCEQ has not been able to make 12/31/2011

Paso, Corpus, and Galveston and these non-required network changes as described in the

at Clinton Drive as described in 2010 ANR. If resources allow, the changes may be

the 2010 ANR. implemented in 201l.

Lead Topics

Renew or resubmit waivers for TCEQ will review the emissions inventory results for these ANR every

Fort Hood and Oxbow Calcining sources annually to ensure they do not increase such that five years

every five years or sooner if they would no longer qualify for the waivers.

emissions increase.

Confirm Air Quality System (AQS) TCEQ confirms that these AQS identifiers will stay the same Completed

identifiers and spatial scale for as prior to the relocation and they will maintain the middle

48-085-0003 and 48-085-0009. spatial scale classification.

Confirm that TCEQ considers AQS TCEQ confirms that AQS 48-085-0009, at its new location, is Completed

48-085-0009, at its new location, considered representative of ambient air.

to be representative of ambient ..

air.

Confirmation that a source- TCEQ confirms that all required one ton per year source- Completed

oriented lead monitoring site has oriented lead monitoring sites have been established.

been established at the required

one ton per year sources. ,
Environmental Protection

Agency (EPA) Request

Advise ~PA o,f plans to meet the

20+0 lead monitoring rule.

Need for confirmation on

rep.resentath~e status for 31

~onitoring sites

Texas Commission on Environmental Quality (TCEQ)

Response

TCEQ has begun assessing the sources that will be subject

to source oriented monitoring under the 2010 lead rule.

This has been delayed by late issuance of the 2008 National

Emissions Inventory (NEI). TCEQ proposes to base the

decisions for source oriented monitoring on the 2009 Texas

Emissions Inventory instead of the 2008 NEI as the data is

more up to date. TCEQ will describe plan's to meet the

requirements' ofthe 2010 lead monitoring rule in the 2011

ANR:

The 31 sites identified during the Technical Systems Audit

as having some access limitations have been confirmed as

measuring ambient air for general air quality as they are

Target

Completion

7/1/2011

Completed

, .............. """~.,,,., ..,..'"=""···.v.,...· "'"'""_ .• "••'"=" ~"""""="!t;~~"-'-"'!~.":o:" •• ':.''!''''''''~.~ • "'=~.~""'l~~ "'""

ad'ditional review should the use of the ,site be revised to

be considered a source oriented monitor.

Relocation of Monitoring Sites

Submit, for EPA approval, the TCEQ will describe plans to relocate the Sun Metro 7/1/2011

new location and conditions for samplers in the 2011 ANR.

repfacement of Sun Metro.

Monitoring Sites listed in the Network

Confirm that NO/NOx is TCEQ confirms that NO/NOx is monitored as required at Completed

monitored in addition to N02 by various locations. Revised ANR Appendix Bto address this

submitting a revised version of issue was submitted to Ms. Maria Martinez on 1/31/2011.

the 2010 ANR Appendix B.

Submit a revised 2010 ANR TCEQ confirms that Meteorological monitoring for Completed

Appendix Bthat includes Photochemical Assessment Monitoring Stations (PAMS)

meteorological parameters at and National Core (NCORE) sites is being conducted as

specified sites. required. Revised ANR Appendix Bto address this issue

was submitted to Ms. Maria Martinez on 1/31/2011.

Submit a revised 2010 ANR TCEQ confirms that speciated volatile organic compound Partially

Appendix Bthat includes the (VOe) and total non-methane organic carbon monitoring is Completed

required samplers at the being conducted as required at the Channelview site and

Channelview, Clinton Drive, and carbonyl monitoring is being conducted as required at the Remaining

Waterworks sites. Clinton Drive site. Revised ANR Appendix Bto address this work in

issue was submitted to Ms. Maria Martinez on 1/31/2011. progress

TCEQ is attempting to relocate the Waterworks site and

resume this sampling as soon as possible. TCEQ is also Full

exploring possibilities to gain access to data from another completion

radar profiler that is operational in the Houston area. 12/31/2011

Confirm that the ozone samplers TCEQ confirms that the ozone samplers at Jefferson County Completed

at the Jefferson County Airport Airport and Sabine Pass sites will be included in the 2011

and Sabine Pass sites will be ANR as SPMs.

included in the 2011 ANR as

Special Purpose Monitors

(SPMs).

Confirm that the ozone sampler TCEQ declines to include the Wallisville Road site in the Not
'; Environnieritar"~rotedi6n ". 'TexasCori\missi6h:on~n\firorimeritaIQualitYfrCEQr '. ·· .. d. ,.Target " . Agency (EPA).Request: . Respons~·:;:··· .······.·.i/.· .. ; ':', ", '. Completion

at the Wallisville Road site will be 2011 ANR or deploy a monitor to this location on the basis Applicable

included in the 2011 ANR as an that the results from this site no longer justify this network·

SPMs or that TCEQ will deploy a revision. The results from this site are no longer among the

monitor at that location highest ozone design values} as they were for 2007-2009.

When compared to regulatory sites} results from Wallisville

Road have dropped into a tie for fourth place} with a design

value of 81 ppb. The most recent results do not justify this

network change at this time.

Data Submittal and Certification

Submit the data certification for

2009 lead and air toxics

Submit an update on 2010 data

certifications.

Confirm that the measurement

scales for all monitors are

included for all applicable

parameter codes.

The certification for the 2009 lead and air taxies data has

been submitted.

TCEQ anticipates meeting the certification deadline for all

2010 ambient air quality monitoring data.

TCEQ will confirm the measurement scales for all monitors

are included for all applicable parameter codes in the 2011

ANR.

Completed

5/1/2011

7/1/2011