BryanW. Shaw, Ph.D., Chairman Buddy Garcia, Commissioner Carlos Rubinstein, Commissioner MarkR. Vickery, P.G., ExecutiveDirector



### TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
Protecting Texas byReducingandPreventingPollution



### March 31, 2011



### AIArmendariz, Ph.D. RegionalAdministrator United States Environmental ProtectionAgency Region 6 1445 

### Ross Avenue, Suite 1200 

### Dallas, Texas 75202-2733



### Re: AmbientAirMonitoring Requests

Dear Dr. Armendariz:

ThankyouforyourDecember 23, 2010 

### letterapproving our 2010

### AnnualAir Monitoring NetworkPlan. Inthatletteryourequestedthatwe resolve severalissues before submittal ofthe 2011 

### NetworkReview. Tofacilitate resolution ofthose issues, yourequestedthatwe submitaresponseforyourreviewbyMarch 31, 2011. 

### The encloseddocumentdescribes ourresponseto these issues: Theseresponses should
serve asthebasis forfurther dialogbetween our staffs.

Ifyouhave any questions concerningthe informationprovidedhere, please contactme at (512) 239-5105, 

### oryourstaffmaycontactDavidBower, Director ofourField Operations SupportDivision, at (512) 239-2953.



### Enclosure

P.O. Box 13087 Austin, Texas 78711-3087 512-239-1000 Internetaddress: www.tceq.state.tx.us printed on recycled paper using soy-based inkRequests Re: 2010 Annual Network Review (ANR) Per 12/23/2010 Letter

### En"iron01e~taIPr6~~~i()rt : : :Texasi COnlrrtissiorl:onEn"ircjnmeritalQual**i~y{TCEG),)"** 'I", Target' .1"'.';

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. ..... ' completion Particulate MatterTopics Bayway Drive and South Padre TCEQ was underthe 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. TCEQwill replace these filter-based samplers with continuous samplers. Continued Particulate Matter 2.5 TCEQ will continue operation ofthis 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 TCEQwill 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 TCEQwill 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. TCEQwill include an evaluation ofthe PM2.5 network in 7/1/2011 the 2011 ANR. Identify a regional PM2.5 TCEQwill 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 qualifyfor 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 priorto 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 peryear 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 underthe 2010 lead rule. This has been delayed by late issuance ofthe 2008 National Emissions Inventory (NEI). TCEQ proposes to base the decisions for source oriented monitoring on the 2009 Texas Emissions Inventory instead ofthe 2008 NEI as the data is
more up to date. TCEQwill 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 airfor general air quality as they are Target Completion 7/1/2011

Completed

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ad'ditional review should the use ofthe ,site be revised to be considered a source oriented monitor. Relocation of Monitoring Sites Submit, for EPA approval, the TCEQwill 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 profilerthat 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

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at the Wallisville Road site will be 2011 ANR or deploy a monitorto this location on the basis Applicable included in the 2011 ANR as an that the results from this site no longerjustify this network· SPMs or that TCEQwill 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 atie for fourth place} with adesign value of 81 ppb. The most recent results do notjustifythis 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