Manager, Air Monitoring Division

Ventura County Air Pollution Control District

669 County Square Drive, 2nd Floor

Ventura, California 93003-5417

Dear Mr. Field:

Thank you for your submission ofthe Ventura County Air Pollution Control District’s (APCD’s)2013 Ambient Air Monitoring Network Plan in July 2013. We have reviewed the submitted

document based on the requirements set forth under 40 CFR 58. Based on the information

provided in the plan, EPA approves all portions ofthe network plan except those specifically

identified below. With this plan approval, we also note that EPA Headquarters has approved the

following change to the PAMS network, per 40 CFR 58.11(c): discontinuation of continuous

hydrocarbon sampling at Simi Valley-Cochran Street monitoring station.

Please note that we cannot approve portions ofthe annual network plan for which theinformation in the plan is insufficient to judge whether the requirement has been met, or for

which the information, as described, does not meet the requirements as specified in 40 CFR

58.10 and the associated appendices. EPA Region 9 also cannot approve portions ofthe plan for

which the EPA Administrator has not delegated approval authority to the regional offices.Accordingly, the first enclosure (A. Annual Monitoring Network Plan Items where EPA is Not

TakingAction) provides a listing ofspecific items of your agency’s annual monitoring network

plan where EPA is not taking action. The second enclosure (B. Additional Items Requiring

Attention) is a listing of additional items in the plan that EPA wishes to bring to your agency’s

attention.

The third enclosure (C. Annual Monitoring Network Plan Checklist) is the checklist EPA used to

review your plan for overall items that are required to be included in the annual network plan

along with our assessment of whether the plan submitted by your agency addresses those

requirements.The first two enclosures highlight a subset ofthe more extensive list ofitems reviewed in the

third enclosure. All comments conveyed via this letter (and enclosures) should be addressed

(through corrections within the plan, additional information being included, or discussion) in

next year’s annual monitoring network plan.

Pnnted on Recycled Paper
Meredith Kurpius, Mana r

Air Quality Analysis Office

Enclosures:

A. Annual Monitoring Network Plan Items where EPA is Not Taking ActionB. Additional Items Requiring Attention

C. Annual Monitoring Network Plan Checklist

cc: Michael Villegas, Ventura County APCD

Gayle Sweigert, California Air Resources Board
(

)

g

g

j

pp

EPA Administrator. Therefore, we are not acting on these items.

• EPA identified items in you agency’s annual network plan where a requirement was not

being met or information in the plan was insufficient to judge whether the requirement

was being met based on 40 CFR 58.10 and the associated appendices. Therefore, we are

not acting on ofthe following items:

Item Checklist Row Issue

Instrument monitor type 46 Incorrect in one instance

Parameter code for each 49 Insufficient information to judge in one

instrument instance

Additional information for each ofthese items may be found for the row listed in column 2, in

the third enclosure (C. Annual Monitoring Network Plan Checklist).
• [Item 34] The requirement to meet the biannual Annual Performance Evaluation

(gaseous) was described. It would be helpful to provide 1-2 dates for verification.

• [Item 35] The last two semi-annual flow rate audits for PM monitors at Piru Station PM25

FEM monitor and Simi Valley PM monitors are listed as occurring on 11/2012 and

5/2013. Tn future, ifthe last two flow rate audits occurred in different calendar years,

please list dates for the three most recent audits (ie, for a plan submitted in 2014, please

list the two audits that occurred in calendar year 2013, as well as any audits available

from 2014).

• [Item 44] Per 40 CFR 58 Appendix D, section (2)(e), the EPA Regional Administrator

and state or local agencies ... “may divide the overall MSAICSA monitoring

responsibilities and requirements among the various agencies to achieve an effective

network design. Full monitoring requirements apply separately to each affected State or

local agency in the absence of an agreement between the affected agencies and the EPA

Regional Administrator.” For future plans, please state if an agreement has been made to

share network design responsibilities for any MSAs in your jurisdiction and attach

documentation.

• [Items 52-5 3] Ifthere is no seasonal sampling or alteration from expected sampling

frequency, then the “current sampling frequency” and the “calculated sampling

frequency” should be the same. Please clarify in next year’s plan.
C. ANNUAL MONITORING NETWORK PLAN CHECKLIST

(Updated 11/26/2013)

Year: 2013

Agency: Ventura County APCD

40 CFR 58.10(a)(1) requires that each Annual Network Plan (ANP) include information regarding the following types o

monitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, STN stations, S

stations, and/or, in serious, severe and extreme ozone nonattainment areas, PAMS stations, and SPM monitoring station

40 CFR 58.10(a)(1) further directs that, “The plan shall include a statement of purposes for each monitor and evidence t

each monitor meets the requirements of appendices A, C, D, and E ofthis part, where applicable.” On this basis, review 

requirements listed in 58.10 along with those in Appendices A, C, D, and E.

EPA Region 9 will not take action to approve or disapprove any item for which Part 58 grants approval authority to the 

Regional Administrators, but we will do a check to see ifthe required information is included and correct. The items req

Administrator are: PAMS, NCore, and Speciation (STN/CSN).

Please note that this checklist summarizes many ofthe requirements of 40 CFR Part 58, but does not substitute for those 

contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in 

comments on its contents and structure.

Key:

White = meets the requirement.

Yellow = requirement is not met, or information is insufficient to make a determination. Action requested in next year’

process. (items listed in Enclosure A)

Green item requires attention in order to improve next year’s plan (items listed in Enclosure B)
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

Submit pian by July 1st 58.10 (a)(1) Yes, late Yes Plan was submitt

Submittal letter

2. Statement of purpose for each monitor 58.10 (a)(l) Yes Yes

Table 3 (p. 8)

Appendix A—

detailed station

information

3. 30-day public comment I inspection period 5 58.10 (a)(1), Yes, cover letter Yes

58.10 (a)(2)

4. Modifications to SLAMS network — case when we 58.10 (a)(2) Yes, p 13-21 Yes In summer or fall 

are not approving actual system modifications (i.e., 58.10(e) sampler will be r

we will do it outside the ANP process 6) at Simi Valley. P

requesting appro

5. Modifications to SLAJvIS network — case when we 58.10 (a)(2) Yes, p 13-21 Yes Plan includes req

are approving actual system modifications per 58.10 (b)(5) hydrocarbon sam

58.14(c) 58.10(e) equipment failur

, 58.14 (c) within the PAMs 

4OCFRS8. 11(c), 

to approve chang

headquarters has 

discontinuation o

sampling at Simi 

6. Does plan include documentation (e.g., attached Yes, Appendix F Yes Plan includes att

approval letter) for system modifications that have system modificat

been approved since last ANP approval? -2012 monitoring 

including the rep

Oaks FRMs with 

-Final PM2.5 ne

Response options: NA (Not Applicable), Yes, No, Incomplete, Incorrect. The responses “Incomplete” and “Incorrect” assume that some inform

2 To the best of our knowledge.

Assuming the information is correct

“Response options: NA (Not Applicable) — [reason], Yes, No, Insufficient to Judge.

The affected state or local agency must document the process for obtaining public comment and include any comments received through the pu

their submitted plan. -

6 See 58. 14(c)
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

.

Flag if the req? 4

incorrect 2?

study shows go

FEMs

- Discontinuatio

-Replacement o

Valley sites wit

2012

-Final PM1O ne

PM1O FEMs at 

collocation with 

7. NCore site operational (by 1/1/2011) 58.10 (a)(3) N/A N/A

8. Pb site for 0.5-1.0 tpy sources operational (by 58.10 (a)(4) N/A N/A No requirement

12/27/2011)

9. NO2plan for area-wide and RA4O sites submitted by 58.10 (a)(5) N/A N/A No requirement

7/1/2012

10. NO2area-wide and RA4O sites operational by 58.10 (a)(5) N/A N/A No requirement

1/1/2013

11. NO2plan for near-road sites submitted by 7/1/2013 58.10 (a)(5) N/A N/A Not required to 

2017. p 18-19 o

information.

12. SO2sites operational (by 1/1/20 13) 58.10 (a)(6) N/A N/A

and 58.13(d)

13. AQS site identification number for each site 58.10 (b)(1) Yes, Appendix B Yes

14. Location of each site: street address and geographic 58.10 (b)(2) Yes, Appendix B Yes

coordinates

15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes, Appendix B Yes

parameter

16. Any proposals to remove or move a monitoring 58.10 (b)(5) Yes, p13-21 Yes See item 4; Als

station within a period of 18 months following plan the justification 

submittal Valley monitori

plan”

17. Scale ofrepresentativeness for each monitor as 58.10(b)(6); Yes, p 7-8 Yes

defined in Appendix D App D

18. Identification ofsites suitable and sites not suitable 58.10 (b)(7) Yes Yes

for comparison to the annual PM2.5NAAQS as Appendix B —

described in Part 58.30 detailed station

information

19. MSA, CBSA, CSA or other area represented by the 58.10 (bX8) Yes, Appendix C Yes
ANP requirement Citation Was the info Does the Notes

within 40 submifted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

monitor

20. Designation of any Pb monitors as either source- 58.10 (b)(9) N/A N/A

oriented or non-source-oriented

21. Any source-oriented Pb site for which a waiver has 58.10 (b)(1 0) N/A N/A

been granted by EPA RA

22. Any Pb monitor for which a waiver has been 58.10 (b)(1 1) N/A N/A

requested or granted by EPA RA for use of Pb-PM 10

in lieu ofPb-TSP

23. Identification ofrequired NO2monitors as either 58.10 (b)(12) Yes, Section 3.2.4 Yes

near-road or area-wide p18

24. Identification of any PM2.5FEMs and/or ARMs not 58.10 (b)(13) N/A N/A

eligible to be compared to the NAAQS (Note 1: must 58.11 (e)

include required data assessment.) (Note 2: Required

SLAMS must monitor PM25 with NAAOS

comparable monitor at the required sample

frequency.)

25. For SPMs listed as non-regulatory, note the start 58.20(c) N/A N/A

Date ofFRM/FEM/ARM at SPM. If> 24 months,

and monitor is eligible for comparison to the

NAAQS per 58.11 (e) and 58.30, the agency must

supply information that App A, C or E requirements

were not met.

26. Document how states and local agencies provide for 58.10 (c) Yes, Appendix C Yes

the review of changes to a PM2.5monitoring network

that impact the location of a violating PM2.5monitor.

27. Does the plan include a request for approval for and 58.11 (a) (2) N/A N/A

alternative to appendix A requirements for SPMs

operating a FRM/FEMJARM which also meets

appendixE?

28. Precision/Accuracy reports submitted to AQS 58.16(a); Yes, p 10 Yes

AppA, 1.3

and 5.1.1

29. Annual data certification submitted 58.15 Yes, plO and Yes

App. A 1.3 Appendix F

30. Frequency of flow rate verification for manual PM App A 3.3.2 Yes, Appendix B Yes

samplers audit

31. Frequency offlow rate verification for automated App A 3.2.3 Yes, Appendix B Yes
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

. Flag if the req? 4

incorrect 2?

PM analyzers audit

32. Frequency of one-point flow rate verification for Pb App A N/A N/A

samplers audit 3.3.4.1

33. Frequency of one-point QC check (gaseous) App. A 3.2.1 Yes, Appendix B Yes

34. Date of last Annual Performance Evaluation App. A 3.2.2 Yes, Appendix B Insufficient The requiremen

(gaseous) information to evaluation was 

judge provide 1-2 dat

35. Dates of last two semi-annual flow rate audits for App A, 3.2.4 Yes, Appendix B Yes Audits noted fo

PM monitors and 3.3.3 and Simi Valley 

5/2013. In futur

occurred in diff

for the three mo

submitted in 20

occurred in cale

available from 2

36. Dates oflast two semi-annual flow rate audits for Pb App A N/A N/A

monitors 3.3.4.1

37. PM2.5collocation App A 3.2.5 No N/A —PQAO Ventura County 

requirement and relies on the 

. collocation requ

to show that thi

currently worki

. address this. (V

collocated PM2

collocated PM1O 

monitoring stati

PMIO FRM sam

38. Designation of a primary monitor ifthere is more Need to Yes, Appendix B, Yes

than one monitor for a pollutant at a site. determine B-13

collocation

39. Distance between collocated monitors (Note: waiver App. A Yes Yes There is one co

request or the date of previous waiver approval must 3.2.5.6 and Simi Valley mo

be included ifthe distance deviates from 3.2.6.3 . from the primar

requirement.)

40. Manual PM10 method collocation met? (note: App A 3.3.1 Yes, Appendix E N/A Addressed by P

continuous PM10 does not have this requirement)

41. Pb collocation App A N/A N/A No requirement
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

3.3.4.3

42. pM10.25collocation (note: only applies to Fresno and App A 3.3.6 N/A N/A

Phoenix NCore sites)

43. Instrument/monitoring method code for each App C 2.4.1.2 Yes Yes

monitor: is it reported properly? Is it reported

correctly (i.e., appropriate method code for

regulatory monitors)?

44. For agencies that share monitoring responsibilities in App D 2(e) Yes, Section 2.3.3 Insufficient to Per 40 CFR 58 A

an MSA/CSA: does each affected State or local judge Regional Admini

agency meet full monitoring requirements or is “may divide the o

an agreement between the affected agencies and the responsibilities a

EPA Regional Administrator in place? agencies to achie

monitoring requir

affected State or 

agreement betwe

EPA Regional A

please state if an 

network design r

jurisdiction and a

45. Start date for each monitor Required to Yes, Appendix B Yes

. determine if

other req.

(e.g., min#

and colloc)

are met

46. Instrument monitor type for each monitor Required to Yes, Appendix B Incorrect in one Non-FEM PM2.5 

determine if instance Cochran Street li

other req. instrument shoul

(e.g., min #

and colloc)

are met

47. Monitoring objective for each instrument App D 1.1 Yes, Table 3, p8 Yes

58.10 (b)(6)

48. Site type for each instrument App D 1.1.1 Yes, Appendix B Yes

49. Instrument parameter code for each instrument Required to Yes, Appendix B Insufficient to PM1O FEM at S

determine if judge in one 81 102-3. Please 

other req. instance

(e.g., mm #
ANP requirement Citation Was the info Does the Notes

within 40 submitted? 1If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

and colloc)

are met

50. Instrument parameter occurrence code for each Required to Yes, Appendix B Yes

instrument determine if

other req.

(e.g., mm #

and colloc)

. are met

51. Sampling season for ozone (note: date of waiver 58.10 (b)(4) Yes, Appendix B Yes

approval must be included ifthe sampling season App D, 4.1(i)

deviates from requirement)

52. Sampling schedule for PM25 - applies to year-round 58.10 (b)(4) Yes, Appendix B Yes Ifthere is no se

and seasonal sampling schedules (note: date of 58.12(d) expected sampl

waiver approval must be included ifthe sampling App D 4.7 sampLing frequ

season deviates from requirement) EPA frequency” sho

flowchart year’s plan.

53. Sampling schedule for PM10 58.10 (bX4) Yes, Appendix B Yes Ifthere is no se

58.12(e) expected sampl

App D 4.6 sampling frequ

frequency” sho

year’s plan.

54. Sampling schedule for Pb 58.10 (b)(4) N/A N/A No requiremen

58.12(b)

AppD4.5

55. Sampling schedule for pM10.25 58.10 (b)(4) N/A N/A

58.12(f)

. AppD4.8

56. Minimum # of monitors for 03 [Note: should be App D, 4.1(a) Yes, Appendix C Yes

supported by MSA ID, MSA population, DV, # and

monitors, and # required monitors] (see footnote) 7 Table D-2

57. Identification of max. conc. 03 monitor(s) App D 4.1 (b) Yes, Section 2.3.1 Yes

and AppendixB

58. Minimum monitoring requirements met for near-road App D 4.3.2 N/A N/A Requirement be

NO2(2014 start date)

Only monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements. In addition, o

traffic count/distance requirements to be neighborhood scale (40 CFR 58 Appendix E, Table E-1) cannot be counted towards minimum monito
ANP requirement Citation Was the info Does the Notes

within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

59. Minimum monitoring requirements met for area- App D 4.3.3 N/A N/A There is no requi

wide NO2 monitoring in Ve

60. Minimum monitoring requirements met for RA-40 App D 4.3.4 N/A N/A There are no N02 

NO2 County for RA-4

61. Minimum monitoring requirements met for SO2 App D 4.4 Yes, Appendix C, Yes

[Note: Only monitors considered tobe required C-4

SLAMs are eligible to be counted towards meeting

minimum monitoring requirements.]

62. Minimum monitoring requirements met for Pb App D 4.5 Yes, Appendix C, Yes

[Note: Only monitors considered to be required 58.13(a) C-6

SLAMs are eligible to be counted towards meeting

minimum monitoring requirements.]

63. Minimum # of monitors for PM2.5[Note 1: should be App D, Yes, Appendix C, Yes

supported by MSA ID, MSA population, DV, # 4.7.1(a) and C-2

monitors, and # required monitors] [Note 2: Only Table D-5

monitors considered to be required SLAMs are

eligible to be counted towards meeting minimum

monitoring requirements.]

64. Optional PM2.5Network Clarifications: Provide a list Need to N/A N/A

ofrequired sites ifit does not include all SLAMS. assess several

[Note: default will assume all SLAMS are requirements

considered required sites.]

65. Required PM2.5sites represent area-wide air quality App D Yes, Table 3 Yes

4.7.1(b)

66. For PM25,is at least one site at neighborhood or App D Yes, Table 3 Yes

larger scale in an area of expected maximum 4.7.l(b)(1)

concentration

67. If additional SLAMS PM2.5required, is there a site in App D N/A N/A

an area of poor air quality 4.7. 1(b)(2)

68. Minimum monitoring requirements for continuous App D 4.7.2 Yes, Appendix C, Yes

PM25 C-2

69. Requirements for PM2.5background and transport App D 4.7.3 N/A N/A

sites

70. Are PM2.5Chemical Speciation requirements met for App D 4.7.4 Yes, Section 2.3.3 Yes

official STN sites?

71. Minimum # of monitors for PM10 App D, 4.6 Yes, Appendix C, Yes

(a) and Table C-3
ANP requirement Citation Was the info Does the Notes

. within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3meet

Flag if the req? 4

incorrect 2?

D-4

72. Minimum monitoring requirements met for PM1025 App D 4.8 N/A N/A PMIO-2.5 moni

mass stations and the

station in Ventu

73. Distance ofsite from nearest road App E 6 Yes, Appendix B Yes

74. Traffic count of nearest road App E Yes, Appendix B Yes

75. Groundcover App E 3(a) Yes, Appendix B Yes

76. Probe height App E 2 Yes, Appendix B Yes

77. Distance from supporting structure App E 2 Yes, Appendix B Yes

78. Distance from obstructions on roof App E 4(b) Yes, Appendix B Yes

79. Distance from obstructions not on roof App E 4(a) Yes, Appendix B Yes

80. Distance from trees App B 5 Yes, Appendix B Yes

81. Distance to furnace or incinerator flue App E 3(b) Yes, Appendix B Yes

82. Unrestricted airflow App E, 4(a) Yes, Appendix B Yes

and 4(b)

83. Probe material (if applicable) App E 9 Yes, Appendix B Yes

84. Residence time (if applicable) App E 9 Yes, Appendix B Yes

Public Comments on Annual Network Plan

Were comments submitted to the S/LIT agency during the public comment period?

If no, skip the remaining questions.

If yes:

No.

• Were any ofthe comments substantive?

o If yes, which ones?

o Explain basis for determination if any comments were considered not substantive:

• Did the agency respond to the substantive comments?

o If yes, was the response adequate?

• Do the substantive comments require separate EPA response (i.e., agency response wasn’t adequate)?

• Are the sections ofthe annual network plan that received substantive comments approvable after consideration o

o If yes, provide rationale: