UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX

75 Hawthorne Street San Francisco, CA 94105

November 1

, 2010

Mr. Robert Kard, Air Pollution Control Officer San Diego County Air Pollution Control District

10124 Old Grove Road San Diego, CA 92131

- 1640

Dear Mr. Kard:

Thank you for your submission of San Diego County Air Pollution Control District’s (SDCAPCD ) 2009 Ambient Air Monitoring Network Plan. We have reviewed the submitted document and have found that it meets the minimum requirements set forth under 40 CFR Part 58.10. 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. We will continue to work with your district to review system changes as they proceed.

Enclosed, please find our comments on the plan. If you have any que stions regarding this letter or the enclosed comments, 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: Mahmood Hossain, SDAPCD David Shina, SDAPCDComments on 2009 Data Year Network Plan for San Diego County APCD

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

1. The general process for soliciting public comments on the Annual Monitoring Network Plan is described on p age 2. For future plans, please also submit the specific dates of the public comment period and specify whether or not any

comments were received.

2. Please include t he design values used for determining minimum monitoring requirements . Also, the data used should include the most recent complete data year. For example, for your next Annual Monitoring Network Plan, the design values should be calculated using 2008

- 2010 data.

3. Page 11 states that there are no required monitors for NO 2 , SO 2 and Pb in

Californi a to comply with Appendix D. In future network plans, please revise

this section to reflect changed requirements due to the r ecent NAAQS revisions.

4. Page 12 outlines the requirements for PM 2.5 samplers. The table lists all the required monitors together. While most of the information needed is included in the footnotes, it might be more easily understood if the requirements and the monitors that satisfy them are listed separately. In addition, the footnote should list what monitor is fulfilling the collo cation requirement for both the FRM and the continuous requirement.

5. Please specifically state which sites are meeting the collocation requirements for

PM 2.5 and PM 10 and include proposed new collocation sites if a required site is moving or shutting down.

6. The discussion on page 12 of the suitability for comparison to the annual PM 2.5 NAAQS discusses the appropriate scale, but not the FRM/FEM/non

- FEM status of the monitors. Please include information about monitor type in this section

and ensure that it is consistent with the information presented in the detailed site

information.

7. Providing for Review of Changes to PM 2.5 Network: 40 CFR 58.10(c) says:

(c) The annual monitoring network plan must document how States and local agencies provide for the review o f changes to a PM 2. 5 monitoring network that impact the location of a violating PM 2.5 monitor or the creation/change to a community monitoring zone, including a description of the proposed use of spatial averaging for purposes of making comparisons to the annual PM 2.5 NAAQS as set forth in appendix N to part 50 of this chapter. The affected State or local agency must document the process for obtaining public comment and include any comments received through the public notification process within their submi tted plan.

The discussion on page 12 of the network plan did not fully address this requirement. As an example of the type of language that would suffice, Santa Barbara’s network plan includes the following statement:

“The PM 2.5 network of FRM monitors in California was largely established in 1999 and completed in 2000. There are two monitors located in Santa Barbara andSanta Maria as part of this larger network in California. CARB located and operates these two monitors. SBCAPCD and CARB would discuss an y proposed changes to the network of PM 2.5 monitors in Santa Barbara County prior to any formal changes being made.”

8. Page 13 lists seven PM 10 locations and page 16 states there are six PM 10 sites please make these references consistent

. For future network plans, l isting the site names in the requirements section may alleviate this confusion.

9. Page 15. The timeframe for EPA’s TSAs are every three years.

10. Please clarify which samplers in table 7 on page 18 are non

- FEMs.

11. Proposed Changes

a. For all proposed changes , when the District has completed its evaluation, please submit any request with the appropriate documentation to EPA Region 9 for approval.

b. Is concurrent monitoring being performed for all pollutants at Kearney Mesa (Overland) before the move, or just ozo ne? (There is also NO 2 , PM 2.5 , PM 10 and PAMS at this site.) Also, will the new site still be the

collocated site for PM 2.5 and PM 10 ?

c. Will there be concurrent monitoring of gaseous pollutants at the new Otay

Mesa

- Donovan site before the old site closes?

d. Pl ease submit the required information for moving the PAMS II site from

KMA/MMR to Escondido to EPA Region 9

.

e. The plan discusses shutting down the CO monitors at Chula Vista and Otay Mesa

. Since EPA is currently reviewing the CO NAAQS, please consider as pa rt of your evaluation that the CO monitoring requirements may change

. f. Please confirm whether the meteorology measurements at Mount S oledad

were requ ired by PAMS.

12. Detailed Site Information

a. The PM monitors at the Beardsley S treet site are not listed in the d etailed

site information table.

b. Siting issues:

i. The distance to trees at the Del Mar monitoring site is listed as less than the recommended 10 meters. In such cases, it would be helpful to include a footnote that characterizes the trees (e.g., tree

below height of probe, tree not in predominant wind direction, etc.). Refer to 40 CFR 58, Appendix E, S ection 5.

ii. 40 CFR 58, App. E, 6.1 and Table E

- 1 describes the minimum separation distance between roadways and ozone moni tor probes as

10 meters for roa dways w ith average traffic counts of less than 1,000 vehicles per day

. The detailed site information for the Beardsley Street and El Cajon sites lists the distance to the nearest streets as 7.6 and 7.5 meters, respectively. It is recommended that

SD C APCD ensure that this ozone monitor is meeting the siting criteria set forth by 40 CFR 58, App. E, 6.1. Because this ozone monitor is only violating the requirement by a minimal distance

, itmay be that tak ing a more precise measur ement from the actual

monitor rathe r than from the general site would resolve the issue

. The network plan reports what seems to be a distance to the road applicable to the entire site in general, rather than the ozone monitor probe.

iii. Please list the traffic counts for the paved cross road a t Donovan

. iv. When distances to more than one road are given for the requirement in 40 CFR 58, App. E, 6.1 and 6.2 , specify which road corresponds to the vehicle counts provided.

v. Adjust the monitor objective and spatial scale for the monitors at

Ot a y Mesa to reflect the current condition s at the site.

vi. Please confirm whether the District will operate the same instrumentation at Donovan as at the original Otay Mesa site.

vii. Please confirm that the collocated monitors at Otay Mesa meet the requirements for distance from each other that is appropriate for

their flow rate.

c. Please add the following information to the detailed site information table

for each monitor (a template table is provided as an example on the following page) : i. Site type (SLAMS/SPM etc.)

ii. List FRM/ FEM/non

- FEM and method code for particulate

monitors.

iii. List POC for each monitor

iv. Frequency of flow rate verification for manual PM samplers audit, App A, 3.3.2: e.g. weekly, bi

- weekly, monthly? (can be quarterly for high volume samplers)

v. Frequency of flo w rate verification for automated PM analyzers audit, App A, 3.2.3: e.g. weekly, bi

- weekly, monthly?

vi. Frequency of one

- point QC check, App. A, 3.2.1 (gaseous instruments): e.g. daily, weekly, bi

- weekly?

vii. Date of the last Annual Performance Evaluation, App. A, 3.2.2 (gaseous instruments)

viii. Dates of the last two semi

- annual flow rate audits for PM monitors, App A 3.2.4 and 3.3.3 (automated and manual)

i. Date of the past year’s PM 2.5 - PEP and Pb

- PEP audits , App A 3.2.7

and 4.3.2.

ix. Will there by changes within the ne xt 18 months? (Y/N)Template for Detailed Site Information

Site Name AQS ID

GIS coordinates

Location In shed, on school, etc.

Address County

Dist. to road meters

Traffic count #

Groundcover Paved, vegetated, etc. Representative Area List MSA or CSA (indicate wh ich)

Pollutant O3 PM2.5 Monitor obj ective List objective List objective Spatial scale List scale List scale Site Type SLAMS/SPM etc SLAMS/SPM etc Sampling method List instrument instrument / code Analysis method N/A e.g., weighed by X

lab

Start date Date when operation began Date when operation

began Operation schedule e.g., 1:1 e.g., 1:3 Sampling season e.g., May

- Nov. e.g., all year

P robe height meters meters Distance from supporting

structure meters meters

Distance from

o bstructions on roof meters meters

Distance from

obstructions not on roof meters meters

Distance from trees meters meters

Distance to furnace or

incinerator flue N/A meters

Distance between

collocated monitors N/A meters

Unrestricted airflow degrees degrees

Probe material e.g., Teflon N/A

Residence time X seconds N/A Will there be changes

within the next 18

months? Y/N Y/N

Is it suitable for comparison against the

annual PM2.5? N/A Y/N

Frequency of flow rate

verification for man ual PM samplers audit N/A weekly, bi

- weekly, monthly, quarterly (high vol) Frequency of flow rate

verification for automated PM analyzers audit N/A weekly, bi

- weekly, monthly, quarterly (high vol)? Frequency of one

- point QC check (gaseous) daily, wee kly,

bi

- weekly? N/A

Last Annual Performance Evaluation (gaseous) date N/A

L ast two semi

- annual flow

rate audits for PM

monitors N/A dates