UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 1445 ROSS AVENUE, SUITE 1200 DALLAS, TX 75202-2733

Mr. Richard Goodyear Chief, Air Quality Bureau New Mexico Environment Department 525 Camino de los Marquez Santa Fe, NM 87505 DearMr. Goodyear: 

# FEB 1 9

# 2014

Thank you for your correspondence submitting the New Mexico Environment Department's (NMED) 2013 Annual Monitoring Network Plan. The U.S. Environmental ProtectionAgency (EPA) has completed its analysis ofthe NMED's 2013 Annual Monitoring Network Plan to ensure itmeets those requirements of40 CFRPart 58 and its appendices that confer approval authority onthe Regional Administrator, now delegated to the Associate Director for Air. We appreciate your cooperation and work to submit your 2013 networkplan. The network assessment process presents an opportunity for the EPA and the NMED to collaborate onthe airmonitoring network design. See 40 CFRPart 58 App. D, 1.1.2. The EPA has reviewed yourplan, including the proposed ozone and particulate matter monitor changes to the NMED Ambient Air MonitoringNetwork. I am pleased to inform you that your 2013 ambient airmonitoring network plan is approved in accordance with 40 CFR §58.10. Details regarding ourreview ofyour airmonitoring network are provided in the enclosure. We look forward to our continued collaborative work with the NMED on your 2014 ambient air monitoring network plan. Ifyou have any questions, please contact me at (214) 665-3102, oryour staff may contact Ms. Maria Martinez, Air Quality Analysis Section Chief, ofmy staffat (214) 665-2230.

Enclosure

cc: Rita Bates, Chief, Planning Section Sincerely yours,

Thomas H. Diggs Associate Director for Air

NewMexico Environment Department (with Enclosure)

Recycled/Recyclable • Printed wHh Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)New Mexico Environment Department (NMED) 2013 Annual Ambient AirMonitoring Network Plan Technical Comments The Environmental Protection Agency (EPA) has reviewed your 2013 Annual Ambient Air Monitoring Network Plan and our comments are provided below. In addition to the network plan, EPA's review includes additional informationprovidedbyNMED. In order to reconcile all proposed network changes and as required by40 CFR 58.14, system modifications need to be submitted to EPA inwriting for approval. NMED will need to formally submit the network changes for all items marked below as

· "ConfirmationNeeded" inthis document.

MonitorApprovals Therequest to discontinue the 0 3 monitors at the 7E Deming Airport site (Air Quality System, AQS #35-029-0003) and the 7T Hurley Smelter site (AQS #35-017-1003) are approved due to historical low concentrations ofthe 0 3 data. The discontinuance ofthe 0 3 monitors will not compromise the data collection needed for implementation ofthe 03 National Ambient Air Quality Standards (NAAQS) and the 40 CFRPart 58, App. D ambient airmonitoringrequirements. NetworkEvaluation- Confirmation Needed BPA recommends that NMEDproceed on the following actions that NMED has indicated itwants to pursue: • The use ofa Special Purpose Monitor (SPM) classification for the 03 monitor at the 2ZJ Bernalillo site (AQS #35-043-1001). • The discontinuation for 03 monitoring at the 5ZS Hobbs Jefferson site (AQS #35-025-0008). The Hobbs Jefferson 0 3 monitor is not required noris it needed to continue since the 5ZR Carlsbad site (AQS #35-015-1005) 0 3 monitor covers the southeast New Mexico area. Recommendation The continued operation ofthe 03 monitor at the 2LL Los Lunas site (AQS #35-061-0008) is not required to meetminimum network requirements. InEPA's preliminaryreview ofthe monitoring data, it appears that the discontinuance ofthe 0 3 monitor at the Los Lunas site would not compromise the data collection needed for implementation ofthe 03 NAAQS and the 40 CFR Part 58, App. D ambient air monitoring requirements. NMED maywant to re-evaluate the appropriateness ofthe 

### 0 3 monitorto ensure optimal use ofresources. Please provide the monitoring data analysis and a rationale for either continued operation ordecommissioning ofthe 

### 0 3 monitor at the Los Lunas site. Any request for a system modification under 40 CFR § 58.14(c) shouldbe submitted to EPA Region 6 for concurrence. ParticulateMatter (PM): PMz.s Monitor Approvals Since 2007, several ofNMED's PM25 monitors have been collecting ambient concentrations below the NAAQS. For the continuous PMz.s network, NMED proposes to discontinue the tapered element oscillating microbalance (TEOM) samplers at 3HM SantaFeRunnels (AQS #35-049-0020), Hobbs Jefferson, Carlsbad, 1NLNavajo Lake (AQS #35-045-0018) and Los Lunas sites. Forthe Federal Reference Method (FRM) PMz.s network, NMED proposes to discontinue the FRM samplers at theSanta Fe Runnels site due to historically low concentrations. The requests to discontinue the PMz.s monitors are approved due to historically low concentrations. We conclude that the discontinuance of the PM2.s monitors will not compromise the data collection needed for implementation ofthe PMz.s NAAQS and the 40 CFR Part 58, App. D ambient air monitoring requirements. 

### PM2.5 

### Network Evaluation- Confirmation Needed EPA recommends that NMED proceed onthe following actions that NMED has indicated it wants to pursue: • The discontinuation ofPM2.5 monitoring at the lFO Farmington site (AQS #35-045-0019). • The relocation and operation ofthe PMz.s equipment from the Farmington site to the lZB Bloomfield site (AQS #35-045-0009). • The addition ofPM2

_ 5monitoring as an SPM at the 2ZJ Bernalillo site. • The operation ofan existing beta attenuation monitor (BAM) 1020 for PM2.s monitoring as an SPM at the Hobbs Jefferson site. Itis ourunderstanding that the BAM 1020 has been operating at this site. • The discontinuation ofthe PM25 TEOM sampler at the 6CM Anthony site (AQS #35-013-0016). • The discontinuation ofthe PM25 TEOM sampler at the 6ZN SantaTeresa site (AQS #35-013- 0022). 

### PM2.s 

### Recommendation NMED plans to discontinue the PMz.s TEOM and operate a PMz.s BAM 1020 at the Hobbs Jefferson site. In EPA's preliminaryreview ofthe monitoring data, it appears that the discontinuance ofthe PMz.s FRM monitor at the Hobbs Jefferson site will not compromise the data collection needed for implementation ofthe PMz.s NAAQS and the 40 CFRPart 58, App. D ambient air monitoring requirements. The PMz.s FRM at the Hobbs Jefferson site has historically reported low values. The 2012 annual design value (DV) is 7.6 micrograms per cubic meter (!-lg/m3) and the 2012 24-hour DV is 17!-lg/m3• The 2012 design values are not exceeding 80% ofthe PM2.5.annual and 24-hourNAAQS of 1211g/m3 and 35!-lg/m3

, respectively. NMED maywant to re-evaluate the appropriateness ofthe PM25 FRMmonitor to ensure optimal use ofresources. Please provide the monitoring data analysis and a rationale for either continued operation ordecommissioning ofthe PM2.s FRM monitor at the Hobbs Jefferson site. Anyrequest for a system modification under 40 CFR § 58.14(c) should be submitted to EPA Region 6 for concurrence. 

### PM10 

### Monitor Approvals Therequest to discontinue the PM 10 monitors at the Hurley Smelter, Santa Fe Runnels and 3ZD Taos (AQS #35"-055-0005) sites is approved due to historically low concentrations. The discontinuance ofthe PM 10 monitors will not compromise the data collection needed for implementation ofthe PM 10NAAQS and the 40 CFRPart 58, App. D ambient air monitoring requirements. The request to discontinue the collocated

### PMw monitors at the the7D Deming site (AQS#35-029-0001) is approved. There are two PM 10 ambient air monitoring sites inthe Demingmicropolitan statistical area with the Deming and Deming Airport sites operating within a 3 mileradius. According to the 2012 US Census population estimates, the Deming micropolitan statistical area is approximately25,041. The discontinuance ofthe collocated PM 10 monitors will not compromise the data collection needed for implementation ofthe PM 10 NAAQS and the 40 CFR Part 58, App. D ambient air monitoringrequirements. EPA supports the continued operation ofthe PM10 monitor at the Deming Airport site to cover the area. Itis ourunderstanding that on September 20, 2013, the PM10 TEOM sampler at the 6WM West Mesa site (AQS #35-013-0024) failed. Subsequently, the PM2.s TEOM sampler from the Los Lunas site was relocated and operational at the West Mesa site on October 2, 2013 for PM10monitoring as previously approved by EPA. Please include this change in the 2014 network plan. 

### PM10 

### Collocation According to the network plan, NMED proposes to move PM10monitoring collocation to the Sunland Park site (AQS #35-013-0017). Please note that collocation for the PM10 manual method is not required to be the same method. This means that a continuous monitor operated in conjunction with the manual method (FRM) meets the collocation requirement. See 40 CPR 58, App. A, 3.3.l(b). Based onthe network plan, NMED will have a maximum offive PM10 FRM manual sites; therefore, NMED is required to have only one site for collocation. NMED operates an FRM manual monitor and TEOM continuous monitor at the Anthony site to meet the 15% cpllocation requirements of40 CPRPart 58, App. D, 3.3.1. Therefore, an additional PM10 collocation site is notrequired and not necessary at the Sunland Park site. In addition, the collocation for PM10 is only required for manual methods (FRM). Collocation is not required for PM10 continuous monitoring which includes the BAM 1020 so please do not operate two PM10 BAM 1020s at one site. 

### PM1o Network Evaluation- Confirmation Needed EPArecommends that NMED proceed on the following actions that NMED has indicated it wants to pursue: • The discontinuation ofPM10 monitoring at the Farmington site. • Therelocation and operation ofthe PM10 equipment from the Farmington site to the Bloomfield site as an SPM. • The discontinuation ofPM10 monitoring at the 2U Bernalillo site (AQS #35-043-0001). • Therelocation and operation ofthe PM10 sequential FRM sampler from the 2U Bernalillo site to the 2ZJ Bernalillo site as an SPM. 

### PM Conversion- Confirmation Needed NMED outlines a conversionplanto begin shifting from sequential PM2.5 and PM10 FRM sampling and continuous TEOMPM10 monitors to continuous Federal Equivalent Method (FEM) sampling in2013 using the BAM 1 020 instruments. We cannot approve the entire network conversion at this time because ofoutstanding questions. Subsequent to the network plan submittal, NMED identified network changes and specific sites and equipment to upgrade to the BAM 1020 samplers. Please claritythe PM25and PM10 sites NMED requests to upgrade before proceeding further. We appreciate the work and effort of the NMED to upgrade the PM network and look forward to your response. During the conversion process to the continuous network, we would preferto see the existing PM2.5 and PM10 FRMS sites' operated in conjunction with the BAM 1020s to verify data qualityuntil the BAM 1

020s are stabilized. Since the PM2.s BAM 1020s are FEMs, any data collected with them needs to be reported as Parameter Code 88101 in AQS.Sunland Park site. (AQS #35-013-0017): According to the network plan, NMED proposes the following changes: • move the collocation sites for 

### PM 25 from the Farmington site to the Sunland Park site • move the collocation site for PM 10 from the Deming site to the Sunland Park site • deploy and operate a BAM 1020 at the Sunland Park site for PM2.s monitoring • discontinuation ofthe

### PM 25 TEOM at the Sunland Park site. Duringthe June 2012 Technical Systems Audit (TSA), EPA informed NMED ofsiting issues for the Sunland Park site and documented the review in the TSA report dated December 5, 2012. Since the TSA, EPA has beenworking with NMED to address our concerns. On December 16, 2013, NMED provided a separate technical analysis that may affect the operational status ofthe Sunland Park site, the pollutants being monitored at the site (03, PM25 and PM 10) and alternate sites for collocation and equipment changes. This may also affect NMED's operation ofthe Las Cruces site, 6ZM Desert View (AQS #35-013-0021) and PJYh.s monitoring at the Farmington site. At this time, EPA cannot approve the changes requested inthe network plan for Sunland Park. We further recommend that no changes take place at the Las Cruces site, Desert View site and the PM2.s monitoring at the Farmington site until a resolution is reached on the future ofthe SunlandPark site. We look forward to working with NMED on the further evaluation ofthese potential changes. · Timeline: In orderto reflect the timely implementation ofnetwork efficiencies, pleasepropose a timeline ofthe approved changes for sites and monitors inthe NMED network to the EPARegion 6 Air Quality Analysis Section Chiefwithin 60 days ofthe receipt ofthis letter. Please include the "Confirmation Needed" information with the timeline.