UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105·3901 

OCT 3'0 2014 

Eric Massey 

Director, Air Quality Division 

. Arizona Department of Environmental Quality 

1110 West Washington Street 

Phoenix, Arizona 85007 

Dear Mr. Massey: 

Thank you for your submission of the Arizona Department of Environmental Quality's 

(ADEQ's) "State of Arizona Air Monitoring Network Plan For the Year 2014" in July 2014. We 

have reviewed the submitted document based on the requirements set forth under 40 CFR 58. 

Based on the information provided in the plan, the U.S. Environmental Protection Agency (EPA) 

approves all portions of the network plan except those specifically identified below. EPA also 

continues to approve the ozone season waiver based on 2007-2013 concentrations. 

Please note that we cannot approve portions of the annual network plan for which the 

information 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 

5 8 .10 and the associated appendices. EPA Region 9 also cannot approve portions of the 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 

Taking Action) provides a listing of specific 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 of the more extensive list of items 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. 

Printed on Recycled Paper 
If you have any questions regarding this letter or the enclosed comments, please feel free to 

contact me at (415) 947-4534 or Jennifer Williams at (415) 972-3938. 

Enclosures: 

Sincerely, 

lJ/q:__?~ rMeredith Kurpius, ~ana" Air Quality Analysis Office 

A. Annual Monitoring Network Plan Items where EPA is Not Taking Action 

B. Additional Items Requiring Attention 

C. Annual Monitoring Network Plan Checklist 

cc (via email): Theresa Rigney, ADEQ 
A. Annual Monitoring Network Plan Items where EPA is Not Taking Action 

We, are not acting on the portions of annual network plans where either EPA Region 9 lacks the 

authority to approve specific items of the plan, or EPA has determined that. a requirement is 

either not met or information in the plan is insufficient to judge whether the requirement has 

been met. 

• Per 40 CFR 58.1 l(c), NCore, PAMS, and STN network design and changes are subject to 

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

• EPA identified items in your agency's annual monitoring 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 the following items: 

Item Checklist Row Issue 

Minimum monitoring requirements for 20 Not meeting requirement 

continuous PM2.s 

Manual PM10 method collocation 33 Not meeting requirement 

Precision/ Accuracy reports submitted to 10 Insufficient information to judge 

AQS 

Annual data certification submitted 11 Insufficient information to judge 

Site type for each monitor 63 Incorrect in some instances 

Scale of representativeness for each 65 Insufficient to judge in some 

monitor as defined in Appendix D instances 

Dates oflast two semi-annual flow rate 31 Insufficient information to judge 

audits for PM2.s monitors 

Dates of last two semi-annual flow rate 37 Insufficient information to judge 

audits for PM10 monitors 

Dates of last two semi-annual flow rate 45 Insufficient infonnation to judge 

audits for Pb monitors 

Date of last Annual Performance 47 Insufficient information to judge 

Evaluation (gaseous) 

Traffic count of nearest road 70 Insufficient information to judge 

in some instances 

Distance from obstructions on roof 74 Insufficient information to judge 

AQS site identification number for each 57 Insufficient information to judge 

site in one instances 

Distance from obstructions not on roof 75 Not meeting requirement in 

some instances; insufficient to 

judge in other instances 

Distance from trees 76 Not meeting requirement in 

some instances 
Additional information for each of these items may be found for the row listed in column 2, in 

the third enclosure ( C. Annual Monitoring Network Plan Checklist). 
B. Additional Items Requiring Attention 

• [Item 1] Please work to submit future plans by the July 1 deadline. 

• [Item 5] In future plans, if requests and approvals were sent outside of the annual network 

plan process, please attach the requests and approval letters that were submitted during 

the relevant calendar year. 

• [Item 14] Per 40 CFR 58 Appendix D, section (2)(e), the EPA Regional Administrator 

and state or local agencies ... "may divide the overall MSA/CSA 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." A draft agreement was submitted with this Plan. Please work 

with EPA to formalize the agreement to share network design responsibilities. 

• [Item 19] The requirement for minimum number of monitors for PM2.s is being met, but 

Table 2a (page 137) incorrectly lists the table headers as"# of Required Continuous 

Monitors", "# of Active Continuous Monitors", and "# of Additional Continuous 

Monitors Needed." Please correct in future plans. 

• [Item 32] The requirement for minimum number of monitors for PM10 is being met, but 

Table 3 (page 138) incorrectly states that 0-1 monitors are required for Lake-HavasuKingman and Sierra Vista-Douglas, when according to the 2011-2013 Max 

Concentration given, 1-2 are required. 

• [Item 50] Please reference the date of the original ozone wavier approval. 

C. ANNUAL MONITORING NETWORK PLAN CHECKLIST 

(Updated March 11, 2014) 

Year: 2013 

Agency: Arizona Department of Environmental Quality 

40 CFR 58.lO(a)(l) requires that each Annual Network Plan (ANP) include information regarding the following types of monitors: SLAMS 

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

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

40 CFR 58.lO(a)(l) further directs that, "The plan shall include a statement of purposes for each monitor and evidence that siting and operation of 

each monitor meets the requirements of appendices A, C, D, and E of this part, where applicable." On this basis, review of the ANPs is based on the 

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 Administrator rather than the 

Regional Administrators, but we will do a check to see if the required information is included and correct. The items requiring approval by the 

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

Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requirements, nor do its 

contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welcome 

comments on its contents and structure. 

Key: 

White= meets the requirement. 

Yell ow = requirement is not met, or information is insufficient to make a determination. Action requested in next year's plan or outside the ANP 

process. (items listed in Enclosure A) 

-p-re_e_n_I =item requires attention in order to improve next year's plan (items listed in Enclosure B) 

1 
ANP requirement I Citation Was the Does the I Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement? 4 

incorrect2? 

GENERAL PLAN REQUIREMENTS 

1. .. ,_·~ ·,.,,..·: . · .,_. ::: fs~1oxa ·1 · -:;;:: ±Yes'.i·."'; '"<·: ; ..:~: No·~< ~> · · • .·: .~ . Plan sub_Jl1.itted_ m.>.J.u.I . 3rc1, 2014 

2. 30-day public comment I inspection period5 58.10 (a)(l), Yes Public comment period ended July 3rct, 2014. No 

public comments were received. 

3. I Modifications to SLAMS network - case when we 158.10 (a)(2) I Yes I Yes I The new location of the Prescott College 0 3 monitor 

are not approving system modifications 58 .10 (b)(5) Pg. 11-13 does not require approval. While approval is not 

required, EPA appreciates up-front coordination with 

4. I Modifications to SLAMS network - case when we 

are approving system modifications per 58.14 

6. I Any proposals to remove or move a monitoring 

station within a period of 18 months following plan 

submittal 

1 58.10 (a)(2) 

58.10 (b)(5) 

58.lO(e) 

58.14 

58.10 (b)(5) 

I NA 

Yes 

Pg. 11 

I NA 

Yes 

agencies on such additions to the network. 

I 

1 .Response options: NA (Not Applicable), Yes, No, Incomplete, Incorrect. The responses "Incomplete" and "Incorrect" assume that some information has been provided. 

2 To the best of our knowledge. 3 Assuming the information is correct 4 Response options: NA (Not Applicable) - [reason], Yes, No, Insufficient to Judge. 5 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 submitted pl~. 

2 
ANP requirement I Citation Was the Does the 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

7. I A plan for establishing a near-road PM2.s monitor (in 58.10(a)(8)(i) NA NA 

CBSAs ~ 2.5 million) by 1/1 /2015 

8. I A plan for establishing a near-road CO monitor (in 58. I O(a)(7) NA NA 

CBSAs ~ 2.5 million) by 1/1/2015 58. I3(e)(l) 

9. I N02 plan for establishment of 2"d near-road monitor 58.IO NA NA 

by 1/I/20I5 (a)(5)(iv) 

I 0.1 Precision/ Accuracy reports submitted to AQS 58. I 6(a); No Insufficient to 

App A, 1.3 Judge 

and 5.1.1 

I I. I Annual data certification submitted I 58.I5 No Insufficient to 

App. A I.3 Judge 

12. I SPMs operating an FRM/FEM/ ARM that meet . I 58.I 1 (a) (2) NA NA 

Appendix E also meet either Appendix A or an 

approved alternative. 

I3.I SPMs operating FRM/FEM/ARM monitors for over I 58 .2o(c) INA I NA 

24 months are listed as comparable to the NAAQS or 

the agency provided documentation that 

requirements from Appendices A, C, or E were not 

met. 6 

GENERAL PARTICULATE MONITORING REQUIREMENTS (PM10, PM2.s, Pb-TSP, Pb-PM10) 

15. I Designation of a primary monitor if there is more I Need to I Yes I Yes 

than one monitor for a pollutant at a site. determine Pg. 17, 57-83 

collocation 

I 6. I Distance between collocated monitors (Note: waiver I App. A I Yes I Yes 

request or the date of previous waiver approval niust 3.2.5.6 and Pg. 57-83 

3.2.6.3 

6 This requirement only applies to monitors that are eligible for comparison to the NAAQS per 40 CFR §§58. I I(e) and 58.30. 

I Notes 

This requirement is being fulfilled by Maricopa 

County. 

This requirement is being fulfilled by Maricopa 

County. 

This requirement is being fulfilled by Maricopa 

County. 

No information provided. 

I No information provided. 

The description of primary monitors is included in 

the text, but adding this information to the site tables 

would be helpful. 

3 

I 
ANP requirement I Citation Was the Does the I Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

be included if the distance deviates from 

requirement.) 

-SPECIFIC MONITORING REQUIREMENTS 

17. I Document how states and local agencies orovide for I 58.10 (c) I Yes I Yes 

Pg. 18 

18. I Identification of anv PM?, FEMs and/or ARMs not I 58.10 (b)(13) I NA I NA 

58.ll(e) 

20. I Minimum monitoring requirements for continuous I AppD 4.7.2 I Yes I No I States that no continuous monitors are required. One 

PM2.s Pg. 137 continuous monitor is required both for Yuma and 

Sierra Vista-Douglas. The requirement is being 

fulfilled at Yuma, but not at Sierra Vista-Douglas. 

21. I PM2.s collocation I App A 3.2.5 I Yes I Yes 

Pg.17-18, 57-85 

22. I PM2.s Chemical Speciation requirements for official App D 4.7.4 Yes I Yes 

STN sites Pg. 8-9, 57-85 

23 . I Identification of sites suitable and sites not suitable 58.10 (b)(7) Yes Yes I All FEM/FRM sites are listed as comparable 

for comparison to the annual PM2.s NAAQS as Pg. 57-85 

described in Part 58.30 

24. I Required PM2.s sites represent area-wide air quality AppD Yes I Yes 

4.7.l(b) Pg. 57-85 

25. I For PM2.s, at least one site at neighborhood or larger AppD Yes I Yes 

scale in an area of expected maximum concentration 4.7. l(b)(l) Pg. 57-85 

4 
ANP requirement 

26. I If additional SLAMS PM2.s is required, there is a site 

in an area of poor air quality 

27.I States must have at least one PM2.s regional 

background and one PM2.s regional transport site. 

28. I Sampling schedule for PM2.s - applies to year-round 

and seasonal sampling schedules (note: date of 

waiver approval must be included if the sampling 

season deviates from requirement) 

29. I Frequency of flow rate verification for manual PM2.s 

monitors audit 

30. I Frequency of flow rate verification for automated 

PM2.s monitors audit 

31. I Dates of last two semi-annual flow rate audits for 

PM2.s monitors 

Mm -SPECIFIC MONITORING REQUIREMENTS 

Citation 

within 40 

CFR58 

AppD 

4.7.l(b)(2) 

App D 4.7.3 

58.10 (b)(4) 

58.12(d) 

AppD 4.7 

EPA 

flowchart 

App A 3.3 .2 

I App A 3.2.3 

App A, 3.2.4 

and 3.3.3 

Was the 

information 

submitted? 1 If 

yes, page #s. 

Flag if 

incorrect2? 

NA 

Yes 

Pg. 57-85 

Yes 

Pg. 57-85 

Yes 

Pg. 57-85 

Yes 

Pg. 57-85 

Yes 

Pg. 57-85 

Does the \ Notes 

information 

provided3 meet 

the 

requirement?4 

NA I No additional monitor is required for each MSA. 

Yes 

Yes 

Yes 

Yes 

Insufficient to 

Judge 

The purpose of the 2014 ANP is to provide for an 

overview of data collected in calendar year 2013. The 

following sites/monitors included dates of the last 

semi-annual audit from 2014, therefore there is 

insufficient information to judge whether the 

requirement was met in 2013 : 

• Douglas Red Cross 

• Nogales Post Office 

In future ANPs, provide dates of semi-annual flow 

audits occurring in the applicable data years for all 

PM2 s monitors in the network. Information from 

other years may be included for informational 

purposes should you desire, but will not on their own 

fulfill this reauirement. 

5 
ANP requirement 

Manual PM10 method collocation (note: continuous 

PM10 does not have this requirement) 

34. I Sampling schedule for PM10 

35.I Frequency of flow rate verification for manual PM10 

monitors audit 

36. I Frequency of flow rate verification for automated 

PM1 0 monitors audit 

3 7. I Dates oflast two semi-annual flow rate audits for 

PM10 monitors 

Pb -SPECIFIC MONITORING REQUIREMENTS 

38. I Minimum # of monitors for non-NCore Pb [Note: 

Only monitors considered to be required SLAMs are 

eligible to be counted towards meeting minimum 

monitoring requirements.] 

Citation 

within 40 

CFR58 

58. 10 (b )(4) 

58. 12(e) 

App D 4.6 

App A 3.3 .2 

App A3.2.3 

App A, 3.2.4 

and 3.3.3 

App D 4.5 

58. 13(a) 

Was the 

information 

submitted? 1 If 

yes, page #s. 

Flag if 

incorrect2? 

Yes 

Pg. 20, 57-85 

Yes 

Pg. 57-85 

Yes 

Pg. 57-85 

Yes 

Pg. 57-85 

Yes 

Pg. 57-85 

Yes 

Pg. 22-23 

Does the I Notes 

information 

provided3 meet 

the 

requirement?4 

No 

Yes 

Yes 

Yes 

Insufficient to 

Judge 

Yes 

Each method of manual PM 10 monitors must be 

collocated with the same method. The Partisol 2000 

FRM at the Nogales Post Office is not meeting this 

requirement. Please contact EPA to discuss. 

The purpose of the 2014 ANP is to provide for an 

overview of data collected in calendar year 2013. The 

following sites/monitors included dates of the last 

semi-annual audit from 2014, therefore there is 

insufficient information to judge whether the 

requirement was met in 2013: 

• Douglas Red Cross 

• Hayden Old Jail 

• Miami Golf Course 

• Nogales Post Office 

• Paul Spur Chemical Lime Plant 

In future ANPs, provide dates of semi-annual flow 

audits occurring in the applicable data year for all 

PM10 monitors in the network. 

6 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

39. Pb collocation: for non-NCore sites App A 3.3.4.3 Yes Yes 

Pg. 23 

40. Any source-oriented Pb site for which a waiver has 58.10 (b)(lO) NA NA 

been granted by EPA Regional Administrator 

41. Any Pb monitor for which a waiver has been 5 8 .10 (b )( 11) NA NA 

requested or granted by EPA Regional Administrator 

for use ofPb-PM10 in lieu ofPb-TSP 

42. Designation of any Pb monitors as either source- 58.10 (b)(9) Yes Yes 

oriented or non-source-oriented Pg. 57-85 

43. Sampling schedule for Pb 58.10 (b)(4) Yes Yes 

58.12(b) Pg. 57-85 

App D4.5 

44. Frequency of one-point flow rate verification for Pb App A 3.3.4. l Yes Yes 

monitors audit Pg. 57-85 

45. Dates of last two semi-annual flow rate audits for Pb App A 3.3.4.1 Yes Insufficient tO The purpose of the 2014 ANP is to provide for an 

monitors Pg. 57-85 Judge overview of data collected in calendar year 2013. The 

following sites/monitors included dates of the last 

semi-annual audit from 2014, therefore there is 

insufficient information to judge whether the 

requirement was met in 2013: 

• Globe Highway 

• Miami Golf Course 

In future ANPs, provide dates of semi-annual flow 

audits occurring in the appropriate data year for all 

Pb monitors in the network. 

11 GENERAL GASEOUS MONITORING REQUIREMENTS I 

46. Frequency of one-point QC check (gaseous) App. A3.2.l Yes Yes 

Pg. 57-85 

47. Date of last Annual Performance Evaluation App. A 3.2.2 Yes Insufficient to The purpose of the 20 14 ANP is to provide for an 

(gaseous) Pg. 57-85 Judge overview of data collected in calendar year 2013. The 

following sites/monitors only had dates of the last PE 

audit from 2014, therefore there is insufficient 

information to judge whether the requirement was 

met in 2013: 

• JLG Supersite 

7 
ANP requirement Citation 

within 40 

CFR58 

Was the 

information 

submitted? 1 If 

yes, page #s. 

Flag if 

incorrect2? 

Does the I Notes 

information 

provided3 meet 

the 

requirement? 4 

• Alamo Lake 

• Hayden Old Jail 

In future ANPs, provide dates of PE audits occurring 

in the appropriate data year for all gaseous monitors 

in the network. 

I 03 -SPECIFIC MONITORING REQUIREMENTS I 

48. Minimum# of monitors for 01 fNote: should be App D, 4.l(a) Yes Yes Requirements for Phoenix and Tucson are fulfilled by 

and Pg. 21, 137 Maricopa County and Pima County, respectively. 

Table D-2 

49.I Identification of maximum concentration 01 I App D 4.1 (b) I Yes I Yes 

N02 -SPECIFIC MONITORING REQUIREMENTS 

51. I Minimum monitoring requirement for single near- App D4.3.2 Yes NA 

road N02 monitor (in CBSA ~ 1 million) by 1/ 1/2014 Pg. 24-25, 138 

52. I Minimum monitoring requirements for area-wide App D 4.3.3 Yes NA 

N02 monitor in location of expected highest N02 Pg. 24-25 

concentrations representing neighborhood or larger 

scale (operation required by January I, 2013) 

53. I Minimum monitoring requirements for susceptible I App D 4.3.4 I NA NA 

and vulnerable populations monitoring (aka RA40) 

N02 (oQeration reguired by Januar}:'. I, 2013) 

54. I Identification of required N02 monitors as either I 58.10 (b)(12) I NA NA 

near-road, area-wide, or vulnerable and susceptible 

population (aka RA40) 

S02 -SPECIFIC MONITORING REQUIREMENTS 

55. I Minimum monitoring requirements for S02 [Note: I App D 4.4 Yes NA 

Only monitors considered to be required SLAMs are Pg. 23-24, 138 

Requirements for Phoenix and Tucson are fulfilled by 

Maricopa County and Pima County, respectively. 

Requirement fulfilled by Maricopa County. 

Requirements for Phoenix and Tucson are fulfilled by 

Maricopa County and Pima County, respectively. 

Requirements for Phoenix and Tucson are fulfilled by 

Maricopa County and Pima County, respectively. 

7 Only monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements. In addition, ozone monitors that do not meet 

traffic count/distance requirements to be neighborhood scale (40 CFR 58 Appendix E, Table E-1) cannot be counted towards minimum monitoring requirements. 

8 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

eligible to be counted towards meeting minimum 

monitoring requirements.] 

I NCORE -SPECIFIC MONITORING REQUIREMENTS I 

56. NCore site and all required parameters operational 58.10 (a)(3); Yes Yes Pb-PM10 and PM10-2.s collocation at NCore is met by 

Pb Pg. 28-29, 71-72 the national network of monitors. 

collocation 

App.A 

3.3.4.3; PM10-

2.s minimum 

monitoring 

App. D4.8; 

PM10-2.s 

sampling 

schedule 

58.10 (b)(4) 

58.12(f) 

AppD4.8; 

PM1 0-2.s 

collocation 

App. A3.3.6 

I SITE OR MONITOR- SPECIFIC REQUIREMENTS (OFTEN INCLUDED IN DETAILED SITE INFORMATION TABLES) I 

57. AQS site identification number for each site 58.10 (b)(l) Yes Insufficient to No AQS ID given for Globe Highway (page 99). 

Pg. 84, 87-135 Judge in one 

instance 

58. Location of each site: street address and geographic 58.10 (b)(2) Yes Yes 

coordinates Pg. 87-135 

59. MSA, CBSA, CSA or other area represented by the 58.10 (b)(8) Yes Yes 

monitor Pg. 87-135 

60. Parameter occurrence code for each monitor Needed to Yes Yes 

determine if Pg. 57-83 

other 

requirements 

(e.g., min # 

and 

9 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

collocation) 

are met 

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

Pg. 87-135 

62. Basic monitoring objective for each monitor App D 1.1 Yes Yes 

58.10 (b)(6) Pg. 57-83 

63. Site type for each monitor App D 1.1.1 Yes Incorrect in some "Downwind" is not a site type. 

Pg. 57-83 instances Incompatible Site Type and Scales: - • Alamo Lake S02, PM10, and PM2.sBackground, Neighborhood 

64. Monitor type for each monitor Needed to Yes Yes "QA Collocated" and "UATMP" are not monitor 

determine if Pg. 57-83 types. 

other Per recent changes, the following are not "monitor 

requirements types", but are "network affiliations": 

(e.g. , min # • NCore 

and • PAMS 

collocation) • Supplemental Speciation 

are met • NATTS 

• IMPROVE 

EPA will send additional information on how these 

changes should be reflected in ANPs. 

65. Scale of representativeness for each monitor as 58.1 O(b )(6); Incorrect Insufficient to Incompatible Site Type and Scales: 

defined in Appendix D AppD Pg. 57-83 judge in some • Alamo Lake S02, PM10, and PM2.sinstances Background, Neighborhood 

66. Parameter code for each monitor Needed to Yes Yes 

determine if Pg. 57-83 

other 

requirements 

(e.g., min # 

and 

collocation) 

are met 

67. .Method code and description (e.g., manufacturer & 58.10 (b)(3); Yes Yes 

model) for each monitor App C 2.4.1.2 Pg. 57-83 

10 
ANP requirement Citation Was the Does the Notes 

within 40 information information 

CFR58 submitted? 1 If provided3 meet 

yes, page #s. the 

Flag if requirement?4 

incorrect2? 

68 . Sampling start date for each monitor Needed to Yes Yes 

determine if Pg. 57-83 

other 

requirements 

(e.g., min # 

and 

collocation) 

are met 

69. Distance of monitor from nearest road App E6 Yes Yes 

Pg. 87-135 

70. Traffic count of nearest road AppE Yes Insufficient to Traffic count not given for: 

Pg. 87-135 Judge in some • JLG Supersite, 17th Ave 

instances • Miami Ridgeline, Linden St 

• Paul Spur Chemical Lime Plant, Paul Spur 

Rd 

71. Groundcover App E 3(a) Yes Yes Dirt and/or Grass: 

Pg. 87-135 • Douglas Red Cross 

• Miami Ridgeline 

• Paul Spur Chemical Lime Plant 

• Rillito 

• Tonto National Monument 

72. Probe height App E2 Yes Yes 

Pg. 57-83 

73. Distance from supporting structure App E2 Yes Yes 

Pg. 57-83 

74. Distance from obstructions on roof App E 4(b) Yes Insufficient to Distance from obstruction given, but no height above 

Pg. 57-83 Judge the probe. Please state explicitly (i.e., if it is the same 

height as the probe, please state "O above probe"): 

• Flagstaff (03) 

75. Distance from obstructions not on roof App E 4(a) Yes No and Insufficient Requirement not being met at: 

Pg. 57-83 to Judge • Miami Townsite (S02) 

• JLG (SVOC) 

• South Phoenix (VOC) 

Distance from obstruction given, but no height above 

the probe, which may be 0, but please state explicitly: 

• Prescott College AQD (03) 

11 
ANP requirement Citation Was the 

within 40 information 

CFR58 submitted? 1 If 

yes, page #s. 

Flag if 

incorrect2? 

76. Distance from trees AppE5 Yes 

Pg. 57-83 

77. Distance to furnace or incinerator flue App E 3(b) Yes 

Pg. 57-83 

78 . Unrestricted airflow App E, 4(a) Yes 

and 4(b) Pg. 57-83 

79. Probe material (NOx, S02, 0 3) App E9 Yes 

Pg. 57-83 

80. Residence time (NOx, S02, 0 3) App E 9 Yes 

Pg. 57-83 

Public Comments on Annual Network Plan 

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

If no, skip the remaining questions. 

If yes: 

• Were any of the comments substantive? 

o If yes, which ones? 

Does the Notes 

information 

provided3 meet 

the 

requirement?4 

• Douglas Red Cross (PM2.s) 

• Rillito (PM10) 

Distance from tress (as an obstruction) given, but no 

height above the probe, which may be 0, but please 

state explicitly: 

• Alamo Lake (03) 

• Flagstaff (03) 

• Hayden Old Jail (S02, PM10) 

• Ajo (PM10) 

• Bullhead City (PM10) 

• Douglas Red Cross (PM10, PM2.s) 

• Paul Spur Chemical Lime Plant (PM10) 

• Payson Well Site (PM10) 

No in some Requirement not being met at: 

instances • JLG Supersite (Pb-PM10, PM10, PM2.s, 

PM10-2.s, Carbonyl, voe, PMIO metals 

speciation) 

• South Phoenix (VOC) 

• Miami Golf Course (Pb) 

Yes . 

Yes 

Yes 

Yes 

No. 

12 
o Explain basis for detennination 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 of the annual network plan that received substantive cofilments approvable after consideration of comments? 

o If yes, provide rationale: 

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