UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION

IX 75 Hawthorne Street San Francisco, CA 94105·3901 DEC 1 1 2013 **~.FUchardStedman** Air Pollution Control Officer Monterey Bay Unified Air Pollution Control District 24580 Silver Cloud Court Monterey, California 93940 **Dear~-** Stedman: Thank you for your submission

of the Monterey Bay Unified Air Pollution Control District's (MBUAPCD's) 2013 Air Monitoring Network Report
in June 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 of the network plan except those specifically identified below. 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 58.10 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.

**Print~d** on **Rtcyd~d** PaptrIf you have any questions regarding this letter or the enclosed comments, please feel free to contact me at (415) 947-4534

or Dena Vallano
at (415) 947-4124. Enclosures:
Sincerely, **vfvr_~~** Meredith Kurpius, Manager 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: Mike Gilroy, MBUAPCD Bill Chevalier, MBUAPCD Gayle Sweigert, California Air Resources BoardA. 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 58.11 (c), NCore,

P AMS, and S1N network design and changes are subject to approval of the EPA Administrator. Therefore, we are not acting on these items. • EPA identified items **~** 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 Dates of last two semi-annual

35

Not meeting requirement. flow rate audits for PM monitors Agencies that share

44 Insufficient information

to judge for one monitoring responsibilities

in
MSA anMSA/CSA PM2.s site at neighborhood

66 Insufficient information

to judge for one scale and maximum

MSA concentration 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 4] EPA notes that the plan mentions two SPM studies that are not included
in the Detailed Site Information tables:
a) PM2.s Survey of wood smoke during winter in Santa Cruz/San Lorenzo,
b) Roadside monitoring study in Salinas

- NOx, CO, black carbon, PM2.s and MET in 2013. If these monitors are operated on a regular schedule for a year or more, they should be described

in the Detailed Site Information tables. If their operation is less or less consistent, please include that information

in next year's plan. Note that if the monitors are FRM, FEM or ARM, and operate greater than 24 months, the data are considered regulatory unless justification

is provided about not meeting regulatory requirements,
per 40CFR58.20. • [Item 7] MBUAPCD

is not required
to have an NCore site. In future ANPs,
it should be mentioned that BAAQMD operates an NCore station
at San Jose which
is part of the San Jose-Sunnyvale-Santa
Clara MSA (for which MBUAPCD and BAAQMD share jurisdiction). • [Item 28] In future ANPs, reference

to EPA's "Aerometric system" should

· refer to AQS instead. • [Item 43] Felton's SPM PM2.s monitor

is listed as N/A with respect
to FRMFEM/ARM/other

but lists the method code

as 170. The instrument manufacturer

is listed as MET ONE FEMBAM-1020. Method code 170 is for an FEM. Please resolve the method code with the FRMIFEM/ARM/other
listing in future ANPs. • [Item 49] The instrument parameter code for the column labeled wind speed shows code 61102 (instead of 61101) and the column labeled wind direction shows code 61101

· (instead of61102)

in the detailed site information
for the Carmel Valley, King City, Santa Cruz, Hollister, Scotts Valley, and Felton sites. This should be corrected
in next year'sANP. • [Item 56} For the Santa Cruz-Watsonville MSA, Table

I lists
2 monitors present. For the purposes
of meeting minimum monitoring requirements under Appendix
D, Sect. 4. 7, Table D-5, only one monitor (SLAMS monitor
at Santa Cruz) qualifies. Scotts Valley has an SPM 03 monitor which cannot be counted per CFR 58.20 for meeting minimum monitoring requirements. (SPMs do not count toward meeting minimum monitoring requirements.) This should be corrected

in next year's ANP. Since zero monitors are required for this MSA, MBUAPCD still meets the requirement. • [Item 63] San Jose-Sunnvvale-Santa
Clara MSA The design value (DV) for the MSA is listed for Hollister. The caption for the table states "DV site is highest listed regardless
of agency". The PM2.s DV site for this MSA shoilld list San Jose (BAAQMD) with annual DV 9.1 and daily DV 28, or perhaps list San Jose and Hollister. Table

2 lists three monitors are required. Since neither Hollister's nor SanJose's DV numbers exceed the 85% PM 2 . s NAAQS threshold,

it would seem that only
2 monitors are required. This should be corrected

in next year's ANP. Santa Cruz- Watsonville MSA Table

2 lists
2 monitors present. For the purposes
of meeting minimum monitoring requirements under Appendix
D, Sect. 4.7, Table D-5, only one monitor (SLAMS monitor
at Santa Cruz) qualifies. Felton has an SPM PM2.s monitor, which cannot be counted per CFR 58.20 for meeting minimum monitoring requirements. (SPMs do not count toward meeting minimum monitoring requirements.) This should be corrected

in next year's ANP. Since zero monitors are required for this MSA, MBUAPCD still meets the requirement. SalinasMSA Table 21ists

3 monitors present. For the purposes
of meeting minimum monitoring requirements under Appendix
D, Sect. 4. 7, Table D-5, only one monitor (SLAMS monitor

at Salinas) qualifies. Carmel Valley and King City have SPM PM 2 .s monitors, which cannot be counted per CFR 58.20 for meeting minimum monitoring requirements. (SPMs do not count toward meeting minimum monitoring requirements.) This should be corrected

in next year's ANP. Since zero monitors are required for.this MSA, MBUAPCD still meets the requirement.

### C. ANNUAL MONITORING NETWORKPLAN CHECKLIST (Updated 11126/2013) Year: 2013 Agency: Monterey BayUnified 

### AirPollution Control District (MBUAPCD) 40 CFR 58.1O(a)(1) requires that each 

### Annual Network Plan (ANP) include informationregarding the following types ofmonitors: SLAMS monitoring stations including FRM, FEM, and ARM monitors that are part ofSLAMS,NCore stations, S1N stations, State speciation stations, SPM stations, and/or, in serious, severe and extreme ozone nonattainment areas, PAMS stations, and SPMmonitoring stations. 40 CFR 58.10(a)(1) further directs that, ''Theplan shall include a statement ofpurposes for eachmonitor and evidence that siting and operation of eachmonitor meets the requirements ofappendices A, C, D, and E ofthis part, where applicable." 

### Onthis basis, review ofthe ANPs isbased onthe requirements listed in 58.10 along withthose inAppendices A, C, D, and E. EPA Region 

### 9 will nottake actionto approve ordisapprove any item for whichPart 58 grants approval authority to the Administratorratherthanthe Regional Administrators, but we will do a checkto see 

### if therequired information is included and correct.

**Th~** 

### items requiring approval bythe Administrator are: PAMS, NCore, and Speciation (STN/CSN). Please note

**~at** 

### this checklist summarizes many ofthe requirements of40 CFRPart 58, butdoes not substitute for those requirements, nor do its contents provide a binding determination ofcompliance withthose requirements. The checklist is subject to revision inthe future andwe welcome comments onits contents and structure. Key: White = meets the requirement. Yellow=requirement is notmet, or information is insufficientto make a determination. Action requested innext year's plan or outside the ANP process. (items listed 

### inEnclosure A) · e -n-- , 

### =itemrequires attention inorderto improve nextyear'splan (items listed inEnclosure B)



### 1

### ANP requirement Citation Was the info Does the Notes within 40 submitted?1

## H information CFR58 yes, page#s. provided3 

### meet Flag if 

### the req?4 

### incorrecf? 1. 

### Submitplanby July 111 

### 58.10 (a)(l) Yes Yes Received 6/28/2013 2. Statement ofpurpose for each monitor 58.10 (aX1) Yes Yes p. 10-24
3. 30-daypublic comment I

### inspection

**period~** 

### 58.10 (a)(1), Yes Yes No comments received 58.10 (a)(2) Appendix A 4. Modifications to SLAMS network- case when we 58.10 (aX2) Yes Yes EPA notes that the plan mentions two SPM studies are not approving actual system modifications (i.e., 58.10(e) p.6 that are not included in the Detailed Site we wiJJ do it outside the ANP process6) 

### Information tables: a) PM2

### .s Survey ofwood smoke during winter in Santa Cruz/San Lorenzo, b) Roadside monitoring study in Salinas

- NOx, CO, black carbon, PM2• 5

### and MET in 2013. If

### these monitors are operated on aregular schedule for a year or more, they should be

### described in the Detailed Site Information tables. Iftheir operation is less or less consistent, please include that information in next year's plan. Note that ifthe monitors are FRM, FEM orARM, and operate greater than 

### 24 months, the data are considered regulatory unlessjustification is provided about not meeting regulatory_requirements, per40CFRS8.20. 5. Modifications to SLAMS network- case when we 58.10 (a)(2) NA NA EPA is not approving any system modifications are approving actual system modifications per 58.10 (bXS) with this 

### plan approval. 58.14(c) 58.10(e) 58.14 (c) 6. Does plan include documentation (e.g., attached Yes Yes Appendix C includes EPA letter dated 2012/11/0 1 approval letter) for system modifications thathave p.34 that approves a CFR 58 App E siting waiver for been approved since last ANP

.approval?

-- 

### C:::armel Valley

1

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

**be~**

### provided. 2 

### To the best ofourknowledge. 3 

### Assuming the information is correct 4

**R~sponse** 

### options: NA (Not Applicable)- [reason], Yes, No, Insufficient to Judge. 5 

### The affected state or local agency must documentthe process for obtaining public comment and include any comments received through the public notification process within their submitted plan. 6 

### See 58.14(c) 

### 2 I I

### ANP requirement Citation Was the info Does the Notes within 40 submitted?1 

### If 

### information CFR58 yes, 

### page #s. provided 3 

### meet Flag if 

### thereq?4 

### incorrecr? 7. NCore site operational (by 1/112011) 58.10 (a)(3) NA NA MBUAPCD is not required to have an NCore site. In future ANPs, it should bementioned that BAAQMD operates an NCore station at San Jose which is part ofthe San Jose-Sunnyvale-Santa Clara MSA (forwhich MBUAPCD and BAAQMD share jurisdiction). 8. Ph site for 0.5-1.0 tpy sources operational (by 58.10 (a)(4) No Insufficientto See Row 44 comment 1212712011) judge for San JoseSunnyvale-Santa ClaraMSA 9. N02plan·for area-wide and RA40 sites submitted by 58.10 (a)(5) No Insufficient to Future ANPs should mention thatthere are no 7/1/2012 judge for San Jose- RA40 sites inthe San Jose-Sunnyvale-Santa Clara Sunnyvale-Santa MSA. ClaraMSA Regarding N02 area-wide, see Row 44 comment. 10. N02 area-wide and RA40 sites

**opera~onal**by 58.10 (a)(5) No Insufficientto See Row 44 comment. 111/2013 judge for San JoseSunnyvale-Santa ClaraMSA 11. N02plan for near-road sites submitted by 7/112013 58.10 (a)(5) No Insufficient to See Row 44 comment. judge for San JoseSunnyvale-Santa ClaraMSA 12. so2 sites operational (by 1/1/2013) 58.10 (a)(6) No Insufficientto See Row44 comment and 58.13(d) judge for San JoseSunnyvale-Santa ClaraMSA 13. AQS site identification number for each site 58.10 (bX1) Yes Yes p. 7, 12, 14, 16, 18, 20, 21,23 14. Location ofeach site: street address and geographic 58.10 (bX2) Yes Yes coordinates p. 7, 12, 14, 16, 18, 20, 21,23 15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes Yes parameter

. p. 10, 11, 13, 15, 17, 19, 22,24 16. Anyproposals to remove ormove a monitoring 58.10 (bX5) NA NA No proposals to remove ormove a monitoring station within a _period of18 months following plan station within a period of18 months following plan 

### 3I 

### ANP requirement Citation Was the info Does the Notes ' 

### within 40 submitted?1

## H information CFR58 yes, page#s. provided 3 

### meet Flag if 

### the req?4 

### incorrecr? submittal submittal. 17. Scale ofrepresentativeness for eachmonitor as 58.10(bX6); Yes Yes Spatial scale provided defined inAppendixD AppD p. 10, 11, 13, 15, 17,19,22,24
18. Identification ofsites suitable and sites not suitable 58.10 (b)(7) Yes Yes No PM2.s sites are listed as beingunsuitable for for comparisonto the annual PM2.s NAAQS as p. 10, 11, 13, 15, comparisonto the annual PM2.5 NAAQS per58.30 described inPart 58.30 17,19,22,24 19. MSA, CBSA, CSA orother arearepresented bythe 58.10 (b)(8) Yes Yes monitor p. 7, 12, 14, 16, 18, 20, 21,23 20. Designation ofanyPb monitors as either source- 58.10 (b)(9) No Insufficientto See Row44 comment oriented ornon-source-oriented judgefor SanJoseSunnyvale-Santa ClaraMSA 21. Any source-oriented Pb site for which a waiverhas 58.10 (b)(lO) No Insufficientto See Row44 comment beengrantedbyEPA RA judgefor SanJose- I Sunnyvale-Santa ClaraMSA 22. AnyPb monitor for which a waiverhasbeen 58.10 (b)(11) No Insufficient to See Row44 comment requested orgranted byEPARA for use ofPb-PM10 judgefor SanJosein lieu ofPb-TSP Sunnyvale-Santa ClaraMSA 23. Identification ofrequiredN02 monitors as either 58.10 (bX12) No Insufficient t9 See Row44 comment. near-road or area-wide judgefor SanJoseSunnyvale-Santa ClaraMSA 24. Identification ofany PM2.5 FEMs and/orARMs not 58.10 (bX13) Yes Yes No PM 2.s sites are listed as being unsuitable for eligible tobe comparedtotheNAAQS (Note 1: must 58.11 (e) p. 10, 11, 13, 15, comparisontothe NAAQS include required data assessment.) (Note 2: Required 17,19,22,24 SLAMS mustmonitorPM2.s withNAAOScomparable monitor atthe required sample frequency.) 25. For SPMs listed asnon-regulatory, note the start 58.20(c) Yes Yes See Row4. Date ofFRMIFEM/ARM at SPM. If> 24months, p. 13, 15, 20, 22, and monitor is eligible for comparison to the 24 NAAQS per 58.11 (e) and 58.30, the agency must supply information thatApp A, C orErequirements 

## 4

### ANP requirement Citation Was the info Does the Notes

.within 40 submitted?1 

### If 

### information CFR58 yes, page#s. provided3 

### meet Flag if 

### thereq?4 

### incorrecf? were not met. 26. Document how states and local agencies provide for 58.10 (c) Yes Yes the review ofchanges to a 

### PM 2.s monitoring network p.6 that impact the location ofa violating

### PM 2.s monitor. 27. Does the plan include arequest for approval for and 58.11 (a) (2) NA NA No requests for alternatives to Ap}lendix A alternative to appendix Arequirements for SPMs requirements for SPMs operating a FRM/FEM/ ARM which also meets appendixE? 28. Precision/Accuracyreports submitted to AQS 58.16(a); Yes Yes In future ANPs, reference to EPA's "Aerometric AppA, 1.3 p.6 system" should referto AQS instead and 5.1.1 29. Annual data certification submitted 58.15 Yes Yes App.A 1.3 p.6 30. Frequency offlow rate verification for manual PM AppA3.3.2 Yes Yes PM10 monitors are continuous I samplers audit p. 11 

### PM2.s FRM QA monitor- monthly 31. Frequency offlow rate verification for automated AppA3.2.3 Yes Yes Weekly PM analyzers audit p. 11, 13, 15, 17, 19,22 32. Frequency ofone-point flow'rate verification for Pb AppA No Insufficientto See Row 44 comment samplers audit 3.3.4.1 judge for SanJoseSunnyvale-Santa ClaraMSA 33. Frequency ofone-point QC check (gaseous) App.A3.2.1 Yes Yes Daily for 0 3, weekly for CO/N02 p. 10, 13, 15, 17, 19,22 34. Date oflastAnnual Performance Evaluation App.A3.2.2 Yes Yes (gaseous) p. 10, 13, 15, 17, 19,22 35. Dates oflast two semi-annual flow rate audits for App A, 3.2.4 Yes No Flow rate audits not being conducted semi-annually. PM monitors and 3.3.3 p. 11, 13 (New PM2.5 SPM station at Felton not audited yet.) 36. Dates oflasttwo semi-annual flow rate audits for Pb AppA NA NA No Pb monitors monitors 3.3.4.1 37. PM2 .s collocation AppA3.2.5 Yes,p. 11 NA MBUAPCD is part ofthe CARB PQAO. As this is a PQAO requirement, it shouldbe addressed in CARB'splan. MBUAPCD meets PM2.5 collocation requirements within its own network. 38. Designation ofa primarymonitor ifthere is more Needto Yes Yes At Salinas, FRM PM2.smonitordesignated as QA 

### 5I 

### ANP requirement Citation Was the info Does the Notes within 40 submitted?1 

### H 

### information CFR58 yes, page#s. · provided 3 

### meet Flag if 

### the req?4 

### incorrecf? than one monitor for a pollutant at a site. determine p.ll collocated, FEM PM2.smonitor designated as collocation SLAMS 39. Distance between collocatedmonitors (Note: waiver App.A Yes Yes request orthe date ofprevious waiver approval must 3.2.5.6 and p. 11 be included ifthe distance deviates from 3.2.6.3 requirement.) 40. Manual PM10 method collocation met? (note: AppA3 :3.1 NA NA PM10monitors are continuous continuous PM10 does nothave this requirement)_ 41. Pb collocation AppA No Insufficientto See Row 44 comment 3.3.4.3 judge for SanJoseSunnyvale-Santa ClaraMSA 42. PM1o..2.s collocation (note: only applies to Fresno and AppA3.3.6 NA NA PhoenixNCore sites) 43. Instrument/monitoring method code for each App C 2.4.1.2 Yes Yes Felton's SPM PM2.s monitor is listed as N/A with monitor: is it reported properly? Is it reported Pgs 10, 11, 13, 15, respect to FRMIFEM/ARM/other but lists the correctly (i.e., appropriate method code for 17, 19,20,22,24 method code as 170. The Instrument manufacturer regulatory monitors)? is listed as MET ONE FEMBAM-1020. Method code 170 is for an FEM. Please resolve the method code with the FRMIFEM/ARM/other listing in future ANPs. 44. For agencies that share monitoring responsibilities in App D 2(e) Yes, pgs 3, 4 Insufficient to MBUAPCD and BAAQMD share monitoring
an MSA/CSA: does each affected State or local judge for San Jose- responsibility for the San Jose-Sunnyvale-Santa agency meet full monitoring requirements or is Sunnyvale-Santa Clara MSA. Agreements provided in the ANP only
an agreement between the affected agencies and the Clara MSA cover PM2.sand PMro. EPA Regional Administrator in place? 45. Start date for each monitor Required to Yes

- Yes determine if Pgs 10, 11, 13, 15, otherreq. 17, 19,20,22,24 (e.g., min# and colloc) are met 46. Instrument monitortype for each monitor Required to Yes Yes determine if Pgs 10, 11, 13, 15, otherreq. 17, 19,20,22,24 (e.g., min# and colloc) are met

--- - - -- - 

### 6

### ANP requirement Citation Was the info Does the Notes within 40 submitted?1 

### H 

### information CFRS8 yes, 

### page #s. provided 3 

### meet Flag if 

### the req?4 

### incorrecr? 47. Monitoring objective for each instrument AppD 1.1 Yes Yes 58.10 (b)(6) Pgs 10, 11, 13, 15, 17, 19,20,22,24 48. Site type for each instrument App D 1.1.1 Yes Yes Pgs 10, 11, 13, 15, 17, 19,20,22,24 49. Instrument parameter code for each instrument Required to Yes Yes The instrument parameter codes for the column determine if Pgs 10, 11, 13, IS, labeled wind speed shows code 61102 (instead of otherreq. 17, 19, 20, 22,24 61101) and the column labeled wind direction (e.g., min# shows code 6110l (instead of61102) in the detailed and colloc) site infonnation for the Cannel Valley, King City, are met Santa Cruz, Hollister, Scotts Valley, and Felton sites. This should be 

### corrected in nextyear's ANP. 

## so. Instrumentparameter occurrence code for each Required to Yes Yes instrument determine if 

### Pgs 10, 11, 13, 15, otherreq. 17, 19,20,22,24 (e.g., min# andcolloc) are met 51. Sampling season for ozone (note: date ofwaiver 58.10 (bX4) Yes Yes approval must be included if 

### the sampling season App D, 4.1(i) Pgs 10, 11, 13, 15, deviates from requirement) 17,19,20,22 52. Sampling schedule for PM2.5

- applies to year-round 58.10 (b)(4) Yes Yes and seasonal sampling schedules (note: date of 58.12(d) Pgs 10, 11, 13, 15, waiver approval mustbe included if 

### the sampling AppD4.7 17, 19,24 season deviates from requirement) EPA flowchart 53. Sampling schedule for PM10 

### 58

.10 (bX4) Yes, pgs 15, 19 Yes 58.12(e) AppD4.6 54. Sampling schedule for Pb 58.10 (bX4) No Insufficientto See Row 44 comment 58.12(b) judge for San JoseAppD4.5 Sunnyvale-Santa ClaraMSA 55. 

### Sampling schedule for PM10

### .2.s 58.10 (b)(4) NA NA No PMta-2.5 monitors 58.12(f) AppD4.8 56. Minimum # ofmonitors for 01 

### [Note: should be App D, 4.l(a) Yes, PI 

### 3, Table I Insufficient to San Jose-Sunnvvale-SantaClara MSA 

### 7

### ANP requirement Citation Was theinfo Does the Notes within 40 submitted? 1 

### If 

### information CFR58 yes, page#s. provided 3 

### meet Flag if 

### the req?4 

### incorrecf? supported by MSA ID, MSA population, DV, # 

### and judge for San Jose- See Row 44 comment monitors, and#required monitors] 

### (seefootnote}' TableD-2 Sunnyvale-Santa ClaraMSA

**Sm:~ta Cruz-Watsonvill~**  

### MSA Forthe Santa Cruz-Watsonville MSA, Table 1lists 2 monitors present. For the purposes ofmeeting minimum monitoring requirements under Appendix D, Sect. 4.7, Table D-5, only one monitor (SLAMS monitor at Santa Cruz) qualifies. Scotts Valley has an SPM 0 3 

### monitor which cannot be 

### counted perCFR 58.20 for meeting minimum monitoring requirements. (SPMs do not count toward meeting minimum monitoring requirements.) This should be 

### corrected in next year's ANP. Since zero monitors are required for this MSA, MBUAPCD still meets the requirement. 57. Identification ofmax. cone. 0 3 

### monitor(s) App D 4.1 (b) 

### Yes,pg3 Yes 58. Minimum monitoring requirements met for near- AppD4.3.2 No Insufficientto See Row 44 comment road N02(2014 start date) judge for San JoseSunnyvale-Santa ClaraMSA 59. Minimum monitoring requirements met for area- AppD4.3.3 No Insufficient to See Row 44 comment wideN02 judge for SanJoseSunnyvale-Santa ClaraMSA 60. Minimummonitoring requirements met for RA-40 AppD4.3.4 No Insufficientto Future ANPs should mention thatthere are no N02 judge for San Jose- RA40 sites in the SanJose-Sunnyvale-Santa Clara Sunnyvale-Santa MSA. ClaraMSA 61. Minimum monitoring requirements met for S02 AppD4.4 No Insufficientto See Row 44 comment [Note: Only monitors consideredto be required judge for San JoseSLAMs are eligible to be counted towards meeting Sunnyvale-Santa minimum monitoring requirements.] ClaraMSA 62. Minimum monitoring requirements met for Pb AppD4.5 No Insufficientto See Row 44 comment [Note: Only monitors consideredto be required 58.13(a) judge for San Jose7 

### Only monitors considered to be required SLAMs are eligible to be countedtowards 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) cannotbe counted towards minimum monitoring requirements. 

### 8 I

### ANP requirement

·Citation Was the info Does the Notes within40 submitted?1 

### If 

### information CFRS8 yes, page #s. provided3 

### meet Flag if 

### the req?4 

### incorrecf? SLAMs are eligible to be countedtowards meeting Sunnyvale-Santa minimum monitoring requirements.] ClaraMSA 63. Minimum # ofmonitors for PM2.5 [Note 1: should be AppD, Yes, pg. 3 Table 2 Yes San

**J~~-Sunnn:ile-S~m~** 

### ClaraMSA supported by MSA ID, MSA population, DV, # 4.7.1(a) and The design value (DV) for the MSA is listed for monitors, and#required monitors] [Note 2: Only TableD-5 Hollister. The caption for the 

### table states "DV site is monitors consideredto be required SLAMs are highest listed regardless ofagency". The PM2 .5 

### DV eligible to be counted towards meeting minimum site for this MSA should list San Jose (BAAQMD) monitoring requirements.] with annual DV 9.I and daily DV 28, orperhaps list SanJose and Hollister. Table 2 lists three monitors are required. Since neither Hollister's nor San Jose's DV numbersexceed the 

### 85% PM2.s 

### NAAQS threshold, it would seem that only 2 monitors are required. This should be corrected in nextyear's ANP.

**Sm~ ~ruz-Watsonville**  

### MSA Table 2 lists 2 monitors present. Forthe purposes of meeting minimum monitorin& requirements under Appendix D, Sect. 4.7, Table D-5, only one monitor (SLAMS monitor at Santa Cruz) qualifies. Felton has 

### an SPM PM2.s monitor, which cannot be counted perCFR 58.20 for meeting minimum monitoring requirements. (SPMs do not count toward meeting minimum monitoring requirements.) This should be corrected in next year's ANP. Since zero monitors are required for this MSA, MBUAPCD still meets the requirement. Salinas MSA Table 2 lists 3 monitors present. For the 

### purposes of meeting minimum monitoring requirements under Appendix D, Sect. 

### 4.7, Table D-5, only one monitor (SLAMS monitor at Salinas) qualifies. Carmel Valley and King City have SPM PM2.5 monitors, which cannot be counted per

### CFR 58.20 for meeting minimum monitoring requirements. (SPMs do not count toward meeting minimum monitoring

- - - - - 

### requirements.) This shguld be corr_c:_cted in next
__ 

### 9

### ANP requirement Citation Was theinfo Does the Notes within 40 submitted?1 

### If 

### information CFR58 yes, page #s. provided3 

### meet Flag if 

### the req?4 

### incorrecf? ' j year's ANP. Since zero monitors are required for I this MSA MBUAPCD still meets the requirement. 

### 64. Optional PM25Network Clarifications: Provide a list Needto NA NA ofrequired sites ifit does notinclude all SLAMS. assess several [Note: default will assume all SLAMS are requirements consideredrequired sites.] 65. RequiredPM2
.5 sites represent area-wide air quality AppD Yes Yes 4.7.1(b) Pgs 11, 17, 19 66. ForPM25, is at least one site at neighborhood or AppD Yes, pgs 3,19 Insufficient to In the San Jose-Sunnyvale-Santa Clara MSA, larger scale in an area ofexpected maximum 4.7.1(b)(l) judge for San Jose- SLAMS PM2.5 monitors are located at Hollister, concentration Sunnyvale-Santa San Jose and Gilroy. Information is not provided ClaraMSA whether the Hollister monitor is located in an area ofexpected maximum concentration. 67. Ifadditional SLAMS PM2 .5 required, is there a site in AppD Yes, pgs 3,19 Yes an area ofpoor airquality 4.7.1(b)(2) 68. Minimum monitoringrequirements for continuous AppD4.7.2 Yes Yes PM2.s Pgs 11, 17, 19 69. Requirements for PM2 .s background andtransport AppD4.7.3 No No This is a state requirement needingto be addressed sites byCARB. 70. Are PM25 Chemical Speciationrequirements met for AppD4.7.4 NA NA official STN sites? 71. Minimum # ofmonitors for PM10 AppD,4.6 Yes, pgs 3, 15, 19 Yes SanJose-Sunnyyale-Santa ClaraMSA (a) and Table ANPApp. B includes letters exchangedbetween D-4 " MBUAPCD andBAAQMD indicating an agreementbetweenthe agencies for shared monitoringresponsibility for PM10• Two-four monitors are required. Twomonitors (Hollister and SanJose) are present. 

### 72. Minimum monitoringrequirements met for PMu).2.5 AppD4

.8 NA NA mass 73. Distance ofsite from nearestroad AppE6 Yes, Yes Pgs 7, 12, 14, 16, ' 18, 20, 21, 23 74. Traffic count ofnearest road AppE Yes, Yes Pgs 7, 12, 14, 16,



### ta, 20, 21, 23

-- 

### 10

### ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If 

### information CFRS8 

## yes, page 

### #s. provided 3 

### meet Flag 

### if the req?4 

### incorrecr? 75. Groundcover AppE3(a) Yes, Yes Pgs 7, 12, 14, 16,

18, 20, 21, 23 76. Probe height AppE2 Yes Yes Pgs 10, 11, 13, 15, 17, 19, 20, 22, 24 

### 77. Distance from supporting structure AppE2 Yes Yes Pgs 10, 11, 13, 15,

17, 19, 20, 22,24 78. Distance from obstructions on roof AppE4(b) Yes Yes Pgs 10, 11, 13, 15, 17, 19,20,22,24 79. Distance from obstructions not onroof AppE4(a) Yes Yes Pgs 10, 11, 13, 15,



### -

17, 19,20,22,24 80. Distance from trees AppE5 Yes Yes Pgs 10, 11, 13, 15,

17, 19, 20, 22,24 81. Distance to furnace or incinerator flue AppE 3(b) Yes Yes Pgs 10, 11, 13, 15,

17, 19, 20, 22,24 82. Unrestricted airflow AppE, 4(a) Yes Yes and4(b) Pgs 10, 11, 13, 15, 17, 19, 20, 22,24 83. Probe material (ifapplicable) AppE9 Yes Yes Pgs 10, 11, 13, 15,

17, 19,20,22,24 84. Residence time (ifapplicable) AppE9 Yes Yes Pgs 10, 11, 13, 15,

---- L__ ___ L_ 11_!_ 19

**~o.**_12,

**~4**

**-~** - ---- L_--



### 11

### Public Comments on AnnualNetworkPlan 

### Were · comments submitted to the S/Lff agency during the public commentperiod? No 

### Ifno, skip the remaining questions. Ifyes: • Were any ofthe comments substantive? o Ifyes, which ones? o Explainbasis for determination 

### ifany comments were considered not substantive:
• Did the agency respond to the substantive comments? o Ifyes, was the response adequate? • Do the substantive comments require separate EPA response (i.e., agency response wasn't adequate)?
• Are the sections ofthe annual networkplanthat received substantive comments approvable after consideration ofcomments?
o 

### Ifyes, provide rationale:

12