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Israels, Ken

From: Kurpius, Meredith

Sent: Friday, February 27, 2015 1:33 PM

To: Israels, Ken; Wehling, Jefferson

Cc: Clover, Fletcher; CHANG, RANDALL

Subject: RE: Pechanga Final Rule - Questions on Monitoring Responses 

See below for additional thoughts (italicized in case we have red/green color issues among our group). 

From: Israels, Ken 

Sent: Tuesday, February 24, 2015 7:26 AM 

To: Wehling, Jefferson 

Cc: Kurpius, Meredith; Clover, Fletcher 

Subject: RE: Pechanga Final Rule - Questions on Monitoring Responses 

Hi Jeff (cc: Meredith and Fletcher) – 

 I’ve responded to some of your questions below in red. I defer to Meredith’s group for better responses. 

Thanks, 

Ken 

7-4102 

From: Wehling, Jefferson 

Sent: Monday, February 23, 2015 5:56 PM 

To: Israels, Ken 

Subject: Pechanga Final Rule - Questions on Monitoring Responses 

Ken: 

Here are some questions that occurred to me during my review of monitoring-related portions of the draft final rule: 

(1) What does it mean to be a “regulatory” monitor? Is it defined in our regs? Does it mean that a given monitor has 

the objective of “NAAQS comparison” and that the relevant State/District/Tribe has adequately demonstrated 

that the monitor meets the quality assurance and data requirements necessary for regulatory decisionmaking? See page 6 of the tribal designations policy for a discussion of the term “regulatory” monitor – I do not 

know if it is defined in the CFR. 

I looked in the monitoring regs of the CFR under the definitions and it’s not there but there is a guidance memo on “nonregulatory” data that helps define regulatory data. See: 

http://www.epa.gov/ttnamti1/files/ambient/pm25/datamang/Non%20Regulatory%20Monitor%20Type%20Guidance.p

df 

The most relevant seems to be this part: 

In order for air concentration data to be compared to the National Ambient Air Quality Standards (NAAQS), ambient air 

monitors must meet three sets of requirements: 

· Use reference (FRM), equivalent (FEM), and approved regional (ARM) methods (40 CFR Part 58 Appendix C); 

· Meet siting criteria (40 CFR Part 58 Appendix E); and 

· Meet quality assurance (QA) requirements (40 CFR Part 58 Appendix A). 
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(2) Is the Pechanga monitor a regulatory monitor? If so, when did it become one? 

Considering the three criteria above, the final activity for their program to be considered regulatory was our TSA in May, 

2010. This was when we confirmed the use of FRM/FEM instruments, checked siting, checked QA, and met the App A 

requirement for a TSA. Their regulatory data was then invalidated due to a sampling issue so that their first valid 

regulatory data was collected in August (I think) 2011 and their first full year of regulatory data was 2012. 

(3) Could you send me the latest AQS summary and design value reports including preliminary 2014 data for 

Temecula and Pechanga? See attached file and graphic. Let me know if you have any problems opening or 

viewing the data file. Done.

(4) With respect to Pechanga data, when do we no longer consider it to be “preliminary” given that I don’t believe 

that they annual certify the data? As I understand it from Meredith’s comments on the draft NPRM, the data 

are certified in May. Correct.

(5) Could you send me the *pdf illustrating the “Maximum Daily 8-hour Ozone Concentrations for Selected 

Monitors 2012-2014.” See attached file and graphic. Done.

(6) Did the equipment issue that we flagged in 2010 at the Pechanga monitor essentially invalidate all of the data 

from the Pechanga monitor prior to September 2011? Yes – please see the analysis that we prepared back then 

that suggests this – I have not yet added this to the draft NFRM as a docket reference (and it was not included in 

the NPRM or its docket) as I had been looking for it on my computer. Done.

(7) I understand that South Coast has modified the 2012 raw data concentration(s) and that, as a result, they lost 

their certification for that year, but I don’t know what that means for our determination of attainment. Do you?

Is this still a work in progress? My latest understanding was that SCAQMD altered 10 days. Although this 

removes the certification flag for the entire year, most of the data represent the values as they were certified.

Jeff Wehling 

U.S. EPA, Region IX, ORC-2 

75 Hawthorne Street 

San Francisco, CA 94105 

(415) 972-3901