UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6

1445 ROSS AVENUE, SUITE 1200

DAlLAS, TX 75202-2733

Mr. Ron Curry

Secretary

New Mexico Environment Department

Post Office Box 5469

Santa Fe, NM 87502-5469

Dear Mr. Curry:

The U.S. Environmental Protection Agency (EPA) Region 6 has completed its

analysis of the New Mexico Environment Department's (NMED) 20 IaAnnual

Monitoring Network Plan to ensure it meets those requirements of 40 CFR Part 58 and its

appendices that confer approval authority on the Regional Administrator. We appreciate

your cooperation and work to prepare and submit your network plan. EPA has reviewed

the proposed changes to the New Mexico Monitoring Network, and I am pleased to

infonn you that your 2010 network plan is approved. Details regarding our review of

your air monitoring network and minor technical changes needed are addressed in the

enclosure.

We appreciate NMED initiating new ozone site discussions with the United States

Forest Service in northern New Mexico in anticipation of upcoming new ozone

monitoring requirements. EPA also looks forward to working with you on

implementation ofthe forthcoming ozone monitoring rule and the reconsidered lead

monitoring regulations.

If you have any questions, please contact me at (214) 665-2100, or your staffmay

contact Ms. Maria Martinez ofmy staff at (214) 665-2230.

\

Enclosure
Technical Comments on New Mexico Environment Department (NMED) 2010 Annual

Monitoring Network Plan

Requests for Additional Information:

Particulate Matter (PM)

A review ofthe PM network has identified that primary and secondary monitors

collocated for the purposes ofQuality Assurance/Quality Control do not utilize the same

sampling method. See 40 CFR Part 58, App. A, 3.2.5.2(a) and 3.3.1.2. Please check on

this infonnation and clarify.

It appears from the data in the Air Quality System (AQS) that in 2009, NMED

tenninated the PM J0 tapered element oscillating microbalance (TEOM) sampling in the

Shiprock area, San Juan County. NM.ED has also been running a PMIO gravimetric

monitor in Farmington, San Juan County, since 2008. We do not have any objections to

the location ofthe PMlO monitor in San Juan County. Please confinn the tennination of

the PM 10 TEOM monitor from the Shiprock area.

In Table I, the following sites were denoted with a "?" in addition to the YeslNo

response for National Ambient Air Quality Standards (NAAQS) comparability: 3ZD

Taos (AQS #35-055-0005), 6ZG Sunland Park (AQS #35-013-0017), and 7S Silver City

(AQS #35-0t 7-1 002). You have listed that the three sites above use the PM I 0 Federal

Reference Method (FRM) monitor with a "1" and either Yes or No in the NAAQS

comparability column. Since they are FRM monitors, they are comparable to the

NAAQS. Please clarify why certain sites were denoted with a "?" in addition to the Yes

or No response for NAAQS comparability.

Recommendations:

PM

The PM2.5 monitor at 6ZG Sunland Park (AQS #35-013-0017) must operate on a

daily schedule since its 24-hour design value is within plus or minus 5% ofthe AAQS

for PM2.5. Please increase the frequency for this monitor to operate on a daily schedule

at the earliest possible date. See 40 CFR § 58.12(d)(1 )(iii).

The PMIO TEOM and gravimetric monitors in Dona Ana and Luna Counties

reported several concentrations exceeding the 24-hour NAAQS. Please be aware that it is

the responsibility of the State to determine the cause of measured exceedances and

submit documentation according to the Exceptional Events Rule at the earliest possible

time.
Since 2007, several ofNMED's PM2.5 monitors have been collecting ambient

concentrations below the NAAQS. NMED may want to re~evaluate these sites. Any

request for a system modification under 40 CFR § 58. 14(c) should be submitted in

writing to EPA Region 6.

NMED operates a PMIO gravimetric monitor in Santa Fe County (AQS

#35-048-0020), two in Grant County (AQS #35-017-1002 and #35-017-1003) and one in

Taos County (AQS #35-055-0005). Since 2007, all four ofthese monitors have reported

values which are very low in comparison with the 24-hour NAAQS. NMED may want to

re-evaluate these sites. Any request for a system modification under 40 CFR § 58.l4(c)

should be submitted in writing to EPA Region 6.

Sulfur Dioxide (S02)

Source based monitoring is no longer required per the revised monitoring rule

promulgated on June 22,2010. However, state and applicable local agencies are strongly

encouraged to monitor above the minimum requirements for population exposure or near

sources in areas that are not conducive to modeling. Also, the subsequent updates to the

2010 Census and 2008 National Emissions Inventory may adjust current S02 monitoring

requirements.

Ozone

In the Monitoring Network Plan, Section 9.0, titled "03 Neh-york," the current

ozone monitoring being done at the Hurley Smelter site (AQS #35-017-1003) and the

new ozone monitor at the Los Lunas site (AQS #35-061-0008) were left off the list.

According to our review ofthe existing ozone network, NMED is currently operating

16 ozone sites. Please update Section 9.0 to reflect this information. Additionally, the

Table 1 listing ofmonitoring stations should be updated to include the additional ozone

monitor at the Los Lunas site (AQS #35-061-0008).

We look forward to working with you on the relocation of the Rio Rancho Site

(AQS #35-043-1003).

Lead (Pb)

Region 6 air monitoring staff looks forward to working with NMED on the

implementation ofthe final Pb monitoring requirements. We expect the final lead

monitoring requirements to be addressed as specified in the reconsidered lead monitoring

regulations signed December 14, 2010. We advise all monitoring agencies to refrain

from siting and installing Pb non-source oriented monitors until the final Pb

reconsideration monitoring regulations are promulgated.