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 DearMr. Curry: The U.S. Environmental Protection Agency (EPA) Region 6 has completed its analysis ofthe New Mexico Environment Department's (NMED) 20I

# aAnnual Monitoring Network Plan to ensure 

### it meets those requirements of40 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 theNew Mexico MonitoringNetwork, and I am pleased to infonn you that your 2010 network plan is approved. Details regarding our review of your air monitoring network and minortechnical 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 ofupcoming 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. Ifyou have any questions, please contact me at (214) 665-2100, or your staffmay contact Ms. MariaMartinez ofmy staffat (214) 665-2230. 

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EnclosureTechnical Comments on New Mexico Environment Department (NMED) 2010 Annual Monitoring Network Plan


### Requests for Additional Information: Particulate Matter (PM) A review ofthe 

### PM networkhas identified thatprimary and secondary monitors collocated for the purposes ofQuality Assurance/Quality Control do not utilize the same sampling method. See40 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 

### PMJ0 tapered element oscillating microbalance (TEOM) sampling in the Shiprock area, San Juan County. NM.ED has also been running aPMIO gravimetric monitorin Farmington, SanJuan County, since2008. We do not have any objections to the location ofthe PMlO monitor 

### in SanJuan 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 SilverCity (AQS #35-0t7-1 002). You have listed that the three sites above use the PMI0 Federal Reference Method (FRM) monitorwith a "1" and eitherYes orNo in the NAAQS comparabilitycolumn. Since they are FRM monitors, they are comparable to the NAAQS. Pleaseclarify why certain sites were denoted with a 

### "?" in addition to the Yes orNo response forNAAQS comparability. Recommendations: PM The PM2.5 monitor at 6ZG Sunland Park (AQS #35-013-0017) must operateon a daily schedule since its 24-hourdesign value is within plus orminus 5% ofthe AAQS for PM2.5. Please increasethe frequency forthis monitorto operate on a daily schedule at theearliest possible date. 

### See40 CFR 

### § 58.12(d)(1)(iii). The 

### PMIO TEOM and gravimetric monitors in DonaAna and Luna Counties reported several concentrations exceeding the 24-hourNAAQS. Please be aware that it is the responsibility ofthe State to determine thecauseofmeasured exceedances and submitdocumentation 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 wantto**re~evaluate** these sites. Any request for a system modification under40 CFR § 58. 14(c) should be submitted in writing to EPA Region 6. NMED operates a PMIO gravimetric monitorin SantaFe 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-hourNAAQS. NMED may want to re-evaluate these sites. Any request for a system modification under40 CFR 

### § 58.l4(c) should be submitted in writing to EPA Region 6. Sulfur Dioxide (S02) Sourcebased monitoring is no longerrequired perthe 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 ornear 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 MonitoringNetwork Plan, Section 9.0, titled "03 Neh-york," the current ozone monitoring being done atthe Hurley Smelter site (AQS #35-017-1003) and the new ozone monitor atthe Los Lunas site (AQS #35-061-0008) were left offthe list. According to ourreview ofthe existing ozone network, NMED is currently operating 16 ozone sites. Please update Section 9.0 to reflectthis information. Additionally, the Table 1 listingofmonitoring 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 ofthe RioRancho Site (AQS #35-043-1003). Lead (Pb) Region 6 air monitoring stafflooks 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 monitoringregulations are promulgated.