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Air Pollution Control Officer 

Imperial County Air Pollution Control District 

150 South 9th Street 

El Centro, California 92243-2801 

Dear Mr. Poiriez: 

Thank you for your submission of the Imperial County Air Pollution Control District's 

(ICAPCD's) Annual Network Plan for Ambient Air Monitoring in July 2013. We have reviewed 

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

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 

year's annual monitoring network plan. 

on 
Enclosures: 

MeredithKmpius, 

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: Monica Soucier, ICAPCD 

Gayle Sweigert, California Air Resources Board 

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• System modifications (e.g., site closures or moves) are subject to approval per 40 CFR 

5 8.14( c). Information provided in the plan was insufficient for EPA to approve the 

system modifications listed in the plan per the applicable requirement. Therefore, we are 

not acting on the following items as part of this year's annual network plan: 

- Relocation of Calexico Ethel 

- Shutdown of Westmorland ozone monitor 

• 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 

PM2.s sampling frequency 52 Not meeting requirement in one instance 

Distance from trees 80 Not meeting requirement in one instance 

PM1o sampling frequency 53 Insufficient information to judge 

Designation of primary 38 Insufficient information to judge 

monitor 

Date of last PE audit 34 Insufficient information to judge in some 

instances 

Distance from furnace or 81 Insufficient information to judge 

incinerator flue 

Document how agency will 26 Insufficient information to judge 

provide for the review of 

changes to PM2.s network 

Parameter code 49 Incorrect information in some instances 

Scale of representation 17 Insufficient information to judge orincorrect in some instances 

Site type 48 Incorrect information in some instances 

Method code 43 Insufficient information to judge 

Monitoring objective 47 Insufficient information to judge 

Monitor type 46 Insufficient information to judge 

Statement of purpose 2 Insufficient information to judge 

Start date 45 Insufficient information to judge in some 

instances 

Shared MSA monitoring 44 Insufficient information to judge 

responsibilities 

Pb monitoring requirements 62 Insufficient information to judge 
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• [Row 76] The probe heights in the 

station details

 do not match the heights above 

ground in the "site survey reports" for Niland, Westmorland, El Centro, and Calexico 

Ethel. 

• [Row 77] The distance from supporting structures in the "station details" do not match 

the heights above platform in the "site survey reports" for Niland, Brawley, 

Westmorland, El Centro, and Calexico Ethel. 
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C. ANNUAL MONITORING NETWORK PLAN CHECKLIST 

(Updated 11/26/2013) 

Year: 2013 

Agency: Imperial County Air Pollution Control District 

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40 CFR 58.10(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, SlN stations, State speciation stations, SPM 

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

40 CFR 58.10(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 (SlN/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) 

oreen I =item requires attention in order to improve next year's plan (items listed in Enclosure B) 

1 
ANP requirement I Citation Was the info Does the I Notes 

within 40 submitted?1 If information 

CFRS8 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecr? 

Submit plan by July 1st 58.10 (a)(1) y 

Statement of purpose for each monitor 58.10 (a)(l) N !Insufficient info I Information not included 

3. I 30-day public comment I inspection period~ 58.10 (a)(l), 

58.10 (a)(2) 

Y, 7/11/2013 Letter I Y 

4. I Modifications to SLAMS network- case when we are 58.10 (a)(2) Y, p.25-26 Insufficient info The plan identifies the proposed change to 

not approving actual system modifications (i.e., we 58.10(e) move the Calexico Ethel site to a nearby 

will do it outside the ANP process, location and changes to the Westmorland site, 

but no analysis was included. EPA will not be 

approving the proposed modifications as part 

of the 2013 ANP review. 

to SLAMS network- case when we are 58.10(a)(2) N/A N/A EPA will not be approving any system 

approving actual system modifications per 58.14(c) 58.10 (b)(5) modifications as part of the 2013 ANP review. 

58.10 N/A N/A 

58.10 (a)(5) N/A N/A 

N/A 502 monitoring Is not required 

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 plan. 

6 See 58.14(c) 

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2 
ANP - requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFRS8 yes, page #s. provided3 meet 

Flag if' the req?4 

incorrecr? 

13 AQS site identification number for each site 58.10 (b)(1) Y, p.29-49 y 

14 Location of each site: street address and geographic 58.10 (b){2) Y, p.29-49 y 

coordinates 

15 Sampling and analysis method(s) for each measured 58.10 (b)(3) Y, p.29-49 y 

parameter 

16 Any proposals to remove or move a monitoring 58.10 (b)(5) Y, p.25-26 y 

station within a period of 18 months following plan 

submittal 

17 Scale of representativeness for each monitor as 58.10(b)(6); Y, p.ll-13, p.29-49 Insufficient/ The site survey reports for Niland and Brawley 

defined in Appendix D AppD Incomplete, p.40 Incorrect info do not contain scale of representativeness for 

the PM10 BAM 1020s. 

An "urban" scale for 03 and N02 at Calexico 

Ethel may be inappropriate, as concentrations 

at El Centro show that 0 3 concentrations vary 

over distances within the "urban" scale 

definition. Due to these differences in 

concentration, the Calexico Ethel site is most 

likely representative of a "neighborhood" 

scale. 

18 Identification of sites suitable and sites not suitable 58.10 (b)(7) Y, p.29-49 y 

for comparison to the annual PM2.s NAAQS as 

descn'bed in Part 58.30 

19 MSA. CBSA. CSA or other area represented by the 58.10 (bX8) Y, p.29-49 y 

monitor 

20 Designation of any Pb monitors as either source- 58.10 (b)(9) N/A N/A Source oriented Pb monitoring Is not required 

oriented or non-source-oriented 

21 Any source-oriented Pb site for which a waiver has 58.10 (b)(10) N/A N/A Source oriented Pb monitoring Is not required 

been granted by EPA RA 

22 Any Pb monitor for which a waiver has been 58.10 (bX11) N/A N/A Source oriented Pb monitoring is not required 

requested or granted by EPA RA for use ofPb-PM10 

in lieu ofPb-TSP 

23 Identification of required N~ monitors as either near- 58.10 (b)(12) N/A N/A Near-road/Area-wide N02 monitoring Is not 

road or area-wide required 

3 . 
I ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecf? 

24 Identification of any PM2.s FEMs and/or ARMs not 58.10 (b)(13) N/A N/A No PM2.s FEM monitors In Imperial County 

eligible to be compared to the NAAQS (Note 1: must 58.11 (e) 

include required data assessment) (Note 2: Required 

SLAMS must monitor PM2.s with NAAOScomparable monitor at the required sample 

frequency.) 

25 For SPMs listed as non-regulatory, note the start Date 58.20(c) N/A N/A No current PM2•

5 SPMs operating >24 months 

ofFRM/FEM/ARM at SPM. If> 24 months, and 

monitor is eligible for comparison to the NAAQS per 

58.11 (e) and 58.30, the agency must supply I 

information that App A, C orE requirements were not 

met. 

26 Document how states and local agencies provide for 58.10(c) N Insufficient info Information not included 

the review of changes to a PM2.

5 monitoring network 

that impact the location of a violating PM25 monitor. 

27 Does the plan include a request for approval for and 58.11 (a) (2) N/A N/A The plan does not Include request for approval 

alternative to appendix A requirements for SPMs of an alternative to app. A for existing SPMs 

operating a FRMIFEM/ ARM which also mee~ 

appendixE? 

28 Precision/ Accuracy reports submitted to AQS 58.16(a); Y, p.27 y 

AppA, 1.3 

and 5.1.1 

29 Annual data certification submitted 58.15 Y. p.27 y 

App.A 1.3 

30 Frequency of flow rate verification for manual PM App A 3.3.2 Y, p.29-49 y 

samplers audit 

31 Frequency of flow rate verification for automated PM AppA3.2.3 Y, p.29-49 y 

analvzers audit 

32 · Frequency of one-point flow rate verification for Pb AppA Y, ~.29-49 y 

samplers audit 3.3.4.1 

33 Frequency of one-point QC check (gaseous) App.A3.2.1 Y, p.29-49 y 

34 Date of last Annual Performance Evaluation (gaseous) App. A 3.2.2 Y, p.29-49 Insufficient info Dates for last PE audit for Westmorland, El 

Centro, and Calexico Ethel are from 2012. 

Information pertaining to 2013 PE audits was 

not included. 

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

within 40 subJirltted?1 If information 

CFRS8 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecr? 

35 Dates oflast two semi-annual flow rate audits for PM AppA, 3.2.4 Y, p.29-49 y 

monitors and3.3.3 

36 Dates of last two semi-annual flow rate audits for Pb AppA Y, p.29-49 y 

monitors 3.3.4.1 

37 PM2 5 collocation App A 3.2.5 N, Y, p.18 NA Method codes and designation of a primary 

monitor are not included in the detailed site 

information. While the collocation 

requirements are applicable to the CARB 

PQAO, relevant information should also be 

included in the ICAPCD ANP. 

38 Designation of a primary monitor if there is more than Need to N Insufficient info Information not included 

one monitor for a pollutant at a site. determine 

collocation 

39 Distance between coUocated monitors (Note: waiver App.A Y,p.48 v. 

request or the date of previous waiver approval must 3.2.5.6 and 

be included if the distance deviates from 3.2.6.3 

requirement) 

40 Manual PM10 method collocation met? (note: App A 3.3.1 N NA ICAPCD is part of the ARB PQAO, and relies on 

continuous PM 10 does not have this requirement) the entire PQAO network to satisfy collocation 

requirements. It is ARB's responsibility to 

show that this requirement is met. ARB is 

currently working on a network document that 

should address this. 

However, collocated monitors within ICAPCD's 

network should still be identified in the 

1-- ·- ICAPCD network plan. 

41 Pb collocation AppA N Insufficient info ICAPCD is part of the ARB PQAO, and relies on 

3.3.4.3 the entire PQAO network to satisfy collocation 

requirements. It is ARB's responsibility to 

show that this requirement is met. ARB is 

currently working on a network docume_nt that 

5 
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? 

should address this. 

However, collocated monitors within ICAPCD's 

network should still be identified in the 

ICAPCD network plan. 

42 PM10-2.s collocation (note: only applies to Fresno and AppA3.3.6 N/A N/A PM10-z.s is not required 

Phoenix NCore sites) 

43 Instrument/monitoring method code for each monitor: App C 2.4.1.2 N Insufficient info Information not included 

is it reported properly? Is it reported correctly (i.e., 

appropriate method code for regulatory monitors)? 

44 For agencies that share monitoring responsibilities in App D 2(e) N Insufficient info Information not included 

an MSNCSA: does each affected State or local 

agency meet full monitoring requirements or is 

an agreement between the affected agencies and the 

EPA Regional Administrator in place? 

45 Start date for each monitor Required to Incomplete, p. 45 Insufficient info Start dates for collocated PM2.

5 FRM and 

determine if collocated non-FEM BAM 1020 were not 

other req. included 

(e.g., min# 

and colloc) 

are met 

46 . Instrument monitor type for each monitor Required to Y, p.16-18, p.29-49 Insufficient info In your next year's network plan, please clarify 

determine if whether the PM10 SPMs at the Brawley and 

other req. Niland sites are FRMs, FEMs or ARMs. Note 

(e.g., min# that if they are FRMs, FEMs or ARMs, and they and colloc) have operated for greater than 24 months, the are met data are considered regulatory. ~ . 

47 . Monitoring objective for each instrument App D 1.1 N Insufficient info Information on basic monitoring objectives for 

. 58.10 (b)(6) each monitor was not included - - 48 . Site type for each instrument App D 1.1.1 Y, p.9-10, p.15-18, Insufficient/ The site survey reports in the plan contain a 

p.29-49 Incorrect info field of "Objective", which EPA is interpreting 

as "site type", as some monitors are defined as 

"population exposure" in this field. Possible 

site types are: extreme downwind, highest 

cone., max ozone cone., max precursor impact, 

population exposure, source oriented, upwind 

--- -

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0 
'- ./ ~ ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 . 

· incorrect2

? 

background, general/background, regional 

transport, welfare-related impacts, quality 

assurance, other. The information in the site 

survey reports are not consistent with tables 

1-3 on p.9-10. The following information 

should be corrected: 

• The site types for Niland 0 3 and PM10 

are inconsistent throughout the ANP. 

• The "support" site type for the Niland 

Site type for each instrument (continued) PM10 BAM is inappropriate. 

• The site types for Westmorland 0 3 

and PM10 are inconsistent throughout 

the ANP. 

• The site types for Brawley PM10 and 

PM1.5 are inconsistent throughout the 

ANP. 

• The "support" site type for the 

Brawley PM10 BAM is inappropriate. 

• The "typical concentration" site type 

for Brawley PM10 is inappropriate. 

• The site types for all El Centro 

monitors are inconsistent throughout 

the ANP. 

• The "typical concentration" site types 

for El Centro CO, NO:u and PM10 are 

inappropriate. 

• Based on 2012 data, the "highest 

concentration" site type for El Centro 

PM10 is inappropriate. 

• The "support" site types for the 

Calexico Ethel PM1 5 BAMs are 

inappropriate. 

• The "state requirement" site type for 

the Calexico Ethel TSP monitor is 

inappropriate. --

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ANP requirement 

Instrument parameter code for each instrument 

51 J Sampling season for ozone (note: date of waiver 

approval must be included if the sampling season 

deviates from requirement) 

Sampling schedule for PM2 5 - applies to year-round 

and seasonal sampling schedules (note: date of waiver 

approval must be included if the sampling season 

deviates from requirement) 

53J Sampling schedule for PM10 

forPb 

Sampling schedule for PM1o.2.s 

0 

Citation 

within 40 

CFR58 

Required to 

determine if 

other req. 

(e.g., min# 

and colloc) 

are met 

Was the info 

submitted?1 1f 

yes, page #s. 

Flag if 

incorrecr? 

Y, p. 16-17 

158.10 (b)(4) I Y, p.29-49 

App D, 4.1(i) 

58.10 (b)(4) Y,p.17-18, p.24-25, 

58.12(d) p.29-49 

AppD4.7 

EPA 

flowchart 

j58.10(b)(4) Y, p.17-18, p.24, 

58.12(e) p.29-49 

App D4.6 

58.10 (b)(4) Y,p.45 

58.12(b) 

AppD4.5 

58.10 (b)(4) N/A 

Does the 

information 

provided3 meet 

the req?4 

Incomplete, 

Incorrect info 

IV 

N 

Insufficient info 

IV 

I N/A 

Notes 

Parameter codes for N02 and 502 were not 

included. The parameter code of 85101 for the 

PM10 BAM SPMs at Brawley and Niland are 

inappropriate, as the monitors have been 

operating for longer than 24 month. 

Currently, the Calexico Ethel site is not 

meeting the required PM2.5 sampling 

frequency. The Calexico Ethel site has been 

sampling at the incorrect frequency since 

2010. 

The analysis in Section IV on PM10 sampling 

frequency does not describe the methodology 

used to determine whether the requirement 

has been met. It is unclear how the data 

presented supports the conclusion that no 

.Jired. 

I PM10-z.s monitoring is not required 

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-

ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecr? 

56 Minimum # of monitors for 0 3 [Note: should be App D, 4.1(a) Y, p.19-20 y 

supported by MSA ID, MSA population, DV, # and 

monitors, and# required monitors] (see footnote)' TableD-2 

57 Identification of max. cone.~ monitor(s) AppD4.1 (b) Y, p. 57 y 

58 Minimum. monitoring requirements met for near-road AppD4.3.2 Y, p.20 y 

N02 (2014 start date) 

59 Minimum mo~toring requirements met for area-wide AppD4.3.3 Y, p.20 y 

N02 

60 Minimum monitoring requirements met for RA-40 AppD4.3.4 N/A N/A RA-40 N02 monitoring Is not required. 

NO;z. 

61 Minimum monitoring requirements .met for SO:z. AppD4.4 v, p. 21 y 

[Note: Only monitors considered to be required 

SLAMs are eligtble to be counted towards meeting 

minimum monitoring requirements.] 

62 Minimum monitoring requirements met for Pb [Note: App 04.5 N Insufficient info Information not included 

Only monitors considered to be required SLAMs are 58.13(a) 

eligible to be counted towards meeting minimum 

monitoring requirements.] 

63 Minimum# of monitors for PM2.s [Note 1: should be AppD, Y, p.22-23 y 

supported by MSA ID, MSA population, DV, # 4.7.1(a) and 

monitors, and# required monitors] [Note 2: Only TableD-5 

monitors considered to be required SLAMs are ' eligible to be counted towards meeting minimum 

monitoring requirements.] 

64 Optional PM2.s Network Clarifications: Provide a list Need to N/A N/A Information not included 

of required sites if it does not include all SLAMS. assess several 

[Note: default will assume all SLAMS are considered requirements 

required sites.] 

65 Required PM2.s sites represent area-wide air quality AppD v, p.17-18, p.29-49 y 

4.7.1(b) 

66 For PM2.s, is at least one site at neighborhood or AppD Y, p.17-18, p.29-49 y 

larger scale in an area of expected maximum 4.7.1(b)(l) 

concentration 

67 If additional SLAMS PM2.s required, is there a site in AppD N/A N/A Only one PM2.5 monitor is required In the El __ 

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. 

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ANP requirement I Citation 

within 40 

CFRS8 

1 4.7.1(b)(2) 

continuous I AooD4.7.2 

AppD4.7.3 

met for I AppD4.7.4 

AppD,4.6 

(a) and Table 

D-4 

AppD4.8 

AppES 

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Was the info 

submitted?1 If 

yes, page #s. 

Flag if 

incorrecf? 

V, p.45-49 

V, p.23 

V, p.23 

V, 21-22 

·1 N/A 

Y, 29-49 

Does the I Notes 

information 

provided3 meet 

the req?4 

IV 

I V 

IV 

IV 

I N/A I PM1o-2.s monitoring is not required 

N, Insufficient info I The PM2 5 and PM10 monitors are within 10 

meters of trees located to the east of the site 

at Calexico Ethel. Also, information was not 

included for the N02, 0 3, CO, and 502 

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10 
requirement Citation Wastheinfo 

within 40 submitted?1 If 

CFR58 ·yes, page #s. 

Flag if . 

incorrecr? 

and4(b) 

83 Probe material (if applicable) AppE9 Y, 29-49 

84 Residence time (if applicable) AppE9 Y, 29-49 

Public Comments on Annual Network Plan 

Were comments submitted to the S!Uf agency during the public comment period? No 

If no, skip the remainjng questions. 

If yes: 

• Were any of the comments substantive? 

o If yes, which ones? 

Does the 

information 

provided3 meet 

the req?4 

y 

y 

o Explain basis for determination if any comments were considered not substantive: · 

• Did the agency respond to the substantive comments? 

o If yes, was the response adequate? 

Notes 

• 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 comments approvable after consideration of comments? 

o If yes, provide rationale: 

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