UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION

IX 75 Hawthorne Street san **Franc ~E'B**  **1f'1f ~&r(**  **3901** Mr. Mahmood Hossain, Chief, Monitoring

and Technical Services San Diego County Air Pollution Control District 10124 Old Grove Road San Diego, California 92131-1640 Dear Mr. Hossain: Thank you for your submission

of the San Diego Air Pollution Control District's (APCD's) 2012 Ambient
Air Quality Network Report

in July 2013. We have reviewed
the submitted document based on the requirements

set forth under
40 CPR 58. Based
on the information provided

in the plan, EPA approves

all portions

of the network plan except those specifically identified below. With this plan approval,

we also formally approve
the following system modification(s): relocation

of the PM

2

. 5 monitor from the temporary Alpine site back
to its original location and relocation

of the current PM

1 o sampler from the current Donovan
site to the new consolidated Donovan site. 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 fourth enclosure

(D. Region

9 Near-road

N0

2 Plan Review Checklist)

is the checklist EPA used to review those elements

of your annual monitoring network plan that deal specifically
with near-road N02 monitoring. The first two enclosures highlight

a subset
of the more extensive

list of items reviewed

in the third and fourth enclosures.

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.
If you have any questions regarding Printed

on Recycled Paperthis letter
or the enclosed comments, please feel free to contact me at (415) 947-4534

or Elfego Felix

at (415) 947-4141.
Sincerely,

- : .. **f/1~ ~**  Meredith Kurpius, Manage

r Air Quality Analysis Office Enclosures:

A. Annual Monitoring Network Plan Items where EPA

is Not Taking Action B. Additional Items Requiring Attention C. Annual Monitoring Network Plan Checklist D. Region

9 Near-road N02 Plan Review Checklist cc: Robert Kard, APCD David Shina, APCD 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, PAMS, and S1N network design and changes
are subject

to approval

of the EPA Administrator. Therefore,

we are not acting on these items. • System modifications
(e.g., site closures

or moves)
are subject

to approval
per 40 CFR 58.14(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: - Termination ofPb monitoring

at Gillespie. - New PM

2

. 5 FEM monitoring

at Donovan. - Relocation

of SLAMS monitoring

at Overland

to Kearny Villa Road. • Plans for establishing near-road
N0

2 monitoring

are required

for submittal

as part of the Annual Monitoring Network Plan per 40 CFR 58.10(a)(5). Information provided was insufficient

for EPA
to approve
the proposed plan for establishing

a near-road N02 monitor

in the San Diego-Carlsbad-San Marcos, CA CBSA per the applicable requirements. Therefore,

we **ar~** not acting on this portion

of the Annual Monitoring Network Plan. See enclosure

D (D. Region

9 Near-road N02 Plan review checklist)

for more information.

· • EPA identi

· fied 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 Modifications

to SLAMS

4 Insufficient

to judge

in some instances network N02 plan for near-road sites

11 Insufficient

to judge submitted

by 7/1/2013 Distance between collocated

39
Not meeting requirement

in one instance monitors Document how states and

26 Insufficient

to judge local agencies provide
for the review
of changes

to
a

· PM2.s monitoring network that impact the location

of
a violating PM2.s monitor. Distance

of site from nearest

73 Insufficient

to judge

in one instance roadN0

2 plan for area-wide
and

9 Insufficient

to judge RA40 sites submitted

by 7/1/2012 Distance from obstructions

78, 79 Insufficient

to judge

in some instances Distance from supporting

77 Insufficient

to judge

in one instance structure 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.AdditionalItemsRequiringAttention•[Item1]WerecommendthatAPCDfindwaystoconsolidatetheplan.Asanexample,informationfoundinmorethanonesectionoftheplanshouldbereferencedratherthanrewritten.•[Item2]APCDincludesa"SiteDescription"and"MonitoringObjective"sectiononthefirstpageofAppendices1-14thatfulfillstherequirementforastatementofpurposeforeachmonitor.WerecommendthatAPCDcombinethesetwosectionsinnextyear'splanandrenamethemto"StatementofPurpose."ThiswouldalsoallowforeliminationofSection2(i.e.''PurposesServedbytheMonitors")oftheplan.•[Item3]APCDverifiedviaemailonDecember17,2013thatnocommentswerereceivedonthe'plan.Forfutureplansubmittals,pleaseclarifyatthetimeoftheplansubmittalwhetheranypubliccommentswerereceived.Ifcommentsarereceived,pleasesubmitthesealongwithanyresponsetothecommentsdraftedbythedistrict.•[Item4]EPArecommendsthatAPCDcompileasinglesectionthatdescribesindetailallrecentandproposedmodificationstotheSLAMSnetwork.ThissectionwouldfollowwellafterTable1.2andcanbeusedtoconsolidatethevariousindividualpollutant/programsectionsthroughouttheplanthatcurrentlyspeaktonetworkchanges(i.e.Sections4.8,5.8,6.8,7.8,8.8,9.9,10.8,11.7,12.6,&13.6).•[Item37]WerecommendthatAPCDrevisitthemostappropriatesiteforPM2.sFRMtoFRMcollocation.Collocatedmonitorsshouldbedeployedatsiteswithdesignvalueswithin20%ofeitherthedailyorannualNAAQS.TheKVRsitedidnotfitthiscriteriaconsidering2010-2012designvalues,whileothersitesinthenetworkdid.See40CFR58,AppendixASection3.2.5.3.•[Item38]ThePM10collocatedmonitorsatChulaVista(Table3.2b2,KearnyVillaRoad(Table9.2b2),andOtayMesa(Table10.2b)shouldnotbelistedasprimary.OnlyoneofthePM2.5samplersattheDowntownsite(Table6.2b1)&Escondido(Table8.2b1)shouldbelistedasprimary.ThePb-TSPcollocatedmonitoratGillespie(Table12.2)shouldnotbelistedasprimary..•[Item46]PleaseensureNCoremonitorsreportedinTables7.2a2and7.2b2alsolistSLAMSasaMonitortype.ThePAMSCarbonylsparametersreportedonTables9.2cand14.2cappeartohavetheMonitortypeandSitetypecellsincorrectlyswapped.Pleaserevisitandcorrectfornextyear'splan.Tables6.2d,7.2d,8.2d,9.2d1,9.2d2,10.2d,14.2d1,and14.2d2appeartoreporttheMonitortypeincorrectlyintheSitetyperow.PleasecorrecttherownametoreadMonitortypeandincludetheappropriateSitetype.•[Item50]WediscourageutilizingthesamePOCforidenticalparametersatasite.ThetwoPM10monitorsatKearnyMesa(Table14.2b2)reportthesamePOCof1,pleaseensurethetwomonitorsdonotsharethesamePOCorprovideanexplanationforuseofthesamePOC.•[Item83]APCDlistsglassandTeflonasprobematerialforgaseousinlets.Pleaseclarifyifborosilicate(orequivalent)glassisused.

### C. ANNUAL MONITORING NETWORK PLAN CHECKLIST (Updated 11/26/2013)

Year: 2013 · Agency: San Diego 

### Air Pollution Control District (APCD)

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, STN stations, State speciation stations, SPM stations, and/or, in serious, severe and extreme ozone nonattainment areas, PAMS stations, and SPM monitoring stations.
40 CFR 58.10(a)(l) further directs that, ''The plan shall include a statement ofpurposes 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 ofthe 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 ifthe required information is included and correct. The items requiring approval by the Administrator are: PAMS, NCore, and Speciation (STN/CSN).

Please note that this checklist summarizes many of the requirements of40 CFR Part 58, but does not substitute for those requirements, nor do its contents provide a binding determination of compliance with those

**requirem~nts.** 

### The checklist is subject to revision in the future and we welcome comments on its contents and structure. 

## Key: White = meets the requirement. Yellow= 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).

**~.. --**  

### ____ • = item requires attention in order to improve next year's plan (items listed in Enclosure B)

.

...._ 

### 1I 

## 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? · I. 

### Submit plan by July 1st 

### 58.10 (a)(l) Yes Yes Plan submitted July 22, 2013.

Please aim to submit plan, with public inspection period completed, by July 1 91 •


### We recommend that APCD fiind ways to consolidate the plan. As an example, information found in more than one section ofthe plan should be 

### referenced rather than rewritten. Other suggestions for simplifying the plan are highlighted in this checklist. 2. Statement ofpurpose for each monitor 58.10 (a)(1) Yes, Section 2, Yes APCD includes a "Site Description" and App.l-14 "Monitoring Objective" section on the first page of Appendices 1-14 that fulfills the requirement for a statement ofpurpose for each monitor. We recommend that APCD combine these two sections in next year's plan and rename them to "Statement of Purpose." This would also allow for elimination of Section 2 (i.e. "Purposes Served by the Monitors") of the plan. 3. 30-day public comment 

### I inspection

**period~** 

### 58.10 (a)(l), Yes, page B ofC Yes APCD verified via email on December 17, 2013 that 58.10 (a)(2) & 

### via email no comments were received on the plan. For future plan submittals, please clarify at the time of the plan submittal whether any public comments were received. If comments are received, please submit these along with any response to the comments from the district. 

### 4. Modifications to SLAMS network

- case when we are 58.10(a)(2) Yes, Summary Insufficient to -For the proposed development ofPM 2
. 5 

### FEM at the not approving actual system modifications (i.e

. , we 58.10(e) matrix found in judge in some Donovan site (App.5, p.l) please indicate the will do it outside the ANP process 6 ) 

### Section 1 p.ll instances planned monitor type for this site (i.e. SLAMS or

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. 

## 2 i

I I I i II 

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

I 

### within 40 submitted? 1 

### If information CFR58 yes, page 

## #s. provided 3 

### meet Flag 

### if the req? 4 

### incorrecf? SPM) along with the purpose describing the rationale to initiate PM 2
. 5 monitoring at the site.

-Insufficient information was provided in this year's plan for EPA to be able to approve the first required near-road N0 2 site in San Diego. See Enclosure D for further details.

-We are withholding approval for the termination of the Gillespie Pb monitor at this time. EPA would expect to formally approve shut down of the Gillespie Pb monitor upon receipt of fmal Summer 

### 2013 data that shows no 

### 3 month rolling averages over half of the Ph NAAQS have been measured at Gillespie.

-We are withholding approval for relocation of the Overland site to the Kearny Villa Road site pending the gathering of further information by APCD that demonstrates 

### 40 CFR 

### 58.14 criteria are met.

-We are aware of APCD's need to vacate the current El Cajon NCore site. While EPA Region 9 does not have the authority to approve system modifications to the NCore network, we are available to work with APCD and EPA HQ to ensure appropriate resolution to this matter. APCD should continue to engage the regional office on this topic and ensure progress is documented in next year's plan.

-While EPA Region 9 does not have approval authority for the proposed relocation ofPAMS parameters at the Alpine (ALP) temporary site back to its original site (approximately 

### 33 meters west),
we fmd the proposed relocation acceptable and

**--** -- --- -- L__

__ - · -

- - ------ would recommend aQQroval to the EPA

6 See 

### 58.14(c) 

## 3

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

### If 

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

## meet Flag if 

## the req? 4 

## incorrecr? Administrator.

-EPA recommends that APCD compile a single section that describes in detail all recent and proposed modifications to the SLAMS network. This section would follow well after Table 1.2 and
can be used to consolidate the various individual pollutant/program sections throughout the plan that currently speak to network changes (i.e. Sections 4.8, 5.8, 6.8, 7.8, 8.8, 9.9, 10.8, 11.7, 12.6, & 13.6). 5. Modifications to SLAMS network- case when we are 58.10 (a)(2) Yes, Summary Yes We approve the following proposed SLAMS approving actual system modifications per 58.14(c) 58.10 (b)(5) matrix found in network modifications: 58.10(e) Section 1 p.11 -Relocation ofPM2

. 5 at the temporary Alpine site 58.14 (c) back to its original location approximately 33 metersWest. -Relocation ofthe current PM 10 sampler at Donovan to a new Donovan site, approximately 700m east. -The discontinuance of 0 3 and N0 2 monitoring at Otay Mesa, with new monitors starting afDonovan,
was approved as part ofthe ANP submitted for 2009. EPA notes that since that time, new monitoring regulations require APCD to install two

- near-road microscale N02 monitors elsewhere in the district between 2014-2015. Ozone at Otay Mesa during the past five years has consistently measured lowered values than a majority of other sites 

### in APCD's network. 

### -In a letter sent December 9, 2013, EPA also approved the shutdown of the existing Palomar Pb monitor and the start up ofthe new Palomar Ph monitor at the north airport boundary site. Please include a copy of this correspondence in next year's plan. 6. Does plan include documentation (e.g., attached Yes Yes approval letter) for system modifications that have been approved since last ANP approval? 7. NCore site operational (by 11112011) 58.10 (a)(3) Yes,App.7 N/A- HQ approval All required parameters operational. 8. Pb site for 0.5-1.0 tpy sources operational (by 58.10 (a)(4) Yes, ApJ:>.ll & 12 Yes Both Gillespie and Palomar Pb airport monitors 

## 4

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

### If 

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

## meet Flag if 

## the req? 4 

## incorrecr? 12/27/2011) began operating in March 2012. 9. N0 2 

### plan for area-wide and RA40 sites submitted by 58.10 (a)(5) Incorrect, Sections Insufficient to The San Diego-Beardsley N0 2 

### monitor cannot be I

I 

### 7/ 1 / 2012 5.5.3 & 

### 5.5.4 judge used to fulfill both the Area- Wide and Regional I 

### Administrator (RA40) monitoring requirement. Per

I 

### 40 CFR 58 Appendix D Section 4.3.4(a), the RA40 monitors must be in addition to the minimum monitoring requirements. We recommend that the district select a different N0 2 

### site to fulfill the AreaWide requirement and keep the Beardsley site to fulfill the RA40 requirement. 

### 10. N02 

### area-wide and RA40 sites operational by 58.10 (aX5) Yes, Section 5 

### Yes APCD operates more than 

### the minimum required 1/112013 N02 

### monitors. See item 9 to correct identification of Area-Wide & 

### RA40 monitors. 11. N0 2 

### plan for near-road sites submitted by 711 /2013 58.10 (a)(5) Yes, but Insufficient to See included near-road checklist (Enclosure D). Plan incomplete, judge submitted July 22, 2013 Section 5 

### 12. S02 

### sites operational (by 111/2013) 58.10 (a)(6) N/A N/A No PWEI monitoring requirement. Required S02 

### and58.13_@ site operational at NCore. 

### 13. AQS site identification number for each site 58.10 (b)(l) Yes, App. 1-14 Yes 14. Location ofeach site: street address and geographic 58.10 (b)(2) Yes, App. 1-14 Yes coordinates 15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes, App. 1-14 Yes parameter 16. Any proposals to remove or move a monitoring station 58.10 (b)(5) Yes, App. 1-14 Yes See items 4 & 

### 5. within a period of 18 months following plan submittal 17. Scale ofrepresentativeness for each monitor as defined 58.10(bX6); Yes, App. 1-14 Yes in

**Ap.~>_endix** 

### D AppD 18. Identification of sites suitable and sites not suitable for 58.10 (b)(7) Yes, Section 9.4.0 Yes All FRM and FEM samplers are sited as to be able comparison to the annual PM2 

### .s NAAQS as described to be compared to the NAAQS. in Part 58.30 19. MSA, CBSA, CSA or other area represented by the 58.10 (b)(8) Yes, App. 1-14 Yes monitor 20. Designation of any Pb monitors as either source- 58.10 (b)(9) Yes, app. 7, 11, 

## f!l. Yes oriented or non-source-oriented 12 21. Any source-oriented Ph site for which a waiver has 58.10 (b)(10) N/A N/A- no waiver yet Palomar has 

### been approved as a permanent site and been granted by EPA RA granted is not eligible for a waiver at this time, see item 5. See item 4 for discussion concerning Gillespie.


### 5

## 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 

## incorrece? 22. Any Pb monitor for which a waiver 

### has been requested 58.10 (b)(ll) N/A N/A- 

### all sites

or granted by EPA RA for use ofPb-PM 10 in lieu 9f operate using PbPb-TSP TSP 23. Identification ofrequired

**N~** monitors as either near- 58.10 (b)(l2) Yes, Section 5 Yes Will need to clarify Area-Wide monitor. See items 9 road or area-wide & 10. 24. Identification of any PM2
. 5 FEMs and/or ARMs not 58.10 (b)(13) Yes, Section 9 N/A- EPA will eligible to be compared to the NAAQS (Note 1: must 58.11 (e) review and include required data assessment.) (Note 2: Required respond outside of SLAMS must monitor PM2
. 5 with NAAQS- ANPreview comparable monitor at the required sample frequency.) process. 25. For SPMs listed as non-regulatory, note the start Date 58.20(c) N/A N/A-noSPMs ofFRMIFEM/ARM at SPM. If> 24 months, and listed monitor is eligible for comparison to the NAAQS per 58.11 (e) w:td 58.30, the agency must supply information that App A, C orE requirements were not met. 26. Document how states and local agencies provide for 58.10 (c) Incomplete, Insufficient to APCD currently documents the proposal process for the review of changes to a PM2 

### .s monitoring network Section 9.9 judge EPA and ARB to review the official that impact the location of a violating PM 2
. 5 monitor. decommissioning of any PM 2
. 5 monitor. Please also

ensure to document the process for obtaining public comment for the review of changes to a PM 2
. 5 monitoring network that impact the location of a violating PM2
.5 monitor. 27. Does the plan include a request for approval for and 58.11 (a) (2) N/A N/A-no SPMs alternative to appendix A requirements for SPMs listed operating a FRMIFEM/ ARM which also meets appendixE? 28. Precision/Accuracy reports submitted to AQS 58.16(a); Yes, Section 15 Yes AppA,1.3 and 5.1.1 29. Annual data certification submitted 58.15 Yes, Section 15.1 Yes App.A 1.3 30. Frequency of flow rate verification for manual PM AppA3.3.2 Yes, Section 9.6 & Yes Every 4 weeks. samplers audit App. 1-14 31. Frequency of flow rate verification for automated PM AppA3

. 2.3 Yes, Section 9.6 & Yes Every two weeks. analyzers audit App. 1-14 32. Frequency of one-point flow rate verification for Pb AppA Yes, Section 8.6 Yes Once per month


## 6

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

### If 

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

## meet Flag if 

## the req? 4

· 

## incorrecr? samplers audit 3.3.4.1 33. Frequency of one-point QC check (gaseous) App.A3.2.1 Yes, App.1-14 Yes NOx/NOy, S02 , 

### & CO at El Cajon at 1:4, 

### all others 1:14 34. Date of last Annual Performance Evaluation (gaseous) App.A3.2.2 Yes, Section 14.3

. Yes 35. Dates of last two semi-annual flow rate audits for PM App A, 3.2.4 Yes, Section 14.3 Yes monitors and3.3.3 36. Dates oflast two semi-annual flow rate audits for Pb AppA Yes, Section 14.3 Yes monitors 3.3.4.1 37. PM2

.s collocation AppA3.2.5 Yes, Section 9 

### & Yes We recommend that APCD revisit the most I 14.2 appropriate site for PM 2
. 5 FRM to FRM collocation. Collocated monitors should be deployed at sites with design values within 20% of either the daily or annual NAAQS. The KVR site did not fit this criteria considering 2010-2012 design values, while other sites in the network did. See 40 CFR 58, Appendix A Section 3.2.5.3. 38. Designation of a primary monitor if there is more 

### than Need to Yes, but incorrect Yes The PM 10 collocated monitors at Chula Vista (Table one monitor for a pollutant at a site. determine in some instances, 3.2b2, Kearny Villa Road (Table 9.2b2), and Otay collocation App.l-14 Mesa (Table 

### I 0.2b) should not 

### be listed as primary. Only one of the PM 2
. 5 samplers at the Downtown site (Table 6.2bl) 

### & Escondido (Table 8.2bl) should 

### be listed as primary. The Pb-TSP collocated monitor at Gillespie (Table 12.2) should not be listed as

_ plWUII.)'• 39. Distance between collocated monitors (Note: waiver App.A Yes, App.l-14 No- Otay Mesa The 5.2 m distance between collocated PM 10 request or the date of previous waiver approval must 3.2

. 5

. 6 and Yes- all others samplers at Otay Mesa (Table 

### I 0.3) is not meeting be included if the distance deviates from requirement.) 3

. 2.6.3 the re quirement. 40. Manual PM 10 method collocation met? (note: AppA3.3.1

- Yes, Section 10.7.3 Yes continuous PM 10 does not have this

**r~uiremen!)** 41. Pb collocation AppA Yes, Section 8 Yes 3.3.4.3 42. PM 10•2 

### .s collocation (note: only applies to Fresno and AppA3.3.6 N/A N/A- No current Phoenix NCore sites) requirement, HQ Approval 43. Instrument/monitoring method code for each monitor: AppC Yes, App.1-14 Yes is it reported properly? Is it reported correctly (i.e., 2.4.1.2 appropriate method code for regulat()_ry monitors)?



### 7

### 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?

I 

### 44. For agencies that share monitoring responsibilities in App D2(e) Yes, Section 3 Yes APCD meets or exceeds all minimum monitoring

! an MSA/CSA: does each affected State or local agency requirements for the MSA. 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 Yes, App.1-14 Yes determine 

### if otherreq. (e.g., min# and colloc)
are met 46. Instrument monitor type for each monitor Required to Yes, App.l-14 Yes -Please ensure NCore monitors re(K>rted in

-Tables determine if 7 .2a2 and 7 .2b2 also list SLAMS 

### a5 a Monitor type. otherreq. -The PAMS Carbonyls parameters reported on (e.g., min# Tables 9.2c and 14.2c appear to have the Monitor and colloc) type and Site type cells incorrectly swapped. Please

are met revisit and correct for next year's plan. -Tables 6.2d, 7.2d, 8.2d, 9.2dl, 9.2d2, 10.2d, 14.2dl, and 14.2d2 appear to report the Monitor type incorrectly in the Site type row. Please correct the
row name to read Monitor type and include the appropriate Site type. 47. Monitoring objective for each instrument AppD 1.1 Yes, App.1-14 Yes 58.10 (b)(6) 48. Site type for each instrument AppD 1.1.1 Yes, App.1-14 Yes See Site type corrections listed in item 46. 49. Instrument parameter code for each instrument Required to Yes, App. 1-14 Yes

I determine 

### if otherreq. (e.g., min# and colloc)
are met 50. Instrument parameter occurrence code for each Required to Yes, App.l-14 Yes We discourage utilizing the same POC for identical instrument determine if parameters at a site. The two PM 10 monitors at other req. Kearny Mesa (Table 14.2b2) report the same POC of (e.g., min# I. Please ensure the two monitors do not share the and colloc) same POC or provide an explanation for use of the
are met samePOC. 51. Sampling season for ozone (note: date of waiver 58.10 (b)(4) Yes, App.1-14 Yes 

### 8

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

### If 

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

### meet ],4'Iag if 

### t h e req? 4 

### incorrecf? approval must be included 

### ifthe sampling season App D, 4.1(i) deviates from requirement) 52. Sampling schedule for PM2 

### .s

- applies to year-round 58.10 (b)(4) Yes, App.1-14 Yes and seasonal sampling schedules (note: date of waiver 58.12(d) approval must be included if the sampling season AppD4.7 deviates from requirement) EPA flowchart 53. Sampling schedule for PM 10 58.10 (b)(4) Yes, App.1-14 Yes 58.12(e) AppD4.6 54. Sampling schedule for Pb 58.10 (bX4) Yes, App.7, 11, 12 Yes 58.12(b) AppD4.5 

### 55. Sampling schedule for PM10-2

.s 58.10 (b)(4) Yes,App.7 Yes 58.12(f) ' AppD4.8 56. Minimum# of monitors for 0 3 [Note: should be App D, 4.1(a) Yes, Section 3 Yes supported by MSA ID, MSA population, DV, # and monitors, and# required monitors] (see footnote) 7 TableD-2 57. Identification of max. cone. 0 3 monitor(s) AppD4.1 Yes, Section 4 Yes (b) 58. Minimum monitoring requirements met for near-road AppD4.3.2 N/A N/A-notyet N02 (2014 start date) required 59. Minimum monitoring requirements met for area-wide AppD4

. 3.3 Yes, Section 

### 5 Yes APCD operates more than the minimum number of

**N~** required N02 monitors however clarification is needed as to which monitor 

### is being counted to meet the area-wide requirement. See item 9.

. 60. Minimum monitoring requirements met for RA-40 AppD4.3.4 Yes, Section 

### 5 Yes APCD operates more than the minimum number of N02 required N02 monitors however clarification is needed as to which monitor 

### is being counted to meet the RA40 requirement. See item 9. 61. Minimum monitoring requirements met for

**S~** [Note: AppD4.4 Yes, Section 7 Yes S02 required only at NCore at this time. Only monitors considered to be required SLAMs are eligible tokcounted

**towar~** meeting minimum

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) cann?t be counted towards 

## minimum monitoring requirements. 

### 9

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

### 1f 

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

### meet

I 

### Flag if 

### the req? 4 

### incorrect2 

### ? monitoring requirements.) 62. Minimum monitoring requirements met for Pb [Note: AppD4.5 Yes, Section 8 Yes 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, Yes, Section 9 Yes supported by MSA ID, MSA population, DV, # 4

. 7.l(a) and monitors, and# required monitors] [Note 2: Only Table D-5 monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements.] 

### 64. Optional PM2

.5 Network Clarifications: Provide a list Need to N/A N/A ofrequired sites 

### ifit does not include 

### all SLAMS. assess several [Note: default will assume all SLAMS are considered requirements I required sites.] 65. Required PM2

.5 sites represent area-wide air quality AppD Yes, Section 9 Yes 4.7.1(b) 66. For PM2

.5 , is 

### at least one site at neighborhood or larger AppD Yes, Section 9.5.2 Yes I scale in an area of expected maximum concentration 4.7.l{b)(l) 67. If additional SLAMS PM2

.5 required, 

### is there a site in AppD Yes, Section 9.5.3 Yes

an area ofpoor air quality 4.7.l(b)(2) 68. Minimum monitoring requirements for continuous AppD4.7.2 Yes, Section 9 Yes PM2.s 69. Requirements for PM2

.5 background and transport sites AppD4.7.3 N/A N/A- state requirement 70. Are PM2

.5 Chemical Speciation requirements met for App D 4

. 7.4 Yes, Section 9 Yes official STN sites? 71. Minimum# of monitors for PM 10 AppD,4

. 6 Yes, Section lO Yes (a) and Table D-4 

### 72. Minimum monitoring requirements met for PM 10•2

.5 AppD4.8 Yes, Section ll Yes

mass 73

. Distance of site from nearest road AppE6 Yes, App.l-14 Insufficient to APCD notes that El Cajon will address 7.8 m judge at El Cajon distance to road siting deficiency when the station is Yes- all others relocated. APCD may also choose to work with EPA to determine if a siting waiver request, per 40 CFR

-- - 58,

**A_l)p~_ndix** E Section I 0, is aQQfOQriate.

----- 

### 10I 

## ANP requirement Citation Was the info Does the within 40 

## submitted? 1 

### If 

## information CFR58 yes, page #s. provided3 

## meet Flag if 

## the req? 4 

## incorrecr? 74. Traffic count of nearest road Apj)_E Yes, Aj)l). 1-14 Yes 75. Groundcover AppE3(a) Yes, App.1-14 Yes

. 76. Probe height AppE2 Yes, App.1-14 Yes



### 77. Distance from supporting structure AppE2 Yes, App.l-14 No at Del Mar Yes- all others

78. Distance from obstructions on roof App E4(b) Yes, App.l-14 Insufficient to judge at Camp Pendleton and Del Mar Yes- all others.
79. Distance from obstructions not on roof App E 4(a) Yes, App.l-14 Insufficient to judge at Camp Pendleton Yes- all others.
80. Distance from trees AppE5 Yes, App.1-14 Yes 81. Distance to furnace or incinerator flue AppE3(b) Yes, App.1-14 Yes 82. Unrestricted airflow AppE,4(a) Yes, App.1-14 Yes and4(b) 83. Probe material (if applicable) AppE9 Yes, App.l-14 Yes

84. Residence time (if 

### applicable) AppE9 Yes, App.l-14 Yes


## Public Comments on Annual Network Plan Were comments submitted to the S/Lff agency during the public comment period? 

## No. If no, skip the remaining questions. If yes:
• Were any of the comments substantive?
o If yes, which ones? 

## Notes

See item 73. The Escondido site appears to be 

### in a parking lot with asphalt ground cover, please clarify as needed. Gillespie and Palomar samplers to be 

### raised 0.5m to meet minimum probe height requirement. Please address this 

### change 

### in next year's plan. The Del Mar gas inlet, at 0.78 m, is not meeting this requirement. Please correct siting deficiency or work with EPA to determine if a waiver request per 40 CFR 58, Appendix E Section 10 is appropriate. Camp Pendleton (Table 2.3) and Del Mar (Table 4.3) list on roof obstruction distances. Please also include height of these and any other potential on roof obstructions in future plan submittals as this is necessary to judge the extent of a potential obstruction. Camp Pendleton (Table 2.3) lists an off roof obstruction distance. Please also include height of this and any other potential off roof obstructions in future plan submittals as this is necessary to judge the extent of a potential obstruction

.

APCD lists glass and Teflon as probe material for gaseous inlets. Please clarify if borosilicate (or equivalent) glass is used.



### 11

### o Explain basis for determination if any comments were considered not substantive:
• Did the agency respond to the substantive comments?
a If yes, was the response adequate?
• 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:

12

### D. Region 9 Near-road N02 Plan review checklist Checklist Version date: November 

## 26,2013 Agency: San Diego Air Pollution Control District CBSA: San Diego-Carlsbad-San Marcos 

## (1st required site in CBSA)
This checklist is intended to clarify those elements that EPA will be looking for during the review ofproposed near-road N02 monitoring sites. Please note that this checklist summarizes near-road N02 site 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. Yellow = Requirement is not met, or information is insufficient to make a determination. Action requested in next year's plan or outside the ANP process

.

........ . ---- , = item requires attention in order to improve next year's plan.

## COMPLETENESS CHECK: Based on 40 CFR 58 

## t Network Plan requirements (40 CFR 58.10)- No
. Near-road N0 2 

### plan requirement Citation 

## Info Requirement Notes submitted? 1 

### met? 2 

### Hyes,page 

## #s. 1 

### A plan (submitted by July 1, 2013) for 40CFR Incomplete, Insufficient to Plan submitted to EPA on July 22, 2013. establishing near-road N02 monitoring 58.1 O(a)(5) Section 5 

### judge site(s) Please resubmit a plan that proposes a final candidate site location and includes the missing information highlighted in this checklist for the final site selection. The plan should go through a minimum 30 day public inspection period prior to submittal to EPA. 2 Evidence of public comment on proposed 40CFR Yes, page B Insufficient to Will need to resubmit a plan that proposes a site(s), no changes subsequent to proposal, 58.1 0( a)(2) ofC judge final site

. See item 1. and submittal of any received comments 3 Anticipated operation start date 40CFR Yes, Section Insufficient to The District acknowledges that one monitor is 58.1 O(a)(5) 5 

### p.7 judge required to be installed in 2014 and another in 2015. Please clarify a more precise anticipated operation start date. 4 AQS site identification number 40CFR No Insufficient to Please include this information in the final 58.10(b)(l) judge submittal if available. 5 Location (street address & 

### geographical 40CFR Yes, Section Insufficient to Please present a street address · and coordinates) 58.1 O(b )(2) 5 p.8 judge geographical coordinates for final site selection. 

## 6 Sampling and analysis method (method 40CFR No Insufficient to Please include this information in the final code) 58.1 O(b)(3) judge submittal. 7 Operation Schedule (Season & 

### sampling 40CFR No Insufficient to Please include this information in the final frequency) 58.1 O(b )(4) judge submittal.

---

1 Response options: N/A (Not Applicable), Yes, No, Incomplete, Incorrect. The responses "Incomplete" and ulncorrect" assume that some information has been provided. 2 Response options: N/ A (Not Applicable)- [reason], Yes, No, Insufficient to Judge. Assumes information submitted is correct. 

### 2 I

### 8 Any proposal to remove or move the 40CFR No Insufficient to Please include this information in the final monitor within a period of 18 months 58.1 O(b)(5) judge submittal. following plan submittal 9 Monitoring objective & 

### spatial scale of 40CFR No Insufficient to Please include this information in the final representativeness 58.1 O(b)(6) judge submittal. 10 

### CBSA represented by the monitor 40CFR Yes, Section Yes 58.1 O(b)(8) 

## 5 p.7 

## Network Design requirements (40 CFR 58, Appendix D, Section 4.3.2 11 

### CBSA population & 

### year 40 CFR58, Yes, Section Yes App.D 

## 5 p.7 4.3.2(a) 12 Maximum AADT counts & 

### year for the 40 CFR58, Yes, Section Yes CBSA(s) App.D 

## 5 p.7 4.3.2(a) 13 

### Correct# ofrequired near-road 

### N0 2 

### 40 CFR58, Yes, Section Yes monitors for the CBSA(s) App.D 

## 5 p.7 4.3.2(a) 14 Were all road segments within the CBSA 40 CFR58, Yes, Section Yes ranked by AADT? App.D 

## 5 p.7 I 

### 4.3.2(a)(1) 15 Discussion of how fleet mix is considered 40 CFR 58, Incomplete, Insufficient to Please clarify how Fleet Equivalency (FE) App.D Section 5 p.8 judge was calculated and include estimated FE4.3.2(a)(1) AADT for final site selected. 16 Discussi o n of how ro adway design is 40 CFR 58, No Insufficient to Please include this information in the final considered App.D judge submittal. 4.3.2(a)(l) 17 Discussion of how congestion is 40 CFR 58, Incomplete, Insufficient to Please clarify the LOS congestion rating for considered App.D Table 5.6b judge the final site selection. 4.3.2(a)(l) 18 Discussion of how terrain is considered 40 CFR 58, No Insufficient to Please include this information in the final App.D judge submittal. 4.3.2(a)(l) 19 Discussion of how meteorology is 40 CFR 58, Incomplete, Insufficient to The District mentions finding acceptable considered App.D Section 5 p.8 judg_e locations on the east side ofthe 1-15, however 3

### 4.3.2(a)(l) no clear connection to meteorology influences for this decision are specified. Clarify if the site will be downwind. Please include this information in the final submittal. 20 After above factors considered, if multiple 40 CFR 58, No Insufficient to Please include this information in the final candidate sites where max concentrations App.D judge submittal. expected: Discussion of how population 4.3.2(a)(l) exposure is considered? 21 Where the site proposed is the 2n 11 

### in the 40 CFR58, N/A N/A- Will need to include information for this CBSA: Discussion of differing factors App.D approval for factor for 2nd proposed site. compared to first site (i.e. fleet mix; 4.3.2(a)(1} 1st site is still congestion; terrain; geographic area within pending. CBSA; or different route, interstate,

· or freeway designation). 

## Sitin2 criteria requirements (40 CFR 58, Appendix E)- 22 Distance from target road segment as near 40 CFR 58, No Insufficient to Please include this information in the final
as practicable (TAD recommendation is App.E judge submittal. within 20 meters) & 

### no more than 50 6.4(a) meters? 23 Vertical inlet placement between 2-7 40 CFR 58, No Insufficient to Please include this information in the final meters? App.E2 judge submittal. 24 Probe distance from supporting structures 40 CFR 58, No Insufficient to Please include this information in the final is at least 1 meter away vertically or App.E 2 judge submittal. horizontall y ? 25 Is air flow unobstructed between the probe 40 CFR 58, No Insufficient to Please include this information in the final and the outside nearest edge of the targeted App.E4(d) judge submittal. road segment?

SUPPORTING/ADDITIONAL INFORMATION: Based on N dNO**~.&.A.a.-** ...**~** .. - ........ At:l 

### TAD and Chec k (Yes, No, N/A, Comments lnsllflicient) H y es,**p~ag e**  

### #s. If top FE-AADT segment not selected, is adequate justification No, Section 5 The District indicates it was unable provided for higher ranks not selected? p.8 to secure permission or approval for
4

### top ranking road segments. Please

I 

### provide further discussion ana justification as to why top segments cannot be selected. For example, include relevant letter exchanges that may have declined the District's permission for access. If similar top FE-AADT candidate sites available, was most Insufficient to See Item 17 above. congested segment selected? judge Is candidate site selected downwind of target road segment? Insufficient to See Item 19 above. judge Are wind roses included to show predominant wind patterns? Insufficient to See Item 19 above. judge Are physical attributes (roadway design, roadside structures, or Insufficient to See Item 16-19 above. terrain) desirable according to Table 4-2 of the Near-road N(h TAD judge (see below)? If physical attributes (roadway design, roadside structures, or terrain) Insufficient to See Item 16-19 above. NOT desirable according to Table 4-2 of the Near-road N0 2 TAD, judge
are they TYPICAL for the area? Was population exposure correctly considered as an additional factor Insufficient to See Item 20 above. AFTER consideration of primary factors (FE-AADT, congestion, judge roadway design, terrain, meteorology) and IF multiple max concentration candidate sites identified? Will this be a multi-pollutant site? 

### If so, list additi<?nal parameters Insufficient to Please clarify any other pollutants planned in Comments. judge that may be installed at the site. Does agency ensure candidate selection is NOT in a "unique" Insufficient to location? (See Near-road N02 TAD section 13.2 included below) judge

5

### I considerations for candidate near-road sites.

Roadway Feasibility of At-grade or Deep cut- Field reconnaissance; design or monitor nearly at-gracje sections/significant satellite configuration placements; with immediate ly below grade; imagery affects pollutant surrounding significantly above transport and terrain. grade (fill or dispersion. bridge); above brid



# - -
. Roadside Feasibility of present other Presence of sound Field reconnaissance; Structures monitor than low (<2 m walls, mature (high satellite placement; in and thick) imagery affects pollutant height) vegetation, transport and vegetation or obstructive dispersion. safety features buildings. such as ardrails. Terrain I Affects pollutant Flat or gentle Along mountain Field reconnaissance; dispersion, local terrain, within a ridges or peaks, digital atmospheric valley, or along a hillsides, or other elevation models and stability. road grade. naturally vegetation windswept areas. files; satellite

. i Meteorology Affects pollutant Relative Strongly Local data; National transport and downwind predominant Oceanic and · dispersion. locations; winds upwind positions. Atmospheric from road to Administration's monitor. (NOM's) National Weather Service (NWS); EPA's Air Quality
n (AQS). 

# I

6

### 13.2 Unique Locations and Background Source Influences
In the evaluation process, state and local air agencies may encounter situations where certain road segments of interest have characteristics that make the location a unique**near-ro~d** 

### location that has elevated pollutant concentrations. In such cases, the pollutant concentrations are not representative of other near-road locations across the CBSA. The unique characteristics of these

. locations could be due to the close proximity of a substantial stationary source, non-road mobile

sources, or roadway design features (such as tunnel entrances and exits or toll plazas). In situations where a state or local air 

### agency has a choice between road segments that otherwise have similar potential for peak N02 concentrations, the air 

### agencies should place a higher weight

on sites that are most influenced by typical roadway activity rather than those that are heavily influenced by unique sources or features. This approach increases the probability that the chosen site can represent a larger population exposure within and across CBSAs. The EPA recognizes that state and local air 

### agencies will likely have a good understanding of whether candidate near-road N02 monitoring sites have unique characteristics that do or do not represent the CBSA that those sites are within. The EPA encourages state and local air 

### agencies
to use their local knowledge in site selection and to engage the EPA Regional staff for assistance in evaluating such a situation as necessary.

7