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 PM2.5 monitor from the temporary Alpine site back to its original location and 

relocation of the current PM1o 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 N02 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 Paper 
Meredith 

Kurpius, Ma

ag

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 Board 
(

), 

, 

, 

g

g

j

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 PM2.5 FEM monitoring at Donovan. 

- Relocation of SLAMS monitoring at Overland to Kearny Villa Road. 

• Plans for establishing near-road N02 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 

road 
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). 
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. 

• [Item 3] APCD verified via email on December 17, 2013 that 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 drafted by the district. 

• [Item 4] 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). 

• [Item 3 7] We recommend that APCD revisit the most appropriate site for PM2.s 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. 

• [Item 38] The PM10 collocated monitors at Chula Vista (Table 3.2b2, Kearny Villa Road 

(Table 9.2b2), and Otay Mesa (Table 10.2b) should not be listed as primary. Only one of 

the PM2.5 samplers at the Downtown site (Table 6.2b1) & Escondido (Table 8.2b1) 

should be listed as primary. The Pb-TSP collocated monitor at Gillespie (Table 12.2) 

should not be listed as primary. . 

• [Item 46] Please ensure NCore monitors reported in Tables 7 .2a2 and 7 .2b2 also list 

SLAMS as a Monitor type. The PAMS Carbonyls parameters reported on Tables 9.2c 

and 14.2c appear to have the Monitor type and Site type cells incorrectly swapped. Please 

revisit and correct for next year's plan. Tables 6.2d, 7.2d, 8.2d, 9.2d1, 9.2d2, 10.2d, 

14.2d1, 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. 

• [Item 50] We discourage utilizing the same POC for identical parameters at a site. The 

two PM10 monitors at Kearny Mesa (Table 14.2b2) report the same POC of 1, please 

ensure the two monitors do not share the same POC or provide an explanation for use of 

the same POC. 

• [Item 83] APCD lists glass and Teflon as probe material for gaseous inlets. Please clarify 

if borosilicate (or equivalent) glass is used. 

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, 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 (STN/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 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) . 

...._ 

1 
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 

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 191• 

We recommend that APCD fiind ways to consolidate 

the plan. As an example, information found in more 

than one section of the plan should be referenced 

rather than rewritten. Other suggestions for 

simplifying the plan are highlighted in this checklist. 

2. Statement of purpose 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 of purpose 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 ofPM2.

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 process6

) 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 

I 
I ANP requirement Citation Was the info Does the Notes 

I within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecf? 

SPM) along with the purpose describing the 

rationale to initiate PM2.5 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 N02 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. provided3 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 of the current PM10 sampler at Donovan 

to a new Donovan site, approximately 700m east. 

-The discontinuance of 0 3 and N02 monitoring at 

Otay Mesa, with new monitors starting afDonovan, 

was approved as part of the 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 of the 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. provided3 meet 

Flag if the req?4 

incorrecr? 

12/27/2011) began operating in March 2012. 9. N02 plan for area-wide and RA40 sites submitted by 58.10 (a)(5) Incorrect, Sections Insufficient to The San Diego-Beardsley N02 monitor cannot be I 

7 I /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 N02 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. N02 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 of each 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 of representativeness 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. provided3 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-PM10 in lieu 9f operate using PbPb-TSP TSP 

23. Identification of required 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 PM2.

5 monitor. decommissioning of any PM2.

5 monitor. Please also 

ensure to document the process for obtaining public 

comment for the review of changes to a PM2.

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. provided3 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 PM2.

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 PM10 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 PM2.

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 PM10 

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 requirement. 

40. Manual PM10 method collocation met? (note: AppA3.3.1 -Yes, Section 10.7.3 Yes 

continuous PM10 does not have this r~uiremen!) 

41. Pb collocation AppA Yes, Section 8 Yes 

3.3.4.3 

42. PM10•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 P AMS 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 

determine if I 

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 the req?4 

incorrecf? 

approval must be included if the 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 PM10 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 

of required sites if it 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 of poor 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 PM10 AppD,4.6 Yes, Section lO Yes 

(a) and Table 

D-4 

72. Minimum monitoring requirements met for PM10•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. -----

10 
I 

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 of proposed 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 N02 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# of required near-road N02 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 Discussion of how roadway 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 2n11 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. 

horizontally? 

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 

Check (Yes, No, N/A, Comments 

lnsllflicient) 

H yes, p~age #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 N02 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