UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

New England Regional Laboratory 

11 Technology Drive, North Chelmsford, Massachusetts 01863 

October 10,2014 

Craig Wright, Director 

Air Resources Division 

Department of Environmental Services 

29 Hazen Drive 

Concord, NH 03301 

Dear Mr. Wright: 

Thank you for your submission of the New Hampshire Ambient Air Monitoring Program 

2014/2015 Annual Network Review and Plan, which was received by EPA in final form on 

September 2, 2014. We appreciate that you have addressed most of the comments that EPA 

provided to you on July 18, 2014. EPA New England has evaluated your plan and finds that 

your plan meets the minimum requirements of 40 CFR Part 58. 

We acknowledge the following modifications and future plans which you outlined in your plan 

(in italics): 

Network Modifications 

lvfodijications consisted of completing and shutting down special monitors associated 

with the Wood Smoke Study, including all equipment at the Stickney Avenue site in 

Concord, and the CO and S02 monitors in Keene. DES also initiated special project 

monitoring in Portsmouth in response to numerous PM complaints concerning an 

industrial facility near lvfarket Street. This monitoring began in September of 2013 and 

was completed in May of2014. 

Future Plans 

lvfove the Photochemical Assessment }vfonitoring Station (PAMS) from Gilson Road in 

Nashua to the Moose Hill School NCORE site in Londonderry. DES plans to relocate 

PAMS monitoringfi'om the Gilson Road, Nashua station to the Moose Hill School, 

Londonderry NCORE station at the conclusion of the 2014 ozone season. With EPA's 

approval of this move, DES intends to fully become operational for PAMS monitoring in 

Londonderry for the 2015 ozone season. The Gilson Road location will continue to 

monitor ozone and meteorology during the near-term, however DES may explore its 

relocation to a Nashua high school athletic complex. 

Shutdown PM2.5 sampling at Crown Street in Nashua. DES intends to shut down PM2.5 

monitoring at Crown Street in Nashua on December 31, 2014. 
Shutdown PM2.5 sampling at Exchange Street in Pembroke. DES intends to shut down 

PM2.5 monitoring at the Pembroke station on December 31, 2014. DES will relocate the 

PQ200 collocation sampling to the Londonderry station. 

NHDES proposes to use the FRlvf (PQ200) at the Londonderry site as the primGJy 

monitor tor Plvh.5 and that the FEA1 data should be excluded tor NAAOS comparisons. 

Per the changes listed above, all network modifications that involve the discontinued operation or 

movement of sites are subject to EPA approval, even if the remaining network meets EPA's 

minimum requirements. In light of possible future state and federal budget restrictions, we 

encourage New Hampshire Department of Environmental Services (NH DES) to consider further 

cost saving measures and discuss those opportunities with the EPA prior to implementation. 

On Aprill7, 2014, EPA proposed its Data Requirements Rule for the 1-Hour Sulfur Dioxide 

Primary National Ambient Air Quality Standard (NAAQS) detailing monitoring and 

modelling guidance for implementing the S02 standard. An outcome of that approach may be 

greater reliance on S02 monitoring. EPA looks forward to future discussion with NHDES 

regarding any changes to so2 standard implementation. 

Consistent with 40 CFR Part 58.ll(e), EPA is approving the exclusion of PM2.s continuous data, 

for NAAQS purposes, from the continuous PM2.s monitor at the Londonderry NCORE site. As 

you know, this included your analysis of continuous PM2.s Federal Equivalent Methods (FEMs) 

as compared to collocated PM2.s Federal Reference Methods (FRMs). This comparison is 

required under 40 CFR Part 58.11(e) for any cases where PM2.s continuous FEM data should not 

be used in comparison to the NAAQS. EPA encourages NHDES to continue its efforts to 

provide NAAQS comparable continuous PM data at its key monitoring locations. 

You discussed the six continuous PM2.s FEM monitors, at the five different locations in your 

network. You indicated that NI-l DES will use data from its FEM monitors for comparison to the 

NAAQS, with the exception of the Londondeny Moose Hill NCORE station because this 

monitor does not have acceptable data comparability with the collocated FRM monitor. In the 

case of the Londonderry Moose Hill station, the analysis shows that the performance is outside 

of the acceptable range. You provided some information from that analysis. My staff 

independently performed this analysis as well, and will include those results in our files 

supporting this action. \Ve have supplied that information to your staff. In the future, to allow 

for public review of this information, please include your FEM/ FRM assessment in this annual 

network plan as required by 40 CFR 58.ll(e). Nevertheless, this assessment, when run for 

calendar years 2011-2013, demonstrates that this monitor does not meet requisite performance 

criteria for National Ambient Air Quality Standard (NAAQS) compliance purposes. We 

recognize that you believe these data are acceptable for AQI purposes, and agree that data from 

this monitor should be reported using parameter code of 88502, indicating that these data are 

appropriate for AQI use, but not for comparison to the NAAQS. Should you determine these 

data are not of acceptable quality for either AQI reporting or for comparison to the NAAQS, then 

the parameter code 88501 should be used. You should continue reporting to the same parameter 

code when generating any new data with the PM2.s continuous FEMs. (Note that the network 

design requirements for PM2.s remain in effect and that your agency is required to operate FRMs 

or other FEMs at all required sites to be used for comparison to the NAAQS.) If you determine 

that the continuous monitor approved for exclusion is operating within acceptable ranges, it 

should be coded as 88101, and the next Annual Network Plan should describe that change. 
The monitor that NHDES specifically identified as not appropriate for NAAQS comparison since 

2011 follow (site will be coded as 88502, as eligible to be repmted for AQI purposes, but not 

NAAQS compliance) is located at the Londonderry- Moose Hill School site (33-015-0018). 

Regarding future annual monitoring network plans, please identify the PM2.s continuous FEMs 

and any pre-FEM continuous monitors that are in use or planned for use in your network. 

Consistent with 40 CFR Part 58.11 (e), your plan should clearly identify the PM2.s continuous 

monitors in your network, and whether they have already been approved (pursuant to this or 

other approval letter) to be excluded from comparison to the NAAQS. To maintain such 

waivers, each subsequent Annual Network Plan must detail the PM2.s continuous FEMs, where 

they are located, and the monitoring objectives that they will support (i.e., eligible for use with 

the NAAQS and/or AQI) for the corning year. An assessment of the most recent three years of 

data for all collocated FRM/continuous FEM monitors must be included in each subsequent 

annual plan where the monitoring agency wishes to continue to exclude such data from 

comparison to the NAAQS. Since this letter only addresses the exclusion of data for a single 

monitor, this issue should be reassessed next year. 

With this letter, I am approving the NHDES 2014/2015 Annual Ambient Air Network Review 

and Plan. We will work with our headquarters offices to address the portions of the plan which 

would require their attention, most notably monitoring associated with NCORE, IMPROVE and 

PAMS. Per 40 CFR Part 58.11 (c), your NCORE, IMPROVE and P AMS network design and 

changes are subject to the approval of the Administrator. We have forwarded your network plan 

to EPA headqumters for their review and approval of these sections. 

EPA-NE appreciates your partnership in conducting ambient air monitoring. We look forward to 

working with you to continuously improve air quality in New Hampshire. If you have m1y 

questions or comments regarding this network review, please contact Alan VanArsdale (617) 

918-8610 or Bob Jud e at (617) 918-8387. 

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obGI:t a · 1 d, irector -~ .. 

Office ofE ironmental Meas rement and Evaluation 

EPA New ·ngland 

cc: Mike Fitzgerald, NI-l DES 

Jeffrey Underhill, NI-l DES 

Kendall Perkins, NI-l DES