UNITED STATESENVIRONMENTAL PROTECTION AGENCY New England Regional Laboratory 11 Technology Drive, North Chelmsford, Massachusetts 01863

October 10,2014
Craig Wright, Director AirResources Division Department ofEnvironmental Services 29 Hazen Drive Concord, NH 03301

DearMr. Wright:
Thank you for your submission ofthe New Hampshire AmbientAirMonitoring Program 2014/2015 Annual Network Review andPlan, which was received by EPA in final form on September 2, 2014. We appreciate that you have addressed most ofthe comments thatEPA providedto you on July 18, 2014. EPANew Englandhas evaluated your plan and finds that yourplan meets the minimum requirements of40 CFRPart 58.
We acknowledge the following modifications and future plans which you outlined in your plan (in italics):
Network Modifications lvfodijications consisted of completing andshutting down specialmonitors associated with the WoodSmoke Study, including all equipment at the StickneyAvenue site in Concord, andthe CO andS02 monitors in Keene. DESalso initiatedspecialproject monitoring in Portsmouth in response to numerous PMcomplaints concerning an industrial facility near lvfarket Street. This monitoringbegan in September of 2013 and
was completed in May of2014.
Future Plans lvfove the PhotochemicalAssessment}vfonitoring Station (PAMS) from Gilson Road in Nashua to the Moose HillSchoolNCOREsite in Londonderry. DES plans to relocate PAMSmonitoringfi'om the Gilson Road, Nashua station to the Moose Hill School, LondonderryNCORE station atthe conclusion of the 2014 ozone season. With EPA's approval of this move, DES intends tofully become operational for PAMSmonitoring in Londonderry for the 2015 ozone season. The Gilson Roadlocation will continue to monitor ozone andmeteorology during the near-term, howeverDESmay explore its relocation to a Nashua high schoolathletic complex.
Shutdown PM2.5 samplingat Crown Street in Nashua. DES intends to shutdown PM2.5 monitoringat Crown Street in Nashua on December 31, 2014.Shutdown PM2.5 sampling atExchange Street in Pembroke. DES intends to shut down PM2.5 monitoringat the Pembroke station on December 31, 2014. DESwill relocate the PQ200 collocation sampling to the Londonderry station.
NHDESproposes to use the FRlvf(PQ200) atthe Londonderrysite as the primGJy monitor tor Plvh.5 andthat the FEA1data shouldbe excludedtorNAAOS comparisons.
Per the changes listed above, all network modifications that involve the discontinued operation or movement ofsites are subject to EPA approval, even ifthe remaining network meets EPA's minimum requirements. In light ofpossible future state and federal budgetrestrictions, we encourage NewHampshire Department ofEnvironmental Services (NH DES) to consider further cost saving measures and discuss those opportunities withthe EPA prior to implementation.
On Aprill7, 2014, EPAproposed its Data Requirements Rule for the 1-HourSulfur Dioxide Primary National Ambient Air Quality Standard (NAAQS) detailing monitoring and modelling guidance for implementing the S02 standard. An outcome ofthat 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 CFRPart 58.ll(e),EPA is approving the exclusion ofPM2.s continuous data, for NAAQS purposes, from the continuous PM2.s monitor atthe Londonderry NCORE site. As youknow, this included your analysis ofcontinuous 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 ofthe Londondeny Moose Hill NCORE stationbecause this monitor does not have acceptable data comparability with the collocated FRM monitor. In the
case ofthe Londonderry Moose Hill station, the analysis shows that the performance is outside ofthe 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 ofthis 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 meetrequisite 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 shouldbe reported using parameter code of88502, indicating that these data are appropriate for AQI use, butnot for comparison to the NAAQS. Should you determine these data are not ofacceptable quality for eitherAQI 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 comparisonto the NAAQS.) Ifyou 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 monitorthat 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 anypre-FEM continuous monitors that are in use or planned for use inyournetwork. Consistent with 40 CFRPart 58.11(e), yourplan should clearly identify the PM2.s continuous monitors in yournetwork, and whetherthey have already been approved (pursuantto this or other approval letter) to be excluded from comparisonto 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 ofthe 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 comparisonto the NAAQS. Since this letter only addresses the exclusion ofdata for a single monitor, this issue should be reassessed nextyear. Withthis letter, I am approving the NHDES 2014/2015 Annual AmbientAirNetwork Review and Plan. We will work with our headquarters offices to address the portions ofthe planwhich would require their attention, most notably monitoring associated with NCORE, IMPROVE and PAMS. Per 40 CFR Part 58.11 (c), yourNCORE, IMPROVE and PAMS network design and changes are subject to the approval ofthe Administrator. We have forwarded your network plan to EPA headqumters for their review and approval ofthese sections.
EPA-NE appreciates your partnership in conducting ambient air monitoring. We look forward to working with youto continuously improve air quality in NewHampshire. Ifyouhave m1y questions or comments regarding this networkreview, please contact Alan VanArsdale (617) 918-8610 orBob Jud e at (617) 918-8387.

/ / / '

# -~ obGI:t a · 1 d, irector

.. Office ofE ironmental Meas rement and Evaluation EPANew ·ngland

cc: Mike Fitzgerald, NI-l DES Jeffrey Underhill, NI-l DES Kendall Perkins, NI-l DES