July 23 , 2012

Reply to Attn Of: OEA

- 095

MEMORANDUM

SUBJECT: Eugene

- Springfield PM 10 NAAQS and LMP Determination

FROM: Chris Hall ECU Air Data Analyst , OEA

TO: Kristin Hall STAPU Air Planning Team, OAWT

Introduction At the request of the Air Planning T eam in OAWT, I have conducted both a NAAQS attainment determination and a Limited Maintenance Plan (LMP) review for the Eugene

- Springfield PM 10 Non

- attainment Area ( NAA )

. Based on a statistical analysis th e Eu gene

- Springfield PM 10 NAA meets the attainment and design value criteria necessary to qualify for the Limited Maintenance Plan option i

.
Background On January 13, 2012, the State (ODEQ) submitted to EPA for approval the Eugene

- Springfield PM 10 LMP and requested that EPA redesignate the Eugene

- Springfield NAA to attainment for the PM 10 NAAQS. To qualify for the LMP option

, the NAA must be attaining the PM 10 NAAQS

, and in the most simplistic case, the a verage Design Value ( A DV) must be below the LMP defined design value ( DV) for both the 24

- hr and annual ii PM 10 standards iii

.

U til izing data through December 31, 20 08

, ODEQ show ed that the NAA had been attaining the PM 10 NAAQS and that the 24

- hr and annual A DV s were below the 24

- hr and annual LMP defined DV s. The 2001 LMP option memo de fines that the most recent five y ears of data needs to be used to determine LMP eligibility . Therefore the purpose of this review is to determine if the Eugene

- Springfield PM 10 NAA attains the PM 10 NAAQS for 2009

- 11 and to determine if the LMP option is an appropriate approach based on a DV analysis for 2007

- 11

.

Data Quality Review A data quality review of the most recent two years of data has also been performed and has been fo und to meet the criteria specified in 40 CFR part 58 for bias, and performing the required number of verifications and audits. Bias results are based on flow rate verifications and werefound to be less than 1% for 2007

- 11 which greatly exceed stated qual ity objectives. Based on these results

, the PM 10 data is of appropriate quality and is usable for determining LMP eligibility for the 2007

- 11 timeframe.

Data Completeness In the 3 rd quarter of 2009

, data completeness was 73% with 7 missing sample days for the Key Bank PM 10 site. For showing NAAQS attainment

, EPA regulation iv allows for substitution for quarters with less than 75% data completeness if approved by the Regional Administrator and in

acco rdance with EPA guidance v . For this LMP review

, data substitution was utilized to determine a 24

- hr and annual ADV to compare to the respective LMP defined DVs.

The optimal source for data substitution is from a collocated monitor

, but as a collocated P M 10 monitor has not been sited at Key Bank

, this is not an available substitution option. The second option is to substitute the highest recorded value from the same quarter for the missing data points. This high substitution value can be from any of th e years within the data set of interest (i.e., 3 rd quarter 2007, 2008, 2009, 2010, or 2011).

For 3 rd quarter 2009

, the highest substitute value found was 58 μ g/m 3

, which was recorded on September 6, 2011. This value of 58 μ g/m 3 will be s ubstitut ed for each of the 7 missing days in 2009, in computing both the expected number of exceedances ( EE ) for 2009

- 11 and the LMP DV

.
NAAQS Attainment Because the annual PM 10 standard was revoked effective December 18, 2006, this document discusses only attainment of the 24

- hour PM 10 standard. To show attainment for the 24

- hour PM 10 NAAQS

, the 3 most recent years of data must be below 1.0 Expected number of Exceedances (EE) p er the criteria estab lished in Appendix K to 40 CFR p art 50. Appendix K also requires three consecutive years of complete data to make an affirmative attainment determination. A year is deemed complete if each of the four quarters has at least 75% data

c omple teness. For calendar years 2009 through 2011

, the Key Bank site met this completeness requirement with the exception of 3 rd quarter 2009, which only had a completeness rate of 73%. As no exceed a nces of the 24

- hour standard were recorded in the 2009

- 11 timeframe

, the EE for Eugene

- Springfield is zero. This is also true when performing data substitution for the seven missing run days in 3 rd quarter 2009, where substitut ing the high value of 58 μ g/m 3 from September 6, 2011, still yields an EE of zero

.

LMP Design Value Computation Results

24 Hour PM 10 NAAQS There are multiple DV determination methods provided in the EPA ‘ PM10 SIP Development Guideline ’, EPA

- 450/2

- 86

- 001, June 1987 . Each method has value and drawbacks individually

, and as a group can provide convincing evidence that an area is either meeting or exceeding the 24

- hr LMP defined DV

. For purposes of this analysis

, the Upper 10% Tail Distribution method and the Tabular Estimation methods are discussed. The advantage of the Upper 10% Tail Distribution method is that this statistical approach only takes into account the high concentration data values which are the most important when determining a DV. The advantageof the Tabular Estimation method is that it does not require any data computations. Both method s allow for data substitution which is necessary for incomplete data sets.

The DV estimation method s below utilized data from the full five years rather than an overall average of the running 3

- yr DV averaging periods. This provides a larger and more robust data
set for computing DV statistics

. To qualify for the LMP option the 24

- hr ADV must be below the 98 μ g/m 3 , and the annual ADV must be below the 40 μ g/m 3 i

. Upper 10% Tail Distributi on This method is a straight statistical equation derived by OAQPS and only uses the high 10% of data values.

Equation 1 : A DV = X 90 + 3.612 (U 90 - X 90 ) Where X 90 = 90 th percentile value = value 54 = 28.0 μ g/m 3
U 90 = mean of the upper 10% of values = 42.9 μ g/m 3 Total Data points = 537 including substituted values for missing days

Solving equation 1 with the provided values yields a n A DV of 82 μ g/m 3

.

Method 4

– Tab ular Estimation Method The T a bular Estimation method is simply a table which tells you which data value to use as your DV and is dependent on the total number of data values in your data set

.

No. of Daily Values Rank of Upper Bound Rank of Lower Bound Value Used for LMP DV
≤ 347

- 1 Highest Value 348 to 695 1 2 Second Highest Value 696 to 1042 2 3 Third Highest Value 1043 to 1390 3 4 Fourth Highest Value

The 2007

- 2011 PM 10 data set for Eugene

- Springfield contains 53 7 data points including substituted points

. Based on the above table t he LMP DV value would be the second highest value or 78 μ g/m 3 (see table below)

.Annual PM 10 NAAQS The A DV for the annual standard is simply the arithmetic mean of all the daily values within the data set. For the 2007

- 11 timeframe the average concentration is 15 μ g/m 3 for Eugene

Springfield , which is well below the LMP defined DV of 40 μ g/m 3 . Substituting 58 μ g/m 3 for the 7 missing sample days for 2009 still yields an A DV o f 15 μ g/m 3

. Summary In summary each computational method described above show s that the 2007

- 11 PM 10 A DVs for the Eugene

- Springfield NAA are well below the annual and 24

- hr LMP defined DVs

. Using the most conservative approach

, the 24

- hour A DV was found to be 82 ug/m 3

, and the annual A DV was found to be 15 μ g/m 3

. Based on the data quality and statistical result s , the Eugene

Springfield NAA meets the attainment and design value criteria to qualify for the LMP option

.

i ‘ LMP Option for Moderate PM 10 Non

- attainment Areas ’, August 9, 2001, as approved by Lydia Wegman designee,
ii Subsequent to the issuance of the 2001 LMP O ption memo, EPA revoked the annual PM10 standard. 71 Fed. Reg. 61,114 (Oct. 17, 2006).
iii An area may still qualify for the LMP option if it cannot meet these basic CDV criteria by meeting the site

specific CDV. Determination of the site

- specific CDVs was not necessary for this LMP analysis.
iv See 40 CFR Part 50, Appendix K, §2.3(b)

v In this case we follow the EPA ‘ Guideline on Exceptions to Data Requirements for Determining Attainment of Particulate Matter Sta ndards ’ EPA 450/4

- 87/005, April 1987. Site Monitor ID Collection Date 24-hr Avg Rank Key Bank 41-039-0058-81102-1 03-Feb-2009 80 1 Key Bank 41-039-0058-81102-1 05-Feb-2007 78 2 Key Bank 41-039-0058-81102-1 02-Feb-2007 69 3 Key Bank 41-039-0058-81102-1 06-Sep-2011 58 4 Key Bank 41-039-0058-81102-1 18-Jul-2009 58 4 Key Bank 41-039-0058-81102-1 21-Jul-2009 58 4 Key Bank 41-039-0058-81102-1 24-Jul-2009 58 4 Key Bank 41-039-0058-81102-1 27-Jul-2009 58 4 Key Bank 41-039-0058-81102-1 05-Aug-2009 58 4 Key Bank 41-039-0058-81102-1 11-Aug-2009 58 4 Key Bank 41-039-0058-81102-1 28-Sep-2009 58 4 Key Bank 41-039-0058-81102-1 15-Sep-2008 56 12 Key Bank 41-039-0058-81102-1 22-Jan-2009 55 13 Key Bank 41-039-0058-81102-1 12-Dec-2009 49 14