From: Clean Air Fairbanks < cleanairfairbanks@gmail.com >

Sent: Thursday, October 16, 2014 8:53 PM To: Green, Gregory; Powers, Tom; Stewart, Lori; Wood, Gil; McCabe, Janet Cc: Atkinson, Emily; Browne, Cynthia Subject: Problems with monitoring, letter previously sent to Region 10 EPA

Dear Ms. McCabe, Ms. Stewart, Mr. Green, Mr. Powers, and Mr. Wood:

To follow

- up on the discussion of monitoring in our meeting Tuesday, I wanted to share with you a recent letter I sent to Region 10. The letter raises questions about the apparent shell game that has been played with the monitoring network and PM2.5 data collection in Fairbanks.

My point in forwarding this letter to you is to make very clear that a strong NSPS is needed. Monitoring is not a panacea. NSPS standards designed to protect health and prevent harm are needed now, not five years from now.

Thank you,

Sylvia Schultz

-- cleanairfairbanks@gmail.com http://cleanairfairbanks.wordpress.com

Polluting is a choice. Breathing is not.October 2 , 2014

Dennis McLerran, EPA Regional Administrator ( mclerran.dennis@epa.gov) Kate Kelly, Director, Office of Air Waste and Toxics ( kelly.kate@epa.gov) US EPA Region 10 1200 Sixth Avenue, Suite 900 Seattle
, WA 98101

- 3140

Re: Request for EPA air monitoring and data reconsideration in the FNSB PM 2.5 nonattainment area

Dear Regional Administrator McLerran and Director Kelly,

The Regional Administrator of the Environmental Prot ection Agency (EPA) should promptly establish and operate air monitoring in the Fairbanks North Star Borough (FNSB) PM2.5 nonattainment area to meet monitoring objectives, network design criteria, and sampling frequency requirements under the Clean Air Act

.

T he Regional Administrator should also review all available data to determine whether North Pole Elementary can be designated State and Local Air Monitoring Stations ( SLAMS) from 2011 to 2013, whether North Pole Fire has already collected sufficient data to be designated SLAMS beginning in 2014, and if design values can be recalculate d based on these stations and using continuous monitor data. Monitor ing from the area of expec ted maximum concentration needs
to drive State Implementation Plan ( SIP ) targets and controls.

In addition, f ull site data record s , including from continuous monitors, should be made available

on EPA AirData htt p://www.epa.gov/airdata to support required monitoring objectives that include informing the public, compliance accountability
, and health studies

.
State and local agencies are playing a n air monitor shell game to hide data and hinder requirements to control PM2.5 pollution . In 2012, the FNSB PM2.5 nonattainment area recorded the nation’s highest 98 th percentile 24

- hour PM2.5

. Downtown Fairbanks PM2.5 concentrations are on par with the most air polluted areas in the nation such as San Joaquin Valley, C A , Salt Lake City, or Logan, UT . However, 98 th percentile 24

- hour PM2.5 in local neighborhoods in areas of expected maximum concentration have been three times higher than downtown Fairbanks

. Meeting PM2.5 attainment in these most impacted neighborhoods

re quires expanding the focus beyond the downtown Fairbanks monitor. The public has been left uninformed about the seriousness of the exceedances and the grave risk to health. F ederal regulators have been misled to think the problem is less serious and are an ticipating a target for reduction far smaller than what is actually required

.
The most significant monitoring failure has been that state and local agencies have not located

a State and Local Air Monitoring Stations ( SLAMS) in an area representing a neigh borhood (or higher ) scale of expected maximum PM2.5 concentration

.Request for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 2

Other failures compound the problem. The current SLAMS in downtown Fairbanks fails to meet monitoring network objectives, SLAMS design criteria, or operating frequency requirements. In 2013, a neighborhood station that had operated for six years and report ed high concentrations was shut down immediately after the public and EPA raised inquiries as to why its data were not considered in nonattainment decisions. Most recently, North Pole Fire, a station that in 2012 record ed the highest PM2.5 concentrations i n the nonattai nment area ( and the nation )
, will be downgraded to represent an area of approximately 100 meters, disqualifying its data from nonattainment decisions. The National Core mu ltipollutant monitoring station ( NCore ) in downtown Fairbanks has not m et sampling frequency requirements for NCore or SLAMS, but has now been proposed to be designated the SLAMS. Sampling frequency has not met minimum requirements , and c ontinuous monitor data ha s not been considered in nonattainment decisions or routinely av ailable to the public. The current air monitoring program relies on inadequate data collected from the incorrect location, misdirecting every element of protection for public health intended under the Clean Air Act.

State and local agencies have shown the mselves incapable or unwilling to meet federal air monitoring network requirements. Inadequate sampling, improper monitor placement, closure of a key monitoring station, and downgrading the monitor in the area of expected maximum concentration hide the severity of the PM2.5 pollution and prevent essential remedies. A SIP based on inadequate data will be insufficient to protect the health of residents in the most severely polluted areas

. This will be grounds to reject the SIP

. A series of state and local agency decisions undermining monitor data collection shows probable intent to subvert Clean Air Act requirements and responsibilities

.

EPA extended the deadline for submittal of the SIP to Dec. 31, 2014 . Y et, the Regional Administrator should be aware that the State of Alaska has not established statutes or regulations to support SIP enforcement or controls. The comment period on draft regulations ended Jan. 24, 2014 . O ver 900 public comments were received by the A laska Department of Environmenta l Conservation (ADEC). The agency ’s website gives this update: “ Due to the number of comments, the Department does not expect to have the response to comments completed until after June 2014. ” ( Information on A DEC's Proposed Regulations ) June has come and gone with no sign of the final regulations.

On October 1, 2014, ADEC planned to decommission the State Office Building station that operated since 1972 and has been the designated SLAMS. ADEC has requested EPA approval to close this station in downtown Fairbanks and relocate it to a different site in downtown Fairbanks. EPA should use its authority under 40 CFR § 58.14(c) to deny this request. Instead, the Regional Administrator should designate North Pole Elementary as SLAMS from 2011 to 2013 and North Pole Fire Station #3 as S LAMS beginning in 2014

. Data, including continuous Federal Equivalent Method (FEM) monitoring, from both sites are eligible for comparison to the National Ambient Air Quality Standards (NAAQS) for PM2.5 per 40 CFR §50 Appendix D 3(a) and 40 CFR § 58.11(e) . Expanding the combined site data record using FEM as well as Federal Reference Method ( FRM ) monitors will likely meet data completeness requirements under 40Request for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 3

CFR § 50 Appendix N 4.1 and 4.2

. Further, the Regional Administration should take over operation of North Pole Fire to en sure operation going forward meets SLAMS requirements

.

T he EPA Regional Administrator is authorized under 40 CFR § 58.60 to locate and ope rate an ambient air monitoring site if the state or local agency fails to locate, or schedule to be located, when necessary in his judgment to meet monitoring network objectives and design criteria specified in 40 CFR § 58 Appendix D

. North Pole Fire meets federal requirements for a SLAMS to be located in an area of expected maximum concentration. 40 CFR § 58 Appendix D 4.7.1(1)

. O peration of a SLAMS site in this neighborhood is necessary to ensure adequate data collection to “s upport compliance with ambient air quality standards and emissions strategy development .” 40 CFR § 58 Appendix D 1.1(b)

. It is not reasonable t o wait for state and local agencies to get it right when the record of im proper air monitoring shows intent to get it
wrong.

T he EPA Regional Administrator should immediately establish year

- round PM2.5 sampling (at least 1

- in

- 3 day) at the North Pole Fire SLAMS t o ensure adequate creditable samples from the neighborhood of expected maximum concentration for NAAQS comparison

.

EPA should also use continuous FEM monitoring in addition to FRM monitors

. 1

- in

- 3 day sampling cannot meet required monitoring network objectives needed to address extreme air pollution. 40 CFR § 58 Appendix D 1.1.1

. C ontinuous FEM monitoring eliminates bias caused by
gap s in samp ling, improves public reporting, strengthens reliability of data comparisons against the NAAQS, supports development of the attainment plan, and allows more robust air pollution research studies

. Anchorage and Juneau ( neither are PM2.5 nonattainme nt areas ) and many
areas designated nonattainment under the 2006 PM2.5 standard rely on continuous FEM monitoring at their SLAMS :

San Joaquin Valley, CA
, Liberty

- Clairton, PA
, Los Angeles, CA
, Harrisburg

- Lebanon

Carlisle

- York, PA
, Lancaster, PA , Cleveland

- Akron

- Lorain, OH , Salt Lake City, UT
, Philadelphia

- Wilmington, PA

- NJ

- DE , Johnstown, PA
, Seattle

- Tacoma, WA , Allentown, PA
, San Francisco Bay Area, CA , Logan, UT

- ID , New York, NY

- NJ

- CT , Canton

- Massillon, OH
, Detroit

- Ann Arbor, MI
, Provo, UT , Pitts burgh

- Beaver Valley, PA
, Yuba City

- Marysville, CA , Detroit

- Ann Arbor, MI
, Steubenville

- Weirton, OH

- WV , and Birmingham, AL

But not Fairbanks. In 2012 and 2013, t he FNSB nonattainment area had higher 98 th percentile daily values than any of these communitie s. It is essential to apply the power and timeliness of continuous FEM monitoring to meet the serious challenge of PM2.5 in the FNSB nonattainment

area.

Action by the Regional Administrator is needed urgently to stop the shell game

. When a site shows high values, FNSB shuts it down or downgrades it to prevent comparison to the NAAQS. FNSB and ADEC have not included c ontinuous FEM monitors in NAAQS considerations even though no evidence of performance problems has been included in the annual plan

. FNSB shut down the North Pole Elementary station apparently to keep its high concentrations from beingRequest for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 4

considered. T he state downgraded North Pole Fire Station #3 to apparently disqualify its data from full NAAQS comparison. FNSB could shut do wn North Pole Fire without notice or EPA approval just like North Pole Elementary. FNSB removed the RAMS from Watershed School without notice in 2013 even though it served an essential objective of alerting the school, parents , and residents of repeated ho t zone episodes in that neighborhood. Watershed School Update

. In the last several days, FNSB put a Relocatable Air Monitoring System (RAMS) trailer calle d “North Pole Water” on the Old Richardson H ighway near Tanana Drive

. Will this be the station used to “ replace ” North Pole Fire?

EPA needs to do more than stop shut downs and downgrades of essential monitors. EPA needs
to take over to ensure sampling frequency protocols are followed this coming winter

. Inadequate sampling limit s data analysis needed to protect health and meet attainment

. EPA also needs to recalculate daily and annual nonattainment design values using continuous FEM monitor data and to make continuous FEM data available on Air Data . It is time to designate monitors from the neighborhood of expected maximum concentration as SLAMS and use these data, not that from downtown Fairbanks, to drive SIP targets and controls an d protect health

.
EPA has the responsibility and authority to stop the game.

We have attached a report to substantiate the errors and violations. Thank you for your attention to the problem of air quality monitoring in the FNSB PM2.5 nonattainment area. A solution depends on your prompt intervention.

Sincerely,

Sylvia Schultz PM2.5 Program Director cleanairfairbanks@gmail.com

Attachment

CC: Governor Sean Parnell (governor@alaska.gov) Mayor Luke Hopkins (mayor@fnsb.us) Commissioner Larry Hartig, ADEC (larry.hartig@alaska.gov) Director Alice Edwards, ADEC Div of Air Quality (alice.edwards@alaska.gov) Lucy Edmondson, EPA Region 10 (edmondson.lucy@epa.gov) EPA Inspector General Hotline (OIG_Hotline@e pa.gov) Eric Jorgensen, Esq, Earthjustice (ericj@earthjustice.org) Colin O’Brien, Esq, Earthjustice (cobrien@earthjustice.org) Vicki Clark, Esq, Trustees for Alaska (vclark@trustees.org) Jonathan Evans, Esq, Center for Biological Diversity (jevans@biologic aldiversity.org) Jeremy Nichols, WildEarth Guardians (jnichols@wildearthguardians.org)Request for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 5

Tomás Carbonell, Esq, Environmental Defense Fund (tcarbonell@edf.org) Joe Minott, Esq, Clean Air Council (joe_minott@cleanair.org) Brian Moench, MD, Utah Physicians for a Healthy Environment (drmoench@yahoo.com) C. Arden Pope III, PhD, Brigham Young University (cap3@byu.edu) Pam Miller, Alaska Community Action on Toxics (pamela@akaction.org) Patrice Lee, Citizens for Clean Air (patricelee3294@gmail.com)

### Errors and Violations Supporting EPA Operation of Air Monitoring and

Reassessment of Existing SLAMS Data and Locations in the

FNSB PM2.5 Nonattainment Area

Sylvia Schultz, Clean Air Fairbanks cleanairfairbanks@gmail.com http://cleanairfairbanks.wordpress.com

October 1, 2014

Request 1 : The Regional Administrator of the Environmental Protection Agency (EPA) should promptly establish and operate air monitoring in the Fairbanks North Star Borough (FNSB) PM2.5 nonattainment area to meet monitoring objectives, network design crit eria, and sampling frequency requirements of the Clean Air Act.

Request 2 : EPA should review all available data to determine whether North Pole Elementary can be designated State and Local Air Monitoring Stations ( SLAMS) from 2011 to 2013, whether North Pole Fire has already collected sufficient data to be designated SLAMS beginning in 2014, and if design values can be recalculated based on these stations and using continuous monitor data

.
Request 3: Full site data record s, including from continuous monitors, should be made available on AirData http://www.epa.gov/airdata to support required monitoring objectives that include informing the public, compliance accountability, and he alth studies.

Evidence of e rrors and violations supporting th ese request s :

1. North Pole Fire Station #3 has shown the highest concentrations in the nonattainment area ( and the nation ). At least one SLAMS is required to be located in the “expected maximum concentration

. ” 2. Current and proposed SLAMS in downtown Fairbanks do not meet “expected maximum concentration” requirement. ADEC represented it met this requirement when it has not

. 3. Locating the only SLAMS in downtown Fairbanks, not an area of expected maximum concentration, does not meet required Clean Air Act monitoring network objectives and PM2.5 design criteria

. 4. In 2013, FNSB pe rmanently shut down North Pole Elementary station
, operated since 2008
, without warning or explanation just one day after a resident questioned why it was not the SLAMS. 5. Solely due to an unidentified obstacle, ADEC’s proposed 2014

- 2015 monitoring network plan disqualified North Pole Fire as a neighborhood scale site

. 6. Contrary to air monitoring data, ADEC is downgrading North Pole Fire from “Neighborhood” to “Micro

- scale” to avoid comparison to NAAQS.Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 2

7. FNSB will operate the North Pole Fire FRM from October through March only, limiting comparison to NAAQS. 8. ADEC mis identified the location and other identifiers for North Pole Fire. 9. FNS B has not operated the FNSB Administration Building station to meet sampling frequency requirements for SLAMS or NCore stations. ADEC has improperly proposed this site as a SLAMS

. 10. In the annual monitoring network plan , ADEC did no t include a performance assessment of monitors that should not be compared to the NAAQS. Thus, continuous FEM monitor data may not be excluded from NAAQS consideration

. 11. If EPA does not step in to operate North Pole Fire as the SLAMS, nothing prevents North Pole Fire from being shut down without notice or ensures data completeness criteria will meet standards for NAAQS comparisons for PM2.5 attainment evaluations

.


### Documen tation :

1. North Pole Fire Station #3 has shown the highest concentrations in the nonattainment area (and the nation). Federal regulation requires at least one SLAMS to be located in the area of “expected maximum concentration.”

State and Local Air Monit oring Stations ( SLAMS) make up the ambient air quality monitoring sites that are primarily needed for National Ambient Air Quality Standards (NAAQS) comparisons for nonattainment decisions. At least one SLAMS in a nonattainment area must meet the “expected maximum concentration” monitoring objective:

“At least one monitoring station is to be sited at neighborhood or larger scale in an area of expected maximum concentration.” 40 CFR § 58 Appendix D 4.7.1(1)

.
In 2012, North Pole Fire recorded the highest PM2.5 98 th percentile daily average concentration in the FNSB PM2.5 nonattainment area: 158.4 μg/m 3 . ( Table 1

. ) North Pole Elementary , a station with the area’s second highest 98 th percentile daily average, recorded: 68.1

. By contrast, t he higher of the two downtown Fairbanks site s recorded a 98 th percentile daily value of 50 in 2012

. North Pole Fire was more than three times higher than downtown Fairbanks in 2012 and higher than any nonattainment area in the nation

.

T he annual average reported from North Pole Fire i n 2012 was 16.8 , also highest in the nonattainment area . ( Table 1. )Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 3

Table 1

. FNSB FRM Monitors, 20 12 PM2.5 Fairbanks State

Office Building FNSB Admin

Building North Pole Elem

School North Pole Fire

Station #3 Site ID 02

- 090

- 0010 02

- 090

- 0034 02

- 090

- 0033 02

- 090

- 0035 Annual Average 10.7 11.3 10.2 16.8 24

- hr Ave (98 th Percentile) 49.6 50 68.1 158.4
EPA Air Trends, PM2.5 Detailed Information 2011

- 2013 , accessed 10 / 1 /2014

.

North Pole Fire has regularly recorded the high est daily PM2.5 concentrations since it began operation in 2012 . ( Figure 1

. ) No other station in the nonattainment area has shown as

c onsistently elevated PM2.5 concentrations as North Pole Fire. This trend is not limited to 2012; it persists across seasons and across years. Due to thi s persistent trend, North Pole Fire meets the SLAMS monitoring network objective for expected highest concentration.

Figure 1 . FNS B Maximum Daily PM2.5 2010

- 2014 ( EPA AirData www.epa.gov/airdata Local Conditions

- 88101, 10/1/2014 )

In addition, North Pole Fire best meets the monitoring objective to locate monitor sites “to determine the highest concentrations expected to occur in the area covered by the network.” 40 CFR § 58 Appendix D 1.1.1

. No other current site comes close to meeting this objective.

Clearly, to capture the area of “ expected maximum concentration ,” the SLAMS site must be at North Pole Fire.

2. Current and proposed SLAMS in downtown Fairbanks do not meet “expected maximum concentration ” requirement

. ADEC represented it met this requirement when it has not.

Because the downtown station s are not lo cated in an area of PM2.5 expected maximum concentration, neither is qualified to be the only SLAMS station

.

0.0 20.0 40.0 60.0 80.0 100.0 120.0 140.0 160.0 180.0
μg/m 3 PM2.5 

# FNSB Maximum Daily PM2.5 2010

- 2014

02-090-0010
02-090-0033
02-090-0034
02-090-0035

EPA AirData www.epa.gov/airdata Local Conditions

88101, 10/1/2014Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 4

The state mis represented on its Appendix D Network Evaluation Form that at least one SLAMS for each area was sited in an area of expected maximum concentration. ADEC Air Quality Monitoring Network Plan 2014

- 20 15 , p 50

. North Pole Fire is in the are a of expected maximum concentration but is not a SLAMS, so this criterion was not met.

ADEC proposed the SLAMS to represent downtown Fairbanks

. “DEC recognizes that the SOB PM2.5 monitor is the violating monitor in the Fairbanks PM2.5 non

- attainment area, but believes that the NCore site can be used as a representative site for the Fairbanks downtown area.” ADEC Air Quality Monitoring Network Pl an 2014

- 2015, p 36

. A SLAMS must meet monitoring network objectives and PM2.5 network design criteria including the expected highest concentration; sites in downtown Fairbanks do not meet these objectives or criteria

.

A State Implementation Plan ( SIP ) targeting reductions to meet attainment in downtown Fairbanks will not be adequate to protect health in the neighborhood of expected maximum concentration.

3

. Locating the only SLAMS in downtown Fairbanks, not an area of expected maximum concentration, d oes not meet required Clean Air Act monitoring network objectives and PM2.5 design criteria.

Required monitoring network objectives include determining the neighborhood of expected highest concentration and locating stations to represent the proper scale for the pollutant and expected sources. 40 CFR § 58 Appendix D 1

. PM2.5 design criteria require at least one SLAMS be located in a neighborhood area of e xpected maximum concentration

. 40 CFR § 58 Appendix D 4.7.1(1)

.

4

. In 2013, FNSB permanently shut down the North Pole Elementary station just one day after a resident questioned why it was not the SLAMS. In operation since 2008, the closure came with no warning or explanation

.

On March 28, 2013, a Fairbanks resident called Lucy Edmondson , EPA Region 10 , to ask why EPA did not count data from North Pole Elementary although it had been in operation since 2008. Ms. Edmondson then consulted EPA’s data team and “in house data” then contacted the Borough by phone. Ms. Edmondson followed

- up with the Fair banks resident that the Borough’s
response was that North Pole Elementary was a “winter

- only site,” but they had actually been running it year

- round. Ms. Edmondson relayed to the resident that the Borough was now working to get the year a round data into the EPA system and that might make North Pole Elementary qualify to be counted.

The next day, March 29, 2013, was the last day North Pole Elementary recorded a sample

.

There was no notice or explanation given for the shutdown

. The annual monitoring network plan must include “any proposals to remove or move a monitoring station within a period of 18Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 5

months following plan submittal .” 40 CFR § 58.10(b)

. However, state moni toring network plan s did not mention removal of the North Pole Elementary station.

S tate plans from 2010 to 2013 did not describe North Pole Elementary as winter

- only. The plans describe d summer and winter monitoring objectives and plans to evaluate pollutant characteristics

. (If s peciation data was recorded at North Pole Elementary as noted in state network plans from 2010 to 2013, EPA AirData shows no record of it.) According to the last plan before the shutdown:

“ The source contribution to winter time PM2.5 is still being studied. Wood smoke from home heating is currently considered one of the major sources. During the summer months, the main source is wildland fire smoke. The goals of the FNSB Winter Monitoring Project conducted during the winters of 2008

- 09, 2009

- 10, and 2010

- 11 are to evaluate wintertime pollutant characteristics and develop a strategy to reduce the concentration in North Pole. ” ADEC, Alaska’s 2013 Air Monitoring Network Plan, Chapter 3, p 14

. The Borough’s decision to shut down the monitor took one day. It takes months for data to be entered into EPA’s AirData system where it is available to the public

. It took more than a year for us to put together that North Pole Elementary ceased operation just one day after a member of the public asked why the station was not considered by EPA

. Was the timing of the North Pole Elementar y shutdown just a remarkable coincidence? Or did the resident’s phone call trigger a decision on the part of the local agency to prevent EPA from considering North Pole Elementary in nonattainment decisions? The absence of any mention in the annual monitor ing network plan as required prior to decommissioning a site speaks to the decision trigger being the phone call.

What then would have been the impact of comparing North Pole Elementary with NAAQS?

North Pole E lementary consistently had the highest t hree

- year design value of the 98 th percentile daily averages from 2008

- 2010 to 2011

- 2013. A nonattainment determination based on North Pole Elementary rather than the cleaner site in downtown Fairbanks would support substantially different control plans to meet a larger increment of improvement. ( However, North Pole Fire had the highest daily design values fro m Jan. 1, 2012 to June 28, 2014

. )Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 6

Table 2 . FNSB Daily PM2.5 Design Values from FRM monitors , 2008

- 2014 Daily PM2.5 Design Va lues (all FRM) F bks State Office

B ldg (SLAMS) FNSB Admin

Bldg (NCore) North Pole

Elem School North Pole

Fire Station #3

Site ID 02

- 090

- 0010 02

- 090

- 0034 02

- 090

- 0033 02

- 090

- 0035 2008

- 2010 50 47 63 2009

- 2011 47 45 63 2010

- 2012 46 42 47 2011

- 2013 42 45 45 2012 to 6/28/2014 4 3 46 128 EPA Air Trends Design Values 2011

- 2013 and Archives 2008

- 2012 , accessed 10/1 /2014.

Regarding annual averages , North Pole Elementary was not considered in the state’s Dec. 10, 2013 letter to EPA regarding designations of PM2.5 nonattainment areas violating the annual standard. The state submitted the FNSB 2 010

- 2012 annual PM2.5 design value of 11.5 , highest in the state , based on data from the State Office Building in downtown Fairbanks

. The FNSB annual design value of 11.5 is within 5 percent of the annual standard of 12. If all the data from North Pole Ele mentary were considered, would the FNSB nonattainment area exceed the annual PM2.5 standard?

5. Solely d ue to an unidentified obstacle, ADEC’s proposed 2014

- 2015 monitoring network plan disqualified North Pole Fire as a neighborhood scale site

.
According to the Part 58 Appendix E evaluation form in the draft plan, the North Pole Fire monitor inlet does not meet the criterion for distance from sampler to obstacle: “must be at least twice the height that the obstacle protrudes above the probe inlet .“ ADEC Air Quality Mo nitoring Network Plan 2014

- 2015 , p 66

.

This failure to meet the spacing from obstructions appears to explain the site’s downgrade to micro

- scale. Neighborhood sites are not allowed to violate the spacing from obstructions criterion. 40 CFR § 58 Appendix E 4(a)

. Micr o

- scale sites may violate the criterion if structures are unavoidable. Further, m icro

- scale sites are “not eligible for comparison to the annual PM2.5 NAAQS

. ” 40 CFR § 58.30

.
However, the evaluation form does not specify how North Pole Fire does not meet Appendix E. Under “Other Comments” the form states: “Trees to the North are just outside the limits.” On page 29 of the draft plan, “Spacing from Obstruction s (meters)” is “none;” “Height (meters)” is “4;” and “Trees” is “> 30.”

I nformation provided by the state for Appendix E is contradictory and unclear. What is the obstacle that causes North Pole Fire to fail spacing from obstructions criterion ? Could it b e the building? The building is approximately 16 meters away from the monitor inlet. T he inlet is 4 meter high, so the building would have to be 12 meters (40 feet) tall

— it is not that tall. Could the group of trees be the obstacle? F our small deciduous tr ees are at least 20 meters away andSupport for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 7

would have to be 14 meters (46 feet) tall to violate the criterion

— they are not. (Dimensions estimated using Google Earth.) If these are obstructions, they are avoidable : raise the monitor inlet, move the monitor a few m eters farther from the building, or top or remove the trees.

Photographs of North Pole Fire do not show an obstacle. ADEC Alaska’s 2013 Air Monitoring Network Plan, Chapter 3, p 18 . The monitor inlet appears taller than the closest side of the fire station.

The state’s Appendix E evaluation form in the 2014

- 2015 draft plan disqualifies North Pole Fire from neighborhood scale and NAAQS comparison purely on the basis of avoidable yet unidentified obstacles.

6

. Contrary to air monitoring data, ADEC has downgraded North Pole Fire from “Neighborhood” to “Micro

- scale” to avoid c omparison to NAAQS

.
In the current proposed monitoring network plan, ADEC downgrades North Pole Fire to “micro

scale” ADEC Air Quality Monitor ing Network Plan 2014

- 2015, p 29 . (EPA approval is not needed to finalize this downgrade unless the station is a SLAMS.) Regulations prohibit micro

- scale stations from being compared against the annual NAAQS standard. 40 CFR § 58.30

. North Pole Fire has been operated as a “n eighborhood” scale station since beginning operation in 2012

. The downgrade takes effect while FNSB collects additional data :

“ The FNSB is also planning to use their mobile monitoring system (sniffer technology) to further evaluate the North Pole Fire #3 site to determine if the site is a hot spot or truly representative of a larger neighborhood scale. ” p 1.

Plans to gather more data can not explain downgrading the station.

PM2.5 design criteria specify the dimensions for neighborhood and micro

- scale:

Neighborhood scale is used for a “reasonably homogeneous urban sub

- region” with dimensions of “a few kilometers.” 40 CFR § 58 Appendix D 4.7.1(c)(3)

.

Micro

- scale monitoring of stationary sources is used for “large industrial processes” impacting an area of “with dimen sions extending up to approximately 100 meters.” 40 CFR § 58 Appendix D 4.7.1(c)(1)

.
Existing data demonstrate North Pole Fire meets spatial requirement s for neighborhood scale, not micro

- scale. M obile monitoring during the winter of 2013/2014 found North Pole Fire centered in an area of highest PM2.5 concentrations with a 4

- km diameter

. (Figure 2 .)Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 8

Figure 2

. FNSB combined average PM2.5 2013/2014 winter season with spatial scales of 2 kilometers and 100 meters overlay

.
FNSB mobile monitoring was used to identify the location for North Pole Fire in 2012. Data from last winter confirms that North Pole Fire represents PM2.5 con centrations in an area of more than several k ilometers (neighborhood scale ). To downgrade it to represent just 100 meters ( m icro

- scale) disregards FNSB ’s years of mobile data.

The state’s downgrade of North Pole Fire comes after the 2013 plan that refere nced North Pole Fire as potentially more representative. “ Preliminary studies suggest that this new site might be more representative of the North Pole neighborhood scale pollutant levels. ” ADEC Alaska’s 2013 Air Monitoring Network Plan, Chapter 3, p 1 6

. ( Representing North Pole neighborhoods may sound good but is not required. )

P M2.5 design criteria explicitly require at least one SLAMS be located in th e area of expected maximum concentration.

North Pole Fire correctly matches n eighborhood scale PM2.5 monitoring network objectives for representing areas of maximum PM2.5 concentration :

“T o determine PM 2.5 concentrations which are typical over a geographic area having relatively high PM 2.5 concentrations, a neighborhood scale site is more appropriate.Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 9

Such a site would likely be located in a residential or commercial area having a high overall PM 2.5 em ission density but not in the immediate vicinity of any single dominant source.” 40 CFR § 58 Appendix D 1.2(d)

.

“ The most important spatial scale to eff ectively characterize the emissions of particulate matter from both mobile and stationary sources is the neighborhood scale for PM2.5 .” 40 CFR § 58 Appendix D 4.7.1(b)(4)(c)

.
Figure 3 further illustrates the appropriateness of neighborhood scale for this “reasonably homogeneous urban sub

- region” with dimensions of “a few kilometers.” 40 CFR § 58 Appendix D 4.7.1(c)(3)

.

Figure 3 . Map of North Pole Fire showing homogeneous urban sub

- region, note 200 m scale

. (B ing Bird’s Eye 2012) Why would the state downgrade North Pole Fire to micro

- scale? The most likely explanation is
to prevent the data from being compared to the NAAQS annual standard.

“ PM 2.5 measurement data from monitors that are not representative of ar ea

- wide air quality but rather of relatively unique micro

- scale , or localized hot spot, or unique middle

- scale impact sites are not eligible for comparison to the annual PM 2.5 NAAQS

. PM 2.5 measurement data from these monitors are eligible for comparison to the 24

- hour PM 2.5 NAAQS. For example, if a micro

- or middle

- scale PM 2.5 monitoring site is adjacent to a unique dominating local PM 2.5 source, then the PM 2.5 measurement data from such a site would only be eligible for comparison to the 24

- hour PM 2.5 NAAQS. ” 40 CFR § 58.30

. ( bold added)

To ignore evidence that fully qualifies North Pole Fire as a neighborhood scale seems to show a calculated intent to p revent the data from being used in nonattainment considerations

.Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 10

7. FNSB will operate the North Pole Fire FRM from October through March only, limiting comparison to NAAQS.

With no explanation, the FRM at North Pole Fire will be operated October through March only. ADEC Air Quality Monitoring Network Plan 2014

- 2015, p 33 . (EPA approval is not needed to finalize this sampling schedule unless the station is a SLAMS.)

In the 2013 plan, ADEC reported that the North Pole Fire FRM would be operated on a 1

- in

- 3 day schedule throughout the year. ADEC, Alaska’s 2013 Air Monitoring Network Plan, Chapter 3, p 17

. Now , without explanation, it will be operated only in the winter.

Reducing sampling frequency undermine d the relevance of data collected at North Pole Elementary before it was shut down without notice. Inadequate sampling frequency prevents comparison with the NAAQS, especially for the annual standard, reducing the modeled target and efficacy of controls in the SIP.

8

. ADEC misidentified the location and other required information for North Pole Fire.

The state included significant factual errors regarding North Pole Fire’s location and other information in the most recent air quality monitoring network plan draft

. ADEC Air Quality Monitoring Network Plan 2014

- 2015 6/30/2014

. Annual m onitoring network plans are required to include information including the a ddress
, geographical coordinates
, and AQS identification number. 40 CFR § 58.10(b)

. Other than the site name, t he entire row o f T able 3

- 1 ( page 9 ) in ADEC’s draft plan is wrong . (Table 3 .)

Table 3 . Comparison of ADEC draft plan with correct identifiers for North Pole Fire Station #3

Site Name Address Latitude/ Longitude AQS

Identification Draft Plan, p 9 North Pole Fire

Station #3 388 Hurst Rd,

North Pole 64.762973N

- 147.310297W 02

- 090

- 0036

Correct North Pole Fire

Station #3 3288 Hurst Rd,

North Pole 64.762740 N

- 147.310233 W 02

- 090

- 003 5

These factual errors make it difficult for federal regulators or the public to review the station location or evaluate the monitoring objective and spatial scale of representativeness

. EPA AirData uses the coordinates for the North Pole Fire monitor that incorrectly place the monitor in a small group of tr ees . ( Figure 4

. )Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 11

Figure 4

. Green pin on image of North Pole Fire monitor (64.762740,

- 147.310233). Red pin on four small deciduous trees misidentified as monitor location (64.762973,

- 147.310297). (Google e arth 6/19/2012, EPA Do wnload Site Data PM2.5)

Figure 5

. North Pole Fire at 3288 Hurst Rd, North Pole, AK prior to monitor installation. (Google Street View Sept 2011)Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 12

Figure 6

. North Pole Fire at 3288 Hurst Rd, North Pole, AK prior to monitor installation

. (Bing Bird’s Eye 2012)
In addition, ADEC’s map on page 18 of the draft plan ( Figure 7 ) incorrectly locates the station on the northeast corner of the Dawson and Hurst intersection . N orth Pole Fire is actually closer to the northwest corner

.

Figure 7

. Map on page 18 of ADEC draft plan incorrectly locates North Pole Fire in NE corner of intersection . (Google e arth )Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 13

9 . FNSB has not operated the FNSB Administration Building station to meet sampling frequency requirements for SLAMS or NCore stations. ADEC has improperly proposed this site as a SLAMS.

The FNSB Administration Building has been operated as the National Cor e mu ltipollutant monitoring station ( NCore ) for Alaska since 2011. The state has requested EPA approval to designate the NCore as the SLAMS. Both NCore and SLAMS must operate on at least a 1

- in

- 3 day schedule.

NCore: “Manual PM 2.5 samplers at NCore stati ons... must operate on at least a 1

- in

- 3 day sampling frequency.” 40 CFR § 58.12(d)(2)

. “ Continuous monitoring methods are to be used at the NCore sites when available for a pollutant to be measured, as it is important to have data collected over common time periods for integrated analyses. ” 40 CFR §58 Appendix D 2(c)

.

SLAMS: “Required SLAMS stations whose measurements determine the design value for their area and that are within plus or minus 10 percent of the NAAQS; and all required sites where one or more 24

- hour values have exc eeded the NAAQS each year for a consecutive period of at least 3 years are required to maintain at least a 1

- in

- 3 day sampling frequency.” 40 CFR § 58.12(d )(1)(ii)

.

Neither the FNSB Administration Building NCore nor the Fairbanks State Office Building SLAMS met 1

- in

- 3 day sample frequency requirements from 2009 to 2013. (Table 4.)

Table 4 . FNSB NCore and SLAMS sampling frequency, 20 09

- 2013 Sampling Frequency, Year/# Days in Year Minimum Sampling Req. FNSB Admin

Building Fairbanks State

Office Building Site ID 02

- 090

- 0034 02

- 090

- 0010 NCore POC 1 & 2 SLAMS POC 1 & 2 2009/365 121 17 118 2010/365 121 115 119 2011/365 121 112 116 2012/366 122 121 119 2013/365 121 113 112 EPA AirTrends PM2.5 Design Values 2011

- 2013 and PM2.5 Design Values Archives and EPA AirData http://www.epa.gov/airdata/ad_viz_plotval.html , all accessed 10/1 /2014.

ADEC improperly submitted the request to move the downtown SLAMS. EPA may approve requests to move a SLAMS monitor to a nearby location only if the requirements of Appendix D to part 58 “continue to be met.” 40 CFR § 58.14(c) . State and local agency failures to meet Appendix D include those raised previously:Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 14

40 CFR § 58 Appendix D 1.1 Monitoring Network Objectives

– improper SLAMS location and sampling frequency inter fere with all three monitoring objectives. 1.2 Spatial Scales

– not met: goal to locat e monitors to correctly match “most appropriate” spatial scale for monitoring site type, air pollutant, and monitoring objective. 4.7.1(b)(1) expected maximum concent ration

– not met: at least one required monitoring station must be sited at neighborhood or larger scale “ in an area of expected maximum concentration

. ” 4.7.1 (c) (1) and 4.7.1 (c) (3) Micro

- scale and Neighborhood scale

– North Pole Fire does not meet micro

- scale dimensions of approximately 100 meters . This site fits neighborhood scale for “ the reasonably homogeneous urban sub

- region with dimensions of a few kilometers .”

In addition, designating t he FNSB Administration Building as both NCore and SLAMS does not complement data collection.

“NCore sites are expected to complement the PM 2.5 data collection that takes place at

non

- NCore SLAMS sites, and both types of sites can be used to meet the minim um PM 2.5 network requirements.” 40 CFR § 58 Appendix D 4.7.1

.
Consolidating SLAMS and NCore into one station minimizes PM2.5 data collec tion in this severely affected PM2.5 nonattainment area , further diminishing already inadequate PM2.5 sampling and interfering with requirements necessary to protect public health.

Regulations do not support EPA approval of ADEC’s request to move the SLA MS to a site in downtown Fairbanks.

1 0

. In the annual monitoring network plan, ADEC did not include a performance assessment of monitors that should not be compared to the NAAQS. Thus, continuous FEM monitor data may not be excluded from NAAQS consideration

.
State and local governments may request that Federal Equivalent Method ( FEM) monitors should not be used in comparison to the NAAQS but must accompany this request with a performance assessment in the annual monitoring network. 40 CFR § 58.11(e)

.
Lacking this request or assessment, EPA has no basis to exclude North Pole Elementary and Nor th Pole Fire continuous FEM data from NAAQS consideration. For that matter, continuous FEM data from the downtown stations also cannot be excluded.

It is unclear exactly why FNSB does not use continuous FEM monitors. According to the state’s 5

- year plan, continuous monitors “cannot be trusted” in Fairbanks, and “several of our FEM PM2.5 samplers operated in Fairbanks are biased high.” State of Alaska 2010 Ambient Air Quality Network Assessment, p 61 . However, no data were provided to substantiate this claim. Without a formal assessment as provided in 40 CFR § 58.11(e)
, continuous FEM monitor data can be compared with the NAAQS.Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 15

For SLAMS, where a monitoring agency has identified that the continuous monitor d oes not produce data of adequate quality, the agency “must ensure” that FRM sample frequency requirements are met. 40 CFR § 58.10(b)(13)

. For this nonattainment area
, FNSB has done the opposite and ensured sample frequency requirements were not met.

We conducted a spot comparison of collocated North Pole Fire FRM and FEM monitors from Sept. to Dec. 2012. We found a slope of 0.9933 . This is within 1 ± 0.10 guidance provided by Table C

- 4 test specifications for PM2.5 FEMs. 40 CFR § 53 S ubpart C

. The data from the two monitors correlated very well, with a correlation coefficient of 0.9768.

Even if continuous FEM data does not meet the correlation criteria, this does not exclude the data from consideration.

“ Correlation is required to be reporte d in the assessment, but failure to meet the correlation criteria, by itself, is not cause to exclude data from a continuous FEM monitor.” 40 CFR §58.11 (e)(6)

. After the first 24 months of operation, data not certified by the reporting agency can be used by EPA if judged “complete and accurate” by EPA. 40 CFR §50 Appendix N (3)(a)

. EPA should not allow state and local efforts to prevent comparison of North Pole Fire to NAAQS to circumvent imperatives of the Clean Air Act and public health.

EPA should collect and review all data to determine whether North Pole Elementary can be desi gnated SLAMS from 2011 to 2013, its continuous monitors accepted as FEM, and the combined site data record reported to EPA Air Quality System (AQS) for comparison with NAAQS.

Similarly, North Pole Fire began operations March 1, 2012. On March 1, 2014, 24 months later, it is eligible for comparison to NAAQS. EPA should determine whether North Pole Fire can be designated SLAMS beginning in 2014, its continuous monitors accepted as FEM, and the combined site record made available on AQS for comparison with N AAQS.

Even without the continuous FEM monitors, North Pole Fire appears to have adequate creditable FRM samples for comparison against the PM2.5 daily standard per 40 CFR §50 Appendix N 4.2 . Data substitution may help fill out requirements for comparison to the PM2.5 annual standard and may be considered valid by Administrator initiative considering “factors such as monitor ing site closures/moves, monitoring diligence, the consistency and levels of the daily values.” 40 CFR §50 Appendix N 4.1

.

EPA should recalculate design values based on SLAMS monitors properly sited in the area of the expected maximum concentration using the combined site data record of the collocated FRM and continuous FEM monitor s

.Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 16

1 1

. If EPA does not step in to operate North Pole Fire as the SLAMS, nothing prevents North Pole Fire from being shut down without notice or ensures data completeness criteria will meet standards for NAAQS comparisons for PM2.5 attainment evaluations

.
North Pole Fire is qualified for NAAQS comparison and SLAMS designation yet may be shut down without notice or accountability just like North Pole Elementary.

Under FNSB control, North Pole Fire will be operated as a micro

- scale site and only every third day from October through March, weakening or defeating the relevance of its data in nonattainment decisions. Meanwhile, with EPA approval , a monitor in downtown Fairbanks will continue to be the only SLAMS , and a ll nonattainment decisions will be based on this location even though the site does not meet requirements for expected maximum concentration. Only FRM data from the downtown station will count even if sampling frequency is less than one out of three days e ach year. FEM continuous data will continued to be labeled “cannot be trusted” and ignored without any assessment of actual performance.

State and local agencies are experienced players in the game of hiding PM2.5 monitoring data even when it prolongs non attainment and continues to expose the public to very unhealthy air

.