UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Ref: 8P-AR 

Mr. Bowen Call 

Division of Air Quality 

REGION 8 

1595 Wynkoop Street 

DENVER, CO 80202-1129 

Phone 800-227-8917 

http://www.epa.gov/region08 

DEC 2 4 2013 

Utah Department of Environmental Quality 

Post Office Box 144820 

Salt Lake City, Utah 84114-4820 

Dear Mr. Call: 

Thank you for submitting the Utah 2013 Air Monitoring Network Plan, which the Division of Air 

Quality (DAQ) submitted under a cover letter dated July 1, 2013. While the portion of the 2013 network 

plan dealing with near-roadway monitoring of nitrogen dioxide is not approved at this time, as explained 

in the enclosure, the remainder of the network plan is approved. This approval also covers the eleven 

network modification request forms that were included with the network plan. Further comments on the 

contents of the network plan are also found in the enclosure. If you have any questions or comments, 

contact me at (303) 312-6431 or Joe Delwiche of my staff at (303) 312-6448. 

Enclosure 

Sincerely, 

Deirdre 

O~u~ Rothery, Chief 

Air Permitting, Monitoring, and Modeling Unit 

Air Program 
Enclosure

EPA Region 8’s Comments on

Utah Ambient Air Monitoring Annual Network Plan, 2013

This document presents comments by EPA Region 8 on the 2013 Network Plan for Utah. With the 

exception of the monitoring of near-roadway nitrogen dioxide (NO2) discussed below, Region 8’s 

review of this network plan did not identify inconsistencies with 40 CFR 58, appendix D (network 

design criteria). However, the Utah Department of Environmental Quality, Division of Air Quality 

(DAQ) proposes several noteworthy changes in the network which are discussed herein. The 2013 

Network Plan for Utah contains two components, a Data Collection Efficiency for Utah Air Quality 

Monitoring Network, with appendix, under a memorandum dated July 1, 2013, and the Annual 

Monitoring Plan 2013. The annual monitoring plan includes the following sections:

Site map.

Site parameters table.

Site address table.

Table of detailed site information.

Planned network changes. 

Network modification request forms (eleven).

Public comment letter – Wasatch Clean Air Coalition. 

Data Collection Efficiency for Utah Air Quality Monitoring Network

The report on data collection efficiency and its appendix present useful statistical analyses of the 

ambient air monitoring network by region within Utah and pollutant. Many of the analyses and technical 

recommendations lead to the proposed network changes that are discussed further elsewhere in the 

document. The data collection efficiency report includes a critique of particulate monitoring, both as 

PM10 and as PM2.5, at Magna (AQS identification number 049-035-1001), but no change in this 

monitoring is mentioned in the planned network changes. Conversations with the DAQ have confirmed 

that the particulate monitoring at Magna will continue at this time. However, the DAQ intends to cease 

the monitoring of sulfur dioxide (SO2) at Magna (and at other stations – see below), as documented on a 

network modification request form that was among the eleven such forms included with the network 

plan. 

Similarly, the report on data collection efficiency mentions the prospect of adding monitoring for 

particulate matter and ozone in Iron County while the network plan does not specify a proposed site for 

this station. Based on recent discussions, we understand that the DAQ will continue to evaluate the need 

for monitoring in Iron County as the population there increases. We appreciate the DAQ giving us early 

notice of this potential new station and we recommend that the DAQ address this proposal in more detail 

in the 2014 network plan. 

Planned Network Changes – NO2

The portion of the network plan on planned network changes, which begins on page 36, includes the 

following wording about near-roadway monitoring for NO2: 
EPA NO2 Near-Road monitoring program requires a monitor to be located near a high traffic

road section. Current proposed location for a near-road monitoring site for Salt Lake County is

on the west side of I-15 near 4900 South. This monitoring site has been identified, but will not be 

implemented until funding and resources are available to establish and operate the site. Other 

monitoring objectives have a higher priority for scarce resources.

A proposal to install this air monitoring station and begin operating it in January 2014 was included in 

the State’s 2012 network plan and the proposal was thus approved by Region 8. The current network 

plan excludes the same proposal. Notwithstanding the issues of funding and resources, its exclusion 

prevents the section of the network plan dealing with near-roadway monitoring of NO2 from meeting the

regulatory requirement (40 CFR 58, appendix D, section 4.3.2). Accordingly, the NO2 section of the 

2013 network plan is not approved at this time. 

Other Planned Network Changes

As explained further below, network changes listed on page 36 of the network plan include the proposal 

to end SO2 monitoring at the North Salt Lake station (049-035-0012) and other sites. The North Salt 

Lake station had also been monitoring particulate matter as PM10. Pages 36 to 37 list the North Salt Lake 

station, along with Logan (049-005-0004) and Rose Park (049-035-3010), as having old shelters. These 

three stations were to be evaluated against probe siting criteria before the DAQ decided whether to 

replace any shelters. On September 23, 2013, the DAQ advised Region 8 of the unplanned closing of the 

North Salt Lake station. The DAQ had lost access due to impending repairs on sewer lines underlying 

the site and, at that time, was considering moving the PM10 monitoring equipment to Rose Park. By late 

2013, the DAQ had not concluded how to resolve the loss of this PM10 monitoring station. We 

recommend that the DAQ document the loss of the North Salt Lake station in the 2014 network plan and 

formalize a proposal to continue PM10 monitoring in the vicinity. 

The section on planned network changes also foresees that the Spanish Fork station (049-049-5010)

might be closed, stating: 

The Spanish Fork (SF) station will need to be moved due to airport construction. Once the

airport determines the extent of their renovations, we will determine if it is possible to keep the

station at the airport or if a new location will need to be found.

In the same section, DAQ proposes to close the North Provo station (49-049-0002), citing redundancy

with Lindon (49-049-4001). The North Provo station has been monitoring carbon monoxide (CO), NO2, 

PM10 and PM2.5 as well as ozone and the Lindon station has been monitoring PM10 and PM2.5; “any 

needed” gaseous pollutant analyzers would be moved from North Provo to Lindon. 

The section on detailed site information states that the Spanish Fork station was “established to 

determine the boundary of the high ozone and PM2.5 concentrations in Utah County,” and the report on 

data collection efficiency notes that Spanish Fork has observed relatively high concentrations of PM2.5

and ozone. Spanish Fork and North Provo have been the two ozone stations in Utah County since the 

end of 2010, when the Highland station (49-049-5008) was closed. For the past several years, Spanish 

Fork has shown maximum ozone concentrations greater than or equal to those observed at North Provo. 
While Region 8 concurs with closing the North Provo station, we also support the DAQ’s proposal to 

move analyzers for gaseous air pollutants (ozone, NO2 and CO) to the Lindon station “to replace the 

North Provo site,” as stated in a network modification form in the network plan. Although closing the 

Spanish Fork station might be unavoidable due to changes on the airport grounds, we understand that an 

alternative site near the airport might be available. If the existing Spanish Fork station must be moved, 

we concur with the stated need to monitor maximum concentrations of both ozone and PM2.5 in Utah 

County. 

The section on planned network changes also mentions plans to: 

Begin monitoring at two new stations in Salt Lake County, one expected to be a multi-pollutant 

monitoring station in the southeast and the other to monitor concentrations of particulate matter 

and ozone in the southwest. 

Close the Fruitland (049-013-1001) and Price (049-007-1003) stations at the end of 2013. 

End SO2 monitoring at North Salt Lake (049-035-0012), Beach (049-035-2004), Bountiful 

(049-011-0004) and Magna (049-035-1001). 

End CO monitoring at the Washington Boulevard station (049-057-0006). 

End PM2.5 monitoring at Harrisville (049-057-1003); however, the report on data collection 

efficiency refers to continuing the monitoring of ozone there.

Set up a station in northern Tooele County near Erda to replace the Beach station (049-035-2004, 

which has conducted monitoring for SO2 and ozone) and the Tooele station (049-045-0003, 

which has conducted monitoring for PM2.5 and ozone). As stated above, at this time PM10 and 

PM2.5 monitoring at Magna would not be affected by this change. 

Begin monitoring PM10 and PM2.5 at Hurricane (049-053-0007) in January 2014.

End meteorological monitoring at the West Jordan station (049-035-3009).

Stop monitoring hexavalent chromium at Bountiful, consistent with guidance from the National 

Air Toxics Trends Station network. 

This portion of the network plan, and its attached network modification request forms, are also approved 

by Region 8. We request that the DAQ develop network modification request forms for the proposed 

additions in Salt Lake and Tooele Counties. 

Site Address Table and Metadata

The EPA and the States, who develop monitoring plans and report data to AQS, have a common interest 

in maintaining accurate and complete metadata in AQS. As stated in the March 2013 memorandum 

Recommendations for Monitoring Agencies to provide consistent and complete Metadata in the AQS 

Database from the Office of Air Quality Planning and Standards, “The focus of the metadata 

recommendations are those fields which are identified as part of the Annual Monitoring Network Plans 

in §58.10.” With the following comments, Region 8 requests that the DAQ address certain errors and

differences between metadata appearing in the network plan and the corresponding data in AQS. 

The pages of detailed site information that follow the site address table include entries for the types of 

stations or monitors. The monitor types shown with some stations installed by the DAQ since 2010 

differ from the monitor types appearing in AQS. In these cases, the detailed site information in the 
network plan appears as “State and Local Air Monitoring Stations” (SLAMS), while AQS shows either 

“special purpose monitor” or “non-regulatory.” These stations include Fruitland (049-013-1001), 

Roosevelt (049-013-0002), Vernal (049-047-1003) and Price (049-007-1003). It is recommended that 

next year’s network plan resolve the differences with AQS in the monitor types for the Roosevelt and 

Vernal stations. Additionally, the latitude and longitude of the Fruitland station in AQS place the site 

near Roosevelt, or about 50 miles from the actual site. Even though the DAQ intends to close the 

Fruitland and Price stations, we recommend correcting the coordinates of the Fruitland station in AQS 

for the benefit of data users.

In AQS, Region 8 requests that the DAQ populate certain key fields of metadata in AQS that are 

relevant to the network plan and are in some cases vacant, or null. These include measurement scale, 

latitude, longitude and local site name. Examples regarding the latter are summarized in the following 

table. The table is in the same order as appears in the Site Address Table (pages 5 and 6 of the Annual 

Monitoring Plan 2013). 

The field in AQS for local site name sometimes either is null or contains a comment on the station’s 

Universal Transverse Mercator (UTM) coordinates. The table below illustrates that, in many of these 

cases, the site name that appears in the network plan could be entered in that field. We recognize that the 

DAQ is more familiar with the names by which air monitoring stations in Utah are known, and we 

suggest that you consider populating these currently null fields in AQS with whatever local site names 

you consider appropriate. Remarks on UTM coordinates may be moved to a comment field in AQS. 

In cases where the station has been closed, or soon will be, the metadata will apply only to historical 

data. In these cases, changes in the metadata are at the discretion of the DAQ. Also, please note that the 

site address table has a typographical error in the AQS site identification number for the Tooele (T3) 

station, where the three-digit county code should be 045 instead of 049. 

AQS 

Identification 

Number

Name & Code from 

Network Plan

Local Site Name in AQS

Existing Suggested Change

049-005-0004 Logan – L4 Logan none

049-003-0003 Brigham City – BR Brigham City none

049-057-1003 Harrisville – HV Harrisville none

049-057-0006 Washington Blvd. – W2 “UTM coordinates = roof of bldg. 

directly above inlet probe” (CO ONLY) none – station to be closed

049-057-0002 Ogden #2 – O2 Ogden none

049-011-0004 Bountiful – BV Bountiful Viewmont none

049-011-6001 Antelope Island – AI Antelope (METEOROLOGICAL) none

049-011-6002 Syracuse – SY Syracuse (METEOROLOGICAL) none

049-035-3006 Hawthorne – HW Hawthorne none

049-035-2004 Beach – B4 “UTM coordinates at probe location” none – station to be closed

049-035-1001 Magna – MG Magna none

049-035-0012 North Salt Lake – N2 “UTM coordinates = inlet probe, location 

on roof of trailer” none – station closed
AQS 

Identification 

Number

Name & Code from 

Network Plan

Local Site Name in AQS

Existing Suggested Change

049-035-3010 Rose Park – RP Rose Park none

049-035-3005 Saltair – SA Saltair (METEOROLOGICAL) none

049-049-4001 Lindon – LN Lindon (METEOROLOGICAL) none

049-049-0002 North Provo – NP North Provo none

049-049-5010 Spanish Fork – SF Spanish Fork none

049-045-0003 Tooele – T3 Tooele none

049-045-6001 Badger Island – BI Badger Is. (METEOROLOGICAL) none

049-013-1001 Fruitland – FL null none – station to be closed

049-013-0002 Roosevelt – RS null Roosevelt

049-047-1003 Vernal – VL Vernal none

049-007-1003 Price – P2 null none – station to be closed

049-053-0007 Hurricane – HC null Hurricane