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 

# DE C 2 

# 4 201 3

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 a l so 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,

# O~u~ Deirdre Rothery, Chief Air Permitting, Monitoring, and Modeling Unit Air ProgramEnclosure EPA Region 8’s Comments on Utah Ambient Air Monitoring Annual Network Plan, 201 3 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 ( NO 2 ) 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 i ncludes a critique of particulate monitoring, both as PM 10 and as PM 2.5 , 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 intend s to cease the monitoring of sulfur dioxide ( SO 2 ) at Magna (and at other stations

– see below), as documented on a network modification request form that w as 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 th e 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

– NO 2 The portion of the network plan on planned network changes, which begins on page 36, includes the following wording about near

- roadway monitoring for NO 2 :EPA NO 2 N ear
- Road monitoring program requires a monitor to be locat ed 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 n etwork 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 mon itoring of NO 2 from meeting the regulatory requirement (40 CFR 58, appendix D, section 4.3.2 ). Accordingly, the NO 2 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 SO 2 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 PM 10 . 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 evaluate d against probe siting criteria before the DAQ decided whether to replace any shelter s
. 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 PM 10 monitoring equipment to Rose Park

. By late 2013, the DAQ had not concluded how to resolve the loss of this PM 10 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 PM 10 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), NO 2 , PM 10 and PM 2.5 as well as ozone and the Lindon station has been monitoring PM 10 and PM 2.5 ; “any needed” gaseous pollutant analyzers would be moved from North Provo to Lindon.
T he sectio n on detailed site information states that the Spanish Fork station was “ established t o determine the boundary of the high ozone and PM 2.5 concentrations in Utah County, ” and the report on data collection efficiency notes that Spanish Fork has observed relatively high concentrations of PM 2.5 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

.W hile Region 8 concurs with closing the North Provo station, we also support the DAQ’s proposal to

move analyzers for gaseous air pollutants ( ozone , NO 2 and CO) to the Lindon station “to replace the North Provo site,” as stated in a network modification for m 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 PM 2.5 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. Clos e the Fruitland (049

- 013

- 1001) and Price (049

- 007

- 1003) stations at the end of 2013. End SO 2 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 B oule v ar d station (049

- 057

- 0006). End PM 2.5 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 SO 2 and ozone) and the Tooele station (049

- 045

- 0003, which has conducted monitoring for PM 2.5 and ozone). As stated above, at this time PM 10 and PM 2.5 monitoring at Magna would not be affected by this change

. Begin monitoring PM 10 and PM 2.5 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 M etad ata
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 Meta data 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 type s shown with some stations installed by the DAQ since 2010 differ from the monitor type s appearing in AQS. In these cases , the detailed site information in thenetwork plan appe ars as “State and Local Air Monitoring St ations” (SLAMS) , while AQS shows either

“special purpose monitor” or “non

- regulatory.” T hese stations include Fruitland (049

- 013

- 1001), Roosevelt ( 049

- 013

- 0002), Vernal (049

- 047

- 1003) and Price ( 049

- 007

- 1003 ). I t is recommended that next year’s network pla n 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 t he 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 ar e 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).
T he field in AQS for local site name sometimes either is null or contains a comment on the station’s Universal Transverse Mercator (UTM) coordinate s. The table below illustrates t hat, 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 popul ating 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 closedAQS

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