Reply to 

Attn Of: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 10 

1200 Sixth Avenue 

Seatlle, WA 98101 

October 5, 2010 

OEA-095 

MEMORANDUM 

SUBJECT: Eagle River Ptt,~tainment Determination 

FROM: Chris Hall fJ jI 

ECU Air Data Analyst, OEA 

TO: Claudia Vaupel 

STAPU Air Planning Team, OA WT 

At the request of the Office of Air, Waste and Toxies, I have conducted an Expected 

number of Exceedances (EE) analysis of all PM,o data submitted to the EPA AQS 

database by the State of Alaska (ADEC) for their monitors located within the Eagle 

River, Alaska nonattainmcnt boundary. The intent of this analysis is to determine the 

attainment status of all Federal Reference Method (FRM) and Federal Equivalent Method 

(FEM) PMIQ monitors which were in operation within the Eagle River non-attainment 

area from January 1, 1992 through December 31, 1994, per the criteria established in 

Appendix K to 40 CFR Part 50. Because the annual PMIQ standard was revoked effective 

December 18,2006, this document discusses only attainment of the 24-hour PMIQ 

standard.' 

Part 50 Appendix K requires three consecutive years of complete data to make an 

affirmative attainment determination for the 24-hour standard. A year is deemed 

complete if each of the four quarters has at least 75% data completeness. For calendar 

years 1992 through 1994, AQS shows both the Parkgate and BaronoffPMIQ sites as 

having data records for these three years. The Parkgate site is still in operation today; the 

Baronoff site was shut down in the fourth quarter of 1996. 

Baronoff Site Data Review: 

The Baronoff site (AQS #02-020-0040) recorded three PMIQ exceedances in 1992; 

August 19, August 20, and September 17. Each of these exceedances was flagged by 

ADEC as special events due to volcanic eruptions. Region 10 concurred on these events 

I See 71 FR 61144, October 17,2006. 

I 
on May 24, 1995, and therefore these days are excluded from EE calculations.

2 For the 

1 st quarter of 1992, the 1 st quarter of 1994, and the 4th quarter of 1996, the Baronoff site 

did not meet the 75% quarterly data completeness requirement (see Table 1). Data 

substitution is not an option for the Baronoff site as data for the 1 st quarter 1992 was less 

than 50% complete and therefore did not meet EPA guideline requirements3 In this 

respect an affirmative attainment determination cannot be made for the 24-hour PMIO 

NAAQS for 1992-94 for this site. We can affirm that the site did not fail the attainment 

test for this timeframe as the data, though incomplete, did not show a violation in any of 

the three years 4

. . 

Table 1 - Baronoff Site Attainment Determination Data 

Parkgate Site Data Review: 

The Parkgate site (AQS #02-020-1004) recorded one exceedance on September 16, 1992. 

This 24-hour value was flagged by ADEC in AQS as a special event due to a volcanic 

eruption and was concurred by Region 10 on May 24, 1995; therefore this value is 

excluded from EE calculations.5 There have been no other recorded exceedances of the 

24-hour PMIO standard during calendar years 1992 through 1994. In the 1

st quarter of 

1994 the Parkgate monitor did not meet the 75% data completeness criteria per Appendix 

K (1 st quarter completeness = 67%); therefore in order to make an affirmative attainment 

determination data was substituted for the five missing days in this quarter per EPA 

guidance (see footnote 2). This guidance allows EPA to substitute the missing values 

with the maximum PMlOconcentration observed from this monitor during the 1st quarter 

of 1992, 1993, or 1994 (see discussion below). After performing data substitution to 

fulfill the Appendix K data completeness requirements, we affirm that the Parkgate site 

2 See Memorandum from Jon W. Schweiss, May 24, 1995, and 'Guideline on the Identification and 

Handling of Ambient Air Quality Data Affected by Special Events or Special Conditions' (EPA-4541D-94-

001, September, 1994). 

3 The ability to perform data substitution is discussed in the EPA 'PMIO SIP Development Guideline' 

(EPA-45012-86-00I, June 1987) and the specific procedures are detailed in the 'Guideline on Exceptions to 

Data Requirementsfor Determining Attainment of Particulate Matter Standards' (EPA-450 4-87 -005, 

April 1987). 

4 Outside of the three regionally concurred special events in 3'" quarter 1992, the Baronoff site did not 

record an exceedance of the 24-hour PMw standard from its commencement on May 28, 1992 to its last day 

on October 1, 1996. See Memorandum from Jon W. Schweiss, May 24,1995, and 40 CFR 50, Appendix K, 

section 2.3(c). 

5 See Memorandum from Jon W. Schweiss, May 24, 1995, and 'Guideline on the Identification and 

Handling of Ambient Air Quality Data Affected by Special Events or Special Conditions' (EPA-4541D-94-

001, September, 1994). • 

2 
has demonstrated attainment for the 24-hour PMIONAAQS as of December 31,19946

. 

Further discussion on the data substitution process is provided in the next section. 

Parkgate Data Substitution: 

The April 1987 guideline document specifies data substitution can occur if (1) minimum 

data completeness requirements are mee, and (2) we can show that the PMIO emissions 

and the meteorology is representative for the quarter in question, as compared to the same 

quarter in 1992 and 1993. For the Parkgate site the first criterion is met as we have more 

than 2 years of data and each quarter has at least 50% data completeness. 

To substantiate the argument that the meteorological conditions are representative a 

comparison of temperature, wind speed, relative humidity, and dew point data was 

conducted for the 1

st quarters of 1992,1993, and 1994. As there is no available climate 

data from Eagle River data from the Elmendorf AFB surface met station is being used. 

The AFB site is approximately 9.3 miles SW of the Parkgate site and can be assumed to 

be representative of conditions in Eagle River. The 1 hour data for each meteorological 

parameter is provided in graphs 1-4 below. As the graphs attest the 1

st quarter 

meteorological data for 1992, 1993, and 1994 track very well and therefore can be 

assumed to be representative of each other. 

To show that the emissions from Eagle River are representative, a comparison of the 1

st 

quarter daily PMIO concentrations from the Parkgate monitor to daily PM 10 data from 

three other sites8 in operation in the Anchorage Borough for years 1992, 1993, and 1994 

was conducted (see graphs 5-7). From a review of these graphs it is clear that the 

Parkgate PMIO concentrations track very well with the other sites over the 1

st quarter for 

each year which indicates that the Parkgate monitor recorded concentrations that are 

typical and not unexpected for this time of year. Reviewing just the Parkgate data over 

these three years we can also see that PMIO emission were typically low with only two 

days above the 50[Lg/m3 level (2/6/93 and 2/19/94). In this respect we can conclude that 

the 1" quarters for 1992, 1993, and 1994, are representative of each other and therefore it 

is appropriate to conduct data substitution per EPA guidance9

. 

There were 5 scheduled sampling days in the I st quarter of 1994 when PMIO sampling did 

not occur at the Parkgate site and for which we have substituted the highest value 

recorded by the Parkgate monitor during the 1

st quarter of 1992, 1993, or 1994 (see Table 

2). This high value is 94[Lg/m3 and was recorded on February 19, 199410. As this high 

value is below the 24-hour PMIO NAAQS there are still no recorded exceedances and the 

EE value for the 1992-94 is still zero (see Table 3). Therefore after performing data 

6 As no exceedances were recorded during calendar years 1991 through 1997, we can as well affirm that 

the Parkgate site attained the 24-hour PMIO NAAQS for EE years 1991-93,1993-95,1994-96, and 1995-

97. 

1 At least two years of data with 50% completeness in each quarter (see footnote 7 guideline document). 

8 Anc-O = Anchorage/Ocean View (AQS 02·020-0042); Anc-G = Anchorage/Gambell (AQS 02-020-

0026); ER-P = Eagle RiverlParkgate; ER-B = Eagle RiverlBaronoff. 

9 See section 3, subsection (I)(b) in the 'Guideline on Exceptions to Data Requirementsfor Determining 

Attainment of Particulate Matter Standards' (EPA-450 4-87 -005, April 1987). 

10 Note: This substitution value of 941'g/m3 is the highest I" quarter value recorded at the Parkgate site for 

years 1990 through 1999 excluding regionally concurred special event data. 

3 
substitution to fulfill data completeness requirements, we can affirm that the Parkgate site 

has demonstrated attainment of the 24-hour PMIQ NAAQS for the three year period 

ending December 31, 1994 

Note: Balded values in this table are the values that have changed due to data substitution. 

4 
Graph I - Temperature Profile 

Elmendorf AFB 1st Quarter Temperature Profile 

20 J uOJ> 0 ~. .• -, ~~~ W. ~J"~~ Vi~ ~ 'l'\1..~ 7 - . '. ,,- • "'i ---+- 1992 

l ,20 , .. -- . --- 1993 .~ ... ~ ----

,40 

Jan 1 through rvtarch 31 hourly values 

Graph 2 - Wind Speed Profile 

Elmendorf AFB 1st Quarter Wind Speed Profile 16 r-----------------------------------__ ~ __ ~=_ ______ ~ 

• 12 +----------------------- ----------------------------~ 

4 

o 

Jan 1 through March 31 hourly value 

Graph 3 - Relative Humidity Profile 

Elmendorf AFB 1st Quarter Relative Humidity Profile 

'00 

80 

!!''-" .",--k ',' ' 

i.e • • &»: ) ~m. ~ " !ltllff~ , ' ' ~~ C 60 " I r~I~ "; v. ~' ~ -t ' ir. ~ 

t fi: ~ '1 I . I • \ • ~. ~ - , _ __" 'f.) . i'i 40 ._ j . 

20 ;' 

• 

0 

Jan 1 through March 31 hourly value 

Graph 4 - Dew Point Profile 

Elmendorf AFB 1st Quarter Dew Point Profile 

5 

-=,." ,, ~ 

LL -5 

0 

~ '- ' .. -11"'" ~ -'1111 :'-- """ • A rr-- JCl~ ~ .. '" -10 . .T.. '" -. V'l. __ ~ ,"V ·15 "..... -,,- ,,;, " 1 - - ~ -20 AI , Il f} :' " • - - - -25 -~ .. -30 

-35 

Jan 1 through Uerch 31 hourly value 

5 

1994 

. 1992 

• 1993 

1994 

. 1992 

· 1993 

1994 

___ 1992 

-- 1993 

1994 

Graph 5 - PMIO daily Concentration for 1992 

PM10 daily values - 1st qtr 1992 

0 

100 

'" 0 o Anc-O 

E 

C, c Anc-G 

:::J 50 0 l>. ER-P 

c 8 c o ER-B 

'I , 0 0 c c q a " c 8 ~ 0 II 0 Q 0 0 8 0 0 y 0 0 

,,~ ~~ ~ ~ ,l' "V"-<> ~ ~~ ",<J-~ ~ 

'" ,,"- ,,'" OJ ~'" 

Graph 6 - PMIO daily Concentration for 1993 

PM10 daily values - 1st qtr 1993 

0 

100 u 

'" <> Anc-O 

E 0 

C, Q c Anc-G :::J 50 ~ 0 l>. ER-P 0 0 

<> g c c o ER-B 

I> 8 0 c <> 0 

0 ~ 0 <> 1:) " " g 

0 0 

0 

0 0 

,,~ ~~ ~ ~ 

"V~<> "V~ ",<J- ~,,"v ~,,-"- "'~ '" ,,"- ,,'" 

Graph 7 - PMIO daily Concentration for 1994 

PM10 daily values - 1st qtr 1994 

0 

150 

c o Anc-O 

'" E 100 c Anc-G 

C, 0 /j. ER-P :::J 

50 0 o ER-B v " f\ c 0' 

l! c 0 

fj 6, 0' II <) 0 

0 

,,~ ,," ~,,<t, ,,<0- ,," '" "V., "V~"- "V~'" "V"-'o 

6 
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