### 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, OAWT
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 Because the annual PMIQ standard was revoked effective December 18,2006, this document discusses only attainment of the 24-hour PMIQ standard.'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.

Ion 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 requirements 3 In this respect an affirmative attainment determination cannot be made for the 24-hour PM IO 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 years4

. . 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 PM IO standard during calendar years 1992 through 1994. In the 1st 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 AmbientAir 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 'G uideline 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 PM w 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). •

2has 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 1st 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 sites 8 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 PM IO 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 PM IO 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, 1994 10. As this high value is below the 24-hour PM IO 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 s ite 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 'Guidelin e on Exceptions to Data Requir emen t sfor Deter mining Attainment of Particulate Matter Standards' (EPA-450 4-87 -005, April 1987)

. 10 Note : This s ubstitution value of 941'g/m3 is the highe st I " quarter value recorded at the Parkgate site for years 1990 through 1999 excluding regionally concurred special event data.

3substitution 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 3 1, 1994

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

4Graph I

- Temperature Profile
Elmendorf AFB 1st Quarter Temperature Profile 20 

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- Wind Speed Profile
Elmendorf AFB 1st Quarter Wind Speed Profile 

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- Relative Humidity Profile
Elmendorf AFB 1st Quarter Relative Humidity Profile

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- Dew Point Profile
Elmendorf AFB 1st Quarter Dew Point Profile 5



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- PMIO daily Concentration for 1992
PM10 daily values - 1st qtr 1992

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- PM IO daily Concentration for 1993
PM10 daily values - 1st qtr 1993

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PM10 daily values - 1st qtr 1994

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