## DEPT. OF ENVIRONMENTAL CONSERVATION OFFICE OF THE COMMISSIONER

CERTIFIED MAIL: 7003 1680 0004 2906 3016 Return Receipt Requested



### September 29, 2010

Dennis McLerran, Regional Administrator U.S. EPA Region 10 1200 6 th 

### Avenue, Suite 900 (Mail Stop RA-140) Seattle, WA 98101

Dear Mr. McLerran:

This letter provides for your approval amendments to Alaska’s State Air Quality Control Plan or State Implementation Plan (SIP), adopted by reference into the Alaska Administrative Code (AAC) at 18 AAC 50.030, with an effective date of October 29, 2010. The revisions primarily affect the state’s vehicle inspection and maintenance program and Anchorage’s carbon monoxide maintenance area plan, which are contained in Volume II, Sections III.A and III.B of Alaska’s SIP, respectively. These amendments also include adopting by reference the Eagle River PM-10 Limited Maintenance Plan contained in Volume II, Section III.D.2 of Alaska’s SIP; and adopting by reference the Department’s Quality Assurance Project Plan for the State of Alaska Air Monito ring & Quality Assurance Program . With the submittal of these SIP revisions, the State of Alaska is requesting that EPA upon approval of the PM-10 limited maintenance plan, formally re-designate the Eagle River PM-10 non-attainment area as an attainment area.

We are providing three paper copies and one electronic version of the following documents to Gina Bonifacino of your staff:

• Alaska Administrative Code, Title 18, Chapter 50 Air Quality Control with an effective date of October 29, 2010, to be published in Register 196, January 2011.

• Sections of the State Air Quality Control Plan , adopted by reference under 18 AAC 50.030 as amended August 20, 2010, including:

• Volume II. Section II: Air Quality Control Program;

• Volume II. Section III.A: Statewide Carbon Monoxide Control Program;

• Volume II. Section III.B: Anchorage Transportation Control Program;

• Volume II. Section III.D.2: Eagle River PM-10 Limited Maintenance Plan;

• Volume III, Appendices to Volume II (includes 18 AAC 50 regulations); and SEAN PARNELL, GOVERNOR

410 Willoughby Avenue, Suite 303 Post Office Box 111800 Juneau, Alaska 99811-1800 Phone: 907-465-5066 Fax: 907-465-5070 www.dec.state.ak.us

### Dennis McLerran 2 September 29, 2010

G:\COMM\WP\2010\10.214 Amendments SIPAnchorage CO-PM10.docx



### • Quality Assurance Project Plan for the State of Alaska Air Monitoring & Quality Assurance Program.

The following supporting documents are also being provided:

1. Signed Adoption Order and certified Filing Certificate for Permanent Regulations, filed September 29, 2010 with an effective date of regulation October 29, 2010, along with appropriate delegations; 2. Notice of Public Comment, signed June 28, 2010; 3. Affidavits (3) of Publication for the Public Notice; 4. Affidavit of Agency Record of Public Comment, signed August 9, 2010, indicating no written public comments were received; 5. Affidavit of Oral Hearing, signed September 10, 2010; 6. Public Hearing Transcripts and Certification of Public Hearing, signed August 3, 2010; 7. Affidavit of Notice of Proposed Adoption of Regulations and Furnishing of Additional Information, signed August 20, 2010; 8. Public Review Draft of 18 AAC 50 regulations which shows the changes made to the regulations, with bold lettering as new language and bracketed language as old language, dated June 28, 2010; and 9. A copy of the tracked regulation amendments prepared by the Department of Law in their transmittal packet to the Lt. Governor for filing, dated September 27, 2010.

Mr. Scott Sloane is available to your staff to respond to questions or to otherwise assist. He can be phoned at (907) 465-5176. As always, I would be pleased to discuss any of this with you.

Sincerely,

Larry Hartig Commissioner

Enclosures

cc: Steve Morris, Municipality of Anchorage (w/enclosures) Rick Albright, EPA Region 10 (w/o enclosures) Gina Bonifacino, EPA Region 10 (w/ enclosures) Alice Edwards, Acting Director, Division of Air Quality, ADEC (w/o enclosures) Cynthia Heil, Acting Program Manager, ANPMS Program, ADEC (w/o enclosures)

# Alaska Department of Environmental Conservation

Amendments to State Air Quality Control Plan

Vol. II: Analysis of Problems, Control Actions

Section III.D.2 Eagle River PM

- 10 Limited Maintenance Plan



# Adopted

August 2 0 th 

# , 2010

### Adopted August 2 0 th 

### , 2010

(This page serves as a placeholder for two sided printing)

### Adopted August 20 th 

### , 2010

III.D.2

- 1 

# SECTION III.D.2

EAGLE RIVER PM 10



### III.D.2 .1. Introduction 

# LIMITED MAINTENANCE PLAN

Between 1985 and 1987 Eagle River frequently violated the national ambient air quality standard (NAAQS) for particulate matter air pollution with an aerodynamic diameter less than or equal to 10 micrometers ( μ m ) in size. This particulate air pollution is known as PM 10

. 

### As a consequence, in 1991 the U.S. Environmental Protection Agency ( EPA ) designated a nine square kilometer area in Eagle River as a moderate nonattainment area for PM 10 

### and required the submission of an air quality attainment plan to bring the area into compliance with the NAAQS. *


### In 1991, the Municipality of Anchorage (MOA) and the Alaska Department of Environmental Conservation (ADEC) prepared a State Implementation Pl an ( SIP ) to address the PM 10 

### problem in Eagle River

. This plan was entitled the Eagle River PM 10 

### Control Plan . The plan identified the main source of PM 10



### 58 FR 43084 as unpaved roads and outlined an ambitious road paving program to reduce emissions from this source

. EPA approved the plan as an amendment to the SIP o n August 13, 1993 ( ). Air quality monitoring data now show that Eagle River has attained the standard. However, in order for EPA to formally re

- designate Eagle River to an attainment area, the Clean Air Act (CAA) requires the State to submit a maintenance plan to EPA that demonstrates that the air qu ality control measures in place in Eagle River are sufficient to ensure continued maintenance of the PM 10 

### NAAQS. Once approved by EPA, this section of the state’s Air Quality Control Plan

, the Eagle River PM 10 

### Limited Maintenance Plan

, will replace the ear lier Eagle River PM 10 

### The State has delegated the responsibility for air quality planning in Anchorage and Eagle River to the MOA. Th e MOA has worked with ADEC to prepare th is new plan using the Limited Maintenance Plan (L MP) opti on provided under EPA guidance. It demonstrate s that Eagle River is now in attainment with the federal air quality standard for PM Control Plan in the Alaska SIP.

10



### The plan includes a request to the EPA Administrator to re

- designate the Eagle River PM as a result of the road paving program and that continued maintenance of the standard is expect ed for a minimum of ten years. The p lan also demonstrate s that Eagle River qualifies for the LMP option and meets the SIP planning requirements stipulated in the Clean Air Act

.

10 

### It should be noted that this plan is predicated on the presumption that EPA will approve an exceptional event waiver for a PM

- 10 exceedance that occurred due to high wind s on December 2, 2007. nonattainment area to attainment.

* Under the Clean Air Act, states are ultimately responsible for the submission of air quality plans. These plans are known as SIPs or State Implementation Plans.

### Adopted August 20 th 

### , 2010

III.D.2

- 2 I II.D.2.2. Local Planning Process

This plan was prepared in accordance with the provisions of sections 110 and 174 of the CAA which require the consultation and participation of local political subdivision s and local elected officials. Under S ection 174 (42 U.S.C. 7504), the revised plan submitted to EPA as a formal SIP amendment must be prepared by "an organization certified by the State, in consultation with elected of ficials of local governments." Such an organization is required to include local elected officials and r epresentatives of the state air quality planning agency (i.e., ADEC), the state transportation planning agency (i.e., Alaska Department of Transportation & Public Facilities ( ADOT/PF) , and the metropolitan planning organization (MPO) responsible for the tr ansportation planning process for the affected area. In 1976, the governor designated the MOA as the MPO for the Anchorage urbanized area which includes Eagle River. In Anchorage , the MPO is known as Anchorage Metropolitan Area Transportation Solutions or AMATS. Consequently, the MOA conducts the transportation planning process required under federal regulation, in cooperation with ADEC and ADOT/PF, through the AMATS organization. In 1978, the governor designated MOA as the lead air quality planning agency in Anchorage. Based on this designation, MOA has continued its role as the lead planning agency in the Anchorage area and prepared this plan. The air quality planning process is outlined in the AMATS Intergovernmental Operating Agreement for Transporta tion and Air Quality Planning. This agreement was last revised in August 2002 and became effective J anuary 1, 2003. This operating agreement establishes the roles and relationships b etween governmental entities involved in the Anchorage air quality planning process.

The AMATS Policy Committee provides guidance and control over studies and recommendatio ns developed by support staff. Voting members of the Policy Committee are listed be low.
MOA Mayor; ADOT/PF Central Regional Director; MOA Assembly representative; MOA Assembly representative; and ADEC Commissioner or designee.

The AMATS Technical Advisory Committee (TAC) and member support staff analyze transportation and land use iss ues and develop draft recommendat ions for the Policy Committee. Voting members include the following:

MOA Traffic Director; MOA Project Management and Engineering Director; MOA Planning Director; MOA Public Transportation Director; MOA Department of Healt h & Human Services representative; MOA Port of Anchorage Director; ADOT/PF Chief of Planning & Administration; ADOT/PF Regional Pre

- Construction Engineer;

### Adopted August 20 th 

### , 2010

III.D.2

- 3 ADEC representative; Alaska Railroad representative; and AMATS Air Quality Advisory Committee representative.

In addition, to help provide public input into the current air quality planning process by interested local groups and individual citizens, a third AMATS committee, the Air Quality Advisory Committee was appo inted by the Policy Committee. The Air Quality Advisory Committee is comprised of nine members. Committee membership has generally included at least one physician or health professional, a representative of the I/M industry, a representative of the environmental community, and a represe ntative from the Municipal Planning and Zoning Commission.

Section 110(a) of the CAAA (42 U.S.C. 7410(a)) requires that a state provide reasonable notice and public hearings of SIP revisions prior to their adoption and submiss ion to EPA. To ensure that the public had adequate opportunity to comment on revisions to the Anchorage air quality attainment and maintenance plans, a multi

- phase public involvement process, utilizing AMATS and the Anchorage Assembly was used. Public Participation Process

AMATS Air Quality Advisory Committee

– The AMATS Air Quality Advisory Committee held a public meeting on the limited maintenance plan on October 21, 2009

. During this meeting they recommended that the AMATS Technical and Policy Committees adopt the plan as submitte d. AMATS Technical and Policy Committees

– The AMATS Technical Advisory Committee released the limited maintenance plan for 30

- day public review on September 17, 2009; no com ments were received. After reviewing the recommendation of the AMATS Citizen Air Quality Advisory Committee, on September 10, 2009 the AMATS Technical Committee recommended that the AMATS Policy Committee adopt the plan. Subsequent to this recommendation, the AMATS Policy Committee met on November 19, 2009 Anchorage Assembly

– The Anchorage Assembly adopted the plan during its regular public meeting held on January 12, 2010

. A copy of Assembly Resolution AR 20 10

- 4 is included in the Appendix to Section III. D.2.2

. to review and adopt the the p lan.

ADEC hearings

– The final opportunity for public involvement occurs at the state administrative level. Prior to regulatory adoption of SIP revisions, ADEC holds public hearings on the revisions in the affected communities. ADEC held a public hearing on the Eagle River PM

- 10 Limited Maintenan ce Plan on August 2 nd 

### , 2010. This provided another forum for the public to comment on the air quality plan prior to state adoption and submission to EPA. No public comments were received.

### Adopted August 20 th 

### , 2010

III.D.2

- 4 III.D.2. 3

. Boundary of the Eagle River Maintenance Area

Eagle River is a community of about 30,000 located roughly 10 miles northeast of downtown Anchorage and is part of the Municipality of Anchorage. It is located at the end of a glacial river valley bounded on the west by Cook Inlet and on the south by the E agle River and the Chugach Mountains on the northeast. Eagle River is a bedroom community to Anchorage and land use in the area is largely suburban and rural residential with some commercial development. When the Eagle River PM 10



### A description of the maintenance area boundary follows. Control Plan was prepared in 1991, it identified a nine square kilometer nonattainment area that
encompasse d all of the central business district and most of the more densely populated suburban sections of the community

. This m ai ntenance plan retain s this same boundary

. It will become the maintenance area boundary effective upon approval of this plan.

Beginning from the point where the centerline of the southbound section of the Glenn Highway crosses Eagle Rive r, thence

Northward three k ilometers to point approximately 200 meters west of the Glenn Highway along the westward extension of Mercy Street, thence, Eastward along the alignment of Mercy Street two kilometers to an undeveloped point, thence

, Southward two kilometers to a point approximately 150 meters west of Eagle River Loop Road and approximately 70 meters southwest of the intersection of Kantishna and Iditarod Streets (near the point where the Loop road crosses Meadow Creek); thence,

Eastward three kilometers to an undeveloped point; thence

, Southward one kilometer to a point approximately 100 meters southeast of the intersection Eagle River Road and Greenhouse Street, thence

, Westward five kilometers approximately 70 meters south of the alignment o f Eagle River ending at the centerline of the southbound section of the Glenn Highway which is the point of the beginning.

### Adopted August 20 th 

### , 2010

III.D.2

- 5

Figure III.D.2

- 1 Eagle River PM 10 Limited Maintenance Area Boundary with Parkgate PM 10 Monitoring Site

### Adopted August 20 th 

### , 2010

III.D.2

- 6 III.D.2. 4

. Demonstration that Eagle River has Attained the PM 10 

### NAAQS

The EPA designated Eagle River as a “moderate” nonattainment for PM 10 

### on November 6, 1990 pursuant to Clean Air Act Section 107(d)(4)(B). The nonattainment designation was based on data collected at the Parkgate site in Eagle River. The primary and secondary NAAQS for PM 10 

### is set at 150 micrograms per cubic meter (μg/m 3



### M onitoring has been performed in the nonattainment area at the Parkgate monitor ing site since 1985. The Parkgate site is located on the east side of a commercial strip that runs along th e Old Glenn Highway. The land use to the north, west and east of the site is generally commercial while the land to the east is primarily residential. Prior to 1988, this site was bounded on two sides by gravel roads. The location of the site is identified in Figure II I .D.2

- 1 , presented earlier in this section

. ). The NAAQS used to also include an annual average standard but that sta ndard was recently revoked by the EPA ( 71FR 61144 ; October 17, 2006)

.

Figure III.D.2

- 2 Looking North from the Parkgate Site in Eagle River (2006)



### In 1987 there were over 22 miles of unpaved gravel roads in the nonattainment area. The Eagle River PM 10 

### Control Plan called for paving or surfacing about one

- third of the unpaved roads in the area. By 2007, all roads in the area had been paved or surfaced with

### Adopted August 20 th 

### , 2010

III.D.2

- 7 recycled asphalt. As illustrated in Figure III.D.2

- 3

, data suggest that paving has successfully lowered PM 10 

### concentrations. Exclusive of natural events, the highest PM 10 

### concentrations measured since 1988 have been roughly half the 24

- hour standard.

F igure III.D.2

- 3 First and Second Highest 24

- Hour Average PM 10 Parkgate Site, Eagle River (1985

- 2007) Concentrations



### PM 10



### Starting December 1989, Mt. Redoubt, about 100 miles southwest of Eagle River, erupted intermittently for six months. On April 12, 1990, the 24

- hour average PM concentrations measured in the Eagle River non

- attainment area have been well below the NAAQS for over 1 5 years. The only incidents that have approached or exceeded the 24

- hour NAAQS since 1988 were due to ash from volcanic eruptions or wind/dust storms.

10 

### concentration reached 143 μ g/m 3



### . However polarized light microscopic (PLM) analysis of PM 10 

### filters deployed on April 7, 9, and 11 showed that volcanic ash comprised 40

- 50% of the total PM 10



### The eruption of Mt. Spurr (approximately 80 miles west of Eagle River) on August 18, 1992 also raised PM assembl age ( Microlab Northwest Laboratory Report No. 1062

- 94

, October 17, 1994).

10 

### concentrations in both Anchorage and Eagle River for an extended period following the eruption. PLM analysis indicated that t he a sh content of the PM 10


### was 87

- 95% of total assembl age immediately after the er uption (August 19 and 20) and remained as a major component (20

- 38%) of the PM 10 

### for several years

. On September 16, 1992 concentrations reached 165

 μ g/m 3 

### at the Park g ate site in Eagle River, an

excee dance of the 24

- hour standard. Similarly high concentrat ions were observed at other PM 10 

### 0 100 200 300 400 500 600

1985 1990 1995 2000 2005 

## YearPM10(ug/m3) 1st Max

2nd Max Street clean-up, paving program starts (1988)

Mt. Spurr eruption (1992) exceptional events due to strong wind

24-hr standard (150 ug/m 3 ) Mt. Redoubt

eruption (1989-90)



### monitors in the Anchorage bowl

. T his event was attributed to re

- entrained volcanic ash.

### Adopted August 20 th 

### , 2010

III.D.2

- 8 The Eagle River PM 10 

### Control Pl an identified fall “freeze

- up” and spring “break

- up” as the two periods w hen the highest PM 10 

### concentrations occur and it focused on controlling emissions during those times. Figure III.D.2

- 4 compares PM 10 

### concentrations before paving (1985

- 87) with concentrations over the past ten years (1998

- 2007) after the completion of the paving program

. The largest declines in Eagle River PM 10 

### have been observed in the fall period. The data show that the 95 th 

### percentile PM 10 

### concentration during fall freeze

- up ha s dropped by a bout 75% while the concentration during spring break

- up has fallen 5% to 20%. These declines are roughly consistent with those predicted in 1 991 when the Control P lan was drafted

. In the late

- 80’s and early

- 90’s

, high fall season PM 10 

### concentrations were a greater concern than spring. T he highest PM 10 

### concentrations in Eagle Riv er now typically occur in spring break

- up rather than the fall freeze

- up period

.

Figure III.D.2

- 4 95th Percentile PM 10 Implementation of Road Paving Program in Eagle River Concentrations Before and After



### The highest, second highest and number of days exceeding the NAAQS are tabulated in Table III.D.2

- 1 for the period 1998

- 2007. Th e table provides clear evidence that Eagle River is in attainment with the NAAQS

. 0 50 100 150 200 250

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov DecPM10Concentration (ug/m3) Before Paving (1985-1987)

After Paving (1998-2007)

### Adopted August 20 th 

### , 2010

III.D.2

- 9 Table III.D. 2

- 1 Maximum, 2 nd

Year Maximum and Number of Exceedances at Parkgate Site, Eagle River 1998

- 2007

24

- hour Max ( μ g/m 3 2

) nd Highest 24

- hour ( μ g/m 3 Number of Days Exceeding ) NAAQS
1998 59 55 0
1999 90 66 0

2000 64 53 0

2001 69 66 0

2002 46 40 0

2003 92 # 90 0

2004 70 43 0

2005 90 65 0

2006 65 60 0

2007 48 # 46 0

# Note: This table does not include wind

- related ex ceptional events that occurred in 2003 and 2007. The 24

- hour PM 10 concentration was 590 μg/m 3 on March 12, 2003

, and 223 μg/m 3 on December 2, 2007.



### III.D.2

. 5

. Demonstration that Eagle River Qualifies for the L MP Option

On August 9, 2001 EPA issued guidance on streamlined maintenance plan provisions for certain PM 10 

### nonattainment areas seeki ng redesignation to attainment ( Limited Maintenance Plan Option for Moderate PM 10 

### Nonattainment Areas

, Wegman 2001 )

. The EPA observed that areas meeting certain statistical criteria have a high degree of probability of continued compliance with the NAAQS. Based on this analysis, they developed specific criteria to qualify for the LMP option

. Elements of th ese criteria follo w:

1. The area should be attain ing the PM LMP Qualification Criteria

10


### 2. The average 24

- hour PM NAAQS;

10 

### design value (DV) for the area, based on the most recent five years of air quality data at all monitors in the area, should be at or below 98 ug/m 3 

### with no violations at any monitor in the nonattainment area; *



### 3. The area should expect only limited growth in on

- road motor vehicle PM and

10

* EPA also established a procedure for determining an alternate, site

- specific criteria (call ed the Critical Design Value) that allows area with design values with little inter

- annual variability to qualify for the LMP option if their DV is above 98 μg/m 3

. 

### emissions (including fugitive dust) and should have passed a motor vehicle regional emissions analysis test

.

### Adopted August 20 th 

### , 2010

III.D.2

- 10 Th e next three sub

- sections will demonstrate that Eagle River meets these three criteri a

.

1. Eagle River is attaining the PM 10


### S ection II.D.2

- 4 provided a demonstration that Eagle River has been in attainment with the NAAQS for over 15 years. Except for uncontrollable natural events such as volcanic eruptions and wind/dust storms, Eagle River last exceeded the NAAQS in 1987. NAAQS

2. The average DV for the Eagle River area is below 98 ug/m Computational methods for determining the 24

- hour DV are outlined in the PM 3

10 

### SIP Development Guideline (EPA

- 450/2

- 86

- 001, June 1987) . The empirical frequency distribution approach (see Section 6.3.3. of the guideline) was used to determine the DV which is defined as the site

- specific PM 10 

### concentration that wo uld be expected to be exceeded at a frequency of once every 365 days. T able III.D.2

- 2 shows that Eagle River has a computed DV for the last 5 years that is below the LMP criteria of 98 μg/m 3 

### ( d etails of this computation can be found in the A ppendix to III.D.2. 5

. )

. The table also demonstrates that there is no increasing trend over the last decade. Exceedances of the NAAQS were recorded on March 12, 2003 and December 2, 2007

. B oth incidents

, however, have been flagged as exceptional events due to blowi ng dust from high winds. These incidents w ere therefore not considered when determining attainment or included in the DV computation

.

Table III.D. 2

- 2 *

Parkgate Site, Eagle River 1998

- 2007 DV Computed from Empirical Data Distribution

Three

- year Period Used to Compute DV DV (computed from empirical data distribution of 3 years data) ( μ g/m 3

1998

- 2000 )
84.5
1999

- 2001 95.5
2000

- 2002 89.7
2001

- 2003 108.0
2002

- 2004 94.1
2003

- 2005 102.7
2004

- 2006 88.2
2005

- 2007 86.0

Average DV for the last 5 years (2003

- 2007) 92.3

LMP criteria 98.0

* Assuming that EPA accepts data from 12/2/07, 10/30/09 and 10/31/09 as exceptional events, the computed DV was 81 ug/m3 for 2006

- 08 and 85 ug/m3 for 2007

- 09

.

### Adopted August 20 th 

### , 2010

III.D.2

- 11 3. Eagle River Passes Motor Vehicle Regional Emissions Analysis Test

I ncreases in emissions from on

- road mobile sources must be taken into account over the next 10 years to help ensure that PM 10 

### concentration s will remain below the NAAQS. *



### Projected DV in 20 2 0 = D V The EPA LMP guidance recommends the use of the following equation to assess the impact of future emission increases from motor vehicle travel:

2007 

### + ( VMT pi 

### x DV mv

Where: 

### ) ≤ MOS

DV = the area’s average DV in μg/m 3

VMT for the period used to demonstrate attainment (base year 2007)

.

pi =

DV the projected % increase in vehicle miles traveled (VMT) between 2007 and 202 0

.

mv = Portion of DV for the attainment year (2007) inventory in μ g/m 3

MOS = margin of safety for the relevant PM that is derived from on

- road emission s

10 standard in μ g/m 3 for a given area

. This can be = 98 μg/m 3 o r a site

- specific value computed f rom data collected at the site of interest using methods outlined in Attachment A of the LMP guidelines . For the Parkgate site in Eagle River this value was computed to be 116.6 μg / m 3

. (See Appendix to III.D.2. 5 for details of this computation.)



### In the preceding sub

- section, the average DV was computed to be 92.3 μg/m 3



### VMT .

pi 

### was estimated using VMT estimates made for the air quality conformity analysis for the Chugiak/Eagle River Long Range Transportation Plan ( CE/LRTP). The analysis included VMT estimates for analysis years 2007, 2017, and 2027

. for the Eagle River PM 10 

### non

- attainment area. Total VMT in 2007 was 165,934. VMT for year 2020 was estimated by interpolat ing between 2017 and 2027 VMT. By 2020, VMT is projected to grow by 36.3% to 226,221. Thus the projected increase in VMT ( VMT pi 

### As will be shown in the PM ) is 0.363

.

10 

### emission inventory presented later in Section III.D.2 .6 , the proportion of total PM 10 

### from on

- road mobile emissions varies with season in the Eagle River maintenance area. In the base year 2007 emission inventory, on

- road mo bile emissions, including fugitive dust emissions, w ere responsible for 5 0.6 % of total daily emissions in spring a nd 44. 4 % in the fall (see Table III.D.2

- 3 for details). For the
purpo ses of the Motor Vehicle Regional Emissions Analysis Test, the higher spring season proportion was assumed. The portion of 2007 DV that is attributed to on

- road mobile sources (DV mv 

### ) can be readily calculated as follows:

DV mv 

### = DV x 0. 5 06 = 92.3 μg/m 3 

### x 0. 5 06 = 46.7 μg/m 3

* This emissions analysis demonstration assumes that EPA will re

- designate Eagle River a maintenance area in 2010. The year 2020 was selected because it is ten years hence.

### Adopted August 20 th 

### , 2010

III.D.2

- 12 Knowing the values of the four variables, the projected DV in 20 20 can be readily computed:

Projected DV in 20 2 0 = DV 2007 

### + ( VMT pi 

### x DV mv



### = 93.6 μg/m )
3 

### + ( 0.363 x 47. 4 μg/m 3



### Projected DV in 20 20 = 109 μg/m )

3 

### < MOS

The projected DV in 20 20 is less than the 116.6 μg/m 3 

### margin of safety value or MOS, demonstrating that the Eagle River Maintenance Area meets the Motor Vehicle Regional Emissions Analysis Test

.

III.D.2. 6

. Attainment Year Emission Inventory for Eagle River

T h e base year attainment inventory for this LMP was selected to be 2007. An e mission inventor y was also prepared for 20 20

, the final year of a ten

- year maintenance period

. *


### As noted in Section III.D. 2. 4

, over the past t en years the highest PM 10



### Five sources of PM concentrations have typically occur red during spring break

- up and fall freeze

- up . For this reason, the emission inventor ies reflect conditions and activity levels (e.g., amount of silt loading on roads , residential wood heating rates ) that commonly occur during these two times of
year

. The assumptions

, methods and computations used to generate the 2007 and 2020 emission inventories are described in detail in the Appendix to III.D.2.6.

10



### The emission inventory prepared for the Eagle River PM emissions were identified and inventoried. Thes e include (1) dust from paved roads; (2) wind

- generated dust from roads, parking lots and un

- vegetated

areas; (3) fireplaces and woodstoves, ( 4 ) natural gas combustion ; and (5) exhaust, tire and brake wear emissions from motor vehicles

.

10



### The EPA publication, AP

- 42, Compilation of Air Pollutant Emission Factors, outlines recommended assumptions and methods for estimating emission factors for various

sources. Control Plan (base year 1987) also included emission estimates for unpaved roads. However, as noted earlier in this document, all roads in the maintenance area have been paved since that plan was
prepare d. Thus, unpaved road emissions are not included in th e 2007 or 2020 inventor ies

.

†

* Again, this assumes that EPA will approve this maintenance plan in 2010. 

### AP

- 42 methods were used to estimate emission factors for four of the five sources inventoried. Instead of AP

- 42, t he EPA mobile source emission factor model, MOBILE6.2 was used to estimate the emission factor for motor vehicle exhaust, tire and brake we ar emissions

. M ethods , assumptions and computations are described in detail in the Appendix to III.D.2

. 6

.

† An emission factor is a representative value that attempts to relate the quantity of a pollutant release to the atmosphere with an activity associated with the release of that poll utant.

### Adopted August 20 th 

### , 2010

III.D.2

- 13 The results of the inventory are presented in Table III.D.2

- 3

. P aved road dust, wind blown dust and fireplace and wood stove emissions are the main sources of PM 10

Table III.D. 2

- 3 

### in the Eagle River maintenance area.

Eagle River Limited Maintenance Area PM 10 ( All Emissions in tons/day with % of Total ) Emissions Inventory

Spring Break

- up (March, April) Fall Freeze

- up (October, November) Source Category 2007 2020 2007 2020

Paved Roads 2.88 (50.6%) 3.97 (57.8%) 0.83 (44.4%) 1.13 (50.8%) Wind blown Dust from Paved Roads, Parking Lots and Un

- Vegetated Areas 2.47 43.5% 2.53 (36.8%) 0.70 (37.6%) 0.72 (32.5%)

Fireplaces and Wood Stoves 0.32 (5.7%) 0.36 (5.2%) 0.32 (17.3%) 0.36 (16.1%)

Natural Gas Combustion 0.008 (0.1%) 0.009 (0.1%) 0.008 (0.4%) 0.009 (0.4%) Exhaust, Tire and Brake Wear Emissions from Motor Vehicles 0.005 (0.1%) 0.006 (0.1%) 0.005 (0.3%) 0.006 (0.3%)

TOTAL 5.69 (100%) 6.87 (100%) 1.87 (100%) 2.22 (100%)



### III.D.2

. 7

. Section 110 and Part D Requirements

Before the EPA a dministrator can re

- designate an area to attainment t he C AA require s that a s tate containing a nonattainment area meet all applicable requirements including those in S ection 110 and Part D of the Act. Section 110 of the Act outlines requirement for S IPs and Part D contains general requirements applicable to all designated nonattainment areas. Subpart 4 of Part D includes specific provisions for particulate matter nonattainment areas.

EPA designated Eagle River as a “moderate” nonattainment for PM Section 110

10 

### on November 6, 1990 pursuant to Clean Air Act Section 107(d)(4)(B). EPA required nonattainment areas like Eagle River to prepare plans to attain the standard. The approval of the Eagle River nonattainment plan by EPA in 1993 is evidence that applicable requirements of Section 110 have been satisfied. EPA approved the Eag le River PM 10 

### attainment plan (58 FR 43084) as an amendment to the Alaska SIP for air quality on August 13, 1993.

There are a number of requir e ments in Part D that are pertinent to the approval of the Eagle River LMP. These include r equir e ments for air quality monitoring, conti n gency
measures, and transportation conformity. These are addressed later in this document. Part D Requirements

The Part D NSR rules for PM 10 

### nonattainment areas in Alaska were approved by EPA. In Eagle River, NSR re quirements will be replaced by the Prevention of Significant

### Adopted August 20 th 

### , 2010

III.D.2

- 14 Deterioration (PSD) program in the maintenance area NSR program upon effective date of redesignation. The federal PSD regulations found in 40 CFR 52.21 are the PSD rules in effect for Alaska . T hese regulation s will apply after Eagle River is redesignated as a maintenance area. Subpart 4 of Part D established an attainment date of December 31, 1994 for Eagle River. Eagle River met this deadline. In addition, a milestone report demonstrating tha t Eagle River met the milestone requirements was submitted by MOA and approved by EPA in 199 5 as required.

III.D.2

. 8

. Maintenance Demonstration EPA guidance on the LMP option (Wegman, 2001) states that if an area qualifies for the LMP option “demonstration of maintenance is presumed to be satisfied

. ” Section III.D.2

. 4 of this document shows that monitored PM 10 

### concentrations in Eagle River are low and “stable” enough to qualify for the LMP option. Thus, Eagle River has satisfied the maintenance demonstration requ i r e ment.

III.D.2. 9

. Demonstration of Permanent and Enforceable Emission Reductions

As noted earlier in Section III.D.2. 4 , a large decline in PM 10



### The MOA and the Alaska Department of Tra nsportation and Public Facilities (ADOT&PF) have also implemented permanent changes in street maintenance practices on paved roads

. Both the MOA and ADOT&PF have set new winter traction sand specifications that limit the amount fines or silt allowed in th e material that is applied to roads within the MOA. In addition, t he MOA is continuing to explore new and more efficient ways to improve road traction during snow and ice conditions without compromising air quality. New methods for controlling PM concentrations has been observed in Eagle River and this de cline is attributed primarily to the paving of local gravel roads in the area. In 1987, almost one

- half of all the roads in the area (22 miles) were unpaved. By 2007 all of these roads were paved either with traditional hot asphalt paving or surfaced wit h RAP. The MOA is committed to the maintenance of these roads. In particular, all RAP

- surfa ced roads in the maintenance area have now been chip

- sealed to improve their durability. The effective lifetime of these chip

- sealed roads is estimated to be 10 t o 15 years. When these roads have reached the end of their lifetime a new lift of chip seal (a mix of crushed aggregate or “chips” and asphalt emulsion) is applied which serves as a new wearing course for the road.

10



### Eagle River has not violated the NA AQS since 1988; this is clear evidence that the controls implemented have provided permanent and enforceable emission reductions

. The Anchorage Assembly recently adopted a revised land use code that requires paving during the spring break

- up period are being investigated. These include the use of chemical dust palliatives and the use of new technology “waterless” sweepers which offer promise of more thorough clean

- up of roadways.

### Adopted August 20 th 

### , 2010

III.D.2

- 15 of all streets except those in low densi ty residential areas zoned R

- 6, R

- 7, R

- 8 or R

- 9

. * 

### Although most of the Eagle River maintenance area is “built out” and few new roads are likely to be constructed, t he requirements stipulated in Anchorage Municipal Code 21.08. 050 will help ensure that new s treets constructed in the Municipality, including Eagle River, will not cause new PM 10 

### The MOA is committed to continued maintenance of existing RAP/chip

- sealed roads in the maintenance area and the MOA and ADOT&PF are committed to maint ain ing
tr action sand specifications tha t allow no more than 2% fines or silt. A ll controls that were relied on to demonstrate attainment will remain in place

. problems.

III.D.2. 10

. Compliance with Air Quality Monitoring Requirements and Verification of Continued Attainment According to CAA Section 110(a)(2) , o nce an area is redesignated, the S tate must continue to operate an appropriate air monitoring network in accord with 40 CFR P art 58 to verify the attainment status of the area. The ADEC has delegated responsibility f or air quality monitoring to the MOA. The MOA is committed to the continued operation of at least one EPA

- approved PM 10



### Monitoring will be used to verify continued maintenance of the standard through the maintenance plan period. The MOA will annually recalculate the design value using the most recent five years of monitor data in o rder to verify the area continues to qualify for the LMP option. The result will be reported to the EPA. monitoring site in the Eagle River maintenance area through the end of the maintenance planning period (2020). Monitor ing will be cond ucted in accord ance with 40 CFR P art 58.

In the event the area does not continue to qualify for the LMP option a full maintenance plan will be prepared as required by the LMP policy.

III.D.2. 1 1

. Natural Events Action Plan

The MOA prepared a Natural Events Action Plan (NEAP) entitled A Natural Events Action Plan for Windblown Dust Events in Anchorage Alaska in September 2002. This plan was submitted to ADEC in response to a wind blown dust

- related exceedance that occurred in Anchorage on March 18, 2001. ADEC forwarded the NEAP to EPA; EPA approved it on May 5, 2003. A copy of the NEAP is included in the Appendix to III.D.2.11. One of the most important features of the NEAP is that it outlines procedures for issuing health advisories to help reduce PM 10 

### exposure to the public during the events. However the issuance of health advisories for the Eagle River area have been impeded by a lack of “real time” PM 10 

### monitoring data. Up until 2008, all PM 10

* R

- 6, R

- 7, R

- 8 and R

- 9 are residential zoning designations defined in Title 21 of the Anchorage Municipal Code. R

- 7 zoning allows between one and two dwelling units per acre. The maximum dwelling unit density allowed in R

- 6, R

- 8 and R

- 9 varies fr om one per acre (R

- 6) to one per four acres (R

- 9). 

### data in Eagle River was

### Adopted August 20 th 

### , 2010

III.D.2

- 16 collected using federal reference method (FRM) monitors

. Because FRM monitoring requires that PM 10 

### filter samples be retrieved after th e required 24

- hour sampling period, the data necessary to declare a heal th advisory are not available until the event is over. Although a health advisory was declared for the March 12, 2003 exceptional event in Eagle River , no such advisory was declared for the December 2, 2007 wind

- blown dust episode. * 

### The MOA has now insta lled “real time,” continuous PM 10 

### monitoring equipment in Eagle River that should remedy this shortcoming.

III.D.2

. 1 2

. Contingency Provisions Section 175A of the CAA requires that a maintenance plan include contingency measures in order to promptly correct any violation of the standard that occurs after the redesignation of the area to attainment. †



### This section identifies a process and a timeline to identify and eva luate appropriate contingency measures in the event of a violation of the PM Normally, the implementation of contingency

me asures is triggered by a violation of the NAAQS

. Contingency measures do not have to be fully adopted at the time of redesignation, but they must be readily adopted if they are triggered.

10 

### NAAQS.

Within 30 days following a violation of the PM Contingency Measures Assessment

10



### Within 120 days of the violation, the assessment team will prepare a report that identif ies the cause or causes of the violation and recommend s appropriate measures for mitigating future violations

. The report shall be presented to the AMATS Policy Committee for review and adoption and then forwarded to the ADEC for approval. NAAQS, the MOA will convene a n assessment team to identify control measures that appropr iately address the source(s) and circumstances causing the violation.

The report should include an analysis of the PM 10 

### monitoring data before and after the violation and a discussion of how the PM 10

* A health advisory was issued during the March 12, 2003 episode because data from “real time” monitors in Anchorage indicated very high PM 10 levels. Although data in Eagle River, 10 miles north were not available, PM 10 concentrations were presumed to be high there also. However, on December 2, 2007 real time data from Anchorage suggested that PM 10 concentrations were not likely to exceed the NAAQS. Without specific data for Eagle River, it was assumed th at an exceedance was also unlikely there and no health advisory was declared. 

### source or sources leading to the violation were determined. Other possible contributing factors such as weather conditions should be discussed. The effectiveness of existing control s, particularly those included in this

† The Eagle River PM 10 Control Plan drafted in 1991 included two contingency measures. The first contingency measure called for the surfacing of two additional miles of gravel r oadway in the nonattainment area with RAP. The second called for “sweetening” existing RAP roads with asphalt emulsion to improve their PM 10 reduction effectiveness . Even though these measures were never triggered by a violation of NAAQS, all roads in the nonattainment area have now been surfaced with RAP or paved

. In addition, all RAP roads have been enhanced with a chip

- seal coating to improve their effectiveness at reducing dust and to increase their durability.

### Adopted August 20 th 

### , 2010

III.D.2

- 17 maintenance plan

, should be discussed and any lapses in the implementation of such
contr ols should be identified

. The assessment team shall review the list of possible contingency measures offered in this Plan and recommend the implementation of one or more for them to address the

source or sources of the PM 10



### Local actions resulting from the assessment team recommendations will be at the discretio n the Municipal Mayor and A ssembly. Several of the possible contingency measures would require changes to local ordinance by the Anchorage Assembly before they could be implemented

. violation. The team has the option of recommending alternative measures not included on this list if circumstance s warrant.

The attainment inventory suggests that the primary sources of PM List of Potential Contingency Measures

10 

### in Eagle River are traffic

- related paved road dust emissions

, wind

- blown dust emissions from roadways, parking lots and cleared areas, and fireplace and wood stove emissions. As such, if a future violation were to occur, a combination of one or more of these sources is most likely to be the cause

.
A list of potential contingency measures for each of these three sources follows:

Traffic

- Related Paved Road Dust

1. Appl y c hemical d ust p alliatives to h igh v olume r oadways u pon p rediction of h igh PM 10


### T he highest emissions typically occur along major roads during the spring break

- up period when they are heavily laden with a winter’s worth of accumulated traction sand and other road sediment. R oad sediment accumulates primarily i n gutters, shoulders, medians and in the dividing strip between turn lanes and through lanes of high volume roadways. During the spring break

- up period of 2008 the MOA performed a field study of the dust palliative magnesium chloride brine (MgCl .

2 

### ). *


### The study concluded that absent significant precipitation, an application of MgCl 2 

### substantially reduced dust emissions for at least a week after application. This suggests that MgCl 2 

### could be used to mitigate roadway PM 10



### 2. Sweep major roadways prior to spring break

- up and other periods when elevated PM emissions when concentrations are pr edicted to approach or exceed the NAAQS

.

10 

### Although sweeping has been included here as a potential contingency measure, it should be noted that its effectivene ss and practicality as a control measure during the spring break

- up period is questionable. Many studies have shown that without extensive back

- flushing, traditional mechanical sweeping methods do not effectively is anticipated.

* A draft report, entitled Field Evalua tion of Suitability of Magnesium Chloride Brine for PM 10 Control on Paved Roads in Anchorage was completed by the MOA Department of Health and Human Services in September 2008.

### Adopted August 20 th 

### , 2010

III.D.2

- 18 reduce PM 10 

### emissions. In late March and early April when PM 10 

### is often highest, subfreezing temperatures make the use of water back

- flushing impractical. Moreover, ice and snow on roadway shoulders prevent effective sweeping where the road is most heavily laden with sediment. The MOA is experi menting with alternatives to “traditional” sweeping such as post

- sweep application of a dust palliative and /or “double

- pass” waterless sweeping. The MOA plans to continue to experiment with alternative s weeping procedures and one or more may prove viable as a contingency measure in the future

.

Wind

- blown Dust from Road ways, Parking Lots and Cleared Areas

1. I mplement one or more of the traffic

- related paved road dust measures discussed above. Paved roadways comprise over 75% of the cleared area in the Eagle River PM 10 

### maintenance area. Thus, the same measures suggested for control l ing traffic

- related PM 10 

### emissions are suitable for reducing wind

- blown dust. For example, the application of MgCl 2



### 2. Require application of dust palliatives to paved parking areas. brine would also be expected to reduce wind

- generated dust from roads.

Parking lots, playgrounds and other similar paved areas comprise about 20% of the cleared area in the maintenance area. The application of dust pallia tives to these areas would b e expected to reduce emissions.

3. Establish required specifications for traction sand materials applied to parking lots. Currently there are no requirements placed on the quality or quantity of traction sand materials applied to parking lots. New MOA regulations could be established that would limit the amount of fines or silt allowed in the traction sand applied to contiguous parking lots and paved areas greater than five acres in size, for example.

Fireplaces and Wood Stoves

1. C urtail fireplace and wood stove use when high PM 10 

### Although fireplace and wood stove emissions currently make up a relatively small part of total PM is predicted.

10 

### emissions, it is possible that future increases in natural gas heating costs could drive mo re households to heat with wood. If this is the case, emissions of PM 10 

### would increase over time

. Presumably air quality monitoring data would provide evidence if such a trend were occurring

. An increase in wood heating would likely jeopardize attainment of the PM 2.5 

### (fine particulate) NAAQS before PM 10


### . Nevertheless, in some circumstances it may be appropriate to consider regulating fire place and wood stove use as means to addressing PM 10 

### violations.

### Adopted August 20 th 

### , 2010

III.D.2

- 19 III.D.2

. 1 3

. Air Quality Conformity for LMP Areas The transportation conformity rule and general conformity rule apply to nonattainment and maintenance areas. Under either rule, an acceptable method of demonstrating that a federal action conforms to the applicable SIP is to demonstrate that expect ed emissions from the planned action are consistent with emissions budget for the area. Although EPA policy does not exempt LMP areas from the need to demonstrate conformity, it allows the area to do so without submitting an emissions budget, because data demonstrates no violation of the NAAQ S will occur due to reasonable growth projections. For transportation purposes, the emissions in a qualifying LMP area need not be capped for the maintenance period and thus no regional emissions analysis is required. Regional transportation conformity is presumed due to the limited potential for emission growth in the area during the LMP period. A regional emissions analysis and associated regional conformity requirements (40 CFR 93.118 and 93.119) are no longer

nece ssary. Similarly, f ederal actions subject to the general conformity rule would automatically satisfy the “budget test’ specified in Section 93.158(a)(5)(i)(A) for the

same reasons.
When Eagle River is designated by EPA as a LMP, transportation conformity determinations will still be required for transportation plans, programs (TIPs) and projects. The conformity determination for the plan and TIP should state that a regional emission analysis is not required because the area has an approved LMP. The Plan and the TIP must still be made available for public review. The portions of the conformity rul e that still apply are found in 40 CFR 93.112 and 93.113 and the consultation requirements as specified under state regulation, 18 AAC 50 .715 and 50.720. In addition transportation projects would still need to meet the criteria for PM 10 

### hot spots (40 CF R 93.116 and 93.123) and for PM 10 

### control measures (40 CFR 93.117). The MOA will work with ADEC and interested parties to develop an evaluation criteria and process to meet these transportation conformity requirements.

I II.D.2

. 1 4

. Redesignation Request

The MOA and ADEC believe this document contains all necessary information and adequately demonstrates th at Eagle River should be reclassifie d to attainment under the L MP option. Therefore, ADEC

, on behalf of the MOA, requests that EPA find this plan compl ete and approve the redesignation of the Eagle River nonattainment area to attainment under th e L MP option.

### Adopted August 2 0 th 

### , 2010


# Alaska Department of Environmental Conservation



# Amendments to:
State Air Qua l ity Control Plan
Vol. III: Appendices

Appendices to:

Volume II, Section II. Air Quality Control Program; Volume II, Section III.A Statewide C arbon Monoxide Control Program ; Volume II, Section III.B Anchorage Transportation Control Program ; and Volume II, Section III .D.2 Eagle River Limited Maintenance Plan



# Adopted

August 2 0 th 

# , 20 1 0

### Adopted August 20 th 

### , 2010



### The State of Alaska’s State Air Quality Control Plan Volume III

, Appendix to Volume II of this
p lan , is amended to include the following documents:

Volume II, Section II. Air Quality Control Program is amended by removing the following regulations:

• 18 AAC 5 0 Air Quality Control as amended through April 1 st 

### , 2010; and replacing them

with the following regulations:

• 18 AAC 50 Air Quality Control as amended through August 20 th 

### , 2010.

Volume II, Section III.B Anchorage Transportation Control Program, adopted into the State Air Quality Control Plan August 20 th 

### , 2010, is amended as follows:

• Appendix III.B.1 is amended by adding the following documents:

· Anchorage Assembly Resolution No. 2010-174, dated June 8, 2010, a resolution of

the Municipality of Anchorage adopting revisions to the Anchorage Carbon Monoxide Maintenance Plan (dated May 13, 2010 ) that delete s the commitment to I/M as a primary CO control measure.

• Appendix III.B.3 is amended by adding the following document:

· Anchorage 2007 Carbon Monoxide Emission Inventory and 2007-2023 Emission

Projections, prepared by the Municipality of Anchorage, dated March 2010.

• Appendix III.B.6 is amended by adding the following document:

· Analysis of Probability of Complying with the N ational Ambient Air Quality

Standard for Carbon Monoxide in Anchorage between 2007 and 2023, prepared by the Municipality of Anchorage, dated March 2010.

• Appendix III.B.9 is amended by adding the following document:

· Municipality of Anchorage Ordina nce No. 20 10-35(S), adopted by the Anchorage

Assembly May 11 , 2010 ; a n ordinance repealing Anchorage Municipal Code Chapter s 15.80 and 15.85, relating to motor vehicle emissions inspection and maintenance (I/M) program; amending Chapter 15.80 and 15.85 in the interim to revise existing fees and program administration; amending section 9.30.155 to repeal reference to I/M certification; and amending the fine schedule at section 14.60.030.

• Appendix III.B.10 is amended by adding the following documents:

· Estimation of Background Carbon Monoxide Concentrations for Anchorage ProjectLev el Conformity Analyses, no date; and

### Adopted August 20 th 

### , 2010



### · Affidavit of Oral Hearing

. Volume II, Section III.D.2 Eagle River PM-10 Control Plan, adopted into the State Air Quality Control Pl an August 20 th 

### , 2010, is amended by adding the following appendice s:

• Appendix III.D.2.2 - Anchorage Assembly Resolution ( AR ) 2010-4, dated January 12, 2010,

adopting the Eagle River PM-10 Limited Maintenance Plan.

• Appendix III.D.2.5 - PM 10 

### design values for Eagle River and qualification for Limited

Maintenance Plan.

• Appendix III.D.2.6 - 2007 and 2020 PM 10 

### Emission Inventories for the Eagle River Limited

Maintenance Area.

• Appendix III.D.2.11 - Natural Events Action Plan for Windblown Dust Events in

Anchorage, Alaska.

Volumes II and III of the State Air Quality Control Plan , as amended August 20 th 

### , 2010, includes the following document which is adopted by reference in 18 AAC 50.030:

• “ Quality Assurance Project Plan for the State of Alaska Air Monitoring & Quality Assurance Program”, dated February 23, 2010.

### Register

___, _____ 2010 ENVIRONMENTAL CONSERVATION



# DEPARTMENT OF

ENVIRONMENTAL CONSERVATION

18 AAC 50

Air Quality Control

Adopted

August 20 th 

## , 2010

### Register

___, _____ 2010 ENVIRONMENTAL CONSERVATION

The lead in language of 18 AAC 50.030 is amended to read:

18 AAC 50.030. State air quality control plan. Volumes II and III of the State Air

Quality Control Plan for implementing and enforcing the provisions of AS 46.14 and this

chapter, as amended through August 20 th 

### , 2010 [N OVEMBER 6, 2009], are adopted by

reference. The plan includes the following docum ents which are also adopted by reference:



# . . .

18 AAC 50.030(4) is amended to read:

(4) the department's Quality Assurance Project Plan for the State of Alaska Air

Monitoring & Quality Assurance Program [ ALASKA QUALITY ASSURANCE MANUAL

FOR AMBIENT AIR QUALITY MONITORING ], as amended through February 23,

2010 [AUGUST 21, 1996];

(Eff. 1/18/97, Register 141; am 6/21/98, Register 146; am 9/4/98, Register 147;

am 1/1/2000; Register 152; am 12/30/2000; Register 156; am 9/21/2001, Register 159; am

1/27/2002, Register 161; am 3/2/2002, Register 161; am 5/3/2002, Register 162; am 2/20/2004,

Register 169; am 6/24/2004, Register 170; am 10/1/2004, Register 171 ; am 12/14/2006, Register

180; am 12/30/2007, Register 184; am 5/17/2008, Register 186; am 7/25/2008, Register 187; am,

11/9/2008, Register 188; am 5/6/2009, Register 190; am 11/4/2009, Register 192; am 4/1/2010,

Register 193; am__/__/____, Register ___)

Authority: AS 46.03.020 AS 46.14.030 Sec. 30, ch. 74, SLA 1993

AS 46.14.020 AS 46.14.140

### Register

___, _____ 2010 ENVIRONMENTAL CONSERVATION

18 AAC 50.215(a) is amended to read:

18 AAC 50.215. Ambient air quality analysis methods. (a) A person who submits

meteorological or ambient air monitoring data under AS 46.03, AS 46.14, or this chapter shall

obtain the data in accordance with

(1) the department's Quality Assurance Project Plan for the State of Alaska Air

Monitoring & Quality Assurance Program [ ALASKA QUALITY ASSURANCE MANUAL FOR

AMBIENT AIR QUALITY MONITORING ], adopted by reference in 18 AAC 50.030 for PM-10,

PM 2.5 , total suspended particulates (TSP), lead, carbon monoxide, nitrogen dioxide, sulfur

dioxide, ozone and ammonia;

(Eff. 1/18/97, Register 141; am 6/21/98, Register 146; am 10/1/2004, Register 171; am

7/25/2008, Register 187; am __/__/____, Register ___)

Au thority: AS 46.03.020 AS 46.14.140 Sec. 30, ch. 74, SLA 1993

AS 46.14.030 AS 46.14.180

# Alaska Department of Environmental Conservation

Amendments to State Air Quality Control Plan

Vol. III: Appendix III.D.2.2

“ Anchorage Assembly Resolution AR 2010

- 4 Adopting the

Eagle River PM

- 10 Limited Maintenan ce Plan ”



# Adopted

August 20 th 

# , 2010

### Adopted August 20 th 

### , 2010

### Adopted August 20 th 

### , 2010

# Alaska Department of Environmental Conservation

Amendments to State Air Quality Control Plan

Vol. III: Appendix III.D.2.5

“ PM 10 

## Design Values for Eagle River and
Qualification for Limited Maintenance Plan ”



# Adopted

August 20 th 

# , 2010

### Adopted August 20 th 

### , 2010

1 

## Appendix to Volume II., Section III.D.2.5

PM 10 

## design values for Eagle River and qualification for Limited Maintenance Plan

Computation of 24- hr Design Value Computational methods for determining the 24-hour d esign value (DV) are outlined in the PM 10 

### SIP Development Guideline (EPA-450/2-86-001, June 1987) . The empirical frequency distribution approach (see Section 6.3.3. of the guideline) was used to determine the site- specific PM 10 

### concentration that would be expected to be exceeded at a frequency o f once every 365 days. To do so, we first ranked all observations by PM 10 

### concentration for each 3-yr block during the 1998 – 2007 period in descending order. Because PM 10 

### concentrations were monitored generally

on a one- in

- six

- days basis, each 3 -yr block had approximately 180 observations (thus the lowest concentration measured in each 3 -yr block had a rank order ≈ 180). Next, for a concentration ranked ( i ), the proportion of PM 10 

### observations that exceed that concentration is calculated as:

i / total number of observations The empirical frequency distribution for each 3-yr block was then graphed by plotting the proportion of occurrence against PM 10 

### concentrations (an example of 2004-2006 period is shown in Figure 1, Line a ). Because by definition the DV is a concentration that corresponds to an exceedance frequency of 1/365 (Line b ), the DV was graphically determined as the intersecting point of Lines a and b in the Figure 1.

Figure 1 Example - D etermination of 24

- hr DV for 2004

- 2006.

Line a = the empirical frequency distribution for all the observations during the 2004

- 2006 period. Line b = DV frequency by definition (1/365). Total number of observations = 181. For this particular period, DV was determined to be 88.2 μg/m 3

. 

### y = 1.2831e -0.0697x



### R 2 

### = 0.9823

0.001 0.010 0.100 1.000 10.000

0 20 40 60 80 100 120



### PM 10 

### concentration ( **μ** g m -3 

### )Proprotion of occurrance exceedingthe conc. 

### a

**b** DV frequency (1/365 = 0.0027)

88.2

### Adopted August 20 th 

### , 2010

2 Table 1 below shows calculated DV’s for the last decade, all eight 3 -yr blocks, to demonstrate that there is no increasing trend in DV’s over this period. The average DV during the last 5- yr period (2003- 2007) was 92.3 μg /m 3 

### . This is under 98 μg/m 3 

### and therefore meets the qualification for the LMP option.

Table 1 Computation of Average DV for Parkgate Site in Eagle River

3- yr Period Equation of Line Describing Empirical Frequency Distribution

++ R 2 DV (computed from previous 3 years data using empirical frequency distribution) (μ g/m 3 )

1998

- 2000 y = 1.4749e -0.0744x 0.960 84.5

1999

- 2001 y = 1.28522e -0.0643x 0.962 95.5

2000

- 2002 y = 1.41446e -0.0697x 0.984 89.7

2001

- 2003 y = 1.1840e -0.0562x 0.944 108.0

2002

- 2004 y = 1.3124e -0.0656x 0.968 94.1

2003

- 2005 y = 1.1248e -0.0586x 0.969 102.7

2004

- 2006 y = 1.2831e -0.0697x 0.982 88.2

2005

- 2007 y = 1.3049e -0.0717x 0.979 86.0

Average DV 2003

- 2007 = 92.3 μ g/m 3

LMP Qualification Criteria < 98 μ g/m 3

++ In this equation y is the proportions of concentrations exceeding a particular PM 10 concentration and x is the concentration of interest. If y is set = 1/365 = 0.0027, the equation can be used to solve for x, the concentration that would be expected to be exceeded once per year.

### Adopted August 20 th 

### , 2010

3 Computation of a Site- Specific Design Value Attachment A of the Limited Maintenance Plan guidance (Wegman memo, EPA , August 9, 2001) outlines a procedure for computing a site

- specific value (called a critical design value or CDV) that may serve as alternative to the 98 μg/m 3 

### value used to determine whether an area qualifies for the LMP option or meets the Motor Vehicle Regional Emissions Analysis Test. The computation is described bel ow:

CDV = NAAQS/(1+t c 

### CV)

Where:

CDV = t he critical design value

CV = the coefficient of variation of the annual design values (the ratio of standard deviation divided by the mean design value in the past)

t c 

### = the critical one

- tail t -value corresponding to a given probability of exceeding the NAAQS in the future and the degree of freedom in the estimate for the CV.

EPA Region 10 staff has recommended that a probability of 5% be assumed to determine the appropriate critical one

- tail t value (t c 

### ) in the computation.

Table 2 24

- hour CDV ( μ g/m 3 ) for Eagle River.

Parameter 24h r- CDV (μ g/m 3 ) Average DV 92.3 SD 9.1 CV 0.098

n 3 df 2

t c (5%, one

- tail) 2.920
CDV 116.6



### The computed CDV for Eagle River is 116.6 μg/m 3 

### . This means that, based on the magnitude of the eight annual DV’s computed for Eagle River between 2000 and 2007 and their year- to

- year variability, there is only an expected 5% probability that the average DV would be higher than 116.6 μg/m 3 

### at the Park gate site. The site -specific criterion is considerably higher than the “default” value of 98 μg/m 3 

### . This higher site- specific value was used as a margin of safety (MOS) value in the Motor Vehicle Regional Emissions Analysis Test.

# Alaska Department of Environmental Conservation



# Amendments to State Air Quality Control Plan

Volume III: Appendix III.D.2.6

“ 2007 and 2020 PM 10 

## Emission Inventories for the

Eagle River Limited Maintenance Area ”



# Adopted

August 20 th 

# , 2010

### Adopted August 20 th 

### , 2010

1 

## Appendix to Volume II., Section III.D.2.6

2007 and 2020 PM 10 

## Emission Inventories for the Eagle River PM

- 10 Limited Maintenance Area

Overview

This document describes the assumptions and methods used to develop the 2007 base year PM 10 

### attainment inventory and the projected inventory for year 2020. The 1987 inventory is also shown for illustrative purposes. Emissions from significant sources within the 9 km 2 

### area were estimated using standard methodologies outlined in AP- 42 for fugiti ve PM 10 

### sources. MOBILE6.2 was used to estimate the contribution of motor vehicle exhaust, tire and brake wear emissions to PM 10 

### As will be shown in the inventory, the large majority of PM .

10 

### emitted in the maintenance area is of “crustal” or geological o rigin. The emission inventory will show that the two most significant sources of this crustal material are the “dust” stirred up by vehicle traffic travelling on paved roadways and wind-lofted dust from roads, parking lots and un- vegetated areas within th e maintenance area. This finding is consistent with past source apportionment studies that have consistently shown that the vast majority of PM 10 

### in Eagle River and Anchorage consists of crustal material. 1


### In 1991, when the attainment plan for Eagle River was prepared, the most important source of PM 10 

### was unpaved roads. Since that time, however, all of the roads in the area have been paved so unpaved road emissions are no longer included in the inventory. For this maintenance plan, the five PM 10



### AP -42, “Compilation of Air Pollution Emissions Factors,” is an EPA publication that providesguidance on the estimation of emissions on a large variety of air pollution emission sources. AP42 was used to estimate emissions for all of the above sources except exhaust, tire and brake wear emissions. These emissions were estimated using the EPA MOBILE6.2 emission factor model. The methods and assumptions used to estimate emissions from each of these sources is described in the next five sections. s ource categories were identified and inventoried within the Eagle River maintenance area. These include (1) dust from paved roads; (2) wind-generated dust from roads, parking lots and un- vegetated areas; (3) fireplaces and woodstoves; (4) natural gas comb ustion; and (5) exhaust, tire and brake wear emissions from motor vehicles.

1 Four studies have been performed to characterize the sources of particulate and Anchorage and Eagle River. These include two chemical mass balance/source apportionment studies (Pritchett & Cooper, 1985, Cooper & Vodovinos, 1988) and two studies that used microscopy (Crutcher, 1994, R.J. Lee, Inc., 1995) to identify and quantify the types (and probable source s) of particulate.

### Adopted August 20 th 

### , 2010

2 (1) Dust from Paved Roads

Dust from paved roads is a major source of PM 10 

### in Eagle River and Anchorage. Roads are often laden with large amounts of “sediment” and other fine- grained mine rals left over from winter sanding operations, material abraded from the road surface itself by traffic (especially from vehicles equipped with studded tires), and spillage from hauling activities. Roads tend to be dirtiest during the spring break-up period which generally occurs between mid- March and the end of April. Although the grain size of most of the sediment on the roads is too large to be PM 10 

### , some of this material has been pulverized to a grain size less than 10 microns. When these very fine grained particles are re

- entrained into the air by turbulence from traffic travelling on the road, they become PM Section 13.2.1 of AP-42 outlines procedures for estimating PM 10.

10 

### emissions from paved roads. According to AP-42, emissions from a paved road are a function of how much fine- grained sediment or silt is on the road and the weight of vehicles using the road. 2



### VMT Estimation Paved road emissions increase in direct proportion to the amount of traffic or vehicle miles travelled (VMT) on the roads. Higher traffi c volumes result in greater emissions.

The air quality conformity analysis for the 2007 Chugiak- Eagle River Long Range Transportation Plan (CE/LRTP) included VMT estimates for analysis years 2007, 2017, and 2027. These VMT estimates served as the basis for the 2007 and 2020 inventories presented here. The CE/LRTP VMT estimates for 2007 in the 2007 base year attainment inventory and 2020 was estimated by interpolating between CE/LRTP projections for analysis years 2017 and 2027. In the conformity analysis for the CE/LRTP, the FHWA-approved Anchorage Transportation Model was used to estimate VMT on arterials and freeways in the Eagle River Maintenance area. The model did not provide VMT estimates for local roads, however. VMT on local roads was estimated by assuming that each household within the maintenance area makes seven home

based trips per day, each involving 0.62 miles of travel on local roads. 3



### Table 1 shows VMT estimates by roadway type. Each household was assumed to generate 4.34 miles (7 trips x 0.62 m) of local road VMT each day.

2 Silt is defined as the finer

- grained soil particles that pass a #200 mesh sieve; these are particles nominally 75 microns and smaller.
3 For example, a trip from home to the local grocery store and back would count as two home

- based trips.

### Adopted August 20 th 

### , 2010

3 Table 1. Estimated and Projected VMT in Eagle River PM 10 Base Year 2007 and E nd of 10

- Year Maintenance Planning Period 2020 Maintenance Area

Local Road VMT (based on housing Stock) Arterial and Freeway VMT (Anchorage Transportation Model estimates)

Housing Stock Local Unpaved VMT Paved (RAP)

VMT ± Paved (SP/CG) VMT **
Arterials Glenn Hwy

2007 4,548 0 7,6 59 12, 079 68,664 77,532

2017 4,908 0 8,2 64 13,0 34 83,370 107,640

2020 5,015 0 8,4 46 13,3 21 87,782 116,672

2027 5,267 0 8,8 70 1 3,989 98,076 137,748

± RAP = recycled asphalt pavement
** SP/CG = strip paved or curb and gutter



### Paved Road Emission Factor Section 13.2.1 of AP-42 (updated November 2006) outlines recommended procedures for estimating PM 10 

### emissions from paved roads. The paved road emission factor, the amount of PM 10



### The AP -42 paved road emission factor equation is: generated in pounds per vehicle mile travelled (VMT), is a function of the “silt loading” on the road and the average weight of the vehicles travelling on the road.

E = k(sL/2) 0.65 

### x (W/3) 1.5

where 

### –C

E = PM 10 k = 0.016 (AP

- 42 specified particle size multiplier for PM emissions in lbs/VMT

10 sL = road surface silt loading (varies by roadway type) )

W = mean vehicle weight in tons (assumed to be 2 tons) C = vehicle exhaust, tire and brake wear emissions (AP

- 42 recommendation = 0.00047 lbs/VMT)



### Data collected in Anchorage in 1996 (Montgomery-Watson, 1996) showed that silt loading varied by roadway type. (For this inventory Eagle River was assumed to have silt loadings identical to Anchorage.) The Municipality of Anchorage maintains a detailed inventory of the surface treatment of roads in the Chugiak – Eagle River area. While the majority of the roads in the area are paved with “traditional” hot asphalt paving (HAP) about one- third of the local roads in the maintenance area are constructed with recycled asphalt paving or RAP. Although air quality monitoring data suggest RAP treatment has proven to be an effe ctive means in reducing PM 10 

### from gravel roads in Eagle River, the surface of these roads is less durable and more erodible than those constructed using HAP. Because roadway abrasion is a significant source of silt on roads, it seems reasonable to assume that the silt loadings on RAP roads are higher than those surfaced

### Adopted August 20 th 

### , 2010

4 with HAP. 4



### Table 2 shows average silt loading measurements a nd the computed AP- 42 PM For the purpose of this inventory, RAP-constructed roads were assumed to have silt loadings twice those constructed with HAP.

10 

### emission factor for each roadway type for the spring and fall PM 10 

### seasons.

Table 2 Typical Silt Loadings and PM 10 Emission Factors by Season for Paved Roads in Eagle River Spring Break

- up Period Fall Freeze

- up Period

Silt loading (g/ m 2 Spring PM

) Emission Factor 10
(lbs/VMT) Silt loading (g/ m 2 Fall PM

) Emission Factor 10
(lbs/VMT)
Arterial Paved Roads 6.7 0.0207 1.1 0.0061 Freeways (Glenn Hwy) 20.4 0.0433 2.6 0.0110 Local Paved Roads (hot asphalt paving) 18.4 0.0404 4.7 0.0164 Local Paved Roads (recycled asphalt) 36.8 0.0637 # 9.4 0.0260 #

# S ilt loading estimated to be double those of local roads constructed with hot asphalt paving

.



### Using AP-42 Emission Factors and VMT Estimates to Compute Paved Road PM 10 

### Paved road PM Emissions

10 

### emissions can be readily computed from the emission factor and VMT on each roadway type. Table 3 shows estimated emissions for the spring and fall periods for base year 2007 and for the end of the maintenance period in 2020.

Table 3 Estimated PM 10 2007 and 2020 Emissions from Paved Roads in the Eagle River Maintenance Area

2007 2020

Roadway Type VMT Spring Emissions (tons/day) Fall Emissions (tons/day) VMT Spring Emissions (tons/day) Fall Emissions (tons/day) Arterial Paved Roads 68,664 0.71 0.21 87,782 0.91 0.27 Freeways (Glenn Hwy) 77,532 1.68 0.43 116,672 2.52 0.64 Local Roads (hot asphalt paving) 12,111 0.24 0.10 13,356 0.27 0.11 Local Roads (recycled asphalt) 7,627 0.24 0.10 8,411 0.27 0.11

TOTAL 165,934 2.88 0.83 226,221 3.97 1.13

4 The Municipality of Anchorage recently completed a study that suggests that roadway abrasion is the source of about 25% of the “dirt” on the road surface during spring break

- up.

### Adopted August 20 th 

### , 2010

5 (2) Wind Generated Dust from Roads, Parking Lots and Un- Vegetated Areas

Although EPA guidance allows the flagging of PM 10 

### exceedances that occur as a result of extreme wind events such as those that occurred on March 12, 2003 and December 2, 2007 in Eagle River, PM 10 

### observations resulting from commonly occurring, less energetic wind- related events are considered valid data and are not excluded when determining the design value for an area or determining whether the area is in compliance with the NAAQS. Monitoring data suggest that wind-generated dust frequently contributes to elevated PM 10



### Estimating the Amount of Area Covered by Roads, Parking Lots and Un- vegetated Areas concentrations in Eagle River.

Wind-generated dust generally originates from paved surfaces laden with dirt and silt. These paved surfaces include roadways and parking lots in the maintenance area. There are also some cleared, un

- vegetated areas that are unpaved. Estimates of the amount of area available for the generation of windblown dust are shown in Table 4. The area amount of roadway was estimated by the length of each type of roadway and the average width of that type of roadway. For example, there are 6.2 miles of arterial roadway in the maintenance area and arterial roadways have an average paved width of approximately 60 feet. The surface area of the arterial roadways in the maintenance area is therefore: ( 6.2 miles length)(5,280 ft/mi)(60 ft width) = 1,964,160 ft
1,964,160 ft 2

2 / 43,560 ft 2 /acre = 45.1 acres



### The amount of acreage covered by parking lots, paved school playgrounds, and similar areas was estimated by inspecting Google satellite photos of the maintenance area. The acreage of un

vegetated, cleared areas was estimated in like manner. The Google map utility includes a distance key that allows the dimensions and acreage of a particular surface feature to be estimated. For example, a parking l ot with dimensions of 250 feet by 500 feet is approximately 3 acres in size. Because parking areas, particularly those serving retail establishments serve the local population, we assumed that the total area covered by parking lots and the like would incr ease in direct proportion with housing stock. Housing stock is projected to increase by 10.3% between 2007 and 2020; paved parking areas were assumed to increase by a like proportion. The total amount of paved or cleared area in the maintenance area in base year 2007 was estimated to be 289 acres. This constitutes about 12.5% of the land surface in the maintenance

area.

### Adopted August 20 th 

### , 2010

6 Table 4 Estimated Surface Area Coverage of Roads, Parking Lots and Un

- vegetated Areas in Eagle River PM 10 Maintenance Area

2007 2020 Roadway

Length (miles) Estimated Area (acres) Roadway Length (miles) Estimated Area (acres) Glenn Highway 1.1 13 1.1 13 Arterials 6.2 45 6.2 45 Local Roads 45.6 165 45.6 165 Parking Lots

---- 55

---- 62 Un

- vegetated Areas

---- 10

---- 10

TOTAL 289 296 Note: To compute the total paved area of roadways, a paved width of 100 feet was assumed for the Glenn Highway, 60 feet for arterials, and 30 feet for local roads.



### Wind Blown Du st Emission Factor Estimation

AP -42 does not provide an emission factor methodology specific to estimating PM 10 

### emission from roads, parking lots and un-vegetated areas. However, it does outline a methodology (see AP -42 Section 13.2.5.1) for estimating emissions from aggregate storage piles and open areas within an ind ustrial facility. After examining other alternatives, the methodology recommended for estimating wind

- generated PM 10 

### emissions from open areas in industrial facilities seemed to offer the best fit available for estimating wind

- generated PM 10 

### The AP -42 Section 13.2.5.1 outlines a step- by -step procedure for estimating wind generated PM in Eagle Rive r.

10



### AP -42 pr ovides the following equation for estimating PM emission factor for open areas in industrial facilities. This methodology was applied to the estimation of emissions from open areas in Eagle River.

10 

### emissions from wind blown dust:

Equation 1

EF wind 

### = 0.5(58(u* - u t * 

### ) 2 

### + 25 (u* - u t *

where: 

### ))

u* = friction velocity (m/s)

u t *



### The next two sub- sections will describe how the variables u = threshold friction velocity (m/s)

t * 

### and u* were determined.

### Adopted August 20 th 

### , 2010

7 Determining u t 

### AP -42 outlines a field procedure and lab test (sieve analysis) for estimating the threshold friction velocity ( u *

t * 

### ). The mode of the aggregate size distribution is determined and can be related empirically (see AP -42 Table 13.2.5-1) to u t *

. 

### In order to estimate u t * 

### for the aggregate material in the Eagle River maintenance area, existing sieve analysis data from street sediment collected in Anchorage was used. 5 

### Over 300 street sediment samples were collected and sieved. Although the sieves used in this analysis did not correspond exactly to those prescribed in Table 13.2.5- 1, they were similar enough so that a reasonable estimate of u t * 

### could be made. 6 

### The mode size was determined from the average of all 300+ sieve analysis results. On average, 24.9% of the total street sediment was “captured” between sieves #40 (0.42 mm) and #100 (0.149 mm). The midpoint size between these two sieves is 0.285 mm (See Figure 1).

Figure 1 Sieve Analysis Results for Anchorage Street Sediment Data



### Table 13.2.5-1 recommends a value for u t * 

### = 0.43 m/s for a midpoint size range of 0.375 mm. Again, because different sieves were use d to characterize the size distribution of Anchorage road sediment than prescribed by AP-42, our midpoint value is slightly different. Nevertheless the data suggest that 0.43 m/s is a reasonable assumption of u t * 

### for Eagle River road sediment.

5 These data were collected in spring of 1996 by Montgomery

- Watson, I nc. for the MOA Watershed Management Section as part of an analysis of street sediment impacts on streams and lakes in Anchorage.
6 The sieves used in the Anchorage street sediment testing were #4, #9, #20, and #100. The method recommends using sieves #5 , #9, #16, #32, and #60. 4.8 13.8 13.9 14.1 24.9

7.6

0.0 5.0 10.0 15.0 20.0 25.0 30.0

4.76 - 9.5 (7.13) 2.00 - 4.76 (3.38) 0.84 - 2.00 (1.42) 0.42 - 0.84 (0.63) 0.149 - 0.42 (0.285) 0.105 - 0.149 (0.127) Size range, (mid-point) (values in mm)% in size range mode of aggregate size distribution

### Adopted August 20 th 

### , 2010

8 The friction wind velocity ( u* ) is the estimated wind velocity at the ground surface where street sediment and other fine materials lay available for re -entrainment by the wind. Wind speed measurements are taken at 10 meters above the groun d (u Determining u*

10 + 

### ), however. The actual wind speed at the ground surface is significantly lower. AP -42 recommends the following equation to estimate u *



### u :

* 

### = 0.053 u 10 +



### In order to estimate the contribution of wind blown dust to PM (expressed in m/sec)

10 

### , we identified the five highest PM 10 

### days during spring break-up (March, April) and fall freeze-up (October, November) over the 10-year period 1998-2007. We excluded the two designated exceptional events that resulted from wind/dust storms occurred on March 12, 2003 and December 2, 2007. 7 

### We examined local climatological data and determined the maximum wind speed (maximum 2 -minute observations) that occurred on each of those days. 8



### Results of this analysis are shown in Table 5. The friction velocity was selected from the spring and fall days with the highest wind speed.

Table 5 Equivalent Friction Wind Velocit ies on High PM 10

Date Days During Spring Break

- up and Fall Freeze

- up (1998

- 2007)

PM (μg/m 10

3 Max 2- min Wind Spd

) u 10 (mph) + Equivalent Friction

Wind Velocity u* (m/s) Date PM (μg/m 10

3 Max 2- min Wind Spd

) u 10 (mph) + Equivalent Friction

Wind Velocity u* (m/s) 3/10/2003 92 23 0.55 11/13/2006 65 16 0.38 3/17/2005 90 15 0.36 11/7/1998 55 7 0.17 3/4/2003 82 23 0.55 10/21/2000 52 20 0.47 4/15/2004 70 8 0.19 10/31/2005 51 14 0.33 3/14/2001 69 13 0.31 11/7/2006 48 20 0.47

Selected value for u* = 0.55 Selected value for u* = 0.47

7 The highest two

- minute wind speed measured on March 12, 2003 was 52 mph and on December 2, 2007
two

- minute winds reached 48 mph.
8 Because there are no comprehensive wind data available for Eagle River, local climatological data from the Ted Stevens Anchorage International Airport were used.

### Adopted August 20 th 

### , 2010

9 Computing the Wind Blown Dust Emission Factor from Equation (1)

Now that the threshold friction velocity u t * 

### and equivalent wind friction velocity u * 

### have been determined for the spring and fall PM 10 

### seasons, we can use Equation 1 to compute the PM 10



### (Equation 1) EF emission factor for wind blown dust.

wind 

### = 0.5(58(u* - u t * 

### ) 2 

### + 25 (u* - u t *

Substituting values for u 

### ))

t * = 0. 43 m/sec and u* = 0.55 m/s (spring) and 0. 47 m/s (fall), the resultant spring and fall wind blown dust PM 10 Spring Windblown Dust PM emission factor are:

10 Emission Factor = 1.9 g/m 2

Fall Windblown Dust PM /day = 17 lbs/acre/day

10 Emission Factor = 0.5 g/m 2 /day =5 lbs/acre/day



### Estimated Wind blown PM 10 

### Now that the emission factor and the amount of cleared acreage in the Eagle PM Emissions for 2007 and 2020

10 

### maintenance area have been estimated, PM 10 

### emissions can be readily calculated. Computed emissions are shown in Table 6.

Table 6 Estimated Windblown Dust PM 10 Emissions
Spring Break

- up Fall Freeze

- up

Year Cleared Areas: Roadways, Parking Lots, Miscellaneous

(total acres) Wind blown Dust PM 10

(lbs/acre) Emission

Factor Total PM 10
(tons/day) Emissions Wind blown Dust PM 10

(lbs/acre) Emission

Factor Total PM 10
(tons/day) Emissions

2007 289 17 2.47 5 0.70 2020 296 17 2.53 5 0.72



### (3) Fireplaces and Woodstoves

Basic assumptions regarding fireplace and wood stove were obtained from a telephone survey conducted by ASK Marketing and Research in 1990. This survey asked Anchorage residents how many hours per week they burned wood in their fireplace or wood stove. B ecause the AP

42 emission factors for fireplaces and wood stoves (See AP -42, Sections 1.9 and 1.10) are based on the amount of wood (dry weight) burned, hourly usage rates from the survey had to be converted into consumption rates. Based on discussions be tween MOA and several reliable sources (OMNI Environmental Services, Virginia Polytechnic Institute, Colorado Department of Health), average burning rates (in wet weight) of 11 pounds per hour for fireplaces and 3.5 pounds per hour for wood stoves were ass umed

. Residential wood burning assumptions are detailed in Table 7. 9

9 Assumptions regarding wood burning activity levels (i.e. the number of households engaging in wood burning on a winter season design day) were corroborated by a more recent telephone survey conducted by In 2003 Ivan Moore

### Adopted August 20 th 

### , 2010

10 T able 7 Estimation of R esidential W ood B urning PM 10

Device E mission F actors for Eagle River
Average use per weekday

(hours per household per day) Average dry weight of wood consumed (lbs per hour)* Average amount of wood burned per household (dry lbs / day) AP

- 42 Emission Factor for PM (g/dry lb wood burned) 10 Estimated PM 10



### Fireplaces emissions per household

(g/day)

1.04 7.15 lbs/hr 7.44 7.9 58.8



### Wood Stoves 0.85 2.275 lbs/hr 1.94 5.4** 10.5 

### TOTAL Fireplaces + wood stoves 1.89

------ 9.38

------ 69.3

* The moisture content of wood burned was assumed to be 35%. Thus, dry burning rates were 65% of wet rates.

** The wood stove emission factor was determined by assuming that the wood stove population in Eagle River is comprised of equal proportions of conventional, catalyst, and non

- catalyst stoves. The emission factor above was calculated as the weighted average of the AP

- 42 emission factors for each stove type. AP

- 42, 5 th Edition (Oct 1996)



### PM 10 

### emissions from residential wood burning can be estimated from the emission factor computed above and the estimated number of households. Table 8 shows estimated PM 10 

### emissions from residential wood burning for base year 2007 and for year 2020. Wood burning rates per household were assumed to be the same in 2007 and 2020.

Table 8 Estimated PM 10

Year Emissions from Residential Wood Burning in Eagle River Maintenance Area 2 007 and 2020

Housing Stock in Inventory Area AP

- 42 PM 10 Estimated PM Wood Burning Emission Factor for Eagle River (g/household/day) 10
(tons/day) Emissions from Fireplaces and Woodstoves

2007 4,548 64.5 0.32

2020 5,015 64.5 0.36

Research (IMR) asked approximately 600 Anchorage residents whether they had used their fireplace or woodstove during the preceding day. The survey was conducted when the preceding day had a minimum temperat ure between 5 and 15 o F. Although the IMR survey did not provide as detailed information as the ASK survey, its results were roughly consistent with the assumptions used in th is inventory.

### Adopted August 20 th 

### , 2010

11 (4) Natural Gas Combustion

Natural gas is the main fuel source for space heating in the Municipality of Anchorage, including Eagle River . Survey information suggests that the vast majority of households use natural gas as their primary source of heat. Average household natural gas consumption during a peak heating day in the winter in the Anchorage area has been estimated to be 658 ft 3 

### /d ay. 10 

### We, however, were interested in estimating natural gas consumption (and consequent PM 10 

### emissions) during spring break- up and fall freeze -up when temperatures are warmer. Estimates of peak household natural gas consumption were estimated for a day w hen the average ambient temperature was approximately -10 oF while the typical average daily temperature during the spring and fall PM 10 

### seasons is approximately +30 oF. Natural gas consumption for a +30 oF day can be estimated from consumption on a -10 oF day by assuming that consumption is proportional to heating degrees. 11

Peak

- day natural gas consumption per household = 658 ft 

### The computation is as follows.

3

Ambient temperature on day of peak natural gas consumption = - 10 oF , heating degrees = 75 /day

A mbient temperature on typical fall or spring day in PM 10 Assume natural gas consumption is proportional to heating degree days, then season = +30 oF , heating degrees = 35

Natural gas consumption during fall or spring PM 10 day = 658 ft 3 /day x (35/75) = 30 7 ft 3



### The Eagle R iver maintenance area is predominantly residential. While there are some commercial natural gas us ers, there is little if any industrial or utility us age. Because “non

residential use” is relatively small within the maintenance area, it seemed reasonable to assume that combined commercial and industrial use would be no more than 50% of residential. Thus, for the purpose of this inventory, total natura l gas use was assumed to be 150% of estimated residential use. /day



### The emission factor for “total” particulate matter (see AP -42 Section 1.4, July 1998) is estimated to be 7.6 lbs per 10 6 

### ft 3 

### of natural gas consumed. PM 10 

### emissions from natural gas combustion in the Eagle River maintenance area can be readily computed from the amount of gas consumed and this emission factor. Table 9 shows the results of this computation.

10 For details see “Anchorage 2007 CO Emission Inventory and 2007 -2 023 Projections,” Municipality of Anchorage, January 2008.
11 Heating degrees are computed as the difference between 65 oF and the average ambient temperature. For example, if the average temperature is 30 oF, heating degrees = 65

- 30 = 35.

### Adopted August 20 th 

### , 2010

12 Table 9 Estimation of PM 10 Emissions from Natural Gas Combustion in Eagle River Maintenance Area

Natural Gas Consumption
per Household (ft 3 Housing Stock ) Total Residential Natural Gas Consumption (ft 3 Estimated Commercial and Industrial Natural Gas Consumption ) (ft 3 Combined Residential, Commercial and Industrial Natural Gas Consu mption ) (ft 3 AP

- 42 PM

) Emission Factor 10

(lbs per 10 6 ft 3 Estimated PM

) 10
(tons/day) Emissions

2007 307 4,548 1.39 x 10 0.7 x 10 6 2.08 x 10 6 7.6 6 0.008 2020 307 5,015 1.54 x 10 0.7 x 10 6 2.31 x 10 6 7.6 6 0.009



### (5) Exhaust, Tire and Brake Wear Emissions from Motor Vehicles

In addition to the PM 10 

### that vehicles stir -up as they travel along dirty roadways, motor vehicles are also responsible for some “direct” PM 10



### MOBILE6.2 was used to estimate the PM emissions. These include tail pipe exhaust emissions, and the emissions that result from tire and break wear. These emissions can be estimated by using the EPA mobile source emission factor model called MOBILE6.2. MOBILE6.2 allows the vehicle fleet cha racteristics of a particular area such as the proportion of diesels in the fleet, age distribution of the fleet and the stringency of the vehicle inspection and maintenance program to taken into account when estimating emissions. Fuel characteristics such as gasoline and diesel fuel sulfur content are also accounted for in the modeling process.

10 

### emission factors for exhaust, tire and brake wear emissions for the Anchorage fleet in base year 2007 and in 2020, the en d of the maintenance planning period. The model produces emission factor estimates in grams per VMT. Thus, if VMT is known, emissions can be readily computed as the product of the emission factor and VMT estimate. Table 10 shows the results of the MOBLE6.2 emission factor modeling and consequent estimates of PM 10 

### emissions. As can be seen in the Table, exhaust, tire and break wear emissions are small. For example, road dust emissions are more than 100 times greater than the combined contribution of exh aust, tire and brake wear emissions.

Table 10 Estimated PM 10 in Eagle River Maintenance Area - 2007 and 2020 Emissions from Motor Vehicle Exhaust, Tire Wear and Brake Wear

2007 2020 MOBILE6.2 Emission Factor (g/mi) VMT PM 10 Emissions (tons/day) MOBILE6.2 Emission Factor (g/mi) VMT PM 10

Tail Pipe Exhaust Emissions (tons/day)

0.0046 165,934 0.0008 0.0037 226,221 0.0009 Brake Wear 0.0125 165,934 0.0023 0.0125 226,221 0.0031 Tire Wear 0.0085 165,934 0.0016 0.0085 226,221 0.0021 TOTAL COMBINED 0.0047 0.0061

### Adopted August 20 th 

### , 2010

13 Eagle River PM 10 

### Emissions Inventory Summary

The Eagle River PM 10 

### emissions inventories for 2007 and 2020 are summarized in Table 11. Separate inventories are provided for the two peak PM 10



### As can be seen in the Table, the most significant sources of PM periods, fall freeze -up and spring breakup.

10 

### in the Eagle River maintenance area are paved roads, wind -blown dust, and fireplaces and wood stoves.

Table 11 Eagle River Limited Maintenance Area PM 10 All Emissions in tons/day with % of Total Emissions Inventory

Spring Break

- up (March, April) Fall Freeze

- up (October, November) Source Category 2007 2020 2007 2020

Paved Roads 2.88 (50.6%) 3.97 (57.8%) 0.83 (44.4%) 1.13 (50.8%) Wind blown Dust from Paved Roads, Parking Lots and Un

- Vegetated Areas 2.47 (43.5%) 2.53 (36.8%) 0.70 (37.6%) 0.72 (32.5%)

Fireplaces and Wood Stoves 0.32 (5.7%) 0.36 (5.2%) 0.32 (17.3%) 0.36 (16.1%)

Natural Gas Combustion 0.008 (0.1%) 0.009 (0.1%) 0.008 (0.4%) 0.009 (0.4%) Exhaust, Tire and Brake Wear Emissions from Motor Vehicles 0.005 (0.1%) 0.006 (0.1%) 0.005 (0.3%) 0.006 (0.3%)

TOTAL 5.69 (100%) 6.87 (100%) 1.87 (100%) 2.22 (100%)

# Alaska Department of Environmental Conservation

Amendments to State Air Quality Control Plan

Vol. III: Appendix III.D.2.11

“ Natural Events Action Plan for Windblown Dust Events

in Anchorage, Alaska ”



# Adopted

August 20 th 

# , 2010

### Adopted August 20 th 

### , 2010



# Natural Events Action Plan for Windblown Dust Events in Anchorage, Alaska

Municipality of Anchorage

Department of Health and Human Services

Environmental Services Division

Environmental Quality Section

September 2002

### Adopted August 20 th 

### , 2010



## Natural Events Action Plan for Windblown Dust Events in Anchorage, Alaska

Introduction On March 18, 2001 the 24

- hour average PM

- 10 concentration measured at the Muldoon monitoring station in east Anchorage was 180 **μ** g/m 3 

### (micrograms per cubic meter), exceeding the national ambient air quality standard of 150 **μ** g/m 3 

### . These elevated levels of PM

- 10 were attributed to blowing dust generated by high winds. Sustained winds of 30 to 35 miles per hour, and peak gusts of up to 60 miles per hour were recorded at National Weather Service monitoring stations in Anchorage. The Municipality of Anchorage (MOA) has requested the Environmental Protection Agency (EPA) exclude the data from this event because the high PM

- 10 concentrations measured have been attributed to an uncontrollable natural event as defined in the EPA Natural Events Policy 1


### The Natural Events Policy allows EPA to exercise its discretion under Section 107(d)(3) of the Clean Air Act not to designate area as nonattainment if the State develops and implements a plan to respond to the health impacts of natural events. The Municipality of Anchorage Department of Health and Human Services (DHHS) is submitting this Natural Events Action Plan to the EPA through the Alaska Department of Environmental Conservation in conformance with this policy. .



## Required Elements of a Natural Events Action Plan In addition to documenting the validity of an exceedance as a natural event, the EPA natural events policy requires a natural events plan include commitments to:

1. Establish public notification and education programs.

2. Minimize public exposure to high concentrations of PM

- 10 due to future natural events.

3. Abate or minimize appropriate contributing controllable sources of PM

- 10.

4. Identify, study and implement practical mitigating measures as necessary.

5. Periodically reevaluate: (a) the conditions causing violations of a PM

- 10 NAAQS in the area, (b) the status of implementation of the NEAP, and (c) the adequacy of the actions being implemented. This plan will document the validity of the March 18, 2001 exceedance as a natural event and address the five required elements listed above.



## Documentation of March 18, 2001 Exceedance as a Natural Event
The 24

- hour average PM

- 10 concentration measured on March 18, 2001 at the Muldoon station (AIRS Code 02

- 020

- 043 ) in east Anchorage was 180 **μ** g/m 3



### , exceeding the national ambient air quality standard for PM

- 10. The Tudor monitoring station was also in operation on that day. It recorded elevated PM

- 10 concentrations

### Adopted August 20 th 

### , 2010

but did not exceed the NAAQS. i



### Figure 1. Location of Muldoon and Tudor PM

- 10 Monitoring Stations The locations of the Muldoon and Tudor sites are shown in Figure 1.

i The 24

- hour PM

- 10 concentration measured at the Tudor Road site (AIRS 02

- 020

- 0044) on March 18, 2001 was 150 **μ** g/m 3 . The EPA considers a value of 155 **μ** g/m 3 or higher an exceedance.

### Adopted August 20 th 

### , 2010

Local Climatological Data from Point Campbell in West Anchorage indicate that strong, northerly winds began late on March 17 and persisted through March 18 and most of the day of March 19. The 24

- hour average windspeed recorded at Point Campbell was 16 mph (miles per hour) with a peak gust of 33 mph. Weather observations also note blowing dust on March 18 and 19. Data f rom other stations to the east of Point Campbell suggest that winds were stronger on the eastside of town. In a report prepared specifically for this event, the National Weather Service noted sustained winds ranging from 30 to 35 mph and peak gusts ranging from 40 to 60 mph. The winds recorded on March 18, 2001 meet the definition of a high wind event as defined in EPA’s July 1986 exceptional events guidance. 2



### Hourly beta attenuation monitor data available from the Tudor site indicate that elevated PM

- 10 was directly associated with this wind event. Figure 2 shows that the PM

- 10 concentration increased dramatically at approximately 11 AM, March 18 and remained elevated into March 19. Although BAM data are not available from the Muldoon site, the pattern there is assumed to have been similar. This guidance defines a wind

- caused exceptional event as one with “an hourly wind speed of grea ter than or equal to 30 mph or gusts equal to or greater than 40 mph...”

Figure 2. Hourly PM

- 10 Concentrations at the Tudor Station March 17, 18, and 19, 2001

### Adopted August 20 th 

### , 2010

It should also be noted that the exceedance measured on March 18, 2001 was the first ever recorded in seven years of monitoring at the Muldoon station. The highest value previously

measur ed at the Muldoon site was 125 **μ** g/m 3 

### . This value was measured on March 17, 1997 and it was also associated with high winds.



### Additional documentation supporting the March 18, 2001 exceedance as a natural event is included in Appendix A.



## Public Notification and Education Program The Anchorage Municipal Code (AMC 15.30.060) and the Alaska State Implementation Plan require that the director of the DHHS declare an air pollution episode when 24

- hour average PM

- 10 concentrations reach or are predicted to reach 150 **μ** g/m 3 

### . The director is also required to publish an air pollution episode plan that describes the curtailment actions, communication and public notification procedures employed during episodes. A copy of stadnard operating procedures employed by DHHS along with the episode plan, published in 1993, is included in Appendix B. These procedures will continue to be followed when air pollution episodes occur. No distinction is made between natural events and “man

- caused” episodes. The public notification procedures outlined in the episode plan were followed during the windblown dust event of March 18, 2001. Even though this event occurred on a Sunday, when municipal personnel were not at work, an air quality advisory was declared and local media were notified. The advisory was declared at approximately 2 PM in the afternoon after staff reviewed BAM data and determined that an exceedance of the 24

- hour PM

- 10 NAAQS was possible if windy conditions persisted. ii



### DHHS immediately reported the advisory to local television and print media and updated the telephone message line to report the air quality index and information regarding the health advisory. At the time the advisory was declared, the most recent 24

- hour average PM

- 10 concentration had not yet exceeded the NAAQS. In accordance with existing standard procedure, staff consulted with the DHHS medical officer prior to issuing the advisory.

iii 

### The Sunday evening newscast and Monday morning newspaper contained information regarding the air quality advisory. A copy of the newspaper article from the March 19, 2001 Anchorage Daily News is included in Appendix C.

ii In addition to conducting PM

- 10 sampling with reference method samplers, the DHHS operates two Graseby

- Anderson beta attenuation monitors (BAMs) to collect hourly

PM

- 10 information. These are operated in order to obtain timely information on PM

- 10 concentrations not available from reference method samplers. DHHS utilizes the
information from the BAMs to report timely air quality index information to the public and to assess whether a health advisory should be declared during a PM

- 10 episode.
The usefulness of the BAMs has been proven in past experience with volcanic eruptions, forest fires, and other wind blown dust events.

iii DHHS maintains a telephone message line to report the air quality index and other pertinent air quality information. Th e telephon e number for the air quality index (AQI)
report is advertised in the municipal section of the local Anchorage phone directory under “frequently called numbers.” Information is updated at least once daily on normal
workdays and, if conditions warrant, it is updated on weekends and holidays. The phone line is utilized by the general public and the news media for updates on air quality.
It has been in use for over 15 years and is routinely used to issue air quality health advisories.

### Adopted August 20 th 

### , 2010



## Minimizing Public Exposure to Elevated PM-10 Concentrations during Natural Events The EPA natural events policy states that a natural events action plan should (a) identify the people most at risk, (b) notify the at

- risk population that a natural event is imminent or currently taking place, (c) suggest actions to be taken by the public to minimize their exposure to high concentrations of PM

- 10, and (d) suggest precautions to take if exposure cannot be avoided. Local epidemiological studies have been conducted by the DHHS in collaboration with other researchers that help identify the people most at risk from PM

- 10 exposure. 3

, 4 

### This research suggests that elevated PM

- 10 concentrations are associated with an increased incidence of bronchitis, upper respiratory illness, and in one study, asthma. This is generally consistent with information contained in the EPA criteria document for particulate matter. 5 

### It is also consistent with the Air Quality Index guideline for reporting air quality that identifies people with respiratory disease among those at most risk. 6


### Health advisories issued by DHHS in response to PM

- 10 events advise those with respiratory diseases such as asthma and emphysema to avoid areas where PM

- 10 levels are likely to be the highest. Those with severe lung disease are advised to remain indoors if possible.

In some events , DHHS is able to identify the particular areas that are likely to have the highest PM

- 10 levels. Monitoring data have shown that areas near major roadways often have the highest PM

- 10 concentrations during most PM

- 10 episodes. If information regarding the areas likely to have the highest concentrations is available, it is contained in the health advisory. A sample health advisory is included in Appendix D. As stated earlier, the DHHS medical officer is consulted prior to the issuance of a health advisory. The specific language included in the advisory is dependent on the nature of the event.


## Abatement or Minimization of Contributing Controllable Sources of PM

- 10 In order for an exceedance to be flagged as a high wind

- caused natural event, the EPA nat ural events policy requires that (1) the dust originated from nonanthropogenic sources, or (2) the dust originated from anthropogenic sources controlled with best available control measures (BACM). Based on observations made during this event and other si milar high wind events in Anchorage, some portion of the PM

- 10 is assumed to be anthropogenic or “man

- caused.”

PM

- 10 concentrations in Anchorage typically peak in the late March and early April. 7 

### Relatively warm daytime temperatures melt ice and snow from roadsides and gutters. As melting occurs, large amounts of dirt and silt from five or six months of winter road sanding and roadway abrasion become exposed along roadway margins. This material, previously locked under ice and snow now becomes available for re

entrainment into the air by passing vehicle traffic or by high winds. This process is illustrated in the two photographs below, taken six days apart on March 16 th 

### and March 22 nd 

### of 2000.

### Adopted August 20 th 

### , 2010 Figure 3(a). Minnesota Drive, March 16, 2000. Ice covers most of roadway margin.

Figure 3(b). Minnesota Drive, March 22, 2000. Receding ice reveals accumulated silt along roadway margin.

### Adopted August 20 th 

### , 2010

The photographs show conditions typical for the late winter. (These photos were taken about the same time of the year as the Muldoon PM

- 10 exceedance but one

year earlier.) Unless there has been a recent snowfall, the majority of the road surface is bare pavement with margins covered in ice. While the traveled portion of the road is relatively clean, large quantities of sand and silt can be found along roadway margins. This material becomes available for re

- entrainment as the ice recedes and the exposed silt and dirt dry out. A number of source apportionment studies have been conducted in Anchorage in an effort to distinguish natural sources like windblown glacial silt and volcanic ash from anthropogenic sources like applied winter traction sand and roadway aggregate. 8

, 9

, 10 

### Because the natural and anthropogenic sources of PM

- 10 are chemically and morphologically similar, these studies have not been very successful in quantifying their relative contribution in past exceedances. For this reason, filter an alysis was not performed for the March 18, 2001 event. Nevertheless, given the amount of road silt available for re

- entrainment prior to the exceedance, it seems likely that this anthropogenic source was contributory to the exceedance. iv

iv Other potential anthropogenic sources like wind blown dust from unvegetated vacant lots and gravel pits were excluded as significant contributors because they were covered in snow during the exceedance. According to observations at the NWS Station at Point Campbell, two inches of snow were on the ground during the exceedance. 

### As such, the natu ral events policy states that this source must be controlled by BACM. The EPA has not defined BACM for this source, however. In this case, because BACM is undefined, the natural events policy requires that “practical mitigating measures” be identified,

s tudied and implemented. The next section of this plan discusses the identification,

### Adopted August 20 th 

### , 2010 study and implementation of measures designed to control PM

- 10 emissions from accumulated silt along major roadways in Anchorage. 

# Identification, Study and Implementation of Practical Mitigating Measures The time sequence of the two photographs in Figure 3(a) and (b) illustrates the difficulty Anchorage faces in developing effective and economical strategies to control PM

- 10 during the late

- winter and early spring “break

- up ” period. These two figures show that large amounts of roadway silt, previously covered by ice and snow, can be made available for re

- entrainment into the air as PM

- 10 in a matter of a few days through daily melting. Under high winds and/or very dry, low humidity conditions, re

- entrainment of this material can result in exceedances of the PM

- 10 standard. The challenge is to develop strategies that can remove or stabilize this material promptly after it is exposed so that it cannot be re

- entrained. As noted in the previous section, Anchorage experiences its highest PM

- 10 concentrations during this three or four

- week break

- up period, typically occurring in late

- March and early

- April. Although high winds sometimes contribute to the elevated PM

- 10 concentrations during this break

- up period, high PM

- 10 is more commonly associated with calm and dry conditions when fast moving vehicular traffic along major roadways stirs up accumulated silt on roadway margins. In late 1995 the Municipality of Anchorage, the Alas ka Department of Environmental Conservation and Department of Transportation and Public Facilities (ADOT&PF) entered into a Memorandum of Understanding (MOU) to cooperatively address the PM

- 10 problem in Anchorage. 11



### 1. Street sweeping; Prior to the MOU, Anchorage had experie nced a number of exceedances of the PM

- 10 NAAQS. In the MOU the municipality agreed to evaluate potential PM

- 10 control measures. Over the past six years, DHHS has worked with municipal and state street maintenance and private consultants in an effort to identify and study appropriate control measures. Although this effort has focused on controlling PM

- 10 generated by vehicular traffic, study results are likely applicable in high wind events like that of March 18, 2002. Over the past six years, efforts have focused on the evaluation of three potential PM

- 10 control strategies. These three strategies are:

2. Changes to winter sanding specifications and application methods;

3. Use of chemical deicing compounds as dust palliatives to reduce re

en trainment of roadway silt material. A brief discussion of each of these strategies follows. Street Sweeping

In the “lower

- 48,” street sweeping is probably the most commonly adopted control strategy for controlling PM

- 10 emissions from paved roads. Many communities adopt winter

- long sweeping programs to prevent the accumulation of the roadway silt as a source of PM

- 10.

### Adopted August 20 th 

### , 2010 Because of its proximity to Cook Inlet, Anchorage experiences relatively mild winter temperatures, similar to many of the colder “snow belt” communities in the lower

- 48. However, despite similar or colder temperatures, these lower

- 48 communities

, because of their lower latitude, receive ten to fifteen times more solar energy per day than Anchorage. Figure 4. Solar Insolation in Anchorage, Winnipeg and Denver in December

In lower

- 48 communities, because of the relatively higher intensity of the solar radiation received, wintertime sunny periods result in significant melting. During these melting periods, accumulated silt is washed off the roadway, reducing the overall silt loading. Moreover, the ice and snow along roadway shoulders and margi ns are largely eliminated, allowing the roadway to be completely swept.

Mid

- winter melt

– off periods are rare in Anchorage. Sunny days result in little or no melting. Ice and snow remain on roadway shoulders and margins making effective sweeping difficult. Large amounts of traction sand and silt accumulate in the ice along the roadway margins throughout the winter until March, when solar intensity is sufficient to generate melting. v



### Sub

- freezing temperatures make sweeping in winter very difficult. When this occurs, large amounts of material are made available in a very short time for PM

- 10 generation.

vi

v In Anchorage, the amount of solar insolation increases by a factor of 20 between December and March. 

### Most sweeping equipment requires pre

- wetting of the road surface to minimize the amount of dust created during the sweeping operation. Moreover, water flushing of the road surface is necessary after sweeping to eliminate residual fines leftover from the sweep. Without flushing, sweeping may actually increase PM

- 10 emissions in the short term

vi In March, the average daily maximum temperature is 33 **°** F; the minimum is 18 **°** F.

### Adopted August 20 th 

### , 2010
because material located in roadway margins is redistributed to the traveled portion of the road. 12


### Despite obstacles to sweeping created by sub

- arctic winter climate, sweeping is performed in the downtown Anchorage central business district (CBD). Winter sweeping in the CBD is viable because of the intensive use of roadway deicers that prevent the buildup of ice and snow in gutters that would otherwise prevent effective sweeping. Moreover, in order to perform sweeping in winter months, municipal road

crew s wet sweep using potassium acetate brine to prevent freezing. Extending this sweeping program to all roads in Anchorage would be cost prohibitive, however. Water flushing in sub

- freezing temperatures is inadvisable.

In 1997 the ADOT&PF purchased an EnviroWhirl **** sweeper with baghouse technology that allows sweepin g without the pre

- wetting required with most other sweeping technologies. Although this sweeper has been successfully operated in the middle of winter, its effectiveness as a PM

- 10 control strategy in Anchorage is limited because most of the accumulated s ilt on the road cannot be removed by sweeping because it is locked within a thick layer of ice along the roadway margins. The ADOT&PF recently decommissioned the EnviroWhirl because they found it to be inefficient and resulted in high operating costs.

Des pite the practical limitations alluded to above, the Municipality of Anchorage and the ADOT&PF have begun work on an agreement that would expedite street sweeping on major roadways in the early spring. Early sweeping of major roadways could be effective means of reducing the severity of PM

- 10 episodes during the peak of the spring break

- up in April. If some sweeping of major roadways can be accomplished in February and March through the use of deicing compounds, it may also be possible to reduce the magni tude of PM

- 10 episodes resulting from late

winter windstorms like the one that occurred on March 18, 2000.

Changes to Winter Sanding Specifications and Application Methods In response to commitments in the MOU with the EPA, the Municipality of Anchorage and the ADOT&PF made significant changes to winter sanding specifications and application methods. The amount of fines or silt (amount passing 200 sieve) allowed in traction sand dropped from about 5% to 1% or less. Municipal and state street maintenanc e departments also made changes to reduce the amount of sand applied during the winter. Work crews apply traction sand together with a magnesium chloride brine to help the traction sand melt into the ice or snow pack and reduce its tendency to be thrown off the road by passing traffic. This reduces the need for reapplication and presumably reduces the amount of material accumulated along roadway margins. Supervisors have also discouraged the excessive use of sand by work crews. PM

- 10 concentrations drop ped significantly after these changes were implemented. Whether this was the effect of the sanding specifications or other factors cannot be definitively determined. Nevertheless, the municipality and ADOT&PF are committed to retaining the new, cleaner s anding specifications and will continue with the judicious application of sand. As stated earlier, in the downtown or CBD, the municipality is using potassium acetate deicers in lieu of traction sand throughout the winter. In 1998, DHHS worked

### Adopted August 20 th 

### , 2010 with the ADOT&PF to evaluate whether a similar deicing program on state roads would provide a

PM

- 10 reduction benefit . The hope was that by applying deicing compounds instead of sand, spring break

- up silt loadings and hence PM

- 10, would be reduced. However, when ambient PM

- 10 concentrations near roads where deicing compounds were used were compared to roads where traction sand was applied, no differences were observed. 13


### The testing of magnesium chloride was continued to see whether its use instead of traction sand would decrease the accumulation of roadway silt. Curiously, the study indicated that there was no significant difference in silt loadings between roads that received deicing compounds versus roads where traction sand was applied. While the testing did not show a decrease in silt accumulation on deicer treated roads, laboratory evaluation suggested that the silt material left on the deicer treated road was less prone to re

- entrainment, presumably due to the palliative effect of applying hygroscopic magnesium chloride on the accumulated silt. Dustiness tests showed that the material along the treated roads was 75% less dusty than the untreated roads. 14


### These studies suggest that the value of deicing compounds lies more in their dust palliative effect than in reducing the amount of traction sand applied to the road. The next section discusses the DHHS effort to evaluate the use of deicers as dust palliatives to control the emission of dust from accumulated silt on paved roadways. Use of Chemical Deicing Com pounds as Dust Palliatives to Reduce PM

- 10 Emissions on Paved Roads Over the past few years, DHHS has focused efforts on the use of deicing compounds like magnesium chloride and potassium acetate as dust palliatives during PM

- 10 episodes. Local studies have suggested that it may be possible to chemically stabilize accumulated roadway silt by applying deicing compounds. Magnesium chloride and potassium acetate are both hygroscopic meaning they tend to bind with moisture. A local study conducted by DHHS in April 1999 suggested that a single application of magnesium chloride brine reduced ambient PM

- 10 concentrations near the roadway for approximately three days. 15


### DHHS is continuing its testing of dust palliatives. While initial test results look promising, a number of important questions remain unanswered. The effectiveness of dust palliatives in a high wind event is unknown. DHHS observations suggest that when dust palliatives are applied to dry silt along a paved roadway, the liquid brine penetration is superficial, perhaps just a few millimeters. Significant mechanical disturbance from a high wind may be sufficient to overwhelm the thin stabilized outside layer of the silt pile. Once the surface layer is eroded, the remainder of the material is untrea ted and prone to re

- entrainment. Investigation into the use of hygroscopic chemicals as dust suppressants is ongoing. A section of parking lot with accumulated traction sand has been cordoned off, divided into three sections, and the pavement cleaned between the sections. Magnesium chloride will be applied to one section, potassium acetate to another, and the third will be treated with water as a control. A leaf blower will be used to simulate a high wind/blowing dust event on the dried control section and observers will

### Adopted August 20 th 

### , 2010
compare the dust raised there to the sections where the deicing compounds have been applied. This testing has been hampered so far by rain this spring and is expected to be completed by November 10, 2002, when cold dry weather mimics spr ing conditions. The intent of the test is to determine whether the application of magnesium chloride or potassium acetate on accumulated silt in the gutters and roadway margins will suppress dust from that source until the streets are free of ice and can be effectively swept. Other researchers have questioned the safety of applying deicing compounds to dry pavement. Under low humidity conditions, application can create a slippery condition that could compromise traffic safety. 16



# Periodic Reevaluation of the Natural Events Action Plan Indeed, in the April 1999 test of magnesium chloride, DHHS received reports of a “greasy” condition on the road. A motorcyclist was reported to have had a near miss when attempting a stop at a treated intersection. The slippery conditions may have arisen because of over

- applicati on of the magnesium chloride brine. The brine was reportedly applied at three times the recommended rate. It was also applied across the entire roadway rather than just the roadway margins where the silt had accumulated. Whether these potential problems are real and/or can be overcome by special deicer application methods (e.g. applying deicers only to the roadway margins) is yet to be determined. Further investigation is required before the municipality can commit to the use of chemical palliatives as a PM

- 10 control measure on paved roads.

The EPA natural events policy requires periodic reevaluation of the conditions causing violations of the PM

- 10 NAAQS, the implementation status of the NEAP, and the adequacy of the actions being implemented. Upon completion of the control measure evaluation discussed in the preceding section, DHHS in cooperation with ADEC, will update this plan to reflect the results of the evaluation. Subsequently, this plan will be reviewed every five years or as

- required to reflect new information and new understanding regarding the nature of the PM

- 10 problem and the effectiveness of the strategies used for control.

### Adopted August 20 th 

### , 2010 

# References

1 

### Memorandum f rom Mary Nicholls, Assistant Administrator for Air and Radiation, regarding “Areas Affected by PM

- 10 Natural Events,” May 30, 1996

2 

### “Guideline on the Identification and Use of Air Quality Data Affected by Exceptional Events,” EPA

- 450/4

- 86

- 007, July 1986

3 

### Gordian, Ozkaynak, Xue, Morris, Spengler, “Particulate Air Pollution and Respiratory Disease in Anchorage, Alaska,” Environmental Health Perspectives, 104(3), 290 (March 1996)

4 

### Choudhury, Gordian, Morris, “Associations between Respiratory Illness and PM

- 10 Air Pollution,” Archives of Environmental Health, 52 (2),113 (March/April 1997)

5 

### Air Quality Criteria for Particulate Matter, EPA/600/P

- 95

- 001, April 1996

6 

### Guideline for Public Reporting of Daily Air Quality, EPA

- 454/R

- 99

- 009, July 1999

7 

### “Air Qualit y in Anchorage – A Summary of Air Monitoring Data and Trends (1980 – 1999),” Air Quality Program, Department of Health and Human Services, Municipality of Anchorage, May 2000

8 

### L.C. Pritchett, J.A. Cooper, Aerosol Characterization Study of Anchorage, Alask a, Final Report to the Municipality of Anchorage by NEA, Inc., Beaverton, OR, February 7, 1985.

9 

### J.A. Cooper, L. Valdovinos, J. Sherman, Source Apportionment by Chemical Mass Balance Technique of PM 10 

### in Eagle River and Juneau, Alaska, Final Report to the Alaska Department of Environmental Conservation by NEA, Inc. Beaverton, OR, May 23, 1988

10 

### E.R. Crutcher, Source of Particles on PM 10 

### Filters, Report #1062

- 94 to the Anchorage Air Pollution Control Agency by Microlab Northwest, Redmond, WA, October 17, 1994

11 

### Memorandum of Understanding between the United States Environmental Protection Agency, the Alaska Department of Environmental Conservation, the Alaska Department of Transportation and Public Facilities, and the Municipality of Anchorage, “A Cooperative Approach Toward Reducing PM

- 10 in Anchorage,” November 1995

12 

### “Compilation of Air Pollutant Emission Factors,” Section 13.2.1, Paved Roads, United States Environmental Protection Agency, October 1997

13 

### “Evaluation of Liquid Magnesium Chloride for Paved Roadway Control in Anchorage,” Air Quality Program, Department of Health and Human Services, Municipality of Anchorage, October 1999

14 

### “Evaluation of Magnesium Chloride Brine for Paved Roadway PM

- 10 Control in Anchorage, Final Report,” prepared by Midwest Research Institute for the Municipality of Anchorage, February 15, 2001

15 

### “Evaluation of Liquid Magnesium Chloride for Paved Roadway Control in Anchorage,” Air Quality Program, Department of Health and Human Services, Municipality of Anchorage, October 1999

### Adopted August 20 th 

### , 2010

16 

### “The Effect of Magnesium Chloride as an Anti

- icing Agent on Tire/Road Friction Coefficient,” Timothy S. Leggett, Eric Brewer, March 24, 1999

# Alaska Department of Environmental Conservation

Amendments to State Air Quality Control Plan

Volume III: Appendices

“ Quality Assurance Project Plan for the State of Alaska Air Monitoring & Quality Assurance Program”



# Adopted

August 20 th 

# , 20101 

## QUALITY ASSURANCE PROJECT PLAN

for the

STATE OF ALASKA

AIR MONITORING & QUALITY ASSURANCE PROGRAM

Febru ary 23 , 20 10

State of Alaska Department of Environmental Conservation 410 Willoughby Ave. Suite 303 PO Box 111800 Juneau, Alaska 99811

- 180023 

# A. PRO JECT MANAGEMENT ELEMENTS45 

### 1. 

## QA PROJECT PLAN IDEN TIFICATION & APPROVAL

Title: Quality Assurance Project Plan for the State of Alaska Ambient Air Quality Monitoring Program The attached Quality Assurance Project Plan for the State of Alaska Ambient Air Quality Monitoring Program is hereby recommended for approval and commits the Alaska Department of Environmental
Conservation to follow the elements described within

.

Alaska Depart ment of Environmental Conservation



### Alice Edwards, Acting Director Phone: (907) 465-5109 Division of Air Quality email: alice.edwards@alaska.gov

Signature: _______________________________ Date:

______________

Barbara Trost , Program Manager Phone: (907) 269-6249 Air Monitoring & Quality Assurance Program email: barbara.trost@alaska.gov

Signature: _______________________________ Date:

______________ Daniel Fremgen, QA Officer Phone: (907) 465-5111 Air Monitoring & Quality Assurance Program email: daniel.fremgen@alaska.gov

Signature: ______________________________ Date:

______________ Gina Grepo -Grove, R10 QA Manager Phone: (206) 553-1632 USEPA Region 10 email: grepo

- grove.gina@epamail.epa.gov

Signature: ______________________________ Date:

______________ Keith Rose, Air Monitoring Program Manager Phone: (206) 553-1949 USEPA Region 10 email: rose.keith @epamail.epa.gov

Signature: ______________________________ Date:

______________67 

### T ABLE OF CONTEN TS

Section P age Revision # Date

1. QA Project Plan Identification & Approval 5 Final 02/23/10

2. Table of Contents 7

List of Tables 8 List of Figures 9
Abbreviations, Terms and Definitions 10

3. Distribution List 12

4. Project/Task Organization 13

5. Problem Definition and Background 21

6. Project/T ask Description 23

7. Quality Objectives and Criteria for Measurement Data 28

8. Training 35

9. Documents and Records 38

10. Sample Process and Design 40

11. Sampling Methods 47

12. Sampling Handling and Custody 55

13. Analytical Methods 56

14. Q uality Control (QC) 63

15. Procurement, Acceptance Testing and Maintenance
Requirements for Instruments, Supp lies and Consumables 67

16. Instrument Cali bration and Frequen cy 68

17. Inspection/Acceptance for S upplies and Consumables 75

18. Data Acqu isition Requirements 76

19. Data Management 77

20. Assessments and Corrective Action 86

21. Repor ts to Management 95

22. Data Review Validation and V er ification Requirements 97

23. D ata Verification a nd Validation Methods 99

24. Reconc iliation wit h User Requirements 1048 

### LIST OF TABLES

Section Page Revision # Date

A1 DISTRIBUTION LIST 12 Final 02/23 /10
A2 AIR M&Q A RESPONSIBILITIES 15

- 20
A3 ALASKA AMBIENT AIR QUALITY STANDARD S 24
A4 METEOROLOGICAL PARAMETERS 25
A5 ASSESSMENT SCH EDULE 27
A6 CRITICAL DOCUM ENTS AND RECORDS 27
A7 ALASKA AMBIENT AIR QUALITY MONITORING MQO’S 31

- 32
A8 ALASKA METEOROLOGICAL MONITORING M QO ’ S 33- 34
A9 SUGGESTED CORE AMBIENT AIR MONITORI NG
TRAINING COURSES 36
A10 SUGGESTED TRAINING COURSES FOR
AIR MONITORING PERSONNEL 37
A11 REPORTING PACKAGE INFORMATION 38

B1 AIR QUALITY & METEOR OLOGICAL SAMPLE
PROCESS & DESIGN DOC UMENTS 40

- 41
B2 DESCRIPTION OF REPRESENTATIVE
MEASUREMENT SCALE 42
B3 RELATIONSHIP AMONG MONITORING OBJ ECTIVES
AND SCALES OF REPRES ENTATIVENESS 42
B4 SPATIAL SCALES APPRO PRIATE FOR NCORE LEV EL 2 SLAMS, SPM MONITORIN G SITES 43

B5 ALASKA NCORE LEVEL 2 and SLAMS/SPM
MONITORING NETWORK 46
B6 TABLE B6 ENVIRONMENTAL CON TROL PARAMETERS
FOR MONITORING SHELT ERS 47-48
B7 GUIDELINES FOR SAMPLE PROBE & MANIFOLD
PLACEMENT 49
B8 SUMMARY OF REPRESENT ATIVE PROBE AND
MONITORING PATH SITI NG CRITERIA 50
B9 M INIMUM SEPARATION DISTANCE BETWEEN
SAMPLING PROBES AND ROADWAYS 51
B10 LABORATORY QC CRITER IA FOR ANALYSIS OF
PM2.5 & PM10 LOW

- VOL FILTERS 59

- 60
B11 LABOR ATORY QC CRITERIA FO R ANALYSIS OF
PM10 HI

- VOL FILTERS 61

- 62

C1 BIAS ASSESSMENTS 91-92
C2 PRECISION ASSESSM ENTS 93
C3 REPORTS TO MANAGE MENT 959 

### LIST OF FIGURES

Section Page Revision # Date

A1 ORGANIZATIONAL STRUCTURE OF THE ADEC AIR
MONITORING & QUALITY ASSURANCE PROGRAM 14 FINAL 02/23 /10

B1 MONITORING SITE SELE CTION PROCESS 45

B2 ACCEPTABLE AREAS FOR PM10 AND PM2.5 MICRO , MIDDLE,

NEIBHBORHOOD & URBAN MONITORS EXCEPT FOR

MICROSCAL E STREET CANYON SITES 52

B3 QUALITY CONTROL & QU ALITY ASSESSMENT’S

RELATIONSHIP WITHIN THE AMBIENT AIR & ME TEOROLOGICAL
MONITORING QUALITY ASSURANCE PROGRAM 64

B4 QUALITY CONTROL’S RELATIONSHIP TO ROUTIN E

ACCEPTANCE OF DATA 65

B5 HIERARCHY OF CALIBRATION STAND ARD(S) 69

B6 AM&QA DATA MANAGEMEN T FLOW CHART

NCORE/SLAMS/SPM 78

B7 AM&QA DATA MANAGEMEN T FLOW CHART – AMBIENT

AIR & METEOROLOGICAL MONITORING CONDUCTED

BY STATIONARY SOURCE FOR REGULATORY

PERMITTING NEEDS 79

B8 DATA MANAGEMENT OF M ANUAL METHODS 81

B9 DATA MANAGEMENT OF C ONTINUOUS METHODS 81

D1 DATA VERIFICAT ION METHODS 100

D2 DATA VALIDAT ION PROCESSS 10210 

### ABBRE VIATIONS, TERMS AND DEFINITIONS

AAQP - Anchorage Air Quality Program- Air quality monitoring in Anchorage is the responsibility of the Air Quality Program. This program is part of the Environmental Services Division of the Department of Health and Human Services , Municipality of Anchorage.

ADEC - Alaska Department of Environmental Conservation - The department of state government with primary responsibility for manageme nt and oversight of provisions of the Clean Air Act, including EPA’s National Ambient Air Quality Standards.

Air Quality Index (AQI) - The AQI is an index for reporting daily air quality and what associated health concerns the public should be aware of. T he AQI focuses on health effects that might happen with in a few hours or days of breathing polluted air. The AQI rates the air quality in 6 steps from good to hazardous.

AM&QA – Air Monitoring and Quality Assurance Program of ADEC - Responsible for coordi nating all aspects (quality assurance, data collection, and data processing) with respect to ambient air quality and meteorological monitoring of the ADEC Division of Air Quality.

BAM 1020 - Met -One Inc. Beta Attenuation Monitor model 1020 continuous monitoring sampler - This sampler can sample for course and fine particulate matter.

Criteria Pollutant - Any air pollutant for which the EPA has established a National Ambient Air Quality Standard for regulation under the Clean Air Act

.



### Coa rs e particulate matter - PM10 - P articulate matter less than or equal to 10 microns in size.

Fine particulate matter - PM2.5 - P articulate matter less than or equal to 2.5 microns.

Performance Audit - An audit of one or more monitors within a monitoring n etwork using certified calibration standards to evaluate monitor accuracy. Performance audits are conducted by an independent auditor using calibration standards provided by the auditor rather than those that are used for routine precision and accuracy ch ecks. ADEC provides regular performance audits for each criteria pollutant monitored by the AAQP.

NAMS - National A ir Monitoring S tation - The NAMS are a subset of the SLAMS network wi th emphasis on urban and multi- source areas. There are no current NAMS -designated monitors in the monitoring network.

National Performance Audits - A type of audit in which quantitative data generated in a measurement system are obtained independently and compared with routinely obtained data to evaluate the proficienc y of an analyst or laboratory or measurement system. EPA conducts these audits through the National Performance Audits Program for the purpose of establishing nationally comparable measurements.11 

### QAPP - Quality Assurance Project Plan - A plan which iden tifies data quality goals and identifies pollutant- specific data quality assessment criteria.

QAMP - Quality Assurance Management Plan - A plan which describes the roles and responsibilities for maintaining a Quality System within a program or organizati on.

SLAMS - State and Local Monitoring S tation - The SLAMS consist of a network of roughly 4000 monitoring station nationwide. Distribution depends largely on the needs of the State and local air pollution control agencies to meet their respective State Implementation plan (SIP) requirements. The SIPs pr ovide for the implementation, maintenance and enforcement of the NAAQS in each air quality control region with in a state. The State of Alaska monitoring network currently has 13 SLAMS sites for carbon monoxide and PM.

SPMS - S pecial Purpose Monitoring St ation - Special Purpose monitoring stations are not permanently established and can be adjusted to accommodate changing needs and priorities for special studies needed by the State and local agencies. The SPMS are used to supplement the fixed monitoring ne twork as circumstances require.

System Audit - An evaluation of an entire monitoring program including guidance documents, policies and procedures, data and site records, and components of the monitoring network.

TEOM – FDMS - Thermo Election Inc. Tapered Element Oscillating Microbalance Filter Dynamic Measurement System continuous monitoring sampler - This sampler can sample for coarse or fine particulate matter.

**μ** g/sm 3



### - microgram per standard cubic meter.12 

### 3. DISTRIBUTION LIST

A hardcopy of this Quality Assurance Project Plan for the State of Alaska PM 2.5 Ambient Air Quality Monitoring Program
has been distributed to the individuals list ed in Table A 1. The document is also available via the Department’s Division of Air Quality, Monitoring & Quality Assurance Program web page ( http://www.state.ak.us/dec/air/am ).



## Table A1: Distribution List

NAME POSITION AGENCY DIVISION/BRANCH CONTACT INFORMATION

Alice Edwards Acting Division Director ADEC

- AQ Division Air Quality 907

- 269

- 5109
alice.edwards@alaska.gov

Barbara Trost Program Manager DEC

- AM&QA Air Monitoring & Quality Assurance Program 907

- 269

- 6249
barbara.trost@alaska.gov

Robert Morgan Section Manager DEC

- AM&QA Air Monitorin g 907

- 269

- 3070
bob.morgan@alaska.gov

Daniel Fremgen Air QA Officer DEC

- AM&QA Quality Assurance 907

- 465

- 5111
daniel.fremgen@alaska.gov

Cy nthia Heil Acting Program Manager DEC

- ANPMS Air Non

- Point Mobile Sources 907

- 269

- 7579
cindy.heil@alaska.gov

John Kuterbach Program Manager DEC

- AP Air Permits 907

- 465

- 5103
john.kuterbach@alaska.gov

Steve Morris Program Manager MOA

- DHHS Air Quality Programs 907

- 343

- 6976
morrisss@ci.anchorage.ak.us

Dr. James Conner Division Manager FNSB

- DOT Air Quality Division 907

- 459

- 1325
jconner@co.fairbanks.ak.us

Chris Hall Air QA Lead EPA

- Region 10 Office of Environmental Assessment 206

- 553

- 0521
hall.christopher@epamail.epa.gov

Keith Rose Project Officer EPA

- Region 10 Office of Air , Waste & Toxics 206

- 553

- 1949
rose.keith@epamail.epa.gov

Gina Grepo

- Grove QA Manager EPA

- Region 10 Office of Environmental Assessment 206

- 553

- 1632

grepo

- grove.gina@epamail.epa.gov13 

### 4. PROJECT/TASK ORGANIZATION

This document presents the Quality Assurance Project Plan (QAPP) for the A mbient Air Monitoring and Quality Assurance Program that has been implemented by the State of Alaska. The monitoring program is being administered by the Alaska Department of Environmental Conservation (ADEC ). The major responsibility of the ADEC is the implementation of a satisfactory monitoring program which includes an appropriate quality assurance program. It is the responsibility of the ADEC to ensure that the quality assurance programs for the field, laboratory, and data processing phases of the monitoring program are implemented.

The ADEC is organized into five main divisions: Division of Administrative Services (DAS), Air Quality (AQ), Environmental Health (EH), Water Q uality (WQ ) and Spill Prevention and Response (SPAR). The Commi ssioner of the ADEC has the overall responsibility for managing these divisions according to stated ADEC policy. The Commissioner delegates the responsibility of QA development and implementation in accordance with ADEC policy to the Division
Directors. The responsibility for assuring data quality rests with these Directors and the line management under them.

The organizational structure of the ADEC Division of Air Quality for the implementation of the Ambient Air Quality Monitoring Program is shown in F igure A1

. Table A2 lists the specific responsibilities of each significant position within the ADEC Ambient Air Quality Monitoring Program.14 FNSB

– DOT Division Air Quality SLAMS/SPM Projects

Management Direction Data Reporting QA Assessment/Reporting Inter

- Government Technical Assistance Tribal Monitoring Data Reporting 

### Figure A1: Organizational Structure of the ADEC Air Monitoring & Quality Assurance Program

ADEC Division of Air Quality Director

ADEC AM&QA Program Manager

ADEC AM&QA Air Monitoring Manager ADEC AM&QA Air QA Officer

Permit & Compliance Ambient Air & Meteorological Monitoring Projects PSD Quality

ADEC Air Permits Program Manager

MOA

- DHHS

, A nchorage

Air Pollution Control Authority SLAMS/SPM Projects Tribal Air Monitoring Projects AM&QA SLAMS/SPM Projects 

### US EPA

AQSADE C AM&QA QAPP Revision : Final Date: 02 / 23/2010

15 

### Table A2: ADEC Division of Air Quality – Air Monitoring & Quality Assurance Organizational Responsibilities

Agency Division Program Position Title Responsibilities

ADEC Air Quality Director The Division of Air contains the Air Monitoring & Quality Assurance (AM&QA) Program. The AM&QA Program is responsible for coordinating all aspects (quality assurance, data collection, and data processing) with respect to ambient air quality and meteorological monitoring of the ADEC Division of Air Quality.
The Division Director has direct access to the Commissioner on all matters relating to the Division’s operation. The Division Director’s duties include:

**•** Maintains oversight of QA activities of AM&QA;

**•** Maintains overall responsibility for monitoring network design & review;

**•** Maintains overall responsibility for certifying and approving data submitted to AQS; and

**•** Reviews budgets, contracts, grants and proposals.

ADEC AM&QA Program Manager The A ir M onitoring Program Man ager reports directly to the AQ Division Director and has the overall responsibility for the development and maintenance of the Quality Assurance activities for the AM &QA program. Responsibilities
include:

**•** D irects the monitoring network design and review process;

**•** E nsures that reviews, assessments and audits are scheduled and completed at the appropriate times;

**•** E nsures that environmental data collection activities are cove red by appropriate QA planning documentation;

**•** D irects and assists in the implementation of QAPPs, work plans, contracts, reports and resource allocation, and ensures that monitoring personnel follow the QAPPs;

**•** E nsures that a QAPP is in place for all enviro nmental data collection activities and that it is up to date;

**•** C ommunicates with EPA Project Officers and EPA QA personnel on issues related to routine sampling and QA activities;

**•** P rovides program costs necessary for EPA allocation activities;

**•** P urchasing eq uipment and issuance of contracts necessary for the implementation of monitoring programs;

**•** E nsures that all personnel involved in environmental data collection have access to any training or QA information needed to be knowledgeable in QA requirements, protocols and technology; and

**•** R ecommends required management level corrective action.ADE C AM&QA QAPP Revision : Final Date: 02 / 23/2010

16 

### Table A2: ADEC Division of Air Quality – Air Monitoring & Quality Assurance Organizational Responsibilities

Agency Division Program Position Title Responsibilities

ADEC AQ AM&QA Environmental Program Specialist –

EPS IV (Meteorologist) Under general direction s of the AM&QA program manager, the EPS IV (Meteorologist) position functions as the sole staff meteorologist for ADEC enabling management to fulfill its duty to advise the public of air quality threats due to natural or man

- made pollution events that may have a broad scale geographical impact for Alaska’s health and environment. Respo nsibilities include:

**•** Routinely evaluate weather and air pollution conditions around the state and, as needed, forecast

, transport of air pollution to project how, where and when pollution will be transported from one part of the state to another. Pollution events that may require forecasting and subsequent issue of health advisories include; broad scale forest fires, volcanic eruptions, prescribed burns of large tracks of land, high wind events generating high concentrations of wind

- blo wn dust, and international incidents that transport pollution to Alaska from abroad;

**•** Work s in partnerships with federal, state land management agencies, communities and tribal organizations to assess local, regional and multi

- national scales of air polluti on;

**•** Provide s technical expertise to Air Permits Compliance staff in regard to when meteorological conditions are appropriate for issuance of open burn approvals ; and

**•** Review s /recommends/rejects approval (in coordination with the Air QA Officer) of PSD ambi ent air quality and meteorological monitoring project plans and data reports;

ADEC AQ AM&QA Air QA Officer (Chemist IV) Regarding matters of quality assurance, the Air Quality Assurance Officer (Air QA Officer) reports directly to the Air Quality Division Director. All other directives and reporting responsibilities are managed by the Air Monitoring & Quality Assurance Program Manager. Responsibilities include:

**•** Conducts QA performance and systems audits of NCore/ SLAMS/SPM monitoring networks in A laska;

**•** Develops and/or recommends for approval procedures for establishing and assuring data quality, use and control of

ambient air quality data;

**•** Recommends modifications to the Alaska Ambient Air Monitoring Quality Assurance Project Plan (QAPP) and to

Al aska’s Ambient Air Monitoring Quality Management Plan;

**•** Provides guidance and assists in the development of QAPPs;

**•** Recommends rejection/approval of ambient air and meteorological monitoring QAPPs;

**•** Provides training and certification to field and laboratory personnel;

**•** Recommends actions to be taken in response to unsatisfactory operation or maintenance of ambient monitors; and

**•** Assists air monitoring community in developing QA documentation and provides answers to technical questions.ADE C AM&QA QAPP Revision : Final Date: 02 / 23/2010

17 

### Table A2: ADEC Division of Air Quality – Air Monitoring & Quality Assurance Organizational Responsibilities

Agency Division Program Position Title Responsibilities

ADEC AQ AM&QA Air Monitoring

Section Manager
(Environmen tal Program Manager 1) Under the general direction of the AM&QA program manger, the Air Monitoring Manag er is responsible for the state

wide development, management and supervision of the field monitoring and laboratory section of the Air Monitoring and Quality Assurance Program. The primary focus of this position is to determine compliance with the national ambient air quality standards. To do this the manager and her/his staff:

**•** Develop air quality monitorin g plans to assess community

- wide air pollution levels on a pollutant/multi

- pollut an t basis;

**•** Evaluate regional air pollution (visibility, wild fire smoke impacts, regional haze);

**•** Oversee local air monitoring projects

**•** Conduct air quality studies to determine pollutant levels;

**•** Provide emergency monitoring of man

- made and/or natural air quality impacts (e.g., wild fires, volcanic eruptions);

**•** Assist in develop ment of air quality control plans and State Implementation Plan control strategies; and

**•** Manage budgetary, fiscal, accounting, procurement and personnel responsibilities necessary for successful

implementation of the section.

ADEC AQ AM&QA Environmental Program Specialists

(EPS)

, Chemists, Electronics Technician Under the supervision of the Air Monitoring Section Manager, these positions perform all of ADEC’s field monitoring and air laboratory operations. Specific duties include, but are not limited to:

**•** Collects , calculat es and review s of environmental data;

**•** Participate s in training and certification activities;

**•** Verif i es that required monitoring QA activities are performed and that measurement quality objectives are met as prescribed in the QAPP;

**•** Document s deviations from established procedures and methods;

**•** Reports all problems and corrective actions to the AM section manager and the Air QA officer;

**•** Assess es data quality and flagging suspect data;

**•** Prepares data reports for submission to the Air Quality System (AQS) database manager.

**•** Maintain s QA records, flagging suspect data, and assessing and reporting data quality; and

**•** Performs and document s maintenance of field and laboratory equipment.ADE C AM&QA QAPP Revision : Final Date: 02 / 23/2010

18 

### Table A2: ADEC Division of Air Quality – Air Monitoring & Quality Assurance Organizational Responsibilities

Agency Division Program Position Title Responsibilities

ADEC AQ AM&QA AQS Data Base Manager Under the supervision of the AM section manager, the AQS data base manager is responsible for:

**•** Coordinating the information management activities for N Core /SLAMS/SPM data entry;

**•** Verifying/reviewing data reliability prior to submission of AQS data to EPA; and

**•** Timely reporting and interpretation and ensuring time ly delivery of all required NCore/ SLAMS/SPM data to the

AQS system.

MOA DHHS AAPCA Air Quality Programs Manager Structure - The Municipality of Anchorage (MOA) maintains the Anchorage Air Pollution Control Agency (AAPCA) which conducts ambient air monitoring within the boundaries of the MOA. This agency is within the Department of Health and Human Services.
Responsibilities and Authority

**•** Monitor site preparation; – The State of Alaska has delegated responsibilities to MOA for air quality monitoring. A Memorandum of Understanding between authorities of both agencies formally delineates the responsibilities of each agency. It is the responsibility of AAPCA to conduct ambient air quality monitoring within the physical boundaries of the Municipality of Anchorage in accordance with the methods, procedures and criteria established within this document. Specifically, the AAPCA responsibilities include, but are not limited to:

**•** Instrument installation, operation, maintenance; corrective action(s);

**•** Data reduction, data validation and data reporting;

**•** Database management;

**•** Site de

- installation;

**•** Instrument inventory control and repair; an d

**•** Contract management.
In addition, the AAPCA will assist the ADEC in site selection/network reviews and quality assurance oversight auditing for ambient monitoring activities performed in the MOA.ADE C AM&QA QAPP Revision : Final Date: 02 / 23/2010

19 

### Table A2: ADEC Division of Air Quality – Air Monitoring & Quality Assurance Organizational Responsibilities

Agency Division Program Position Title Responsibilities

FNSB - DOT Air Quality Division Manager Structure - Fairbanks North Star Borough (FNSB) maintains the Air Quality Division within the Department of Transportation. The ADEC has delegated responsibilities for air quality monitoring to the FNSB. A Memorandum of Understanding between authorities of both agen cies has formally delineated the responsibilities of each agency.
Responsibilities and Authority – Responsibilities and Authority of the Air Quality Division are identical to those listed for the Municipality of Anchorage.

Tribal Air Monitoring Organizat ions Tribal Air Monitoring Support

**•** Development of project specific air monitoring QAPPs, – The ADEC Division of Air Quality provides monitoring assistance to Tribal Villages as funding allows in the same fashion as it does to other non

- tribal communities in Alaska (e.g., Anchorage, Fairbanks, and Juneau ). The Department provides direct monitoring assistance to villages receiving air monitoring funding through EPA Region 10 Air Tribal Programs. Technical assistance may include any of the following:

**•** Air mo nitoring equipment operations training,

**•** Air monitoring station site selections,

**•** Installation of monitoring sites,

**•** Instrument maintenance and repairs,

**•** Instrument calibrations and operations,

**•** Instrument performance and systems audits,

**•** Laboratory analysis o f air monitoring samples,

**•** Equipment loans,

**•** Data analysis.ADE C AM&QA QAPP Revision : Final Date: 02 / 23/2010

20 

### Table A2: ADEC Division of Air Quality – Air Monitoring & Quality Assurance Organizational Responsibilities

Agency Division Program Position Title Responsibilities

Independent Projects by Industry and Others Ambient air quality and meteorological monitoring is performed throughout the state by a variety of private and academic concerns. Monitoring projects directed by a Title I and/or Title V permit must meet the respective PSD quality criteria as set forth in the ADEC AM&QA QAPP and in the Ambient Monitoring Guidelines for Prevention of Significant Deterioration (PSD) EPA

- 450/4

- 87

- 007. Other monitoring projects beyond the direct review authority of the Department are not required to comply with the criteria set out in this document.
Prior to initiation of an independent monitoring project, a Quality Assurance Project Plan (QAPP) must be submitted to the Dep artment for review and approval. The QAPP must follow QAPP criteria as defined in, “Elements for Ambient Air Monitoring Quality Assurance Project Plan, Revision 1.1.” This document prescribes the required QAPP format and content for a Department appro ved QAPP and is available via the Department’s Division of Air Quality, Monitoring & Quality Assurance Program web page ( http://www.dec.state.ak.us/air/am ). The Department also prescribes the format, acceptance criteria and reporting frequencies for all data collected/reported in support of PSD quality ambient air and/or meteorological monitoring projects. These web

- linked documents are:
http://www.dec.state.ak.us/air/am/Elements_Ambient_Air_Monitoring_QAPP_rev1

- 1.pdf
http://www.dec.state.ak.us/air/am/Ambient_Air_Monitoring_QAPP_cklst_9

- 04.pdf
http://www.dec.state.ak.us/air/am/PSD_Met_annual.pdf
http://www.dec.state.ak.us/air/am/PSD_Met_qrtly.pdf

EPA OAQPS Responsibilities and Authority

EPA – The Office of Air Quality Planning and Standards ( OAQPS ) is charged under the authority of the Clean Air Act ( CAA ) to protect and enhance the quality of the nation’s air resources. OAQPS sets standards for pollutants considered harmful to public health or welfare and, in cooperation with EPA’s Regional Offices and the States, enforces compliance with the standards th rough state implementation plans (SIPs) and regulations controlling emissions from stationary sources. The OAQPS evaluates the need to regulate potential air pollutants and develops national standards; works with the State, local agencies and Tribes to de velop plans for meeting these standards; monitors national air quality trends and maintains a database of information on air pollution and controls; provides technical guidance and training on air pollution control strategies; and monitors compliance with air pollution standards.

Region 10 Responsibilities and Authority – EPA Regional Offices have been developed to address environmental issues related to the states within their jurisdiction and to administer and oversee regulatory and congressionally mandated programs. The major QA responsibilities of EPA’s Region 10 Of fice are the coordination of quality assurance matters at the Regional level with state, local agencies and T ribes. This is accomplished by the designation of EPA Regional Project Officers who are responsible for the technical aspects of the program.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

21 

### 5. PROBLEM DEFINITION AND BACKGROUND

5.1 Problem Statement and Background

Between the years 1900 and 1970, the emission of six principal ambient air pollutants increased significantly. The principal pollutants, also called criteria pollutants, are: particulate matter (PM), sulfur dioxide ( SO 2 ), carbon monoxide (CO), nitrogen di oxide ( NO 2 ), ozone (O 3 ) and lead (Pb). In 1970 the Clean Air Act (CAA) was signed into law. The
CAA and its amendments provide the framework for all pertinent organizations to protect air quality. This framework provides the structure for pertinent organ izations to protect air quality and for the monitoring for these criteria pollutants by State and local organizations.

Air quality samples are generally collected for one or more of the following purposes:

**•** To judge compliance with and/or progress made towa rds meeting the National Ambient Air Quality Standards (NAAQS) and Alaska Ambient Air Quality Standards (AAAQS).

**•** To develop, modify or activate control strategies that prevent or alleviate air pollution episodes.

**•** To observe pollution trends throughout the region, including non

- urban areas.

**•** To provide a database for research and evaluation of effects of air pollution.

With the end use of the air quality samples as a prime consideration, various networks can be designed to meet one of six basic monitoring obj ectives listed below:

**•** Determine the highest concentration to occur in the area covered by the network.

**•** Determine representative concentrations in areas of high population density.

**•** Determine the impact of significant source or source categories on pollution levels

.

**•** Determine general background concentration levels.

**•** Determine the extent of regional pollutant transport among populated areas, and in support of secondary
standards.

**•** Determine the welfare

- related impacts in more rural and remote areas.



### 5.2 Alaska’s Air Monitoring Network

The State of Alaska’s monitoring network consists of t hree major categories of monitoring stations that measure the criteria pollutants. These types of stations are described below:

1. Secondary National Core ( NCore Level 2 ) Multi

- Pollu tant Monitoring Station. Alaska will have one NCore
Level 2 that will be sited to meet NCore Level 2 monitoring station criteria

. The monitoring site is expected to
be located in Fairbanks; however, a specific site has not been selected yet. The site will be selected, sited and
installed after sufficient federal monies are allocated and made available to the AM&QA program.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

22 2. The State and Local Air Monitoring Stations ( SLAMS , NCore Level 3 ) network consi sts of monitoring stations
with size and d istribution largely determined by the needs of State and local pollution control agencies to meet their respective SIP requirements.

3. The Special Purpose Monitoring Stations ( SPMS ) network provides for special studies needed by the State and local agencies to support their State Implementation Plan (SIP s) and other air program activities. The SPMS are not permanently established and can be adjusted easily to accommodate changing needs and priorities. The SPMS are used to supplement the fixed monitoring ne twork as circumstances require and resources permit. If the data are used for SIP purposes, the data must meet all QA and methodology requirements for SLAMS monitoring.

This Quality Assurance Plan focuses on the QA activities of the NCore Level 2, SLAMS and SPM network and the objectives of this network, which include any air monitor/s used for comparison to the NAAQS and AAAQS. Since there is more than one objective for this data, the quality of the data will be based on the highest priority obje ctive, which is identified as the determination of violations of the NAAQS and AAAQS.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

23 

### 6. PROJECT/TASK DESCRIP TION

6.1 Description of Work to be performed

The Department is responsible for maintaining the quality of ambient air to protect the health and welfare of Alaskans. To facilitate the protection of public health and welfare from the effects of air pollution, the Department adopted the Alaska Ambient Air Quality Standards (AAAQS 18AAC50.010) which are equal to or more restrictive than the NAAQS. The AAAQS parameters and regulated concentrations are listed in Table A3

. Table A4 list s meteorological parameters the Department may monitor in support of characterizing the air quality of selective monitoring networks.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

24 

### TABLE A3

-- ALASKA AMBIENT AIR QUALITY STANDARDS ( 18 AAC 50.010)

Parameter 1- hour 3- hour 8- hour 24

- hour Quarterly Annual

(mg/m 3 ) (ppm) (mg/m 3 ) (ppm) (mg/m 3 ) (ppm) (mg/m 3 ) (ppm) (mg/m 3 ) (mg/m 3 ) (ppm)

Ammonia (NH 3 ) 2.1 3.0

Carbon
Monoxide (CO) 40 35 9.0 10

Nitrogen Dioxide (NO 2 ) 0.100 0.053

Ozone (O 3 ) 4 th high 3

- yr annual avg.

0.041 0.0 75

Sulfur Dioxide (SO 2 ) 1.300 0.497 0.365 0.139 0.080 0.031

(μg/m 3 ) 3- year 98% (μg/m 3 ) (μg/m 3 )

Lead (Pb) 0.15

PM 10 150

PM 2.5 35 15 .0ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

25 

### TABLE A4

-- METEOROLOGICAL PARAMETERS

Wind Speed (WS) Wind Direction (WD) Ambient Temperature (T) Temperature Difference (ΔT) Solar Radiation

(SR) Ambient Pressure (P) Dew Point Temperature Relative Humidity

(RH) Precipitation

With the end use of the air quality samples as a prime consideration, various networks can be designed to meet one of the basic monitoring objectives listed below:

**•** Determine/document the highest concentrations to occur in the area covered by the network;

**•** Determine/document representative concentrations in areas of high population density;

**•** Determine/document the impact on ambient pollution levels of significant source or source categories;

**•** Determine/document general background concentration levels;

**•** De termine/document the extent of r egional pollutant transport among populated areas, and in support of secondary standards;

**•** Determine/document the welfare

- related impacts in more rural and remote areas;

**•** Document existing air quality and air quality trends at selected locations of interest;

**•** Evaluate compliance with the NAAQS, AAAQS and increment standards after the start up of new air po llution

sources;

**•** In response to citizen complaints, investigate air quality degradation to determine the level of action required.

**•** Judge compliance with and/or progress made towards meeting the NAAQS and AAAQS;

**•** Maintain or improve the existing ambient air quality of Alaska;

**•** Develop, modify or ac tivate control strategies that prevent or alleviate air pollution episodes;

**•** Observe pollution trends throughout the region, including non

- urban areas; and

**•** Provide a data base for research and evaluation of effects.

When the Department or other entity deter mines that an air quality monitoring project is to occur, the responsible party
will:

**•** Survey the impacted area to identify the pollutant source/s.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

26 **•** Survey the impacted area to identify the aerial extent of the pro blem.

**•** Utilize appropriate dispersion modeling tools or other scientific or engineering principles to identify the zone/s of potential impact.

**•** Evaluate meteorological data t o identify maximum impact zones.

**•** Survey potential maximum impact areas to identify approp riate monitoring site locations.

**•** Conduc t air quality monitoring to reliably assess air quality conditions.



### 6.2 Field Activities and Measurements

Field activities and measurements include all field activities performed that support the collection of valid samples to assess air quality within Alaska’ s ambient air quality network. This includes but is not limited to problem identification, site selection, site installation/deinstallation, equipment calibration, sample and data collection and shipping.



### 6.3 Laboratory Activities

The AM&QA program includes an air quality laboratory that supports field moni toring activities throughout Alaska. Laboratory activities include repair of equipment, calibration and certification of various air quality standards and gravimetric analysis of particulate matter (PM) sa mpl e filters.

Gravimetric analysis of PM 10 and PM 2.5 samples include s preparing the filters for the routine field operator, which
includes t he following :

**•** Pre

- Sampling Weighing

**•** Shipping/Receiving

**•** Post

- Sampling Weighing

**•** Filter s torage /archival.

Standard Operating Procedures (SOPs) for particulate sample filter analyses are described in the respective ADEC Laboratory PM SOP and are available on the internet at http://www.dec.state.ak.us/air/am/index.htm

.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

27 

### 6.4 Project Assessment Techniques

An assessment is an evaluation process used to measure the performance or effectiveness of a system and its elements. As used here, assessment is an all

- inclusive term used to de note any of the following: audit, performance evaluation, management systems review, peer review, or inspection. Table A 5 presents a schedule of these assessments. Section 18 discusses the details of these assessments.


### Table A5 Assessment Schedule

Assessment Type Assessment Agency Frequency

Technical Systems Audit EPA Region 10/ADEC 1 every 3 years

Network Review EPA Region 10/ADEC Annual

Data Qualifiers/Flags Review ADEC Annual

SOP Review ADEC E very 3 years

Performance Evaluations EPA Region 10 5 valid audits/yr for primary QA orgs with ≤ 5 sites 8 vali d audits/yr for primary QA orgs with > 5 sites All samplers in 6 years Performance Audits ADEC SLAMS/SPM each site monitor every 6 months

Data Quality Assessment ADEC Annual



### 6.5 Project Records



### Table A6 Critical Documents and Records Categories Record/Document Types

Site Information Network description Site characterization file Site maps Site p ictures Environmental Data Operations QA Project Plans Standard operating procedures (SOPs) Field and laboratory notebooks Sample handling/custody records Inspection/maintenance records
Raw Data Any original data (routine and QC data) including data entry forms Data Reporting Air quality index report Annual NCore/ SLAMS /SPM air quality information Data/summary reports Data Management Data algorithms Data management plans/flowcharts Air m onitoring data Data m anagement s ystems Quality Assurance Network reviews Control charts Data quality assessments QA reports System audits Response/Corrective action reports Site a uditsADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

28 

### 7. QUALITY OBJECTIVES A ND CRITERIA FOR MEASUREMENT DATA

The ADEC will meet the QA/QC requirements outlined in 40 CFR Parts 50 and 58 or, where different, as described
with in this QAPP.



### 7.1 Data Quality Objectives (DQOs)

DQOs are qualitative and quantitative statements derived from the DQO Process that:

**•** Clarify the monitoring objectives.

**•** Define the appropriate type of data.

**•** Specify the tolerable levels of decision errors for the monitoring program.

By applying the DQO Process to the development of a quality system the Air Quality Program guards against committing resources to data collection efforts that do not support a defensible decision.

Data Quality Objectives are being developed by the EPA for a determination of whether or n ot a particular location meets the national ambient air quality standards. These data quality objectives are still in draft form. EPA decided that there should be a 5% (or less) chance of being wrong about whether a site meets or does not meet the standa rd. For example, if the true concentration is below the NAAQS but the measure d value is above. This may be due to measurement bias, imprecision, or incomplete data. The other possibility is that the true concen tration is above the NAAQS but the measurement is below. The general goal is to keep the rate of these decision errors (whether or not the
standard has been met ) to below 5%. In order to do this, EPA looked at all the data from the past few years in terms of bias and imprecision, and calculated that if each site keeps bias and precision under the pollutant specific values listed in
Table 7 , these overall goal s of limiting the decision error rate will be met. T he DQO subsequently were translated in to the measurement quality objective (MQO) for each parameter (Table 7) . This document does not describe how they
h ave been translated into MQOs.



### 7.2 Clarify Monitoring Objectives

The monitoring objectives for implementing the Air Quality Program are to:

**•** Determine ambient concentrations of criteria p ollutants.

**•** Determine compliance with the NAAQS for the criteria pollutants.



### 7.3 Define Appropriate Type of Data

In order to accomplish the monitoring objectives, the appropriate type of data needed is defined by the NAAQS. For criteria pollutants, compliance with the NAAQS is determined by specific measurement requirements. The measurement system is designed to produce criteria pollutant concentration data that are of the appropriate quantity and quality necessary to determine compliance with these standards

.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

29 

### 7.4 Specify Tolerable Levels of Decision Errors for the Monitoring Program

DQOs for criteria pollutant monitoring are based on data requirements of the decision maker(s). Regarding the quality of the measurement system, the objective is to control precision and bias in order to reduce the probability of decision

errors.



### 7.5 Measurement Quality Objectives (MQOs)

Once a DQO is established, the quality of the data must be evaluated and controlled to ensure that it is maintained within the established acceptance criteria. MQOs are designed to evaluate and control various phases (sampling, preparation, and analysis) of the measurement process to ensure that total measurement uncertainty is within the range prescribed by the DQOs. MQOs can be defined in terms of Precision, Bias, Representativeness, Detectability, Completeness and Comparability.

Bias – Bias is the systematic or persistent distortion of a measurement process that causes uncertainty in one direction. (e.g., results are either higher than or lower than they should be). It is estimated by evaluating the instrument measured result against a known standard used as the "true" value. It is expressed as a positive or negative percentage of the "true"
value. In this program, the manual quality control (QC) checks with a known concentration done every two weeks for gaseous pollutants, or monthly for particulate pollutants, will be the major estimate of bias on an ongoing basis, and the performance audits will p rovide another estimate of bias

. P erformance audit s of the monitoring equipment will be performed with personnel and equipment/standards completely independent from the standards used to calibrate the monitoring equipment and the personnel responsible for site operations. In this program, bias is estimated using the
calculations found in T able C1

.

Precision - Precision is a measure of mutual agreement among individual measurements of the same property usually under prescribed similar conditions, or how wel l side

- by

- side measurements of the same thing agree with each other. It is important that the measurements be as similar as possible, using the same equipment or equipment as similar as possible. Precision represents the random component of uncertainty. This random component is what changes randomly high or low, and which cannot be contro ll ed with the equipment and the procedures us ed . Precision is estimated by various statistical techniques using the standard deviation or, if you only have two measurem ents, the percent difference. In this program, precision is estimated using the calculations found in T able C2.

Accuracy – Accuracy has been a term frequently used to represent closeness to truth and includes a combination of precision and bias uncertainty components. This term has been used throughout the CFR. In gen eral, ADEC AM&QA will follow the conventions of the NIST and, more recently, of EPA (ref. NIST Report 1297 and EPA G

- 9) and will not use the term accuracy, but will describe measurement uncertainties as precision, bias, and total uncertainty (total uncertainty is the combination of both precisi on and bias). In this program, total error is estimated using the calculations
found in T able s C1 and C2

.

Representativeness - Representative ness is defined as a measure of the degree which data really represent some characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition. The representativeness of measurements made in this pr ogram is ensured by following EPA siting guidelines, and is fully explained in element 10. The goal is to measure the pollutant concentrations representative of what most people breathe in our many diverse population centers

-- microclimates throughout Alask a.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

30 De te ctability – D efined as the lowest value that a method procedure can reliably discern a measured response above background noise. In other words, detectability is th e level below which the instrument cannot reliably discriminate from zero. Because there is always variation in any measurement process (precision uncertainty), the level of detectability depends on how much precisio n error is in the process. D etection limits for ADEC

- M&QA air quality instruments are consistent with the requirements listed in 40 CFR 53. For Federal Reference Methods (FRM) and Federal Equivalent Methods (FEM), the detection limits are specified with the respective EPA FRM/FEM designation.

Completeness - Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under correct, normal conditions. Data completeness requirements are included in the reference methods (40 CFR 50) and 40 CFR 58 Appendix A

.

Comparability – Comparability is a measure of confidence with which one set of data can be compared to another. Comparability is important so that d ata sets within one part of the country can be compared with another area or data from another year.

Various parts of 40 CFR have identified acceptance criteria for some of these attributes as well as U.S. EPA Quality
Assurance Guidance Document s and additional DEC ambient air regulatory monitoring methods

. These Ambient Air Quality parameter MQOs are listed in Table A7

. Table A8 lists MQOs for meteorological parameters. More detailed descriptions of these MQO’s and how they will be used to control and assess measurement unc ertainty are described in method specific data val i dation tables. Method specific data validation tables may be found i n Appendix A

.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

31 

### Table A7 Alaska Ambient Air Quality Monitoring MQOs

Parameter Comparability Completeness Bias Precision Representativeness

Equipment Reference/ Method Hourly Daily Quarter Sampling
Frequency Siting

PM 2.5 FRM EPA PM 2.5 FRM sampler, EPA QA Handbook Vo II method 2.12, ADEC PM 2.5 QAPP 24

- hr ± 1hr SLAMS ≥ 75%

all sample days

PSD ≥ 80% Flow audit

Design Flow:

≤±5% Δ (16.7lpm),

Accuracy Flow:

≤±4% Δ

 CV ≤ 10% for paired values ≥3 ug/m 3 1/3 day,

1/12 collocated

15% of sites EPA siting guidelines for PM 10 and PM 2.5

PM 2.5 and PM 10
Continuous Methods R&P TEOM 1400a, Met One BAM 1020, EPA PM 10 continuous FEM ADEC M&QA Met One 1020 BAM SOP, EPA QA guidance criteria for continuous PM ≥75 % ≥ 75% aggregate hours/day SLAMS ≥ 75% all sample days

PSD ≥ 80% Flow audit

PM 2.5 Design Flow :

≤±5% Δ (16.7lpm)

PM 10 Design Flow :

≤±5 % Δ (16.7lpm) PM 10

PM 10 & PM 2.5 Accuracy Flow: ≤±4 % Δ

 Continuous, hourly
average, collocated 1/12 with like continuous PM

PM 2.5 Aethalometer

Continuous Method Magee Sci e ntific Aethalometer ≥75 % ≥ 75% aggregate hours/day SPM ≥ 75% all sample days Flow audit

Design Flow:

≤±7.5 % Δ (

5 .0 lpm),

Accuracy Flow:

≤±10 % Δ


PM 10 FRM/FEM HiVol Method EPA FRM/FEM sampler EPA QA Handbook Vol II Method 2.11,

ADEC method 4.2 24

- hr ± 1hr SLAMS ≥ 75% all sample days

PSD ≥ 80% Flow audit

Design Flow:

≤±10% Δ (1.13m 3 /min)

Accuracy Flow:

≤±7 % Δ

 CV ≤ 10%

for paired values ≥15 ug/m 3 1/3 day,

1/12 collocated 15% of sites

PM 10 – FRM Low Volume

Method EPA FRM/FEM sampler 24

- hr ± 1hr ≥ 75% all sample days

PSD ≥ 80% Flow audit

Design Flow:

≤±10 % Δ (16.7lpm),

Accuracy Flow:

≤±7 % Δ

 CV ≤ 10%

for paired values ≥15 ug/m 3 1/3 day,

1/12 collocated 15% of sites

EPA PM 2.5 Speciation Method Met One SSASS EPA PM 2.5 Speciation QAPP http://www.epa.gov/ttn /amtic/files/ambient/p m25/spec/finlqmp.pdf 24

- hr ± 1hr SLAMS ≥ 75% all sample days Flow audi t

Design Flow:

≤±10% Δ (6.7lpm),

Accuracy Flow:

≤±10% Δ 1/3 day,

Lead on TSP EPA FRM/FEM sampler and analytical method EPA QA Handbook Vol II method 2.8, ADEC method 4.4 24

- hr ± 1hr SLAMS ≥ 75% all sample days

PSD ≥ 80% Flow audit

1.1 m 3 /min ≥ Design Flow ≤1.7m 3 /min

Accuracy Flow:

≤±10%Δ CV ≤ 10%

for

paired values0.15 ≥ ug/m 3 1/3 day,

1/12 collocated 15% of sites EPA siting guidelines for Pb on TSP,ADEC method 4.4.1

CO EPA FRM/FEM EPA QA Handbook Vol II method 2.6

ADEC method 4.05 ≥75 % SLAMS ≥ 75% all hours

PSD ≥ 80% Mean absolute Δ ≤± 15%,

Linear regression criteria:

Slope ≤± 15%,

Y intercept ≤±3% FS, and

.995 > r 2 < 1.000 90% CL CV ≤± 15% Continuous EPA siting criteria for CO, ADEC CO method 4.05.1ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

32 

### Table A7 Alaska Ambient Air Quality Monitoring MQOs

Parameter Comparability Completeness Bias Precision Representativeness

Equipment Reference/ Method Hourly Daily Quarter Sampling
Frequency Siting

NH 3 NO 2 EPA FRM/FEM approved analyzer with NH 3 converter ADEC NH 3 method (4.10) ≥75 % ≥75% all hours Mean absolute Δ ≤±15%

Linear regression criteria:

Slope ≤± 15%,

Y intercept ≤±3% FS, and

.995 > r 2 < 1.000

NO 2 converter efficiency ≥96 %

NH 3 converter efficiency ≥90% 90% CL CV ≤± 15% Continuous ADEC NH 3 method 4.10.1

NO

- NO x - NO 2 EPA FRM/FEM EPA QA Handbook Vol II method 2.3

ADEC method 4.07 ≥75 % SLAMS ≥ 75% all hours

PSD ≥ 80% Mean absolute Δ ≤± 15%,

Linear regression criteria:

Slope ≤± 15%,

Y intercept ≤±3% FS, and

.995 > r 2 < 1.000

NO 2 converter efficiency ≥96 % 90% CL CV ≤± 15% Continuous EPA siting guidelines for NO 2, , ADEC method 4.07.1

O 3 EPA FRM/FEM EPA QA Handbook Vol II

http://www.ecy.wa.gov /pubs/95201g.pdf ≥75 % SLAMS ≥ 75% all hours

PSD ≥ 80% Mean absolute Δ ≤± 10%,

Linear regression criteria:

Slope ≤± 10%,

Y intercept ≤±3% FS, and

.995 > r 2 < 1.000 90% CL CV ≤± 10% Continuous EPA siting criteria for O 3

SO 2 EPA FRM/FEM EPA QA Handbook Vol II method 2.9

ADEC method 4.06 ≥75 % SLAMS ≥75% all hours

PSD ≥ 80% Mean absolute Δ ≤± 15%,

Linear regression criteria:

Slope ≤± 15%,

Y intercept ≤±3% FS, and

.995 > r 2 < 1.000 90% CL CV ≤± 15% Continuous EPA siting guidelines for SO 2 , ADEC method 4.06.1ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

33 

### Table A8 Alaska Meteorological Monitoring MQOs

Parameter Comparability Completeness Bias Representativeness

Method & Measurement

Resolution Equipment Reference/ Method Hourly Daily Quarter Sampling
Frequency Siting

WS Cup or Sonic

Anemometer

0.25 m/s WS Range 0.5m/s – 50 m/s

VWS Range

- 25.0 m/s – 25.0 m/s

WS Threshold ≤ 0.5 m/s

Accuracy. ≤ (0.2m/s+5% obs)

Dist Const. ≤ 5m/s at 1.2kg/m 3 Meets minimum specs per EPA

454/R

- 99

- 005 Section 5.1, Table 5.1 and appropriate for range of site environmental conditions ≥75 % NCore and SLAMS :

≥ 80 % all

sample days

PSD :
≥ 90% all sample days for 4 consecutive

quarters ± 0.2 m/s Continuous, 1 min sample interval, hourly avg EPA

454/R

- 99

- 005 Section 3.1

EPA QA Handbook Vol IV Vertical

WS Cup or Sonic

Anemometer

0.1 m/s ± 0.2 m/s Continuous, 1 min sample interval, hourly avg

WD Vane or sonic
anemometer

1.0 m/s 1 – 360 o (540 o )

Threshold ≤ 0.5 m/s

Accuracy. ≤ 3 o from sensor mount

. ≤ 5 o absolute error

Delay Disrt. ≤ 5m/s at 1.2kg/m 3

Damping Ratio 0.4 at 1.2kg/m 3 or Overshoot ≤ 25% at 1.2kg/m 3 ± 5 o

includes ± 3 o from sensor
mount Continuous, 1 min sample interval, hourly avg

Vector Data

WS

WD

Sigma Theta (σθ)

Sigma W (σФ) DAS Calculation

0.1 m/s

1.0 degree

1.0 degree

0.1 m/s Range 0 – 50.0 m/s,

Range 0 o – 360 o

Ra nge 0 o – 105 o

Range 0 – 10 m/s Vector Data

WS ± 0.2 m/s

WD ± 5 o

σθ ± 5 o

σ Ф ± 0.2 m/s Continuous, 1 min sample interval, hourly avg

Ambient Temperature Thermistor

0.1 o C Range -40 o C - +40 o C

Meas. Resolution ≤ 0.1 o C

Accuracy ≤ ±0.5 o C ± 0.5 o C Continuous, 1 min sample interval, hourly avg

Vertical Temperature

Difference Thermistor

0.02 o C Motor aspirated

Range -3 o C to +7 o C

Relative Accuracy ≤ 0.1 o C ± 0.1 o C

Relative Accuracy Continuous, 1 min sample interval, hourly avg

Temperature

Radiation

Shield Motor aspirated Range

- 100 to 1300W/m 2

Flow Rate ≥ 3 m/s

Radiation error < 0.2 o C

Relative Humidity Psychrometer/

Hygrometer

0.5 %RH Range 0 – 100%

Accuracy ± 7% ± 7% RH Continuous, 1 min sample interval, hourly avg

Dew Point Psychrometer/

Hygrometer

0.1 o C Range -30 o to +30 o C

Accuracy ± 1.5 o C ± 1.5 o C Continuous, 1 min sample interval, hourly avg

Barometric

Pressure Aneroid Barometer Range

- 600 to 100 Mb

Accuracy ± 3Mb ± 3 Mb (0.3 kPa) Continuous, 1 min interval

Hourly avg.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

34 

### Table A8 Alaska Meteorological Monitoring MQOs

Parameter Comparability Completeness Bias Representativeness

Method & Measurement

Resolution Equipment Reference/ Method Hourly Daily Quarter Sampling
Frequency Siting

0.5 Mb

Precipitation Tipping bucket

0.2 mm/hr Range 0 - 50 mm/hr

Accuracy ± 5% of input volume ≤± 10% Δ Continuous,

5/min sample interval

Hourly avg

Solar Radiation pyranometer

10 W/m 2 Range 0 to 1300 W/m 2

Accuracy ± 5% of mean observed interval ± 5% Δ of observed Continuous,

1 min sample interval,

Hourly avgADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

35 

### 8. TRAINING

Air monitoring personnel will be recruited and screened to ensure they are experienced and qualified

. Air monitoring personnel will meet the educational, work experience, responsibility, personal attributes, and training requirements for their respective positions. Training will be available to employees supporting the Ambient Air Quality Monitoring Prog ram, commensurate with their assigned duties and sufficient to contribute to the reporting of complete and high quality data

.

Pri mary responsibility for training will rest with the individual's supervisor. Records on personnel qualifications and training will be maintained in personnel files. Tr aining may consist of courses, workshops, classroom lectures, teleconferences, and on

- the

- job

- training. The following groups provide training: U.S. EPA’s Air Pollution Training
Institute ( http://www.epa.gov/air/oaqps/eog/course_topic.html ) , U.S. EPA Quality Assurance Division (QAD), U.S.EPA Office of Air Quality Planning and Standards (OAQPS), American Society for Quality Control (ASQC) and Air & Waste Management Association (AWMA). Table A9 suggests a list of training courses for all air monitoring personnel.
Table A10 suggests a sequence of specific training courses for the respective air monitoring responsibility ( e.g. field personnel, lab per sonnel, monitoring supervisor, QA officer, etc).ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

36 

### Table A9 Suggested Core Ambient Air Monitoring Training Courses

Sequence 

### Course Title Course APTI Type

Source Self Instruction classroom web

1 Air Pollution Control Orientation Course 422 X X APTI

2 Principles and Practices of Air Pollution Control, 452 X APTI

3 Mathematics Review for Air Pollution Control 100 X X APTI

4 Orientation to Quality Assurance Management QA1 EPA QAD

5 Introduction to Ambient Air Monitoring, PM2.5 Monitoring Update, 434 X APTI

6 General Quality Assurance Considerations for Ambient Air Monitoring 471 X X APTI

7 Basic Air Pollution Meteorology 409 X X APTI

8 Data Quality Objectives Workshop QA2 QAD

9 Chain of Custody Procedures for Samples and Data 443 X X APTI

10 Quality Assurance Project Plan QA3 QAD

11 Atmospheric Sampling 435 X APTI

12 Network Design for Monitoring PM 2.5 & PM 10 in Ambient Air 433 X X APTI

13 Analytical Methods for Air Quality Standards 464 X APTI

14 Beginning Environmental Statistical Techniques 473A X X APTI

15 Quality Assurance for Air Pollution measurement Systems 470 X APTI

16 Site Selection for Monitoring SO 2 436 X X APTI

17 AQS Training (annual AQS conference) OAQP S

18 Data Quality Assessment QA4 QAD

19 Management Systems Review QA5 QAD

20 Introduction to Environmental Statistics, SI 473B X APTI

21 Quality Audits for Improved Performance QA6 AWM A

22 Statistics for Effective Decision Making STAT 1 ASQCADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

37 

### Table A10 Suggested Training Courses for Air Monitoring Personnel

Course # Air Monitoring Position

Field Personnel Laboratory Personnel QC Supervisor Data Management Monitoring Supervisor QA Personnel QA Management

422 x x x x x x

452 x x x x x

100 x x
QA1 x x x

434 x x x x x x x

471 x x x x x x x

409 x x x x x
QA2 x x x

443 x x x x x x
QA3 x x x x

435 x x x x x

433 x x x

464 x x x x

473A x x x x x x x

473B x x x

470 x x x x

436 x x x x
QA4 x x x
QA5 x x x

473B x x x x x x x
QA6 x x
AQS Conf. x

STAT1 x x x xADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

38 

### 9. DOCUMENTS AND RECORD S

ADEC’s Quality Management Plan for Ambient Air Monitoring describes document and records procedures for the Ambient Air Monitoring Program. This document may be found at http://www.dec.stat e.ak.us/air/doc/aq_qmp_sep06.PDF

.

As indicated in 40 CFR Part 58, the Air Quality Program shall submit to the EPA Administrator, through the Region 10 Office, an annual summary report of all the air quality monitoring data from monitoring stations designat ed as SLAMS. The report will be submitted by July 1 of each year for the data collected from January 1 to December 31 of the previous

year. The AM& Q A Program Manager will certify that the annual summary is accurate to the best of his/her knowledge.
This c ertification will be based on the various assessments and reports performed by the organization. D ocuments and records required to support concentration data reported to EPA, which includes all data required to be collected as well as data deemed importan t by the ADEC are listed in Table A11

.



## Table A11 Reporting Package Information

Categories Record/Document Types File Locations

Management and Organization State Implementation Plan Reporting agency information Organizational structure Personnel qualifications and training Training Certification Quality management plan Document control plan EPA Directives Grant allocations Support Contract ADEC

- A M&QA Anchorage/Juneau

Site Information Network description Site characterization file Site maps Site Pictures ADEC

- AM&QA Anchorage/Juneau

Environmental Data Operations QA Project Plans Standard Operating Procedures (SOPs) Field notebooks Inspection/Maintenance records Laboratory notebooks Sample handling/custody records ADEC

- AM& QA Anch.&Juneau/FNSB/MOA “ ADEC

- AM&QA Anch.&Juneau/FNSB/MOA/ADEC AM&QA Laboratory (Juneau)

Raw Data Any original data (routine and QC data) including data entry forms ADEC AM&QA Laboratory (Juneau)/Anch/FNSB/MOA Data Reporting Air quality index report Annual SLAMS air quality information Data/summary reports Journal articles/papers/presentations ADEC

- AM&QA Anch.&Juneau/FNSB/MOA ADEC

- AM&QA Anchorage/Juneau ADEC

- AM&QA Anch.&Juneau/FNSB/MOA Data Management Data algorithms Data management plans/flowchar ts Data Management Systems ADEC AM&QA Laboratory (Juneau) ADEC

- AM&QA Anchorage ADEC AM&QA Anc h /Juneau Lab Quality Assurance Network reviews Control charts Data quality assessments QA reports System audits Response/Corrective action reports Site Audits ADEC

- AM&QA Anchorage/Juneau “ “ ADEC

- AM&QA Anch.&Juneau/FNSB/MOA “ “ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

39 

# B. MEASUREMENT AND DATA ACQUISITIONADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

40 

### 10. SAMPLE PROCESS AND D ESIGN

The purpose of this section is to describe the relevant components of the State of Alaska’s National Core Level 2 and 3 (SLAMS), SPM monitoring network as well as monitoring conducted to support PSD quality monitoring objectives

. The network design components comply with the regulations stipulated in 40 CFR Part 58 Section 58.13, Appendix A,

an d Appendix D. In addition, Table B1 lists criteria pollutant and other parameter specific siting guidance documents
available from EPA’s AMTIC web site. These documents are listed as a resource to those parties considering air quality and meteorological monitoring projects as an aid in identifying areas of air quality concern as well as selecting the best available monitoring site

.



## Table B1 Air Quality & Meteorological Sample Process & Design Documents

Parameter Document Title Source Location

Criteria & Non

Criteria Pollutants SLAMS/NAMS/PAMS Network Review Guidance EPA AMTIC http://www.epa.gov/ttnamti1/files/ambient/criteria/reldocs/netrev98.pdf

Criteria & non

Criteria Pollutants QA Handbook for Air Pollution Measurement Systems, Vol 2: Part 1, Section 6.0 Sampling Process Design EPA AMTIC http://www.epa.gov/ttn/amtic/files/ambient/qaq c/redbook.pdf

Criteria & non

Criteria Pollutants 40CFR Part50 EPA AMTIC http://www.epa.gov/ttn/amtic/40cfr50.html

Criteria & non

Criteria Pollutants 40CFR Parts 53 and 58 EPA AMTIC http://www.epa.gov/ttn/amtic/40cfr53.html

CO Selecting Sites for Carbon Monoxide Monitoring EPA AMTIC http://www.e pa.gov/ttnamti1/files/ambient/criteria/reldocs/3

- 75

- 077.pdf

NO 2 , O 3 Site Selection for the Monitoring of Photochemical Pollutants EPA AMTIC http://www.epa.gov/ttnamti1/files/ambient/criteria/reldocs/3

- 78

- 013.pdf

NH 3 Method for the Determination of Ammonia (NH 3 ) by Chemiluminescence ADEC Method 4.10 ADEC Ambient Air Quality Method 4.10

O 3 Guidance on Ozone Monitoring Site Selection EPA AMTIC http://www.epa.gov/ttnamti1/files/ambient/criteria/reldocs/r

- 98

- 002.pdf

O 3 Guideline on Modification to Monitoring Seasons for Ozone EPA AMTIC http://www.epa.gov/ttnamti1/files/ambient/criteria/reldocs/modozsea.pdf

SO 2 Optimum Site Exposure Criteria for SO 2

Monitoring EPA AMTIC http://www.epa.gov/ttnamti1/files/ambient/criteria/reldocs/3

- 77

- 013.pdf

PM 10 , PM 2.5 Network Design and Optimal Site Exposure Criteria for Particulate EPA AMTIC http://www.epa.gov/ttnamti1/files/ambient/criteria/reldocs/4

- 87

- 009.pdfADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

41 

## Table B1 Air Quality & Meteorological Sample Process & Design Documents

Matter

PM 10 Guideline for PM 10 Episode Monitoring Methods EPA AMTIC http://www.epa.gov/ttnamti1/files/ambient/criteria/reldocs/4

- 83

- 005.pdf

Pb on TSP Guidance for Siting Ambient Air Monitors Around Stationary Lead Sources EPA AMTIC http://www.epa.gov/ttnamti1/files/ambient/criteria/reldocs/pbgde997.pdf

Pb on TSP Optimum Sampling Site Exposure Criteria for Lead EPA AMTIC http://www.epa.gov/ttnamti1/files/ambient/criteria/reldocs/4

- 84

- 012.pdf

Pb on TSP Guideline for short

- Term Lead Monitoring in the Vicinity of Point Sources EPA AMTIC http://www.epa.gov/ttnamtic/files/ambient/criteria/reldocs/oa12

- 122.pdf

Meteorological Measurements Meteorological Monitoring Guidance for Regulatory Modeling Applications,

Section 3.0 Siting & Exposure EPA SCRAM http://www.epa.gov/scram001/guidance/met/mmgrma.pdf

Meteorological Measurements QA Handbook for Air Pollution Measurement Systems, Vol 4

, Meteorologi cal Measurements Version 1.0 (Draft) EPA AMTIC http://www.epa.gov/ttn/amtic/files/ambient/met/Volume%20IV_Meteorological_Measurements.pdf

PSD Criteria and

Non Criteria

Pollutants Ambient Monitoring Guidelines for Prevention of Significant Deterioration EPA AMTIC http://www.epa.gov/ttn/amtic/files/ambient/crite ria/reldocs/4

- 87

- 007.pdf

10.1 Network Objectives

NCore Level 2 Monitoring Objectives

**•** Represent ambient concen trations over a neighborhood scale representative of many similar neighborhoods ; The ADEC NCore Level 2 Monitoring site will be one of 75 nation

- wide multi

pollutant sites focusing on community

- wide air quality assessment. Assuming EPA provides adequate funding, the ADEC’s plan for a Level 2 NCore monitoring site will be submitted to EPA by J uly 1, 2009 and operational by January 1, 2011. The NCore parameters to be measured are listed in Table B2 . The intent of the NCore monitoring site will be

to:

**•** Represent an area impacted by mobile source emissions ;

**•** Represent an area not impacted by unique local emission sources ;

**•** Remain a long

- term site with reasonable assurance of 5+ year “permission” period;

**•** Be c ollocated with an STN or NATTS si te
, if possible ; and

**•** Have r oom for multiple gas monitors and associated equipment, integrated samples, meteorology

.

NCore Level 3 (SLAMS) and SPM Monitoring Objective s Alaska’s SLAMS/SPM Monitoring Network is designed

to:ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

42 **•** De termine compliance or non

- compliance with the NAAQS/AAAQS;

**•** B est represent the exposure of populations that may be affected by elevated criteria and non

- criteria pollutant concentrations; and

**•** M eet EPA objectives. The design of the SLAMS/SPM network must achieve one of six basic monitoring objectives as described in 40 CFR Part 58, Appendix D. These are:

**•** D etermine the highest concentrations expected to occur in the area covered by the network;

**•** D etermine representative concentrations in areas of high popul ation density;

**•** D etermine the impact on ambient pollution levels of significant sources or source categories;

**•** D etermine general background concentrations levels;

**•** D etermine the extent of regional pollution transport among populated areas, and in support of secondary standards; and

**•** Determine the welfare

- related impacts in more rural and remote areas (such as visibility impairment and effects on vegetation.

10.2 Selection of Monitoring Areas

The ADEC ambient air quality monitoring network is designed to protect th e health and welfare of its residents and visitors. To meet this objective, monitoring sites are installed at locations specifically selected to evaluate public impac ts of air quality pollutants in areas with the highest potential for exceeding the NAAQS/AAAQS. Where problems exist, priority will be given to communities with high population density. Where impacts are seasonal, monitoring studies will be designed to examine seasonal impacts on local residents.

Alaska does not meet many of the traditional concept s of population centers envisioned in the guidance document s for
the criteria pollutant standard s . Instead, Alaska’s “population centers” closely resemble the supply centers of the 1800’s used to explore the West. Alaska has only five communities over 15,000 people: Anchorage, Fairbanks, Juneau, Wasilla/Palmer and Ketchikan. Each of these areas must be considered separately and independent from the others when considering air quality impacts and influences on neighboring communities. Alaska’s lon g- term goals are split between using SPM monitors to help characterize the most representative SLAMS sites and evaluating potential microscale impacts on the public.

Table B2 describes the representative measurement scales appropriate for Alaska’s state

- wide monitoring network.



### Table B2 Description of Representative Measurement Scale

Measurement Scale Description

Micro Concentrations ranging in area from several meters to 100 meters.

Middle Concentrations typical of areas of several city blocks in size with dimensions ranging from 0.1 to 0.5 kilometers.

Neighborhood Concentrations within an extended area of the city that has relatively uniform land use with dimensions ranging from 0.5 to 4.0 kilometers.

Urban Overall, city

- wide conditions with dimensions ranging from 4 to 50 kilometers.

Regional Rural area of reasonably homogenous geography ranging from tens to hundreds of kilometers

Table B 3 summarizes relationships among monitoring objectives and appropriate scales of representativeness.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

43 

### Table B3 Relationship Among Monitoring Objectives and Scales of Representativeness

Monitoring Objective Appropriate Siting Scale

Max Concentration Micro, middle, neighborhood, sometimes urban

Population Neighborhood, urban

Source Impact Micro, middle, neighborhood

General/Background Neighborhood, regional

Regional Transport Urban, regional

Welfare

- Related Urban, regional

Table B 4 summarizes spatial scales for appropriate NCore Level 2 , SLAMS and SPM monitoring sites.



### Table B4 Spatial Scales Appropriate for NCore Level 2 , SLAMS, SPM Monitoring Sites

Spatial Scale Scales for NCore Level 3 ( SLAMS and SPM ) Scales for NCore Level 2

CO NO 2 O 3 SO 2 Pb PM 10 PM 2.5 CO NO 2 O 3 SO 2 Pb PM 10 PM 2.5

Micro 

### • • • • • • • •

Middle 

### • • • • • • • • • •

Neighborhood 

### • • • • • • • • • • • • • •

Urban 

### • • • • • • • • •

Regional 

### • • • • • •

10.3 Sampling Schedule

Sampling schedules for criteria pollutants, NH 3 and meteorological parameters are continuous, except for the 24

- hour integrated gravimetric methods PM 10 , PM 2.5 , and Pb

- TSP. All continuous monitors are required to report hourly values. Continuous PM methods are required to sample continuously and report hourly as well as 24

- hr values.

All integrated PM 10 and Pb

- TSP monitors used to collect NCore and SLAMS quality criteria data must sample 24

- hours from midnight (local standard time) to midnight. Minimum sampling frequency is every six days following the EPA national sampling schedul e. Every 3 rd day sampling is encouraged to adequately represent PM concentrations. In cases where PM concentrations approach the NAAQS/AAAQS, every day sampling is required.

All integrated PM 2.5 monitors used to collect NCore and SLAMS quality criteria data must sample 24

- hours from midnight (local standard time) to midnight. Minimum sampling frequency is every third day following the EPA national sampling schedule. In some cases the sampling frequency may be reduced to every 6 th day with EPA regional o fficeADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

44 waiver. In cases where PM 2.5 concentrations are within 85 – 115% of the NAAQS/AAAQS, every day sampling is required.

The EPA National Sampling Schedule is updated yearly and is available from the following web link: http://www.epa.gov/ttn/amtic/calendar.html

.

10.4 Selection of Monitoring Sites

Monitoring site locations will be based on the State’s present understanding of local sources and their potential
contributions to the NAAQS/AAAQS

. Alaska ’s monitoring network will contain one NCORE site as well as a mix of
SLAMS and SPM monitoring locations to address neighborhood

- scale, micro

- scale and associated gradients where necessary to develop effective control strategies. Final selection of the NC ORE site has not yet been determined. Installation and operation of the site will be dependent upon receipt of federal monies and man power to operate the site.
SLAMS and SPM s ites are selected to meet as much as possible guidance documents listed in Tab le B1 . Siting criteria
not met are documented with sufficient reasons to justify the selection. Flow Chart , Figure B1

, depicts the overall monitoring site selection process.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

45 Step 1 Formulate m onitoring o bjective and consider pollutants of concern

Step 2

a. Review applicable siting g uidance b. Review state and federal pollutant requirement s

Step 3 Evaluate e xisting d ata Air quality m onitoring d ata Meteorological d ata

Step 4 Evaluate topographical influences

Step 5 Is data sufficient for modeling? Improve database.

Step 6

a. Conduct modeling runs b. Identify potential hot spots

Step 7 Reconsider monitoring objectives to determine spatial scale and network requirements Monitoring objective

Step 8 Evaluate potential sites for measurement parameters, representativeness and installation compatibility

Step 9 Select monitoring sites and complete site documentation 

### Figure B1 Monitoring Site Selection Process

No Re

- evaluation

YesADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

46 10.5 Monitoring Network Description

The configuration of ADEC’s monitoring network, based on the site selection criteria described above is summarized in
Table B 5

. Detailed site information, inc luding the ration ale for each site selection, is available in Alaska’s Ambient Air Monitoring Network Plan ( http://www.dec.state.ak.us/air/am/index.htm ).



### Table B5 ALASKA NCore Level 2 and SLAMS/SPM MONITORING NETWORK

Network Site ID Ambient Air Quality Parameters Monitored

CO NO 2 O 3 Pb SO 2 PM 2.5 FRM PM 10 FRM PM 2.5 Spec iation PM 2.5 Continuous PM 2.5 Continuous

FEM PM 10 Continuous

FEM PM 10- 2.5 Continuous

FEM

Anchorage

MOA 16 th & Garden SLAMS / SPM ■ ■ + ■ ■ ■

Turnagain SLAMS ■

Parkgate

- Eagle River SLAMS/ SPM ■ ■ + ■ ■

All s tate Bldg.

- Tudor Road SLAMS ■ 

### * ■

8 th & L Street SPM ■ ■

Fairbanks

FNSB To be selected Δ NCore Level 2 ■ ■ ■ ■ ■ ■ 

### * ■ ■

State Office Bldg. SLAMS ■ 

### * ■ ■

Peger Rd S PM ■ ■ ■

2 nd & Cushman (Old Post Office) SLAMS ■

North Pole School SPM ■ ■ ■

ADEC - Kenai Soldotna SPM ■

ADEC - Juneau Floyd Dryden School SLAMS ■ ■ * ■

ADEC - MatSu Butte (Harrison Court) SPM ■ ■ ■

Wasilla Fire Station SPM ■

Palmer SPM ■ ■

ADEC - Noatak Noatak SLAMS ■



### * collocated PM monitors + start

- up April 2010 Δ start

- up July 2011ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

47 

### 11. SAMPLING METHODS

This Section describes the sample collection methods and continuous measurement methods for determining compliance with the primary and secondary NAAQS/AAAQS criteria pollutants and meteorological parameters.

11.1 Environmental Control

Monitoring stations shoul d be designed for functionality and with the station operator in mind, considering safety, ease of access to instruments, optimal work space and security. Table B 6 lists recommended environmental control parameters for monitoring shelters. Continuous tem perature measurement is strongly recommended inside monitoring shelters to ensure temperature is maintained within required shelter temperature criteria for all gaseous monitors (15° - 30°C, ±2°C SD/24

- hrs.). Ambient air monitoring data collected outside this shelter temperature criteria needs to be flagged and evaluated regarding if acceptable data quality criteria has been met to validate the affected data.



### Table B6 Environmental Control Parameters for Monitoring Shelters

Parameter AQ method Source of Specification Method of Control

Instrument Vibration All Equipment Manufacturer’s Specs Design of Instrument housing’s benches, per manufacturer’s specs.

Light Overhead light Method Description or manufacturer’s specs Shield chemicals or instruments that can be affected by natural or artificial light.

All parameters Sample lines for automated methods Borosilicate glass, Teflon, laminar flow, moisture trap See guidance on sample lines for automated methods http://www.epa.gov/ttn/amtic/files/ambient/qaqc/redbook.pdf , Section 7.2

Electrical Voltage All Equipment Method Description or manufacturer’s specs Constant voltage transformers or regulators; separate power lines, isolated high current drain equipment such as High

- Vols, heating baths, pumps from regulated circuits

Temperature,

Humidity All gaseous monitoring equipment Method description or manufacturer’s specs. EPA monitoring shelter criteria unless otherwise specified. Regulated temperature conditioning (EPA criteria 20° – 30°C ±2°C SD/24

- hr). Alaska variance 15° – 30°C ±2°C SD/24

- hr ) system, continuous temperature recorder, electric cooling and heating only

Temperature PM 2.5 - FRM, if inside monitoring shelter EPA

- Alaska Modification http://www.epa.gov/ttn/amtic/files/cfr/recent/akmod799.pdf Alaska Modification for operating PM 2.5 FRM within monitoring shelter with sample probe to outside shelter

Temperature All PM continuous monitors Alaska continuous PM method Requirement Operated within temperature controlled monitoring shelter with sample inlet line sampling air at ambient temperature conditions.

Security Shelter Security Shelter secured with lock. Where monitoring equipment located outside shelter (e.g., met tower, PM monitors, etc.) monitoring equipment should be surrounded by locked chain link fence.

Safety Cylinder gas Cylinder gases secured upr ight in cylinder racks or other wise secured upright against wall, instrument rack etc. Cylinders not in use capped with threaded cylinder gas cap.

Venting exhaust/excess calibration gases Excess calibration gas delivered to Gaseous mo nitors as well as exhaust gases vented outside shelter.

Electrical Local/state Comply with local, State or national building codes.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

48 

### Table B6 Environmental Control Parameters for Monitoring Shelters

Safety Shelter Construction Local/state Comply with local, State or national building codes. If monitors located on roof of shelter, safety railing required.

Fire Safety Local/state Fire extinguisher mounted by door

Basic First Aid Kit

Emergency light with battery back

- up by door.

11.2 Sampling Probes and Manifolds

Variables affecting s ample manifold design are: diameter, length, flow rate, pressure drop, and construction materials. These variables must be taken into consideration when designing a sample delivery system. Sample probe manifold
material for gaseous reactive gases may only be constructed with smooth, non

- reactive and non

- porous materials ( i. e ., FEP Teflon or borosilicate glass). Sample probe material for non

- reactive gases (e.g., CO) should also utilize the same sample probe and manifold materials as used for reactive gases (e .g., SO 2 , NO 2 , O 3 )

. Connective tube fittings must also
be constructed of smooth non

- react ive and non

- porous materials ( e. g. FEP Teflon, 316 or better stainless steel). Water traps should be configured into the sampling system to remove condensate that may accumulate in the sample line upstream of any monitoring equipment. Please see http://www.epa.gov/ttn/amtic/files/ambient/pm25/qa/QA

- Handbook

Vol

- II.pdf , Section 7.2 for recommended design configurations of sampling probes and manifolds

11.3 Sample Residence Time

The residence time of pollutants within the sample train is critical. Residence time is defined as the amount of time it takes for a sample of air to travel from the sample probe inlet to the sample inlet at the back of the analyzer. For the reactive gases (NO 2 , SO 2 , NH 3 and O 3 ), sample residence must be < 20 seconds . Sample residence time can be determined using the formula: V = π * (d/2) 2 *L

Determine V separately for sample probe, manifold and line. Where : 

### V = volume



### π = 3.14159 L = length d = inside diameter Add volume of various volume components together ( 

### V Total )

Determine sample residence time 

### ( R ) using the formula: 

### R = 

### V Total /(flow rate of all instruments)

If the sample residence time is found to be >10 seconds, it is strongly encouraged to install a blower motor (or other device) to decrease the sample residence time to within 10 seconds.

Sample residence times for CO should be minimized as much as possible. It is recommended that CO sample residence times also be kept to < 20 seconds.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

49 11.4 Placement of Sample Probes and Manifolds

Careful consideration must be taken in the placement of sample probes and manifolds to avoid introducing bias to the sample collection process. Considerations such as probe height (above ground), length (distance from structures) and physical influences nearby are factors that can influence collection of a representative sample. Table B 7 lists some general guidelines for placement of sample probes and manifolds.



### Table B 7 Guidelines for Sample Probe & Manifold Placement

**•** Do not place probes next to air outlets (e.g., exhaust fan openings)

**•** Horizontal probes must extend beyond building overhangs

**•** Avoid placing probes near physical obstructions (e.g., chimneys) which can affect air flow in vicinity of the sample probe/inlet

**•** Sample probe/inlet height above ground dependent upon pollutant being measuredADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

50 Table B 8 summarizes probe and monitoring pat h siting criteria

.



### Table B 8 Summary of Representative Probe and Monitoring Path Siting Criteria

Pollutant Representative Scale Height above ground to probe or 80% of monitoring path A (meters) Horizontal and vertical distance to supporting
structures B to probe or 90% monitoring path Distance from trees to probe of monitoring path A (meters)



### SO 2 C, D, E, F Middle (300 m)
Neighborhood, Urban, and Regional (1 km) 3 – 15 >1 >10



### CO D,E,G Micro, Middle (300 km) Neighborhood (1 km) 3 ± 0.5;

3 – 15 >1 >10



### O 3 C,D,E Middle (300 m)
Neighborhood, Urban, and Regional (1 km) 3 – 15 >1 >10



### NO 2 C,D,E Middle (300 m)
Neighborhood, and Urban (1 km) 3 – 15 >1 >10



### NH 3 C,D,E Middle (300 m)
Neighborhood, and Urban (1 km) 3 – 15 >1 >10



### Pb C,C,E,F,H Micro, Middle, Neighborhood, Urban and Regional (1 km) 2 – 7 (micro);

2 – 15 (all other scales) >2 (all scales, horizontal distance only) >10 (all scales)



### PM 10 C,D,E,F,H Micro, Middle, Neighborhood, Urban and Regional 2 – 7 (micro);

2 – 15 (all other scales) > 2 (all scales, horizontal distance only) >10 (all scales)



### PM 2.5 C,D,E,F,H,I Micro, Middle, Neighborhood, Urban and Regional 2 – 7 (micro);

2 – 15 (all other scales) >2 (all scales, horizontal distance only) >10 (all scales)

A ≡ Monitoring path for open path analyzers is applicable only to middle or neighborhood scale CO monitoring and all applicable scales for SO 2 , O 3 , NO 2 and NH 3

B ≡ When probe is located on rooftop, this separation distance is in reference to wall, parapets, or penthouses located on roof

.

C ≡ Should be >20 meters from drip line of tree(s) and must be ≥10 meters from the drip line when trees(s) act as an obstructio n.

D ≡ Distance from sampler, probe, or 90% of monitoring path to obstacle, such as a building, must be at least twice the height of the obstacle that protrudes above the sampler, probe or monitoring path. Sites not meeting this criterion must be classif ied as middle scale.

E ≡ Must ≥ 270° unrestricted air flow around probe or sampler; 180° if the probe is located on the side of a building.

F ≡ The probe, sampler, or monitoring path should be away from minor sources, such as furnace or incineration flues. The separa tion distance is dependent on the height of the minor source’s emission point (such as a flue), the type of fuel or waste bed, and the quality of fuel (sulfur, ash, or lead content). This criterion is designed to avoid undue influences from minor sources.

G ≡ For microscale CO monitoring sites, the probe must be >10 meters from a street intersection and preferably at a midblock lo c ation.

H ≡ For collocated Pb and PM 10 samplers, a 2 – 4 meter separation distance between collocated Hi

- Vol samplers and/or paired HiVol and Low

- Vol samplers must be met. For collocated Low Volume samplers a 1 – 4 meter separation distance must be met.

I ≡ For collocated PM 2.5 samplers, a 1 – 4 meter separation distance must be met between samplers.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

51 Table B 9 summarizes spacing of probes from roadways. This information can be found in 40CFR part 58 Appendix E.



### Table B 9 Minimum Separation Distance Between Sampling Probes and Roadways

Roadway avg.

daily traffic vehicles/day Minimum separation distance between roadways and probes or monitoring paths at various scales (meters)

O 3 Neighborhood

& Urban NO 2 Neighborhood

& Urban CO

Neighborhood Pb

Micro Middle Neighborhood & Regional

≤10,000 10 10 10 5 – 15 >15 – 50 >50

15,000 20 20 25

20,000 30 30 45 5 – 15 >15 – 75 >75

30,000 80

≥40,000 5 – 15 >15 - 100 >100

40,000 50 50 115

50,000 135

≥60,000 150

70,000 100 100

≥110,000 250 250ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

52 Figure B2 shows acceptable areas for locating PM 10 and PM 2.5 monitors for the representative siting scales.

100 Middle Scale Suitable for Category (a) Site but not Preferred

80

60 Neighborhood Scale Suitable for Category (b) Site

40

20
No Urban Scale
Category
0 (a) sites

0 20 40 60 80 100 120 140 160 Distance of PM 10 & PM 2.5 Samplers from Nearest Traffic Lane (meters)Unacceptable at All Traffic Levels 

### Figure B2 - Acceptable Areas for PM 10 

### and PM 2.5 

### Micro, Middle, Neighborhood and Urban MonitorsExcept for Microscale Street Canyon SitesAverage Daily Traffic (ADT) of Affecting Roads X 10^3Preferred siting for category (a) site, microscaleif sampler 2 - 7m high, middlesclae otherwise

11.5 

### Monitoring Methods

Monitoring methods used to support Level 2 NCore, Level 3 NCore (SLAMS), SPM and PSD monitoring must use EPA FRM, FEM or ARM (for continuous PM only) approved method analyzers and operated as specified within the EPA FRM/FEM and/or state method designations. For a list of EPA approved reference and equivalent criteria pollutant methods, please go to : Federal Reference and Equivalent Methods

http://www.epa.gov/ttn/amtic/criteria.html . The EPA QA Handbook for Air Pollution Measurement Systems, Volume II, Part II provides specific Federal Reference Method procedures for the measurement of the ambient air quality criteria pollutants. A list of these methods can be found under the EPA AMTIC web site: http://www.epa.gov/ttn/amtic/files/ambient/pm25/qa/QA

- Handbook

- Vol

- II.pdf

.

DEC maintains an inventory of “DEC approved” Ambient Air Quality Monitoring Methods and Standard Operating
Procedures. These methods, SOPs and other QA guidance documents can be found on the DEC M&QA web site: DEC Approved Monitoring Methods

http://www.dec.state.ak.us/air/am/index.htm , and in Appendix A of this document. For those methods not yet developed, or under development by ADEC, the respective EPA method is the default criteria.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

53 Meteorological m onitoring data collected to support NCore, SLAMS and PSD quality monitoring projects will follow

E PA guidance criteria found in: Meteorological Monitoring

EPA QA Handbook Volume I V, Meteorological Monitoring, web link: http://www.epa.gov/ttn/amtic/files/ambient/met/Volume%20IV_Meteorological_Measurements.pdf

**•** EPA Meteorological Monitoring Guidance for Regulatory Modeling Applications, EPA

- 454/R

- 99

- 005, web link: http://www.epa.gov/scram001/guidance/met/mmgrma.pdf ; and

**•** Ambient Monitoring Guidelines for Prevention of Significant Deterioration (PSD), EPA

- 450/4

- 87

- 007.

Additional meteorological monitoring criteria specific to Alaska can be found on the Meteorological Monitoring Data Validation Tables ( Appendix A ) and Table A8 , Alaska Meteorological Measurement Quality Objectives

.

If monitoring data is to be used to support NCore, SLAMS, SPM or PSD quality criteria pollutant monitoring, and design changes to the method equipment and/or method procedures are intended, prior approval must be received from
the DEC’s Ai r QA Officer (or designee) through the Quality Assurance Plan (QAPP) approval process before monitoring begins

. Monitoring data collected without this approval may be rejected. Full responsibility for potential DEC non

acceptance of monitoring data rests solely on the primary organization/permittee/contractor collecting the data. Modifications to EPA/ADEC Method Analyzer s and Procedures

Even though EPA has given federal equivalent method (FEM) approval to some continuous PM 10 monitoring methods, ADEC requires that such monitoring methods must demonstrate in

- situ comparability testing for one year with an approved EPA FRM PM 10 monitor operating on a minimum every -6 th

- sampling day frequency. Comparability (least squares fit) between the PM 10 FRM method and the contin uous PM 10 method must be : PM 10 Continuous Method Analyzers and Procedures

**•** 0.90 ≥ s lope ≤ 1.10

**•** Intercept ≤ 5 ug/m 3

**•** Correlation coefficient ( R 2 ) ≥ 0.95

The collected data must adequately represent sufficient density of data points that span the PM 10 method measurement range of interest. Once approval is received, the continuous PM 10 monitoring method may be used in a similar local/regional air shed pending A DEC M&QA concurrence. However, if meteorology, PM source characteristics, etc. change significantly, in

- situ PM 10 method comparability may be requ ired for new location s

. The following EPA document, “Data Quality Objectives (DQOs) for Relating Federal Reference Method (FRM) and continuous PM 2.5 Measurements to Report an Air Quality Index (AQI),” ( http://www.epa.gov/ttn/amtic/files/ambient/monitorstrat/aqidqor2.pdf ) provides guidance on developing acceptable
inter

- method comparability.

Even though EPA has given federal equivalent method (FEM) approval to some continuous PM 2.5 monitoring methods, ADEC requires that such monitoring methods must demonstrate in

- situ comparability testing for one ye ar with an approved EPA FRM PM 2.5 monitor operating on a minimum every -6 th

- sampling day frequency. Comparability (least squares fit) between the PM 2.5 FRM method and the continuous PM 2.5 method must be: PM 2.5 Continuous Method Analyzers and ProceduresADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

54 **•** 0.90 ≥ s lope ≤ 1.10

**•** Intercept ≤ 3 ug/m 3

**•** Correlation coefficient ( R 2 ) ≥ 0.95

The collected data must adequately represent sufficient density of data points that span the PM 2.5 method measurement range of interest. Once approval is received, the continuous PM 2.5 monitoring method may be used in a similar local/regional air shed pending ADEC M&QA concurrence. However, if meteorology, PM source characteristics, etc. change significantly, in

- situ PM 2.5 method comparability may be required for new locations. The fo llowing EPA document, “Data Quality Objectives (DQOs) for Relating Federal Reference Method (FRM) and continuous PM 2.5 Measurements to Report an Air Quality Index (AQI),” ( h ttp://www.epa.gov/ttn/amtic/files/ambient/monitorstrat/aqidqor2.pdf ) provides guidance on developing acceptable
inter

- method PM 2.5 comparability.

11.6 Good Field M easurement Practices

Good Field M easurement Practices (GFMPs) refer to general practices that rela te to many, if not all of the measurements made in the field (similar in scope and common sense as those referred to as Good Laboratory Practices (GLPs)). They are usually independent of SOPs and encompass subjects as:

**•** F acility maintenance

**•** R ecords

**•** F ield sample management and handling

**•** M aintenance of monitoring equipment

**•** C leanliness of sample collection equipment, manifolds, etc.

**•** R epresentative traceability of calibration/audit standards (certification/recert ification of calibration/audit

s tandards over their intended range of use)

**•** G eneral principles for calibration of monitoring equipment

**•** S afe handling of hazardous and/or potentially hazardous materials

**•** F ield safety

**•** E tc.

In many cases the activities may not be formally documented because they are considere d common knowledge and common sense. However, not applying GFMPs can significantly affect the reliability of the collected data and may even
be cause for data invalidation.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

55 

### 12. SAMPL E HANDLING & CUSTODY

Maintaining sample integrity through field collection, transit, storage and subsequent analytical phases is critical to establishing final sample data reliability. Careful documentation of the process ensures that proper handling, etc.
occurred and is par t of the custody record.

The State of Alaska does not follow strict Sample “Chain of Custody” for Alaska’s NCore, SLAMS and SPM monitoring program. The State, however, does maintain sample/sample data integrity by tracking samples/sample data from sample collection through analysis, data reduction, data validation, data reporting and archiving of sample/sample data. These procedures can be found in the respective monitoring method.

For the Ambient Air Quality Monitoring Program, sample handling pertains o nly to the manual methods of particulates (PM 10 , PM 2.5 , PM 2.5 speciation) and Lead (Pb). Careful attention and consistency in the process of filter handling as specified in SOPs is critical to minimizing potential measurement errors. The phases of sample handling include:

**•** S ample labeling

,

**•** S ample retrieval, and

**•** S ample transport

.

12.1 Sample Labeling and Identification

Sample labeling and identification will follow the specific procedures in the respective method/SOPs to ensure positive identification throughout the testing and analytical procedures. In general each:

**•** S ample will have a unique identification label that is indelible and unaffected by gases and temperatures to which it will be subjected and does not impair the sample filter’s capacity to function as designed.

**•** S ample transport container will have a unique identification to preclude the possibility of sampl e interchange.

**•** S ample will be properly handled to ensure there is no contamination and that the sample analyzed is actually the sample taken under the conditions reported.

**•** S ample collected will be accompanied by pertinent sample collection data as specifie d in the respective method/SOP (e.g., sample date, sample run time, sample begin/end flow rate, sample retrieval date, operator’s initials, etc.).

If strip charts are used to record sample data from automated analyzers, they must be clearly identified. I nformation must be recorded so as not to interfere with any chart recorded data. If the strip chart is long, information should be placed at periodic intervals on the chart. Markings should be indelible and permanently affixed to each strip chart.

12.2 Sample Retrieval

In order to protect the integrity of each sample, samples need to be carefully removed from monitoring equipment/devices and place in sealed and non

- reactive containers. Specific sample retrieval procedures may be found in the respective monito ring method/SOP.

12.3 Sample Transport

Precautions must be taken to eliminate the possibility of tampering, accidental destruction, and/or physical and chemical action on the sample. Attributes that can affect a sample’s integrity include: temperature, air pressure, moisture, and physical handling of samples (packing, jostling, etc.). The practical aspects of sample transport can vary dependent upon the method. Specific handling procedures are addressed in the respective EPA and DEC monitoring methods and project

- specific QAPPs and SOPs.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

56 

### 13. ANALYTICAL METHODS

Analytical methods for the Ambient Air Quality Monitoring Program are those methods requiring laboratory analysis of samples collected under field monitoring conditions, specifically the filter

- based PM 10 , PM 2.5 and Pb methods. These
methods all have Federal Reference or Equivalent Methods designations. For a list of these methods, please go to: http://www.epa.gov/ttn/amtic/criteria.html . The EPA QA Handbook for Air Pollution Measurement Systems, Volume II, Part II provides specific Federal Reference Method procedures for the measurement of the ambient air quality criteria pollutants. These meth ods can be found on the EPA AMTIC web site http://www.epa.gov/ttnamti1/qabook.html

.

A DEC A M&QA also maintains a set of A DEC approved analytical procedures for the analysis of PM 10 , PM 2.5 and Pb

TSP filt ers. T hese methods, SOPs and other QA guidance documents can be found on the DEC M&QA web site: http://www.dec.state.ak.us/air/am/index.htm

. A list of these methods/SOPs can be found in Appendix B of this
document.

Since both specific field and analytical procedures for ambient air quality criteria pollutants are available in the above referenced documents, this section limits discussion to general concepts of Standard Operating Procedures (SOPs) and Good Laboratory Practices (GLPs) as they relate to EPA and DEC criteria pollutant monitoring methods.

13.1 Standard Operating Procedures (SOPs)

In order to perform sampling and analysis operations consistently, SOPs must be written as part of a QAPP. SOPs are written documents that detail the method for an operation, analysis, or action with thoroughly prescribed techniques and steps and are officially approved as the method for performing routine and repetitive tasks.

SOPs should ensure consistent perform ance with organizational practices, serve as training aids, provide ready reference and documentation of proper procedures, reduce work effort, reduce error occurrences in data, and improve data comparability, credibility, and defensibility. They should be sufficiently clear and written in a step

- by

- step format to be readily understood by a person knowledgeable in the general concept of the procedure. Elements to include in an SOP

are:

1. Scope & Applicability 2. Summary of Method 3. Definitions 4. Health & Safety Wa rnings 5. Cautions 6. Interferences 7. Personnel Qualifications 8. Apparatus & Materials 9. Instrument or Method Calibration 10. Sample Collection 11. Handling and Preservation Sample Preparation & Analysis 12. Troubleshooting 13. Data Acquisition, Calculations & Data Reduction 14. Computer Hardware & Software (used to manipulate analytical results and report data) 15. Data Management & Records Management 16. Data Validation Table (predetermined criteria that defines limits to determine collected data quality)ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

57 SOPs should follow the guidance document, Guidance for the Preparation of Standard Operating Procedures EPA QA/G -6 . This document is available through the EPA Quality System Homepage and web link

, http://www.epa.gov/quality/qs

- docs/g6

- final.pdf

.

It is the policy of ADEC that SOPs be written by the individual / s who are performing the procedures that are being standardized and subsequently reviewed by personnel that oversee the respective measure ment operations. SOPs for the ambient air quality monitoring program must be included in QAPPs, either by reference or by inclusion of the actual method. If a method is referenced, it must be stated that the method is followed exactly or an addendum that explains changes to the method must be included in the QAPP. If a modified method will be used for an extended period of time, the method should be revised to include the changes to the appropriate sections. In general, approval of SOPs occurs during ap proval of the QAPP. QA personnel (or their designees) with appropriate training and experience review and approve the SOPs.

13.2 Good Laboratory Practices (GLPs)

GLPs refer to general practices that relate to many, if not all of the measurements made in a laboratory. They are usually independent of the SOP and cover subjects such as maintenance of facilities, records, sample management and handling, reagent control, and cleaning of laboratory glassware. In many cases the activities mentioned above may not be formally documented because they are considered common knowledge. Although not every activity in a laboratory needs to be documented, the activities that could potentially cause unnecessary measurement uncertainty, or have caused significant variance or bias, should be cause to generate a method.

In 1982, the Organization for Economic Co

- operation and Development (OECD) developed principles of good laboratory practice. The intent of the GLP is to promote the quality and validity of test data by covering the process and
conditions under which Environmental Data Operations (EDOs) are planned, performed, monitored, recorded and reported. The principles include:

**•** T est facility organization and personnel

**•** Q uality assurance program

**•** F acilities

**•** A pparatus, material and reagents

**•** T est systems

**•** T est and reference substances

**•** S tandard operating procedures

**•** P erformance of the study

**•** R eporting of study results

**•** S torage and retention of records and material

13.3 Laboratory Activities

For ambient air samples to provide useful information or evidence, laboratory analyses must meet the four basic requirements:

1. Equipment must be frequently and properly calibrated and maintained. 2. Personnel must be qualified to make the analysis. 3. Analytical procedures must be in accordance with accepted practice. 4. Complete and accurate records must be kept.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

58 These laboratory activities relate not only to the analysis of particulate matter and lead but also other activities necessar y to collect and report measurement data such as:

**•** Certification of field and laboratory calibration standards,

**•** Certification of field and laboratory audit standards, and

**•** Preparation of standard reference materials.

Table B 10 and Table B1 1 List Laboratory Quality Control activities, their frequency of occurrence and criteria important to th e analyses and data validation f or PM 10 and PM 2.5 sample filters.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

59 

### Note 

### : PM 10 Low Vol filter analysis criteria same as PM 2.5 filter analysis, except no filter holding time criteria. 

## Table B 10 Laboratory QC Criteria for Analysis of PM 2.5 

## & PM 10 

## Low

- Vol Filters

Requirement Frequency Acceptance Criteria QA Guidance Document 2.12 Reference Information Provided

Filter Checks Unexposed filter integrity check Every filter No defects 40CFR Part 50 App. L Sec. 10.2 2.12 Sec. 7.5 ± Contamination of filter blanks from moisture gain/loss or other contaminants Exposed filter integrity check
Lot Blanks 9 filters/lot < 15 **μ** g between weighings 2.12 Sec. 7.7 Exposure Lot Blanks 3 filters/lot < 15 **μ** g between weighings 2.12 Sec. 7.7

PM 2.5 Filter Holding Times

Pre

- sampling Weighing All filters < 30 days before sampling Part 50 App l Sec 8.3 2.12 Sec. 7.9 Control s established to minimize potential loss of volatile/sub

- volatile components of particulate mass Sample Recovery ≤ 177 hours (7 days & 7 hrs) 40CFR Part 50 App. L Sec.3.3 and http://www.epa.gov/ttn/amtic/files/ambient/pm25/fil tere.pdf
Post

- sampling Weighing ≤ 10 days at 25° C from sample end date, or
≤ 30 days at 4°C from sample end date 40CFR Part 50 App. L Sec. 7.4.15

Filter Conditioning Environment Time Range All filters 24 h rs minimum Part 50 App l Sec 8.2 2.12 Sec. 7.6 Summary of Guidance; Filter conditioning and Weighing Facilit i es and Procedures for PM 2.5

Reference and Class I Equivalent Methods ( http://www.epa.gov/ttnamti1/files/ambient/pm25/qa/ba lance.pdf ) Controls established to minimize potential mass gain/loss contamination due to moisture Temperature Range 24

- hr mean

, 20 ° – 23 ° C Temperature Control ± 2° C SD over 24

- hr Humidity Range 24

- hr mean 30% - 40% RH or < 5% sampling RH bu > 20% RH Humidity Control ± 5% RH SD over 24

- hr Pre/Post Filter Conditioning RH Difference in 24

- hr means ≤ ± 5%RH Part 50 App. L Section 8.3.2
Balance Located in filter conditioning environment Part 50 App. L Section 8.3.3
Calibration/Verification

Micro Balance Readability At purchase 1 μg 40CFR Part 50 App. L Sec 8.1 2.12 Sec 4.3.6 Required balance sensitivity

Micro Balance Repeatability 1/year 1 μg 2.12 Sec 4.3.6 Required balance precision
Balance Calibration 1/yr Manufacturers spec. 2.12 sec 7.2 Verification of equipment operation Lab Temp. Calibration 6 month + 2 o C 2.12 Sec 3.3 Verification of equipment operation Lab Humidity Calibration 6 month + 2% RH 2.12 Sec. 3.3 Verification of equipment operationADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

60 

## Table B 10 Laboratory QC Criteria for Analysis of PM 2.5 

## & PM 10 

## Low

- Vol Filters

Requirement Frequency Acceptance Criteria QA Guidance Document 2.12 Reference Information Provided

Calibration standards Working Mass Stds. 3- 6 month 25 **μ** g 2.12 Sec 4.3 and 7.3 Working s tandards verification Primary Mass Stds. 1/yr 25 **μ** g 2.12 Sec 4.3 and 7.3 Transfer standards c er t ification Temperature Standards 1/yr ± 0.1 °C resolution, ± 0.5 °C accuracy 2.12 Section 4.2 Transfer standard c er t ification Humidity Standards 1/yr + 2% RH Transfer standard c er t ification QC Checks

Zero Balance Check Prior to every weighing Balance bias /stability

Balance Check (100 mg and 200 mg) beginning, every 10 th samples, end < 3 **μ** g 2.12 Sec. 7.9

Field Filter Blank 10% or 1/weighing session < 30 **μ** g between weighings 40CFR Part 50 App. L,, Sec 8.3 2.12 Sec 7.7 Overall filter handling/contamination
Lab Filter Blank. 10% or 1/weighing session < 15 **μ** g between weighings 40CFR Part 50 App. L,, Sec 8.3 2.12 Sec 7.7 C ontamination of lab blank due to moisture control , etc

. Duplicate Filter Weighing 1/weighing session < 15 **μ** g between weighings 2.12 Sec 7.11 Weighing repeatability/filter stability
Bias

Balance Audit 1/yr + 15 **μ** g for unexposed filters 2.12 Sec 10.2 Laboratory technician operationADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

61 

## Table B11 Laboratory QC Criteria for Analysis of PM 10 

## Hi

- Vol Filters

Requirement Frequency Acceptance Criteria Fed Register & EPA QA QA Guidance Document Information Provided

Filter Checks Unexposed filter integrity check Every filter No defects 2.11 Section 4.2 Filter integrity/damage Exposed filter integrity check Filter Conditioning Environment Time Range All filters 24 h rs minimum 2.11 Section s 1 .2.3 , 2 and 4 Environmental controls set to control moisture and static electricity contamination from net particulate analysis Temperature Range 24

- hr mean

, 15° – 30° C Temperature Control ± 3° C SD over 24

- hr Humidity Range 24

- hr mean 20% - 45 % RH Humidity Control < ± 5% RH SD over 24

- hr
Pre/Post Filter Conditioning RH Difference in 24

- hr means ≤ ± 5%RH
Calibration/Verification Analytical Balance Readability At purchase 0.1 mg 2.11 Section s 2 .0 and 4 .5 Verification of equipment operation Analytical Balance Repeatability 1/year 0.5 mg Analytical Balance Calibration 1/yr Manufacturers spec. Lab Temp. Calibration 3 month + 0.5 o C, 2.11 Section s 1.1.2 Lab Humidity Calibration 3 month + 6% RH 2.11 Section s 2 .0 Unexposed filter integrity check Every filter No defects 2.11 Section s 4.0, 4.1, 4.2, 4.6 Sample contamination Exposed filter integrity check Every filter No defects
Calibration standards Working Mass Stds. 3- 6 month ≤ ± 0.5 mg of NIST traceable 2.1 1 Sec 2 .1 4.3 and 4.5 Working s tandards verification
Mass Transfer Stds. 1/yr ANSI/ ASTM Classes 1, 1.1 or 2, indiv mass std accuracy ≤± 0.025mg from NIST accredited weights & measures lab or NVLAP accredited lab 2.11 sec 1.2.4, 9.0 Transfer standards certification

Temperature Standards 1/yr ± 0.1 °C resolution, ± 0. 1 °C
accuracy , NIST/ASTM traceable 2.11 Section s 1.12 Transfer standard certification

Humidity Standards 1/yr + 2% RH , NIST/ASTM traceable 2.11 Sections 2.0 Transfer standard certification QC Checks

Zero Balance Check Prior to every weighing ≤ ± 0.1 mg 2.11 section s 4.4 and 4.5 Verification of analytical balance accuracy Balance Checks (bracketing expected range of unexposed and exposed sample filters e.g., 1.0g

- 5.0g) beginning, every 10 th samples, end ≤ ± 0.5 mg

Field Blanks 10% of filters Filter contamination Filter Transport Blanks 1/batch of shipped filters Integrity of filter shipments Replicate un

- exposed Filter Weighing 10% each of pre - and post

- < ± 2.8 mg difference 2.11 section 4.5.3 Lab technician filter handlingADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

62 

## Table B11 Laboratory QC Criteria for Analysis of PM 10 

## Hi

- Vol Filters

Requirement Frequency Acceptance Criteria Fed Register & EPA QA QA Guidance Document Information Provided

Replicate un

- exposed Filter Weighing exposed filters/weighing session < ± 5.0 mg difference procedures
Bias

Balance Audit 1/yr ≤ + 5 mg of audit stds that bracket routine weights of un exposed and

exposed sample filters (3g, 5g) Laboratory technician operationADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

63 

### 14. QUALITY CONTROL (QC)

14.1 Definitions

Care must be taken not to equate Quality Control (QC) with Quality Assurance (QA). Though the two are very similar,

t here are some basic differences: QC is concerned with the product, while QA is process

– oriented. QC hence is a subset of QA.

Even with such a clear

- cut difference defined, identifying the differences between the two can be hard. Basically, QC
involves evaluating a product, activity and/ or service. By contrast, QA is designed to make sure processes are sufficient

to meet the end objectives. Simply put, QA ensures a product or service is manufactured, implemented, created, or produced in the right way; while QC evaluates whether or not th e end result is satisfactory.

Quality Assurance (QA)
– QA for ambient air and meteorological monitoring operations is the overall systematic process of planning, implementation, monitoring, verifying and determining whether the collected data meets or exce eds
the data quality objectives (DQOs) of NCore, SLAMS, SPM and/or PSD quality monitoring data.

Quality Control (QC)

– QC for ambient air and meteorological monitoring operations is the overall system of technical
functions , technical process es and physica l characteristics that measures the attributes and performance of the monitoring

pro cedure to ensure quality data meets the NCore, SLAMS, SPM and/or PSD data criteria requirements and objectives

Quality Ass essments – Q uality A ssessments are independent measurements /reviews (verifications) made of the QC
S ystem ( i.e., the technical functions, technical processes and physical characteristics that measure the attributes and performance of the monitoring procedure ) . Quality Assessments include such items as Technical Systems Audits, Performance Audits, Network Reviews, etc. (please see Section 20, Quality Assessments). As with Quality Control, Quality Assessments are also under the umbrella of Quality Assurance.

Figure B3 de picts the functional aspects of Q uality C ontrol , Q uality Assessment and their relationship within the
umbrella Quality Assurance Program for Ambient Air & Meteorological Monitoring Program

.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

64 Proper F acilities & Instrumentation

Proper Documentation Quality Control Quality Assessment 

### Figure B3

— Quality Control & Quality Assessment ’s Relationship within the Ambient Air & Meteorological Monitoring Quality Assurance Program

Standard Operating P rocedures (SOP)

Good Field Measurement Practices (GFMP) Good Laborator y Practices (GLP)

Technical Competence of Analysis Training Internal Reference Materials

Instrument Calibrations

Calibration & Verification Checks (QC Checks)

Replicate & Collocated Measurements

Quality Control Chart s

Measurement

Method Comparability

Sample Design

& Sample Representativeness ADEC Air Quality Assurance EPA Quality Assurance

Quality Assessment

External Standard Reference Materials

Performance

Audits

Technical Systems Audits

DQO/MQO Assessment

Network Reviews Inter Field/Lab Method Comparisons External Standard Reference Materials

Performance

Audits (NPAP/PEP)

Technical Systems Audits

Inter Lab Comparisons

DQO/MQO Assessment

Network ReviewsADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

65 Figure B4 describes the overall process of accepting routine data.

14.2 Measurement Quality Objectives and Quality Control

The Alaska Ambient Air Monitoring MQO Table (Table A7) and Alaska Meteorological Monitoring MQO Table (Table A8) list the most critical QC sample/criteria that must be met in order to validate/report reliable monitoring data.

14.3 Data Validation Tables and Quality Control

Method Speci fic Data Validation Criteria have been developed for the various ambient air quality and meteorological measurement methods. These criteria are ranked under three classes of “data acceptance criteria” for a measurement method and define how the criteria should/must be used to evaluate overall data quality. These method specific Data
Validation Tabl es are located in Appendix A. These data quality criteria categories are:

1. CRITICAL CRITERIA TABLE - Criteria deemed critical to mai ntaining the integrity of a sample or group of samples reside in the Critical Criteria Table. Observations that do not meet each and every criterion on the Critical Table should be invalidated unless there are compelling reason and justification for not d oing so. Basically, the samples for which one or more of these criteria are not met are invalid unless proven otherwise. The cause for not operating in the acceptable range for each violated criteria must be investigated and minimized to reduce the likel ihood that additional samples will be invalidated. 2. OPERATIONAL EVALUATIONS TABLE - Criteria that are important for maintaining and evaluating the quality of the data collection system reside in the Operational Evaluations Table. Violation of a criterion o r a number of criteria may be cause for invalidation. The decision should consider other quality control information that may or may not indicate the data are acceptable for the parameter being controlled. Therefore, the sample or group of samples for wh ich one or more of these criteria are not met is suspect unless other quality control information demonstrates otherwise. The reason for not meeting the criteria MUST be investigated, mitigated and/or justified. Reference Material

Sample

QC Sample Sample Quality Control

Sample Data

QC Data Reference Material

Data

Quality Assessment Accept Data

Data Specifications 

### Figure B4 Quality Control’s Relationship to Routine Acceptance of DataADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

66 3. SYSTEMATIC ISSUES TABLE - Criteria important for the correct interpretation of the data but do not usually impact the validity of a sample or group of samples reside in the Systematic Issues Table. For example, data quality objectives are included in this table. If data quality objectives are not met, this does not invalidate any of the samples but it may impact the error rate associated with the attainment/non

- attainment decision

.

Other elements of this QAPP that contain related sampling and analytical QC requirements include:

**•** Sample Process and Design (Section 10) – discusses requirements/issues for determining if the collected sample(s) accurately represents population/area of interest;

**•** Sample Method Requirements (Section 11) – Identifies planned field QC samples and procedures for

s ample(s) pr eparation and handling, etc.;

**•** Sample Handling & Custody (Section 12) – discusses requirements/issues related to maintaining integrity of sample(s) during transport;

**•** Analytical Methods (Section 13) - discusses requirements/issues related to subsampling methods, preparation of QC samples (e

. g., blanks and replicates); and

**•** Instrument Calibration and Frequency (Section 15) – defines prescribed criteria for triggering recalibration.

14.4 Use of Computers for Quality Control

Computers are used throughout the Ambient Air Monitoring and Quality Assurance Program for various aspects of Quality Control. Some analytical methods incorporate the use of a computer to control and semi

- automate routine analytical measurement operations (i.e., DEC laboratory gravimetric an alysis of PM 10 and PM 2.5 sample filters). Other Computers are also routinely used to monitor/measure QC within the Ambient AM&QA Program to:

**•** Compute calibration equations

**•** Compute measures of linearity for calibrations (e.g., correlation coefficients, slope and intercept)

**•** Plot calibration curves

**•** Compute zero/span drift data

**•** Compute precision and accuracy results

**•** Plot and compute control limits

**•** Automatically flag out

- of

- control results

**•** Maintain and retrieve calibration and performance records.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

67 15. 

### P ROCUREMENT, ACCEPTANCE TESTING AND MAINTENANCE REQU IREMENTS FOR INSTRUMENTS, SUPPLIES AND CONSUMABLE S

This section details the procedures used for procuring, inspecting, testing, and accepting instruments, supplies and consumables that directly or indirectly affect data quality. By having documented inspection and acceptance criteria consistency can be assured.

15.1 Procurement and Acceptance Testing of Equipment

The Air M&QA Program Manager with support form the Air Monitoring Section Manager will be responsible for identifying air monitoring equipment needs and approving equipment purchases. The following protocol will be used in procurement of air monitoring equipment:

**•** Equipment evaluation and selection. Prior to purchase, the equipment's pe rformance will be evaluated and other users queried in regard to the performance, dependability and ease of operation.

**•** Purchase specifications. The purchase contract will state the performance specifications that ensure only equipment of the desired quality is obtained, require a one year warranty, and indicate payment will not be made until the equipment has passed an acceptance test.

**•** Acceptance Testing. Prior to payment, the equipment should be tested to ensure that it meets the requirements listed in the purchase specifications. For analyzers, the minimum test consists of checking zero drift, span drift, voltage stability, temperature stability, and linearity. Acceptance test reports are to be prepared and archived by the Air Monitoring Section Manager or his/her designee.

15.2 Maintenance of Equipment

Utilizing the specifications in EPA's Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II and IV, preventive and remedial maintenance tasks, schedules, parts and supplies will be mainta ined by the AM&QA Program

.

The Station Operators are responsible for performing routine preventive and corrective maintenance. They will prepare maintenance reports that will be reviewed and archived by the Air Monitoring Section Manager or his/her design ee. Each monitoring site and/or laboratory will maintain a log book in which the Operator will record a brief description of the need for maintenance, the actions performed and the condition of the instrument after maintenance procedures were performed. Additionally, the date, time, shelter temperature, operator’s initials and any pertinent site observations will
be recorded.

Major maintenance and repair will be performed by or under the direction of the AM&QA Section Electronic
Technician. Equipment wil l be maintained according to frequencies developed by the Air Monitoring Section Manager, or as a default by the maintenance frequency recommended in the respective instrument manual or monitoring
method/SOP.

15.3 Maintenance of Calibration/Audit Standards and Equipment

Calibration, Quality Control (QC) Check and Audit Standards will be maintained within the recommended certification time period. Calibration, QC and audit standards must be maintained within specified accuracy criteria for the method
and must be calibrated/certified o ver the intended range of use. Upon receipt of a recertified or new standard, it should be compared against another standard of known quality and accuracy to ensure its reliability before routine use. C opies of
all calibration/audit / QC check standards will be maintained by the respective monitoring agency.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

68 

### 16. INSTRUMENT CALIBRATION AND FREQUENCY

Cali bration of an analyzer (or any other piece of measurement equipment) establishes the quantitative relationship
between a calibration stand ard of known pollutant concentration input (in ppm, ppb, μg/m 3 , etc.) and the analyzer’s response (chart recorder reading, output volts, digital output, etc.). This relationship is subsequently used to convert an analyzer’s response to corresponding pollutant concentrations. For these measured values to be consider ed reliable, the analyzer must be calibrated over its expected range of use with calibration standards of known accuracy (i.e., certified accurate over the calibration standard’s intended range of use). Each analyzer shall be calibrated as directed by the analyzer’s operation/instruction manual and in accordance with method specific SOPs and data validation templates.
Calibration documentation shall be maintained with each analyzer in the field and in a central backup file.
Documentation should be readil y available for review and must include:

**•** Calibration data,

**•** Calibration equation(s),

**•** Analyzer identification,

**•** Calibration date,

**•** Analyzer location,

**•** Calibration standards used and their traceabilities (showing the standard’s certified traceability over range of intended use),

**•** Identification of calibration equipment used, and

**•** Person conducting the calibration.

16.1 Calibration Standards

This section primarily address es requirements for calibrating the equipment used to calibrate the field equipment, e.g.,
transfer standards and working standards . The requirements for calibrating the field and laboratory analyzers /equipment are listed in method specific Data Validation Tables (section 14) and Tables B9 and B10 Laboratory QC Criteria for the Analysis of PM 2.5 & PM 10 Filters (section 1 3). Calibrations include adjusting the instrument or sensor to produce a response that is consistent with a standard. Calibration of a flow rate, for example, must consist of at least three separate flow rate measurements (a multipoint calibration, which is different than a multipoint verification) approximately evenly spaced within the range of the operational flow rate. Verifications, on th e other hand, are made to verify that the operations of the instrument are within specified limits. Verifications do NOT include any adjustment to the sampler /analyzer , and are described in Section 14).

Calibration activities follow a two step process:

**•** Ce rtifying the calibration standard ( typical standards used by ADEC include flow rate instruments, thermometers, barometer s and laboratory scale weights ) against a NIST standard (usually done by sending the calibration standard to a weights and measures laboratory), and

**•** Comparing the calibration standard and/or transfer standard against the routine samplers or sensors.

16.2 Calibration Hierarchy

Figure B5 , Hierarchy of Calibration Standard(s) depicts the hierarchy of calibration standards and their relationship to the field/lab equipment that they are used to calibrate.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

69 Primary Reference Standard - A primary reference standard can be defined as a homogenous material with specific properties, such as identity, unity, and potency that has been measured and certified by a qualified and recognized organization 36 , such as the NIST standard reference materials (SRMs). NIST also describes a Primary Reference Standard as a Definitions

standard that is designated or widely acknowledged as having the highest metrological qualities and whose value is accepted without reference to other standards of the same quantity. For example, NIST -F1 Atomic Clock is recognized as a primary standard for time and frequency. A true primary standard like NIST

- F1 establishes maximum levels for the frequency shifts caused by environmental factors. By summing or combining the effects of these frequency shif ts, it is possible to estimate the uncertainty of a primary standard without comparing it to other standards

. NIST maintains a catalog of SRMs that can be accessed through the Internet (http://www.nist.gov ). Primary reference standards are usually quite expensive and are often used to calibrate, develop, or assay working or secondary standards. In order to establish and maintain NIST traceability the policies posted at http://ts.nist.gov/traceability/ should be observed.

NIST Traceable Transfer Standard – is a standard that has been compared and certified either directly or via no more than one intermediate standard to a p rimary s tandard such as a NIST Standard Reference Material (NIST SRM) or a USEPA/ NIST approved Certified Reference Material (CRM). A NIST Traceable Reference Material TM (NTRM TM ) is a commercially produced reference material with a well

- defined traceability linkage to existing NIST standards for chemical measurements. This traceability linkage is established via criteria and protocols defined by NIST to meet the needs of the metrological community to be served (NIST SP 260

- 136). Reference materials producers adhering to these requirements are allowed use of the NTRM trademark. A NIST NTRM may be recognized by a regulatory authorit y as being equivalent to a CRM.

Working Standard – A working standard is used to directly calibrate analyzers/equipment. W orking s tandards may either be a NIST Traceable standard or a standard that has been directly certified against a NIST traceable standard. Certification of working standards may be established by either the supplier or the user of the standard. At a minimum, the certification procedure for a working standard:

**•** E stablishes the concentration and accuracy tolerance of a working standard or calibrates/establishes the readout of an analog/digital meter (e.g., flow meter, thermometer, barometer, RH meter and meters used to calibrate meteorological sensors). For analog/digital meter outputs the certification range and accuracy tolerances must be specified ;

**•** C ertifies that the working standard is traceable to a NIST traceable standard that is “ in

- certification over the

ran ge of measurements over which t he working standard is certified;”

**•** Includes a test of the stability of the working standard over several days; and

**•** Specifies a recertification interval for the working standard.

Note 1 : For standards that are calibrated/certified meters (e.g., flow rate, volume, thermometers, hygrometers, pressure devices, etc.), the certified standard needs to have a measurement resolution greater than the minimum required NIST SRM Primary Standards that have a NIST calibration certificate and

are periodically sent back to

NIST for rece rtification Manufacturer that uses the primary standard and may sell transfer standards Field/lab organization periodically using the transfer standard(s).to directly calibrate analyzers 

## Fi gure B5 Hierarchy of Calibration Standard(s)

Field/lab organization periodically using the transfer standard(s).to calibrate working standards Field/lab organization periodically using the working standard(s).to calibrate analyzers & equipmentADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

70 accuracy required by the monitoring method as well as to be at a minimum 2 to 4 times more accurate than the measurement method’s required accuracy criteria. Typically Commercial Reference Method (CRM) certifications for these meters are valid for one year, or as specified by the CRM c ertification time frame. Flow rate certifications, verifications, calibrations, acceptance criteria, methods and frequencies are discussed in respective methods and method specific data validation tables found in Appendices A and B and in the EPA QA
Handb ook for Air Polluti on Measurement Systems, Volumes 2 and 4.

Note 2 : Test concentrations of ozone (O 3 ) must be traceable to a primary standard UV photometer as described in 40CFR Part 50 Appendix D.

Note 3 : Test concentrations at zero concentration are considered valid standards. Although zero standards are not required to be traceable to a primary standard, care should be exercised to ensure that zero standards are free of all substances likely to cause a detectable response from the analyzer. Periodically, several different sources of
zero standards should be inter

- compared. The one that yields the lowest response can usually (but not always) be assumed to be the “best zero standard.” If several independent zero standards produce the same response, i t is likely that all the zero standards are adequate.

Note 4 : All test gas concentrations (except zero) used for multi

- point calibrations, zero/span

, precision and one

— point QC checks must be certified NIST traceable or EPA protocol as described earlier in this section.

16.3 Multi

- point Calibrations

Gaseous Analyzer Multi

- point Calibrations (e.g., CO, O 3 , NH 3 , NO 2 , SO 2 )- Mul ti

- point calibrations consist of five test concentrations, including zero concentration, a span concentration (between 8 0% and 90%) of the full scale (FS) of the analyzer under calibration, and the remaining test concentrations equally distributed between zero and span. T he zero/span test concentration s are to be introduced directly to the back of the analyzer’s sample inlet port and analyzer response adjusted to match zero/span test concentrations. After the analyzer’s zero/span has been adjusted, zero/span
test concentrations sh all again be repeated to verify analyzer response match the zero/span test gas concentrations.

Before generating the remaining test gas concentrations, the same zero/span test concentrations sh all be introduced through as much of the sample train (sample probe/lines and manifold) as practicable prior to being introduced to the analyzer’s sample inl et. The zero/span analyzer responses for both test gas configurations should be the same. If not, either there is a leak or obstruction in the sample introduction system or sample lines are contaminated. After verifying sample inlet configuration is not biasing calibration gas concentrations, complete the analyzer’s multi

- point calibration by supplying test gas concentrations directly to the back of the analyzer . Multi

- point calibrations are used to establish or verify the linearity of analyzers upon ini tial installation, after major repairs, after failure of a zero/ span or one

- point QC
check or performance audit, and at specified frequencies.

Most analyzers have zero and span adjustment controls, which are adjusted based upon zero and span test concentra tions (8 0 – 90% FS), respectively to provide the desired scale range within the analyzers specifications. For analyzers in routine operation, unadjusted (“as is”) analyzer zero and span response readings must be obtained and recorded prior to making any z ero or span adjustments. Analyzer zero and span controls often interact with each other, so adjustments may have to be repeated several times to obtain the desired final adjustment. After analyzer adjustment, final post

adjusted zero and span analyzer res ponse (using the same zero/span test gas concentrations) readings must be taken and recorded from the same calibrated output device (data acquisition system, chart recorder, etc.) that will be used for subsequent ambient air measurements.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

71 The analyzer measured responses are plotted against the respective test gas concentrations, and the best fit linear (or non

linear if appropriate) curve fit is determined. Ideally, least squares regression analysis (with an appropriate transformation of the data for n on

- linear analyzers) should be used to determine the slope and intercept for the best f it calibration line of the form:

y = m•x + b

Where : y = the analyzers response

, x = the value of the corresponding test gas concentration, m = the slope , and b = the x axis intercept of the best fit calibration line

.
When this calibration relationship is subsequently used to compute concentration measurements (x) from the analyzer response readings (y ), the formula is transposed to:

x = (y – b)/m

Specific calibration procedures and calibration criteria are found in the respective measurement methods/SOPs and data validation tables (see Appendices A and B).

As a quality control check on calibrations, the standard error or correlation coefficient must be calculated along with the regression calculations. A control chart of the standard error or correlation coefficient should be maintained to monitor the degree of scatter in the calibration points and limits of acceptability.

Calibrations of gaseous analyzers are generally required on a quarterly basis (see respective method SOPs and data validation templates for method specific calibration frequency criteria).

Particulate Monitor/Sampler Multi

- point Calibrations - Multi

- point flow rate calibrations consist of generating five evenly spaced calibration flows , including zero

, that bracket the sampler’s expected operating range.

Multi

- point calibrations will be used by ADEC to establish or verify the linearity of particulate monitor flow rate responses to known flow rates upon initial installation, after major repairs, after failure of a one

- point QC flow check or performance audit, and at specified frequencies.

Most particulate monitors have flow adjustment controls, which are adjusted based upon known flow rates generated to bracket the sampler’s expected flow operating range. For particulate monitors in routine operation, unadjusted (“as is”) flow readings must be obtained and recorded prior to making any adjustments. After adjustment, a final post

- adjusted sample r flow shall be measured/recorded to verify that the particulate monitor’ s flow rate was set correctly

.

The p articulate monitor measured responses are plotted against the respective “known” flow rates , and the best fit linear (or non

- linear if appropriate) curve fit is determined. Least squares regression analysis (with an appropriate transformation of the data for non

- linear analyzers) shall be used to determine the slope and intercept for the best f it calibration line of the form:

y = m•x + b

Where : y = the particulate sampler’s flow rate response , x = the value of the corresponding flow rate standard m = the slope , and b = the x axis intercept of the best fit calibration lineADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

72 When this cal ibration relationship is subsequently used to compute concentration measurements (x) from the analyzer response readings (y), the formula is transposed to:

x = (y – b)/m

Specific calibration procedures and calibration criteria are found in the respective measurement methods/SOPs and data validation tables (see Appendices A and B).

As a quality control check on calibrations, the standard error or correlation coefficient must be calculated along with the regression calculations. A control chart of the stand ard error or correlation coefficient should be maintained to monitor the degree of scatter in the calibration points and limits of acceptability.

Calibrations of particulate monitor flow rate measurement systems are generally required on an annual basis (s ee respective method SOPs and data validation templates for method specific calibration frequency criteria).

16.4 Zero/Span Quality Control (QC) Checks for Gaseous Analyzers

A zero/span QC check is a simplified two

- point analyzer calibration used when analyzer linearity does not need to be
checked. F or continuous gaseous analyzer s, zero/span QC checks wi ll be performed at least every 2 weeks (see specific method requirements)

, although more frequent zero/span checks are encouraged. Frequent 2

- point calibrat ion (zero/span) checks minimize the extent of analyzer drift by enablin g earlier detection of drift and enables subsequent analyzer adjustment to be made before the analyzer breaches out

- of

- control criteria with subsequent loss of collected sample data.

Th e span concentration shall be within 70% to 90% of the analyzer’s full scale (FS) range and must be certified traceable (as described in section 16.1). The zero/span gas should be introduced into as much of the sample train as practicable. Periodically t he zero/span gas should be introduced into the sampling system as close to the outdoor sample inlet as possible as an integrity check of the entire sample inlet system (sample train). The analyzer’s response to the zero/span gas at the sampler’s outside inlet should mimic the analyzer’s response to the zero/span gas as normally configured (either at the span port on the back of the analyzer or at the sample manifold).

Before any adjustment is made to the analyzer’s zero or span settings, the “unadjusted ” or “ as found” measurement must be recorded. Subsequent adjustment to the analyzer’s zero/span can then proceed. After completing analyzer adjustments, a post

- adjusted (or “as left”) zero/span measurement must be performed and recorded. These “as found” and “as left” zero/span measurements obtained prior to and after the calibration adjustment provides valuable
information for:

**•** Confirming the validity of (or invalidating) the measurements obtained prec eding the calibration,

**•** Monitoring the analyzer’s cal ibration drift, and

**•** Determining the frequency of recalibration.

Zero/span QC checks are to be documented in chronological format. Documentation includes: analyzer ID, date, standard used and its traceability, equipment used, operator performing the zero/span QC check, unadjusted zero and span responses, and final adju sted zero/span responses. Documentation shall be maintained both with the analyzer onsiteADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

73 as well as in a central file. The use of quality control (QC) charts will be used to graphically record and track level 1 zero/span results and analyzer drift.

For method specific zero/span procedures and acceptance criteria, please see the respective monitoring methods and data validation tables found in Appendices A and B and in the EPA QA Handbook for Air Pollution Measurement Systems, Volume ll, Part ll.

16.5 One -po int QC Checks for Gaseous Analyzers

ADEC will employ a one

- point QC check to monitor both precision and bias of gaseous measurement systems. A one

point QC check for gaseous measurement systems is the same as the precision gas int roduced every two weeks t o the back of the gaseous analyzer. O ne

- po int QC check results will be used to assess precision and bias over time of each gaseous analyzer

. Gaseous o ne

- point QC checks are required once every two weeks

, though more frequent checks are encouraged . One -p oint QC check concentrations must be within 16% to 20% of an analyzer’s calibrated full

- scale
measurement range.

For method specific o ne

- point QC check acceptance criteria, please see the respective monitoring methods and data validation tables found in Ap pendices A and B

.

One

- point QC checks are not to be used as a basis for analyzer zero/span adjustments, calibration updates or adjustment of ambient data. They are to be used as a verification tool showing an analyzer’s continued calibration status. Whenever

a one

- point QC check shows an analyzer is not within recommended calibration control, a subsequent zero/span (or a
multi

- point) calibration must be conducted before any corrective action is taken.

If a level 2 zero/span check is to be used in the quality control (QC) program, a reference response for the check must be obtained immediately following a level 1 zero/span (or multi

- point) calibration while the analyzer’s calibration relationship is accurately known. Subsequent level 2 zero/span check responses are compared to the most recent reference response to determine if a change in response has occurred. All level 2 zero/span checks are documented similar to level 1 zero/span checks.

16.6 Particulate Monitor One

- point QC Checks

A one

- point QC check of a PM monitor’s flow meas urement system is a simplified o ne

- point calibration of the PM measurement system when the monitor’s measurement linearity does not need to be evaluated. One

- point QC checks of particulate monitors are used by ADEC when the lin earity of t he flow measurement range (temperature and pressure also
included for PM 2.5 monitors and some PM 10 monitors) does not need to be c hecked.

One

- point QC check s of particulate monitors are conducted o n a monthly basis, although more frequent checks may be conducted when meteorological conditions are favorable and access to monitoring sites is feasible. More frequent one point QC checks minimizes the extent of measurement drift by enabling earlier detection of the PM monitor’s drift and
allows subse quent adjustment to be made before the monitor breaches out

- of

- control criteria with subsequent loss of collected sample data.

One

- point QC checks generally evaluate both :

**•** T he bias of the PM monitor’s calibrated flow measurement system,

**•** W hether specific sa mple design flow rate conditions are being met to ensure fractionation of particle s izes within specific ranges (e.g., ≤ 2.5μm for PM 2.5 ≤ 10μm for PM 10 , and ≤ 35μm for TSP), andADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

74 **•** W hether other required method specific criteria are being met (e.g., bias of temperature

, pressure and time measurement sensors).

For method specific o ne

- point QC check acceptance criteria, please see the respective monitoring methods and data validation tables found in Appendices A and B and in the EPA QA Handbook for Air Pollution Measurement Systems,
Volume II , Part s I and II

.

16.7 Data Reduction Using C alibration Information

An a nalyzer /particulate monitor/meteorological sensor ’s response calibration curve s relate the measurement system’s response to actual concentration units of measure, and the response of most measurement system’ s tends to change (dri ft) unpredictably with passing time. Hence, for sample monitoring data to be meaningful the measurement system must:

**•** B e calibrated over the range of expected measurement concentrations, and

**•** All sample measurements must be bracketed by calibration zero/span checks and o ne

- point QC checks (p articulate and gaseous measurement systems) and/or multipoint calibrations.

These two conditions must be addressed in the mechanism that is used to process the raw sample measurement readings into final concentration measurements. Specific data reduction processes are addressed in the respective monitoring
methods/SOPs and Data Validation Templates (see Appendices A and B ).

16.8 Validation of Ambient Data Based Upon Calibration Information

When zero, span and/or precision drift validation limits are exceeded, ambient measurements should be invalidated back to the most recent point in time where such measurements are known to be valid. Usually this point is the previous calibration (multipoint, level 1 zero/span , One

- point QC check or accuracy audit) unless some other point in time can clearly be identified and related to the probable cause of the excessive drift (power failure, etc.). Also, data following a measurement system’s malfunction or period of non

- operation should be regarded as invalid until the next subsequent calibration (multipoint or level 1 zero/span or o ne

- point QC che ck ). Specific validation criteria can be found in the Alaska Ambient Air Quality Monitoring MQO ( Table A7 ) and the Alaska Meteorological Monitoring MQO Table
A8

. More detailed descriptions of these MQO’s and how they are to be used to control and assess measurement

unc ertainty are described in method specific data validation tables. Method specific data validation tables may be found
in Appendix A

.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

75 

### 17. INSPECTION/ACCEPTANCE FOR SUPPLIES AND CONSUMABLES

Ambient air quality and met eorological parameters are measured using either chemical techniques or physical methods. Chemical analysis as well as some physical analysis involves the use of consumable supplies that must be replaced on a schedule consistent with their stability and t he rate at which samples are taken. Some continuous analyzer methods require chemical scrubbers to remove contaminants from zero air sources, etc. Such scrubbers need to be replaced at a frequency determined by the manufacturer as well as by the rate it is consumed, which often are monitoring site specific. Please refer to the respective method/SOPs and/or manufacturer’s operations manual for inspection/acceptance testing
and consumables criteria.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

76 

### 18. DATA ACQUISITION REQUIREMENTS

This section addresses d ata not obtained by direct measurement from the Air Quality Program. This includes both outside data and historical monitoring data. Non

- monitoring data and historical monitoring data are used by the Program in a variety of ways. At this time, the ADEC h as not formalized the types of additional data that may be needed in support of the monitoring program. Possible data bases which might be used include:

**•** Chemical and Physical Properties Data

**•** Sampler Operation and Manufacturers’ Literature

**•** Geographic Loca tion

**•** Historical Monitoring Information

**•** External Monitoring Data Bases

**•** Lead and Speciated Particulate Data

**•** Air Toxics Monitoring Data

**•** Regional Haze Monitoring Data

**•** U.S. Weather Service Data

Any use of outside data will be quality controlled to the extent possible following QA procedures outlined in this document and in applicable EPA guidance documents.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

77 

### 19. DATA MANAGEMENT

The s uccess of Alaska’s Ambient Air Quality Monitoring Program’s objectives relies on data and their interpretation. It is critical that data be available to users and that these data are:

**•** Of known quality,

**•** Reliable,

**•** Aggregated in a manner consistent with their prime use, and

**•** Accessible to a variety of users

. Quality Assurance/Quality Control (QA/QC) of data management begins with the raw data and ends with a defensible report, preferably through the compu terized messaging of raw data.

Data management encompasses the overall flow of data, from field instruments, through transfer computers (laptops, data acquisition systems , etc.) to final systems, which may be local office computers, a local network, or external systems (AQS). Various air quality staff are responsible for separate or discrete parts of the data management process :

 The site operators are responsible for data download from i nstrument s or data logger s to laptop s or work computer s . They assemble data file s , which includes raw data, calibration information and certificates, QC checks (routine checks and audits), data flags, operator comments and meta

- data where available. These files

are stored on a DEC network drive or emailed to the secondary reviewer.

 Secondary reviewers are responsible for QC review, data reformatting for AQS ( if necessary )

, and report ing to the program manager

 The p ro gram m anager is responsible for fi nal data certification



###  AQS data entry staff conducts a final review (tertiary review) and submits the validated S LAMS/SPM data to AQS

.

Figure s B 6 and B7 , AM&QA Overall Data Management Flow Charts provide a visual summary description of the data flow/managemen t process.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

78 

### Figure B6, AM &QA Data Management Flow Chart

– NCore/SLAMS/SPM

ADEC AM&QA

Juneau PM 10 & PM 2.5 Gravimetric Laboratory

ADEC

- AM&QA

Statewide Field

Monitoring Operations

FNSB Fairbanks Field

Monitoring Operations MOA

- AAPCA Anchorage Field Monitoring & PM 10 Laboratory ADEC

- AM&QA QA Officer QA Assessments Contract Lab For MOA AAPCA PM 2.5 filter

analysis

ADEC

- AM&QA Monitoring Supervisor

ADEC

- AM&QA 2 nd Tier Data Validation of AM&QA monitoring operations

EPA AQS ADEC

- AM&QA
Data Files/Archive No Data acceptable Yes

PM FRM/Continuous Data DEC PM FRM/ Continuous Data FNSB PM FRM/Continuous Data MOA AAPCA NCore/SLAMS/SPM Valid Data Reported Data Assessments ADEC Air Quality Division DirectorADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

79 

### Figure B7 , AM &QA Data Management Flow Chart

– Ambient Air & Meteorological Monitoring Conducted by Stationary Source for Regulatory Permitting Needs

Stationary Source

Air Monitoring Project Q APP P reparation Stationary Source Ambient Air and/or Meteorological Monitoring Project
Data Collection &

Independent QA Audits of Project Stationary Source Air Monitoring

Begins per Approved QAPP

A DEC Air

Permits Program/Project Manager

ADEC AM&QA QAPP QA Review & Approval Recommend reject and/or request

additional information ADEC AM&QA Ambient Air/Met Monitoring Data Review/Approval A DEC Air Permits Data Archival



### Data Management Flow Legend QAPP Submission QAPP Review/Approval Reporting of Validated Data Request Additional Data Data Review/ApprovalADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

80 There are two basic sources of data collected in support of ADEC’s NCore/SLAMS/SPM /PSD ambient air monitoring network. These are: 1. Data collected via manual ambient air monitoring sampling methods . Manual methods are those methods that require manual /physical intervention by an operator/analyst to collect and measure and calculate subsequent sample result s

. Each sample is collected/measured as an aggregate of a preset sample collection time, usually 24

- hours. These m ethods include

**•** PM 10 HiVol FRM and PM 10 LoVol FRM ;

**•** PM 2.5 FRM ;

**•** Lead on TSP ; and

**•** A variety of parameter

- specific sampling systems utilizing various methodologies and sample collection media (i.e., drum samplers, dragger tube samplers, canister samplers for VOCs, sorbent trap cartrid g es for carbonyl compounds, etc)

2. Data collected via continuous sampling ambient air and meteorological monitoring methods . Continuous methods are those methods that sample and analyze the pollutant of interest without required physical intervention by an operator to collect and measure the result. These methods utilize instrumentation that continuously measure s and re cords the measured result, usually as an hourly average. These methods include:

**•** Gaseous monitors (e.g., CO, NO 2 , O 3 , SO 2 , NH 3 );

**•** Continuous particulate monitors for PM 10 and PM 2.5 (e.g., TEOMs, BAMs, Black carbon

— Aethalometers, Nephelometers ); and

**•** M eteorologica l parameters (e.g., wind speed, wind direction, temperature, barometric pressure, relative humidity, solar radiation, ).

Measurement methods utilized in support of NCore/SLAMS/SPM/PSD monitoring projects will utilize specific standard operating procedures (SOPs) and method

- specific data validation tables that detail the necessary steps to be taken to ensure collected/reported data is reliable and of known quality.

The specific process of data management (sample collection, measurement, verification, validation, review and reporting) may vary depending upon overall method specific process. However, the overall goal for data management is to develop and implement the necessary steps to ensure that the data that resides in the final storage area reliably represents the data that

were collected. This process begins with providing proper training to the field operators and/or lab analysts.

All data are first reviewed b y the field/lab operators. The operator checks the collected data to ensure that the data file is complete and accurately represents the collected samples. The operator ensures all field /lab logbooks and/or data sheets are reviewed and any questionable d ata is appropriately flagged with additional comments added to the file describing the reason for the flag. Data files should include raw data, instrument calibration and all subsequent quality control checks and independent audit results, plus a copy of t he certification documentation.

The data the n go through a secondary review process where the field operator’s comments are reviewed and appropriate actions taken regarding the data in question. This action may include flagging data, voiding data, re

- eva luating SOPs and making changes in cases where there are recurrent problems, or as corrective action response to problem areas identified in an audit. The secondary review will be conducted by a section member not immediately involved with data collection, to add

an independen t perspective to the data

.

All NCore/SLAMS/SPM data collected and/or reported to ADEC are then stored on a secured state operate d network server. If the data are to be submitted to AQS, they are properly formatted and uploaded to the AQS data storage system following AQS data management protocols.

Figures B8 and B9 depicts ADEC’s Manual and Continuous Method Data Management Schemes.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

81 

### Figure B9, Data Management of Continuous Method s

Data storage ADEC server AQS

Reports and Statistical Analysis Field operator

100% check of all Data, Log Books, Field Data Sheets, QC checks, data reviews & Initial data flags, providing flag rational Internal QA/QC Data Managemen t Responsibilities

10% check of all data, Verify QAPP & SOP compliance Verify and validate flags, Responses to audit issues SOP procedural adjustment & recommendations Data Co llection

Data is collected electronically, via direct download to a PC, via modem or DSL Field Operator Data Management Responsibilities Maintains all log books, field data sheets, QA/QC forms Calculates concentrations as needed

, Conducts preventative maintenance, calibrations and QC checks. E nsures all test equipment is in certification and all SOPs are followed. Field operator

100% check of all data, logbooks, field data sheets & i nitial data flags, p roviding flag rational 

### Figure B8, Data Management of Manual Methods

Internal QA/QC Personnel

10% check of all data, Verify QAPP & SOP compliance Verify and validate flags, SOP procedural adjustment & recommendations Data storage ADEC S erver AQS

Reports and Statistical Analysis Field/Lab Operator Data Management Responsibilities

Maintains all log books, field data sheets, QA/QC forms Calculates concentrations as needed

, Conducts preventative maintenance, calibrations and QC checks. E nsures all test equipment is in certification and all SOPs are followed. Field/Lab Data Data is collected and recorded on forms, logbooks computer files and concentrations calculatedADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

82 19.1 Data Recording

Data entry, validation, and verification functions are integrated in to each monitoring method’s data management scheme. Procedures for data entry are provided in method specific procedures /SOPs included in Appendix B.

D ata for gaseous analyzers are continuously collected via on

- site data acquisition systems and accessed either remotely from office computers or downloaded onto computers on

- site.

Air monitoring station reports are prepared by ADEC s tation o perators and revised when changes in the instrumentation or surrounding area occur. These reports identify the station name, station identification , date and time of the change

, operator, instrument identification, parameter, scale and units. Additionally, report s document the station location, address, GPS coordinates, elevation, and probe location. These reports will be sent to the air monitoring supervisor for
review p rocessing and archiving. Annually an updated Network Plan including a desc ription of SPM and SLAMS sites
should be provide d for public comment on the DEC web page for at least 30 days. After addressing the public comments
the document will be submitted to EPA.

Air monitoring equipment calibration reports will be prepared and sen t to the air monitoring supervisor for review, processing and archiving.

The Station Operators maintain station logbooks/log sheets documenting operational and maintenance activit ies at the monitoring site. Station l ogbook /log sheets are identified with the station name, station identification , date and time of site visit, operator, instrument identification, parameter, scale and units. L og book /log sheets are used to document quality control checks (time, zero, span, precision, calibration, temperature, pressure, flow, etc.), maintenance, audits, equipment changes (span gas, permeation tubes, analyzer, recorder, pen, paper, probe, etc), and missing or invalid data.
Station records are reviewed periodically by the air monitoring supervisor, and when full, archived by the respective monitoring unit (AM&QA, FNSB, MOA

- AAPCA, etc. ) accordingly. Station records will be reviewed as part of oversight QA audits

.

Charts documenting air monitoring data are processed by the station operator, reviewed and archived by the respective monitoring unit. The charts will identify the station name, station number, date and time of the review , operator initials

, instrument identification, parameter, scale and units. The charts will be used to document quality control checks (ti me, zero, span, precision, calibration, temperature, pressure, flow, etc.), maintenance, audits, equipment changes (e.g., span gas, permeation tube, analyzer, data acquisition system, chart recorder, pen, paper, probe, etc), and missing or invalid
data.

SL AMS/SPM summary data reports should be produced annually or as directed by the project and should be published on the DEC Web page. The summary data reports will identify the project, date of issue and author. The report will
include: station identificatio n, pollutant parameter s measured

, monitoring period, max and second max value, averages, precision and bias, and units of measure

. The monitoring results will be compared to the National Ambient Air Quality Standards, where applicable.



### 19.2 Data Transformation & Reduction

Data reduction processes involve aggregating and summarizing results so that they can be understood and interpreted in different ways. The ambient air monitoring regulations require certain summary data to be computed and r eported regularly to U.S. EPA. Other data are reduced and reported for other purposes such as station maintenance. DataADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

83 transformation and reduction for criteria pollutants will follow EPA guidance. Currently the State uses scientific
calculators and Windo ws ExcelTM® software to manipulate the data. In the future some of the data reduction and transformation will be accomplished in the DR DAS data acquisition system.

The data collected by ADEC can fall into two main categories: Data transformation

**•** Data collected using a manual method requiring subsequent laboratory analysis of samples and concentration calculations

**•** Data collected using a continuous method that requires no subsequent laboratory sample analysis and concentration calculations.

Manual Method Data that are manually collected requiring subsequent calculat ions to report a concentration are listed at the beginning of Section 19 and include such method parameters as PM 10 and PM 2.5 . For all of these methods

, only those calculations identified in th e SOP for that specific method and/or listed in the CFR for that specific method are used. Currently all of these calculations are done within an established E xcel spreadsheet designed for that specific purpose. All of the E xcel spreadsheet s used in this process are established forms that have been review by ADECs Air QA officer and AM&QA’s lead technical personnel. As regulations and methodologies change these forms may be edited to reflect the respective changes. When a spreadsheet is edited

, the edits a re reviewed by lead technical staff (and as needed by the Air QA Officer) to e nsure they conform to all CFR requirements with regard to calculations and content. Where possible, it is the policy of the air monitoring group to develop and maintain concentra tion calculation procedures that minimize the possibility of transcription and calculation errors.

On occasion the ADEC operates monitoring sites that collect data using a manual method that is not a federal or equivalent PM 10 or PM 2.5 method . In these cas es , it is the ADEC’s policy to follow establishe d methodology using a two level review process for all data concentration determinations. In some cases the se methods require laboratory analysis that can not be performed within ADEC. In these cases ADEC mak es the best effort to e nsure that the sample collection and lab analysis method s are in accordance with established procedures and are followed. Specifics detailing these methods will be developed a s needed. Project plans and SOP s will be developed , reviewed and approved by knowledgeable professionals.

Continuous Methods Continuous sampling methods are listed at the beginning of Section 19 and include such method s as gaseous monitors, meteorological sensors, and continuous PM monitors. The m ethod used for each of type of monitoring system is specific to the monitor type, monitor manufacturer, and the data end use requirements. In all cases the ADEC follows either

es tablished EPA CFR requirements or manufacturer recommended operating procedures or A DEC developed methods and SOPs. The ADEC is currently in the process of developing and/or updating some of these SOP s. In some cases the ADEC is attempting to reduce the level of work needed to develop these SOPs. In these cases the ADEC is using approved SOPs from other monitoring groups to develop the new SOPs that will be used in the future. During this developmental stage the SOP that is being used as a template will be followed.

Data reduction is performed according to the needs of the project. Continuous data which are used in comparisons with the FRM data will be reduced to yield concentrations covering the same time periods and interval as the FRM data. Data Reduction

Data formatting is performed according to the needs of the proj ect. SLAMS and SPM data will be reformatted as required for AQS submittal. PSD quality data will be formatted as required by DEC Air Permits. Data FormattingADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

84 19.3 Data Transmittal

Data transmittal occurs whenever information is transferred from one person or location to another or copied, by hand or electronicall y, from one form to another. An example of data transmittal is copying raw data from a notebook onto a data entry form for keying into a computer file . Data copied from data forms and/or logbooks and entered int o computer files will be checked at 10%. I nstructions for data verification will be included in method specific SOPs.

19.4 Data Storage and Retention

Hard copy files (paper files) of Ambient Air Quality Monitoring projects and Stationary Source (e.g., PSD) Am bient Air Quality and Meteorological Monitoring projects are kept in the project manager’s office. Electro nic files of validated data maintained on ADEC network drives managed by the AM&QA Program manager and his/her staff. Validated data
is also availab le from the EPA Air Quality System (AQS) Database ( http://www.epa.gov/ttn/airs/airsaqs/index.htm ).

The Division of Air Quality maintains a hard copy of the Division’s Air Records Retention Schedul e #183200 in the Anchorage, Juneau and Fairbanks offices. The Division of Air Quality follows this retention schedule. AS: Alaska Statute, Management & Preservation of Public Records, may be found at: http://www.archives.state.ak.us/pdfs/records_management/schedules/dec/air/183200.pdf

.

Raw data sheets are retained on file at the respective air monitoring office for a minimum of three years, and are readily
available for audits and data verification activities. After three years, hardcopy records

, and computer backup media are cataloged and boxed for storage. Data archival policies for the data are listed in follow ing table. Security of data in the database is ensured by password protection.

Official data storage for NC ore/SLAMS data is AQS. In addition DEC will store all monitoring data on the DR DAS

server (Washington Department of Ecology (DOE) server). The int ent is to import as much of the historical data as possible. Data and log sheets will be stored in electronic format on the state owned server in station specific folders. Data retention on the DEC and DOE server, as well as AQS

, are indefinite.

Annual an d special summary data reports are developed for upper management and the public and are stored on the DEC web page. Raw and validated data will be stored on the AQS

, DR DAS , and State network server s. Automated data backup is performed according to DOE a nd State procedures

. AQS

, DR DAS , and the State network server s are all password protected system s , which only allow state authorized per sonnel to access and manipulate data (follow ing state and federal procedures)

.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

85 

# C. ASSESSMENTS AND OVER SIGHTADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

86 

### 20. A SSESSMENTS AND CORRECTIVE ACTION

Assessments are evaluation processes used to measure the performance or effectiveness of a system and its elements. It
is an all

- inclusive term used to denote any of the following: audit, performance evaluation, managemen t system review, peer review

, inspection and surveillance. For the Ambient Air and Meteorological Quality Monitoring Program,

assessments are:

**•** Network Reviews,

**•** Bias — Performance Evaluations (ADEC)

,

**•** Bias — Performance Evaluations (Independent Audits by EPA)

,

**•** Technical Systems Audits, and

**•** Data Quality Assessments.

Section 14 of this QAPP provides definitions for Quality Assessment, Quality Control and Quality Assurance. Figure
B3 (in S ection 14) depicts Quality Assessment’s relationship to Quality Contr ol and the overarching umbrella of Quality
Assurance.

20.1 Network Reviews

ADEC’s Ambient A ir Quality Monitoring program conducts annual network reviews of its own and other monitoring networks/agencies under its umbrella as time and resources permit. Detailed Network Assessments are conducted every five years. Network reviews and assessments are conducted to determine how well the ambient air quality monitoring system is achieving the required monitoring objectives and how it may need to be modified to continue and/or to meet its objectives (monitoring objectives are set forth in 40 CFR Part 58 Appendices D and E).

20.1.1 Network Selection

Prior to the implementation of the network review, significant data and information pertaining to the review is compiled
and eval uated. Such information might include the following:

**•** Date of last review,

**•** Areas where attainment/non

- attainment

, redesignations are taking place or are likely to take place,

**•** Results of special studies, saturation sampling, point source oriented ambient monitoring, etc.,

**•** Agencies which have proposed network modifications since the last network review, and

**•** Pollutant

- specific priorities such as PM 10 problem areas, etc.

**•** N etwork files (including updated site information and site photographs)

,

**•** AQS reports

,

**•** A ir quality summaries for the past five years for the monitors in the network

,

**•** E missions trends reports for metropolitan area

,

**•** E mission information, such as emission density maps for the region in which the monitor is located and emission maps showing the maj or sources of emissions , and

**•** National Weather Service summaries for monitoring network area

.
Upon receiving the information it is checked to ensure it is the most current. Discrepancies are noted on the checklist and resolved during the review. Files an d/or photographs that need to be updated will also be identified. Adequacy of the location of monitors can only be determined based on stated objectives. During the network review, the statedADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

87 objective for each monitoring location or site (see section 10) are reconfirmed and the spatial scale re

- verified and then compared to each location to determine whether these objectives can still be attained at the present location.

An on

- site visit will consist of the physical measurements and observations to deter mine compliance with the requirements, such as height above ground level, distance from trees, paved or vegetative ground cover, etc. Since many of these conditions will not change within one year, this evaluation at each site is performed every 3 years.

In addition to the items included in the checklists, other subjects for discussion as part of the network review and overall adequacy of the monitoring program will include:

**•** I nstallation of new monitors

,

**•** R elocation of existing monitors

,

**•** S iting criteria pro blems and suggested solutions

,

**•** P roblems with data submittals and data completeness

,

**•** M aintenance and replacement of existing monitors and related equipment

,

**•** Q uality assurance problems

,

**•** A ir quality studies and special monitoring programs

,

**•** O ther issues, such as community concerns

,

**•** P roposed regulations

, and most importantly

**•** F unding

.
A report of the network review should be written within two months of the review , distributed and appropriately filed

.

20.1.2 Conformance to Network Siting Design (40 CFR Part 58 Appendix D)

Using requirements of 40 CFR Part 58 Appendix D and Section 10, Sampling Process & Design

, the network is
evaluated to ensure:

**•** Monitoring network meets number of monitors required by design criteria requirements, and

**•** Monitors a re properly located based upon the monitoring objectives and spatial scale of representativeness.

Alaska only has SLAMS, SPM and PSD quality category monitoring sites

. ADEC and EPA Region 10 meet periodically
to decide how to best achieve the monitoring objectives specified in 40 CFR Part 58 Appendix D.

PSD monitoring networks/stations are regulated by the ADEC Air Permits Program. ADEC AM&QA provides technical support to the Air Permits Program on all aspects of Ambient Air Quality and Meteorological Monitoring.

20.1.3 Conformance to Probe Siting Requirements (40 CFR Part 58 Appendix E)

Siting criteria are specified in 40 CFR Part 58 Appendix E and Section 1 1 , Sampling Methods. Using these criteria, on

site physical measurements and observations are made to determine compliance with sample probe/monitor criteria such

as : probe height and distance from potential obstructions, pa v ed or vegetative ground co ver, potential sources of point

source pollution , etc.

EPA QA Manual Volume II Part I Appendix 15 contains an on

- site checklist for use in evaluating monitoring networks. In addition to items on this checklist, the reviewer should also:ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

88 **•** Ensure manifold and inlet probes/lines are clean and free of obstructions

,

**•** Estimate sample manifold and probe/lines inside diameters and lengths,

**•** Inspect monitoring shelters for weather leaks, safety and security,

**•** Check to ensure all sample lines are connected and free of kinks,

**•** Check to ensure that monitor exhausts are not lik ely to be reintroduced back to the sample inlet,

**•** Check to ensure that monitor exhausts are vented properly so as not to be a safety concern,

**•** Check equipment for missing parts, frayed cords, etc.,

**•** Record findings/obse r vations in a field notebook and/or checklist,

**•** Take p hotographs in each cardinal direction, (b oth looking at and looking away from sample probe as well as the shelter’s interior layout,

**•** Record monitoring site’s GPS location (l a titude / longitude/elevation) , and

**•** Document site conditions (includ e any additional photographs/videotape).

20.2 Bias – Performance Evaluations (ADEC)

Performance evaluations are a type of audit in which the quantitative data generated in a measurement system are obtained independently and compared with routinely obtained dat a to evaluate the proficiency of an analyst , air monitoring station, and/or laboratory. In order to estimate bias, an external instrument/standard must be compared against the field instruments collecting monitoring data. This external (independent) stan dard can not be the same standard/s as used to calibrate and/or perform the routine QC checks of the monitoring instruments. In addition, the individual conducting the “independent evaluation ” must also be independent from routine operations and calibration(s) of the monitoring instruments. Bias is expressed as a positive or negative percentage of the "true" value

.

Bias (Performance Evaluations) implemented in this air monitoring program incl ude periodic:

**•** Flow rate performance audits of PM monitors,

**•** L aboratory audits of PM gravimetric operations,

**•** L ead filter (laboratory analysis) audits,

**•** Performance audits of gaseous ambient air monitors, and

**•** Meteorological performance audits

The equations to be used to calculate results of performance audits are found in the respective monitoring methods , EPA QA Handbook for Air Pollution Measurement Systems Volume II Part I Section 15, and references listed in T able C 1, Bias (Accuracy) Assessments. The required frequency of performance audits and the equations used to assess gathered bias/accuracy data are listed and/or referenced in T able C 1. In general, the corresponding equations in the referenced software (EPA Data Assessment Statistical Calculator, DAS C) are suggested rather than the hand

- calculated versions

.

20.3 Bias

– Performance Evaluations (Independent Audits by EPA)

EPA Performance Evaluations are conducted through the EPA regional office in the form of participation i n the National
Performance Evaluation Program (NPE P). The NPE P audit is a quantitative comparison of results between the equipment being tested and the equipment calibrated by another primary standard (audit standard). Successful participation requires an agreement of less than 10% between the NPE P equipment and the auditee ’s equipment. ADEC AM&QA will participate in NPE P as arranged and agreed to with EPA Region 10

.

NPEP audits will be conducted by US EPA Region 10 personnel in accordance with all applicable EPA SOPs once per

yea r ( http://www.epa.gov//ttn/amtic/npepqa.html ). These audits will be conducted when necessary and if resources are available. The audit results will be summarized and reported to DEC Division of Air Quality director and the Air QA Officer when they are finalized by U.S. EPA Region 10.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

89 PSD quality monitoring projects are required to participate in the NPE P audit program, however participation is dependent upon funding and audit equipment availability thr ou gh EPA

.

20.4 Bias – Performance Evaluations (PSD Quality Monitoring Projects )

Bias for PSD quality monitoring operations is determined the same as for NCore/SLAMS monitoring except for the

req uired frequency of performance evaluations (see Table C1) and independence of agencies/contractual firms allowed
to conduct the p erformance e valuations.

Performance Evaluations for PSD quality monitoring operations will only be conducted by air monitoring contractors/agencies that are completely independent from the air monitoring contractor/agency responsible for the specific PSD ambient air and/or meteorological monitoring operations. Specifically, this requires th at agencies/industry selecting contractors to conduct perform ance evaluations and /or technical systems audits must use independent
contractual firms /air monitoring agencies with the requisite expertise to conduct the performance evaluations and that the agency/contractual firm must have complete managerial, fiscal and technical independence from the agency/contractual firm conducting /managing the monitoring and laboratory operations.

20.5 Technical Systems Audits

A technical system audit (TSA) is a thorough

, systematic, on

- site (field & laboratory) qualitative audit o f facilities, equipment, personnel, training, procedures, record keeping, data validation, data management, and reporting aspects of a
system. Once every 3 years the U.S.EPA Region 10 may conduct a technical systems audit of th e ADEC air

- monitoring

program

. These audits and/or reviews may also be conducted when necessary and if resources are available. The audit results will be summarized and reported to the DEC Division of Air Quality director and the Air QA Officer when they
are finalized.

In addition t o the EPA TSAs, t he ADEC QA Officer may also conduct internal technical system audit s of ADEC’s AM&QA program a s time and resources allow.

EPA QA Handbook for Air Pollution Measurement Systems Volume II Part I Section 15 contains an example TSA form.

PSD q uality monitoring networks are required to have an independent TSA performed at the beginning of a monitoring project (recommended with in 30 days of start

- up) and annually thereafter

.



### 20.6 Data Quality Assessments

Data quality assessments are statistical and scientific evaluations of the data set to determine the validity and performance of the data col lection design and statistical test, and to determine the adequacy of the data set for its
intended use. Data Quality Assessments for ADEC’s Ambient Air Qualit y Monitoring Network are reported quarterly, annually and every 3 years to the A M&QA program manager and to EPA Region 10. Each parameter reported will

assess the reported data :

**•** Completeness

,

**•** Bias , and

**•** PrecisionADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

90 20.6.1 Completeness

Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under correct, normal conditions. Data completeness requirements are included in the reference methods (40 CFR 50). Data Completeness objectives are listed in the Measurement Quality Objectives Tables

B 7 and B8. The data completeness goal for NCore, SLAMS and SPM pollutants is ≥ 75% valid data /monitoring quarter
and for meteo rological measurements is ≥ 80% valid data/monitoring quarter. The completeness of the data will be determined for each monitoring instrument and expressed as a percentage (equation s below)

.

Gaseous & Meteorological % DC = valid hourly data/all hours within monitoring quarter

PM 10 /PM 2.5 /Pb on TSP % DC = valid 24

- hour data/all scheduled sample run days within monitoring quarter (1/1, 1/2

, 1/3, and/or 1/6 sample day frequency)

20.6.2 Bias

Accuracy has been a term frequently used to represent closeness to truth and includes a combination of precision and bias uncertainty components. This term has been used throughout the CFR. In general, ADEC follow s the conventions of the NIST and, more recently, of EPA (ref. NIST Report 1297 and EPA G

- 9) and will not use the term accuracy, but
will describe measurement uncertainties as precision, bias, and total uncertainty (total uncertainty is the combinatio n of both precision and bias). For the Ambient Air Quality & Meteorological Monitoring program

, bias is estimated using
the results of the manual checks with a known concentration performed every two weeks for gaseous pollutants, or monthly for particulate pollutants, and will be the major estimate of bias on an ongoing basis. T he performance evaluations (performance audits) will provide another estimate of bias (see Table C1 , Bia s Assessments and web link to EPA Data Assessment Statistical Calculator, DASC ). In general, the corresponding equations in the referenced DASC software are suggested rather than the hand

- calculated version shown.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

91 

### TABLE C 1 BIAS ASSESSMENTS

Method Parameters Bias Assessment Frequency References

Single/Multi

- Point Analyzer Audits Quarterly, Annual and 3

- Year Network

Assessment

Manual (gravimetric) and continuous PM 10 , PM 2.5 , and TSP monitors Audit flow rate percent difference, d i , is calculated by:

where X i is the flow rate of the audit standard and Y i is the sampler’s measured flow rate

Note 1 : for SLAMS, SPM and NCore sites 50 % of network audited frequency every 6 months, and each network sampler audited 1/ year.

Note 2 : for PSD quality monitoring each sampler audited 1/quarter

For specific calculations (and calculators) for

determining and reporting quarterly and annual bias please refer to the federal references/web links

listed in this table **•** 40CFR Part 58 Appendix A section 4, Calc ulations for Data Quality Assessment, http://www.epa.gov/ttn/amtic/files/ ambient/pm25/092706sign.pdf

**•** Guideline on the Meaning and The

Use of Precision and Bias Data Required by 40 CFR Part 58 App A http://www.epa.gov/ttn/amtic/parsl ist.html

**•** Data Assessment Statistical

Calculator (DASC)
– The software to assist those in calculating the new precision and bias statistics
– MS Excel File Type http://www.epa.gov/ttn/amtic/parsl ist.html

**•** See EPA QA Handbook Volume

II Part 1 Appendix 15 Section 3 for audit procedures

**•** See respective ADEC Gaseous

monitoring Methods for audit
pr ocedures Lead on TSP Lead Filter Strip Performance Audit

where X i is the known concentration audit filter strip and Y i is the lead filter strip’s measured value

Note 1 : for SLAMS, SPM, NCore quality monitoring network s, each lab reporting lead on TSP is audited 2/ year

Note 2 : for PSD quality monitoring network, each lab is audited 1/quarter

Gaseous (NH 3 , CO, NO 2 , O 3 , SO 2 ) Where: Y i =analyzer response value

X i =audit gas known value

Note 1: Each multipoint audit requires at a minimum the following audit concentration
ranges:

**•** Zero

**•** Within 6% to 16% of analyzer full scale (FS)

**•** Within 30% to 40% of analyzer FS

**•** Within 70% to 90% of analyzer FS

**•** Report individual % Δ and avg. % Δ

**•** Report Linear Regression factors: slope, y

- intercept, correlation coefficient (r 2 )

**•** Report % NO 2 converter efficiency (NO 2 method)

**•** Report % NO 2 converter efficiency and % NH 3 converter efficiency (NH 3 method)

Note 2: For SLAMS, SPM and NCore monitors, each pollutant instrument within a network audited 1/year with 25% of a network audited each quarter

Note 3: For PSD quality monitoring networks each monitor audited every monitoring quarter.

WS, WD, VWS, VWD, σθ, σФ, T, TΔ, SR,BP, Dew Point , RH Δ = Y – X

Where: Δ = audit differences, Y = sensor response, X = audit known value

Note: For PSD Quality Data, Performance Audits of each sensor required semiannually EPA

- 454/R

- 99

- 005 Section 5. http://www.epa.gov/scram001/g uidance/met/mmgrma.pdf 

### 100 **× −** 

**=**

i ii i 

### X XY d

100 **× −** 

**=**

i ii i 

### X XY d

100 **× −** 

**=**

i ii i 

### X XY dADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

92 

### TABLE C 1 BIAS ASSESSMENTS

Method Parameters Bias Assessment Frequency References

Single/Multi

- Point Analyzer Audits Quarterly, Annual and 3

- Year Network

Assessment

SR, Precipitation %Δ =( Y
– X)X • 100
Where: %Δ = audit % difference, Y = sensor response, X = audit known value

Note: For PSD Quality Data, Audits of each sensor required semiannually EPA QA Handbook Volume IV ( revised draft) http://www.epa.gov/ttn/amtic/fil es/ambient/met/draft

- volume

4.pdf

20.6.3 Precision

Precision is a measure of mutual agreement among individual measurements of the same property usually under prescribed similar conditions, or how well side

- by

- side measurements of the same thing agree with each other. Sometimes, as in the case of environmental measurements such as flow rate of an instrument, precision can be estimated by repeated measurements of the same thing over some time period, such as three months. It is important that the measurements be as similar as possible, using the same equipment or equipment as similar as possible. Precision

represe nts the random component of uncertainty. This random component is what changes randomly high or low, and which, try as you might, you cannot control with the equipment and procedures you are using. Precision is estimated by various statistical techniques using the standard deviation or, if you only have two measurements, the percent difference

The equations and references in Table C2

, Precision Assessments lists references, frequency of required precision checks and the equations that are to be used to evaluate gathered precision data for NCore, SLAMS, SPM and PSD quality monitoring networks. Some of these equations are used on an ongoing basis to evaluate frequent precision checks, some are used every quarter and annually or as

- needed. In general, the corresponding equations in the referenced software (EPA Data Assessment Statistical Calculator, DASC) are suggested rather than the hand

- calculated version
shown.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

93 

### TABLE C2 PRECISION ASSESSMENTS

Method Parameters Precision Assessment Frequency Reference

Single Point Quarterly Annually

PM 10 – Collocated, gravimetric relative percent difference, di, is
calculated by:

Where X i is the concentration of the primary sampler and Y i is the concentration value from the collocated sampler.

Notes:

**•** PM 10 precision calculated for all

PM 10 measurements, however, reported only for paired values ≥ 15 μg/m 3

**•** PM 2.5 precision calculated and

reported only for paired values ≥ 3.0 μg/m 3

**•** Pb on TSP precision calculated

for all paired measurements, however, reported only for paired values with mass ≥ 0.15 μg/m 3

**•** Note 1 : Collocated sampling

required on 1/12 day g frequency for SLAMS/SPM/NCore Monitoring Networks

**•** Note 2 : Collocated sampling

required on 1/6 day frequency for all PSD Quality monitoring projects The precision upper bound statistic, CVub, is a standard deviation on di with a 90 percent upper confidence limit (Equation 11).

CVub, is a standard deviation on di with a 90 percent upper confidence limit.

Where , n is the number of valid data pairs bei ng aggregated, and χ 2
0.1 , n

- 1 is the 10th percentile of a chi

- squared distribution with n

- 1 degrees of freedom. The factor of 2 in the denominator adjusts for the fact that each di is calculated from two values with error. **•** 40CFRPart 58 App A section 4.2.1 Precision Estimate from Collocated Samplers and section 4.3.1 Precision Estimate(PM2.5 & PM10

- 2.5)
http://www.epa.gov/ttn/amtic/parslist.html

**•** Guideline on the Mea ning and The Use of

Precision and Bias Data Required by 40 CFR Part 58 App A

**•** Data Assessment Statistical Calculator

(DASC) – The software to assist those in calculating the new precision and bias statistics – MS Excel File Type). PM 2.5 – Collocated, gravimetric

Lead on TSP - Collocated

Gaseous (NH 3 , CO, NO 2 , O 3 , SO 2 )

Where: Y i =analyzer response value

X i =precision gas known value

Precision check gas standard (X ) recommended in range of 16 to 20% of instrument full scale response.

Note 1: Gaseous precision sample at 15 – 20% of analyzer FS response required on every 2 week frequency for all SLAMS, SPM, NCore and PSD quality monitoring The precision estimator is the coefficient of variation upper bound and is calculated using the above equation.

Where χ 2 0.1 , n

- 1 is the 10th percentile of a chi

- squared distribution with n

- 1 degrees of freedom. **•** 40CFRPart 58 App A section 3.2.1
http://www.epa.gov/ttn/amtic/parslist.html

**•** Guideline on the Meaning and The Use of

Precision and Bias Data Required by 40 CFR Part 58 App A

**•** Data Assessment Statistical Calculator

(DASC) – The software to a ssist those in calculating the new precision and bias statistics – MS Excel File Type).

Meteorological Precision not assessed for Meteorological Parameters 

# ( ) 100 2 **× +** 

**−**

**=**

ii ii i 

### XY XY d



# ( ) 100 2 **× +** 

**−**

**=**

ii ii i 

### XY XY dADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

94 

### 20.7 Corrective Actions, Corrective Actions Response & Corrective Action Reports

The ADEC and the audited organization may work together to solve required corrective actions for findings issued . As part of corrective action and follow

- up, an audit finding response will be generated by the audited organization for each finding submitted by the ADEC. T he audit finding response is signed by the local monitoring network manager or (where appropriate) the Laboratory Manager and sent to the ADEC Air Quality Assurance Officer and AM&QA Program Manager which reviews and accepts the corrective action. The aud it response will be completed within 30 days of acceptance of the audit report. The next audit of the monitoring network will ensure that the stated corrective action(s) were implemented and corrective action(s) taken were appropriate to return routine mo nitoring operations to acceptable levels of precision, bias, completeness, representativeness , comparability and detectability.

For PSD quality monitoring, each audit finding the audit agency/audit contractor issues, a corresponding audit finding

response and corrective action report will be generated and signed by the audited organization ’s project manager and project QA officer. This response will be included in the PSD Quality Ambient Air Quality & Meteorological Monitoring Annual Data Report ( http://www.dec.state.ak.us/air/am/PSD_Met_annual_1

- 1.pdf ).

All c orrective action reports at a minimum shall include the following information :

**•** Audit f inding (s)

**•** Cause of the problem (s)

**•** Actions taken or planned to be taken to rectify the problem (s)

**•** Responsibilities and timetable for the above actions taken

**•** Project manager’s printed name, title, signature and date

**•** Organization’s QA Officer approval (printed name, signature and date of approval)

**•** S tatement identifying if finding is closed or further following action is required

.

All corrective action report s are to be filed with the official audit records with copies sent to the auditee and all other affected parties.

20.8 Revisions to ADEC AM&QA QAPP

Annually the ADEC AM&QA QAPP will be reviewed and revised as needed. Minor revisions may be made without formal comment. Such minor revisions may include changes to identified program staff, QAPP distribution list and/or minor editorial changes.

Revision s to the QAPP that affect stated monitoring Data Quality Objectives, Method Quality Objectives, method specific data validation “critical” criteria and/or inclusion of new monitoring methods will solicit public input/comment prior to adoption of major revisions.

Notice of proposed major revisions to the QAPP will be posted on the ADEC AM&QA web site with a specified formal comment period/window.

Only the most current QAPP revision will be pos ted on the ADEC AM&QA web site.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

95 

### 21. R EPORTS TO MANAGEMENT

Table C3 , Reports to Management identifies the type and content of quality

- related reports and communications to
management necessary to support NCore/ SLAMS/SPM network operations associated with data acquisition, validation, assessment, and data reporting.

Required reports to management for the NCore/ SLAMS /SPM ambient air quality monitoring program

, and in general are discussed in various sections of 40 CFR Parts 50, 53, and 58. Guidance for man agement report format and content are provided in guidance developed by EPA's Quality Assurance Division (QAD) and the Office of Air Quality Planning and Standards (OAQPS). These reports are described in EPA QA Handbook Volume II Part 1, Section 16.

Requi red reports to management /ADEC Air Permits Group for PSD ambient air quality and meteorological monitoring are further prescribed in the following two data report formats and are available online at http://www.dec.state.ak.us/air/am/index.htm :

**•** PSD Quality Ambient Air Quality & Meteorological Monitoring Annual Data Report Format

**•** PSD Quality Ambient Air Quality & Meteorological Monitoring Summary Data Report Format 

## Table C3 Reports to Management

QA Report Type Contents Presentation Method Report Issued by Reporting Frequency

As Required Quarte r Year

Performance Audit Report s (NCore, SLAMS, SPM) Description of audit results, audit methods and standards/equipment used and any recommendations Written text and charts, graphs displaying results QA Officer/auditor 

###  

Performance Audit Report (PSD) Description of audit results, audit methods and standards/equipment used and any recommendations Written text and charts, graphs displaying results QA Officer/auditor 

###  

Corrective Action Recommendation Description of problem(s); recommended action(s) required; time frame for feedback on resolution of problem(s) Written text/table QA Officer/auditor 

### 

Response to Corrective Action Report Description of problem(s), description/date corrective action(s) implemented and/or scheduled to be implemented Written text/table Air Monitoring Program Manager 

### 

EPA NPAP Audit Results Description of audit results, audit methods and standards/equipment used and any recommendations Written text and charts, graphs displaying results EPA NPAP Program and/or Region X 

###  

EPA PM2.5 PEP Audit Results Description of audit results, audit methods and standards/equipment used and any recommendations Written text and charts, graphs displaying results EPA PEP Program and/or Region X 

###  

Technical Systems Audits (NCore, SLAMS, SPM) Summary of results; description of TSA areas reviewed; findings; and any recommendations Written text and charts, graphs displaying results EPA Region X QA Manager 

###  

Technical Systems Audits (PSD) Summary of results; description of TSA areas reviewed; findings; and any recommendations Written text and charts, graphs displaying results Responsible QA Officer 

###  

AQS Report to EPA Alaska NCore/SLAMS/SPM data report Quarterly valid data & QA/QC results ADEC

- AM&QA data base manager 

### 

Annual summary data report for local monitoring network s (NCore, SLAMS, SPM) Summary of monitoring data and associated QA/QC used to validate reported data. See PSD Quality Annual Data Report Format (above ) as example. Written text, charts, graphs, etc summarizing monitoring

data for collection period Air Monitoring Section Manager or designe e 

### 

Quality Assurance Report to Management Executive summary, precision, bias and system and performance audit results Written text and charts, graphs displaying results ADEC Air QA Officer 

### 

Network Reviews Review results and suggestions for actions, as needed Written text and tables, charts, graphs displaying results ADEC AM&QA Division Director 

###  ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

96 

# D. DATA VALIDATION AND USABILITYADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

97 

### 22. DATA REVIEW VALIDATION AND VERIFICATION REQUIREMENTS

Data review, verification an d validation

, are assessment techniques used to accept, reject or qualify data in an objective
and consistent manner.

Data review – data review is the process that evaluates the overall data package to ensure procedures were followed and
that reported data is reasonable and consistent with associated QA/QC results.

Data verification – data verification is the process of evaluating the completeness, correctness, and conformance/compliance of a specific data set against the method, procedural, or contractual requirements.

Data v alidation – data validation is an analyte - and sample

- specific process that extends the evaluation of data beyond method, procedural, or contractual compliance (i.e., data verification) to determine the analytical quality of a specific
data set to ensure that the reported data values meet the quality goals of the environmental data operations (method specific data validation criteria)

.

These assessment techniques are performed by persons implementing the environmental data o perations as well as by personnel “independent” of the operation, such as the respective organizations QA personnel and at some specified frequency. These activities occur prior to submitting data to AQS, or as in the PSD program, reporting data to DEC Ai r
P ermits.

Each of the f ollowing areas of discussion is to be considered during the data review/v erification/validation process.

1. Sampling D esign – How closely the measurement(s) represent the actual environment at a given time and location is a complex issue that is considered during development of the sampling design. Each sample should be checked for conformance to the specifications, including type and location (spatial and temporal). By noting deviations in sufficient detail, subsequent data users should be able to determine the data’s usability under scenarios different from those included in project planning.

2. Samp le Collection Procedures – D etails of how a sample is separated from its native time/space location are important for properly interpreting the measured results. Sampling methods , method specific data validation templates and field SOPs provide these details, which include sampling and ancillary equipment and procedures (including equipment contamination). Acceptable departures (for example, alternate equipment) from the QAPP,
and the action to be taken if requirements cannot be satisfied, should be specified for each critical aspec t. Validation activities should note potentially unacceptable departures from the QAPP. Comments from fie l d surveillance on deviations from written sampling plans should also be noted.

3. Samp le Handling – Details of how a sample is physically treated and h andled during relocation from its original site to the actual measurement site are extremely important. Correct interpretation of subsequent measurements requires that deviations from “accepted/standardized” sample handling procedures and the actions take n to minimize or control the changes be detailed and justified. Data collection activities should indicate events that occur during sample handling that m ay affect sample integrity. At a minimum, sample containers, sample preservation and sample shipping methods should be evaluated to ensure they are appropriate to the nature of the sample and the type of data generated from the sample. Sample identity, transport and proper sample storage conditions should also be confirmed to ensure that samples are rep resentative of its native environment as it moves through the analytical p rocess.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

98 4. Analytical procedures – Each sample should be verified to ensure that the analytical procedures used to generate the data were implemented as specified (e.g., method specific data validation templates). Sample analyses deviating from specified criteria should be flagged with suitable codes so that the potential effects of the deviation can be evaluated during data quality assessment (DQA).

5. Quality Control (QC) – The quality control section of the QAPP specifies the QC checks that are to be performed during sample co llection, handling and analysis. These include analyses of check standards, blanks and replicates, which provide indications of the quality of the data being prod uced by specific components of the measurement process. For each specific QC check, the procedure, QC check standard certified value, certification/expiration date, acceptance criteria, and corrective action (and changes) need to be specified. All

measur ement data need to be bracketed by acceptable QA, calibration and/or audit (accuracy) data to be
considered valid. Data validity needs to document the corrective actions that were taken, which samples were affected, and the potential effect on affected da ta validity. Method specific QC criteria are summarized in the respective method data validation templates (Appendix A).

6. Calibration – Calibration of instruments and equipment and the information that should be presented to ensure
that the calibrations:

**•** w ere performed within an acceptable time prior to generation of measurement data ;

**•** were performed in the proper sequence;

**•** included the proper number of calibration points;

**•** were performed using in

- certification standards that bracketed the range of reported m easurement results otherwise, results falling outside the calibration range should be appropriately flagged; and

**•** had acceptable linearity checks and other checks to ensure that the measurement system was stable when the calibration was performed.

Method s pecific calibration criteria can be found in the respective monitoring method/SOP and are summarized in the respective method data validation templates (Appendix A).

7. Data Reduction and Processing – Checks on data integrity evaluate the accuracy of “raw” data and include the comparison of important events and the duplicate keying of data to identify data e ntry errors.

Data reduction involves aggregating and summarizing results so that they can be understood and interpreted in different ways. The ambient air monitoring regulations require certain summary data (e.g., precision, bias, data completeness, etc.) to be computed and reported regularly to U.S. EPA. Other data are reduced and reported for other purposes such as station maintenance , PSD data reporting , etc. DEC requires PSD quality monitoring data to be reduced and reported on a quarterly (summary results only) and annual basis to the ADEC Air Permits Program. The required reporting formats are available on line at: http://www.dec.state.ak.us/air/am/index.htm

.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

99 

### 23. DATA VERIFICATION AND VALIDATION METHODS

Th e following data verification and validation processes will provide for data that meets the Project's quality assurance criteria.



### 23.1 Data V erification Methods

Data verification is a two

- step process: 1. Identify project needs for records, documentation, and technical specifications for data generation, and determining the location and source for these records. 2. Verify records that are produced or reported against the method, procedural, or contractual requirements, as per the field and analytical operations (i.e., sample collection, sample receipt, sample preparation, sample analysis and data verification records review).

Step 1

-- Identify p roje ct needs for r ecords, etc : For ambient air and/or me teorological monitoring project needs can be broken down into whether the monitoring pro ject supports NCore, SLAMS, SPM or PSD quality monitoring. The project needs is stated in the required monitoring project’s QAPP (chapter 5). The data verifier uses this and other support documents to determine the purp ose of data collection and specifie d needs for sample collection, data generation and documentation of the analysis.

Even though requirements for NCo re, SLAMS, SPM and PSD quality monitoring are standardized, planning document requirements will vary according to the specific purpose of sample collection and anticipated end

- use of the collected monitoring data. These differences should be reflected in the planning documents.

Project specifications may also include specifications for monitoring data (sample collection and field and /or lab analyses) and for the resulting data reports. These specifications are important in verifying that the actual metho ds employed (field/lab equipment as well as measurement procedures, etc. used) match what was requested. This ensures, “verifies,” that the specified method was used and that it met technical criteria established in the approved QAPP.

Know/determine where the records are maintained. Records may be produced by a number of personnel and maintained in a number of rooms or locations. All personnel need to comply with the record

- keeping procedures of the monitoring project (field, laboratory, etc). At any point in the data generation chain, the information needed for data verification needs to be available to the people responsible and the respective project requirements need to be clearly identified in the planning documents.

Step 2
– Verify records that are produced or reported, etc : Step 2 compares the records produced against the project needs/requirements. The project planning document (respective QAPP) that specifies the records to be reported should be used to determine what records to verify. Note: In the rare absence of such an organizational specification, the determination of data to be verified may be left to the discretion of the project manager/principal investigator and the respective agency’s quality assurance pers o n. Such a determi nation must be justified/documented and appended to the data package for subsequent data validation.

Outputs of Data Verification

1. The first output is “ verified data .” Examples of verified data that have been checked for a variety of factors during th e data verification process include:

**•** Transcription errors,

**•** Correct application of dilution factors,

**•** Correct application of conversion factors

,

**•** Correct reporting units of measure, and

**•** Appropriate field and/or laboratory data qualifiers.

Any changes to the results as origin ally reported by the field/lab monitoring group must be accompanied by a note of explanation from the data verifier or reflected in a revised sample data report.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

100 2. The second output of data verification is the “data verification record.” This record includes a “certification

statement ” certifying the data have been verified. The statement is signed by responsible personnel either within the organization or as part of external data verification. Data verification records must also include technical non

compliance issues or shortcomings of the data produced during the field and/or laboratory activities. If the data verification identified any non

- compliance issues, then the narrative must identify the records involved and indicate
t he appropriate corrective actions taken in response. The records routinely produced during field activities and at the analytical laboratory (commonly referred to as a data package) and other documentation such as checklists, handwritten notes, or tables should also be included as part of the data verification records. Definitions and supporting documentation for any field/laboratory qualifiers assigned also should be included.

The following Figure D1 , Data Verification Process

, summarizes the steps.



### - Note 1: For NCore, SLAMS, SPM monitoring projects performed by ADEC AM&QA staff, steps 1 and 2 of data verification is the responsibility for the ADEC AM&QA field and laboratory technicians.

Note 2: For NCore, SLAMS, SPM monitoring projects performed by Local Agencies, steps 1 and 2 of data verification is the responsibility for the local agency’s air monitoring staff.

Note 3: For PSD quality monitor ing projects performed by agencies/facilities / industry, steps 1 and 2 of data verification is the responsibility of the respective agency/facility /industry reporting data to ADEC.



### 23.2 **Data Validation Methods** 

Data validation is an analyte - and sample

- specific process that extends the evaluation of data beyond “data verification” to determine the analytical quality of a specific data set. Data validation criteria are based upon the measurement quality objectives (MQOs, see chapter 5) developed in a quality assurance project plan (QAPP). Data validation includes a determination, where possible, of the reasons for any failure to meet method, procedural, or contractual requirements, 

## Figure D1: Data Verification Process

Inputs to Data Verification:

**•** Project Specific Planning

Documents (e.g., ADEC and/o EPA Approved QAPP)

**•** Generic Planning Documents

**•** Field SOPs

**•** Sampling Protocols

**•** Laboratory SOPs

**•** Analytical Methods Step 1 of Data Verification

**•** Identify Project Requirements and

Determine the Location and Source of Records

Step 2: Verify Records

**•** Sample Collection

**•** Sample Shipping

**•** Sample Receipt

**•** Sample Preparation

**•** Sample Analysis

**•** Records Review Outputs of Data Verification:

**•** Data Verification Records

**•** Verified DataADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

101 and an evaluation of the impact of such failure on the overa ll data set. Data validation applies to activities in the field as well as in the analytical laboratory.

Method specific data validation tables for ADEC criteria pollutants and meteorological parameters can be found in Ap pendix A

. These validation tables list criteria for determining whether data under evaluation is acceptable for reporting as NCore, SLAMS, SPM and/or PSD quality data.

Prior to the ADEC officially reporting or using the data to make decisions concerning air quali ty, air pollution abatement, or control, the data will be verified and certified by the M&QA program manager in consultation with the Air Quality Assurance Officer.

In order for the data to be considered valid the following conditions must be satisfied:

**•** The air monitoring instrumentation must be calibrated and operated according to standard methods that have been approved for use in the ambient air and meteorological monitoring program

.

**•** The data must be accompanied by back up documentation which meet the specifications outlined in Section 14 of this Plan, and be identified with respect to station name, station number, date, time, operator, instrument identification, parameter, scale and units.

**•** The data must be bracketed by documented quality control which substantiate that t hey meet the criteria in Section 14 of this plan.

Data which are reviewed and found to satisfy these criteria will be considered valid. Data that do not, will be invalidated back to the last valid quality control check and future data will be invalidated until it can be shown to meet the project's tolerances.

Figure D 2, Data Validation Process , depicts the overall process

.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

102 Note 1: For NCore, SLAMS and SPM monitoring projects performed by ADEC AM&QA staff, initial tier of data validation is the responsibility for the ADEC AM&QA field and laboratory technicians. For NCore, SLAMS and SPM projects, the focused data validation step is the responsibility of the ADEC AM&QA Monitoring supervisor or his/her designee. Note 2: For NCore, SLAMS and SPM monitoring projects performed by Local Monitoring Agencies, the initi al tier of data validation is the responsibility of that local monitoring agency. The focused data validation step is the responsibility of the ADEC AM&QA Monitoring supervisor or his/her designee.

Note 3: For PSD quality monitoring projects performed by agencies/facilities

, both tiers of data validation are the responsibility of the responsible agency/ facility conducting the monitoring project. ADEC

- AM&QA conducts an additional independent data validation/data review to ensure monitoring project conformed to ADEC

- AM&QA PSD data quality criteria

. The primary focus of data validation is determining data quality in terms of accomplishment of the monitoring project’s stated measurement quality objectives (MQOs). 

## Figure D2: Data Validation Process

Inputs to Data Validation

**•** Project specific planning

documents (e.g., ADEC and/or EPA approved QAPP)

**•** Generic planning documents

**•** Field/laboratory SOPs

**•** Method specific data validation

tables

**•** Sampling methods

**•** Laboratory methods Perform Initial Tier Data Validation Field

**•** Evaluate field records for consistency

**•** Review field QC information

**•** Review QA information (field

performance and systems audits)

**•** Summarize deviations and determine

impact on data quality

**•** Summarize samples collected

**•** Prepare field data validation report
Laboratory

**•** Assemble planning documents and data to

be validated. Review summary of data verification to determine method, procedural, and contractually required QA/QC compliance/non

- compliance

**•** Review QA information ( laboratory

performance and systems audits)

**•** Review verified, reported sample results

collectiv ely for the data set as a whole, including laboratory qualifiers

**•** Summarize data and QC deficiencies and

evaluate the impact on overall data quality

**•** Assign data qualification codes as

necessary

**•** Prepare analytical data validation report Inputs to Data Val idation from Data Verification Process

**•** Data verification records

**•** Verified data Identify Project Requirements Initial Data Validation Outputs

**•** Data validation report

**•** Validated data

Focused Data Validation

**•** Review data validation package

(similar to initial tier data validation)

**•** Evaluate project validated data for

completeness, precision and bias

**•** ADEC M&QA NCore, SLAMS,

SPM data validation prior to AQS reporting

**•** ADEC M&QA validation of

industry/facility PSD quality data



### Focused Data Validation Rep ort

PSD Project Data Validation Report to ADEC Air Permits Group NCore, SLAMS, SPM Project Data Validation Report to EPA

- AQSADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

103 Data validation is typically performed by person(s) independent of the activity which is being validated. In large organizations this is standard practice. However, in smaller organ izations/agencies it is acceptable for the air monitoring technician s (who conduct the monitoring) to conduct the f irst tier of data validation, with the focused data validation performed by the air monitoring project’s supervisor/project manager. The appropriate degree of independence is determined on a program specific basis and identified and approved in the respec tive QAPP.

As in the data verification process, planning documents, methods, procedures, data validation tables, verified data, etc. need to be readily available to the data validators. The data validator must be knowledgeable of the specific types of in formation to be validated. For this reason, it may require different individuals with specific knowledge to validate discreet components of a data set (e.g., field monitoring/measurement activities, laboratory gravimetric analyses, metals analyses, volati le organic compound analyses, etc.).

The data validator needs to be aware of signs that indicate improper field and laboratory practices that can/will affect data integrity . EPA QA/G -8 , “ Guidance on Environmental Data Verification and Validation, ” EPA/24 0/R

- 02/004

, devotes chapter 5 to Data Integrity. This document can be found at: http://www.epa.gov/quality1/qs

- docs/g8

- final.pdf

. Each data v alidator is encouraged to familiarize the m sel ves with this and other chapters in this guidance document.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

104 

### 24. RECONCILIATION WITH USER REQUIREMENTS

The Air Quality Assurance Officer will prepare a quarterly Air Monitoring Data Quality Assessment Report for Alaska’s NCore/SLAMS/SPM monitoring network that d escribes data quality in terms of precision, accuracy and data completeness. This report will be posted o n the ADEC website at http://www.dec.state.ak.us/air/am/index.htm

.ADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

105 

# APPENDIX A

METHOD SPECIFIC DATA VALIDATION TABLES

Met

- One BAM 1020 PM 10 

### & PM 2.5 

### PM 2.5 

### FRM PM 10 

### FRM & FEM HiVol PM 10 

### FRM & FEM LowVol Met

- One SSASS PM 2.5 

### Meteorological Measurements Pb on TSP FRM/FEM by AA Spectroscopy Gaseous (SO 2 

### , NO
x 

### , CO, O 3 

### ) Methods NH 3 

### by chemiluminescenceADEC AM&QA QAPP Revision : Final Date: 02 / 23/2010

106 

# APPENDIX B

MONITORING METHODS AND STANDARD OPERATING PROCEDURES

PM 10 

### GMW Accu

- Vol FRM Hi Volume Sampler PM 10 

### & PM 2.5 

### Met -One Beta Attenuation Mass (BAM) Monitor Model 1020 PM 2.5 

### FRM R&P Partisol 2000 PM 2.5 

### R&P 1400a Tapered Element Oscillating Microbalance (TEOM) PM 2.5 

### R&P 1400a Tapered Element Os cillating Microbalance w/ 8500 FDMS (TEOM/FDMS) PM 2.5 

### Met -One Super SASS Speciation Monitor PM 2.5 

### Magee Scientific Aethalometer Thermo Electron 48(c) Carbon Monoxide Monitor O 3 

### by UV absorption SO 2 

### by UV fluorescence NO
x 

### by chemiluminescence NH 3 

### by c hemiluminescence Laboratory Gravimetric Analysis of PM 2.5 

### Air Quality Filter Samples Network Data Collection Meteorological Monitoring

These documents can be viewed at: http://www.dec.state.ak.us/air/am/index.htm

# Alaska Department of Environmental Conservation

Amendments to:
State Air Quality Control Plan

Vol. II: Analysis of Problems, Control Actions

Section II: Air Quality Control Program

Adopted

August 20 th 

# , 2010

### Adopted August 20 th 

### , 2010

(This page serves as a placeholder for two

- sided copying)

### Adopted August 20 th 

### , 2010

II

- 1 Volume II, Section II is amended as follows:

Section II

STATE AIR QUALITY CONTROL PROGRAM

The Department of Environmental Conservation (ADEC) administers the state air quality control program in Alaska and is the primary agency responsible for implementing the state air quality control plan. Portions of the control plan make up Alaska’s State Implementation Plan (SIP) and address the requirements of the Clean Air Act Amendments of 1990 and subsequent re quirements set out by the U.S. Environmental Protection Agency (EPA). Each time EPA approves an amendment to the state’s control plan those amendments become a part of the federally required and approved SIP. Other portions of the control plan are state requirements that may be pending approval by EPA or cover control measures that are not required by EPA. The air quality control plan, including the SIP, has been adopted by reference into Title 18, Chapter 50 of the Alaska Administrative Code . ADEC is responsible for establishing the air quality standards throughout the state, and ensuring that regulations are enforced statewide to maintain ambient air quality standards.

The Fairbanks North Star Borough (FNSB) and the Municipality of Anchora ge (MOA) both operate local air quality control programs in their respective jurisdictions. Their local programs concentrate on ambient air monitoring, enforcement of visible emission and dust control regulations, and local control measures to reduce moto r vehicle carbon monoxide emissions. In ad dition, the interjurisdictional Southcentral Clean Air Authority has been established to aid the MOA and the Matanuska

- Susitna Borough in pursuing joint efforts to control emissions and improve air quality in the air shed common to the two jurisdictions. As a matter of policy, ADEC encourages the development of strong local air quality control programs. ADEC provides technical assistance to ensure that air quality objectives are satisfactorily carried out. The l egal authority for establishing local air pollution control programs is found in Alaska Statute (AS) 46.14.400

— Local Air Quality Control Programs.
Department of Environmental Conservation

ADEC’s Division of Air Quality works to protect the public from th e adverse health effects of air pollution and is divided into three programs: Air Permits Program ; Air Non

Point & Mobile Source Program ; and Monitoring & Quality Assurance Program.

The Air Permits P rogram issues both construction and operating permits from offices in Anchorage , Fairbanks, and Juneau. T he Air Permits P rogram also focuses on compliance assurance with an enforcement program and a regulation devel opment team

.
The Air Non

- Point & Mobile Source P rogram consists of two sections: mobile sour ces and area source pollutants. The mobile sources section is centered in Anchorage, with staff also located in Fairbanks. The mobile sources section is responsible for implementation of mobile source air pollution programs such as the Inspection and Mai ntenance (I/M) program and low

- sulfur diesel requirements. The area source

### Adopted August 20 th 

### , 2010

II

- 2 pollutants group is centered in Juneau , with staff also located in Fairbanks, and is responsible for development of the State Air Quality Control Plan, the state implementation pla n (SIP), and air quality regulations such as I/M and conformity regulations.

The Monitoring and Quality A ssurance Program is centered in Anchorage , with staff also in Juneau and is responsible for air monitoring projects that measure the actual concentrations of carbon monoxide, particulate matter, sulfur dioxide, nitrogen oxides, ozone, lead, or other meteorological parameters. The monitoring program’s Juneau laboratory assi sts in operation and maintenance of a statewide monitoring network and assists in special monitoring projects.

AS 44.46.020, 46.03.020, 46.03.024, 46.03.760, 46.03.765, 46.03.780, 46.03.790, and AS 46.14 .010 through 46.14.990 provide ADEC’s legal authori ty (copies are in the appendi x to Section II ). In 1972, the State of Alaska Department of Law determined that AS 46.03 contained the necessary legal authorities as required by the Clean Air Act to carry out the statewide air quality control plan. This le gal opinion, found in the appendix to section II, identifies the prerequisite legal authorities for the state's air quality control program. It also covers the six basic legal requirements identified in 40 C.F.R. Part 51.11(a) in 1972. (Note: in 1986, th e legal requirements were moved to 40 C.F.R. Section 51.230.)

ADEC's Air Quality Control regulations, 18 AAC 50, are located in the appendix to Section II. Amendments adopted in 1982 allowed assumption of the Prevention of Significant Deterioration ( PSD ) program, New Source Performance Standards review for six sources, and other activities. Amendments adopted in 1983 created administrative procedures to maintain ambient air quality standards in locations where emissions from residential wood burning acti vities threaten public health and modified open burning regulations.

In 1987, the department amended regulations that control the height of stacks and the use of dispersion techniques. In 1988, the department amended fugitive emission accounting procedu res for determining permit applicability, and asphalt plant emission standards. In 1991, ADEC adopted an ambient air quality standard for ammonia. In a separate 1991 amendment package, further amendments accomplished the following:

• established an ambi ent air quality standard for particulate matter smaller than 10 microns (PM 10 

### );

• set an upper boundary for any increases of nitrogen dioxide emissions;

• reduced the visible emission standard for marine vessels from 40 to 20 percent opacity;

• revised the criteria for owners of incinerators to obtain an operating permit;

• established a new permit procedure for facilities in Anchorage and Fairbanks;

• established a new air episode category called "air quality advisory"; and

• restricted wood stove operatio n during an air quality advisory and an air
emergency.

### Adopted August 20 th 

### , 2010

II

- 3 The 1991 package also included amendments to reduce PM 10 

### levels in Eagle River and in the Mendenhall Valley. Those amendments include a public notice and 30

- day comment period for all new air quality control permits; and clarify certain permit requirements and procedures, especially issues pertaining to the definition and application of "actual" and "allowable" emissions.

In 1994, the department amended the Air Quality Control regulations (18 AAC 50) to address New Source Review and Conformity requirements. In 1998, the Transportation Conformity requirements were updated . In 2004, 18 AAC 50 was updated to identify Anchorage’s and Fairbanks’ re

- designations as maintenance areas.

The department’s Emi ssions Inspection and Maintenance Requirements for Motor Vehicles (18 AAC 52), initially adopted in 1985, were amended twice in 1994, once to establish an I/M program for vehicles used to commute into the MOA, and again in response to federal I/M regulatio ns dated November 1992. In 1996, the regulations were amended to change the implementation schedule from an annual to a biennial inspection frequency. In 1999, DEC amended Chapter 52 to incorporate a switch from BAR

- 90 to the Alaska2000 Emissions Inspectio n System. In 2000, an amendment changed the start date of the OBDII testing requirement from January 1, 2001 to July 1, 2001

. In 2009

, some minor changes were made to 18 AAC 52 to add flexibility fo r enforcement options and to recognize improved performa nce of new vehicles through a multi

- year exemption period prior to inclusion in the program. A copy of 18 AAC 52, as amended through November 4 th 

### , 2009 , is contained in Volume III, in the Appendix to Section III.A.

State oxygenated fuel regulations are contained in 18 AAC 53. These regulations were initially adopted in 1992. These regulations require d the sale of oxygenated fuels in the MOA during the control period of November 1 to March 1 from 1995 until 2004 when the MOA was re

- designated from nonattainment to attainment

.
In 2000, DEC amended Chapter 53 to change the per

- gallon CAR fee amount and in 2004 amended it to suspend the required use of gasoline containing 10% ethanol during the winter months. The amendments clarified the procedure for reestablishing blended gasoline should there be a violation of the carbon monoxide (CO) standard in the future. The use of ethanol containing gasoline has been effective for reducing tailpipe carbon monoxide emissions. However, the technology of newer vehicles reduces the emission benefits associated with this control program. Consequently as new cars replace older cars this strategy provides diminished air quality returns. It is also no longer necessary for meeting clean air standards in Anchorage. The amendments inserted language that defines guidelines for suspension or reestablishment of fuel control periods. A copy of 18 AAC 53, as amended through February 20, 2004, is contained in Volume III in the appendix to III.A.

### Adopted August 20 th 

### , 2010

II

- 4 Municipality of Anch orage
The Southcentral Clean Air Authority (SCAA) includes the MOA and the Matanuska

Susitna Borough (Mat

- Su Borough). As a means to address inter

- jurisdictional issues, the MOA and the Mat

- Su Borough may activate the SCAA, as needed.

The Anchorag e Air Pollution Control Agency (AAPCA), the air quality section of the Municipal Department of Health and Human Services, confines its control activities to just the MOA. The MOA is also the official Metropolitan Planning Organization (MPO) for Anchorage , and has lead responsibility for the continuing, cooperative and comprehensive (3C) transportation planning process throughout the MOA. In Anchorage, the MOA, along with ADEC and the Alaska Department of Transportation and Public Facilities (ADOT/PF), co nducts the 3C process through the Anchorage Metropolitan Area Transportation Study (AMATS) planning group. The AMATS group has a key role in the ongoing development of Anchorage's transportation control plan, as described in Section III.B.

The local ordinances establishing a local air program in Anchorage are included in the appendix to Section III.B

. To minimize duplicate efforts and maximize the use of available resources, ADEC and MOA maintain a formal Memorandum of Understanding (MOU) t hat serves as the basis for the division of responsibilities between state and local government for air pollution control within the Municipality of Anchorage

MOA's air pollution control efforts currently involve the AAPCA and the Municipality's Departme nt of Community Planning and Development (DCPD). AAPCA had lead responsibility for developing the transportation control plan described in Section III.B, and is also responsible for conducting the remaining local air pollution control program functions th roughout the MOA. DCPD has lead responsibility within the MOA for coordinating AMATS transportation planning activities, and works closely with AAPCA on all transportation control efforts.

Fairbanks North Star Borough

The Fairbanks North Star Borough ( FNSB) has operated a local air pollution control program since 1972. The FNSB became an official “small

- urbanized area” in the spring of 2002, when the Census Bureau issued its designations of urbanized areas based on the 2000 population census. With a pop ulation surpassing 50,000, Fairbanks is now required to operate as an MPO. The FNSB Department of Transportation has the responsibility for air pollution control in the borough, including the administration of the Fairbanks I/M Program. The FNSB air ordi nances cover the I/M program, open burning, visible emissions from stationary sources, and emergency procedures. These ordinances, which have undergone several minor revisions since 1983, are included in the appendix to Section III.C .9. In 2001, the Bo rough Assembly approved an ordinance mandating plug

- ins in some parking lots

. This ordinance, No. 2001

- 17, is found in the Appendix to Section III.C.5.

### Adopted August 20 th 

### , 2010

II

- 5 The Fairbanks air pollution control efforts, discussed in detail in Section III.C, concentrate on viol ations of the carbon monoxide ambient air quality standards. The FNSB has relied on the ADEC to control large stationary emission sources within the borough. The division of responsibilities between ADEC and the FNSB is formalized in Memorandum s of Unders tanding (MOU), which are reviewed periodically by both parties.

The FNSB, along with ADEC, ADOT/PF and the cities of Fairbanks and North Pole, participates in MPO transportation planning through the Fairbanks Metropolitan Area Transportation Study (FMAT S) planning group. The FMATS group is involved in the ongoing development of the transportation control plan for Fairbanks, as described in Section III.C.

### Craig E. 

### Campbell Lieutenant Governor State Capitol Juneau, Alaska 99811 907.465.3520 465.5400 Fax
WWW.LTGOV.ALASKA.GOV 530 

### West 

### t h 

### Ave, Suite 1700 

### Anchorage, Alaska 99501

907.269.7460 269.0263
LT.GOVERNOR@ALASKA.GOV



### OFFICE OF THE LIEUTENANT GOVERNOR 

### ALASKA

MEMORANDUM

TO: Gary Mendivil, AAC Contact Department of Environmental Conservation



### FROM:

DATE: Scott Clark Special Assistant 907.465.4081

September 29,2010



### RE: Filed Permanent Regulations: Department of Environmental Conservation

State Air Quality Improvement Plan; Air Quality Control: 18 AAC 50.030; 18 AAC 50.215

Attorney General File:

Regulation Filed:

Effective Date:

Print: JU2010201261

9/29/2010

10/29/2010

196, January 2011

cc with enclosures: Linda Miller, Department of Law Jim Pound, Administrative Regulation Review Committee Judy Herndon, LexisN exis

### ORDER ADOPTING CHANGES TO REGULATIONS OF THE DEPARTMENT OF ENVIRONMENTAL CONSERVATION

The attached two pages of regulations, dealing with air quality control at 18 AAC 50 are hereby adopted and certified to be a correct copy of the regulation changes that the Department of Environmental Conservation adopts under the authority of AS 46.03.020, AS 46.14.020, 46.14.030, 46.14.140, and 46.14.510 and after compliance with the Administrative Procedure Act (AS 44.62), specifically including notice under AS 44.62.190 and 44.62.200 and opportunity for public comment under AS 44.62.210.

This action is not expected to require an increased appropriation.

Although no comments were received, the Department of Environmental Conservation paid special attention to the cost to private persons of the regulatory action being taken. The Department of Environmental Conservation also gave special attention to alternate practical methods in this regulatory action, as required by AS 46.03.024.

The regulation changes adopted under this order take effect on the 30th day after they have been filed by the lieutenant governor, as provided in AS 44.62.180.

DATE: August 20,2010 Juneau, Alaska

# Da~~~..L1:-'----"om-m-l-ss-l-on-e-r-----­ Pursuant to delegation by Larry Hartig, Commissioner Department of Environmental Conservation

FILING CERTIFICATION

I, Craig E. Campbell, Lieutenant Governor for the State of Alaska, certify that on

# ~::;~;pieA;V~~)t" 

# 2<1 ,2010, at

# ...L:.'.-~~YH~., I filed the attached regulations according to the provisions

of AS 44.62.040

- 44.62.120.

E. Campbell, Lieutenant Governor

Register:

### FOR DELEGATION OF THE LIEUTENANT GOVERNOR'S AUTHORITY

I, CRAIG E. 

### CAMPBELL, LIEUTENANT GOVERNOR OF THE STATE OF ALASKA, designate the following state employee to perform the Administrative Procedures Act filing functions of the Office of the Lieutenant Governor:

SCOTT CLARK, Special Assistant

IN TESTIMONY WHEREOF, I have signed and affixed the Seal of the State of Alaska, at Juneau, on February 23,2010

.



## ...............•....

# :'~ .**~.L'vy''-"** 

### E. CAMPBELL LIEUTENANT GOVERNOR

### Re gister**-t'llbJ~~~jtl:t1V** 

### ENVIRONMENTAL CONSERVA nON

The lead-in language of 18 AAC 50.030 is amended to read:

# ~~ 18 AAC 50.030.

### Stat}J~!~"qua!!~**co~~~la3.** Volumes II and III of the State Air

Quality Control Plan 

### for implementing and enforcing the provisions of AS 46.14 and this

# t!n~ chapter, as amended through August 20 ,2010 [NOVEMBER 6,2009], are adopted by

reference. The plan includes the following documents which are also adopted by reference:



# . . 

# .

18 AAC 50.030(4) is amended to read:

(4) the department's 

### Quality Assurance Project Plan (or tlte State o(Alaska Air (it



## r--- Monitoring & 

### Quality Assurance Program[ALASKA QUALITY ASSURANCE MANUAL

"'--_

.... ,.,A


### /-"---' FOR AMBIENT AIR QUALITY MONITORING], 

### as amended through February 23,



## '-_/ [.ff.
2010[AUGUST 21,1996];

(Eff. 1/18/97, Register 141; am 6/21/98, Register 146; am 9/4/98, Register 147;**~------,--_..-**



### am

# 1/1/200~Register 152; am 12130/2000hRegister 156; am 9/21/2001, Register 159; am .1\

### l3/~ 1\ 

### 1/27/2002, Register 161; am

### If"m~, Register 161; am 5/3/2002, Register 162; am 2/20/2004,

Register 169; am 6/24/2004, Register 170; am 10/1 /2004, Register 171; am 12/14/2006, Register

180; am 12/30/2007, Register 184; am 5/17/2008, Register 186; am 7/25/2008, Register 187; arrj'

11/9/2008, Register 188; am 5/6/2009, Register 190; am 11/4/2009, Register 192; am 4/1/2010,

Register 193;

Authority: AS 46.03.020

AS 46.14.020 AS 46.14.030

AS 46.14.140



### 1 Sec. 30, ch. 74, SLA 1993

## 'Z. 

# 01\ Register**l{()iJf8+~-** 

### ENVIRONMENTAL CONSERVATION

18 AAC

# 50.215~~amended to read:



### (1) the department's 

### Quality Assurance Project Plan &r the State o(Alaska Air

Monitoring & 

### Quality Assurance Program 

### [ALASKA QUALITY ASSURANCE MANUAL FOR



### AMBIENT AIR QUALITY MONITORING], adopted by 

### reference in 18 AAC 

### 50.030

# for{:r-~**~;~--_._--,._---~_._._~.,,---~----_._-~._-_._-----'"----._'",** ... ,,"'-_
...**~_** .. "'--,

.. ,,_._.



# __ .".,,_



### .. 

## -

.. 

# -"**~total** 

### suspended particulates (TSP), lead, carbon monoxide, nitrogen dioxide, sulfur

dioxide, Q?;pnepand ammonia;



### (Efl 1/18/97, Register 141; am 6/21/98, Register 146; am 10/1/2004, Register 171; am

### ~1..C>Il'l**~5~)fet::.illjJ** 7/25/2008, Register

# 18~> Register A



### Authority: AS 46.03.020

AS 46.14.030 AS 46.14.140

AS 46.14.180



### 2 Sec. 30, ch. 74, SLA 1993ADDITIONALREGULATIONSNOTICEINFORMATION(AS44.62.190(d))Adoptingagency:AlaskaDepartmentofEnvironmentalConservation.2.Generalsubjectofregulation:AdoptionbyreferencerevisionstotheStateAirQualityControlPlan(SIP).3.Citationofregulation(maybegrouped):18AAC50.030andISAAC50.215(a).4.Reasonfortheproposedaction:(x)compliancewithfederallaw()compliancewithneworchangedstatestatutecompliancewithcourtorderdevelopmentofprogramstandardsother:(pleaseList)5,RDU/componentaffected:DivisionofAirQuality.6.Costofimplementationtothestateagencyandavailablefunding(inthousandsofdollars):InitialYearSubsequentFY2OIOYearsOperatingCost$0CapitalCost$0Federalreceipts$0GeneralRindmatch$0$0Generalfund$0$0Generalfund!programreceipts$0Generalfund!mentalhealth$0$0Otherfunds(specify)$07.Thenameofthecontactpersonfortheregulations:Name:ScottJ.Sloane.Title:EnvironmentalProgramSpecialist.Address:DivisionofAirQuality,ADEC,410WilloughbyAvenue,Suite303P.O.Box111800,Juneau,Alaska99811-1800.Telephone:907-465-5176E-mailaddress:scott.sloanealaska.gov8.Theoriginoftheproposedaction:XstaffofstateagencyfederalgovernmentgeneralpublicpetitionforregulationchangeXother(pleaselist)MunicipalityofAnchorageAirQualityProgram9.Date:02?’‘/0Preparedby:.?rf24”72.,Ø4na._X___Name(typed)Scott.ST,aneTitle(typed)EnvironmentalProgramSpecialistIllTelephone:465-5176Affidavit of Publication RECEIVED JULO 62010 4DEC AO

United States of America

State of Alaska

First Division Ad#: ooIg73q5 Ref#:]jo* 3-sisS-’

Legal #:

Loct-oqa.

i, ‘Eartaca laWet-,

being first

duly sworn, oath, depose, and

say that I

am the Principle Clerk of the JUNEAU

EMPIRE, a newspaper of general
circulation, published in the city of

Juneau, State of Alaska; that the publication was published in said
newspaper on the 24%ay of__________ 20lOandthereafterfor I

ad itional day(s), the last date of
publication being &.s. 3• , 2010.

4.’. Subscribed and

orn to before

me this

I dayof 2010.

Notary Public in and for the State of Alaska.

1 Nor;’;r 0 Iasiofl ExpiNOTICE

OF PROPOSED CHANGES

TO TIE REGULATIONS

OF ThE ALASKA DEPARTMENT

OF ENVIRONMENTAL CONSERVATION The Alaska Department

of Environmental

Con servation (ADEC) proposes

to adopt regulation changes

in TItle iSof
the Alaska Administrative Code (AAC) Chapter

50 AIr Quality Control.

18 AAC 50.030 State
Air Quality Control
Plan

is being amended

to adopt

the tollowing
docu ments

by reference: - Volume

I. Section

II: Air Quality Control Pt.,.. is being revised

to update references

to the Municipal ity of Anchorage’s (MOA’s) Vehicle Inspection

& Main tenance

(IRA) Program wt’ilch

is being removed

as

a primary ca,ton monoxide

(GO) control measure follow ing the adoption

of this SIP subrnltal

aid approval

by EPA; -Volume

II, Section
lIlA: Statewide Carben Mon oxIde Control Program

Is being revised

to update

ref ers noes

to MOA’s

CO control measures

and 1dM Pro gram. MOA

is discontinuing

its IN Program

arid there- tore removing

it as

a primary

CO control measure

with the adoption

of this SIP submittal

and approval

by EPA. The State

of Alaska’s commuter

1dM program

will be discontinued

upon
the suspension

of the MOA
IN Program; -Volume

U, Sectien

lii. B: Anchorage flanspesta lIon Control Program

is being revised

to update MOA’s

CO Maintenance

Plan witti new data and infor mation tiemonatraing

that MOA
wili conlflie

to main tain the CO National Ambient

Air Ouality Standards (NAAQS) ttwough

tiw year 2023 following

the aspen sion

of its 1dM Program;

to update

the Co control

and contingency measures

that MOA
will employ

to main tain the CO NPAQS;

and establish

a mobile source emission budget

to be used

in tuture conformity
deter miriations

of
U isportatlon

plans aid programs wRit MOA. -Volume

II, Section lll.D2: Eagle RIver PU-b Urn Red Maintenance

Plan

is being adopted

to demon strate compliance

with maintaining

the coarse pesttai late matter (PM-to) NMOS

in Eagle River, Alaska$ -Volume

Ill, Appendices

to Volume

II,

is being

re vised

to include

the amended

18 MC 50.030 regula tion; MOA’s 2007 Co emission inventory

and 2023
CO enlission projections;
MOA’s analysis

of probthiMy

of complying

with the CO NMQS through 2023;
end MOWs most recently adopted resolutions

and code. -Volume

Ill, Appendices

to Volume

II,
is also being revised

to adopt

by reference

the Anchorage Assembly Resolton

AR 2010-4 adopting

the Eagle River PM-ID Limited Maintenance

Plan:
the PM1O design values

for Eagle River and qualification

for Limited Maintenance Plan;
the 2007 and 2020 PMIO Emission Inventories for the Eagle River Umited Maintenance

Area; and the Natural Events Action Plan
for Windblown

Oust Events in Anchorage. Alaska. -Rated Quaftty Assume Pttsa
Plan

fo, the State

of Alaska

Air Monitoring

S Qualify Asswance Avgram, dated February 23,2010. You may comment

on the proposed regulation changes, including

the potential
costs

to private persons

of complying

and alternative practical methods

of complying

with
the proposed changes,

by submitting written comments

to Scott Sloane, Division

of Ak Quly, ADEC,
410 Willoughby Avenue,

Suite
303, RO. Box 111800, Juneau, Alaska 99611-1600,

or by fac simile

at: (907) 465-5129. Comments

must

be received

by 5:00p.m.

on August

6, 2010. Com ments received
alter this date will not be consid ered

in final action

on these rules.

The Department

will hold

a public hearing

on this proposal

on August

2, 2010 from 1230-1:30

pm,

at the ADEC Bayview Office Building, Cohterence

Room

A, 619 ShIp Creek Drive, Anohorage, Alaska.

Oral

or written com ment may

be submitted

at the hearing.

The hearing

wRi be extended

if necessary

to accom modate those present before
1:30 pm who dd not have

an opportunity

to comment.

If you will not be able

to attend

the public hearing

In per son please contact Cindy

Hell

at (907) 269-7579

by five days prior

to the hearing

to make arrangements

to participate

by phone. The State

of Alaska, Department

of Environ mental Conservation complies

with TItle

II of the Americans

with Disabilities

Act
of 1990.

II you are

a person
with

a disability

who may need

a special accommodation

in order

to participate

In this pubiic process, please contact Deborah Pock

at (907) 269-0291

or TDD Relay Service l-800-770-SS7SITTY

or dIal 711 within

20 days of publication

of this notice

to ensure
that any necessary acconinodatioris

can be provided. For

a copy

of the proposed regulation changes and SIP documents please refer

to this ADEC webpage i*tpMIwW.deC.state.ak

us/al r/apkal coder. hun,

or contact Scott Sloane

by tele phone

at (907) 465-5176,

or by e-mail

at fIshaiie@Ala*S.a0Y. Alter the public coriwnent period ends

on August 6, 2010, ADEC

will either adopt these

or other previsions dealing
with the same subject, with out further notice,

or decide

to take

no action

on them.

The language

of the final regulations may
be dIfferent
from that

of the proposed
regal latlons.
You should comment during

the time

al lowed

if your interests could

be affected.

Writ ten comments received

are public records

arid are subject

to public inspection. Statutory Authority:

AS 46.03.010, AS 48.03.020,

AS 46.14.030,

AS 4814.510 Statutes BeIng Implemented, Interpreted, or Made Specific:

AS 46.14.030,

AS 4614.510 Fiscal Infonnatloll:

The proposed regulation changes

are rick expected

to require

an increased appropriation. Dated: June 28th, 2010 Hat ConclasiOn Publish: June29

and 30, 2010.6fl0/2Q10RECEIVEDADIDAThAnchorageDailyNewsAffidavitofPublication1001NorthwayDrive,AnchongeAK99508niaOTHEROThEROThERGRAND£2ACCOUNTPERDAYCHARGESCHARGES*2CHARGES#31TYFALJULDC2010ADECAQ33513610STOflIDI33513610STOFI1DI$468.12$468.12$936.2450.00$0.00$0.00$936.24STATEOFALASKATHIRDJUDICIALDISTRICTShaneDrew,beingfirstdulyswornonoathdeposesandsaysthatheisanadvertisingrepresentativeoftheAnchorageDailyNews,adailynewspaper.ThatsaidnewspaperhasbeenapprovedbytheThirdJudicialCourt,Anchorage,Alaska,anditnowandhasbeenpublishedintheEnglishlanguagecontinuallyasadailynewspaperinAnchorage,Alaska,anditisnowaridduringaUsaidtunewasprintedinanofficemaintainedattheaforesaidplaceofpublicationofsaidnewspaper.Thattheannexedisacopyofanadvertisementasitwaspublishedinregularissues(andnotinsupplementalform)ofsaidnewspaperontheabovedatesandthatsuchnewspaperwasregularlydistributedtoitssubscribersduringallofsaidperiod.Thatthefullamountofthefeechargedfortheforegoingpublicationisnotinexcessoftheratechargedprivateindividuals.SignedSubscribedandsworntomebeforethisdate:@6.9%’NotaryPublicinandfortheStateofAlaska.ThirdDivision.Anchorage,AlaskaNOI1CEOPPROPOSEDCHANGESTO11IERBGUIAflONSOPThEALASKaDEPAMMENTOPinWIRONMBNTALCONSBRVATIONTheAlaskaDepartmentDiEnvironmentalConsavetioti(ADEC)proposestoadoptregulationchangesinTitleieoftheAlaskaAdministrativeCode(MC)Oiapter50AirQualityControl.ISMC50.030StateAirQualityControlPlanisbeingamendedtoadoptthefollowingdocumentsbyav.lameIi,SectionII:MrQualityCentralbeingrevIsedtoupdatereferencestothetclpalityofAnchorages(MOAs)vehIclemspectlon&Maintenance(i/hi)Programwhichisbeingr&novedasaprlnincattonmonoxide(CO)controlmeaswefollowingtheadoptionofthisSIPubTdualarIdapproyeibyPAVolumeII,SectionIfl.A:StatewideCarbeaM.n.xideC.ntrolPrograaisbeingrevisedtoupdatereferencestoM0AsCocontrolmeasuresandi/NProgram.MOAisdiscontinuingitst/MProgramandthereforeremovingftasaprtnaryCOcontrolmeasurewiththeadoptionofthisSIPsubmittalandapprovalbyEPA.TheStateofAabsccqnntutut/Mpr08nwbethcontlrtieduponthesuspensionoftheMOAI/hiProgram;velumeIi,Sectloaill.B:AitcborageTnn.portalloaControlProyamIsbeingrevisedtoupdateMOA’sCOMaIntenancePlanwitnewdataandinformationdemonstratingthatMOAwillcontinuetomaintaintheCONationalAmbient*QualityStandds(NaAQS)throughtheyear2023followingthesuspensionofitsi/MProgram;toupdatetheCOcontrolandcontingencymeaswesthattAwillemploytomaintaintileCONAAOS;acidtsiian’aliesoirceentlssionbuettobeusedInfutureconformitydetermInationsoftrainpan&IdprogramwflMO&volateil,Sectionlil.D.tBleRiverPM•lOUndtedMaIntenaacePlanisbeingadoptedtodemonstratecompliancewIthmaintainingthecoarserticuiatematterWM’lO)NAAQSInEagleFdV%Volumeill.Appendicestovolumeii,IsbeingrevisedtoincludetheamendedISAAC50.030regulation;MOA’s29)7COemissionWwentoryand2023COemIssionproiectlens;MOASan&vsisofprltycf.corrcdr€withtheCONMQSifrctiØiMOAsmostrecentjadoptedresokrioesvolumein.AppendicestoVolumeII,IsalsobeingrevIsedtoadoptbyreferencetheAnchorageAssemblyResolutionAR2010-4adoptingtheEagleRiverPM-bLimitedMaintenancePlan;thePMIOdesignvaluesforEagleRiverandqualificationforLimitedMaintenancellan;the2007and2020PM1OEmissionInventoriesfortheEagleRiverLimitedMaintenanceArea;andtheNaturalEventsActionPlanforWindblownOustEventsinAnchorage.Alaska.RevisedQuailtyAssuranceProlectPlanfortheStateofAlaskaAirMonitoring&QualityAssuranceProgram,datedFebruary23,210.Youmaycommentontheproposedregulationchanges,includingthepotentialcoststoprivatepersonsofcomplyingandalternativepracticalmethodsofcomplyingwiththeproposedchanges,bysubmittingwrittencommentstoScottSloane,DivisionofAirQuaiity.ADEC,410WilioughbyAvenue,Suite303,P.O.Sox111800,Juneau,Alaska99811-1800,orbyfacsimileat:(907)465-5129.Commentsmustbereceivedby5:00p.m.onAogust6,2010.CommentsreceivedafterthisdatewllrnotbeconsIderedInfinalactionontheserules.TheDepartmentwillholdapublichearingonthisproposalonAugust22010from12:30-1:30pm,attheADEC8atewOffice8uildinConferenceRoomA,619shipCreekDrive.Anchorage,Alaska.Oralorwrittencommentmaybesubmittedatthehearing.Thehearingwillbeextendedifnecessarytoaccommodatethosepresentbefore1:30pmwhodidnothaveanopportunitytocomment,ifyouwillnotbeabletoattendthepublichearinginperson,nintnrnntsr’trinrlvNeilat10n719A0.7S70bynyc78596306//2O1006/30/2010RECEIVEDJUL02010UNITEDSTATESOFAMERICASTATEOFALASKA>-SS.FOURTHDISTRICTJNOTICEOFPROPOSEDCHANGESTOThEREGULATIONSOFThEALASKADEPARTMENTOFENVIRONMENTALCONSERVATIONTheAlaskaDepartrnentofErMronrnentalConservation(AD€C)ProposestoadoptregulationchangesInTItle18oftheAlaskaAdrnb-ilstratlveCode(AAC)chapter50AkQualityControl.ISAAC50.030StateAkQualityControlPlanisbeingsTiendedtoadoptthefollowingdocumentsbyreference:•VolumeII,SectionU:AkQusalyControlProgramisbeIngrevisedtoupdatereferencestotheMunicpantyofAnchoragws(MONa)VehicleInspection&MaIntenaice(I/IA)ProgramwhIchIsbeingremovedasaprfrnamycarbonmonoxide(GO)controlmeasisefollowingtheadoptionoftillsSIPatmittalandapprovalbyEPA;•VolumeIi.SectionULAStatewideCarboaMonoxideControlProgramIsbeingrevisedtoupdatereferencestoMOAsCOcontrolmoastxesandI/IAPro9rain.MOAIsdiscontktdngItsI/IAProgramandthereforersfnoQfngItasaprimaryCOcontrolmeasurewiththeadoptionofthisSIPsubmittalandapprovalbyEPA.TheStateofAlaaksscommuterI/Mprogramwillbedlscan0ilnueduponthesuspensionoftheMOAi/IAProgram;VolumeII,Sectionill.B:AnchoragefranapottatlonCon-g.troiProgramIsbeingt,*revisedtoupdateMONaCOMalnte4nancoPlanwtttinew4ataandinformationrdemonstratingthatMOAwillcontinuetomaintaintheCONationalAmbientAirQualityStandards(NAAOS)throughtheyear2023followingthesuspensionofItsI/MProgram;toupdatetheCOcontrolandcontIngencymeasuresthatMOAwillemploytomaintaintheCONAAQS;andestablishaNotaryPublicinandfortheStateAlaska.Ad4354989AFFIDAVITOFPUBLIATIONADECAQBeforeme,theundersigned,anotarypublic,thisdaypersonallyappearedBnnnteKeanan,who,beingfirstdulysworn,accordingtolaw,saysthathe/sheisanAdvertisingClerkoftheFairbanksDailyNews-Miner,anewspaperCi)publishedinnewspaperformat,(ii)distributeddailymorethan50weeksperyear.(iii)withatotalcirculationofmorethan500andmorethan10%ofthepopulationoftheFourthJudicialDistrict,(iv)holdingasecondclassmailingpermitfromtheUnitedStatesPostalService,(v)notpublishedprimarilytodistributeadvertising,and(vi)notintendedforaparticularprofessionaloroccupationalgroup.Theadvertisementwhichisattachedisatruecopyoftheadvertisementpublishedinsaidpaperonthefollowingday(s):June29,2010June30,2010andthattheratechargedthereonisratechargedprivateindividuals,discounts.notexcessofthewiththeusualSubscribedandsworntobeforemeonthisfldayofTi,nø,20JQMycommissionexpires6//13STATEOFALASKA)FIRSTJUDICIALDISTRICT))AFFIDAVITOFAGENCYRECORDOFPUBLICCOMMENTI,ScottJ.Sloane,EnvironmentalProgramSpecialistIIIfortheDepartmentofEnvironmentalConservation,beingdulysworn,statethefollowing:TheDepartmentofEnvironmentalConservationdidnotreceiveanyfactualorothersubstantiveinformationthatwassubmittedinwritingaspubliccommentandthatwasrelevanttotheaccuracy,coverage,orotheraspectoftheDepartmentofEnvironmentalConservationregulationsonamendmentstotheStateAirQualityControlPlanasadoptedbyreferencein18AAC50.030.ScottJ.Soane,EPSIIISUBSCRIBEDANDSWORNTObeforemethis —[NOTARYSEAL]STATEOPALASKAOFFICIALSEALCassidyV.KearneyNOTARYPUBLICMyCommissionExpiresWithOffice.dayof____________F3O1O áL4 A4NotaryPubffciffandforthe

7StateofAlaskaMycommissionexpires:&/J4f_4QtcDate: Aca’

9 ,zqo/neau,Alaska/12STATEOFALASKA34DEPARTMENTOFENVIRONMENTALCONSERVATIONS67B910PUBLICHEARING1112PROPOSEDREGULATIONSAMENDMENTS13TOTITLE18OFTHEALASKA14ADMINISTRATIVECODE,CHAPTER5015ARTICLE116AIRQUALITYCONTROL171819202122August2,20102312:30p.m.24Anchorage,Alaska2526272829PRESENT:3031CindyHeil32EnvironmentalProgramManager33StateofAlaska,DEC34DivisionofAirQuality35619ShipCreek36Anchorage,Alaska9950137(907)269—7634383940414243444546KRONASSOCIATES1113W.FireweedLane,Suite200Anchorage,Alaska99503(907)276355421PROCEEDINGS2THEREPORTER:Onrecordat12:30p.m.3MS.HElL:ThePublicHearinghasnowstarted.4PleaseopenthePublicRecord.MynameisCynthiaHeil,5EnvironmentalProgramManagerwiththeDivisionofAirQuality,6AlaskaDepartmentofEnvironmentalConservation.7Today’sdateisAugust2,2010,anditis12:30p.m.,in8Anchorage,Alaska.9ThepurposeoftodaysPublicHearingistoreceive10testimonyontheproposedregulationamendmentstoTitle18of11theAlaskaAdministrativeCode,Chapter50,Article1-Air12QualityControlplanwhichincludestheadoptionbyreference13changesbeingmadetotheAnchorageTransportationControl14Programplanwhichisbeingrevisedtoupdatechangesbeingmade15totheMunicipalityofAnchorage’sVehicleInspectionand16MaintenanceProgramwhichisbeing--proposedbeing17discontinued;thediscontinuationoftheStateofAlaska’s18commuterI/Mprogramwhichwillalsobediscontinueduponthe19suspensionoftheMOAVehicleInspectionandMaintenance20Program;theEagleRiverPM-l0LimitedMaintenancePlan,which21isbeingadoptedtodemonstratecompliancewithmaintainingthe22PM-bNAAQSinEagleRiver,Alaska.Andfinallytherevised23QualityAssuranceProjectPlanfortheStateofAlaskaAir24MonitoringandQualityAssuranceProgram,whichisbeingadopted25byreference.KRONASSOCIATES1113W.FireweedLane,Suite200Anchorage,Alaska99503(907)276355431Atthispointintimethereisonlymyself,andastaff.2Therearenomembersofthegeneralpublic.Andatthispointin3timewewillgooffrecorduntilanyonefromthepublicshould4showup.STHEREPORTER:Offtherecord12:31p.m.6THEREPORTER:Ontherecord1:30p.m.7MS.HElL:ThisisCindyHellwithDepartmentof8EnvironmentalConservation.Therewasnopublictestimony9received.Anypubliccommentswewillmake--wewillreceivein10writingwillbepartofthedecisionmakingprocess.Afterthe11closeofthispublicperiod,thiscommentperiod,theDECwill12draftaresponsetoanycommentsreceived.Withoutanyfurther13noticeDECwilldecideeithertoadoptasproposed,adoptwith14otherprovisionsdealingwiththesamesubject,ordecideto15takenoactionontheproposal.Thelanguageofthefinal16regulationsmaybedifferentfromthatoftheproposed17amendments.18ThisisAugust2’,2010,at1:30p.m.inAnchorage,Alaska.19Again,mynameisCynthiaHeilandthishearingisnowclosed.20THEREPORTER:Offtherecordat1:31p.m.2122232425KRONASSOCIATES1113W.FireweedLane,Suite200Anchorage,Alaska99503(907)276355441TRANSCRIBER’SCERTIFICATE2I,ChristineArnold,herebycertifythattheforegoing3pagesnumbered2through3areatrue,accurateandcomplete4transcriptofproceedingsofthePublicHearing,Proposed5ChangestoAlaskaDepartmentofEnvironmentalConservation6Regulations,heldAugust2nd,2010atAnchorage,Alaska,7transcribedbymefromacopyofthedigitalsoundrecordingto8thebestofmyknowledgeandability.11ChristineArnoldDate1213141516171819202122232425KRONASSOCIATES1113W.FireweedLane,Suite200Anchorage,Alaska99503(907)2763554STATE

OF ALASKA

) ) FIRST JUDICIAL DISTRICT

) AFFIDAVIT

OF NOTICE

OF PROPOSED ADOPTION

OF REGULATIONS AND FURNISHING

OF ADDITIONAL INFORMATION I, Scott

J. Sloane, Environmental
Program Specialist

III, of the Department

of Environmental Conservation,

being sworn, state the following: As required

by AS 44.62.190,
notice

of the proposed adoption

of changes

to 18 AAC 50.030 State
air quality control
plan has been given

by being: (1) published

in

a newspaper

or trade publication; (2) furnished

to interested persons; (3) furnished

to appropriate

state officials; (4) furnished

to the Department

of Law, along with

a copy

of the proposed regulations; (5) electronically transmitted

to incumbent

State

of Alaska legislators; (6) furnished

to the Legislative Affairs Agency, Legislative

Legal
and Research Services; (7) posted

on the Alaska Online Public Notice System

as required

by AS 44.62.175(a)(1)

and (b) and 44.62.190(a)(1);

and (8) furnished electronically,

along with

a copy

of the proposed regulations,

to the Legislative Affairs Agency,

the chair

of the Resources Committee

of the Alaska Senate
and House

of Representatives,

the Administrative Regulation Review Committee,

and the legislative council. As required

by AS 44.62.190(d), additional regulations
notice information regarding

the proposed adoption

of the regulation changes described above

has been furnished

to interested persons

and those

in (5) and (6) of the list above.
The additional regulations
notice information

also has been posted

on the Alaska Online Public Notice System.DATE:____________ Qunu, Alaska

/6 ScottJ.€’lot,

PS III SUBSCRIBED

AND SWORN

TO before

me this_____

day of___________ [NOTARY SEAL]

State

of Alaska My commission expires; bt)j%hK &13t77CL STATEOFALASKA OFFICIAL
SEAL Cassidy

Y. Kearney NOTARY PUBLIC \a-’ My Commission Expires With Office.

### Register

___,

_____ 2010 ENVIRONMENTAL CONSERVATION



# DEPARTMENT OF

ENVIRONMENTAL CONSERVATION

18 AAC 50

Air Quality Control

Public Review Draft

June 28 th 

## , 2010

### Register

___,

_____ 2010 ENVIRONMENTAL CONSERVATION

The lead in language of 18 AAC 50.030 is amended to read:

18 AAC 50.030. State air quality control plan. Volumes II and III of the State Air

Quality Control Plan for implementing and enforcing the provisions of AS 46.14 and this

chapter, as amended through { adoption date of these proposed regulations } [ N OVEMBER 6,

2009 ], are adopted by reference. The plan includes the following documents which are also

adopted by reference:



# . . .

18 AAC 50.030(4) is amended to read:

(4) the department's Quality Assurance Project Plan for the State of Alaska Air

Monitoring & Quality Assurance Program [ ALASKA QUALITY ASSURANCE MANUAL

FOR AMBIENT AIR QUALITY MONITORING ] , as amended through February 23 ,

2010 [ AUGUST 21, 1996 ] ;

(Eff. 1/18/97, Register 141; am 6/21/98, Register 146; am 9/4/98, Register 147;

am 1/1/2000; Register 152; am 12/30/2000; Register 156; am 9/21/2001, Register 159; am

1/27/2002, Register 161; am 3/2/2002, Register 161; am 5/3/2002, Register 162; am 2/20/2004,

Register 169; am 6/24/2004, Register 170; am 10/1/2004, Register 171 ; am 12/14/2006, Register

180; am 12/30/2007, Register 184; am 5/17 /2008, Register 186; am 7/25/2008, Register 187; am,

11/9/2008, Register 188; am 5/6/2009, Register 190; am 11/4/2009, Register 192; am 4/1/2010,

Register 193; am__/__/____, Register ___)

Authority: AS 46.03.020 AS 46.14.030 Sec. 30, ch. 74, SLA 1993

AS 46.14.020 AS 46.14.140

### Register

___,

_____ 2010 ENVIRONMENTAL CONSERVATION

18 AAC 50.215(a) is amended to read:

18 AAC 50.215. Ambient air quality analysis methods. (a) A person who submits

meteorological or ambient air monitoring data under AS 46.03, AS 46.14, or this chapter shall

obtain the data in accordance with

(1) the department's Quality Assurance Project Plan for the State of Alaska Air

Monitoring & Quality Assurance Program [ ALASKA QUALITY ASSURANCE MANUAL FOR

AMBIENT AIR QUALITY MONITOR ING ], adopted by reference in 18 AAC 50.030 for PM

- 10,

PM 2.5

, total suspended particulates (TSP), lead, carbon monoxide, nitrogen dioxide, sulfur

dioxide, ozone and ammonia;

(Eff. 1/18/97, Register 141; am 6/21/98, Register 146; am 10/1/2004, Register 171; am

7/25/2008, Register 187 ; am __/__/____, Register ___)

Authority: AS 46.03.020 AS 46.14.140 Sec. 30, ch. 74, SLA 1993

AS 46.14.030 AS 46.14.180MEMORANDUM

State

of Alaska Department

of Law TO: The Honorable
Craig

E. Campbell

DATE: September

27, 2010 Lieutenant Governor

StENO.: JU2010201261 TELEPHONE

NO.: 465-3600 FROM: Deborah

E. Behr

st RJECT: Department

of Environmental Chief Assistant Attorney General
Conservation Regulations

re: and Regulations Attorney

State Air Quality Improvement Legislation/Regulations

Section

Plan;
Air Quality Control (I8AAC5O.030; I8AAC5O.215) We have reviewed

the attached regulations

from the Department

of Environmental Conservation (department).

A duplicate

of this memorandum

is being furnished

to Commissioner

Hartig, along with

a copy

of the regulations. The Department

of Law has reviewed

the attached regulations,

and materials adopted

by reference, against

the statutory standards

of the Administrative Procedure

Act. Based upon our review,

we find
no legal problems.

This memorandum

and the attached duplicate original memorandum

dated September

27, 2010 constitute

the written statement

of approval under

AS 44.62.060(b)

and (c) that authorizes

your office

to file the attached regulations. The regulations

were adopted

by the department

after the close

of the public comment period.

The regulations

are regarding updates

to the State Air Quality Control Plan
for air quality control

in the state. The adoption order

for the regulations

states that this action

is not expected to require

an increased appropriation. Therefore,

a fiscal note under

AS 44.62.195

is not required.
We have made some technical corrections

to conform

the regulations

with the drafting manual under

AS 44.62.060

and 44.62.125.

The corrections

are shown

on the attached
copy

of the regulations. DIEL3 KIM :kjm cc: [ton. Larry Hartig, Commissioner Department

of Environmental Conservation2-oilRegister,2BtENVIRONMENTALCONSERVATIONTheIead.inlanguageof18AAC50.030isamendedtoread:pPlj18AAC50.030.StatefrqualitycontrolpIa3VolumesIIandIIIoftheSlateAirQualityControlPlanforimplementingandenforcingtheprovisionsofAS46.14andibischapter.asamendedthroughAugust20,2010[NOVEMBER6,2009],areadoptedbyreference.Theplanincludesthefollowingdocumentswhicharealsoadoptedbyreference:18AAC50.030(4)isamendedtoread:(4)thedepartment’sQualityAssuranceProjectPlanfortheStateofAlasliaAirMonitorinø&QualityAssuranceProfram[ALASKAQUALITYASSURANCEMANUAL‘‘FORAMBIENTAIRQUALITYMONITORING],asamendedthroughFebruary23,‘—A2010[AUGUST2I,1996];(Eff.1/18/97,Register141;am6/21/98,Register146;am9/4/98,Register147;am1/1/2000Register152;amI2/30/2000Register156;am9/21/2001,Register159;amAL3/t1i9_Io1i‘I1/27/2002,Register161;am/2/206,Register161;am5/3/2002,Register162;am2/20/2004,Register169;am6/24/2004,Register170;am10/1/2004,Register171;am12/14/2006,Register180;am12/30/2007,Register184;am5/17/2008,Register186;am7/25/2008,Register187;amj’11/9/2008,Register188;am5/6/2009,Register190;am11/4/2009,Register192;am4/112010,Register193;am_/_/,Register__)Authority:AS46.03.020AS46.14.030Sec.30,ch.74,SLA1993AS46.14.020AS46.14.140Register—,____ ENVIRONMENTAL CONSERVATION L) 18 AAC 50.21 5(aTs amended

to read: 1.&&Ac-5O.215.
Amhient

air quality analysis methods.

(a)

A person who cubmits e-teornIngicnl

pr

air monite,;ii data ..der-AS 16.03,

Ag 16.11,

or this chapter 5halj,... ebtain

thc data

in aeeord& 1 ... w;tJp_— (1) the departments Quality Assurance Project Plan for the Slate ofAlaska

Air Monitoring

& Quality Assurance Program [ALASKA QUALITYASSURANCE

MANUAL

FOR AMBIENTAIR QUALJTYMONJTORING],

adopted

by reference

in
18 AAC 50.030 for4 ________total suspended particulates
(TSP), lead, carbon monoxide, nitrogen dioxide, sulfur dioxide, ozon%and ammonia; (Eff. 1/18/97, Register

141; am 6/21/98, Register

146; am 10/1/2004, Register

171; am ,c13;J 7/25/2008, Register

I 87; 1 am_/_/, Register
__J Authority;

AS 46.03.020

AS 46.14.140

Sec. 30, ch. 74, SLA 1993 AS 46.14.030

AS 46.14.180