The Kent, Seattle, and Tacoma, WA		

Second 10‐year Limited Maintenance Plan for PM10

November 4, 2013

In conjunction with  

Washington State Department of Ecology  
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Table of Contents

Executive Summary....................................................................................................................................... 1

1. Introduction........................................................................................................................................... 2

Particulate Matter Standards................................................................................................................. 2

Maintenance Area Compliance History.................................................................................................. 2

Plan Structure.........................................................................................................................................3

2. Background............................................................................................................................................ 4

Geographic Area.....................................................................................................................................4

Compliance History ................................................................................................................................8

3. Limited Maintenance Plan Option......................................................................................................... 9

NAAQS Qualification Criterion ............................................................................................................... 9

Design Value Criterion.......................................................................................................................... 10

Motor Vehicle Regional Analysis Criterion........................................................................................... 12

LMP Qualification .................................................................................................................................13

4.1. PM10 Concentrations............................................................................................................................ 14

Kent Maintenance Area........................................................................................................................ 14

Kent Monitoring ...................................................................................................................................15

Seattle Maintenance Area.................................................................................................................... 17

Seattle Monitoring ............................................................................................................................... 17

Tacoma Maintenance Area .................................................................................................................. 19

4.2. Model Development............................................................................................................................ 21

Kent ......................................................................................................................................................21

Seattle...................................................................................................................................................23

Tacoma .................................................................................................................................................24

PM10Violation Unlikely......................................................................................................................... 26

4.3. Current PM10 and PM2.5 Data Availability ............................................................................................ 26

5. Emission Inventory .............................................................................................................................. 27

Emission years and categories ............................................................................................................. 27

Emission inventory geography ............................................................................................................. 28

Significant source categories................................................................................................................ 28

Maintenance Plan Inventory ................................................................................................................ 29

6. Control Measures ................................................................................................................................ 30

Emission Reduction Programs.............................................................................................................. 31

Wood Smoke Curtailment.................................................................................................................... 31

Fugitive Dust.........................................................................................................................................32
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Industrial Sources.................................................................................................................................32

Diesel Emissions ...................................................................................................................................32

Voluntary diesel emissions reductions:................................................................................................ 33

Outdoor burning...................................................................................................................................34

Control Measures in PSCAA Rules........................................................................................................ 34

7. Contingency Measures ........................................................................................................................ 36

Contingency Measure Trigger .............................................................................................................. 36

8. Commitment to Continued Monitoring and Verification of Continued Attainment........................... 37

9. Summary of Maintenance Plan Commitments ................................................................................... 38

Appendix A  .........................................................................................................................................A‐1

Appendix B  ..........................................................................................................................................B‐1

Appendix C  ..........................................................................................................................................C‐1

Appendix D  ........................................................................................................................................ D‐1
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Table of Figures

Figure 2.1: The Kent, WA PM10 Maintenance Area....................................................................................... 5

Figure 2.2: The Seattle, WA PM10 Maintenance area ................................................................................... 6

Figure 2.3: The Tacoma, WA PM10maintenance area .................................................................................. 7

Table 3.1: Three‐year design values calculated using the most recent three years of estimated PM10

concentrations..............................................................................................................................................9

Table 3.2: Tabular Estimation of PM10 Design Values4.............................................................................. 10

Table 3.3: Five‐Year Design Values for Kent, Seattle, and Tacoma............................................................. 11

Table 3.4: Margin of Safety Comparison..................................................................................................... 12

Figure 4.1.1: Kent Historical PM10 Concentrations ..................................................................................... 14

Figure 4.1.2: PM10 and PM2.5 data used to develop the PM10 to PM2.5 relationship.................................15

Figure 4.1.3: PM2.5 monitoring data used to estimate PM10 concentrations from 2008‐present..............16

Figure 4.1.4: Seattle Historical PM10 Concentrations ................................................................................. 17

Figure 4.1.5: PM10 and PM2.5 data used to develop the PM10 to PM2.5 relationship ..................................18

Figure 4.1.6: PM2.5 monitoring data used to estimate PM10 concentrations from 2008‐present..............18

Figure 4.1.7: Tacoma Historical PM10 Concentrations................................................................................ 19

Figure 4.1.8: Tacoma monitoring data used to calculate the PM10 PM2.5 relationship...............................20

Figure 4.2.1: Summer and Winter PM10 to PM2.5 from 1999‐2007 at the Kent Monitoring Site................22

Figure 4.2.2: Estimated PM10 to Measured PM10 for the years 1999‐2007................................................ 22

Figure 4.2.3: Summer and Winter PM10 to PM2.5 from 1999‐2007 at the Seattle Monitoring Site............23

Figure 4.2.4: Estimated PM10 to Measured PM10 for the years 1999‐2007................................................ 24

Figure 4.2.5: Summer and Winter PM10 to PM2.5 from 1999‐2007 at the Tacoma Monitoring Site ..........25

Figure 4.2.6: Estimated PM10 to Measured PM10 for the years 1999‐2007................................................ 25

Table 4.2.1 PM2.5 concentrations corresponding to a PM10 concentration of 150 μg/m3

..........................26

Table 5.1: Emission Categories used in this LMP........................................................................................ 27

Table 5.2: Seattle, Tacoma, and Kent Maintenance Area Annual and Winter Day PM10 Emissions ..........29

Table 6.1: PSCAA Regulation I – Article 8: Outdoor Burning ...................................................................... 34

Table 6.2: PSCAA Regulation I – Article 9: Emission Standards.................................................................. 34

Table 6.3: PSCAA Regulation I – Article 13: Solid Fuel Burning Device Standards......................................35

Table 9.1: Second 10‐Year LMP Commitments........................................................................................... 38

Table A.1: Kent PM10 Maximums and 5‐Year Design Values, 1999‐2007  ................................................A‐3

Table A.2: Kent, Washington Modeled PM10 5‐Year Design Values,  2008‐2012  ....................................A‐4

Table A.3: Seattle, Washington PM10 Maximums and 5‐Year Design Values, 1999‐2007  ......................A‐5

Table A.4: Seattle, Washington Modeled PM10 5‐Year Design Values, 2008 ‐ 2012  ...............................A‐6

Table A.5: Tacoma, Washington  PM10 and 5‐Year Design Values, 1999‐2007  .......................................A‐7
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Table A.6: Tacoma, Washington Modeled PM10 5‐Year Design Values, 2008 ‐ 2012  ..............................A‐8

Table A.7: Design Values used for Motor Regional Analysis  ...................................................................A‐10

Table A.8: Projected 10‐year Increase in VMT  ........................................................................................A‐10

Table A.9: Calculation of Motor Vehicle Design Value  ...........................................................................A‐11

Table A.10: Margin of Safety Comparison  ..............................................................................................A‐12

Table C.1: List of 2011 Emission Categories...............................................................................................C‐1

Table C.2: 1994 emission categories with their respective 2011 representative emission category .......C‐1

Table C.3: Spatial surrogate and sources of data for sub‐county region (maintenance area) estimates .C‐3

Table C.4: Tons of PM10 by wood burning device, King and Pierce County .............................................C‐5

Table C.5: PM10 Maintenance Area Population Data ...............................................................................C‐5

Table C.6: Tons of PM10 by wood burning device in each maintenance area:.........................................C‐6

Table C.7: Paved road dust PM10 emissions with the fraction of the maintenance areas vehicle miles

traveled......................................................................................................................................................C‐7

Table C.8: MOVES Model Parameters and Data Sources ..........................................................................C‐9

Table C.9: Onroad mobile PM10 emissions with the fraction of the maintenance areas vehicle miles

traveled....................................................................................................................................................C‐10

Table C.10: Unpaved road dust PM10 emissions with the fraction of the maintenance areas vehicle miles

traveled....................................................................................................................................................C‐11

Table C.11: Fraction of Port Areas in Maintenance Areas.......................................................................C‐12

Table C.12: PM10 emissions breakdown in tons of port and marine emissions within each maintenance

area by subcategory.................................................................................................................................C‐13

Table C.13: List of emission sources and methods used to estimate locomotive emissions..................C‐14

Table C.14: Values used in the rail coal dust emission factor equation ..................................................C‐16

Table C.15: Estimated annual locomotive PM10 emissions by category ................................................C‐17

Table C.16: Maintenance area fraction of the rail line of the total county rail for estimating passenger

and coal dust emissions...........................................................................................................................C‐18

Table C.17: Fraction of county rail activity in the maintenance area for line haul estimates. ................C‐18

Table C.18: The number of industrial sources (active or inactive) reporting PM10 emissions between

1994 and 2011. ........................................................................................................................................C‐19

Table C.19: PM10 Emissions from all industrial sources from 1994 to 2011: .........................................C‐20

Table C.20: Estimated annual emissions by reporting industrial source.................................................C‐20

Figure D.1: The Kent, WA PM10 Maintenance area ................................................................................. D‐4

Figure D.2: The Seattle, WA PM10 Maintenance area ............................................................................. D‐5

Figure D.3: The Tacoma, WA PM10 maintenance area ............................................................................ D‐6

Table D.4: 1994 PM10 Average Daily Emissions from the 1997 maintenance plan................................. D‐7

Table D.5: Emission Categories to be used in this LMP ............................................................................ D‐8

Table D.6: MOVES Model Parameters and Data Sources....................................................................... D‐10
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Table D.7: The number of industrial sources (active or inactive) reporting PM10 emissions between 1994

and 2011. ................................................................................................................................................ D‐12

Table D.8: PM10 Emissions from all industrial sources from 1994 to 2011:.......................................... D‐13

Table D.9: Spatial Surrogates.................................................................................................................. D‐15

   
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Acronyms and Abbreviations

ADVMT .......................................Average Daily Vehicle Miles Traveled

AERR...........................................Air Emissions Reporting Rule

AP42...........................................EPA’s Compilation of Air Pollutant Emission Factors

AQI .............................................Air Quality Index

AQS  ............................................Air Quality System

BNSF ...........................................Burlington Northern Santa Fe Railway

bscat .............................................A measure of light scatter, scattering coefficient

CAA.............................................Clean Air Act

CAAA ..........................................Clean Air Act Amendments

CARB...........................................California Air Resources Board

CNG ............................................Compressed Natural Gas

CRAB...........................................County Road Administration Board

DOL.............................................Department of Licensing

DQO............................................Data Quality Objectives

DV...............................................Design Value

ECA.............................................Emission Control Area

Ecology .......................................Washington State Department of Ecology

EPA .............................................U.S. Environmental Protection Agency

FEM ............................................Federal Equivalent Method

FR ...............................................Federal Register

FRM............................................Federal Reference Method

FTA .............................................Federal Transit Administration

GIS ..............................................Geographic Information Systems

g/hr.............................................grams per hour

HPMS..........................................U.S. DOT Highway Performance Monitoring System

IPP/QAP  .....................................Inventory Preparation Plan and Quality Assurance Plan   

LMP  ...........................................Limited Maintenance Plan

MA..............................................Maintenance Area

MOS  ...........................................Margin of Safety

MOVES .......................................Motor Vehicle Emission Simulator

NAA ............................................Nonattainment area

NAAQS........................................National Ambient Air Quality Standards

NAMS .........................................National Ambient Monitoring Sites
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NEI..............................................EPA’s National Emission Inventory

NESHAP ......................................National Emission Standards for Hazardous Air Pollutants

NRLM..........................................Non‐Road, Locomotive, and Marine

NSPS ...........................................New Source Performance Standards

OLS .............................................Ordinary Least Squares

ODEQ..........................................Oregon Department of Environmental Quality

OSPI............................................Office of the Superintendent of Public Instruction

PSCAA.........................................Puget Sound Clean Air Agency

PM10 ...........................................Particulate Matter, ten microns or less

PM2.5...........................................Particulate Matter, 2.5 microns or less

RACM .........................................Reasonably Available Control Technologies

RWC  ...........................................Residential Wood Combustion

SIP  ..............................................State Implementation Plan

SLAMS  .......................................State and Local Ambient Monitoring Sites

TCMA..........................................Thurston County Maintenance Area

TRPC  ..........................................Thurston Regional Planning Council

TEOM .........................................Tapered Element Oscillating Microbalance

TSP..............................................Total Suspended Particulate

ULSD...........................................Ultra Low Sulfur Diesel

UP...............................................Union Pacific Railroad

μg/m3 .........................................micrograms per cubic meter

VMT............................................Vehicle Miles Traveled

WRAP .........................................Western Regional Air Partnership

WSDOT  ......................................Washington State Department of Transportation

   
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Executive Summary

Portions of Kent and the industrial areas of the Duwamish Valley in Seattle and the Tideflats of Tacoma

meet the federal 24‐hour standard for particulate matter 10 micrometers  and smaller (PM10). This

State Implementation Plan (SIP) revision explains how these areas will continue to meet the standard

through 2020.  

The Environmental Protection Agency (EPA) sets air quality standards for particulate matter to protect

public health. Particulate pollution is classified by its size, PM10 is considered coarse particulate matter

and PM2.5 is considered fine particulate matter.  Particles less than 10 micrometers can penetrate into

the lungs and cause short and long‐term health problems. There are separate 24‐hour standards for

PM10 (150 μg/m3) and PM2.5 (35 μg/m3) because particle size is directly linked to their potential for

causing health problems.

These three areas were classified as nonattainment areas in 1990 by the Environmental Protection

Agency (EPA) for the 24‐hour PM10 National Ambient Air Quality Standard (NAAQS). The Kent, Seattle,

and Tacoma PM10 nonattainment areas were reclassified to maintenance areas in 1993, 1995, and

1995, respectively.  The Clean Air Act (CAA)  requires a two 10‐year maintenance plans for the three

areas, the first 10‐year maintenance plan was submitted to the EPA in 1997. This plan is the second and

final 10‐year maintenance plan and fulfills the CAA requirement.

The Kent, Seattle, and Tacoma PM10 maintenance areas are currently well below the 24‐hour NAAQS

for PM10. Compliance with this standard is maintained if PM10 values do not exceed 150 μg/m3 more

than once a year, on average, over three years.  

The areas qualify to submit a streamlined Limited Maintenance Plan (LMP) because the 5‐year Design

Values for these areas do not exceeded 98 μg/m3 —a screening threshold— and meet other criteria.

LMPs are for areas that show little risk of re‐violating the PM10  NAAQS.

PM10 concentrations are estimated using the historic relationship between PM10 and PM2.5 described

in Section 4.  PSCAA will continue to operate ambient PM2.5 monitors in all three maintenance areas.

Three‐year design values from PM10 concentrations for the three maintenance areas will be estimated

annually to verify continued attainment of the NAAQS. Five year design values will be calculated to

verify continuing qualification for the LMP option. Direct PM10 monitoring will be reestablished if

calculated PM10 design values reach 98 μg/m3, the LMP option screening threshold.

The control and contingency measures from the attainment and maintenance plans are still in place. All

existing PM10 control measures will continue in the region and are described in Section 6. Primary

control strategies include a residential wood smoke control program, fugitive dust program, and a

prohibition on outdoor burning.  PSCAA’s Regulation I – Article 13.07 (b) provides for prohibition of the

use of uncertified woodstoves for the sole purpose of meeting CAA requirements for contingency

measures.  The contingency measure will be triggered if the estimated PM10 concentrations violate the

PM10 NAAQS at the maintenance area monitors.
2

1. Introduction

This State Implementation Plan (SIP) revision explains how the PM10 maintenance areas of Kent, Seattle,

and Tacoma currently meet and will continue to meet the 1987 National Ambient Air Quality Standard

(NAAQS) for particulate matter ten microns or smaller (PM10) through 2020.  Puget Sound Clean Air

Agency (PSCAA) prepared this plan with the Washington State Department of Ecology (Ecology). PSCAA

is the local clean air agency with jurisdiction over the Kent and Seattle maintenance areas in King County

and the Tacoma maintenance area in Pierce County.   

Particulate Matter Standards

The Environmental Protection Agency (EPA) sets air quality standards for particulate matter to protect

public health. Particulate matter pollution is a public health issue because smaller particles can

penetrate deep into the lungs and cause health problems.  Particulate matter comes from soot, dust,

unburned fuel suspended in the air, and can also be formed in the air from chemical reactions involving

gaseous precursors.  EPA revised the particulate matter NAAQS from total suspended particulate (TSP)

to PM10 on July 1, 1987, since smaller particles were determined to be more harmful.  The primary

health‐based 24‐hour standard for PM10 is 150 μg/m3

, and cannot be exceeded more than once a year

on average over three years.  A 24‐hour standard for fine particulate matter 2.5 microns or smaller

(PM2.5) was set to 65 μg/m3 on July 18, 1997, and was revised to 35 μg/m3 in 2006.  

Maintenance Area Compliance History		

The Kent, Seattle, and Tacoma PM10 maintenance areas were designated Group 1 PM10 areas in 1987 by

the Environmental Protection Agency (EPA) for having a greater than 95% probability of violating the 24‐

hour PM10 standard. These areas were then classified as nonattainment areas in 1990 as required for

Group I areas by the 1990 Amendments to the Clean Air Act (CAA).  The PM10 attainment plan for Kent

was fully approved by EPA on July 27, 1993 (58 FR 40059) and the plans for Tacoma and Seattle were

fully approved by EPA on October 25, 1995 and October 26, 1995, respectively (60 FR 54599 and 60 FR

54812). EPA approved the first 10‐year maintenance plan on March 13, 2001 (66 FR 14492).  

This second 10‐year maintenance plan is a Limited Maintenance Plan (LMP) and demonstrates

continued attainment of the NAAQS through 2020 at existing PM2.5monitors in the Puget Sound region.

PM10 concentrations will be estimated using the relationship between PM10 and PM2.5 described in

Section 4. All existing PM10 control measures will be continued in the region and are described in Section

6.  

Primary control strategies included in the PM10 attainment and maintenance plans for the three areas

included a residential wood smoke control program, a fugitive dust program, and a prohibition on

opening burning, and industrial emission controls.  The control and contingency measures from the

attainment and maintenance plans are still in place.  PSCAA’s Regulation I – Article 13.07 (b) provides for

prohibition of the use of uncertified woodstoves for the sole purpose of meeting CAA requirements for

contingency measures.  The contingency measure will be triggered if the estimated PM10 concentrations

violate the PM10 NAAQS at the maintenance area monitor based on nephelometer and/or FEM

monitoring of PM2.5.
3

PSCAA will continue to operate ambient PM2.5 monitors in all three maintenance areas. PM10

concentrations will be estimated based on these measurements and the values will be evaluated

annually to verify continued attainment of the NAAQS.  PM10 monitoring will be reinstituted if calculated

design values reach 98 μg/m3

.  If air quality degrades significantly or if there are significant changes in

any of the assumptions of this LMP, PSCAA will re‐evaluate the plan.   

Plan Structure		

This SIP revision includes the compliance history for Kent, Seattle, and Tacoma and describes how the

areas met and will continue to meet the standard, as well as what will be done if an area violates the

NAAQS.  This plan also includes other EPA‐required elements, such as an emissions and monitoring

review and public process requirements.  

This document is organized as follows:

Section 2 –Background ‐ describes the area’s compliance history and contains background

information on the PM10 standard

Section 3 – Limited Maintenance Plan (LMP) Option ‐ describes the criteria an area must meet to

qualify for this option and how the three maintenance areas meet these criteria

Section 4 – PM10 Monitoring History ‐ provides a brief history of monitoring in the three

maintenance areas, an evaluation of the relationship of PM10 to PM2.5 and justification for using an

alternative monitoring method

Section 5 – Emission Inventory ‐ includes historical information on the most significant PM10

emission categories from the original maintenance plan and an updated inventory on these

categories

Section 6 – Control Measures ‐ lists the measures and rules that were in place in the original

maintenance plan and the current rules that maintain and enforce these measures  

Section 7 – Contingency Measures ‐ describes the provisions that are in place in rules and will be

taken, if the PM10 standard is violated

Section 8 – Commitment to Continued Monitoring and Verification of Continued Attainment–

describes how monitoring will be continued and how compliance will be confirmed

Section 9 – Summary of Maintenance Plan Commitments – outlines commitments of this plan

Section 10 – Completion of Required Plans – states that this document fulfills federal planning

requirements
4

2. Background

Geographic Area

The Kent PM10 maintenance area is located on the eastern side of the Green River Valley between the

Cities of Tukwila and Auburn. The PM10 sources in this region come from residential wood burning, light

industry, and mobile sources. The valley floor is roughly two to three miles in width and is bound by hills

which rise 300‐400 ft. in elevation. These hills act to trap pollutants under stable meteorological

conditions (inversions). These conditions exist most frequently during the late fall and winter and are

associated with the majority of particulate matter violations. Figure 2.1, below, shows the Kent PM10

maintenance area boundary and the location of the monitoring site.

The Seattle PM10 maintenance area is comprised of the Duwamish industrial and commercial area

immediately south of the downtown district and includes the Port of Seattle. The monitoring site has

been in place since 1971 and is located in the center of the Duwamish industrial valley near the Port of

Seattle. The site is a neighborhood scale site that is representative of South Seattle neighborhoods and

ambient exposure in the industrial valley.  The site is influenced by a very complex mixture of mobile

sources, port and marine sources, industrial sources, winter home heating wood smoke, and other

pollution sources.  The site is 80 meters west of E. Marginal Way, which is a main arterial for many large

haul trucks, as well as service vehicles and personal automobiles. Figure 2.2 shows the Seattle

maintenance area boundary, the areas of the Port of Seattle that lie within the maintenance area, and

the air monitoring station.  

The Tacoma PM10 maintenance area is comprised of the industrial area of Tacoma, including the Port of

Tacoma, a Kraft pulp mill and other industrial operations. The monitoring site has been in place since

1987 in the industrial area near the Port of Tacoma. The site is neighborhood scale located near several

industrial air pollution sources. The sources that impact the area are a mixture of mobile sources, port

and marine sources, industrial sources, and winter home heating from wood burning.  The site is also

within the Puyallup Indian Reservation, as well as the 2006 PM2.5 Tacoma‐Pierce County nonattainment

area. Figure 2.3 shows the Tacoma maintenance area boundary, the Port of Tacoma, and the location of

the monitoring site.  

   
5

Figure 2.1: The Kent, WA PM10 Maintenance Area
6

Figure 2.2: The Seattle, WA PM10 Maintenance area
7

Figure 2.3: The Tacoma, WA PM10maintenance area
8

Compliance History		

On August 7, 1987, EPA identified Kent and the industrial areas of Seattle and Tacoma as having greater

than 95% probability of violating the 24‐hour PM10 average standard. By operation of law, all three areas

were designated moderate PM10 nonattainment areas upon enactment of the CAA on November 15,

1990.  

State Implementation Plan (SIP) submittals addressing PM10 nonattainment in Kent and Seattle were

submitted by Ecology to EPA in November 1990, followed by the submittal for Tacoma one year later.

The principal control strategies included in the PM10 attainment plans for the three areas included a

residential wood smoke control program, a fugitive dust control program, and a prohibition on outdoor

burning.   

The PM10 attainment plan for Kent was fully approved by EPA on July 27, 1993 (58 FR 40059) and the

plans for Tacoma and Seattle were fully approved by EPA on October 25, 1995 and October 26, 1995,

respectively (60 FR 54599 and 60 FR 54812). The maintenance plan and request for redesignation from

nonattainment to maintenance for Kent, Seattle, and Tacoma were approved on March 13, 2001 (66 FR

14492).

This plan is the Second 10‐Year Limited Maintenance Plan for PM10 in Kent, Seattle, and Tacoma and is

the last maintenance plan for these areas.  This maintenance plan revision ensures compliance through

2020 and fulfills the second 10‐year planning requirement of CAA Section 175A (b).
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3. Limited Maintenance Plan Option

In consultation with Ecology and EPA, PSCAA chose to follow the EPA’s Limited Maintenance Plan (LMP)

option for the second PM10maintenance plan for the Kent, Seattle, and Tacoma maintenance areas.  The

EPA developed the Limited Maintenance Plan (LMP) option for areas with little risk of re‐violating the

PM10 standard.  EPA allows states to use this policy to prepare the required second 10‐year maintenance

plans, if the area meets the qualification criteria in the EPA LMP Option Guidance (LMP Guidance)1

.  The

LMP option for moderate PM10 nonattainment areas requires an area to meet certain applicability

criteria in order to qualify for the LPM option.  The first criterion is that an area should be attaining the

National Ambient Air Quality Standard (NAAQS), the second that the average PM10 design value based

on the most recent 5 years of air quality data should be at or below 98μg/m3 for the 24‐hour PM10

NAAQS2

. The third criterion is that the area should expect only limited growth in on‐road motor vehicle

emissions and pass a motor vehicle regional emissions analysis test.  The Kent, Seattle, and Tacoma

maintenance areas meet these criteria as described below; supporting information can be found in

Appendix A.

NAAQS Qualification Criterion

To qualify for the LMP option, the area must be attaining the 24‐hour NAAQS, 150 μg/m3.  Monitoring

data shows that Kent, Seattle, and Tacoma have been in attainment of the standard since 1987, 1990,

and 1989 respectively. The areas were reclassified to attainment for the 24‐hour PM10 standard in March

2001 when EPA approved the first 10‐year maintenance plan for Kent, Seattle, and Tacoma. Table 3.1

below shows the 3‐year design values are well below the 24‐hour NAAQS of 150 μg/m3 for all three PM10

maintenance areas.

Table 3.1: Three‐year design values calculated using the most recent three years of

estimated PM10 concentrations

Site YEARS NO. DATA

POINTS

TABLE LOOK‐

UP, μg/m3

STATISTICAL

FIT, μg/m3

Kent 2010 ‐ 2012 1017 44 44±3

Seattle 2010 ‐ 2012 1068 48 49±4

Tacoma 2010 ‐ 2012 1030 59 55±5

  

                                                            

1 Limited Maintenance Plan Option for Moderate PM10 Nonattainment Areas 2 Limited Maintenance Plan Option for Moderate PM10 Nonattainment Areas, pp 3
10

Design Value Criterion		

To qualify for the LMP option, the average 24‐hour PM10 design value for the area based upon the most

recent five years of data should not exceed 98 μg/m3

.  A design value is the statistic based on monitoring

data that determines an area’s compliance status.  The LMP Guidance directs the design value be based

on the most recent five years of data.  The design values for Kent, Seattle, and Tacoma based on Federal

Equivalence Method (FEM) 24‐hour PM10 monitoring data from 2003 through 2007 are 57±3 μg/m3

,

68±4 μg/m3

, and 72±9 μg/m3.  The most recent design values estimated based on an alternative

method, using 2008 to 2012 values, are 46±3 μg/m3

, 50±5 μg/m3, and 58±8 μg/m3 respectively.  All of

these values are below the 98 μg/m3 value stipulated in the LMP Guidance.

The PM10 SIP Development Guideline3 (SIP Guideline) outlines the following four approaches to

determine the PM10 design value: a table look‐up procedure; fitting a statistical distribution to several

years of data; a graphical estimation technique; and the use of a conditional probability approach. This

analysis uses both the table look‐up method and a statistical fit to calculate the PM10 design values.  The

graphical estimation and the conditional analysis were considered for this analysis however the table

look‐up method and the statistical fit were the most appropriate for the Kent, Seattle, and Tacoma

monitoring datasets. The graphical estimation technique was not used in this analysis due to insufficient

data in some cases. Where there was insufficient data the concentration that corresponds to a

frequency of 1/365 could not be read directly off a graph of the distribution at each of the sites for all of

the 5‐year time periods.  The conditional probability approach is used in cases where individual years of

data should be treated separately.  Preliminary analysis of the conditional probability approach showed

that values for individual years did not vary significantly from year to year. Calculating the design value

using the table look‐up method and the statistical fit method allows for the most conservative design

value to be selected.  

The table look‐up procedure is outlined in the PM10 SIP development guide4

.  The PM10 SIP development

guide states that the design concentration for PM10 is the concentration that corresponds to a frequency

of 1/365 on an empirical frequency distribution.4

  Table 3.2 below is used to estimate which point on the

empirical frequency distribution corresponds to a frequency of 1/365.  

Table 3.2: Tabular Estimation of PM10 Design Values4

Number of Values Data Point to be Used

1  ‐ 347

348 ‐ 695

696 ‐ 1042

1043 ‐ 1390

Highest Value

Second Highest Value

Third Highest Value

Fourth Highest Value

                                                            

3 PM‐10 SIP Development Guideline, publication EPA 450/2 86‐001 4 PM‐10 SIP Development Guideline, publication EPA 450/2 86‐001, Table 6‐1, pp.6‐5
11

The statistical fit is calculated according to the approach is outlined on pages 18‐20 of the Ozone

guideline5

. The design value is calculated by solving for the concentration of PM10 that is equal to a

probability of 1/3654

.  The 95% confidence interval is reported with the statistical fit design value. The

design values calculated using with the table look‐up method all fall within the range of the 95%

confidence interval of the statistical fit design values.

Design values for the most recent 5 years of monitoring data are shown in bold in Table 3.3 alongside

design values calculated using estimated PM10 concentrations.  Monitoring data is discussed in Section

4.1 and PM10 estimates are discussed in Section 4.2.

Table 3.3: Five‐Year Design Values for Kent, Seattle, and Tacoma

5‐YEAR

PERIOD 5‐YEAR 5‐YEAR

DESIGN VALUE

5‐YEAR

DESIGN VALUE

Site YEARS NO. DATA

POINTS

TABLE LOOK‐

UP, μg/m3

STATISTICAL

FIT, μg/m3

   

Kent 2003‐2007 1149 58 57±3

   

Kent 2008 ‐ 2012 1762 43 46±3

   

Seattle 2003‐2007 1318 69 68±4

   

Seattle 2008 ‐ 2012 1311 50 50±5

   

Tacoma 2001‐2007* 900 68 72±9

      

Tacoma 2008 ‐ 2012 1725 54 58±8

*2004 was excluded because more than 75% of the data was missing

   

                                                            

5 Guideline for the Interpretation of Ozone Air Quality Standards, EPA‐450/4‐79‐003
12

Motor Vehicle Regional Analysis Criterion

To qualify for the PM10 LMP option, an area should expect only limited growth in on‐road motor vehicle

PM10 emissions (including fugitive dust) and  pass a motor vehicle regional emissions analysis test, found

in Appendix B of the LMP Guidance. The results of the analysis must be less than 98 μg/m3, the Margin

of Safety (MOS) value for the 24‐hour PM10 standard. The Kent, Seattle, and Tacoma maintenance areas

meet both these criteria, as described below and in Appendix A.

The following methodology was used to determine whether increased emissions from on‐road mobile

sources could, in the next 10 years, increase concentrations in the maintenance areas and threaten the

assumption of maintenance that underlies the LMP Guidance.  

DV + (VMTpi x DVmv) < MOS

Where:

DV = the area’s design value based on the most recent 5 years of data in μg/m3

VMTpi = the projected percent increase in vehicle miles traveled (VMT) over the next 10 years

DVmv = motor vehicle design value based on on‐road mobile portion of the attainment year inventory in

μg/m3

MOS = margin of safety for the relevant PM10 standard for a given area: 40 μg/m3 for the annual

standard or 98 μg/m3 for the 24‐hour standard

Qualification for the LMP approach is demonstrated when the motor vehicle regional analysis results in

a value less than the MOS of 98 μg/m3 for the 24‐hour PM10 standard.  The variables and results for the

equation for each of the three maintenance areas are shown in Table 3.4.  The results of the calculation

is less than the MOS of 98 μg/m3 and therefore demonstrates that the Kent, Seattle, and Tacoma PM10

maintenance areas pass the motor vehicle regional analysis and qualify for the LMP approach.

Table 3.4: Margin of Safety Comparison

Kent Seattle Tacoma

DV (μg/m3) 60 72 81

VMTpi 9% 11% 12%

DVmv (μg/m3) 16.8 24.5 24.3

DV + (VMTpi x DVmv) 61.5 74.7 83.9

MOS (μg/m3) 98 98 98

   
13

LMP Qualification		

The Kent, Seattle, and Tacoma PM10 maintenance areas meet the LMP qualification criteria and qualify

for the LMP option.  As described above and in Appendix A, these areas are in compliance with the 24‐

hour NAAQS for PM10, the five year design values are well below 98μg/m3 and the growth in PM10

emissions from motor vehicles will not threaten compliance with the standard.   

PSCAA provided its analysis to Ecology and EPA Region 10 office.  EPA Region 10 and Ecology mutually

agreed to the LMP approach.  We have discussed the alternative approach for PM10 estimation, outlined

in Section 4.2, with Ecology and EPA. With this submittal, we request approval for the alternative

approach for PM10 estimation. PSCAA will calculate the 3‐year and 5‐year PM10 design value estimates

and provide them to Ecology annually.  Ecology will include a statement that the area continues to

qualify for the LMP option in the annual monitoring network report. The report can be found at

https://fortress.wa.gov/ecy/publications/UIPages/Home.aspx  

   
14

4. Particulate Matter Monitoring

4.1. PM10 Concentrations		

Kent Maintenance Area

The daily (midnight to midnight) concentrations of PM10 and PM2.5 are shown in  Figure 4.1.1. PM10

monitored values are shown from 1987 through 2007 (blue circles), PM2.5 monitored values are shown

from 1999 through 2012 (green plus), and estimated PM10 values based on PM2.5 monitored values are

shown from 1999 through 2012 (black dots). Monitored concentrations have never exceeded the

NAAQS since monitoring began in 1987.  The maximum 24‐hour concentration recorded during the last

five years of PM10 FEM monitoring was 69 μg/m3 in 2006. Estimated PM10 concentrations are shown in

black, the highest estimated PM10 concentration is 144 μg/m3

, this value occurred on July 4, 2009.

Estimated concentrations of PM10 are shown in the figure below (black dots). Model development is

described in Section 4.3.

Figure 4.1.1: Kent Historical PM10 Concentrations
15

Kent Monitoring		

The Kent PM10 maintenance area is shown in  Figure 4.1.1. PSCAA monitored PM10 at James Street and

Central Avenue using a Federal Reference Method (FRM) between 1988 and 2003 and a Federal

Equivalent Method (FEM) from July 2004 through December 2007.  The area has been in compliance

with the standard since 1987. Federal Equivalent Method (FEM) PM10 values were low enough that the

FEM monitor was removed with EPA approval at the end of 2007.  Excerpts from this report are included

as Appendix B.  Since then, continuous monitoring of PM2.5 has been conducted in Kent with a TEOM,

which has been correlated with a co‐located PM10 monitor to provide estimated PM10 values.

Figure 4.1.2 shows the dates and monitors located at the Central and James Street monitoring site from

1988 – 2007. All of the data used to develop the relationship between PM10 and PM2.5 relied exclusively

on data downloaded from EPA’s Air Quality System (AQS). The data downloaded from AQS was collected

using the monitors show in Figure SS. The model described in section 4.2 was developed using data from

the time period where PM10 and PM2.5 measurements are co‐located (1999‐2003). For the period 2008 –

present the PM10 concentrations are estimated using PM2.5 concentrations measured with the

instruments in Figure 4.1.3.  Details on the PM10 and PM2.5 relationship are described in section 4.2.

Figure 4.1.2: PM10 and PM2.5 data used to develop the PM10 to PM2.5 relationship

   
16

Figure 4.1.3: PM2.5 monitoring data used to estimate PM10 concentrations from 2008‐present

   
17

Seattle Maintenance Area

The 24‐hour concentrations of PM10 and PM2.5 are shown in Figure 4.1.4 below. PM10 monitored values

are shown from 1985 through 2007 (blue circles), PM2.5 monitored values are shown from 1999 through

2012 (green plus), and estimated PM10 values based on PM2.5 monitored values are shown from 1999

through 2012 (black dots). Monitored concentrations have not exceeded the NAAQS since 1990.  The

maximum 24‐hour concentration recorded during the last five years of FEM monitoring was 80 μg/m3 in

2006.  

Figure 4.1.4: Seattle Historical PM10 Concentrations

Seattle Monitoring

The Seattle PM10 maintenance area is shown in Figure 2.2. PSCAA monitored PM10 at both 4401 and

4752 East Marginal Way South using an FRM between June 1988 and December 2003 and an FEM from

October 2004 through 2007.  The area has been in compliance with the standard since 1990. Federal

Equivalent Method (FEM) PM10 values were low enough that the monitor was removed with EPA

approval at the end of 2007.  Excerpts from this report are included as Appendix B. Since then,

continuous, reference and non‐reference method monitoring of PM2.5 has been conducted at the Seattle

monitoring site and correlated with a co‐located PM10 monitor to provide estimated PM10 values.  .  

Figure 4.1.5 shows the dates and monitors located at the 4401 and 4752 East Marginal Way South

monitoring site from 1985 – 2007. All of the data used to develop the relationship between PM10 and

PM2.5 relied exclusively on data downloaded from EPA’s Air Quality System (AQS). The data downloaded

from AQS was collected using the monitors show in Figure 4.1.5. The model described in section 4.2 was

developed using data from the time period where PM10 and PM2.5 measurements are co‐located (1999‐

2007). For the period 2008 – present the PM10 concentrations are estimated using PM2.5 concentrations

measured with the instruments in Figure 4.1.6.  Details on the PM10 and PM2.5 relationship are described

in section 4.2.
18

Figure 4.1.5: PM10 and PM2.5 data used to develop the PM10 to PM2.5 relationship

Figure 4.1.6: PM2.5 monitoring data used to estimate PM10 concentrations from 2008‐present

   
19

Tacoma Maintenance Area

The 24‐hour concentrations of PM10 and PM2.5 are shown in Figure 4.1.7 below. PM10 monitored values

are shown from 1987 through 2007 (blue circles), PM2.5 monitored values are shown from 1999 through

2012 (green plus), and estimated PM10 values based on PM2.5 monitored values are shown from 1999

through 2012 (black dots).    Monitored concentrations have not exceeded the NAAQS since 1988.  The

maximum 24‐hour concentration recorded during the last five years of FEM monitoring was 69 μg/m3 in

2006.  

Figure 4.1.7: Tacoma Historical PM10 Concentrations

Tacoma Monitoring

The Tacoma PM10 maintenance area is shown in Figure 2.3. PSCAA monitored PM10 at 2301 Alexander

Avenue site in Tacoma, Washington.  The area has been in compliance with the standard since 1990.  

Federal Equivalent Method (FEM) PM10 values were low enough that the monitor was removed with EPA

approval at the end of 2007.  Excerpts from this report are included as Appendix B. Since then

continuous monitoring of PM2.5 has been conducted at the Tacoma monitoring site and correlated with

a co‐located PM10 monitor to provide estimated PM10 values.  Figure 4.1.8 shows the dates and monitors

located at the 2301 Alexander Avenue monitoring site from 1988 – 2007. All of the data used to develop

the relationship between PM10 and PM2.5 relied exclusively on data downloaded from EPA’s Air Quality

System (AQS). The data downloaded from AQS was collected using the monitors show in Figure 4.1.8.

The model described in section 4.2 was developed using data from the time period where PM10 and

PM2.5 measurements are co‐located (1999‐2003). For the period 2008 – present the PM10 concentrations

are estimated directly from a correlated nephelometer. The nephelometer is the only instrument

presently reporting PM2.5 concentrations at the Alexander Avenue monitoring site.  
20

Nephelometers have been used to monitor particulate matter light scatter in the maintenance areas for

decades.  A nephelometer measures light scatter (bscat) and, when correlated with a Federal Reference

Method (FRM) instrument, accurately represents particulate matter levels.  Because of the high

correlation between nephelometer readings and FRM and Federal Equivalent Method (FEM) monitors,

Ecology and PSCAA conclude that PM2.5 values calculated directly from a nephelometer are sufficiently

reliable and reproducible.  Nephelometer measurements began in the maintenance areas in 1999 and

measurements continue in those areas today.  Each of the monitoring stations in the three maintenance

areas measure PM2.5 with a nephelometer. The Seattle and Kent monitoring stations currently both use

a FEM method and a nephelometer. PM2.5 measurements reported using the FEM monitoring and the

nephelometer the Seattle and Kent maintenance areas are well correlated.

Details on the PM10 and PM2.5 relationship are described in Section 4.2.

Figure 4.1.8: Tacoma monitoring data used to calculate the PM10PM2.5 relationship
21

4.2. Model Development

Monitoring for PM10 concentrations was discontinued with EPA approval at all three monitoring stations

in late 2007 because PM10 levels were so low and continued attainment of the NAAQS could be ensured

through correlation with PM2.5 monitoring. PM10 concentrations from 2008 to the present are calculated

using a relationship between PM10 and PM2.5. PM2.5 measurements collected from 1999 – 2007 were

correlated to PM10 measurements collected in the same period. Many of the sources of PM10 are

independent of season; however, residential wood burning in all three maintenance areas occurs

primarily in the winter months, October‐March. Due to the difference in emission sources in the winter

months compared to the summer months, the relationship was calculated separately for summer

months, April – September, and winter months, October – March.

The relationship between PM2.5 and PM10 was calculated using a robust regression technique. The

standard ordinary least squares (OLS) regression technique, which uses a Pearson correlation, is not

suitable for data with outliers or uncertainty in the independent variable. For weaker correlations, an

OLS regression will result in a slope with a significant low bias. A robust regression technique reduces

the low bias on the slope6.1 and is less sensitive to outliers6.2. For our analysis, the OLS approach resulted

in a slope with a low bias for some of the maintenance areas, which underestimated the PM10

concentrations. Instead, we used an iteratively re‐weighted least squares algorithm (with a bi‐square

weighting function) to calculate the slope and intercept of the PM10 to PM2.5 relationship. This

relationship was then used to estimate PM10 concentrations using measurements of PM2.5.

Kent		

The correlation between PM10 and PM2.5 is strongest in the winter months, October – March. This is

expected because residential wood burning accounts for most of the winter time PM10 and PM2.5

emissions in Kent. For the winter time period, the PM10 to PM2.5 relationship can be described similarly

using and OLS regression or a robust regression. The summer months, April – September, have lower

concentrations and a weaker relationship. Since the summer relationship has a lower correlation than

the winter relationship, the robust regression technique produces a steeper slope for the PM10 to PM2.5

relationship than the OLS technique. For consistency we use the robust regression technique to

calculate the slope and intercept to describe the relationship for both the winter and summer months.

The relationships for PM10 to PM2.5 in the summer and winter months are shown in Figure 4.2.1.

The estimated PM10 values are calculated using measured PM2.5 and the equation of the line for summer

or winter depending on the date of the PM2.5 measurement. In other words, all PM10 concentrations

estimated for dates from April through September use the summer slope and intercept as the PM10

model. As a check for the model, PM10 concentrations were estimated over the period 1999‐2007 and

plotted against PM10 measurements from the same period. The results are shown in Figure 4.2.2.

                                                            

6.1 Ayers, G. P. (2001), Comment on regression analysis of air quality data, Atmos. Environ., 35(13), 2423 – 2425,

doi:10.1016/S1352‐2310(00)00527‐6 6.2Huber, P. J. Robust Statistics. Hoboken, NJ: John Wiley & Sons, Inc., 1981.
22

Figure 4.2.1: Summer and Winter PM10 to PM2.5 from 1999‐2007 at the Kent Monitoring Site

Figure 4.2.2: Estimated PM10 to Measured PM10 for the years 1999‐2007
23

Seattle

The relationship between PM10 and PM2.5 in Seattle is similar in both seasons. Because this area is

characterized by emissions from industry and the Port of Seattle, PM10 and PM2.5 emissions are likely

more uniform throughout the year.  Higher wintertime concentrations are likely a result of winter

inversion and stagnation events which trap pollutants near the surface. Although the OLS technique

produces a slightly steeper slope than the robust regression technique, the PM10 model for the Seattle

maintenance area will use the relationship described by the robust regression technique for consistency

with the Kent and Tacoma maintenance areas. The relationships for PM10 to PM2.5 in the summer and

winter months are shown in Figure 4.2.3

The estimated PM10 values are calculated using measured PM2.5 concentrations and the equation of the

line for summer or winter depending on the date of the PM2.5 measurement. In other words, all PM10

concentrations estimated for dates from April through September were estimated using the

summertime slope and intercept from the PM10 model. As a check for the model, PM10 concentrations

were estimated over the period 1999‐2007 and plotted against PM10 measurements from the same

period. The results are shown in Figure 4.2.4.

Figure 4.2.3: Summer and Winter PM10 to PM2.5 from 1999‐2007 at the Seattle Monitoring

Site
24

Figure 4.2.4: Estimated PM10 to Measured PM10 for the years 1999‐2007

Tacoma

In the Tacoma maintenance area the winter correlation between PM10 and PM2.5 is stronger than the

summer months. This may be explained by the residential wood smoke emissions in the Tacoma region

as well as decreased road dust emissions in the wintertime. For the winter time period, the PM10 to

PM2.5 relationship can be described similarly using and OLS regression or a robust regression. The

summer months, April – September, have higher PM10 concentrations and a weaker relationship. It is

likely this is a reflection of the difference in PM10 and PM2.5 emission sources in the summer months. The

PM10 model for the Tacoma maintenance area uses the relationship described by the robust regression

technique. The relationships for PM10 to PM2.5 in the summer and winter months are shown in Figure

4.2.5

The estimated PM10 values are calculated using measured PM2.5 and the equation of the line for summer

or winter depending on the date of the PM2.5 measurement. In other words, all PM10 concentrations

estimated for dates from April through September the summer slope and intercept are used as the PM10

model. As a check for the model, PM10 concentrations were estimated over the period 1999‐2007 and

plotted against PM10 measurements from the same period. The results are shown in Figure 4.2.6.

   
25

Figure 4.2.5: Summer and Winter PM10 to PM2.5 from 1999‐2007 at the Tacoma Monitoring

Site

Figure 4.2.6: Estimated PM10 to Measured PM10 for the years 1999‐2007
26

PM10Violation Unlikely

Compliance with the 2006 24‐hour PM2.5 standard of 35 μg/m3 will help assure continued compliance

with the 1987 PM10 standard.  PSCAA ran collocated FRM/ FEM PM10 and FRM/FEM PM2.5 monitors from

1999 through 2007.  Using the relationships described in the model development section above, we can

estimate the measured PM2.5 concentrations that would suggest an exceedance of the 24‐hour PM10

standard of 150μg/m3 in the summer and winter seasons. PM2.5 concentrations that would be required

to exceed the 24‐hour PM10 standard are summarized in Table 4.2.1.   

Table 4.2.1 PM2.5 concentrations corresponding to a PM10 concentration of 150 μg/m3

Summer PM2.5

Concentration (μg/m3

)

Max Summer

PM2.5 (μg/m3)*

since 2008

Winter PM2.5

Concentration (μg/m3

)

Max Winter

PM2.5 (μg/m3)

since 2008

Kent 75 71*   122 33

Seattle 79 28 113 34

Tacoma 62 35 114 53

*Maximum value was observed on July 4th , 2009. The second highest value at Kent from 2008‐2012 is 28μg/m3

The maximum summer and winter PM2.5 concentrations observed at each of the monitoring sites from

2008‐2012 are listed in Table 4.4.1. Using the relationship between PM10 and PM2.5,  24‐hour PM2.5

levels would have to exceed, at a minimum, 62 μg/m3

, in summer or at least 113 μg/m3 in the winter to

exceed the PM10 standard at any of the three maintenance area monitoring sites.  Because of the form

of the PM10 standard, the PM2.5 level would have to be exceeded more than once a year, over a three

year average, to violate the PM10  standard.  For example the 71 μg/m3

, recorded at Kent on July 4, 2009,

corresponds to a PM10 concentration of 142 μg/m3

. While 142 μg/m3 is near the NAAQS of 150 μg/m3, it

is not an exceedance. However, the PM2.5 concentration of 71 μg/m3 is well above the NAAQS of 35

μg/m3

. This demonstrates that PM2.5 is the controlling standard.  The maximum observed PM2.5

concentrations in table 4.4.1 demonstrate that an exceedance of the PM10 NAAQS is highly unlikely.  

4.3. Current PM10 and PM2.5 Data Availability		

PM10 concentrations calculated from the PM10 model described above are available from PSCAA and can

be provided to EPA and the public on request. Both the 3‐year and 5‐year design values will be included

in Ecology’s annual monitoring network report to EPA, this report is available to the public at

https://fortress.wa.gov/ecy/publications/UIPages/Home.aspx The PM2.5 monitored concentrations used

to calculate the PM10 concentrations are available from the PSCAA website, www.pscleanair.org.
27

5. Emission Inventory

This section presents the emissions inventory for this second 10‐year maintenance plan and briefly

describes its development.  The LMP Guidance requires the maintenance plan include an attainment

inventory—that is, an inventory with emission levels consistent with attainment of the PM10 standard.  

EPA develops a triennial national emission inventory based on EPA and state inputs.  EPA issued the Air

Emissions Reporting Rule (AERR) to clarify state reporting requirements.  EPA and Ecology agreed on

developing the attainment inventory from available triennial inventory information and annual reported

industrial emissions.  Appendix C provides details on the emission inventory development.

Emission years and categories

EPA approved the Inventory Preparation Plan (IPP) prepared by Ecology that proposed use of readily

available information.  This plan is provided as Appendix D.  Emission estimates in this maintenance plan

inventory are from Ecology’s draft 2011 triennial emissions inventory7 (2011 EI) and the annual 2011

industrial emissions reported to PSCAA and Ecology.

The original seven significant emission categories are reorganized in seven new categories in this

attainment inventory as listed in Table 5.1.  County values from the seven most significant categories

have been temporally and spatially allocated to their respective maintenance areas.  These seven

emissions categories were chosen based on a review of the emission sources in the original

maintenance plan.  

Table 5.1: Emission Categories used in this LMP		

1994 Emissions Categories 2011 Emission Categories

Gasoline Exhaust On‐road Mobile

Diesel Exhaust Port and Marine, On‐road Mobile

Ships Port and Marine

Locomotives Locomotives (including fugitive dust)

Wood Burning Residential Wood Combustion

Road Dust Paved Road Dust, Unpaved Road Dust

Allowable Industrial Industrial

                                                            

7 Draft Excerpts of the Washington State Base Year 2011 County Inventories, Washington State Department of Ecology Air

Quality Program, Sally Otterson, 2013.
28

Emission inventory geography		

The emission inventory is an estimate of the total PM10 tons boundaries shown in the Figure 2.1, Figure

2.2, and Figure 2.3.  

Significant source categories

The most significant sources of PM10 listed in the original maintenance plan for the Seattle and Tacoma

Maintenance Areas was industrial emissions.  For the Kent Maintenance Area, the major source of

emission was from Residential Wood Combustion, and to a lesser extent diesel and gas vehicle exhaust.  

Fugitive dust emissions from coal trains were estimated and are included in the total locomotive

emissions, see Appendix C.  

Other sources are deemed insignificant, including outdoor burning, construction dust, aircraft emissions,

wildfires, cigarette smoke, commercial charbroiling, and secondary particulate matter.  Outdoor burning

is prohibited in the three maintenance areas, so emissions would be minimal.  Neither Ecology nor

PSCAA have local information on emissions for construction dust, cigarette smoke, or commercial

charbroiling, but is assumed to be minimal in these areas.  Smoke from wildfires in Puget Sound is rare

and was considered negligible.  Some of these values are included in the 2011 NEI, however the

emission estimates have large uncertainties because the data was collected nationally and was not

developed specifically for local areas, or for sub‐county regions like the Seattle, Tacoma, and Kent

Maintenance Areas.
29

Maintenance Plan Inventory

Emissions for these seven emission categories are shown in Table 5.2 below. Washington State’s 2011 EI

is the most recent, complete, readily available emission inventory for King and Pierce County.   

Table 5.2: Seattle, Tacoma, and Kent Maintenance Area Annual and Winter Day PM10

Emissions

Seattle Duwamish Tacoma Tideflats Kent

Emission Categories

Emission Inventory Source

Emission Report Year

Annual, tons/yr

Tons/winter day

% of total tons/winter day

Annual, tons/yr

Tons/winter day

% of total tons/winter day

Annual, tons/yr

Tons/winter day

% of total tons/winter day

On‐road Mobile 2011 EI 2011 100.8 0.29 12% 59.9 0.17 11% 21.7 0.06 10%

Port and Marine 2011 EI 2011 122.2 0.33 14% 77.0 0.21 14% 0.0 0.00 0%

Locomotives

(including fugitive

dust)

2011 EI 2011 43.5 0.12 5% 13.4 0.04 2% 13.8 0.04 6%

Residential Wood

Combustion

2011 EI 2011 17.0 0.13 5% 6.6 0.05 3% 34.8 0.26 42%

Paved Road Dust 2011 EI 2011 190.1 0.53 22% 104.6 0.29 19% 40.9 0.11 18%

Unpaved Road Dust 2011 EI 2011 133.6 0.65 27% 23.3 0.11 7% 28.7 0.14 23%

Industrial PSCAA,

Ecology

2011 127.3 0.35 15% 243.4 0.67 43% 0.5 0.00 0%

Total ‐‐  2011 734.5 2.40 ‐‐  528.2 1.53  ‐‐  140.

4

0.61 ‐‐ 
30

6. Control Measures

PSCAA and Ecology relied upon Reasonably Available Control Measures (RACM) for residential wood

combustion and fugitive dust to return the three maintenance areas to compliance with the 1987 PM10

standard. In addition to the RACM for wood smoke and fugitive dust, PSCAA and Ecology have

enforceable and permanent control measures for industrial sources and outdoor burning. Improved

federal standards for diesel emissions have also helped to control emissions.   

PSCAA and Ecology continue to implement the control measures included in the attainment plan and

the first maintenance plan.    

Federal, PSCAA, and Ecology rules provide the legal authority to implement, maintain, and enforce the

control measures in this plan.   Control measures are listed below, with further explanation and

references following:   

Wood Smoke Curtailment

 Mandatory curtailment and enforcement program during impaired air quality (PSCAA Regulation

1, Article 13.05)

 Opacity limits (PSCAA Regulation 1, Article 13.03)

 Fuel restrictions (PSCAA Regulation 1, Article 13.04)

 Prohibition and sale of uncertified wood stoves (PSCAA Regulation 1, Article 13.07)

 Allow woodstoves to be prohibited entirely as a SIP contingency measure (PSCAA Regulation 1,

Article 13.07 (b))

 Certification of new woodstoves (PSCAA Regulation 1, Article 13.02)

 Rules that govern the sale and transfer of uncertified stoves (PSCAA Regulation 1, Article 13.06)

Fugitive Dust Control Measures

 Prevent spillage and track out of dirt and mud on to public roadways (PSCAA Regulation 1,

Article 9.15(a)(4))

 Improved industrial hygiene (PSCAA Regulation 1, Article 9.15(a))

Industrial Source Program

 Modifications of existing major sources

 Boiler replacement

 Facility Shutdown  

 Monitoring opacity of emissions (PSCAA Regulation 1, Article 9.04)

 Emissions standards in PSCAA Regulation I ‐ Article 9 and Chapter 173‐400 WAC

 PSCAA Orders of Approval and Ecology Regulatory Orders for Simpson Tacoma Kraft
31

Diesel Programs		

 Emissions have been reduced as a result of federal regulations on the sulfur content of diesel

fuel and the particulate emissions of new vehicles.  

 Chapter 173‐422A WAC requires heavy duty vehicles registered in Kent, Seattle, and Tacoma to

pass a vehicle inspection and pass specific emissions standards.

Outdoor Burning Restrictions

 Land clearing is prohibited in King and Pierce Counties (PSCAA Regulation 1, Article 8.13)

 Residential yard waste burning is prohibited in urban growth areas in King and Pierce Counties

(PSCAA Regulation 1, Article 8.9 and 8.10)

Emission Reduction Programs

The following programs are believed to be responsible for the region maintaining compliance with the

ambient air quality standard. Where applicable, we have also included voluntary measures that reduce

emissions under the appropriate category (explicitly noted voluntary).   Unless noted voluntary, the

emission reductions listed below are considered permanent and enforceable.   

Wood Smoke Curtailment

PSCAA successfully implements the curtailment program in the Kent, Seattle, and Tacoma PM10

maintenance areas.  Mandatory curtailment and enforcement of solid fuel burning devices is outlined in

PSCAA Regulation I, Article 13.05. When wood smoke pollution is forecasted to impair air quality, PSCAA

restricts wood burning.  When PSCAA calls burn bans for the area, woodstove use and outdoor burning

are restricted or prohibited.  Burn bans do not apply to homes without another source of adequate

heat.  

PSCAA calls burn bans in two stages.  A Stage 1 ban prohibits all uncertified wood heating devices when

pollution approaches unhealthful levels.  A Stage 2 ban prohibits all wood heating when pollution

reaches a specified higher level.  Unhealthful levels are defined as follows: a Stage 1 burn ban (First

Stage of Impaired Air Quality) is declared when meteorological conditions are forecast to cause fine

particulate levels to exceed 35 μg/m3 within 48 hours, when measured on a 24 hour average basis (or

30ug/m3 within 72 hours in counties with a PM2.5 nonattainment area – this includes Pierce County).  A

Stage 2 burn ban (Second Stage of Impaired Air Quality) is declared when a first stage of impaired air

quality has been in force and has not been sufficient to reduce the increasing fine particulate pollution

trend.  Under certain circumstances a Stage 2 ban may be declared without calling a Stage 1 ban first.  

Since Stage 1 and Stage 2 burn bans are designed to maintain the more stringent 2006 PM2.5 standard,  

PSCAA’s burn ban rules are more protective of the PM10 standard than the state burn ban rules

supporting the attainment and first 10‐year maintenance plan for Kent, Seattle, and Tacoma PM10

maintenance areas.  
32

Fugitive Dust

Spillage and track out of dirt and mud onto public roadways is regulated in section 9.15(a) of Regulation

I in the PSCAA rules. The PSCAA fugitive dust program has been determined by EPA to meet the RACM

requirements in CAA Section 189(a)(1)(C). The emission reductions from this program are considered

both permanent and enforceable.  

Industrial Sources

Reductions in actual and allowable emissions from industrial sources have occurred as a result of

facilities permanently shutting down as well as new federal regulations for specific stationary sources.

The National Emission Standards for Hazardous Air Pollutants (NESHAPS) are stationary source

standards for hazardous air pollutants (40 CFR Part 61 and 40 CFR Part 63). Particulate matter is

regulated in NESHAPs found in 40 CFR Part 63. Section 111 of the Clean Air Act authorized the EPA to

develop technology based standards which apply to specific categories of stationary sources. These

standards are referred to as New Source Performance Standards (NSPS) and are found in 40 CFR Part 60.

The NSPS apply to new, modified and reconstructed affected facilities in specific source categories such

as manufacturers of glass, cement, rubber tires and wool fiberglass.8 The NSPS apply to industrial

sources in the Tacoma and Seattle PM10 maintenance areas. Emission standards contained in Article 9 of

PSCAA Regulation I and Chapter 173‐400 WAC as well as PSCAA Orders of Approval and the Ecology

Regulatory Orders for Simpson Tacoma Kraft have been determined by EPA to be permanent and

enforceable.  

Diesel Emissions

National diesel fuel standards have significantly reduced sulfur content in diesel fuel since 1997. The

diesel program regulations are located in 40 CFR Part 80 subpart I. A 15 parts per million (ppm) sulfur

specification, known as Ultra Low Sulfur Diesel (ULSD), was phased in for highway diesel fuel from 2006‐

2010. Diesel engines equipped with advanced emission control devices (generally, 2007 and later model

year engines and vehicles) must use highway ULSD fuel. Exhaust emissions from these engines will

decrease by more than 90%.9 Low sulfur (500 ppm) and Ultra Low Sulfur Diesel (ULSD) fuel will be

phased in for non‐road, locomotive, and marine (NRLM) engines from 2007‐2014. These fuel

requirements, coupled with advanced emission control technologies, will decrease emissions from these

engines by more than 90%.9 EPA adopted changes to the diesel fuel program to allow for the production

and sale of diesel fuel with up to 1,000 ppm sulfur for use in Category 3 marine vessels. The regulations

generally forbid production and sale of fuels with more than 1,000 ppm sulfur for use in most U.S.

waters, unless operators achieve equivalent emission reductions in other ways9.  

   

                                                            

8 New Source Performance Standards and State implementation Plans

http://www.epa.gov/compliance/monitoring/programs/caa/newsource.html 9 EPA Diesel Fuel Page http://epa.gov/otaq/fuels/dieselfuels/index.htm
33

In 2010, the International Maritime Organization designated specific portions of U.S. waters as an

Emission Control Area (ECA). In our region, the ECA extends out to approximately 200 nautical miles

west of the West Coast. The ECA became enforceable in August 2012, but the most stringent fuel sulfur

reductions will come into effect in January 2015.

The ECA will reduce the sulfur content in fuels from an average of about 2.7% sulfur to 0.1% sulfur by

January 2015. This cleaner fuel will result in decreases in both sulfur oxides and PM10 pollution in the

Tacoma and Seattle Maintenance Areas. It should reduce emissions from ocean‐going ships of sulfur

oxides by approximately 95% and PM10 pollution by approximately 60 to 80%.

Voluntary diesel emissions reductions:

Strategies for reducing diesel emissions in the Kent, Seattle, and Tacoma PM10 maintenance areas

have been achieved through the PSCAA Diesel Solutions Program as well as the Northwest Ports

Clean Air Strategy. These programs target emissions in four transportation sectors: off‐road

equipment, on‐road vehicles, maritime vessels and equipment, and rail.  

Off‐road:  Off‐road diesel emissions include construction equipment, aircraft‐support equipment,

and cargo handling equipment used at seaports and rail yards. Voluntary strategies to reduce

diesel emissions in the off‐road sector include cleaner fuels, retrofit technologies and vehicle

replacement.  Through the voluntary programs, cargo handling equipment has been retrofitted

and replaced in the Seattle and the Tacoma PM10maintenance areas.

On‐road and School Buses: Voluntary strategies to reduce diesel emissions from the on‐road

sector include cleaner fuels, retrofit technologies and vehicle replacements. Between 2003 and

2008 PSCAA retrofitted school busses through the Puget Sound region with diesel oxidation

catalysts and crankcase filters.  As part of the Puget Sound Clean Cities Petroleum Reduction

Project, waste hauling fleets are reimbursed for the cost difference between a conventional diesel

truck and a natural gas or hydraulic‐hybrid natural gas truck

Ports: Since both The Port of Tacoma and The Port of Seattle fall within two of the maintenance

areas, diesel reduction projects at the ports have contributed to reducing emissions. Public and

private fleets in The Port of Seattle were replaced with new trucks and diesel oxidation catalysts

as part of the Diesel Solutions Program between November 2009 and January 2011. Through the

voluntary programs, cargo handling equipment has been retrofitted and replaced in both the

Seattle and the Tacoma PM10 maintenance areas.  As part of the Puget Sound Clean Cities

Petroleum Reduction Project, waste hauling fleets are reimbursed for the cost difference between

a conventional diesel truck and a natural gas or hydraulic‐hybrid natural gas truck.
34

Outdoor burning

While not considered a significant contributor to high PM10 concentrations on stagnant winter days,

outdoor burning of land clearing debris and yard waste has potential for causing violations of the PM10

standard. In 2000 and 2008 Article 8 of Regulation I was amended to prohibit residential yard burning in

the King and Pierce County urban growth areas as well as the former carbon monoxide non‐attainment

area (Seattle/Tacoma/Everett urban areas, as defined by the Washington State Department of

Transportation, 1983 version, urban area maps).  Article 13 of Regulation 1 prohibits land clearing

burning completely in King and Pierce counties.  PSCAA continues to encourage development of

alternatives to outdoor burning such as chipping, composting and yard waste collection programs.  

Control Measures in PSCAA Rules		

Washington State’s Clean Air Act grants the authority for and outlines the conditions under which PSCAA

may adopt its own rules.  PSCAA has jurisdiction over the Kent, Seattle, and Tacoma PM10 maintenance

areas and relies upon its rules to maintain and enforce the PM10 standard.  

The PSCAA rules as listed in Table 6.1, Table 6.2, and Table 6.3 are included in the federally approved

SIP.  

Table 6.1: PSCAA Regulation I – Article 8: Outdoor Burning

Regulation I ‐ Article 8: Outdoor Burning State Adoption   EPA Effective

Date

8.04 General Conditions for Outdoor Burning 11/9/2000 9/30/2004

8.05 Agricultural Burning Permits 11/9/2000 9/30/2004

8.06 Outdoor Burning Ozone Contingency Measure 12/19/2002 9/7/2004

8.09 Description of the King County No‐Burn Area 11/9/2000 9/30/2004

8.10 Description of the Pierce County No‐Burn Area 11/9/2000 9/30/2004

8.11 Description of the Snohomish County No‐Burn Area 11/9/2000 9/30/2004

8.12 Description of the Kitsap County No‐Burn Area 10/24/2002 9/30/2004

Table 6.2: PSCAA Regulation I – Article 9: Emission Standards

Regulation I ‐ Article 9: Emission Standards State Adoption   EPA Effective

Date

9.03 Emission of Air Contaminant: Visual Standard 3/11/1999 9/30/2004

9.04 Opacity Standard for Equipment with Continuous Opacity

Monitoring Systems

4/9/1998 9/30/2004

9.05 Refuse Burning 12/9/1993 6/29/1995

9.08 Fuel Oil Standards 4/14/1994 6/29/1995

9.09 Particulate Matter Emission Standards 4/9/1998 9/30/2004

9.15 Fugitive Dust Control Measures 3/11/1999 9/30/2004

9.16 Spray‐Coating Operations 7/12/2001 9/30/2004

9.20 Maintenance of Equipment 6/9/1988 10/28/1994
35

Table 6.3: PSCAA Regulation I – Article 13: Solid Fuel Burning Device Standards

Regulation I – Article 13: Solid Fuel Burning Device Standards State Adoption   EPA Effective

Date

13.03 Opacity Standards 10/25/2012 6/28/2013

13.04 Allowed and Prohibited Fuel Types   10/25/2012 6/28/2013

13.05 Restrictions on Operation of Solid Fuel Burning Devices 10/25/2012 6/28/2013

13.06 Emission Performance Standards 10/25/2012 6/28/2013

13.07 Prohibitions on Wood Stoves that are not Certified

Wood Stoves

10/25/2012 6/28/2013
36

7. Contingency Measures

CAA Section 175(A) requires a maintenance plan include contingency measures necessary to ensure

prompt correction of any violation of the standard that may occur after redesignation.  PSCAA’s

Regulation I – Article 13.07 (b) provides for prohibition of the use of uncertified woodstoves for the sole

purpose of meeting CAA requirements for contingency measures.  To implement this provision, the rule

requires that the EPA, in consultation with Ecology and PSCAA, must make written findings that:  

(1) The area has failed to maintain a national ambient air quality standard

(2)   Emissions from solid fuel burning devices from a particular geographic area are a contributing

factor to such failure to make reasonable further progress or attain or maintain a national ambient air

quality standard

Contingency Measure Trigger

The contingency measure will be triggered if a violation of the PM10 standard occurs at the maintenance

area monitor based on nephelometer and/or FRM monitoring.  A violation of the PM10 standard will be

determined by the procedures outlined in 40 CFR Part 50.
37

8. Commitment to Continued Monitoring and Verification of Continued

Attainment

Emissions in the Kent, Seattle, and Tacoma PM10 maintenance areas are not expected to grow to

threaten compliance with the standard as discussed in Section 3 of this plan.  

PSCAA makes a commitment to continue operation of PM2.5 monitors in the Kent, Seattle, and Tacoma

PM10 maintenance areas through 2020, the end of the maintenance period. The PM2.5 measurements

will be used to calculate PM10 levels in the maintenance areas.  In the unlikely event that after

exceptional events are taken into account (using EPA guidance), the calculated design value for PM10

exceeds the LMP threshold of 98μg/m3

, PSCAA will reestablish PM10 monitoring as part of the annual

network monitoring report process.  PM10 concentrations calculated from the PM10 model described in

section 4.3 are available from PSCAA and can be provided to EPA and the public on request.  The PM2.5

monitored concentrations used to calculate the PM10 concentrations are available from the PSCAA

website, www.pscleanair.org.  Both 3‐year and 5‐year design values will be provided annually to Ecology

for the annual monitoring network report. The network review is available at

https://fortress.wa.gov/ecy/publications/UIPages/Home.aspx

PSCAA will calculate 3‐year and 5‐year PM10 design value estimates annually for the Kent, Seattle, and

Tacoma maintenance areas through 2020 to confirm the areas continue to meet the PM10 NAAQS.  A 3‐

year PM10 design value estimate of or below 150 μg/m3 demonstrates continued compliance with the

PM10 NAAQS.  Ecology will include a statement in the annual network report to inform EPA of continued

attainment for the Kent, Seattle, and Tacoma PM10 maintenance areas based on calculated PM10 values.  
38

9. Summary of Maintenance Plan Commitments		

Commitments made in this maintenance plan are summarized in Table 9.1.

Table 9.1: Second 10‐Year LMP Commitments

Section Commitment Responsible

Agency

3 Annual calculation of the Kent, Seattle, and Tacoma PM10 5‐year

design values through 2020 to show continued qualification for

the LMP option.  

PSCAA

3 Reporting to EPA on continued qualification for the LMP option in

the annual monitoring network report

Ecology

7 Implementation of the contingency measure if the Kent, Seattle,

or Tacoma maintenance area violates the PM10 standard based on

PM2.5 monitoring

PSCAA

8 Continued monitoring of PM2.5 in the Kent, Seattle, and Tacoma

maintenance areas through 2020

PSCAA

9 Annual calculation of the 3‐year PM10 design values for the Kent,

Seattle, and Tacoma maintenance areas through 2020 to assess

compliance with the PM10 standard  

PSCAA

9 Reporting to EPA on continued PM10 attainment in the annual

monitoring network report

Ecology

The PM10 attainment plan for Kent was fully approved by EPA on July 27, 1993 (58 FR 40059) and the

plans for Tacoma and Seattle were fully approved by EPA on October 25, 1995 and October 26, 1995,

respectively (60 FR 54599 and 60 FR 54812).  EPA approved the first 10‐year maintenance plan on March

13, 2001 (66 FR 14492). This plan ensures compliance through 2020 and fulfills the final requirement for

maintenance plans specified by the CAA.
A‐1

Appendix A

Limited	Maintenance	Plan	Qualification	

A. Design Values

The Limited Maintenance Plan (LMP) option for moderate PM10 nonattainment areas requires an area to

meet certain applicability criteria in order to qualify for the LPM option.  The first criteria is that an area

should be attaining the National Ambient Air Quality Standard (NAAQS) and the average PM10 design

value based on the most recent 5 years of air quality data should be at or below 98μg/m3 for the 24‐

hour PM10 NAAQS1

. Using the most recent 5 years of data, downloaded from the Air Quality System

(AQS), for the Kent, Seattle, and Tacoma PM10 maintenance areas design values are, 57±3μg/m3

,

68±4μg/m3

, and 72±9μg/m3 respectively.

The PM10 SIP Development Guideline2 (SIP Guideline) outlines the following four approaches to

determine the PM10 design value: a table look‐up procedure; fitting a statistical distribution to several

years of data; a graphical estimation technique; and the use of a conditional probability approach. This

analysis uses both the table look‐up method and a statistical fit to calculate the PM10 design values. The

graphical estimation and the conditional analysis were considered for this analysis however the table

look‐up method and the statistical fit were the most appropriate for the Kent, Seattle, and Tacoma

monitoring datasets. The graphical estimation technique was not used in this analysis due to insufficient

data in some cases. Where there was insufficient data the concentration that corresponds to a

frequency of 1/365 could not be read directly off a graph of the distribution at each of the sites for all of

the 5‐year time periods. The conditional probability approach is used in cases where individual years of

data should be treated separately. Preliminary analysis of the conditional probability approach showed

that values for individual years did not vary significantly from year to year. Calculating the design value

using the table look‐up method and the statistical fit method allows for the most conservative design

value to be selected.  

The table look‐up procedure is outlined in the PM10 SIP development guide3

.  The PM10 SIP development

guide states that the design concentration for PM10 is the concentration that corresponds to a frequency

of 1/365 on an empirical frequency distribution4

. The table below is used to estimate which point on the

empirical frequency distribution corresponds to a frequency of 1/365.  

   

                                                            

1 Limited Maintenance Plan Option for Moderate PM10 Nonattainment Areas, pp 3 2 PM‐10 SIP Development Guideline, publication EPA 450/2 86‐001 3 PM‐10 SIP Development Guideline, publication EPA 450/2 86‐001, Table 6‐1, pp.6‐5 4 Ibid. 3
A‐2

Tabular Estimation of PM10 Design Values5

Number of Values Data Point to be Used

1  ‐ 347

348 ‐ 695

696 ‐ 1042

1043 ‐ 1390

Highest Value

Second Highest Value

Third Highest Value

Fourth Highest Value

The statistical fit is calculated according to the approach is outlined on pages 18‐20 of the Ozone

guideline6

. The design value is calculated by solving for the concentration of PM10 that is equal to a

probability of 1/3657

. The 95% confidence interval is reported with the statistical fit design value. The

design values calculated using with the table look‐up method all fall within the range of the 95%

confidence interval of the statistical fit design values

   

                                                            

5 Ibid. 3

6 Guideline for the Interpretation of Ozone Air Quality Standards, EPA‐450/4‐79‐003 7 Ibid. 6
A‐3

Kent Design Values

The Kent, Washington design value is based on FRM and FEM 24‐hour PM10 monitoring data from the

James Street and Central Avenue site in Kent, Washington.  The LMP Guidance directs the design value

be based on the most recent five years of data5

.  The five most recent years of FRM data are from 1999

– 2003. From 2004 – 2007 FEM data was collected using a Tapered Element Oscillating Microbalance

(TEOM). The most recent five year design value for Kent, 58±3 μg/m3

, included both FRM and FEM data

and spanned the period 2003‐2007.  The 95% confidence interval of the statistical fit included the design

value calculated using the table look‐up method. The relevant values are shown in Table A.1 below.

Table A.1: Kent PM10 Maximums and 5‐Year Design Values, 1999‐2007

ANNUAL MAXIMUM 5‐YEAR PERIOD 5‐YEAR 5‐YEAR DESIGN

VALUE

5‐YEAR

DESIGN VALUE

YEAR NO.

OBSERVATIONS

AQS

MONITORED

VALUES, μg/m3

YEARS NO.

OBSERVATIONS

TABLE LOOK‐

UP, μg/m3

STATISTICAL

FIT, μg/m3

                

1999 52 51

       

   2000** 5 34

       

2001 52 51

       

2002 61 50

       

2003 59 45 1999‐2003* 273 51 64±3

       

2004 184 42 2000‐2004* 179 50 54±4

       

2005 365 50 2001‐2005 533 50 54±5

       

2006 365 69 2002‐2006 788 55 57±3

       

2007 360 62 2003‐2007 1149 58 57±3

**This year was not used calculate the design value

*This Design Value is missing data from the years marked with “**”   

                                                            

5 PM‐10 SIP Development Guideline, publication EPA 450/2 86‐001
A‐4

Table A.2: Kent, Washington Modeled PM10 5‐Year Design Values,		2008‐2012

ANNUAL MAXIMUM 5‐YEAR PERIOD 5‐YEAR 5‐YEAR

DESIGN VALUE

5‐YEAR

DESIGN VALUE

YEAR NO. DATA

POINTS

MODELED

VALUES, μg/m3 YEARS NO. DATAPOINTS

TABLE LOOK‐

UP, μg/m3

STATISTICAL

FIT, μg/m3

               

2008 323 41

   

2009 364 143*

   

2010 362 56

   

2011 356 38

   

2012 357 46 2008 ‐ 2012 720 43 46±3

            

*This value occurred on July 6, 2009

   
A‐5

Seattle Design Values

The Seattle, Washington design value is based on FRM and FEM 24‐hour PM10 monitoring data from the

4401 East Marginal Way South site in Seattle, Washington.  The five most recent years of FRM data are

from 1999 – 2003. From 2004 – 2007 FEM data was collected using a TEOM. The most recent five year

design value for Seattle, WA included both FRM and FEM data and spanned the period 2003‐2007.  The

design value for 2003‐2007 is 68±4μg/m3 and was calculated using the statistical fit method. The 95%

confidence interval on the statistical fit includes the design value calculated using the table look‐up

method, 69μg/m3

.  The relevant values are shown in Table A.3 below.

Table A.3: Seattle, Washington PM10 Maximums and 5‐Year Design Values, 1999‐2007

ANNUAL MAXIMUM 5‐YEAR PERIOD 5‐YEAR 5‐YEAR DESIGN

VALUE

5‐YEAR

DESIGN VALUE

YEAR NO.

OBSERVATIONS

AQS

MONITORED

VALUES, μg/m3

YEARS NO.

OBSERVATIONS

TABLE LOOK‐

UP, μg/m3

STATISTICAL

FIT, μg/m3

1999 60 53

2000 53 73

2001 55 73

2002 61 71

2003 59 65 1999‐2003 287 73 87±5

2004 184 57 2000‐2004 410 71 80±6

2005 363 77 2001‐2005 720 71 75±5

2006 352 80 2002‐2006 1016 71 71±4

       

2007 364 69 2003‐2007 1318 69 68±4
A‐6

Table A.4: Seattle, Washington Modeled PM10 5‐Year Design Values, 2008	‐	2012

ANNUAL MAXIMUM 5‐YEAR PERIOD 5‐YEAR 5‐YEAR

DESIGN VALUE

5‐YEAR

DESIGN VALUE

YEAR NO. DATA

POINTS

MODELED

VALUES, μg/m3 YEARS NO. DATAPOINTS

TABLE LOOK‐

UP, μg/m3

STATISTICAL

FIT, μg/m3

   

2008 122 51

   

2009 121 50

   

2010 122 51

   

2011 358 45

   

2012 363 48 2008 ‐ 2012 1311 50 50±5

   
A‐7

Tacoma Design Values

The Tacoma, Washington design value is based on FRM and FEM 24‐hour PM10 monitoring data from the

2301 Alexander Avenue site in Tacoma, Washington.  The five most recent years of FRM data are from

1999 – 2003. From 2004 – 2007 FEM data was collected using a TEOM. The monitoring dataset from

2004 is less than 75% complete and was not used in the five year design value calculation.  The most

recent five year PM10 design value for Tacoma, WA included both FRM and FEM data and spanned the

period 2002‐2007, 2004 was excluded.  The table look‐up design value, 68μg/m3 falls within the 95%

confidence interval of the statistical fit method design value, 72±9μg/m3

. The relevant values are shown

in Table A.5 below.

Table A.5: Tacoma, Washington PM10 and 5‐Year Design Values, 1999‐2007

ANNUAL MAXIMUM 5‐YEAR PERIOD 5‐YEAR 5‐YEAR DESIGN

VALUE

5‐YEAR

DESIGN VALUE

YEAR NO.

OBSERVATIONS

MONITORED

VALUES, μg/m3 YEARS NO.OBSERVATIONS

TABLE LOOK‐

UP, μg/m3

STATISTICAL

FIT, μg/m3

1999 50 72

2000 59 67

2001 60 58

2002 60 94

2003 60 68 1999‐2003* 290 94 88±7

2004** 2000‐2004* 238 94 89±9

2005 87 50 2001‐2005* 180 94 85±10

2006 363 69 2002‐2006* 422 69 76±9

       

2007 332 65 2003‐2007* 753 65 66±3

    2001‐2007* 873 68 72±9

** This year is less than 75% complete and was not used to calculate the design value

*This Design Value is missing data from the years marked with “**”   
A‐8

Table A.6: Tacoma, Washington Modeled PM10 5‐Year Design Values, 2008	‐	2012

ANNUAL MAXIMUM 5‐YEAR PERIOD 5‐YEAR 5‐YEAR

DESIGN VALUE

5‐YEAR

DESIGN VALUE

YEAR NO. DATA

POINTS

MODELED

VALUES, μg/m3 YEARS NO. DATAPOINTS

TABLE LOOK‐

UP, μg/m3

STATISTICAL

FIT, μg/m3

   

2008 348 40

   

2009 347 84

   

2010 334 53

   

2011 374 36

   

2012 349 71 2008 ‐ 2012 1725 54 58±8

   

   
A‐9

Motor Vehicle Regional Analysis

To qualify for the PM10 LMP option, an area should expect only limited growth in on‐road motor vehicle

PM10 emissions. This means the area must pass the Motor Vehicle Regional Analysis, found in Appendix

B of the LMP Guidance. The results of the analysis must be less than 98 μg/m3, the Margin of Safety

(MOS) value for the 24‐hour PM10 standard.  

The following methodology was used to determine whether increased emissions from on‐road mobile

sources could, in the next 10 years, increase concentrations in the maintenance areas and threaten the

assumption of maintenance that underlies the LMP Guidance.  

DV + (VMTpi x DVmv) < MOS

Where:

DV = the area’s design value based on the most recent 5 years of data in μg/m3

VMTpi = the projected percent increase in vehicle miles traveled (VMT) over the next 10 years

DVmv = motor vehicle design value based on on‐road mobile portion of the attainment year inventory in

μg/m3

MOS = margin of safety for the relevant PM10 standard for a given area: 40 μg/m3 for the annual

standard or 98 μg/m3 for the 24‐hour standard

   
A‐10

Step 1.		 Determine the 5‐year design value (DV)

As described above, a number of methodologies were used to determine the most recent 5‐year design

values based on monitored data. For the purposes of the motor vehicle regional analysis, the most

conservative values were used in order to represent the highest possible emissions increase due to on‐

road mobile sources. The values used for this analysis are summarized in Table A.7, and represent the

upper range of the highest design value for each maintenance area.

Table A.7: Design Values used for Motor Regional Analysis

PM10 Maintenance Area Kent Seattle Tacoma

Design Value (DV) in μg/m3 60 72 81

Step 2. Determine the percent increase in maintenance area average

daily VMT over the next ten years (VMTpi).

The VMT values for 2010 and 2020 for the three maintenance areas were provided by the Puget Sound

Regional Council (PSRC)6

. The percent increase in VMT was determined using the difference between

2020 and 2010 modeled VMT per day, as summarized in Table A.8.

Table A.8: Projected 10‐year Increase in VMT

Kent Seattle Tacoma

2010 VMT 589,892 2,285,165 1,591,430

2020 VMT 642.401 2,540,361 1,778,486

10‐year increase 52,509 255,196 187,056

Percent increase (VMTpi) 9% 11% 12%

                                                            

6 Puget Sound Regional Council. 2009 Air Quality Conformity Determination. Per concurrence of the region’s Air Quality

Consultation Partners (EPA, Ecology, PSCAA, FHWA, FTA and WSDOT), starting in 2010 the region was no longer required to

demonstrate conformity for PM10 in the year 2010, since it was a past year; only forecast years were thereafter analyzed. The

2009 documentation is therefore the last analysis of 2010 PM10 values.
A‐11

Step 3.		 Determine the motor vehicle design value based on on‐road

mobile portion of the attainment year inventory (DVmv).

The third paragraph of Attachment B of the LMP Guidance offers: “Please note that DVmv is derived by

multiplying DV by the percentage of the attainment year inventory represented by on‐road mobile

sources. This variable should be based on both primary and secondary PM10 emissions of the on‐road

mobile portion of the attainment year inventory, including re‐entrained road dust.”

The percentage of total on‐road mobile (ORM) source emissions from vehicle exhaust, brakewear and

tirewear, were presented in Table 5.2 of the Emissions Inventory. Using the equation below, these

percentages were used to determine the motor vehicle design value (DVmv), as summarized in Table A.9.  

DVmv = DV x ORM percent of inventory

Table A.9: Calculation of Motor Vehicle Design Value

Kent Seattle Tacoma

DV (μg/m3) 60 72 81

On‐road vehicle exhaust,

brakeware, tirewear percent

of total ton/winter day

10% 12% 11%

Paved Road Dust percent of

total ton/winter day 18% 22% 19%

Total ORM percent of

ton/winter day 28% 34% 30%

Motor vehicle design value

(MVdv) (μg/m3) 16.8 24.5 24.3

   
A‐12

Step 4. Comparison of Regional Analysis to Margin of Safety (MOS)

Qualification for the LMP approach is demonstrated when the motor vehicle regional analysis results in

a value less than the MOS of 98 μg/m3 for the 24‐hour PM10 standard. The variables and results for the

equation for each of the three maintenance areas are shown in Table A.10. The results of the calculation

is less than the MOS of 98 μg/m3 and therefore demonstrates that the Kent, Seattle, and Tacoma PM10

maintenance areas pass the motor vehicle regional analysis and qualify for the LMP approach.

Table A.10: Margin of Safety Comparison

Kent Seattle Tacoma

DV (μg/m3) 60 72 81

VMTpi 9% 11% 12%

DVmv (μg/m3) 16.8 24.5 24.3

DV + (VMTpi x DVmv) 61.5 74.7 83.9

MOS (μg/m3) 98 98 98
B‐1

Appendix B

2008 Ambient Air Monitoring Network Report

Washington State Department of Ecology

2008

Ambient Air Monitoring Network Report

     

Washington State Department of Ecology

300 Desmond Drive/PO Box 47600
B‐2

Olympia, Washington 98504‐7600

Publication number:  08‐02‐012

If you need this publication in another format, please call Tami Dahlgren at (360) 407‐6800. Persons with

hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877‐833‐6341.
B‐3

Executive Summary

Purpose of the report

The Department of Ecology (Ecology) reviews its ambient air quality monitoring network each year to

ensure that it collects adequate, representative, and useful air quality data.  This report summarizes the

results of the 2008 review which include:

 Identifying modifications to Ecology’s ambient air monitoring network since the 2007 annual

network report  

 Identifying proposed modifications to the network for the upcoming year

 Documenting Ecology’s ambient air quality monitoring needs, goals, and priorities  

Background information

The United States Environmental Protection Agency (EPA) ambient air quality surveillance regulations ‐‐

Code of Federal Regulations, Title 40, Part 58 (40 CFR Part 58) ‐‐ require states to establish air quality

surveillance systems in their State Implementation Plans (SIPs). An air quality surveillance system

consists of a network of State and Local Air Monitoring Stations (SLAMS).  These stations measure

ambient concentrations of those air pollutants for which 40 CFR Part 50 sets standards.  

Monitoring network requirements

SLAMS must meet requirements of 40 CFR Part 58 contained in:

 Appendix A (Quality Assurance Requirements)

 Appendix C (Ambient Air Quality Monitoring Methodology)

 Appendix D (Network Design Criteria)

 Appendix E (Probe and Path Siting Criteria)  

States determine if they conform with Appendices A and C in part through periodic systems and

performance audits (per Section 2.4 of Appendix A).  States conform with Appendices D and E by
B‐4

conducting an annual network review of their air quality surveillance systems (per 40 CFR 58.20(d)).  The

annual network review:

 Determines if an ambient air quality monitoring network is achieving its required air

monitoring objectives

 Identifies changes to the network needed to enable an organization to meet its objectives

Using monitoring data

Ecology uses its air monitoring data to:   

 Determine compliance with the national ambient air quality standards (NAAQS)

 Determine maximum pollutant concentrations

 Forecast air quality

 Evaluate the effectiveness of air pollution control programs,

 Evaluate the effects of air pollution on public health,

 Track the progress of SIPS

 Support dispersion models

 Determine air quality trends

 Develop responsible and cost‐effective pollution control strategies
B‐5

Table of Contents

1 Introduction...........................................................................................................................................7

2 Regulatory Requirements and Other Data Needs................................................................................. 7

2.1 Appendix D Requirements ......................................................................................................................... 7 

2.1.1 Monitoring Objectives and Spatial Scales ........................................................................................ 7 

Monitoring Objectives ............................................................................................................................................ 8 

2.1.2 Number of SLAMS Sites .................................................................................................................. 9 

2.2 Appendix E Requirements .......................................................................................................................... 9 

2.3 Other Ambient Air Monitoring Data Needs ............................................................................................. 10 

3 Network Review Procedure................................................................................................................. 11

3.1 Network Review Team and Preparation ................................................................................................... 11 

3.2 Network Modifications ............................................................................................................................. 11 

3.3 Determining Compliance with Appendix D and Special Monitoring Requirements ................................ 12 

3.3.1 Number and Location of Monitors .................................................................................................. 12 

3.4 Determining Compliance with Appendix E Requirements ....................................................................... 13 

4 Network Evaluation and Recommendations/Modifications............................................................... 13

4.1 Carbon Monoxide (CO, 42101) ................................................................................................................ 13 

4.2 Ozone (O3, 44201) .................................................................................................................................... 15 

4.3 Nitrogen Dioxide (NO2, 42602) ............................................................................................................... 20 

4.4 Sulfur Dioxide (SO2, 42401) .................................................................................................................... 21 

4.5 Particulate Matter 10 (PM10, 81102) ......................................................................................................... 21 

4.6 Particulate Matter 2.5 (PM2.5, 88101, 88502) ........................................................................................... 25 

4.7 PM2.5 - Other ............................................................................................................................................. 40 

4.7.1 Other – Contracted Sites USFS ....................................................................................................... 41 

4.7.2 Other – Contracted Sites Tribal/EPA .............................................................................................. 42 

4.7.3 Other Contracted Local Air Agencies ............................................................................................. 43 

4.8 Trace Gas Monitoring ............................................................................................................................... 44 

4.9 Toxics/Speciation Monitoring .................................................................................................................. 45 

5 References...........................................................................................................................................48

Table of Figures

Table 1:  Relationship Between Monitoring Objectives and Scale of Representativeness ..........................8

Table 2: Summary of Spatial Scales for SLAMS............................................................................................. 8

Table 3:  Summary of Probe and Monitoring Path Siting Criteria............................................................... 10

Table 4: Carbon Monoxide, 42101.............................................................................................................. 14

Table 5: Ozone, 44201 ................................................................................................................................15
B‐6

Table 6: Nitrogen Dioxide, 42602 ............................................................................................................... 20

Table 7: Sulfur Dioxide, 42401 .................................................................................................................... 21

Table 8: Particulate Matter 10 (PM10, 81102)............................................................................................. 22

Table 9: Particulate Matter (PM2.5, 88101, 88502)..................................................................................... 26
B‐7

1 Introduction

The Code of Federal Regulations, Title 40, Part 58 (40 CFR Part 58) contains the federal Environmental

Protection Agency’s (EPA’s) ambient air quality surveillance regulations.  Section 58.20 requires states to

establish air quality surveillance systems in their State Implementation Plans (SIPs).  The air quality

surveillance system consists of a network of monitoring stations designated as SLAMS.  These stations

measure ambient concentrations of those air pollutants for which standards exist in 40 CFR Part 50 and

Part 58,  Appendices A (Quality Assurance Requirements), C (Ambient Air Quality Monitoring

Methodology), D (Network Design Criteria) and E (Probe and Path Siting Criteria). States determine

compliance with Appendices A and C in part through periodic systems and performance audits (per

Section 2.4 of Appendix A).  States comply with Appendices D and E by conducting an annual network

review of their air quality surveillance systems (per 40 CFR 58.20(d)).  The annual network review

determines if the network achieved its required air monitoring objectives and if it should be modified

(e.g., termination, relocation or establishment of monitoring stations) to meet those objectives.  The

main purpose of this review is to ensure that an ambient air quality monitoring network collects

adequate, representative, and useful air quality data.  The ambient air quality data from Ecology’s

network is used for a variety of purposes including:

 Determining compliance with the national ambient air quality standards (NAAQS) 

 Determining the location of maximum pollutant concentrations 

 Determining the effectiveness of air pollution control programs 

 Evaluating the effects of air pollution on public health 

 Tracking the progress of SIPS 

 Supporting dispersion models 

 Developing responsible, cost-effective, control strategies 

 Developing air quality trends 

2 Regulatory	Requirements	and	Other	Data	Needs

2.1 Appendix D Requirements

Appendix D of 40 CFR 58 describes concepts for designing the SLAMS network.  It addresses monitoring

objectives and the criteria for selecting the location and number of air monitoring stations.  The

concepts and guidance in Appendix D, as well as other non‐regulatory EPA data needs, should be

considered when evaluating the adequacy of the SLAMS network.

2.1.1 Monitoring Objectives and Spatial Scales
B‐8

Appendix D calls for the design of SLAMS networks to meet a minimum of six basic objectives:

(1) Determine the highest pollutant concentrations expected in the area covered by the network

(2) Determine representative pollutant concentrations in areas of high population density

(3) Determine the impact of significant sources or source categories on pollutant concentrations in

the ambient air

(4) Determine general background pollutant concentrations

(5) Determine the regional extent of pollutant transport between populated areas

(6) Determine the impacts (e.g., visibility impairment, vegetation effects) in more rural and remote

areas on the secondary (i.e., welfare) standards

SLAMS networks should be designed to provide data for meeting the monitoring objectives described

above and to assist EPA and states in solving environmental problems.

Appendix D also provides guidance on spatial scales of representativeness for stations in a SLAMS

network (Table 1).  Ideally, the monitor is located so that its sample represents the air quality over the

entire area that the monitoring station is intended to represent (Table 2).

Table 1:		Relationship Between Monitoring Objectives and Scale of Representativeness

Monitoring Objectives

Appropriate Siting Scales

Highest concentration Micro, middle, neighborhood, urban

Population Neighborhood, urban

Source impact Micro, middle, neighborhood

General/Background Neighborhood, urban, regional

Regional transport Urban/regional

Welfare‐related impacts Urban/regional

Table 2: Summary of Spatial Scales for SLAMS

Scales Applicable for SLAMS

SO2 CO O3 NO2 Pb PM10 PM2.5

Micro..............     

Middle............       

Neighborhood       
B‐9

Urban.............      

Regional.........     

2.1.2 Number of SLAMS Sites

Appendix D to 40 CFR Part 58 does not contain criteria for determining the total number of stations in

the SLAMS network, except for requiring a minimum number of SLAMS lead, SO2, and PM2.5 sites.  For

lead, EPA requires state and local agencies to focus their network design efforts on establishing

monitoring stations around lead stationary sources which generate or have the potential to generate

exceedances of the quarterly lead NAAQS.  Sources around which lead monitoring networks should be

established are those emitting five or more tons per year or smaller stationary sources which may be

problematic based on the size of the facility and their proximity to populated neighborhoods.   

EPA recommends a minimum of two lead sites per source, one to measure stack impacts and the second

to measure fugitive emissions.  Other factors such as topography, source type, proximity and locations

of nearby populations may affect the number of stations in the network.

SLAMS SO2 monitoring requirements for counties not within the boundaries of any Consolidated

Metropolitan Statistical Area/Metropolitan Statistical Area (CMSA/MSA) are based on the emissions of

SO2 in the airshed. A minimum number of SO2 SLAMS sites are required for targeted sources of SO2

emissions.  Other than these requirements, the optimum size of a particular SLAMS network involves

tradeoffs between data needs and available resources which can best be resolved during the network

design process.

2.2 Appendix E Requirements

Appendix E contains siting criteria to be applied to ambient air quality analyzers or samplers after the

general site location has been selected based on the monitoring objectives and spatial scales of

representativeness presented in Appendix D and summarized in Section 2.1 of this document.  The siting

criteria presented in Appendix E are summarized in Table 3.

EPA believes that most sampling probes or monitors can be located so that they meet the Appendix E

siting requirements.  Some existing stations, however, may not meet these requirements and yet still

produce useful data for some purposes.  EPA will consider written requests from the State to waive one

or more siting criteria for some monitoring stations provided that the State can demonstrate the

following: (1) The site is as representative of the monitoring area as it would be if siting criteria were

met; and (2) the siting criteria cannot be met because of physical constraints (e.g., inability to locate the

station the necessary setback distance from roadways or obstructions).  Waivers may be granted to
B‐10

existing SLAMS if one of these criteria is met; waivers may be granted for new SLAMS only if both

criteria are met. Written requests for waivers must be submitted to the EPA Regional Administrator.   

2.3 Other Ambient Air Monitoring Data Needs

Washington has a number of special purpose monitors (SPMs) deployed throughout the State for PM10,

PM2.5, CO and NO2, monitoring.  They are used for a variety of purposes, including Washington’s Air

Quality Index program, ambient air quality assessment and special studies such as secondary aerosol

and ozone precursor assessments   SPM monitoring sites often utilize Federal Reference Method (FRM)

sampling equipment, and are operated in accordance with CFR requirements for quality assurance and

quality control.  SPM designation for criteria pollutant monitoring sites allows Ecology to assess ambient

particulate levels within regions of the State, while providing the flexibility to relocate the sites if it is

determined there is no concern for NAAQS violations in the area (typically after three years of data

collection).  SPM sites may be added to Ecology’s SLAMS network when a NAAQS exceedance has been

recorded, or if elevated pollutant concentrations are consistently measured at the site.  

Table 3:		Summary of Probe and Monitoring Path Siting Criteria

Pollutant

Scale

[maximum

monitoring

path length,

meters]

Height from ground

to probe or 80% of

monitoring  path

(meters)

Horizontal and vertical

distance from

supporting structures to

probe or 90% of

monitoring path

(meters)

Distance from

trees to probe or

90% of

monitoring path

(meters)

SO2

Middle [300m]

Neighborhood,

Urban, and

Regional [1km]

3‐15 >1 >10

CO

Micro, Middle

[300m]

Neighborhood

[1km]

30.5; 3‐15 >1 >10

O3

Middle [300m]

Neighborhood,

Urban, and

Regional [1km]

3‐15 >1 >10

Ozone

precursors

Neighborhood

and urban

[1km]

3‐15 >1 >10
B‐11

Pollutant

Scale

[maximum

monitoring

path length,

meters]

Height from ground

to probe or 80% of

monitoring  path

(meters)

Horizontal and vertical

distance from

supporting structures to

probe or 90% of

monitoring path

(meters)

Distance from

trees to probe or

90% of

monitoring path

(meters)

NO2

Middle [300m]

Neighborhood

and Urban

[1km]

3‐15 >1 >10

PM10

Micro; Middle,

Neighborhood,

Urban and

Regional

2‐7 (Micro);

2‐15 (All other scales)

>2 (All scales, horizontal

distance only)

>10 (All scales)

3 Network Review Procedure

3.1 Network Review Team and Preparation

Network report participants include Washington Department of Ecology Air Monitoring staff and where

applicable, representatives from Washington’s seven local air agencies. Sufficient information must be

provided to determine compliance of the network with regulatory network design and siting

requirements specified in 40 CFR Part 58, Appendices D and E as well as to determine compliance of the

network design and siting requirements specified for all special ambient air monitoring networks.

 

3.2 Network Modifications

Modifications to the SLAMS network are addressed in 40 CFR 58.25, 58.36, and 58.46, respectively.  

Under Section 58.25, States are required to annually develop and implement schedules to modify the

SLAMS network to eliminate any unnecessary stations or to correct any inadequacies indicated by the

annual network review required by 58.20(d).  As part of the annual network review, evaluations of the

special networks established as partnership agreements between EPA and Ecology should also be

conducted.  Modifications to these networks should be recommended as a result of this annual report.

An important objective of the network modification process is determining whether or not sufficient

ambient air quality information and data are being provided by the regulatory and other special

monitoring networks to satisfy the principal data needs.  If sufficient air quality data are not being

collected, the deficient area must be identified and corrective action taken to resolve the problem.  
B‐12

Conversely, if it is determined that excessive data are being collected (e.g., there are redundant sites

resulting in data that agree closely), then efforts need to be taken to determine where dis‐investment

should be made and on what schedule.

Network modifications may be initiated by EPA or proposed by Ecology and agreed to by EPA.  Network

modifications may result from revisions to the Part 58 regulations, systems audits, site visits, or

performance evaluations; special studies/saturation sampling, population increases/decreases; air

quality concentrations consistently recorded below the NAAQS; loss of permission to use a site;

demolition of a building which is used for monitoring; building construction; growth of trees; changes in

roadways; change in neighborhood type of use, etc.

3.3 Determining Compliance with Appendix D and Special Monitoring

Requirements

Ecology uses this review to determine whether it is meeting the number of monitors required by the

Part 58 Appendix D design criteria requirements, and whether the monitors properly located based on

the monitoring objectives and spatial scales of representativeness presented in Appendix D.  For special

monitoring networks, compliance determinations will be conducted in accordance with applicable

program documents.

3.3.1 Number and Location of Monitors

For SLAMS, the number of monitors required and their locations are not specified in the regulations but

rather are determined by EPA Region 10 and Ecology on a case‐by‐case basis.  EPA and Ecology ensure

that SLAMS meet the monitoring objectives specified in Appendix D. Adequacy of the network is be

determined by using a variety of tools, including the following:

 Analyses of historical monitoring data 

 Maps of emissions densities 

 Dispersion modeling 

 Special studies/saturation sampling 

 Best professional judgment 

 SIP requirements 

 Revised monitoring strategies (e.g., new regulations, reengineering air monitoring network) 

 Monitoring network maps and network descriptions with site objectives defined 
B‐13

Appropriate location of monitors can be determined on the basis of stated objectives. Maps, graphical

overlays, and GIS‐based information are extremely helpful in visualizing or assessing the adequacy of

monitor locations.  Plots of potential emissions and/or historical monitoring data versus monitor

locations are especially useful.  When questions arise about the adequacy of a particular location,

modeling or special studies (including saturation monitoring studies) may be appropriate.

Monitor locations are based on the objectives specified in Appendix D, Section 3. Most often, these

locations are those that have high concentrations and large population exposure.  Population

information may be obtained from the latest census data and ambient monitoring data from AQS.  If the

zip codes for various monitoring locations are obtained, use of electronic media census information and

GIS‐based information can be more easily combined with ambient monitoring data.

For special monitoring serving AQI, etc., program documents applicable to the network must be

reviewed to determine the goals and specific siting criteria for the network.  Compliance with

monitoring objective determinations of the special network should be conducted using procedures

similar to those used for Appendix D evaluations (i.e., are the number of monitors appropriate and are

the monitors properly located).

3.4 Determining Compliance with Appendix E Requirements

Applicable siting criteria for SLAMS are specified in 40 CFR 58, Appendix E. The on‐site visit itself consists

of the physical measurements and observations needed to determine compliance with the Appendix E

requirements, such as height above the ground level, distance from trees, paved or vegetative ground

cover, etc.

4 Network Evaluation and Recommendations/Modifications

4.1 Carbon Monoxide (CO, 42101)

National Ambient Air Quality Standard (NAAQS):

 1‐hour average concentration not to exceed 35 ppm, on more than one occasion in a

calendar year, measured at any monitoring site.
B‐14

 8‐hour average concentration not to exceed 9 ppm for any 8‐hour period, on more than one

occasion in a calendar year, measured at any monitoring site.

Washington’s carbon monoxide monitoring network is comprised of two sites statewide.

Table 4: Carbon Monoxide, 42101

AQS # Site Name Est.   Type Scale Sampling  

Freq.

Action for

2008

530330019 Bellevue, 148th 12/1/98 SLAMS Micro Continuous Continue

530630049 Spokane, 3rd & Washington 1/1/97 SLAMS Micro Continuous Continue

Additional Monitors: None

Recommendations/Modifications:  Continue the Bellevue 148th and Spokane 3rd & Washington sites.   

Bellevue, 148th ‐ SLAMS

AQS # 530330019         Method code: 054

Address: 2421 148th NE, Bellevue     LAT/LONG: 047 37' 54" / 122 08' 34"

Monitoring objective: Highest Concentration    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Bellevue 148th is micro scale SLAMS site established in 1998.  It is located in a commercial area near a

highly‐traveled commuter roadway (SR520).   

Exceedences

This site has not exceeded the standard in the past 3 years.

Spokane, 3rd & Washington ‐ SLAMS

AQS # 530630049         Method code: 054
B‐15

Address: W. 408 3rd Avenue, Spokane     LAT/LONG: 047 39' 13" / 117 25' 07"

Monitoring objective: Highest Concentration    MSA: Spokane, WA

Comments  

3rd & Washington is a micro scale SLAMS site established in 1997.  It is located in the downtown core of

Spokane in a highly‐traveled commercial area.  The site is currently used for maintenance plan purposes.

Spokane is a former CO nonattainment area.

Exceedences

This site has not exceeded the daily or annual standard for CO in the past 3 years.

4.2 Ozone (O3, 44201)

National Ambient Air Quality Standards (NAAQS):

 8-hour average of the 4th highest measured O3 concentration averaged over three consecutive 

years, not to exceed 0.075 ppm at any given monitoring site. 

Washington’s ozone monitoring network is comprised of ten sites statewide.

Table 5: Ozone, 44201

AQS # Site Name Est. Type Scale Sampling

Freq.

Action

For 2008

530330080 Seattle, Beacon Hill 4/1/97 SLAMS Urban Continuous Continue

530330010 Issaquah, Lake

Sammamish

12/1/75 SLAMS Urban Continuous Continue

530330023 Enumclaw, Mud

Mountain

7/8/98 SLAMS Urban Continuous Continue

530330017 North Bend, North

Bend Way

6/1/98 SLAMS Urban Continuous Continue

530531008 LaGrande, Pack Forest 5/30/85 SLAMS Urban Continuous Continue
B‐16

530530012 Mt. Rainier, Jackson

Visitor Center

7/13/98 SLAMS NPS supported

site

Continuous Continue

530110011 Vancouver, Blairmount 4/1/90 SLAMS Neighborhood Continuous Continue

530670005 Yelm, Northern Pacific 5/1/06 SLAMS Urban Continuous Continue

530630001 Cheney, Turnbull 4/1/99 SLAMS Urban Continuous Continue

530630046 Spokane, Greenbluff 4/1/90 SLAMS Urban Continuous Continue

Additional Monitors:  None  

Recommendations/Proposed Modifications: Continue the above listed ozone sites.  

Ozone

Seattle, Beacon Hill ‐ NCore  

AQS # 530330080         Method code: 056

Address: 4103 Beacon Avenue S., Seattle    LAT/LONG: 047 34' 58" / 122 18' 30"

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Beacon Hill is an urban scale NCORE site located south of downtown Seattle, within a City of Seattle

park/reservoir.  In addition to ozone, the site is used for monitoring Trace level CO, SO2, NO2, PM2.5, air

toxics, speciation and other special studies.  The Beacon Hill site is also a long‐term trend site and

research site.

Exceedences

This site has not exceeded the 8‐hour standard.

Issaquah, Lake Sammamish ‐ SLAMS  

AQS # 530330010         Method code: 056

Address: 20050 SE 56th (Lk. Sammamish SP), Issaquah LAT/LONG: 047 33' 07" / 122 02' 40"
B‐17

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Lake Sammamish is an urban scale site established in 1975 located east of Seattle, within Lake

Sammamish State Park.  The Lake Sammamish site is a long‐term trends site.  

Exceedences

This site has not exceeded the 8‐hour standard in the past 3 years.

Enumclaw, Mud Mountain Dam ‐ SLAMS

AQS # 530330023         Method code: 056

Address: 30525 SE Mud Mountain Road, Enumclaw LAT/LONG: 047 08' 28" / 121 56' 09"

Monitoring objective: Regional Transport    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Mud Mountain Dam is an urban scale State and Local Monitoring Site (SLAMS) established in 1998 and

located 30 miles East of Seattle, outside of Enumclaw at the end of the ozone transport zone near the

Cascade Mountains.  Enumclaw Mud Mountain historically has been the highest reading site in the

ozone network.   

Exceedences

This site has exceeded the 8‐hour standard in the past 3 years.

North Bend, North Bend Way ‐ SLAMS

AQS # 530330017         Method code: 056

Address: 42404 SE North Bend Way, North BendLAT/LONG: 047 29' 23" / 121 46' 24"

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

North Bend Way is an urban scale site established in 1998 and located outside of North Bend, 25 miles

East of Seattle.  North Bend typically indicates some of the highest readings in the ozone network.

Exceedences

This site has not exceeded the 8‐hour ozone standard in the past 3 years.
B‐18

LaGrande, Pack Forest ‐ SLAMS

AQS # 530531008         Method code: 056

Address: .6 mi North of LaGrande on SR 7, Pierce Co.   LAT/LONG: 046 50' 33" / 122 18' 55"

Monitoring objective: Highest Concentration    MSA: Tacoma, WA

Adequacy

LaGrande is a regional scale site established in 1985 and located in the UW Pack Forest.  LaGrande has

been a high concentration, transport and long term trend site.  

Exceedences

This site has not exceeded the 8‐hour ozone standard in the past 3 years.

Mt. Rainier, Jackson Visitor Center ‐ SLAMS

AQS # 530530012         Method code: 056

Address: Jackson Visitor Center, Mount Rainier LAT/LONG: 046 47' 07" / 121 43' 58"

Monitoring objective: Background     MSA: Tacoma, WA

Comments

The Jackson Visitor Center site is a regional scale site established in 1998.  The site is part of an outreach

project at the Jackson Visitors Center at Mt. Rainier National Park.  

Exceedences

This site has not exceeded the 8‐hour ozone standard in the past 3 years.

Vancouver, Blairmount ‐ SLAMS

AQS # 530110011         Method code: 056

Address: 1500 SE Blairmount Drive, Vancouver    LAT/LONG: 045 36' 37" / 122 30' 59"

Monitoring objective: Population Exposure    MSA: Portland‐Vancouver, OR‐WA

Comments
B‐19

Blairmount is an urban scale site established in 1990 and located in a residential area, near downtown

Vancouver.  The site represents the Portland/Vancouver airshed. It is part of the ozone maintenance

planning effort of the Southwest Clean Air Agency (SWCAA).

Exceedences

This site has not exceeded the 8‐hour ozone standard in the past 3 years.

Yelm, Northern Pacific ‐ SLAMS

AQS # 530670005         Method code: 056

Address: NEW ‐ 931 Northern Pacific Road, Yelm LAT/LONG: 046 57' 03" / 122 35' 43"

Monitoring objective: Population Exposure    MSA: Olympia, WA

Comments

The Yelm site is urban scale site established in 2006 and located in a commercial/residential area in

Yelm.  The Yelm site represents ozone transport impacts in the Southern Puget Sound area.

Exceedences

This site has not exceeded the 8‐hour ozone standard in the past 3 years.

Cheney, Turnbull ‐ SLAMS

AQS # 530630001         Method code: 056

Address: S. 26010 Smith Road, Cheney       LAT/LONG: 047 24' 55" / 117 31' 49"

Monitoring objective: Unknown       MSA: Spokane, WA

Comments

Turnbull is a background/transport scale site established in 1999 and is located within the Turnbull

Wildlife Refuge at Cheney, south of Spokane.  It has been a high‐concentration and

background/transport site for the Spokane area. A CFR required site by population.  

Exceedences

This site has not exceeded the 8‐hour ozone standard in the past 3 years.
B‐20

Spokane, Greenbluff ‐ SLAMS

AQS # 530630046         Method code: 056

Address: E. 9814 Greenbluff Road, Spokane    LAT/LONG: 047 49' 37" / 117 16' 31"

Monitoring objective: Unknown       MSA: Spokane, WA

Comments

Greenbluff is an urban scale site established in 1990 and located in near Spokane.  The site is used in

conjunction with the Cheney site to identify ozone patterns for the Spokane area.  It is a CFR‐required

site due to population size.

Exceedences

This site has not exceeded the 8‐hour ozone standard in the past 3 years.

4.3 Nitrogen Dioxide (NO2, 42602)

National Ambient Air Quality Standards (NAAQS):

 Annual arithmetic average concentration not to exceed 0.053 ppm at any monitoring site. 

Washington no longer monitors nitrogen dioxide.

Table 6: Nitrogen Dioxide, 42602

AQS# Site name Est.   Type Scale Sampling

Freq.

Action for 2008

N/A N/A N/A N/A N/A N/A None

Additional Monitors: None

Recommendations/Proposed Modifications:   
B‐21

Nitrogen Dioxide (NO2)

4.4 Sulfur Dioxide (SO2, 42401)

National Ambient Air Quality Standards (NAAQS)

 Annual arithmetic average concentration not to exceed 0.03 ppm at any monitoring 

site. 

 24-hour average concentration not to exceed 0.14 ppm at any monitoring site. 

 3-hour average concentration not to exceed 0.5 ppm at any monitoring site (secondary 

standard). 

Washington no longer monitors sulfur dioxide.

Table 7: Sulfur Dioxide, 42401

AQS# Site Name Est. Type Scale Sampling

freq.

Action for

2008

N/A N/A N/A N/A N/A N/A None

Additional Monitors: None

Recommendations/Proposed Modifications:   

Sulfur Dioxide (SO2)

4.5 Particulate Matter 10 (PM10, 81102)

National Ambient Air Quality Standard (NAAQS), 1987:
B‐22

 Twenty-four hour average PM10 concentration not to exceed 150 μg/m3 on more than 

one occasion per year when averaged over three years. 

 Due to a lack of evidence linking health problems to long-term exposure to coarse 

particle pollution, the EPA revoked the annual PM10 standard in 2006 (effective 

December 17, 2006). 

Washington’s PM10 monitoring network consists of 5 sites statewide, including one collocated site.

Table 8: Particulate Matter 10 (PM10, 81102)

AQS# Site Name Est. Type   Scale Sampling

Type

Action for

2008

530332004 Kent, James &

Central

5/87 SLAMS Neighborhood Continuous only Discontinued

530330057 Seattle, E Marginal

Way

8/71 SLAMS Neighborhood Continuous only Discontinued

530530031 Tacoma, Alexander

Ave

2/87 SLAMS   Neighborhood Continuous only Discontinued

530050002 Kennewick,

Metaline Ave

10/94 SLAMS Neighborhood Continuous only Continue

530770009 Yakima, S 4th 4/00 SLAMS Neighborhood 1/6 Continue

530650004 Colville, S Oak   11/96 SPMS Neighborhood Continuous only Continue

530710006 Burbank, Maple St 1/03 SPMS Middle Continuous only Continue

530630016 Spokane, Ferry St 4/72 SLAMS Middle Continuous &

1/6

Continue

both

530630016 Spokane, Ferry St 4/72 Collocated Middle Continuous &

1/12

Continue

both

Additional Monitors: None

Recommendations/Proposed Modifications: Kent, James & Central; Seattle, Marginal Way; and

Tacoma, Alexander Ave PM10 continuous devices were discontinued as of 12/31/2007. Continue all

other PM10 sites as described.
B‐23

Kennewick, Metaline Ave ‐ SLAMS

AQS # 530050002         Method code: 079

Address: 5929 West Metaline, Kennewick    LAT/LONG: 046 13' 06" / 119 12' 03"

Monitoring objective: Population Exposure    MSA: Richland‐Kennewick‐Pasco, WA

Comments

Metaline is a neighborhood scale site for PM10 established in 1994 and located in the downtown

Kennewick area.  It is representative of Kennewick which is subject to windblown dust.

Exceedences

This site has not exceeded the standard for PM10 in the past 3 years.   

Yakima, S 4th ‐ SLAMS

AQS # 530770009         Method code: 079/063

Address: 402 South 4th Avenue, Yakima     LAT/LONG: 046 35' 42" / 120 30' 44"

Monitoring objective: Population Exposure    MSA: Yakima, WA

Comments

S 4th is a neighborhood scale site for PM10 established in 2000 and located in a commercial/residential

area near downtown Yakima. The site is representative of the Yakima area which is a past PM10

nonattainment area.  

Exceedences

This site has not exceeded the daily or annual standard for PM10 in the past 3 years.

Colville, S Oak ‐ SLAMS

AQS # 530650004         Method code: 079

Address: 215 South Oak, Colville    LAT/LONG: 048 32' 41" / 122 54' 13"

Monitoring objective: Population Exposure    MSA: Not in an urban area

Comments
B‐24

S Oak is a neighborhood scale site for PM10 established in 1996 and located the commercial/residential

area of Colville.  

Exceedences

This site has not exceeded the standard for PM10 in the past 3 years.  

Burbank, Maple St ‐ SLAMS

AQS#530710006         Method code: 079/063

Address: 755 Maple Street, Burbank     LAT/LONG: 046 12' 00" / 119 00' 30"

Monitoring objective: Population Exposure    MSA: Not in an urban area

Comments

Maple St is a middle‐scale site for PM10 established in 2002 and located a residential area of Burbank.

The site is within the previous Wallula PM10 nonattainment area and subject to windblown dust.   

Exceedences

The Burbank/Wallula site has not exceeded the standard for PM10 in the past 3 years.

Spokane, Ferry St ‐ SLAMS

AQS # 530630016         Method code: 079/063

Address: E. 3530 Ferry Street, Spokane     LAT/LONG: 047 39' 39" / 117 21' 26"

Monitoring objective: Population Exposure    MSA: Spokane, WA

Comments

Ferry St is middle scale site for PM10 established in 1972 and located in a commercial area of Spokane.  

The site is representative of the Spokane area which is a past PM10 nonattainment area.

Exceedences

This site has not exceeded the standard for PM10 in the past 3 years.

Discontinued PM10 Sites
B‐25

Kent, James & Central ‐ SLAMS

AQS # 530332004         Method code: 079

Address: 614 Railroad Avenue N., Kent     LAT/LONG: 047 23' 10" / 122 13' 55"

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Seattle, E Marginal Way ‐ SLAMS

AQS # 530330057         Method code: 079

Address: 4752 East Marginal Way South, Seattle   LAT/LONG: 047 33' 31" / 122 20' 19"

Monitoring objective: Highest Concentration    MSA: Seattle‐Bellevue‐Everett, WA

Tacoma, Alexander Ave ‐ SLAMS  

AQS #530530031         Method code: 079  

Address:  2301 Alexander Avenue, Tacoma    LAT/LONG: 047 15' 56" / 122 23' 09"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

4.6 Particulate Matter 2.5 (PM2.5, 88101, 88502)

National Ambient Air Quality Standard (NAAQS):

 Twenty-four hour average PM2.5 concentrations not to exceed 35 μg/m3

 for a three-year 

average of annual 98th percentiles at any population-oriented monitoring site in a monitoring 

area. 

 Three-year annual average PM2.5 concentration not to exceed 15 μg/m3

 from a single 

community-oriented monitoring site or the spatial average of eligible community-oriented 

sites in a monitoring area. 

Washington’s PM2.5 monitoring network consists of thirty‐seven sites statewide, including two

collocated sites.
B‐26

Table 9: Particulate Matter (PM2.5, 88101, 88502)

AQS# Site Name Type Sample Type Sampling Freq. Action for

2008

530272002 Aberdeen Division St SLAMS Continuous Continuous Continue

530330037 Bellevue, Bellevue Way SLAMS Continuous Continuous Continue

530730015 Bellingham, Yew Street SLAMS Continuous Continuous Continue

530610020 Darrington, Fir St SLAMS SEQ/Continuous 1/3 Continue

530330023 Enumclaw, Mud Mountain

Dam

SLAMS Continuous Continuous Continue

530050002 Kennewick, Metaline Ave SLAMS Continuous Continuous Continue  

530332004 Kent, James & Central SLAMS Continuous Continuous Continue

530750005 LaCrosse, Hill St SLAMS Continuous Continuous Continue

530330024 Lake Forest Park, Ballinger

Way

SLAMS Continuous Continuous Continue

530150015 Longview, 30th Ave SLAMS Continuous Continuous Continue

530610005 Lynnwood, 212th SLAMS Continuous Continuous Continue

530611007 Marysville, 7th Ave SLAMS SEQ/Continuous 1/1 Continue

530090009 Shelton, Mt View Dr SLAMS Continuous Continuous Continue

530351005 Meadowdale, Blackbird Dr SLAMS Continuous Continuous Continue

530210002 Mesa, Pepoit Way SLAMS Continuous Continuous Continue

530251002 Moses Lake, Balsam St SLAMS Continuous Continuous Continue

530570014 Mt. Vernon, S Second St SLAMS Continuous Continuous Continue

530330017 North Bend, North Bend

Way

SLAMS Continuous Continuous Continue

530670013 Lacey, College St   SLAMS Continuous Continuous Continue

530090009 Port Angeles, W 14th St SLAMS Continuous Continuous Continue

530310003 Port Townsend, San Juan

Ave

SLAMS Continuous Continuous Continue

530750003 Pullman, Dexter Ave SLAMS Continuous Continuous Continue
B‐27

AQS# Site Name Type Sample Type Sampling Freq. Action for

2008

530531018 Puyallup, 128th St SLAMS Continuous Continuous Continue

530530028 Woodinville, 133rd Ave SLAMS Continuous Continuous Continue

530010003 Ritzville, Alder St SLAMS Continuous Continuous Continue

530750006 Rosalia, Josephine St SLAMS Continuous Continuous Continue

530330080 Seattle, Beacon Hill NAMS SEQ/Continuous 1/3 Continue

530330057 Seattle, E Marginal Way   SLAMS SEQ/Continuous 1/3 Continue

530330057 Seattle, E Marginal Way   Collocated SEQ 1/12 Continue

530330048 Seattle, Olive St SLAMS Continuous Continuous Continue

530630016 Spokane, Ferry St SLAMS SEQ/Continuous 1/3 Continue

530630016 Spokane, Ferry St Collocated SEQ 1/12 Continue

530630047 Spokane, Monroe Street SLAMS Continuous Continuous   Continue

530190001 Starbuck, 6th Ave SLAMS Continuous Continuous Continue

530530031 Tacoma, Alexander Ave SLAMS Continuous Continuous Continue

530530029 Tacoma, S L Street SLAMS SEQ/Continuous 1/3 Continue

530110013 Vancouver, 4th Plain SLAMS Continuous 1/1 Continue

530710005 Walla Walla, 12th St SLAMS Continuous Continuous Continue

530770009 Yakima, S 4th Ave SLAMS Continuous 1/3 Continue

Additional Monitors: None

Recommendations/Modifications: Seattle Beacon Hill FRM sampling frequency was reduced to 1/3.

Marysville FRM sampling frequency was increased to 1/1. Continue all other sites as described.
B‐28

PM2.5

Aberdeen, Division St ‐ SLAMS  

AQS #530272002         Method code: 771

Address:  359 North Division, Aberdeen     LAT/LONG: 046 58' 21" / 123 49' 54"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Not in an urban area

Comments

The Aberdeen site is neighborhood scale and meets criteria for a SLAMS site. The site represents

impacts to the Aberdeen and Grays Harbor area from wood burning and mobile sources.

Bellevue, Bellevue Way ‐ SLAMS  

AQS #530330037         Method code: 771

Address:  305 Bellevue Way, Bellevue     LAT/LONG: 047 36' 47" / 122 12' 06"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

The Bellevue Way site is neighborhood scale and is representative of mobile source and smoke impacts

in the area.

Bellingham, Yew Street ‐ SLAMS  

AQS #530730015         Method code: 771

Address:  2420 Yew Street, Bellingham     LAT/LONG: 048 45' 46" / 122 26' 25"

Sampling: Continuous correlated      

Monitoring objective: Population Exposure    MSA: Bellingham, WA

Comments
B‐29

Bellingham, Yew Street site is neighborhood scale and is impacted by wood burning and mobile sources

in the Bellingham/Whatcom County area.

Darrington, Fir St ‐ SLAMS  

AQS #530610020         Method code: 118/771

Address: 1085 Fir St, Darrington     LAT/LONG: 048 14' 49" / 121 36' 11"

Sampling: Continuous correlated, in progress

Monitoring objective: Population Exposure    MSA: Not in an urban area

Comments

Darrington is neighborhood scale residential site.  The primary monitoring objective is to characterize air

quality conditions impacting the town of Darrington and the nearby residents.  Special Purpose

Monitoring (SPM) conducted since 2004 has documented numerous exceedances of the 24 hour

NAAQS.   This site has an FRM and is suitable for comparison to the PM2.5 NAAQS.

Enumclaw, Mud Mountain Dam ‐ SLAMS  

AQS #530330023         Method code: 771

Address:  30525 SE Mud Mountain Rd, Enumclaw LAT/LONG: 047 08' 28" / 121 56' 09"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Enumclaw, Mud Mountain Dam is a neighborhood scale site which meets SLAMS criteria.  It is a

transport/background site for the Puget Sound.

Kennewick, Metaline Ave ‐ SLAMS  

AQS #530050002         Method code: 771

Address:  5929 W Metaline, Kennewick     LAT/LONG: 046 13' 06" / 119 12' 03"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Richland, Kennewick, Pasco, WA
B‐30

Comments

Kennewick is neighborhood scale and meets SLAMS criteria. The site is impacted from mobile sources

and is geographically representative of the Tri‐Cities area.

  

Kent, James & Central ‐ SLAMS  

AQS #530332004         Method code: 712/713

ADDRESS:  614 N Railroad, Kent     LAT/LONG: 047 23' 10" / 122 13' 55"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Kent is neighborhood scale site in the South Puget Sound that is impacted from mobile sources, light

industry, wood smoke.  The site is representative of the Kent Valley area.

LaCrosse, Hill St ‐ SLAMS  

AQS #530750005         Method code: 771

Address: 100 Hill Street, LaCrosse     LAT/LONG: 046 48' 55" / 117 52' 26"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Not in an urban area

Comments

LaCrosse is neighborhood scale small‐community monitor in Eastern Washington.  The site is impacted

by smoke and burning in the LaCrosse community.  The site provides valuable modeling and mapping

information.
B‐31

Lake Forest Park, Ballinger Way ‐ SLAMS  

AQS #530330024         Method code: 702/704

Address:  17171 Bothell Way NE, Lake Forest Park LAT/LONG: 047 45' 18" / 122 16' 50"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Lake Forest Park is neighborhood scale site is impacted by  wood smoke.

Longview, 30th Ave ‐ SLAMS  

AQS #530150015         Method code: 771

Address:  1324 30th Ave, Longview     LAT/LONG: 046 08' 22" / 122 57' 43"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Longview, WA

Comments

Longview is a neighborhood scale site which is impacted by mobile sources and wood smoke.  It is

representative of the Longview/Kelso area.

Lynnwood, 212th ‐ SLAMS  

AQS #530610005         Method code: 771

Address:  6120 212th SW, Lynnwood     LAT/LONG: 047 48' 23" / 122 19' 00"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Lynnwood is neighborhood scale site. The Lynnwood site is impacted by wood smoke.

Marysville, 7th Ave ‐ SLAMS  

AQS #530611007         Method code: 118/712/713
B‐32

Address:  1605 7th ST, Marysville     LAT/LONG: 048 03' 18" / 122 10' 33"

Sampling: 1/3 & continuous correlated

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Marysville is a neighborhood scale site impacted by wood smoke, mobile sources, and light industry.  It

is representative of the Marysville/North Snohomish County area.  The site has an FRM and is suitable

for comparison to the PM2.5 NAAQS.

Shelton, Mt View Dr ‐ SLAMS  

AQS #530450004         Method code: 771

Address:  901 Mt View Dr, Shelton     LAT/LONG: 047 13' 33" / 123 06' 53"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    UA: Not in an urban area

Comments

Shelton is a neighborhood scales site established in 2001.  Shelton is impacted by wood smoke.

Meadowdale, Blackbird Dr ‐ SLAMS  

AQS # 530351005         Method code: 771

Address: 7252 Blackbird Dr NE, Bremerton    LAT/LONG: 047 37' 51" / 122 38' 28"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Bremerton, WA

Comments

Meadowdale, Blackbird Dr is a middle‐neighborhood scale residential site.  It provides air quality

information to a population of 280,000 residents.
B‐33

Mesa, Pepoit Way ‐ SLAMS  

AQS #530210002         Method code: 771

Address:  200 Pepiot Way, Mesa    LAT/LONG: 046 34' 32" / 119 00' 25"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Richland, Kennewick, Pasco, WA

Comments

Mesa is a neighborhood scale small‐community site in Eastern Washington.  Mesa is impacted by smoke

from burning in the area.

Moses Lake, Balsam St ‐ SLAMS  

AQS #530251002         Method code: 771

Address:  412 S Balsam St, Moses Lake     LAT/LONG: 047 07' 50" / 119 16' 22"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Richland, Kennewick, Pasco, WA

Comments

Moses Lake is a neighborhood scale small‐community site in Eastern Washington. Moses Lake is

impacted by smoke from burning in the area.

Mt. Vernon, S Second St ‐ SLAMS  

AQS #530570015         Method code: 771

Address:  1600 South Second St, Mount Vernon    LAT/LONG: 048 24' 37" / 122 20' 16"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Not in an urban area

Comments

Mt. Vernon is a neighborhood scale small‐community site.  It is impacted by wood smoke. The

continuous monitor is representative of area.
B‐34

North Bend, North Bend Way ‐ SLAMS  

AQS #530330017         Method code: 771

Address:  42404 SE North Bend Way, North Bend LAT/LONG: 047 29' 23" / 121 46' 24"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

North Bend is a neighborhood scale transport/background PM2.5 site for the Puget Sound that is

impacted by wood smoke.

Lacey, College St ‐ SLAMS  

AQS #530670013         Method code: 771

Address:  1900 College St SE, Lacey     LAT/LONG: 047 01' 43" / 122 49' 15"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Olympia, WA

Comments

Lacey, College St is a neighborhood scale site that is impacted by wood smoke. The site is representative

of the Olympia/Thurston County area.

Port Angeles, W 14th St ‐ SLAMS  

AQS #530090009         Method code: 771

Address:  1139 W 14th St., Port Angles     LAT/LONG: 048 06' 59" / 123 27' 52"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    UA: Not in an urban area

Comments

Port Angeles is a neighborhood scale site adjacent to Olympic National Park, a Class 1 Area. Port Angeles

is impacted by smoke related activities.
B‐35

Port Townsend, San Juan Ave ‐ SLAMS  

AQS #530310003         Method code: 771

Address:  3939 San Juan Avenue, Port Townsend LAT/LONG: 048 07' 45" / 122 46' 46"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA:

Comments

Port Townsend is neighborhood scale and meets the criteria for a SLAMS site.  The site is impacted by

wood burning and is representative of the area.

Pullman, Dexter Ave ‐ SLAMS  

AQS #530750003         Method code: 771

Address:  240 SE Dexter, Pullman     LAT/LONG: 046 43' 28" / 117 10' 46"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    UA: Not in an urban area

Comments

Pullman is a neighborhood scale site is in Eastern Washington that is impacted by smoke from burning.    

Puyallup, 128th St ‐ SLAMS  

AQS #530531018         Method code: 771

Address:  9616 128th St E, Puyallup     LAT/LONG: 047 08' 24" / 122 18' 01"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Puyallup is a neighborhood scale site that is impacted by wood in the South Hill area.
B‐36

Ritzville, Alder St ‐ SLAMS  

AQS #530010003         Method code: 771

Address:  109 W Alder, Ritzville     LAT/LONG: 047 07' 43" / 118 22' 55"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    UA: Not in an urban area

Comments

Ritzville is a neighborhood scale small‐community located in Eastern Washington.  The site is impacted

by smoke from burning activities in the area.

Rosalia, Josephine St ‐ SLAMS  

AQS #530750006         Method code: 771

Address:  906 S Josephine Avenue, Rosalia    LAT/LONG: 047 13' 52" / 117 22' 08"

Sampling:  Continuous correlated  

Monitoring objective: Population Exposure    UA: Not in an urban area

Comments

Rosalia is a neighborhood scale small‐community site located in Eastern Washington.  It is impacted by

smoke from burning in the area.

Seattle, Beacon Hill ‐ NCore

AQS #530330080         Method code: 118/771/702/704

Address:  4103 Beacon Avenue S., Seattle    LAT/LONG: 047 34' 58" / 122 18' 30"

Sampling: 1/1 & correlated continuous

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Seattle, Beacon Hill is an urban scale NCORE site.

Seattle/Duwamish ‐ SLAMS  
B‐37

AQS #530330057         Method code: 118/771

Address:  4401 E Marginal Way S., Seattle    LAT/LONG: 047 33' 31" / 122 20' 19"

Sampling: 1/3 & correlated continuous

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Seattle, E Marginal Way is a neighborhood scale site located in the Duwamish River Valley.  It is

impacted by mobile and industrial sources.  This site is equipped with an FRM and is suitable for

comparison to the PM2.5 NAAQS.

Seattle, Olive St ‐ SLAMS  

AQS #530330048         Method code: 771

Address:  1624 Boren Avenue, Seattle       LAT/LONG: 047 36' 55" / 122 19' 48"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Seattle, Olive Street was established in 2002 as a micro scale PM2.5 site adjacent to Interstate 5 designed

to measure the effects of mobile source diesel emissions.  This site is not suitable for comparison to the

PM2.5 NAAQS.

Spokane, Ferry St ‐ SLAMS  

AQS #530630016         Method code: 118/702/704

Address:  E 3530 Ferry, Spokane     LAT/LONG: 047 39' 39" / 117 21' 26"

Sampling: 1/3 & continuous  

Monitoring objective: Population Exposure    MSA: Spokane, WA

Comments

Spokane, Ferry St is a neighborhood scale site impacted by wood smoke and light industrial sources.  

This site is equipped with an FRM and is suitable for comparison to the PM2.5 NAAQS.
B‐38

Spokane, Monroe Street ‐ SLAMS  

AQS #530630047         Method code: 771

Address:  N 4601 Monroe St., Spokane     LAT/LONG: 047 42' 03" / 117 25' 30"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Spokane, WA

Comments

Spokane, Monroe Street is a neighborhood scale site that meets SLAMS designation criteria.  It is

impacted by wood smoke and is representative of the area.

Starbuck, 6th Ave‐ SLAMS  

AQS # 530130001         Method code: 771

Address:  6th & Tucannon Road, Starbuck    LAT/LONG: 046 31' 05" / 118 07' 36"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    UA: Not in an urban area

Comments

Starbuck is a neighborhood scale small‐community site located in Eastern Washington that is impacted

by smoke from burning activities in the area.

Tacoma, Alexander Ave ‐ SLAMS  

AQS #530530031         Method code: 771  

Address:  2301 Alexander Avenue, Tacoma    LAT/LONG: 047 15' 56" / 122 23' 09"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Tacoma, Alexander Ave is a neighborhood scale site impacted by wood smoke and industrial point

sources on the Tacoma tideflats.  The site is representative of the NE Tacoma/Fife area.
B‐39

Tacoma, S L St ‐   SLAMS  

AQS #530530029         Method code: 118/712/713

Address:  7802 South L St., Tacoma     LAT/LONG: 047 11' 11" / 122 27' 06"

Sampling: 1/3 & continuous correlated

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Tacoma, L Street is a neighborhood scale site impacted by wood smoke sources.  This site is equipped

with an FRM and is suitable for comparison to the PM2.5 NAAQS.

Vancouver, 4th Plain ‐ SLAMS  

AQS #530110013         Method code: 118/771

Address:  8205 E 4th Plain Boulevard, Vancouver LAT/LONG: 045 38' 55" / 122 35' 16"

Sampling: Continuous correlated

Monitoring objective: Population Exposure    MSA: Portland‐Vancouver, OR‐WA

Comments

Vancouver, 4th Plain is a neighborhood scale site impacted by wood smoke sources.  The site is equipped

with an FRM and is suitable for comparison to the PM2.5 NAAQS.

Walla Walla, 12th St ‐ SLAMS  

AQS #530710005         Method code: 771

Address:  200 S 12th, Walla‐Walla     LAT/LONG: 046 03' 32" / 118 21' 06"  

Sampling: Continuous correlated

Monitoring objective: Population Exposure    UA: Not in an urban area

Comments

Walla Walla is a neighborhood scale small‐community site located in Eastern Washington.  It is impacted

by smoke from burning activities in the area.
B‐40

Woodinville, 133rd Ave‐ SLAMS  

AQS #530330028         Method code: 771

Address:  17401 133rd Avenue NE, Woodinville    LAT/LONG: 47.754/‐122.161

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Seattle‐Bellevue‐Everett, WA

Comments

Woodinville is a neighborhood scale site impacted by area wood smoke.

Yakima, S 4th Ave ‐ SLAMS  

AQS #530770009         Method code: 118/771

Address:  402 South 4th Avenue, Yakima    LAT/LONG: 046 35' 42" / 120 30' 44"

Sampling: Continuous correlated  

Monitoring objective: Population Exposure    MSA: Yakima, WA

Comments

Yakima is a neighborhood scale site impacted by smoke from burning sources in the area. The site is

equipped with an FRM and is suitable for comparison to the PM2.5 NAAQS.

4.7 PM2.5	‐	Other

Wenatchee, Alaska Way ‐ SLAMS  

AQS # 530070006         Method code: 771

Address: 600 Alaska Street, Wenatchee     LAT/LONG: 047 25' 06" / 120 19' 14"

Sampling: Continuous

Monitoring objective: Population Exposure    UA: Not in an urban area

Comments
B‐41

Wenatchee, Alaska Way is a neighborhood scale site established in 1994 as a PM10 site.  It is located in a

residential area of Wenatchee that is impacted by wood smoke.  The nephelometer at Wenatchee was

correlated with an FRM since the last network report and is now reporting near‐real‐time PM2.5.  

Ellensburg, Ruby St ‐ SLAMS  

AQS # 530370002         Method code: 771

Address: 201 North Ruby Street, Ellensburg     LAT/LONG: 046 59' 37" / 120 32' 42"

Sampling: Continuous

Monitoring objective: Population Exposure    MSA: Not in an urban area

Comments

Ellensburg is a neighborhood scale site established in 1995 as a PM10 site.  It is located in a residential

area of Ellensburg impacted by wood smoke.  The nephelometer at Ellensburg was correlated with an

FRM since the last network report and is now reporting near‐real‐time PM2.5.  

Clarkston,	STP	–	SLAMS	

AQS # 530030004         Method code: 771

Address: 13th Street and Port Way, Clarkston    LAT/LONG: 046 25' 32”/ 117 3' 35”

Sampling: Continuous

Monitoring objective: Population Exposure    UA: Not in an urban area

Comments

Clarkston is a neighborhood scale site established in 1993 as a PM10 site.  It is located in a

mixed/residential area of Clarkston.  With placement of an FRM, this site is suitable for comparison to

the PM2.5 NAAQS.  The nephelometer was correlated with an FRM since the last network report and is

now reporting near‐real‐time PM2.5.  

4.7.1 Other – Contracted Sites USFS

Chelan,	Woodin	Ave	

AQS#530070007‐	USFS		 	 	 Method code: 771

Address: 428 W. Woodin Avenue, Chelan	 	 LAT/LONG: 047 50' 18” / 120

01' 23”
B‐42

Sampling: Continuous		 	 	 	 	 	 	 	 	

	 	

Monitoring objective: Other

Leavenworth,	Evans	St	

AQS#530070010‐	USFS		 	 	 Method code: 771

Address: 330 Evans Street, Leavenworth	 	 LAT/LONG: 047 35' 56”		/ 120

39' 53”

Sampling: Continuous		 	 	 	 	 	 	 	 	

	 	

Monitoring objective: Other

Twisp,	Glover	St	

AQS#53047009‐	USFS		 	 	 Method code: 771

Address: 118 South Glover Street, Twisp	 	 LAT/LONG: 48° 21' 51” / 120

12' 40”

Sampling: Continuous		 	 	 	 	 	 	 	 	

	 	

Monitoring objective: Other

Naches,	Hwy	12	

AQS#530770007‐	USFS		 	 	 Method code: 771

Address: 10237 Hwy 12, Naches		 	 LAT/LONG: 046 43' 47” / 120

42' 13”

Sampling: Continuous		 	 	 	 	 	 	 	 	

	 	

Monitoring objective: Other

Winthrop,	W	Chewuch	Rd	

AQS#530470010‐FS		 	 	 	 Method code: 771

Address: 24 West Chewuch Road, Winthrop		 LAT/LONG: 048 28' 38” / 120

11' 26”

Sampling: Continuous		 	 	 	 	 	 	 	 	

	 	

Monitoring objective: Other

4.7.2 Other – Contracted Sites Tribal/EPA

Toppenish,	Ward	Rd	(Yakama)	

AQS#530770015		 	 	 	 Method code: 771

Address: 141 Ward Road, Toppenish		 	 LAT/LONG: 046 23’ 07” / 120

18' 49”

Sampling: Continuous		 	 	 	 Monitoring objective: Other

Oakville,	Howanut	Dr	(Chehalis)	

AQS#530270008		 	 	 	 Method code: 771
B‐43

Address: 252 Howanut Drive, Oakville	 	 LAT/LONG: 046 49' 23” / 123

09' 40"		

Sampling: Continuous		 	 	 	 Monitoring objective: Other

Skokomish,	Tribal	Center	Rd	(Skokomish)	

AQS#530450006		 	 	 	 Method code: 771

Address: N. 533 Tribal Center Road, SheltonLAT/LONG: 047 19' 33” / 123 09' 01”

Sampling: Continuous		 	 	 	 Monitoring objective: Other

Usk,	LeClerc	Rd	N	(Kalispel)	

AQS# 530510007		 	 	 	 Method code: 771

Address: 1981 LeClerc Road North,		 Usk	 	 LAT/LONG: 048 20' 45” / 117

16' 20”

Sampling: Continuous		 	 	 	 Monitoring objective: Other

Wellpinit,	Ford‐Wellpinit	Rd	(Spokane)	

AQS#530650002		 	 	 	 Method code: 702/704

Address: 5298 Ford‐Wellpinit Road, Wellpinit LAT/LONG: 047 53' 19” / 117

59' 19”

Sampling: Continuous		 	 	 	 Monitoring objective: Other

Neah	Bay,	(Makah)	

AQS#53000914		 	 	 	 Method code: 771

Address: 159 Waada View, Neah Bay	 	 LAT/LONG: 048 22' 19” / 124 35' 43”

Sampling: Continuous		 	 	 	 Monitoring objective: Other

Taholah,	Chitwhin	Dr	(Quinault)	

AQS#530270009		 	 	 	 Method code: 771

Address: 600 Chitwin Drive, Taholah	 	 LAT/LONG: 047 20' 37” / 124 17' 13”

Sampling: Continuous		 	 	 	 Monitoring objective: Other

Puyallup,	66th	Ave	(Puyallup)		

AQS#530530022		 	 	 	 	 Method code: 771

Address: 5722 66th Avenue E. Puyallup	 	 LAT/LONG: 047 12' 19” / 122

20' 19”

Sampling: Continuous		 	 	 	 Monitoring objective: Other

4.7.3 Other Contracted Local Air Agencies

Cheeka	Peak	(Olympic	Region	Clean	Air	Agency)	

AQS#530090013		 	 	 	 Method code: 771, 056,		

Address: Cheeka Peak, Jefferson County	 	 LAT/LONG: 048 17’ 12”/ 124

37' 13”			

Sampling: Continuous		 	 	 	 Monitoring objective: Other

Port	of	Vancouver	(Southwest	Clean	Air	Agency)	
B‐44

AQS#530110018		 	 	 	 	 Method code: 050,040

Address: 6305 NW Old Lower River Rd, Vancouver	 	 	 	 	

							 LAT/LONG:		045 39’ 01’/ 122 44' 24”

Sampling: Continuous		 	 	 	 Monitoring objective: Other

4.8 Trace Gas Monitoring

NCore – Precursor Gas & Multi‐Pollutant Monitoring – From an emission source perspective, multiple

pollutants and their precursors are released simultaneously (e.g., a combustion plume with nitrogen,

carbon, hydrocarbon, mercury, sulfur gases, and particulate matter).  Meteorological processes that

shape pollutant movement, atmospheric transformations, and removal act on all pollutants.  Numerous

chemical and physical interactions underlie the dynamics of particle and ozone formation and the

adherence of air toxics on surfaces of particles.   

Overwhelming programmatic and scientific interactions across pollutants have demanded a movement

toward integrated air quality management.  Collocated air monitoring benefits health assessments and

emissions strategy development.  Health studies with access to multi‐pollutant data will be better

positioned to identify confounding effects of different pollutants, particularly when concentration,

composition, and population types are included.  Air quality models and source attribution methods

used for strategy development also benefit from the multi‐pollutant approach.  Modelers will be able to

perform more robust evaluations by checking performance on several variables to ensure the model

produces results for correct reasons and not through compensating errors.  As emission sources are

characterized by a multiplicity of pollutant releases, related source apportionment models yield more

conclusive results from use of multi‐pollutant measurements.  Multi‐pollutant measurements also

streamline monitoring operations and offer increased diagnostic capabilities to improve instrument

performance.   

The multi‐pollutant monitoring provided for these needs by starting to fill the measurement gaps that

have accumulated over the years.  The objective of this strategy is to provide for the following important

needs;

 Improved data flow and timely reporting to the public

 Future NAAQS compliance determinations and revisions

 Support for development of emissions strategies

 Assess effectiveness of air pollution control programs

 Data for scientific and health‐based studies.
B‐45

Seattle, Beacon Hill  

AQS #530330080

Address:  4103 Beacon Avenue S., Seattle    LAT/LONG: 047 34' 58" / 122 18' 30"

Monitoring objective: Special Studies     MSA: Seattle‐Bellevue‐Everett, WA

Comments

Seattle Beacon Hill is an urban scale site for carbon monoxide and ozone. Seattle Beacon Hill also

measures chemical speciated particulate matter, volatile organic air toxics, carbonyls and semi‐volatile

(PAH) toxics. In addition, data from this site supports the Particulate Research Center activities.

Cheeka	Peak	(ORCAA)	

AQS#530090013		 	 	 	 Method code: 771, 056,		

Address: Cheeka Peak, Jefferson County	 	 LAT/LONG: 048 17’ 12”/ 124

37' 13”			

Sampling: Continuous		 	 	 	 Monitoring objective: Other

Carbon Monoxide

Precursor or trace level Carbon monoxide is in operation at the Beacon Hill and Cheeka Peak sites.

Sulfur Dioxide

Precursor or trace level sulfur dioxide is in operation at the Beacon Hill and Cheeka Peak sites.

Reactive Nitrogen Compounds

Precursor or trace level NOy is in operation at the Beacon Hill and Cheeka Peak sites.

4.9 Toxics/Speciation Monitoring

Toxics

Collocated National Air Toxics Trend Site (NATTS) ‐ In addition to the STN and NCore Precursor Gas

Monitoring Programs currently underway, Beacon Hill is also a designated National Air Toxics Trend Site

(NATTS).  The primary objectives of Washington’s National Air Toxics Trends Site Monitoring Program 

include but are not limited to: 

 Provide long-term air toxic monitoring data in order to establish and track trends.
B‐46

 Evaluate the air toxic program’s progress by characterizing air toxics concentrations, and

determining their spatial and temporal differences between cities and regions over time.

 Provide representative air toxic data to support exposure assessments (i.e. determine health

risks).

 Determine where air toxics emissions come from (source apportionment).

 Provide air toxic data for evaluating modeling results that are used for exposure

assessments.

 Assess the effectiveness of the air toxic program’s emission reduction and control strategies.

Seattle, Beacon Hill

AQS #530330080         Method code: 593/560/574

Address:  4103 Beacon Avenue S., Seattle    LAT/LONG: 047 34' 58" / 122 18' 30"

Monitoring objective: Special Studies     MSA: Seattle‐Bellevue‐Everett, WA

Comments

Seattle Beacon Hill is a designated National Air Toxics Trends Site (NATTS).  Seattle Beacon Hill

monitoring station was nominated by the National Air Toxics Committee and chosen by EPA

headquarters to represent urban scale air toxics in the Pacific Northwest.  As part of NATTS designation

the site was selected to receive continuing funding for long‐term air toxics monitoring.  It is currently the

only designated urban scale NATTS located in the Pacific Northwest.

Speciation

National Speciation Trends Network (STN) ‐ The PM2.5 Chemical Speciation Program continues to have a

significant role in the new Monitoring Strategy.  Washington’s STN site is located at Jefferson Park on

Beacon Hill in Seattle.  The primary goal of the PM2.5 speciation monitoring is to:

 Provide long‐term data in order to establish and track tends.

 Determine the spatial and temporal differences of PM2.5 composition between cities and

regions over time.

 Provide representative PM2.5 speciation data to support exposure assessments (i.e. determine

health risks).

 Determine where PM2.5 emissions come from (source apportionment).

 Evaluate modeling results that are used for exposure assessments.

 Assess the effectiveness of the program’s emission reduction and control strategies.

Seattle, Beacon Hill
B‐47

AQS #530330080         Method code:  

Address:  4103 Beacon Avenue S., Seattle    LAT/LONG: 047 34' 58" / 122 18' 30"

Monitoring objective: Special Studies     MSA: Seattle‐Bellevue‐Everett, WA

Supplemental Speciation Sites ‐ In addition to the Beacon Hill STN site, the State operates four

supplemental speciation sites.  These supplemental sites are located at:

Spokane, Ferry St (SCRAA)

AQS #530630016         Method code:

Address:  E 3530 Ferry, Spokane     LAT/LONG: 047 39' 39" / 117 21' 26"

Monitoring objective: Special Studies     MSA: Spokane, WA

Tacoma, L Street (PSCAA)   

AQS #530530029         Method code:

Address:  7802 South L St., Tacoma     LAT/LONG: 047 11' 11" / 122 27' 06"

Monitoring objective: Special Studies     MSA: Seattle‐Bellevue‐Everett, WA

Vancouver, 4th Plain (SWCAA)

AQS #530110013         Method code:  

Address:  8205 E 4th Plain Boulevard, Vancouver LAT/LONG: 045 38' 55" / 122 35' 16"

Monitoring objective: Special Studies     MSA: Portland‐Vancouver, OR‐WA   

Yakima, S 4th (YRCAA)

AQS #530770009         Method code:  

Address:  402 South 4th Avenue, Yakima    LAT/LONG: 046 35' 42" / 120 30' 44"

Monitoring objective: Population Exposure    MSA: Yakima, WA
B‐48

5 References

1. Code of Federal Regulations, Title 40, Part 58, Appendix A,B,C,D,E, U.S. Government 

Printing Office, 1999. 

2.   Code of Federal Regulations, Title 40, Part 50, U.S. Government Printing Office, 1999.

3. Code of Federal Regulations, Title 40, Part 53, U.S. Government Printing Office, 1999.

4. Code of Federal Regulations, Title 40, Part 58, U.S. Government Printing Office, 1999.

5. U.S. EPA, Revised Requirements for Designation of Reference and Equivalent Methods for

PM2.5 and Ambient Air Quality Surveillance for Particulate Matter ‐Final Rule.  40 CFR

Parts 53 and 58.  Federal Register, 62(138):38763‐38853.  July 18, 1997.

6. Guidance for Network Design and Optimum Site Exposure for PM2.5 and PM10, J.G.

Watson, et. Al., U.S. EPA/OAQPS, December 15, 1997.

7. SLAMS/NAMS/PAMS Network Review Guidance, EPA‐454/R‐98‐003, March 1998.

8. Ambient Monitoring Guidelines for Prevention of Significant Deterioration (PSD), EPA‐

450/4‐87‐007, May 1987.

9. Guideline on Ozone Monitoring Site Selection, EPA‐454/R‐98‐002, August 1998.
B‐49
C‐1

Appendix C

Emission Inventory Documentation

C. Emission Categories

Ecology developed an inventory of annual and winter weekday PM10 emissions estimates for the LMP.  

For this LMP, the seven sources in the original 1994 plan were inventoried, but were reorganized as

described in Table C.1 and Table C.2.  The seven sources are: Residential Wood Combustion, Paved Road

Dust, Unpaved Road Dust, Onroad Mobile, Port and Marine, Locomotives, and Industrial.  Other

categories inventoried in the original maintenance plan were deemed insignificant, and were not

inventoried.

Table C.1: List of 2011 Emission Categories

2011 Emission Categories

Onroad Mobile

Residential Wood Combustion

Port and Marine

Locomotives

Paved Road Dust

Unpaved Road Dust

Industrial

Table C.2: 1994 emission categories with their respective 2011 representative emission category

1994 Emissions Categories 2011 Representative Emission Categories

Gasoline Exhaust Onroad Mobile

Diesel Exhaust Port and Marine, Onroad Mobile

Ships Port and Marine

Locomotives Locomotives

Wood Burning Residential Wood Combustion

Road Dust Paved Road Dust, Unpaved Road Dust

Allowable Industrial Industrial
C‐2

Ecology’s draft 2011 triennial emissions inventory (2011 EI) was used for all categories except industrial

emissions, where actual emissions submitted to PSCAA and Ecology were used.

Fugitive dust emissions from coal trains were estimated and are included in the total locomotive

emissions category.

Other sources are deemed insignificant, including outdoor burning, construction dust, secondary

particulate matter, aircraft emissions, wildfires, cigarette smoke, and commercial charbroiling.  Outdoor

burning is prohibited in the three maintenance areas, so emissions would be minimal.  Neither Ecology

nor PSCAA have local information on emissions for construction dust, cigarette smoke, or commercial

charbroiling, but they are assumed to be minimal in these areas.  Smoke from wildfires in Puget Sound is

rare and was considered negligible.  Some of these values are included in the 2011 NEI, however the

emission estimates have large uncertainties because the data was collected nationally and was not

developed specifically for local areas, or for sub‐county regions like the Seattle, Tacoma, and Kent

Maintenance Areas.

Method for Emission Estimates

All the non‐industrial source emissions were estimated by multiplying an activity level, such as wood

combusted or Vehicle Miles Traveled (VMT), by an emission factor in mass per activity.

Emissions = Activity level x Emission FactorSpatial Allocation Methods

Spatial surrogates were used to approximate emissions inside the maintenance areas from county data.  

For sources without specific coordinates, spatial surrogates were used to approximate both the location

and magnitude of the emissions.  Maintenance areas (MA) emissions are estimated as:

EMA = ECounty * SurrogateMA / SurrogateCounty

Where EMA = emissions in the maintenance area, ECounty = emissions in county,  

SurrogateMA = surrogate activity in the maintenance area, and SurrogateCounty = surrogate activity in

county.

The spatial surrogates and data sources used are shown in Table C.3 below.

   
C‐3

Table C.3: Spatial surrogate and sources of data for sub‐county region (maintenance area) estimates

Emission Category Spatial Surrogate Source

Onroad Mobile

Percent of VMT within the maintenance area vs.

the county

Puget Sound Regional Council

Estimates

Residential Wood

Combustion

Percent of households within the maintenance

area vs. the county

Puget Sound Regional Council

Estimates

Port and Marine

Percent of Port of Seattle and Tacoma area within

the maintenance area

2011 Draft Ecology EI (from 2011

Puget Sound Marine Emission

Inventory)

Locomotives

Rail yards: N/A ‐‐‐ used entire county

Passenger rail: used proportion of county rail that

goes through the maintenance area

Fugitive dust from coal trains: used proportion of

rail within the maintenance area vs. the entire

route from the Powder River coal basin

Line haul: used the actual rail segments in the

maintenance area and then applied activity

information

2011 Draft Ecology EI

Paved Road Dust

Percent of VMT within the maintenance area vs.

the county

Puget Sound Regional Council

Estimates

Unpaved Road Dust

Percent of VMT within the maintenance area vs.

the county

Puget Sound Regional Council

Estimates

Industrial N/A ‐‐‐ source coordinates were used

Source Emission Data Reported to

PSCAA and Ecology

Temporal Allocation Methods

The 2011 EI estimates were available as annual and winter season emissions for King and Pierce County.  

These estimates were temporally allocated to a winter weekday, and spatially allocated to the

maintenance areas as described below.

Annual emissions data were adjusted to tons per average winter day for the maintenance area for each

source category.  Methods for each category are described below.

   
C‐4

Residential Wood Combustion

Residential wood combustion (RWC) emissions are based on Ecology’s draft 2011 Emission Inventory.  

RWC consists of home heating and recreational use of woodstoves, fireplaces, fireplace inserts and

central furnaces.  Activity parameters for the 2011 EI include the type of wood burning devices [certified

(catalytic and noncatalytic) woodstoves, uncertified woodstoves and fireplaces], the amount and species

of wood burned from each device and seasonal, daily and hourly usage rates.  Most of this information

was obtained through the 2007 National Research Center Survey.1

  Emission factors were taken from AP

42, the 2002 NEI, and the particulate matter size distribution from the California Air Resources Board

(CARB).

Wood burning devices include central furnaces, fireplaces, pellet stoves, and certified and uncertified

woodstoves and inserts.  Close to three quarters of all wood burning devices in the state are fireplaces

or uncertified woodstoves and inserts.  

For residential wood combustion, seasonal activity fractions from the NRC survey were used to calculate

emissions for a winter day.1

  To quantify winter day emissions, the three month fraction (November,

December, January) of the annual emissions was 68%.  Then the emissions were further divided to a per

day (92 winter days in November, December, and January). Table C.4 shows county annual and winter

emissions by device type and by county.  Table C.5 shows the population data used for as the surrogate

to estimate emissions for the maintenance area.  Table C.6 shows the final results.

   

                                                            

1 Puget Sound Clean Air Agency Indoor Wood‐burning Emission Inventory Survey of King, Kitsap, Pierce and Snohomish

Counties, Report of Results, Prepared by National Research Center, Inc., 3005 30th Street, Boulder, CO 80301, November 2007.
C‐5

Table C.4: Tons of PM10 by wood burning device, King and Pierce County

Device King County Pierce County

Annual tons Winter tons Annual tons Winter tons

Fireplace: general 2,176 1,480 358 244

Woodstove: fireplace inserts; non‐EPA

certified

596 405 250 170

Woodstove: fireplace inserts; EPA

certified; non‐catalytic

205 139 155 105

Woodstove: fireplace inserts; EPA

certified; catalytic

71 48 54 36

Woodstove: freestanding, non‐EPA

certified

601 409 341 232

Woodstove: freestanding, EPA certified,

non‐catalytic

206 140 211 144

Woodstove: freestanding, EPA certified,

catalytic

72 49 73 50

Woodstove: pellet‐fired, general 15 10 6 4

Other: All Combustor Types 51 35 23 15

Total 3,993 2,715 1,470 1,000

Source: 2011 Draft Ecology EI

Table C.5: PM10 Maintenance Area Population Data

Area Name Area Population County Population Fraction of County

Kent 16,841 1,931,249 0.00872

Seattle 8,216 1,931,249 0.00425

Tacoma 3,594 795,225 0.00452

Source: PSRC 2011
C‐6

Table C.6: Tons of PM10 by wood burning device in each maintenance area:

Device Kent Seattle Tacoma

   Annual

tons

Winter

tons

Tons/

winter

day

Annual

tons

Winter

tons

Tons/

winter

day

Annual

tons

Winter

tons

Tons/

winter

day

Fireplace: general 19.0 12.9 0.14 9.2 6.3 0.07 1.6 1.1 0.01

Woodstove: fireplace inserts; non‐

EPA certified

5.2 3.5 0.04 2.5 1.7 0.02 1.1 0.8 0.01

Woodstove: fireplace inserts; EPA

certified; non‐catalytic

1.8 1.2 0.01 0.9 0.6 0.01 0.7 0.5 0.01

Woodstove: fireplace inserts; EPA

certified; catalytic

0.6 0.4 0.00 0.3 0.2 0.00 0.2 0.2 0.00

Woodstove: freestanding, non‐EPA

certified

5.2 3.6 0.04 2.6 1.7 0.02 1.5 1.0 0.01

Woodstove: freestanding, EPA

certified, non‐catalytic

1.8 1.2 0.01 0.9 0.6 0.01 1.0 0.7 0.01

Woodstove: freestanding, EPA

certified, catalytic

0.6 0.4 0.00 0.3 0.2 0.00 0.3 0.2 0.00

Woodstove: pellet‐fired, general 0.1 0.1 0.00 0.1 0.0 0.00 0.0 0.0 0.00

Other: All Combustor Types 0.4 0.3 0.00 0.2 0.1 0.00 0.1 0.1 0.00

Total 34.8 23.7 0.26 17.0 11.5 0.13 6.6 4.5 0.05

   
C‐7

Paved Road Dust

Dust emissions are generated as vehicles pass along paved roadways and disturb the layer of loose

material on or near the road surface.  This material contains particulate matter from soil, brake and tire

wear, exhaust, and other substances.  The paved road dust calculation excludes emissions from exhaust

and brake and tire wear.  These vehicle emissions are estimated as on‐road mobile sources emissions.  

VMT on unpaved roads was estimated using data from the County Road Administration Board (CRAB)

and WSDOT.  The Road Dust equations in AP‐42 were used to calculate emission factors. The measures

of activity and spatial allocation will be based on VMT in the maintenance areas. Temporal allocation is

identical to the on‐road category, which was defined as December, January, and February.  Table C.7

shows the fraction of the total county VMT within the maintenance area and respective PM10 emissions.

Table C.7: Paved road dust PM10 emissions with the fraction of the maintenance areas

vehicle miles traveled

King County Emissions, in Tons Maintenance Area

Emissions, in Tons

Maintenance

Area Annual Winter Days /

winter

Tons /

winter

day

Maintenance

Area Fraction Annual

Tons /

winter

day

Seattle 3522.2 875.9 90 9.73 0.0540 190.1 0.525

Kent 3522.2 875.9 90 9.73 0.0116 40.9 0.113

Tacoma 1329.4 333.6 90 3.71 0.0787 104.6 0.292

Onroad Mobile Sources

On‐road mobile source emissions are those generated by operating vehicles on public roadways.  The

LMP Emission Inventory will be based on Ecology’s “Washington State Base Year 2011 County

Inventories.” Winter day emissions were estimated for each county using EPA’s Motor Vehicle Emission

Simulator (MOVES) model version 2010b, using a combination of default and local data as input

parameters.  Total PM10 emissions included primary PM10 from running exhaust and start exhaust, as

well as brakewear and tirewear particulate.

The number of vehicle miles traveled (VMT) are used in MOVES.  The MOVES input files require

summations of VMT statistics by several different road and vehicle classifications, which were developed

using national Department of Transportation’s Highway Performance Monitoring System (HPMS) as

obtained from the Washington State Department of Transportation (WSDOT). HPMS is a system of

traffic counts collected over several urban and rural sampling areas. WSDOT makes estimates of county

VMT by roadway (functional) classifications.
C‐8

Fleet characteristics, including vehicle population and age distribution, were derived from local data.

Registration data from the Washington Department of Licensing (DOL) was supplemented with transit

and intercity bus data from the Federal Transit Administration (FTA) and public school bus data from the

Washington State Office of the Superintendent of Public Instruction (OSPI).  

MOVES defaults were used for gasoline and diesel fuel parameters, which reflect current regulations

regarding sulfur content and Reid vapor pressure. All transit buses in Pierce County were assumed to

operate using compressed natural gas (CNG).

MOVES defaults were used for meteorological data. MOVES defaults are based on historical

meteorological observations from local monitors for each county.

All input parameters are described in Section 3.1 of the 2011 EI. The model parameters and data sources

are summarized in Table C.8 below.
C‐9

Table C.8: MOVES Model Parameters and Data Sources

Parameter Data Source

County vehicle population Washington State Department of Licensing (DOL),

Federal Transit Administration (FTA), Washington State

Office of the Superintendent of Public Instruction

(OSPI)

County VMT Department of Transportation’s Highway Performance

Monitoring System (HPMS) obtained from the

Washington State Department of Transportation

(WSDOT)

Temporal allocation to month and day of week WSDOT

Vehicle age distribution DOL, FTA, OSPI

Average speed distribution MOVES defaults

Road type distribution HPMS obtained from WSDOT

Fuel supply and formulation MOVES defaults

Meteorology data MOVES defaults

Winter emissions were allocated for December, January, and February.

Table C.9 shows the fraction of the total county VMT within the maintenance area and respective PM10

emissions.
C‐10

Table C.9: Onroad mobile PM10 emissions with the fraction of the maintenance areas vehicle

miles traveled

King County Emissions, in Tons Maintenance Area

Emissions, in Tons

Maintenance

Area Annual Winter Days /

winter

Tons /

winter

day

Maintenance

Area Fraction Annual

Tons /

winter

day

Seattle 1868.1 475.7 90 5.29 0.0540 100.8 0.285

Kent 1868.1 475.7 90 5.29 0.0116 21.7 0.061

Tacoma 761.52 198.27 90 2.20 0.0787 59.9 0.173

   
C‐11

Unpaved Road Dust

Similar to paved roads, dust emissions are generated as vehicles pass along unpaved roadways and

disturb the layer of loose material on or near the road surface.  This material contains particulate matter

from soil, brake and tire wear, exhaust, and other substances.   

The unpaved road dust calculation excludes emissions from exhaust and brake and tire wear since they

are estimated as on‐road mobile sources emissions. The unpaved road dust estimate assumes a dry day,

when you would have the highest potential of dust emissions and highest potential contribution to a

high PM10 event.  Additionally, this estimate assumes uniform unpaved roads and uniform traffic volume

in the maintenance area as outside the maintenance area.  This result could be an overestimate, as

there is a higher unpaved road density outside the maintenance areas.

The Road Dust equations in AP‐42 were used to calculate emission factors2

.  Winter emissions were

allocated for December, January, and February. Table C.10 shows the fraction of the total county VMT

within the maintenance area and respective PM10 emissions.

Table C.10: Unpaved road dust PM10 emissions with the fraction of the maintenance areas

vehicle miles traveled

King County Emissions, in Tons Maintenance Area

Emissions, in Tons

Maintenance

Area Annual Winter Days /

winter

Tons /

winter

day

Maintenance

Area Fraction Annual

Tons /

winter

day

Seattle 2474.6 1091.4 90 12.13 0.0540 133.6 0.655

Kent 2474.6 1091.4 90 12.13 0.0116 28.7 0.141

Tacoma 295.7 130.4 90 1.45 0.0787 23.3 0.114

   

                                                            

2 US EPA, AP 4 Compilation of Air Pollutant Emission Factors, http://www.epa.gov/ttn/chief/ap42/index.html
C‐12

Port and Marine

To estimate port and marine activity, the 2011 Ecology Emission Inventory used the 2011 inventory

prepared for the Puget Sound Maritime Air Forum by Starcrest Consulting Group, LLC.3 The inventory is

a bottom‐up, activity‐based emissions inventory which provides detailed information on the five major

source categories associated with the marine activities: ocean‐going vessels, harbor vessels, cargo

handling equipment, on‐road heavy‐duty vehicles, and rail operations.  It was an update to a similar

inventory prepared by Starcrest for the 2005 inventory. Activity level and emission rates are described in

the source inventory documentation.

Port and marine emissions were multiplied by the fraction within the maintenance area.  Table C.11

shows the fractions of the port areas within the maintenance areas.  For winter day estimates, the

emissions were assumed to be uniform throughout the year.  Table C.12 shows the annual emissions.  The

Kent maintenance area has no port or marine activities to estimate.   

Table C.11: Fraction of Port Areas in Maintenance Areas

Maintenance Area Fraction of Port Area Name of Port

Seattle 65% Port of Seattle

Tacoma 100% Port of Tacoma

Kent NA NA

                                                            

3  2011 Puget Sound Maritime Air Emissions Inventory.  Prepared by: Starcrest Consulting Group, LLC, Starcrest consulting

Group, LLC, Poulsbo, Washington 98370.  September 2012.
C‐13

Table C.12: PM10 emissions breakdown in tons of port and marine emissions within each

maintenance area by subcategory

Port and Marine Emission Category

Annual Emissions in

tons Tons/winter day

Seattle Maintenance Area    

Ocean‐going vessels hoteling 33.3 0.091

Harbor craft cruising 77.1 0.211

Off‐hwy diesel cargo handling equipment 10.77 0.030

Off‐hwy gas cargo handling equipment 0.001 0.000

Off‐hwy LPG cargo handling equipment 0.04 0.000

ARGO Railyard: Off‐highway Diesel /Construction &

Mining Equipt /Rubber Tire Loaders/Terminal

Tractors/Indust Equip

0.5 0.001

BNSF SIG Railyard: Off‐highway Diesel /Construction

& Mining Equipt /Rubber Tire Loaders/Terminal

Tractors/Forklifts

0.5 0.001

Seattle Total 122.2 0.334

   

Tacoma Maintenance Area    

Ocean‐going vessels hoteling 36.1 0.099

Harbor craft cruising 30.9 0.085

Off‐hwy diesel cargo handling equipment 10.0 0.027

Off‐hwy gas cargo handling equipment 0.01 0.000

Off‐hwy LPG cargo handling equipment 0.01 0.000

Tacoma Total 77.0 0.211

   
C‐14

Locomotives

Four types of locomotive emissions were estimated for the emission inventory.  These are listed in Table

C.13.

Table C.13: List of emission sources and methods used to estimate locomotive emissions

Emission Source Data Source Estimation method

Fugitive dust from

coal trains US Energy Information Administration Cope (2001) emission factor10

Rail yards BNSF and Union Pacific Used total county rail yard emissions

Line haul trains BNSF and Union Pacific

With rail segments within the

maintenance areas, used county activity

data from EPA shapefile

Passenger trains Amtrak

Proportion of county emissions with

length of rail through the maintenance

area

To estimate locomotive activity, the 2011 Ecology Emission Inventory used the emissions from Class I

line haul and switch yard locomotives using EPA guidance and other information.4

  U.S. Class I railroads

are line haul freight railroads with operating revenue in excess of $319.3 million (amount changes over

time).  Two Class I railroads operate in Washington: Burlington Northern Santa Fe Railway (BNSF) and

Union Pacific Railroad (UP).  Amtrak was also included in this inventory.  Class 2 and 3 railroad

locomotive emissions were not inventoried.  A special AIRQUEST (formerly Northwest Regional

Technical Center) project conducted by the Oregon Department of Environmental Quality (ODEQ) found

that emissions from Class 2 and 3 railroad locomotives were a small percentage of total locomotive

emissions.5,6

BNSF and UP provided activity and emissions information for 2011.   Amtrak provided passenger rail

activity information for 2011. Spatial surrogates for passenger rail were based on the length of rail in

each county.   

                                                            

4  Procedures for Emission Inventory Preparation, Vol. IV: Mobile Sources.  EPA‐450/4‐81‐026d (Revised), Section 6.0.  1992.

5  Regional Technical Center Demonstration Project: Summary Report.  Idaho Department of Environmental Quality, Oregon

Department of Environmental Quality, Washington Department of Ecology, US EPA Region 10, Washington State University,

University of Washington.  January 11, 2002 (draft).

6  Oregon 1996 Railroad Emissions Inventory Project, Emission Estimate Methodology Documentation.  Oregon Department of

Environmental Quality.  August 2001.
C‐15

Activity level is measured in gallons of diesel consumed by locomotives.  All of the railroads provided

county fuel use for line haul and switch yard locomotives for 2011.7 EPA rail activity shape fractions

were used to allocate emissions to the segments of rail within the maintenance areas.

The spatial surrogate for fugitive dust from coal trains was the length of the rail through the

maintenance area vs. the entire length of the route from the Powder Basin.

To quantify winter day emissions, locomotives were assumed to operate uniformly year‐round per EPA

guidance.8

   

                                                            

7 BNSF, UP and Amtrak Railway Company 2011 Estimation of Locomotive Emissions.  Email transmittal of information from

Kelly Harvey (BNSF), Michael Germer (UP), and Delia Ann Pfleckl (Amtrak) to Sarah Clouse Washington State Department of

Ecology.  March 2012.  County fuel use and emissions.

8 Procedures for the Preparation of Emission Inventories for Carbon Monoxide and Precursors of Ozone.  Volume II, table 6‐11.  

EPA‐454/R‐92‐026, March 1992.
C‐16

Estimate of fugitive dust from coal trains

Fugitive coal dust emissions from rail transport were estimated using the suggested approach described

by Cope and Bhattacharyya, 2001.9 The emission factor is described below:

Rail Coal Dust Emission Factor (kg dust/tonne of coal transported) = 0.1*(0.62*D)0.6*((365‐

P)/365)*(SD/D)*((100‐CE)/100)*SF

Where: D = total rail distance from origin to destination (km)

P = number of precipitation days

SD = segment distance through the maintenance area (km)

CE = coal dust control efficiency (i.e. surfactant efficiency)

SF = scaling factor from TSP to PM10

The reported tons of coal exported in 2011 that would have travelled through the maintenance areas

was 4,854,451.10 The proportional segment distances through the maintenance areas were calculated

through ArcGIS 9.3 and listed in Table C.14. Table C.14 shows the values for the variables above for each

maintenance area.

Table C.14: Values used in the rail coal dust emission factor equation

Variable Value Units Source

D 2414 km 10

P 177 days 2011 EI – KSEA

CE 21.25 (0 for 9 months, and then 85 for last 3 months of 2011 with

adopted surfactant requirement) % 10

SF 0.5 none 9

SD

3.80 – Kent

10.51 – Seattle

3.01 – Tacoma

km

Estimated with

GIS

                                                            

9 Cope, Douglas; Bhattacharyya Kamal. “A Study of Fugitive Coal Dust Emissions in Canada”, prepared for the Canadian Council

of Ministers of the Environment, 2001.

10 Kotchenruther, Robert. “Fugitive Dust from Coal Trains: Factors Effecting Emissions and Estimating PM2.5”, EPA Region 10,

Annual NW‐AIRQUEST Meeting, June 2013.
C‐17

Rail Yards

As rail yards are only reported by county, we can’t adequately separate the emissions from the major

railyards in King County and Pierce County, therefore all the county emissions were used without a

spatial surrogate for activity within the Seattle and Tacoma maintenance areas.

Line Haul and Passenger Rail

Table C.15 shows the emissions from each locomotive category.  Table C.16 shows the maintenance

area fraction of the rail line of the total county rail for estimating passenger, line haul, and coal dust

emissions. Table C.17 shows the fraction of county rail activity in the maintenance area for line haul

estimates.

Table C.15: Estimated annual locomotive PM10 emissions by category

Locomotive Emission Category Annual Emissions in tons Tons/winter day

Kent Maintenance Area    

Passenger 0.1 0.000

Coal 12.5 0.034

Line Haul 1.2 0.003

Kent Total 13.8 0.038

Seattle Maintenance Area    

Passenger 0.3 0.001

Coal 34.4 0.094

Line Haul 2.4 0.007

Rail Yards 6.4 0.018

Seattle Total 43.5 0.120

Tacoma Maintenance Area    

Passenger 0.02 0.000

Coal 9.9 0.027

Line Haul 1.6 0.004

Rail Yards 1.9 0.005

Tacoma Total 13.4 0.037
C‐18

Table C.16: Maintenance area fraction of the rail line of the total county rail for estimating

passenger and coal dust emissions

Maintenance Area

Length of County

Passenger and Coal Train

Line in miles

Length of

Maintenance Area

Portion in miles

Fraction of County

Passenger and Coal Train

Lengths in Maintenance

Area

Kent 40.18 2.36 0.0587

Seattle 40.18 6.53 0.163

Tacoma 71.79 1.87 0.0260

Table C.17: Fraction of county rail activity in the maintenance area for line haul estimates.

Maintenance Area Fraction of County Rail Activity in Maintenance Area

Kent 0.060

Seattle 0.118

Tacoma 0.104

   
C‐19

Industrial

The federal Clean Air Act defines point sources as any stationary source having the potential to emit 100

tons per year of a criteria pollutant.  These sources require Air Operating (Title V) Permits.   

Sources that emit more than 25 tons, but less than 100 tons per year of PM10, must register with the

Puget Sound Clean Air Agency.  These registered sources must report their PM10 emissions if over 25

tons per year.  Although not required, many other sources report their PM10 emissions. Table C.18

summarizes the all the industrial sources that report PM10 emissions since 1994.

Table C.18: The number of industrial sources (active or inactive) reporting PM10 emissions

between 1994 and 2011.

Maintenance Area Air Operating Permit Sources Other reporting sources Total

Seattle 8 17 25

Tacoma 5 17 22

Kent 1 6 7

Grand Total 14 40 54

To have a more complete inventory, we used reported emissions from both air operating permit sources

and other reporting registered sources.  All these sources fall within PSCAA’s jurisdiction, except for

Simpson Tacoma Kraft, which Ecology provided.

In the Inventory Preparation Plan, we originally proposed to create our industrial inventory using the

maximum emissions from each emission segment since 1994.  However, EPA commented that only a

future year inventory would need such a conservative estimate.  They also suggested that the best

inventory for a limited maintenance plan is a base year planning inventory, which would better

represent actual emissions.  Therefore, we used actual reported emissions for 2011 from the reporting

industrial sources.   

Table C.19 below shows the added maximums from each segment since 1994 (including sources that no

longer emit or report), as was previously proposed in the Inventory Preparation Plan, along with the

actual emissions in 1994 and 2011.  Industrial emissions have lowered significantly since 1994.

   
C‐20

Table C.19: PM10 Emissions from all industrial sources from 1994 to 2011:

Maintenance

Area

1994

Allowable

Emissions

(tons)

Max of emissions each

emission segment since

1994 (tons)

1994 actual

emissions

(tons)

2011 actual

emissions

(tons)

Seattle 955 866 510 127

Tacoma 1,624 1212* 544* 243

Kent N/A 1.0 0.1 0.5

* Since data for Simpson Tacoma Kraft is missing for 1994 and 1995, 1996 data was used for the 1994 actuals.  The Simpson Tacoma Kraft

maximum was estimated using 1996‐2011 emissions.

Table C.20: Estimated annual emissions by reporting industrial source

Maintenance Area Source 2011 Emissions

(tons) Tons/winter day

Seattle Saint‐Gobain Containers, Inc (Verallia) 64.9 0.178

Seattle CertainTeed Gypsum Manufacturing

Inc

31.4 0.086

Seattle Ash Grove Cement Co, E Marginal 30.7 0.084

Seattle Puget Sound Coatings Machinists DSR 0.3 0.001

Seattle Kinder Morgan Liquids Terminal, LLC 0.1 0.000

Seattle Total 127.3 0.349

Kent Rexam Beverage Can Co 0.4 0.001

Kent Hytek Finishes Co 0.1 0.000

Kent Total 0.5 0.001

Tacoma Simpson Tacoma Kraft Co 97.0 0.266

Tacoma Graymont Western US Inc 85.1 0.233

Tacoma Georgia‐Pacific Gypsum LLC 26.8 0.073

Tacoma Simpson Lumber Company, LLC 22.2 0.061

Tacoma US Oil & Refining Co 12.3 0.034

Tacoma Total 243.4 0.666

   
D‐1   

Appendix D

Inventory Preparation and Quality Assurance Plan

Kent, Seattle and Tacoma PM10 Maintenance Area

D. Introduction

The Kent, Seattle, and Tacoma Washington PM10 maintenance areas were designated Group 1 PM10

areas in 1987 by the Environmental Protection Agency (EPA) for having a greater than 95% probability of

violating the 24‐hour PM10 standard, 150 μg/m3

. These areas were then classified as nonattainment

areas in 1990 as required for Group I areas by the 1990 Amendments to the Clean Air Act (CAA).  

Monitoring data shows that Kent, Seattle, and Tacoma have been in attainment of the standard since

1987, 1990 and 1989 respectively. The area was reclassified to attainment for the 24‐hour PM10

standard in March 2001 when EPA approved the first 10‐year maintenance plan for Kent, Seattle, and

Tacoma.    The maintenance plan for the second 10‐year period was due before March 2011.  Once

approved by EPA, the second ten year plan will fulfill the final maintenance planning requirement of the

Clean Air Act.  This Inventory Preparation and Quality Assurance Plan (IP/QA Plan) is in support of the

development of the required second 10‐year PM10 maintenance plan.  

The Kent PM10 maintenance area is shown in Figure 1. PM10 was monitored at James Street and Central

Avenue using a measured Federal Reference Method (FRM) between 1988 and 2003 and a measured

Federal Equivalent Method (FEM) from July 2004 through December 2007.  The area has been in

compliance with the standard since 1987.  Measured Federal Equivalent Method (FEM) PM10 values

were so low that the monitor was removed with EPA approval at the end of 2007.  Since then,

continuous, non‐reference method monitoring of PM2.5 has been conducted in Kent with a

nephelometer, which has been correlated with a co‐located PM10 monitor to provide estimated PM10

values.

The Seattle PM10 maintenance area is shown in Figure 2. PM10 was monitored at both 4401 and 4752

East Marginal Way South using a measured FRM between June 1988 and December 2003 and a

measured FEM between October 2004 through 2007.  The area has been in compliance with the

standard since 1990.  Measured Federal Equivalent Method (FEM) PM10 values were so low that the

monitor was removed with EPA approval at the end of 2007.  Since then, continuous, reference and

non‐reference method monitoring of PM2.5 has been conducted at the Seattle monitoring site and

correlated with a co‐located PM10 monitor to provide estimated PM10 values.   

The Tacoma PM10 maintenance area is shown in Figure 3. PM10 was monitored at 2301 Alexander

Avenue site in Tacoma, Washington.  The area has been in compliance with the standard since 1990.  

Measured Federal Equivalent Method (FEM) PM10 values were so low that the monitor was removed

with EPA approval at the end of 2007.  Since then continuous monitoring of PM2.5 has been conducted at
D‐2   

the Tacoma monitoring site and correlated with a co‐located PM10 monitor to provide estimated PM10

values.   

Puget Sound Clean Air Agency (PSCAA) will prepare the maintenance plan in coordination with The

Washington State Department of Ecology (Ecology).  The Kent, Seattle and Tacoma areas qualify for the

Limited Maintenance Plan (LMP) approach because they satisfy all the criteria outlined in the Limited

Maintenance Plan Option for Moderate PM10 Nonattinment Areas document. The areas have been in

compliance for over 20 years, calculated design values for the most recent 5 years of 24‐hour

monitoring data are below 98μg/m3

. The Kent, Seattle, and Tacoma, Washington conservative design

values are 58μg/m3

, 71μg/m3, and 71μg/m3 respectively. The three maintenance areas expect only

limited growth in on‐road motor vehicle PM10 emissions, and they are expected to pass a motor vehicle

regional emissions analysis test, which will be demonstrated using methodology in Attachment B of the

LMP guidance once the EI is finalized. A LMP assumes there is low risk of exceeding the standard and the

demonstration of maintenance is presumed to be satisfied.  A LMP includes a base year (attainment)

inventory, but does not require a projected year inventory. PSCAA proposes using existing information

from draft excerpts of Ecology’s Washington State Base Year 2011 County Inventories1 (2011 EI) to

create the emission inventory (EI) for the most significant emission sources.  

The following sections describe the planned approach to the LMP EI and the basis for selecting that

approach.  PSCAA and Ecology are submitting this IP/QA Plan for EPA approval.  

   

                                                            

1 Draft excerpts from the Washington State Base Year 2011 County Inventories, email transmittal from Sally Otterson to Sara

Harrold, 8/19/2013
D‐3   

Geographic Area

The City of Kent is located on the eastern side of the Green River Valley between the Cities of Tukwilla

and Auburn. The PM10 sources in this region come from residential wood burning, light industry, and

mobile sources. The valley floor is roughly two to three miles in width and is bound by hills which rise

300‐400 ft. in elevation. These hills act to trap pollutants under stable meteorological conditions

(inversions). These conditions exist most frequently during the late fall and winter and are associated

with the majority of particulate matter violations.   Figure D.1, below, shows the Kent PM10 maintenance

area and the location of the monitoring site.The Seattle PM10 maintenance area is comprised of the

Duwamish industrial and commercial area immediately south of the downtown district and includes the

Port of Seattle. The monitoring site has been in place since 1971 and is located in the center of the

Duwamish industrial valley near the Port of Seattle.  The site is a neighborhood scale site that is

representative of South Seattle neighborhoods and ambient exposure in the industrial valley.  The site is

influenced by a very complex mixture of mobile sources, port and marine sources, industrial sources,

winter home heating wood smoke, and other pollution sources.  The site is 80 meters west of E.

Marginal Way, which is a main arterial for many large haul trucks, as well as service vehicles and

personal automobiles. Figure D.2 shows the Seattle maintenance area.  

The Tacoma PM10 maintenance area is comprised of the industrial area of Tacoma, including the Port of

Tacoma, a Kraft pulp mill and other industrial operations.  The monitoring site has been in place since

1987 in the industrial area near the Port of Tacoma.  The site is neighborhood scale located near several

industrial air pollution sources.  The sources that impact the area are a mixture of mobile sources, port

and marine sources, industrial sources, and winter home heating from wood burning.  The site is also

within the Puyallup Indian Reservation. Figure D.3 shows the Tacoma maintenance area.  

Our emission inventory will be based on sources located within the maintenance areas only.  
D‐4   

Figure D.1: The Kent, WA PM10 Maintenance area
D‐5   

Figure D.2: The Seattle, WA PM10 Maintenance area

   
D‐6   

Figure D.3: The Tacoma, WA PM10 maintenance area

Temporal Resolution

Historical exceedances of the 24‐hour PM10 standard occurred primarily during cold days from October

through March.  Therefore, the inventory will address average winter daily emissions in the

maintenance area in addition to annual emissions.
D‐7   

Inventory Development

Ecology and PSCAA will develop an emission inventory using readily available data.  We will document

the estimation methods and gather information from the relevant inventory reports.  We will begin with

existing county data and temporally and spatially allocate it to the Kent, Seattle, and Tacoma

maintenance areas. The emission inventory will include annual and winter day emissions. Detailed

descriptions of the county wide 2011 emission inventory estimates are attached in Appendix A.  

We propose seven emissions categories be included in this LMP for the Seattle and Tacoma

maintenance areas and six emission categories for the Kent maintenance area.  The categories are based

on a review of emission categories listed in the first, 1997, maintenance plan. Table D.1 shows the

breakdown of average daily PM10 emissions in 1994. We will use the same emission categories as the

1997 maintenance plan with the exception of Allowable Industrial. We propose to use reported

emissions from both registered and air operating permit sources in the LMP. The methodology we plan

to use for industrial point sources is outlined in section 2.4.

Table D.1: 1994 PM10 Average Daily Emissions from the 1997 maintenance plan

1994 Emissions

Categories

Emissions Per Day

(kg/day)

Percent of Daily Emissions

(%)

Kent Seattle Tacoma Kent Seattle Tacoma

Wood Burning 77 65 90 42.1 2.3 2.0

Road Dust 30 55 37 16.4 1.9 0.8

Gasoline Exhaust 30 105 50 16.4 3.7 1.1

Diesel Exhaust 45 223 122 24.3 7.8 2.8

Ships n/a 15 26 n/a 0.5 0.6

Locomotives 1 20 13 0.5 0.7 0.3

Allowable Industrial n/a 2,374 4,035 n/a 83.1 92.3

   
D‐8   

Emission Categories

The most significant sources of PM10 in the Kent maintenance area are Residential Wood Combustion

(i.e., Wood Burning), Diesel and Gasoline Exhaust, and Road Dust.  Smaller contributions come from

Locomotives.  The Port and Marine category is not applicable to the Kent maintenance area. The Seattle

and the Tacoma PM10 maintenance areas are dominated by Industrial Emissions as well as Port and

Marine sources, On‐road Mobile, and Locomotives with some influence from Residential Wood

Combustion.   Table D.2 outlines the emission categories that will be included in the LMP emission

inventory. Inventory values for all of these source categories are available from Ecology’s 2011 EI2 for

King County and Pierce County.

Table D.2: Emission Categories to be used in this LMP

1994 Emissions Categories 2011 Emission Categories

Gasoline Exhaust On‐road Mobile

Diesel Exhaust Port and Marine, On‐road Mobile

Ships Port and Marine

Locomotives Locomotives

Wood Burning Residential Wood Combustion

Road Dust Paved Road Dust, Unpaved Road Dust

Allowable Industrial Industrial

                                                            

2 The categories are defined in the 2005 Emission Inventory Guidance for Implementation of Ozone and Particulate Matter

National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations.
D‐9   

On‐road Mobile Sources

On‐road mobile source emissions are those generated by operating vehicles on public roadways.  The

LMP Emission Inventory will be based on Ecology’s “Washington State Base Year 2011 County

Inventories.” Winter day emissions were estimated for each county using EPA’s Motor Vehicle Emission

Simulator (MOVES) model version 2010b, using a combination of default and local data as input

parameters.  Total PM10 emissions included primary PM10 from runnning exhaust and start exhaust, as

well as brakewear and tirewear particulate.

The number of vehicle miles traveled (VMT) are used in MOVES.  The MOVES input files require

summations of VMT statistics by several different road and vehicle classifications, which were developed

using national Department of Transportation’s Highway Performance Monitoring System (HPMS) as

obtained from the Washington State Department of Transportation (WSDOT). HPMS is a system of

traffic counts collected over several urban and rural sampling areas. WSDOT makes estimates of county

VMT by roadway (functional) classifications.

Fleet characteristics, including vehicle population and age distribution, were derived from local data.

Registration data from the Washington Department of Licensing (DOL) was supplemented with transit

and intercity bus data from the Federal Transit Administration (FTA) and public school bus data from the

Washington State Office of the Superintendent of Public Instruction (OSPI).  

MOVES defaults were used for gasoline and diesel fuel parameters, which reflect current regulations

regarding sulfur content and Reid vapor pressure. All transit buses in Pierce County were assumed to

operate using compressed natural gas (CNG).

MOVES defaults were used for meteorological data. MOVES defaults are based on historical

meteorological observations from local monitors for each county.

All input parameters are described in Section 3.1 of the 2011 EI. The model parameters and data sources

are summarized in Table D.3 below.
D‐10   

Table D.3: MOVES Model Parameters and Data Sources

Parameter Data Source

County vehicle population Washington State Department of Licensing (DOL),

Federal Transit Administration (FTA), Washington State

Office of the Superintendent of Public Instruction

(OSPI)

County VMT Department of Transportation’s Highway Performance

Monitoring System (HPMS) obtained from the

Washington State Department of Transportation

(WSDOT)

Temporal allocation to month  and day of week WSDOT

Vehicle age distribution DOL, FTA, OSPI

Average speed distribution MOVES defaults

Road type distribution HPMS obtained from WSDOT

Fuel supply and formulation MOVES defaults

Meteorology data MOVES defaults

   
D‐11   

Port and Marine Emission Estimates

The 2011 inventory prepared for the Puget Sound Maritime Air Forum by Starcrest Consulting Group,

LLC was used to estimate emissions from ships in Puget Sound.3

  The inventory is a bottom‐up, activity‐

based emissions inventory which provides detailed information on the five major source categories

associated with the marine activities: ocean‐going vessels, harbor vessels, cargo handling equipment,

on‐road heavy‐duty vehicles, and rail operations.  It was an update to a similar inventory prepared by

Starcrest for the 2005 inventory. Activity level and emission rates are described in the source inventory

documentation.

Locomotives

Emissions from Class I line haul and switch yard locomotives were estimated using EPA guidance and

other information.4

  U.S. Class I railroads are line haul freight railroads with operating revenue in excess

of $319.3 million (amount changes over time).  Two Class I railroads operate in Washington: Burlington

Northern Santa Fe Railway (BNSF) and Union Pacific Railroad (UP).  Amtrak was also included in this

inventory.  Class 2 and 3 railroad locomotive emissions were not inventoried.  A special AIRQUEST

(formerly Northwest Regional Technical Center) project conducted by the Oregon Department of

Environmental Quality (ODEQ) found that emissions from Class 2 and 3 railroad locomotives were a

small percentage of total locomotive emissions.5, 6

BNSF and UP provided activity and emissions information for 2011.   Amtrak provided only activity

information for 2011.  

Activity level is measured in gallons of diesel consumed by locomotives.  All of the railroads provided

county fuel use for line haul and switch yard locomotives for 2011.7

Most of the activity information is available in the maintenance areas and no spatial surrogate is

necessary. Spatial surrogates for passenger rail and coal line will be based on the length of rail in each

county.   

Locomotives were assumed to operate uniformly year‐round per EPA guidance.8

                                                            

3  2011 Puget Sound Maritime Air Emissions Inventory.  Prepared by: Starcrest Consulting Group, LLC, Starcrest Consulting

Group, LLC, Poulsbo, Washington 98370.  September 2012.

4  Procedures for Emission Inventory Preparation, Vol. IV: Mobile Sources.  EPA‐450/4‐81‐026d (Revised), Section 6.0.  1992.

5  Regional Technical Center Demonstration Project: Summary Report.  Idaho Department of Environmental Quality, Oregon

Department of Environmental Quality, Washington Department of Ecology, US EPA Region 10, Washington State University,

University of Washington.  January 11, 2002 (draft).

6  Oregon 1996 Railroad Emissions Inventory Project, Emission Estimate Methodology Documentation.  Oregon Department of

Environmental Quality.  August 2001.

BNSF, UP and Amtrak Railway Company 2011 Estimation of Locomotive Emissions.  Email transmittal of information from Kelly

Harvey (BNSF), Michael Germer (UP), and Delia Ann Pfleckl (Amtrak) to Sarah Clouse Washington State Department of Ecology.  

March 2012.  County fuel use and emissions.

8  Procedures for the Preparation of Emission Inventories for Carbon Monoxide and Precursors of Ozone.  Volume II, table 6‐11.  

EPA‐454/R‐92‐026, March 1992.
D‐12   

Fugitive coal dust emissions from rail transport will be estimated using the suggested approach

described by Cope and Bhattacharyya, 2001.9

   

Industrial Emissions

The federal Clean Air Act defines point sources as any stationary source having the potential to emit 100

tons per year of a criteria pollutant.  These sources require Air Operating (Title V) Permits.   

Sources that emit more than 25 tons but less than 100 tons per year of PM10 must register with the

Puget Sound Clean Air Agency.  These registered sources must report their PM10 emissions if over 25

tons per year.  Although not required, many other sources report their PM10 emissions.

Table D.4  The number of industrial sources (active or inactive) reporting PM10 emissions between 1994

and 2011.

Table D.4: The number of industrial sources (active or inactive) reporting PM10 emissions

between 1994 and 2011.

Maintenance Area Air Operating Permit Sources Other reporting sources Total

Seattle 8 17 25

Tacoma 5 17 22

Kent 1 6 7

Grand Total 14 40 54

For a more complete inventory, we propose to use reported emissions from both air operating permit

sources and other reporting registered sources.  All these sources fall within PSCAA’s jurisdiction, except

for Simpson Tacoma Kraft.  Ecology will provide PSCAA available emissions data for Simpson Tacoma

Kraft by Source Classification Code (SCC) code or facility back to 1994.   

Typically, the maximum allowable emissions are used in maintenance plan demonstrations.  We propose

to us a similarly conservative estimate grounded by historical emission data.   

We propose to use the maximum actual emissions since 1994 for each SCC or facility for all the reported

emissions from air operating permit sources and other registered sources in our emission estimate.  

That is, we would include every maximum emission from each segment from each point source even if

the maximum of different segments is on different years.  This gives the most conservative estimate of

emissions from each industrial source.   

                                                            

9 Cope, Douglas; Bhattacharyya Kamal. “A Study of Fugitive Coal Dust Emissions in Canada”, prepared for the Canadian Council

of Ministers of the Environment, 2001.
D‐13   

We’ve determined with our professional judgment that the maximum reported actual emissions result

in a more representative estimate than allowable emissions do.  Specifically, only air operating permit

sources are included in allowable emissions, and our proposed approach also includes the 40 other

sources (see Table D.1) that would not be captured anywhere else.  Similarly, the maximum actual

emissions represent real potential emissions rather than a theoretical estimate that is often never

reached in practice.

Table D.5 below demonstrates that our proposed industrial emission estimate approach is comparable

to the allowable emission estimate.

Table D.5: PM10 Emissions from all industrial sources from 1994 to 2011:

Maintenance

Area

1994

Allowable

Emissions

(tons)

Max of emissions each

emission segment since

1994 (tons)

1994 actual

emissions

(tons)

2011 actual

emissions

(tons)

Seattle 955 866 510 127

Tacoma 1,624 1212* 544* 243

Kent N/A 1.0 0.1 0.5

* Since data for Simpson Tacoma Kraft is missing for 1994 and 1995, 1996 data was used for the 1994 actuals.  The Simpson Tacoma Kraft

maximum was estimated using 1996‐2011 emissions.

Since the last maintenance plan was written in 1994, many sources have stopped reporting their

emissions.  These industrial sources either reduced their emissions below 25 tons per year or they are

no longer active.  To remain conservative in our estimate, we propose to include these sources in the

inventory as well.

Since Simpson Tacoma Kraft data is missing for 1992‐1994, we propose to use the maximum reported

emissions back to 1996 instead of 1994.

Nonpoint Source Emission Estimates

Residential Wood Combustion, Unpaved Road Dust, and Paved Road Dust are nonpoint sources.  These

emissions are typically estimated by multiplying an activity level, such as wood combusted or Vehicle

Miles Traveled (VMT), by an emission factor in mass per activity.

Emissions = Activity level x Emission Factor

Estimation methods and data sources for these nonpoint sources are described below.   
D‐14   

Residential Wood Combustion

Residential wood combustion (RWC) emissions will be based on the “Washington State Base Year 2011

County Inventories.” Residential wood combustion consists of home heating and recreational use of

woodstoves, fireplaces, fireplace inserts, and pellet stoves.  Other residential wood burning devices

were not inventoried. The measure of activity for residential wood combustion is the amount of wood

burned.  Residential wood combustion activity for King County and Pierce County was estimated using

data from a survey conducted by the National Research Center in 2007 (NRC2007).     Criteria pollutant

emission factors in pounds of pollutant per ton of wood burned were taken from version 1 of EPA's 2011

Residential Wood Combustion tool.   

Spatial and Temporal Allocation

Spatial allocation will be based on the number of households in the maintenance area for the year

2011. Temporal allocation was completed by Ecology and is based on a relationship between

temperature and ambient fine particulate concentrations.  For more detail please see the Ecology

2011 Emission Inventory in Appendix A.  

Paved Road Dust

Dust emissions are generated as vehicles pass along paved roadways and disturb the layer of loose

material on or near the road surface.  This material contains particulate matter from soil, brake and tire

wear, exhaust, and other substances.  The paved road dust calculation excludes emissions from exhaust

and brake and tire wear.  These vehicle emissions are estimated as on‐road mobile sources emissions.  

VMT on unpaved roads was estimated using data from the County Road Administration Board (CRAB)

and WSDOT.  The Road Dust equations in AP‐42 were used to calculate emission factors10. The measures

of activity and spatial allocation will be based on VMT in the maintenance areas. Temporal allocation is

identical to the on‐road category.

Unpaved Road Dust

Similar to paved roads, dust emissions are generated as vehicles pass along unpaved roadways and

disturb the layer of loose material on or near the road surface.  This material contains particulate matter

from soil, brake and tire wear, exhaust, and other substances.  The unpaved road dust calculation

excludes emissions from exhaust and brake and tire wear since they are estimated as on‐road mobile

sources emissions. The Road Dust equations in AP‐42 were used to calculate emission factors11.

                                                            

10 Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources.  AP42.  Section 13.2.1 Paved

(11/06) and Section 13.2.2 Unpaved (11/06). (Note that the methodology for calculating Road Dust for the maintenance plan

was different. The alternative method correlated relative humidity and entrained road dust using a WSDOT 2006 algorithm.) 11 Ibid. 10
D‐15   

Spatial Allocation Methods

Spatial surrogates are used to approximate emissions inside the three maintenance areas from county

data.  For sources without specific coordinates, spatial surrogates are used to approximate both the

location and magnitude of the emissions.  Maintenance area (MA) emissions are estimated as:

EMA = ECounty * SurrogateMA / SurrogateCounty

Where EMA = emissions in the maintenance area, ECounty = emissions in county,  

SurrogateMA = surrogate activity in the maintenance area, and SurrogateCounty = surrogate activity in

county.

The spatial surrogates and data sources used are shown in Table D.6 below.

Table D.6: Spatial Surrogates

Sector and Category Spatial Surrogate Data Source

Nonpoint Sources

Woodstoves and Fireplaces Households or Population Puget Sound Regional Council

(PSRC)

Paved Road Dust VMT PSRC

Unpaved Road Dust VMT WSDOT

On‐Road Mobile Services

All Vehicles Road VMT PSRC

Non‐Road Sources

Marine and Port Port Area in Maintenance Area 2011 Puget Sound Maritime Air

Emission Inventory

Locomotives – Line Haul Line Haul shape fractions, with

activity level EPA Rail Activity Use Shape File

Locomotives ‐ Passenger Fraction of rail in maintenance

area County Rail Shape Files
D‐16   

Temporal Allocation Methods

Annual emissions data will be adjusted to tons per average winter day for the maintenance area for

each source category.  Methods for each category are described below.

Residential Wood Combustion

Residential wood combustion activity for King County and Pierce County was estimated using data from a

survey conducted by the National Research Center in 2007 (NRC2007). Temporal allocation was based on

a relationship between temperature and ambient fine particulate concentrations.  Briefly, analysis of

several PM2.5 and meteorological monitoring sites showed a strong linear relationship between ambient

temperature and ambient fine particulate concentrations at temperatures below 50 degrees

Fahrenheit.12   Heating degree days (based on 50 degrees = HDD50) were calculated for each day during

the NRC2007 survey period (Sept. 2006 ‐ Aug. 2007).13  The season total HDD50 were divided by the

annual HDD50 to estimate seasonal fractions.

On‐road Mobile Sources

VMT is not temporally uniform.  WSDOT provided adjustment factors for month, day‐of‐week, and hour

(weekday and weekend).14   

Road Dust

VMT is not temporally uniform.  WSDOT provided adjustment factors for month, day‐of‐week, and hour

(weekday and weekend).15   

   

                                                            

12 Clint Bowman, Ecology, On a Possible Wood Stove Signature in PM2.5 Observations,  October 2008. 13  Tacoma South L‐Street meteorological site. 14  Email from Guorong Liu, Washington State Department of Transportation to Sally Otterson, Washington State Department of

Ecology.  Transmitting spreadsheets with monthly, day‐of‐week, and hourly adjustment factors.  Seasonal Factor_08.xls, Day of

Week Factor_08.xls, Hourly Factor_08.xls.  Nov. 24, 2009.  Ibid. i 15  Ibid. i
D‐17   

Quality Assurance and Quality Control		

We are using existing data that has already been quality checked.  Ecology uses the data quality

objectives of accuracy, completeness, comparability, and representativeness.  Ecology and PSCAA staff

will perform quality assurance on the spatial and temporal allocation of emissions from the existing

inventory.   

External Audits

The state is willing to be audited by EPA, and make changes to this inventory preparation and quality

assurance plan if warranted.

Responsibility

Since we are using available data, the inventory process will be simplified.  PSCAA will create the

inventory with assistance from Ecology and PSRC.  Both agencies will participate in inventory review and

quality assurance activities outlined in this plan.   

Schedule

The section below shows the schedule for document submittal to EPA Region 10.  We will submit the

final inventory according to this Inventory Preparation and Quality Assurance (IP/QA) Plan.

Draft SIP Development Plan (PSCAA) August 16, 2013

Draft Inventory Preparation Plan (IPP) (PSCAA) August 23, 2013

Draft Plan Development and Supporting Technical Work (PSCAA) August 30, 2013

SIP to Ecology (and EPA) (PSCAA) September 12, 2013

Ecology, EPA Review and PSCAA revisions (All) September 12 – 27, 2013

Public comment period (incl. public notice, press release etc) (Ecology) September 27 – Nov. 7, 2013

Ecology signature and submittal to EPA (Ecology) Week of December 2, 2013