## Justification for D iscontinuation of M onitoring in Carbon

Monoxide and PM 10 

## Maintenance Areas

Submitted to: Keith Rose, EPA Region 10

By: Anthony Barnack, Oregon DEQ

October , 2011

Last Updated: 12 / 01 /11 By: Anthony Barnack 

## ReportThis report prepared by:

Oregon Department of Environmental Quality

811 SW 6 th Avenue Portland, OR 97204

1

- 800

- 452

- 4011 www.oregon.gov/deq

Contact: Anthony Barnack (503) 229

- 57133 3



## Monitoring Discontinuation Justification

Table of Contents

1. Executive Summary

................................ ................................ ................................ ..................... 1

2. Introduction

................................ ................................ ................................ ................................ .. 2

3. Pollutant Trends and Source of Emissions

................................ ................................ .................. 2
3.1 Carbon Monoxide Trends for Eugene/Springfield and Medford

................................ ................................ ........ 2 3.2 Carbon Monoxide Emission Sources in Eugene/Springfield and Medford

................................ ........................ 4

3.3 PM 10 Trends

................................ ................................ ................................ ................................ ........................ 4

3.4 PM 10 Emission Sources in Eugene/Springfiel d and Medford

................................ ................................ ............. 5

4. Fraction of PM 10 that is PM 2.5

................................ ................................ ................................ ...... 5

4.1 Klamath Falls PM 10 vs. PM 2.5

................................ ................................ ................................ ............................ 6

4.2 Grants Pass PM 10 vs. PM 2.5 :

................................ ................................ ................................ ............................... 7

4.3 PM 10 vs. PM 2.5 Summary:

................................ ................................ ................................ ................................ .. 9

5. Emission Estimate Methods:

................................ ................................ ................................ ....... 9
5.1 The Central Lane MPO Regional Emissions Analysis

................................ ................................ ....................... 9 5.2 The Rogue Valley Regional Emissions Analysis

................................ ................................ .............................. 10

6. An alternate approach for tracking the pollutant

................................ ................................ ....... 10
6.1 Tracking Carbon Monoxide:

................................ ................................ ................................ ............................ 10 6.2 Tracking PM 10 :

................................ ................................ ................................ ................................ ................ 11

7. Alternate contingency measure trigger

................................ ................................ ...................... 11
7.1 Alternative trigger for CO for Medford UGB:

................................ ................................ ................................ . 11 7.2 Alternative trigger for CO for Eugene/Springfield AQMA:

................................ ................................ ............ 12 7.3 Alternative trigger for Klamath Falls PM 10 Urban Growth Boundary

................................ ............................. 13 7.4 Alternative trigger for Grants Pass PM 10 Urban Growth Boundary

................................ ................................ . 14

8. Conclusion

................................ ................................ ................................ ................................ . 14

9. Reference

................................ ................................ ................................ ................................ ... 15

Table of Figures Figure 1. Medford and Eugene/Springfield CO trends.

................................ ................................ . 3 Figure 2. Grants Pass and Klamath Falls PM 10 trends.

................................ ................................ .. 4 Figure 3. Klamath Falls, Peterson School PM 10 /PM 2.5 Correlation.

................................ .............. 6 Figure 4. Klamath Falls winter time PM 10 distribution of PMcoarse and PM 2.5

. .......................... 7 Figure 5. Grants Pass, Parkside School PM10/PM2.5 Correlation.

................................ ............... 8 Figure 6. Grants Pass, winter time PM 10 distribution of PMcoarse and PM 2.5

. ............................. 8

Table of Tables Table 1. Medford and Eugene/Springfield CO design values.

................................ ...................... 3 Table 2. Medford and Eugene/Springfield PM 10 design values.

................................ ................... 5

Table 3. PM 2.5 fraction of PM 10 Average and 95% confidence level.

................................ ........... 9 Table 4. 2010 CO emission estimates within the Eugene/Springfield boundary.

....................... 10

Table 5. 2010 CO emission estimates within the Medford urban growth boundary.

.................. 10 Table 6. Linear regression equations and ratios used to estimate PM 10 using PM 2.5

. .................. 14Glossary of Terms:

NAAQS

– National Ambient Air Quality Standards (EPA criteria pollutant standards)

CO

– Carbon monoxide

PM 10

– Particulate matter, 10 microns in diameter or smaller

PM 2.5 - Particulate matter, 10 microns in diameter or smaller ODEQ

– Oregon Department of Environmental Quality

LRAPA

– Lane Regional Air Protection Authority (Lane County, Oregon)

SIP

– State Implementation Plan

ppm

– Parts per million (concentration) μg/m 3

– micrograms per meter cubed (concentration)

FRM

– Federal Reference Method

MPO

– Metropolitan Planning Organization AQCD

- The Air Quality Conformity Determination1 1

1 

## Monitoring Discontinuation Justification

1

. Executive Summary

Due to budget cuts, Oregon DEQ and the Lane Regional Air Protection Authority need ed t o discontinue c arbon monoxide and PM 10 monitoring in maintenance areas which are now far below the National Ambient Air Quality Standard (NAAQS) . The monitoring funds have either been lost or reinvested in higher priority monitoring such as PM 2.5 or ozone. These pollutants are much closer to the NAAQS and require sustained monitoring.

The CO and PM 10 maintenance plans require continued monitori ng for compliance determination and as triggers for contingency plans . To remove this requirement from the plan s would require resources and time that ODEQ and LRAPA cannot afford at this time

. EPA Region 10 has proposed a compromise which would require the use of alternative

methods to track these pollutants in maintenance areas . The alternative methods w ill be

inc luded in the next maintenance plan revisions

.

The method fo r tracking CO would use th e regional emissions analysis performed in the A ir Quality Transportation Conformity Determination . This is conducted every four years by the Metropolitan Planning Organizations. The se analyse s will show the emission trend s and will provide a trigger for the contingency plans written into the maintenan ce plans

. As a real time

measure, the Portland CO monitor will be used to track trends in general CO levels

.

For PM 10 , PM 2.5 will be used as a surrogate. The percent of PM 10 that is PM 2.5 is very high in Oregon and the control strategies are the same for both pollutants.

Maintenance Plans are located at: http://www.deq.state.or.us/aq/planning/maintenance.htm2 2

2 

## Monitoring Discontinuation Justification

2

. Introduction

Beginning i n the 1970s

, and continuing through the early part of the 1990s, Oregon had

several communities that violated the carbon monoxide and PM 10 NAAQS and were consequently declared out of attainment for these pollutants. Oregon DEQ and local stake holders implemented State Implementation Plans (SIPs) to bring these areas under the NAAQS. After many years of levels below the standards , maintenance plans were installed to keep the air quality below the NAAQS. The mainten ance plans included requirements to

continue monitoring to determine long

- term trends and compliance . Monitoring was also required for contingency measure trigger s for additional regulatory actions.

Over the last twenty years, the CO and PM 10 concentrati ons have dropped far below the NAAQS. Monitoring continued only to meet the maintenance requirements, but had no real

benefi t for public health. The maintenance plans require monitoring until 2014 for Eugene/Springfield CO, and 2022 for Medford CO, and 2 023 for Grants Pass PM 10 and

Klamath Falls PM 10 . Public health benefits most from PM 2.5 , ozone, and air toxic monitoring.

In the last ten years ODEQ and LRAPA ha ve experienced repeated budget cuts as a result of

diminished revenue and expanded costs. In 2010 and 2011, budget cuts were especially deep

and re sulted in the elimination or reprioritization of many m onitoring activities . ODEQ and

LRAPA had alre ady cut discretionary monitoring and had to now consider shutting dow n required, but low priority monitoring. CO and PM 10 sites were considered expendable as long as alternative methods were available to track general concentrations and act as contingency measure triggers.

This report shows the how alternative methods can be used to adequately track CO and PM 10 and trigger contingency measure s

.

3

. Pollutant Trends and Source of Emissions

3.1 Carbon Monoxide Trends for Eugene/Springfield and Medford

The carbon monoxide levels have continuously dropped over the past 20 years and are now routinely one quarter of the NAAQS. Figure 1 show s the CO trend s for Medford and Eugene/Springfield and Table 1 provides the design values from 200 0 to 2010

. Medford has been below the NAAQS since 1993 and Eugene/Springfield has been below the NAAQS

since 1983. With ever more cleaner cars on the road, the design values are not expected to

increase.3 3

3 

## Monitoring Discontinuation Justification

Figure 1 . Medford and Eugene/S pringfield CO trends. Second highest 8 hour average.

Table 1 . Medford and Eugene/Springfield CO design values. Eugene Medford

(ppm) % of

NAAQS (ppm) % of

NAAQS

2000 4.3 45% 4.7 49%

2001 4.1 43% 4.6 48%

2002 4.2 44% 5.5 58%

2003 3.4 36% 4.7 49%

2004 3.4 36% 4 42%

2005 2.6 27% 3.8 40%

2006 2 21% 2.8 29%

2007 2.1 22% 2.7 28%

2008 1.7 18% 2.4 25%

2009 1.7 18% 2.4 25%

2010 1.3 14% ND ND

Based on a nnual 2 nd highest, daily maximum eight hour average.4 4

4 

## Monitoring Discontinuation Justification

3. 2 Carbon Monoxide Emission Sources in E ugene/Springfield and Medford In the past, CO emissions in M edford and Eugene/Springfield wer e primarily from mobile source. In newer vehicles, catalytic converters, fuel injections, and electronic timing have greatly reduced tailpipe CO levels. As the vehicle fleet becomes newer the CO levels are expected to continue drop ping

.

Non

- mobile CO sources include industrial and area sources. Both areas have EPA Title V sources with Plant Site Emission Limits over 100 tons per year. These sources have been operating for years and are regulated. The y would have to go through P revention of Significant Deteriora tion review if they wanted to raise their CO emissions.

Both areas also have a significant population using residential wood heating

. Both were

PM 10 non

- attainment area s and ha ve had program s in place for years that encourages the use of certified woodstoves. All of Oregon now has the Heat Smart Program which requires the

removal of non

- certified woodstove upon sale of a home. Certified wood stoves emit far less

CO than non

- certified stoves.

3. 3 PM 10 Trends Over the last 20 years PM 10 levels have dropped statewide because of permitting programs and other reduction strategies

. Figure 2 shows the PM 10 trends for Grants Pass and Klamath

Falls from 1987 to 2010

. Table 2 provides the design values from 200 0 to 2010. Grants Pass

has been below the NAAQS since 1988 and Klamath Falls has been bel ow the NAAQS since

1991.

Figure 2 . Grants Pass and Klamath Falls PM 10 trends.5 5

5 

## Monitoring Discontinuation Justification

Second highest 24 hour average PM 10 values.

Table 2

. G r a n t s P a s s a n d K l a m a t h F a l l s PM 10 design values.

Grants Pass Klamath Falls

(μg/m3) % of

NAAQS (μg/m3) % of NAAQS

2000 40.0 27% 93.0 62%

2001 50.0 33% 62.0 41%

2002 41.0 27% 121.0* 81%

2003 49.0 33% 63.2 42%

2004 32.3 22% 70.4 47%

2005 37.5 25% 75.5 50%

2006 37.7 25% 56.3 38%

2007 39.3 26% 71.8 48%

2008 42.3 28% 71.7 48%

2009 ND ND 61.8 41%

2010 ND ND 40.8 27%

Based on annual 2 nd highest, 24 hour average.

* The 2002 Klamath Falls PM 10 value was from a forest fire but was not considered an exceptional event because it was below the NAAQS.

3. 4 PM 10 Emission Sources in E ugene/Springfield and Medford In the past, PM 10 emissions in Medford and Eugene/Springfield were primarily from

industr ial and area sources. Both areas have EPA Title V sources with Plant Site Emission Limits over 100 tons per year. Industrial sources were regulated and now have cyclones , bag houses, and more efficient boilers to control emissions. Other methods such as Wigwam

burners were outlawed. If these sources wanted to emit more PM 10 they would have to go through Prevention of Significant Deteriation review.

The primary source of PM 10 is now smoke from residential wood heating. Medford and Eugene/Springfie ld were PM 10 non

- attainment areas and have had programs in place for years that encourage the use of certified woodstoves. All of Oregon now has the Heat Smart Program which requires the removal of non

- certified woodstove upon sale of a home.

Certified w ood stoves emit far less PM 10 than non

- certified stoves.

4

. Fraction of PM 10 that is PM 2.5 In Oregon, PM 10 is mostly made up of PM 2.5 . This section will show the results of years of

wintertime collocated PM 10 and PM 2.5 sampl ing in Klamath Falls and Grants Pass to
ascertain the PM coarse (PMc) fraction of PM 10

. In Oregon, winter weather occurs from November through February . This is when most winter inversions occur and the highest

concentrations are measured.6 6

6 

## Monitoring Discontinuation Justification

4.1 Klamath Falls PM 10 vs. PM 2.5 C omparable PM 10 and PM 2.5 FRM samplers were operated in Klamath Falls from 2007 through 20 10 . Comparison of the winter PM 2.5 and PM 10 data shows a correlation with an R Squared of 0. 87 (Figure 3 ). During this period there were 17 samples greater than 1⁄4 of the NAAQS, three of which were greater than 1⁄2 the NAAQS. The highest value in the past

three winters was 57% of the PM 10 NAAQS. On average, winter PM 10 is 70 % PM 2.5 by weight with a 95% confidence level of 66% to 74% (summarized in Table 3). Figure 4

shows the PM 2.5 and PMcoarse fractions for the highest winter values for 2007

- 2009.

Figure 3 . Klamath Falls, Peterson School PM 10 /PM 2.5 Correlation.7 7

7 

## Monitoring Discontinuation Justification

Figure 4

. Klamath Falls winter time PM 10 distribution of PMcoarse and PM 2.5

. Note: In Figure 4, PMc(red)+PM 2.5 (blue) = PM

10

Over the past ten years there were two years with elevated days outside of winter. In 2002,

massive forest fires caused elevated levels during August; the PM 10 was mostly PM 2.5 . In 2009, a dust event caused an elevated level in early October. The dust event had a low PM 2.5 quotient but the PM 10 concentration (87μg/m 3 ) was well below the NAAQS. If that single

dust event was included in t he linear regression done in Figure 2, the RSquared would change from 0.87 to 0.76 and the equation would change from y =1.4x+1.0 to y =1.4x+3.2. This is only a 2.2μg/m 3 higher PM 10 derived value if the dust event is included.

4.2 Grants Pass PM 10 vs. P M 2.5 : C omparable PM 10 and PM 2.5 samplers were co

- located in Grants Pass from 2006 through

2008. The PM 2.5 and PM 10 correlation has an R Squared of 0.94 (Figure 5).

From 2006 to 2008 there were only four samples over 1⁄4 of the NAAQS, and none over 1⁄2 the NAAQS. On average, winter PM 10 is 73% PM 2.5 by weight with a 95% confidence level of 70% to 76% (summarized in Table 3) . The highest value in the past three winters was only

29% of the PM 10 NAAQS. Figure 6 shows the PM 2.5 and PM coarse fractions for the winter

values for 2006

- 2008.8 8

8 

## Monitoring Discontinuation Justification

Figure 5

. Grants Pass, Parkside School PM10/PM2.5 Correlation.

Figure 6

. Grants Pass, winter time PM 10 distribution of PMcoarse and PM 2.5

. Note: In Figure 6, PMc( red)+PM 2.5 (blue) = PM

109 9

9 

## Monitoring Discontinuation Justification

4.3 PM 10 vs. PM 2.5 Summary:

T able 3 shows t he summary of the winter co

- located PM 10 and PM 2.5 samples . This percentage shows the percentage (by weight) of PM 10 that is PM 2.5

.

Table 3 . PM 2.5 fraction of PM 10 Average and 95% confidence level.

Average 95% Confidence Level

Klamath Falls 70% 66%

- 74%

Grants Pass 73 % 70 %

- 76%

5

. Emission Estimate Methods : Modeled CO emission estimates are developed by the Metropolitan Planning Organizations (MPOs) for Eugene/Springfield and Medford as part of the transportation conformity requirements in the maintenance plans in accordance with Clean Air Act section 176(c)

. T ransportation conformity ensure s that f ede ral funding and approval are given to highway and transit projects that are consistent with ("conform to") the air quality goals established by a SIP. Conformity, to the purpose of the SIP, means that transportation activities will not cause new air qualit y violations, worsen existing violations, or delay timely attainment of the NAAQS

.

A regional emissions analysis is a major component of demonstrat ing transportation conformity

. The regional emissions analysis includes emissions from all current and plan ned regionally significant projects in the entire transportation system in the maintenance area for the duration of the transportation plan or TIP

. The regional emissions analysis must use the latest planning assumptions and latest emissions mode l

.

This following section discusses the regional emissions analyses conducted in Eugene/Springfield and Medford for transportation conformity determinations.

5. 1 The Central Lane MPO Regional Emissions Analysis

T he Central Lane MPO is the agency responsible for performing the regional emissions analysis in the Eugene/Springfield maintenance area

. The most recent regional emissions analysis was completed in 2010 for the “ FY10

- 13 Metropolitan Transportation Improvement Program

. ”

The 2010 CO emission s projections from the regional emissions analyses are shown in Ta ble

4 (in tons per year)

. T he first year listed, 2004, is the regional land use/transportation model

base year

.10 10

10 

## Monitoring Discontinuation Justification

Table 4

. 2010 CO emission estimates within the Eugene/Springfield boundary.

Analysis Year Estimated CO Emissions ( t ons/yr)

2004 2,198

2008 1,634

2018 1,160

2028 1,056

203 1 1,059

5.2 The Rogue Valley Regional Emissions Analysis

T he Rogue Valley MPO is the agency responsible for performing the regional emissions analysis in the Medford maintenance area

. The most recent regional emissions analysis was completed in 2010 “ 2010

- 2013 Metropolitan Transportation Improvement Program 2009

- 2034 Regional Transportation Plan ”

.

The 2010 AQC D’s C O emissions from the regional emissions analysis are shown in Table 5 (in pounds per day)

. The first year listed, 200 5 , is the regional land use/transportation

model base year used in the “ 2001

- 2023 Regional Transportation Plan and 2002

- 2005 Transportation Improvement Program ”

.

Table 5

. 2010 CO emission estimates within the Medford urban growth boundary.

Analysis Year Estimated CO Emissions ( lbs/day )

2005 33,910

2015 19,359

2020 20

, 2 80

2026 19

, 770

2034 32,640

6

. An alternate approach for tracking the pollutant

CO and PM 10 maintenance plans required continued monitoring to determine NAAQS compliance. If the monitoring agency discontinues monitoring, CO and PM 10 must be tracked using alternative methods. This section outlines the specific tracking methods

O DEQ and LRAPA will use for CO in Medford and Eugene/Springfield, and PM 10 in

Klamath Falls and Grants Pass.

6.1 Tracking Carbon Monoxide : Carbon monoxide h as traditionally been tracked by monitoring and modeling

. Once monitoring is discontinued in the Eugene/Springfield and Medford maintenance areas, regional emissions modeling will be the primary method of tracking CO.11 11

11 

## Monitoring Discontinuation Justification

Because on

- road motor vehicle emissions are the primary source of CO in the Eugene/Springfield and Medford maintenance areas, ODEQ believes the regional emissions analysis conducted for the CO maintenance area s provides an effective surrogate method for

tr acking CO emissions. The regional emissions analysis must use the latest planning assumptions (e.g., population, vehicle miles traveled, employment estimates) a nd the latest

emissions model

. The regional emissions modeling is done at least every four years and produces CO estimates based on current and planned transportation activities throughout the

CO maintenance areas . If these estimates exceed the base year estimates (shown in italics in Tables 4 and 5)

, then the curren t CO concentrations may be higher than the design values for those years (3.4 ppm in Eugene in 2004 and 3.8 ppm in Medford in 2005, see Table 1). If this occurs, EPA and ODEQ or LRAPA will decide whether to conduct CO survey monitoring. If the CO survey monitoring shows levels > 1⁄2 of the NAAQS, then CO monitoring will be restarted

. Survey monitoring is done with an inexpensive non

- FRM

monitor.

ODEQ will also continue to monitor CO i n Portland

. T his monitoring will track general CO concentrations, because if the CO levels increase in Portland, they may also be going up in

the other cities. If the Portland CO design value exceeds 1⁄2 the NAAQS , survey monitoring may be performed at the former Medford and Eugene/Springfield C O sites to determine current conditions. If the surveyed CO levels are 1⁄2 the NAAQS, CO monitoring will be

restarted.

The CO estimates will be included in the annual network review.

6.2 Tracking PM 10 :
PM 10 in Klamath Falls and Grants Pass will be tracked using PM 2.5 monitoring. The major

source of PM 10 in these communities is smoke from wood heating

. The percentage of PM 10 which is PM 2.5 is known in both of these communities and PM 10 estimates can be made using

PM 2.5 monitored levels. PM 2.5 is monitored with both continuous and FRM samplers. Table 6 contains the linear regression equations used to estimate PM 10 from PM 2.5 at these sampling

locations.

The PM 10 estimates will be included in the annual network review.

7

. Alternate contingency measure trigger

CO and PM 10 maintenance plans contain contingency triggers which are tied to monitored levels. If the trigger concentration is reached, O DEQ or LRAPA must institute the contingency measures outlined in the maintenance plan. If the monitoring agency wants to discontinue monitoring, they need to offer an alternative method to measure air quality for comparison to the trigger level. This section outlines the specific alternative trigger methods for CO in Medford and Eugene/Springfield, and PM 10 in Klamath Falls and Grants Pass.

7.1 Alternative trigger for CO for Medford UGB : Contingency trigger requirements:

On March 9 th , 2001, the Environmental Quality Commission adopted the State implementation plan revision for carbon monoxide in the Medford urban growth boundary (a12 12

12 

## Monitoring Discontinuation Justification

plan for maintaining the national ambient air quality standards for carbon monoxide). Section 4.52.3.3 of the plan requires a “Contingen cy Plan” to take effect if the second highest daily 8 hour average monitored values were 1) above 90% of the NAAQS (phase 1), or 2) above the NAAQS (phase 2). The “Plan” makes an exception for the Medford Old Car Rally. The problem:

O DEQ had to disconti nue CO monitoring due to budget cuts and very low concentrations

. The contingency plan r elies on continued monitoring to compare to the tr igger points

. O D EQ needs to adopt a trigger point based on an alternative pollutant measure.

The Solution :
For Medford , two alternative contingency trigger methods will be used. Method 1 relies on estimates produced every four years. Method 2 relies on hourly, real time data.

Method 1:

The first method will be to use the modeled CO emission s in the regional emissions analysis

c onducted every four years by the Rogue Valley MPO for the transportation conformity

determination

. If the modeled emissions are above the modeled baseline year emissions

, CO survey monitoring will be started to determine whether the co ntingency requirements are triggered. Survey monitoring is done with an inexpensive non

- FRM monitor.

Method 2:

T he Portland, SE Lafayette CO monitor will be used as a surrogate. This provides real time

monitor ing data. If the Portland monitor reaches 1⁄2 the NAAQS

, survey sampling will be

started in Medford to determine whether the contingency requirements are triggered. Survey monitoring is done with an inexpensive non

- FRM monitor.

7.2 Alternative trigger for CO for Eugene/Springfield AQMA: Contingency trigger requirements:

On February 27 th , 1992, Lane Regional Air Pollution (now Protection) Authority sent an

addendum to their carbon monoxide maintenance plan title “Contingency Commitment for Amendment of Oregon’s SIP, Eugene

- Springfield carb on monoxide Attainment Redesignation & Adoption of Maintenance Plan”. The letter commi t ted LRAPA to a carbon

monoxide contingency plan as part of their carbon monoxide maintenance plan. The letter stated that “Within 60 days of reporting on AIRS that a v iolation of the carbon monoxide NAAQS has occurred within the Eugene

- Springfield AQMA , LRAPA and LCOG will submit to the EPA a contingency plan for attaining the standard, which will be implemented as expeditiously as practicable”. Since the carbon monoxide NAAQS was never violated following this letter, the contingency plan for attaining the standard was never required.

The problem:

LRAPA had to discontinue CO monitoring due to budget cuts and low CO concentrations

. The contingency plan relies on continued monitoring to compare to the trigger points. LRAPA needs to adopt a trigger point based on an alternative pollutant measure.13 13

13 

## Monitoring Discontinuation Justification

The Solution : For Eugene/Springfield, one of two alternative contingency trigger methods will be used.

Method 1 relie s on estimates produced every four years. Method 2 relies on hourly, real time

data.

Method 1:

The first method will be to use the modeled CO emissions in the regional emissions analysis conducted every four years by the Central Lane MPO . If the modeled emissions are above

the modeled baseline year emissions , CO survey monitoring will be started to determine whether the contingency requirements are triggered. Survey monitoring is done with an inexpensive non

- FRM monitor.

Method 2:

T he Portland, SE Lafayette CO monitor will be used as a surrogate. This provides real time monitoring data. If the Portland monitor reaches 1⁄2 the NAAQS

, survey sampling will be

started in Eugene to determine whether the contingency requirements are triggered

. Survey monitoring is done with an inexpensive non

- FRM monitor.

7.3 Alternative trigger for Klamath Falls PM 10 Urban Growth Boundary Contingency trigger requirements:

I n October 2002, the Klamath Falls PM 10 maintenance plan was finalized, installing a contingency plan that said:

Phase 1: Risk of Violation The County and DEQ will reconvene a planning group to develop an action plan if ambient concentrations (actual or estimated) equal or exceed 90% of the NA AQS

concentration of PM 10 (135 μg/m3 for the 24 hour average or 45μg/m3 for an annual average) at Peterson School. The planning group will prepare an action plan that includes a schedule for implementation of additional strategies as necessary to prevent a n exceedance or violation of PM 10 standards. If the high PM 10 concentration was determined to be a natural event based on EPA's policy or an exceptional event, no further action may be needed.

Phase 2: Actual Violation

If a violation of the PM 10 standard occurs and is validated by DEQ, the following contingency measures will automatically be implemented:

The problem: DEQ had to discontinue PM 10 monitoring due to budget cuts and low PM 10 levels . The contingency plan relies on continued PM 10 monitoring to compare to the trigger points.

O DEQ needs to adopt a trigger point based on an alternative pollutant measure.

The Solution : The PM 10 alternative pollutant measure will be to use PM 2.5 monitoring as a surrogate. The

PM 2.5 relationship to P M 10 has been established in recent years with collocated PM 10 and

PM 2.5 monitors. Linear regression analysis was performed on the PM 10 and PM 2.5 data14 14

14 

## Monitoring Discontinuation Justification

(Figure 3) and a linear regression e quation was established (Table 6 ). Using this linear regression equa tion, O DEQ has determined the PM 2.5 concentration needed to trigger the

PM 10 “Risk of Violation” and “Actual Violation” levels discussed above, also shown in

Table 6

.

7.4 Alternative trigger for Grants Pass PM 10 Urban Growth Boundary Contingency trigger requirements: In October 2002, the Grants Pass PM 10 maintenance plan was finalized, installing a contingency plan that said:

“DEQ will convene a planning group if the 24

- hour PM 10 concentration as measured at

the Grants Pass PM 10 monitor equals or excee ds 120μ g/m 3 . The planning group will assess the probable emissions event resulting in the elevated PM 10 level and consider a range of measures with the potential to reduce emissions. However, if a violation of the

24

- hour PM 10 standard occurs, Lowest Ach ievable Emission Rate requirements, plus offsets, for major new industrial sources in the UGB will be restored and the exemption

for offsets eliminated.”

The problem:

O DEQ discontinue d PM 10 monitoring due to budget cuts and low PM 10 levels . The contingency plan relies on continued PM 10 monitoring to compare to the trigger points.

O DEQ needs to adopt a trigger point based on an alternative pollutant measure.

The Solution : The PM 10 alternative pollutant measure will be to use PM 2.5 monitoring as a surrogate. The

PM 2.5 relationship to PM 10 has been established in recent years with collocated PM 10 and

PM 2.5 monitors. Linear regression analysis was performed on the PM 10 and PM 2.5 data (Figure 3 ) and a linear regression equation was established (Tab le 6 ). Using this linear regression equation, DEQ has determined the PM 2.5 concentration needed to trigger the PM 10 trigger of 120μg/m 3 . This is shown in Table 6

.

Table 6

. L inear regression equations and ratios used to estimate PM 10 using PM 2.5

. Klamath Falls Grants Pass Linear Regression Equation y = 1.4 x + 3.2 y = 1.2x + 2.6

PM 2.5 trigger for “Risk of Violation” 94 μg/m 3

PM 2.5 trigger for “Actual Violation” 105 μg/m 3

PM 2.5 trigger for 120 μg/m 3 PM 10 101 μg/m 3

Y = PM 10 , X = PM 2.5

8

. Conclusion

B udget cuts have forced O DEQ and LRAPA to cut CO and PM 10 monitoring where they are required by the maintenance plans for compliance determination and contingency measure triggers. Fortunately, the CO and PM 10 levels are so far below the NAAQS that there is very little probability that the monitors would trigger the contingency plans. Regardless, the maintenance plans need ambient levels for comparison, so alternative methods are needed to

estimate concentrat ions . The alternative contingency plans described in this document will15 15

15 

## Monitoring Discontinuation Justification

allow O DEQ and LRAPA to track CO and PM 10 levels into the future. If levels start trending back up near the NAAQS, funding from other monitoring can be shifted and CO and PM 10 monito rs restarted

. This is very unlikely however.

Finally, monitoring is only required during the first 20 years of the maintenance plan. The monitoring requirement for Eugene/ Springfield CO expire s in 2014 . The monitoring requirements for Medford CO will expire in 2023 and for Grants Pass PM 10 and Klamath

Falls PM 10 , the monitoring requirements will expire in 202 3

.

9

. Reference

1

. Air Quality Conformity Determination, Central Lane MPO FFY10

- 13 Metropolitan Transportation Improvement Program a nd 2007

- 2031 Regional Transportation Plan, October, 2010.

2

. Air Quality Conformity Determination for 2010

- 2013. Metropolitan Transportation Improvement Program & 2009

- 2034 Regional Transportation Plan

– Amended, Rogue Valley MPO, April, 2010.