San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement Annual Air Monitoring Network Plan 

### APPENDIX C:

Bakersfield-Golden AMS Closure and ReplacementSan Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement Annual Air Monitoring Network Plan This page is intentionally blank.San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-1 Annual Air Monitoring Network Plan In December 2009, the District was forced to close the Bakersfield-Golden State Highway (Bakersfield-Golden) air monitoring site (A MS) due to the expansion of Golden State Highway (compromising the siting criteria for proper distance from a roadway) and subsequent loss of the air monitoring site lease at the request of the landowner. This Appendix provides further information regarding the relocation, as outlined under 40
CFR Part 58.

40 CFR Part 58.14 paragraphs (c), and (c)(6), state that requests for discontinuation of a SLAMS monitoring station may be approved on a cas e-by-case basis if it does not compromise the data collection needed for compariso n to the NAAQS and that the requirements listed in Appendix D of 40 CFR Part 58 continue to be met. A SLAMS monitor that is not eligible for removal under any of the criteria listed in 40 CFR Part 58, can be moved if logistical problems beyond the Stat e’s control make it impossible to continue operating at the current site. When that i s the case, the SLAMS monitor may be moved to a nearby location with the same scale o f representation. The District has
met both of these conditions in the closure of Bake rsfield-Golden.

The Bakersfield-Golden site was shut down due to te rmination of the lease by the landowner and highway expansion which would directl y impact the siting criteria for the station. The District notified and kept EPA and CA RB fully informed throughout the entire siting and relocation process via telephone calls and in the appropriate Network Plans. After an exhaustive effort, the Bakersfield -Golden monitoring site was relocated to the Bakersfield-Municipal Airport (Bakersfield-M uni) location.

The Bakersfield-Golden monitoring site operated fro m June 1994 until December 2009 and served primarily as a PAMS Type 2 site. PM10 e quipment was installed in 1994 and PM2.5 equipment was installed in 1999. As Tabl e 1 below shows, over the past five years, this site is not the design value site for ozone, PM2.5, or PM10 for the Bakersfield MSA which comprises the entire county o f Kern. Additionally, the District is able to meet or exceed minimum NAAQS monitoring req uirements for each of those pollutants without this site being operational as s hown in Table 2. 1

1 Monitors from both the District and the Eastern Ker n County Air Pollution Control District can be coun ted in determining compliance with minimum monitoring requ irements for the Bakersfield MSA. However, only mo nitors
located within the District’s boundaries are includ ed in this network plan.San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-2 Annual Air Monitoring Network Plan Table 1 Design Value Comparisons for Kern County

1-hour Ozone Design Values (ppb)

Monitoring Site 2005-2007 2006-2008 2007-2009 2008-2010 2009-2011
Arvin-Di Giorgio - - - 120 118

Arvin-Bear Mountain 131 135 135 139

Bakersfield- California Ave 117 120 117 114 111

Bakersfield-Golden State 108 110 - - -

Edison 135 136 135 134 124
Maricopa 100 97 97 97 102

Oildale 112 114 112 110 102

Shafter 105 106 106 106 102
8-hour Ozone Design Values (ppb)
Monitoring Site 2005-2007 2006-2008 2007-2009 2008-2010 2009-2011
Arvin-Di Giorgio - - - - 73

Arvin-Bear Mountain 107 108 105 104 -

Bakersfield-California Ave 97 97 90 93 88

Bakersfield-Golden State 86 88 87 - -

Edison 99 102 99 101 96
Maricopa 88 86 85 85 88

Oildale 95 98 93 94 89

Shafter 88 89 85 88 85

24-hour PM10 Design Values ( μ g/m 3 )

Monitoring Site 2005-2007 2006-2008 2007-2009 2008-2010 2009-2011

Bakersfield-California Ave 115 122 94.5 99 108

Bakersfield-Golden State 103 142 104 - -

Oildale 104 107 117.5 88.6 100.2

24-hour PM2.5 Design Values ( μ g/m 3 )

Monitoring Site 2005-2007 2006-2008 2007-2009 2008-2010 2009-2011

Bakersfield-Golden 69 64 66 - -

Bakersfield-California Ave 66 66 68 62 62

Bakersfield-Planz 68 70 70 65 55

Annual PM2.5 Design Values ( μ g/m 3 )

Monitoring Site 2005-2007 2006-2008 2007-2009 2008-2010 2009-2011

Bakersfield-Golden 19.2 18.8 19.3 - -

Bakersfield-California Ave 19.6 20.9 21 18.4 16.5

Bakersfield-Planz 20.3 21.5 22.6 21.2 18.2San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-3 Annual Air Monitoring Network Plan Table 2 Summary of Monitoring Requirements and Curr ent Monitoring Sites

in the District portion of Kern County

Pollutant/Program Required # of
Sites Current # of

Sites State and Local Air Monitoring Stations (SLAMS )
Ozone 2 6
PM10 2-4 2
PM2.5 2 2

The Bakersfield-Muni site is intended to be a long term site that will serve as the replacement PAMS Type 2 site for Bakersfield-Golden (measuring ozone, NO2, and other PAMS compounds). PAMS stations can be used t o meet minimum monitoring requirements, if the site meets NAAQS siting criter ia for that pollutant. The ozone, carbon monoxide, and nitrogen dioxide analyzers req uired as part of the PAMS program may be used for regulatory purposes after two years of operation provided the site meets NAAQS siting criteria for each of pollutants. Currently, the site does not meet NAAQS siting criteria for CO (near-road) and it doe s not meet NAAQS siting criteria for NO2 (area-wide, near-road, or RA40).

Finding an appropriate replacement location took a considerable amount of time and staff effort (approximately two years) and proved v ery difficult. The District was unsuccessful in finding a location within a couple of kilometers of the BakersfieldGolden site, so the siting radius was expanded whic h enabled the District to find a suitable location approximately 6 km away. The Bak ersfield-Muni site is located at the northern end of the Municipal Airport in a light co mmercial/industrial area downwind from freeways, which is similar to the Bakersfield- Golden site’s location.

Construction of the site was also delayed in order to obtain the proper operating permits from the Federal Aviation Administration (FAA), app roval from the City of Bakersfield, and electrical power installed. Once power was ins talled, construction of the platform to support the air quality monitoring equipment commen ced and installation of the necessary equipment both inside the shelter and on the platform followed. Since the structure and power at Bakersfield-Golden have been removed and the site is closed, it is impossible to conduct parallel monitoring. As m ore data becomes available at the new Bakersfield-Muni site, the District will conduc t ongoing comparative evaluation of the various Bakersfield monitoring sites.San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-4 Annual Air Monitoring Network Plan PAMS Program

EPA’s PAMS program is designed to provide enhanced information of ozone and its precursors to aid in modeling and development contr ol strategies for Serious, Severe, and Extreme non-attainment areas. The speciated VOC equipment for PAMS and the PAMS related meteorological equipment became operat ional at Bakersfield-Muni AMS in June 2012. The station’s carbonyl and meteorolo gical equipment for PAMS began operating in July 2012. The NMHC equipment was ins talled in October 2012. Table 3 below compares the PAMS PAMS Type 2 equipment at th e Bakersfield-Golden site to
the Bakersfield-Muni site. Method code refers to t he actual measurement method each piece of equipment.

Table 3 Bakersfield-Golden and Bakersfield-Muni Com parison Table

Site Latitude Longitude
Bakersfield

- Golden 35.385269 119.014733
Bakersfield

- Muni 35.331572 118.999995

Parameters Site Sampling Schedule Method Code

Golden Muni Golden Muni Golden Muni
Ozone x x 087 087
CO x x 054 054
NO x x 074 074
NO2 x x 074 074
NOx x x 074 074

Speciated-VOC x x 1:3 (Seasonal) 1:3

(Seasonal) 011 011

NMHC x x 011 011

Carbonyls x x 1:3 (Seasonal) 1:3

(Seasonal) IT x x 014 014

OT x x 040 040

BPR x x 014 014

WS x x 020 020

WD x x 020 020

RH x x 011 011

SRAD x x 011 011

PM10 and PM2.5 Monitoring

The District already meets the minimum monitoring r equirements in Kern County
without the PM10 and PM2.5 monitors at the Bakersfi eld-Muni site. The District attempted to utilize the air monitoring station to monitor both PM10 and PM2.5 to provide information for forecasting, in addition to conducting monitoring as a PAMS Type 2 site. Installation and initial operation o f the PM monitoring equipment began in July 2012. However, it soon became apparent that t his site was not acceptable as a PM10 and PM2.5 site because site specific emissions from nearby sources were impacting the site, and the site was therefore not measuring ambient particulate
concentrations.San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-5 Annual Air Monitoring Network Plan Under federal regulation, the purpose of particulat e matter monitoring sites is to capture ambient (or neighborhood level) air quality. The si ting requirements for both PM10 and PM2.5 state that the ideal monitoring site for thes e pollutants is of “neighborhood scale”. For PM10, the regulation states, in part,

(b) Although microscale monitoring may be appropria te in some circumstances, the most important spatial scales to effectively ch aracterize the emissions of
PM 10 from both mobile and stationary sources are the mi ddle scales and neighborhood scales. (Appendix D to Part 58 4.6 (b) )

Likewise, for PM2.5, the regulation states in part,

(b) Specific Design Criteria for PM 2.5 . The required monitoring stations or sites must be sited to represent community-wide air quali ty. These sites can include sites collocated at PAMS. These monitoring stations will typically be at neighborhood or urban-scale; however, in certain in stances where populationoriented micro-or middle-scale PM 2.5 monitoring are determined by the Regional Administrator to represent many such locations thro ughout a metropolitan area, these smaller scales can be considered to represent community-wide air quality. (Appendix D to Part 58 4.7 (b))

After building the site, problems with the site loc ation became apparent. During detailed surveillance of the area (particularly during perio ds of peak emissions readings), the District discovered that nearby sources, including regular airport operations, were impacting PM levels at the site. For example, acti vities such as street sweeping, taxiing of aircraft, and soil disking were causing PM to be entrained immediately adjacent to or near the site. Figure 1 shows the location of the site from an aerial perspective. Figures 2 through 5 show nearby sources from variou s directions. Figures 6 through 11 are pictures that show sources of dust near the sit e that is impacting both PM10 and
PM2.5 concentrations.

The Bakersfield-Muni AMS is surrounded by asphalt a nd the District is now aware that street sweeping activities occur regularly next to and around the structure. While conducting surveillance of the area, District staff observed a layer of dust coating flat surfaces at site. The plume generated by the stree t sweeper does not impact adjacent property owners but it directly impacts the Bakersf ield-Muni AMS because the plume generated by the street sweeper engulfs the site. When this occurs, the analyzer measures the plume from the street sweeper (a point source) rather than the ambient air. Additionally, taxiways are nearby and planes using them entrain dust as they go by.

Vacant land that occupies areas within and surround ing the airport is comprised of very fine, silty soil. Over 60% of this native soil con sists of particles between 5 and 50 microns in diameter. Such areas on the airport pro perty that are next to the BakersfieldMuni AMS are routinely disked and mowed for weed co ntrol abatement which causes a considerable of dust to be deposited on the runway, taxiways, and other asphalt surfaces. Additionally some of the light industria l and commercial businesses locatedSan Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-6 Annual Air Monitoring Network Plan adjacent to the airport have large unpaved areas th at can contribute to PM levels in the

area.

In addition to the visual observations of the nearb y sources, the District also installed additional PM monitoring equipment to help confirm that the aforementioned activities led to higher PM10 and PM2.5 measurements than woul d be normally found in ambient air, and to verify the that the suspect analyzers w ere operating properly. Through the extensive efforts of District staff, it was determi ned that this site was measuring nearby sources rather than measuring ambient air. Therefo re, the site does not represent a “neighborhood scale” PM site and does not qualify a s a SLAMS site due to near-source emission impacts that were unknown at the time of i nitial installation.

Given the PM10 and PM2.5 measurements at this site were not representative of ambient air quality and the PM monitors are not req uired regulatory monitors, the District removed the PM analyzers at the Bakersfiel d-Muni AMS and is seeking another location in which to place them for continued forec asting support. Additionally, there is a nearby air monitoring site (Bakersfield-Planz) th at currently measures PM2.5 concentrations in the Municipal Airport area. The District will continue to operate the Bakersfield-Muni AMS for PAMS Type 2 purposes and w ill continue monitoring gaseous pollutants.

Next Steps

After the District determined that the site was not suitable to measure PM10 and PM2.5, the District began the search for a replacement sit e. During its investigation, the District discovered that the planned road expansion of Golde n State Highway, which caused the closure of the original Bakersfield-Golden AMS, did not take place and the prior location would still meet appropriate siting criter ia. Therefore, the District may be able to locate the replacement site at or near the old B akersfield-Golden air monitoring site, which would be the preferred option since there is almost 15 years of air monitoring data that already exists for that area in Bakersfie ld. In fact, the District is now in talks with Kern County to place these two analyzers on th e property where the previous
Bakersfield-Golden AMS was sited. If the recommend ed location on the property meets appropriate siting criteria, the new PM site will b e 40 feet away from the original site. If this location is determined to be infeasible, the D istrict will continue its search for a new
site.San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-7 Annual Air Monitoring Network Plan Figure 1: Aerial View of Bakersfield-Municipal Site

Figure 2: Looking North from the ProbeSan Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-8 Annual Air Monitoring Network Plan Figure 3: Looking East from the Probe

Figure 4: Looking South from the ProbeSan Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-9 Annual Air Monitoring Network Plan Figure 5: Looking West from the Probe

Figure 6: Panoramic view of asphalt that is regular ly cleaned by street

sweepers adjacent to the site.San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-10 Annual Air Monitoring Network Plan Figure 7: Additional photo of asphalt that is regul arly cleaned by street

sweepers adjacent to the site.

Figure 8: Dirt and debris near the site, in areas t hat the street sweeper cannot

reachSan Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-11 Annual Air Monitoring Network Plan Figure 9: Looking south east from the probe. Unpav ed areas that are disked

and mowed to keep the area weed free. Much of the airport property is unpaved.

Figure 10: A disking operation being conducted on o ne of the large unpaved

areas. Due to the sun angle, the plume is almost n ot visible.San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix C: Bakersfield-Golden AMS Closure and Repl acement C-12 Annual Air Monitoring Network Plan Figure 11: Visible dust plume from disking operatio n

.