UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


REGION 10 


1200 Sixth Avenue, Suite 900 

Seattle, WA 98101-3140 

or SEP 062011 /,Jrt vVJ\ST[. i\i\-!fJ TOXiCS

Mr. Bruce Louks 

Air Quality Manager 

Idaho Department of Environmental Quality 

1410 North Hilton 

Boise, Idaho 83706-1255 

Dear Mr. Louks: 

We have evaluated the 20 II Idaho Ambient Air Monitoring Network Plan, which describes the Idaho 

monitoring network for 2011-12. The EPA has the followi ng comments on proposed changes to the 

network in this network plan: 

I. 	 PM 10-2.5 monitoring (PMcoarse) was initiated at the Meridian St. Luke's NCore site on 1/1/20 II 

(160010010). IDEQ is operating three lo-vol R&P 2025 FRM samplers for PM 10-2.S 

determinations. One sampler is configured to capture PM2.5 and the other to capture PM 10. The 

primary pair of PM2.5 and PM 10 samplers run every third day (1/3) and the second PM 10 sampler 

runs every twelfth day (1/12) to assess the lo-vol PM 10 precision. PM 10-2.5 is calculated by 

difference of PM 10 PM2.5. The EPA approves this change. 

2. 	 The Met One BAM 1020 PM2.S monitor was terminated at the S1. Maries (1600900 I 0) site on 

09127/2010. It was replaced by a PM2.5 TEOM. IDEQ evaluated the relationship of the BAM 24­

hour data to the filter data collected on the FRM over a one year period. The relationship did not 

meet the statistical criteria for a Class III FEM (40 CFR Part 53.35). Because the BAM is designated 

FEM by the EPA, and following the evaluation period allowed by the EPA for IDEQ to perform this 

assessment, the data would then become regulatory data and used for determining NAAQS 

compliance. IDEQ decided to continue utilizing the FRM filter-based method as the primary 

regulatory monitor at this site and redeploy a PM2.5 continuous monitor for air quality forecasting 

and AQI determinations. The EPA approves this change. 

3. The Met One BAM at the Pinehurst (160790017) site was terminated on 12/3112010 for the same 

reason stated above. IDEQ chose to designate the TEOM-FDMS the primary monitor at the Pinehurst 

site and report daily (III) 24-hour averaged data, initiated on 11112011. The TEOM-FDMS is an 

FEM and data can be used for determining NAAQS compliance in addition to air quality forecasting 

and AQI. IDEQ evaluated the relationship of the TEOM-FDMS 24-hour data compared to the filterbased FRM values over a period of one year, and the statistical criteria for Class III FEM monitors 

was satisfIed. The two co-located filter-based FRM PM2.S monitors at this site are running every 

sixth day in order to assess precision for IDEQ's PM2.5 FRM network. The EPA approves this 

change. 

4. The Met One BAM at the Sal mon site (160590004) was designated as the primary monitor for the 

purpose of daily sampling for NAAQS compliance, in addition to air quality forecasting and AQI. 

The PM2.S FRM is operating on a 1/6 schedule for determining precision of the BAM 24-hollf 

averaged PM2.S data. The EPA approves this change. 

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5. 	The Met One BAM at the Nampa Fire Station (160270002) site was terminated on 9/30/2010 for the 

reason stated above. The existing PM2.5 TEaM will continue to be used for the purpose of air 

quality forecasting and AQI determination. The EPA approves this change. 

6. 	The Met One BAM at the Meridian St. Luke's site (160010010) was terminated on 12/30 2010 for 

the reason stated above. The existing PM2.5 TEaM will continue to be used for the purpose of air 

quality forecasting and AQI determination. The EPA approves this change. 

7. 	 Other comment: IDEQ has within their network 17 SPM "NR" (non-regulatory) PM2.5 samplers (16 

TEOMs and I BAM) that are non-FRM and non-FEM. Over the past couple years TDEQ had been 

evaluating a number of BAMs at different sites and determined in most cases that they do not meet 

Class III FEM status, therefore IDEQ is replacing them with TEaMs. For most all of these sites the 

use of a non-FRM, or non-FEM, sampler is appropriate for non-regulatory purposes (such as AQI 

and burn ban purposes). However, of all these PM2.5 monitors, the only monitor that the EPA 

recommends to be an FRM, or FEM continuous PM2.5 monitor, is the PM2.5 monitor at the 

Meridian NCore site, since it would be desirable to compare the PM2.5 values measured at this site 

to the NAAQS. 

The following monitors are designated "core" monitors because they are either: I) required by 40 CFR Part 

58, Appendix 0, 2) have a design value near or above the new PM2.5 24-hour standard of 35ug/m3, or 3) 

they are essential monitoring parameters at NCore sites: 

I. 	 PM2.5 FRMs (or Approved Regional Method): 

a) Nampa (primary and co-located) 

b) Meridian/St. Luke's Hospital 

c) Pinehurst 

d) Salmon 

e) Franklin 

f) St Maries 

2. 	 PM2.5 speciation monitors and pre-cursor gas monitors at the Meridian/St. Luke's Hospital NCore 

site. 

"Core" monitors are those monitors in the network that must be operated with available PM2.5 

monitoring funds. The "non-core" PM2.5 monitors in the State's network can be operated at IDEQ's 

discretion with any remaining federal funds or State funds. If you have any questions about our approval 

of the Idaho monitoring network, please contact Keith Rose at (206) 553-1949. 

Sincerely, 

Robert Elleman, Acting Unit Manager 

State and Tribal Air Programs Unit 

cc: 	 Mike McGown, lao 

Keith Rose, OA WT 

Chris Hall, OEA 

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