UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 900 Seattle, WA 98101-3140



# DEC 072011 Mr. Mike Ragan Air Monitoring Coordinator W A Department ofEcology P.O. Box 47600 Olympia, Washington 98504-7600

Dear Mr. 

### Ragan:

We have evaluated the 2011 Washington Ambient Air Monitoring Network Plan, which describes the W A monitoring network for 2011-2012. Following are proposed specific network changes and EPA's responses:
I) Ecology continues to 

### recommend discontinuance ofthe Burbank PM 10 site. Through analysis in the 2010 Network Assessment, the Burbank PM10 site was deemed to be redundant with the Kennewick PM 10 site. These two monitors are located at stations within the same airshed, are about 7 miles apart, and can likely serve as surrogates for each other. Burbankrecords slightly higherconcentrations overall though Kennewick is sometimes higherduring windblown dust events. Ecology also intends to relocate the Burbank meteorology equipment to the Kennewick siLeo Ecology has added a graph to the plan showing the Burbank daily PM 10 

### concentrations from 12/25/2002 

### through 6130120

### II. All exceedances ofthe standard during that period are documentedexceptional events due to high winds. There have been no exceedunces ofthe standard at this site in the past 3 years. Ecology has also added a statement to the plan which reads:

nleKennewick monitorwill rep/ace the BurbankHumitorlor thepurposes oide/erminil1M compliance with the PM10NAAQS ill the Wollu/(llllaime1/o1/ce area, determininM**~lallY** contil1Mency actioll 

### levels are triggered

### il1 the Wallula maintenance area, 

### andmeeting 

### the IJwnitoril1Mprovisions in sections4.4 

### and4.5**(~l**

### the Wallu/a maintenanceplan.



### Response: Ecology has demonstrated a good correlation between the Burbank PM 10 monitor and the Kennewick PM 10 monitor in the discLlssion on pages 1 14 ofthe 20I I network plan. In addition, Ecology added a graph to the plan showing the data trends at this site since the end of2002, and the above statement stating that the Kennewick monitor will "replace" the Burbank monitor for all regulatory purposes. EPA approves this change.

2) The Marysville site has been relocated on the school grounds. The new Marysville site is the result ofan effort to satisfyboth the Marysville School District and Marysville city (codes). The original location was located on a building scheduled for demolition, and therefore no longer viable as a long-term site. DailyPM values at this site have been very close to the NAAQS, thercl"ore Ecology and the Puget Sound Clean Air Agency placed a high value retaining this site on school grounds. Response: EPA approves this change.


# o PrintedonRecycledPaper3) Relocate the Bremerton Meadowdalc site to meet rederalmonitor sitingcriteria. The Meadowdale site is amiddle-neighborhood scale residential site which currentlydoes not meet EPA sitingcriteria. PSCAA plans to relocate Meadowdalc in 20JI. 

### It provides air quality information to a population 

### of280,000 Kitsap residents. Response: EPA approves this change.

4) The EPA RIO Tribal airprogram has recommendcd, and Ecologyconcurs, that thc PM2.S continuous monitorat Usk (on thc Kalispcl rescrvation) be discontinued. Response: EPA approves this change.

5) Ecology's network plan requested discontinuing the Spokane 3rd and Washington carbon monoxide monitorbascd on continucd diminishing CO valucs at that site 

### and the need to reinvest resources in new monitoringefrorts. We have since been informed by Ecology that this site will continue to operate for the immediate future. Please correct the discussion on page 

### 6 ofthe plan about this monitorto say that it will continue to operate.



### In addition, EPA requests that Ecology make the following minorchanges 10 the W A monitoring network in 2012:



### I. 40 CFR Part 58 Appendix A slales that a collocated PM2.5 1110nitor shouldbe at 

### a site that has 

### a design value CDV) within 20% ofthe NAAQS (>28 ug/m3). The 2008-10 DV for Ecology's lone collocated FRM site in Spokane is 25 ugim3, which is outside ofthis 20% range. EPA recommends that Ecology move its PM2.5 collocated monitor to eitherTacoma, Marysville, or Yakima, all which havc DVs within 20% ofthe NAAQS.

2. The Naches and Chelan nephelometers are designatcd as SLAMS, yet the data from these monitors are notbeing entered inlo AQS. Ecology should eitherbegin entering the data from these monitors into AQS, orchange the "monitortype" designation for these monitors to "SPM".

The following monitors are designated "core" monitors because they are either: I)required by40 CFR Part 

### 58, Appendix D, 2) have a design valuc ncaror above the new PM2.5 24-hour standard of 35 ug/m3, or 3) they are NCore pre-cursor gas monitors:



### I. PM2.5 FRMs (or Approved Regional Method): a) Beacon Hill b) Duwamish (primary and co-located) c) Crown Zellerbach (primary and co-located) d)Tacoma/L Street e) Darrington f) Marysville g) Yakama h) Vancouver



# o PrlnteclonRecycledPaper2. PM2.S speciation monitors: a) Seattle, Beacon Hill b) Tacoma, L Street c) Spokane, Ferry Street d) Vancouver,4lh and Plain Boulevard e) Yakima, South4th Avenue

3. Pre-cursorgas monitors a) Beacon Hill NCore site b) Cheeka Peak 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 canbe operated 

### at Ecology's discretion with any remaining federal funds orState funds. 

### Ifyou have any questions about ourapproval ofthe Washington monitoring network, please contact Keith Rose at (106) 553-1949.

Sincerely, 

# !Vi'iJ,lf-­ ()

# IS~ t!{
Debra Suzuki, Manager ) State and Tribal AirProgram 

### Unit

cc: Chris Hall, OEA Keith Rose, OAWT JeffHunt, OAWT



# o PrintedonRecycledPaper