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 of Ecology 

P.O. Box 47600 

Olympia, Washington 98504-7600 

Dear M r. 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 of the Burbank PM 10 site. Through 

analysis in the 2010 Network Assessment, the Burbank PM 10 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. 

Burbank records slightly higher concentrations overall though Kennewick is sometimes 

higher during 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 of the standard during that period are documented exceptional events due to 

high winds. There have been no exceedunces of the standard at this site in the past 3 years. 

Ecology has also added a statement to the plan which reads: 

nle Kennewick monitor will rep/ace the Burbank Humitorlor the purposes oide/erminil1M 

compliance with the PM10 NAAQS ill the Wollu/(llllaime1/o1/ce area, determininM ~lallY 

contil1Mency actioll levels are triggered il1 the Wallula maintenance area, and meeting the 

IJwnitoril1M provisions in sections 4.4 and 4.5 (~l the Wallu/a maintenance plan. 

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 of the 20 I I network 

plan. In addition, Ecology added a graph to the plan showing the data trends at this site since 

the end of 2002, 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 of an effort to satisfy both 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. Daily PM 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 Printed on Recycled Paper 
3) 	 Relocate the Bremerton Meadowdalc site to meet rederalmonitor siting criteria. The 


Meadowdale site is a middle-neighborhood scale residential site which currently does not 


meet EPA siting criteria. PSCAA plans to relocate Meadowdalc in 20 J I. It provides air 


quality information to a population of 280,000 Kitsap residents. 


Response: EPA approves this change. 


4) 	 The EPA RIO Tribal air program has recommendcd, and Ecology concurs, that thc PM2.S 

continuous monitor at 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 monitor bascd on continucd diminishing CO valucs at that site and the need to 

reinvest resources in new monitoring efrorts. 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 of the plan about this monitor to say that it will continue to operate. 

In addition, EPA requests that Ecology make the following minor changes 10 the W A monitoring 

network in 2012: 

I. 	 40 CFR Part 58 Appendix A slales that a collocated PM2.5 1110nitor should be at a site that has a 

design value CDV) within 20% of the NAAQS (>28 ug/m3). The 2008-10 DV for Ecology's 

lone collocated FRM site in Spokane is 25 ugim3, which is outside of this 20% range. EPA 

recommends that Ecology move its PM2.5 collocated monitor to either Tacoma, Marysville, or 

Yakima, all which havc DVs within 20% of the NAAQS. 

2. 	 The Naches and Chelan nephelometers are designatcd as SLAMS, yet the data from these 

monitors are not being entered inlo AQS. Ecology should either begin entering the data from 

these monitors into AQS, or change the "monitor type" designation for these monitors to 

"SPM". 

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

CFR Part 58, Appendix D, 2) have a design valuc ncar or 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 Prlntecl on Recycled Paper 
2. PM2.S speciation monitors: 

a) Seattle, Beacon Hill 

b) Tacoma, L Street 

c) Spokane, Ferry Street 

d) Vancouver,4lh and Plain Boulevard 

e) Yakima, South 4th Avenue 

3. Pre-cursor gas 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 can be operated at 

Ecology's discretion with any remaining federal funds or State funds. If you have any questions 

about our approval of the Washington monitoring network, please contact Keith Rose at 

(106) 553-1949. 

Sincerely, 

!Vi'iJ,lf-­ () IS~ t!{ 

Debra Suzuki, Manager ) 

State and Tribal Air Program Unit 

cc: Chris Hall, OEA 

Keith Rose, OAWT 

Jeff Hunt, OAWT 

o Printed on Recycled Paper