2018 Annual Network Plan for Ambient Air Monitoring

Transcription

1 2018 Annual Network Plan for Ambient Air Monitoring July 1, 2018 North Coast Unified Air Quality Management District 707 L Street, Eureka, CA (707)

2 Contents Contents... 2 Definition of Terms... 3 Executive Summary... 4 Network Design... 5 Table 1. List of Special Purpose Monitoring Sites... 5 Table 2. List of State and Local Air Monitoring Sites... 5 Table 3. List of Instruments Proposed for Shutdown... 5 Table 4. List of Instruments Proposed for Replacement... 5 Monitoring Station Locations... 6 Jacobs Monitoring Station...6 Humboldt Hill Monitoring Station...7 Crescent City Monitoring Station...8 Weaverville Monitoring Station...9 Minimum Monitoring Requirements Ozone Table 5. Minimum Monitoring Requirements for Ozone Sites PM Table 6. Minimum Monitoring Requirements for SLAMS PM2.5. Sites Table 7. Minimum Monitoring Requirements for Continuous PM2.5 Sites Table 8. Collocation of continuous PM2.5 monitors PM Table 9. Minimum Monitoring Requirements for PM10 Sites NO Table 10. Minimum Monitoring Requirements for NO2 Monitors SO Table 11. Minimum Monitoring Requirements for SO2 Monitors CO Table 12. Minimum Monitoring Requirements for CO Monitors Lead (Pb) Table 13. Minimum Monitoring Requirements for Pb Quality Control Collocation Recent or Proposed Modifications to Network Review of Changes to PM2.5 Monitoring Network Page 2 of 35

3 Data Submission Requirements Data Availability Detailed Site Information Site Name: Jacobs...18 Site Name: Humboldt Hill...21 Site Name: Weaverville...24 Site Name: Crescent City...26 ATTACHMENT A Waiver Request for an FEM PM2.5 Grimm 180 located at Humboldt Hill Station Review of Network...28 Review of data comparability of the PM2.5 continuous monitors...28 Waiver Request...28 PM2.5 Continuous Monitor Comparability Assessment...29 ATTACHMENT B Jacobs Station Relocation Documents NCUAQMD request letter:...30 EPA Response/Approval Letter:...35 Definition of Terms AAC Atmospheric Analysis and Consulting AQI Air Quality Index AQS Air Quality System BAAQMD Bay Area Air Quality Management District CARB California Air Resources Board E-BAM Emergency Beta-Attenuation Monitor FEM Federal Equivalency Method FRM Federal Reference Method MSA Micropolitian Statistical Area NAAQS National Ambient Air Quality Standards NOAA National Oceanographic and Atmospheric Administration NCUAQMD North Coast Unified Air Quality Management District POC Parameter Occurrence Code PQAO Primary Quality Assurance Organization SIP State Implementation Plan SLAMS State and Local Air Monitoring Station SOP Standard Operating Procedure SPM Special Purpose Monitor TRS Total Reduced Sulfur Page 3 of 35

4 Executive Summary Title 40, Code of Federal Regulations, Part (40 CFR 58.10) requires the annual review of governmental air monitoring networks. The North Coast Unified Air Quality Management District s (NCUAQMD) 2018 Annual Network Plan for Ambient Air Monitoring is an examination of the NCUAQMD s network of ambient air pollution monitoring stations. This report meets the requirements for an annual network plan as listed in 40 CFR 58.10, Appendix A. The NCUAQMD is located in the northwestern portion of California, covering a territory of 7,753 square miles. This area is made up of varied terrain, from coastal wetlands to rugged mountains. Inversions and diurnal offshore wind patterns are common. The NCUAQMD is bordered on the west by the Pacific Ocean and extends from the Oregon Border south approximately 140 miles to the Mendocino County line. It has jurisdiction over three counties: Humboldt, Del Norte, and Trinity. The NCUAQMD office is located in Eureka, the county seat of Humboldt County. Eureka is 284 miles north of San Francisco, 466 miles south of Portland, Oregon and on the coast of the Pacific Ocean. Except for non-attainment of the California State 24-hour PM10 standard in Humboldt County, the air in Humboldt, Del Norte and Trinity County is considered to be either unclassified, or in attainment of State and Federal Standards. All Title V sources in the NCUAQMD jurisdiction are located in Humboldt County: Humboldt Redwood Company (Scotia), PG&E Humboldt Bay Generating Station (Eureka), DG Fairhaven (Samoa), and the Blue Lake Power LLC (Blue Lake). In addition to these major sources, the NCUAQMD is impacted by several large saw mills, minor industrial sources, and mobile sources throughout the traffic corridors. Wildfire events have the potential of heavily impacting NCUAQMD air quality. The two pollutants of greatest concern in the NCUAQMD jurisdiction are ozone and particulate matter. The NCUAQMD air monitoring network was initiated nearly six decades ago because of concerns about practices at pulp mills in the area. Total Reduced Sulfur started to be monitored in the 1970s at Fort Humboldt. Numerous special studies, including speciation, have occurred around Humboldt Bay. The very first time the California Air Resources Board (CARB) mobile monitoring trailer was deployed it was to Humboldt County to investigate concerns around the Humboldt Flakeboard Panel plant in Arcata. Beginning in 1986, PM10 monitoring began with a solitary PM10 monitoring sampler in Eureka. Currently the NCUAQMD operates four air monitoring stations at sites within the jurisdiction. This report will be available for a 30-day public inspection period. Any comments received during the public inspection period will be forwarded to the United States Environmental Protection Agency (EPA) concurrently with submittal of the plan. Changes suggested in the comments will be addressed in subsequent plan updates. This report may be viewed on the NCUAQMD s website, and hard copies are available for review at the NCUAQMD office. Written comments should be submitted to the North Coast Unified Air Quality Management District, Attn: Comments on Annual Network Monitoring Plan, 707 L Street, Eureka, California, Page 4 of 35

5 Network Design The NCUAQMD operated four monitoring sites in The following maps show the locations of the monitoring sites. Tables 1 and 2 list the pollutants measured at each site. Table 1. List of Special Purpose Monitoring Sites Site Name AQS Site # Pollutant Monitored Humboldt Hill PM2.5, O3, NO2, CO, SO2 Crescent City PM2.5 Table 2. List of State and Local Air Monitoring Sites Site Name AQS Site # Pollutants Monitored Jacobs PM10, PM2.5, O 3, NO 2, CO, SO 2 Weaverville PM2.5 Several instruments are proposed for shutdown or relocation or replacement in The instruments proposed for shutdown are shown in Table 3. The instrument proposed for replacement is listed in Table 4. Table 3. List of Instruments Proposed for Shutdown Site Name AQS Site # Instrument Humboldt Hill Thermo 2000i, Grimm 180 PM2.5, Thermo 48i CO, Thermo 43i SO 2, Thermo 42i NO 2, Thermo 49i O 3 Table 4. List of Instruments Proposed for Replacement Site Name AQS Site # Instrument Crescent City Grimm 180 Page 5 of 35

6 Monitoring Station Locations Jacobs Monitoring Station (717 South Ave, Eureka, Humboldt County) Page 6 of 35

7 Humboldt Hill Monitoring Station (7333 Humboldt Hill Rd., Eureka, Humboldt County) Page 7 of 35

8 Crescent City Monitoring Station (994 G Street, Crescent City, Del Norte County) Page 8 of 35

9 Weaverville Monitoring Station (11 Court Street, Weaverville, Trinity County) Page 9 of 35

10 Minimum Monitoring Requirements This network meets the minimum monitoring requirements for all criteria pollutants (Tables 5-11). Ozone Table 5. Minimum Monitoring Requirements for Ozone Sites. Micropolitan Statistical Area (MSA) County Pop. In Year th highest 8- hour max. (ppm) ( ) 3-year design value SLAMS Ozone Sites Required Active SLAMS Ozone Sites Active Ozone SPMs Sites Needed Eureka, Arcata, Fortuna Humboldt 134,623 Jacobs Humboldt Hill Jacobs Humboldt Hill Crescent City Del Norte 28, none Trinity 13, Ozone monitors are not required by either a SIP or Maintenance Plan. The NCUAQMD monitors Ozone as an examination of population exposure levels. Page 10 of 35

11 PM 2.5 Table 6. Minimum Monitoring Requirements for SLAMS PM2.5. Sites. Micropolitan Statistical Area County Pop. In Year 2010 Annual Design Value ( g/m 3 ) ( ) Daily Design Value ( g/m 3 ) ( ) FRM Sites Required SLAMS Sites Active SPM Sites Active Sites Needed Eureka, Arcata, Fortuna Humboldt 134,623 Jacobs 6.8 Jacobs 20.5 Humboldt Hill 5.9 Humboldt Hill Crescent City Del Norte 28, none Trinity 13, Since NCUAQMD has no required FRM PM2.5 sites, it is not necessary to identify the maximum concentration PM2.5 site. Table 7. Minimum Monitoring Requirements for Continuous PM2.5 Sites. Micropolitan Statistical Area County Pop. In Year 2010 SLAMS FEM Sites required SLAMS Sites Active SPM Sites Active Eureka, Arcata, Fortuna Humboldt 134, * Crescent City Del Norte 28, * none Trinity 13, * Grimm 180 Table 8. Collocation of continuous PM2.5 monitors POC designations Method Code # Primary Monitors Required NCUAQMD operated collocated monitors Active NCUAQMD operated collocated FRM monitors Active Collocated FEM Monitors Collocation is the responsibility of the Primary Quality Assurance Organization (PQAO). The NCUAQMD works with the CARB PQAO to assist wherever possible. PM2.5 monitors are not required by either a State Implementation Plan (SIP) or Maintenance Plan. Page 11 of 35

12 PM10 Table 9. Minimum Monitoring Requirements for PM10 Sites. Micropolitan Statistical Area County Population in Year 2010 Max Concentration ( ) (ug/m 3 ) SLAMS Sites Required SLAMS Sites Active SPM Sites Active Sites Needed Eureka, Arcata, Fortuna Humboldt 134,623 Jacobs Crescent City Del Norte 28, none Trinity 13, Additional PM10 monitors are not required by either a SIP or Maintenance Plan. NO2 Table 10. Minimum Monitoring Requirements for NO2 Monitors. Micropolitan Statistical Area Eureka-Arcata, Fortuna County Population. in Year 2010 Humboldt 134,623 Annual Design Value (ppb) ( ) Jacobs 2.6 Humboldt Hill 0.1 SLAMS Monitors Required Active SLAMS Monitors Active SPM Monitors Monitors Needed Crescent City Del Norte 28, none Trinity 13, NO2 monitors are not required by either SIP or Maintenance Plan. The NCUAQMD monitors NO2 in Humboldt County to examine population exposure. Based on population, near-road NO2 monitors are not required within NCUAQMD boundaries. Page 12 of 35

13 SO2 Table 11. Minimum Monitoring Requirements for SO2 Monitors. Micropolitan Statistical Area County Pop. in Year 2010 Annual Design Value (ppb) ( ) Max 24 hour (ppb) ( ) Max 1 hour (ppb) ( ) SLAMS Monitors Required Active SLAMS Monitors Active SPM Monitors Monitors Needed Eureka, Arcata, Fortuna Humboldt 134,623 Jacobs 0.1 Humboldt Hill 0.0 Jacobs 0.8 Humboldt Hill 0.3 Jacobs 3.0 Humboldt Hill Crescent City Del Norte 28, none Trinity 13, SO2 monitors are not required by either a SIP or Maintenance Plan. The NCUAQMD monitors SO2 in Humboldt County to examine population exposure. CO Table 12. Minimum Monitoring Requirements for CO Monitors. Micropolitan Statistical Area County Pop. in Year hour Design Value (ppm) ( ) 1 hour. Design Value ( ) SLAMS Monitors Required Collocated Monitors Required Active SLAMS Monitors Active SPM Monitors Monitors Needed Eureka, Arcata, Fortuna Humboldt 134,623 Jacobs 1.7 Humboldt Hill 2.2 Jacobs 2.2 Humboldt Hill Crescent City Del Norte 28, none Trinity 13, CO monitors are not required by either a SIP or Maintenance Plan. The NCUAQMD monitors CO in Humboldt County to examine population exposure. Page 13 of 35

14 Lead (Pb) Table 13. Minimum Monitoring Requirements for Pb. Micropolitan Statistical Pop. In Annual County Area Year 2010 Design Value Eureka, Arcata, Monitors Required Active Monitors Monitors Needed Humboldt 134, Fortuna Crescent City Del Norte 28, none Trinity 13, The NCUAQMD is not required to monitor Lead (Pb) as monitors are not required by either a SIP or Maintenance Plan. Quality Control The NCUAQMD is a member of the CARB Primary Quality Assurance Organization (PQAO). All NCUAQMD ambient air monitoring meet CARB Quality Control and Quality Assurance requirements. CARB audit records and site information for the NCUAQMD can be found on the CARB website or obtained by contacting the NCUAQMD at (707) The NCUAQMD s PM2.5 FRM filters are analyzed by the Bay Area Air Quality Management District (BAAQMD). The BAAQMD Laboratory meets Federal Requirements for Quality Control and Quality Assurance. Information regarding the laboratory can be found on the BAAQMD website. Collocation The NCUAQMD is a member of the CARB PQAO and relies on the PQAO network to satisfy all collocation requirements (CFR 58 App A 3.2.5). The NCUAQMD does not have any permanently collocated PM2.5 samplers. It currently operates one collocated FRM PM2.5 sampler. A FEM Grimm 180 (AQS# POC 1) has been collocated with an FRM Thermo 2000 instrument (AQS# POC 2) since March 2013 at the Humboldt Hill station for the purpose of evaluating the performance of the Grimm 180. The FRM is labeled the Primary instrument. A waiver request for the Grimm 180 at Humboldt Hill, for the time period January 2016 through December 2017 is attached. Two different Grimm instruments operated at the Humboldt Hill Station during this time period: Grimm 180 S/N #18A11018 was used from January 2016 to May 2016, and Grimm 180 S/N #18A10013 was used from May 2016 through December Because waivers are issued for a site, rather than an instrument, data from both instruments has been combined to meet the number of data pairs required for the current Comparability Assessment. The EPA hosted a Grimm users group call in December of 2016 to discuss issues with the Grimm in the hopes of improving Grimm 180 data quality. All entities reporting method code 195 to the AQS system in 2016 were invited to the call. Unfortunately, there were no rectifiable operational causes identified for the poor performance of NCUAQMD s Grimm units. A flow problem is one possible reason for the low correlation between NCUAQMD FRM data, and Grimm data. Unfortunately, there is no way to assess the flow of the Grimm Page 14 of 35

15 during sampling, thus there is no way for NCUAQMD to determine if this is the problem nor to find a way to rectify this potential problem. The NCUAQMD operates a monitoring site in Crescent City which uses the Grimm 180. Unfortunately, the distance between the NCUAQMD office and the Crescent City Monitoring Site precludes the possibility of running a collocation study there. Currently, the Grimm 180 S/N #18A11018 is deployed in Crescent City. This instrument could not meet correlation or bias requirements when collocated with an FRM instrument at Humboldt Hill south of Eureka. The Crescent City site is similar to the Humboldt Hill site, and there is little reason to expect the instrument is performing better in this different location. Based on the earlier collocation study, the NCUAQMD deems the data generated by this instrument is not comparable to the NAAQS. However, because it is impossible for NCUAQMD to file a waiver application for this data, the data was uploaded to the Federal Air Quality Database under code to allow researchers to fully employ the Grimm data in their assessments and potentially use in to the NAAQS. This data is not certified however due to the lack of flow audits. The lack of flow audits for the Grimm 180 is further described in section, Review of Changes to the PM2.5 network. The NCUAQMD has received funding for the purchase of a new continuous PM2.5 instrument. The NCUAQMD is in the process of evaluating instrumentation options and looks forward to replacing the Grimm 180 with an instrument able to meet all CFR requirements. Recent or Proposed Modifications to Network This Humboldt Hill Monitoring Station south of Eureka was intended as a Special Purpose Monitoring Station to evaluate the impacts of the modification of a Title V Major Source (Pacific Gas and Electric (PG&E) plant facility). The Title V Major Source permit was conditioned such that the source was required to fund the air monitoring station downwind of the plant for a period of five years. Monitoring at this location began in PG&E has satisfied the terms of the permit and has requested relief from this permit condition in the most recent Title V permit renewal. The NCUAQMD proposes to cease monitoring at the Humboldt Hill location. Data has been evaluated and NCUAQMD determined monitoring at the Humboldt Hill Station can be discontinued. EPA approval of these shutdowns is pending. The NCUAQMD has received funding from the EPA 103 grant program to purchase new PM2.5 monitoring equipment. This funding will be used to replace the Grimm 180 in Crescent City with a more appropriate instrument. The Jacobs Station had to be moved approximately 60 feet to the South in April 2017 due to a parking lot realignment project at the school which hosts the station. A letter from EPA approving this movement is attached. (Attachment A). Construction activity near the station caused the level of data collection to drop below that required to determine the Annual Arithmetic Mean in A letter from EPA approving this movement is attached. (Attachment A). Page 15 of 35

16 Review of Changes to PM2.5 Monitoring Network Any change to the NCUAQMD s PM2.5 network is reviewed by EPA Region 9. The NCUAQMD has not changed the location of any violating PM2.5 monitor. The Humboldt Hill FRM PM2.5 instrument failed in April 2018, and a request for shutdown of this instrument is in progress with EPA. The Humboldt Hill FRM PM2.5 sampler collected PM2.5 samples which were lower than the Jacobs PM2.5 sampler 96% of the time in 2017, and it was under consideration for shutdown prior to its failure. This is a non-violating instrument. The main purpose of the Humboldt Hill FRM was to function as a collocated instrument to the Grimm 180. Since the inception of the Grimm 180 collocation to an FRM, it has never met requirements for an FEM instrument, thus it will be requested for shutdown at the same time as the FRM. The NCUAQMD has never before eliminated an FRM PM2.5 sampler from the network. Should a violating PM2.5 monitor need to be moved, the annual network plan inspection/comment process would be used to provide for the review of the change. The NCUAQMD has received EPA 103 grant funds for the purchase of new PM2.5 monitoring equipment. NCUAQMD plans to replace the Grimm 180 currently operating in Crescent City. It has been found that the Grimm 180 instrument does not meet the EPA Minimum Data Assessment Requirements for PM2.5 instruments (CFR 40, part 58, Appendix A) or an approved alternative, as it does not indicate a flow rate. With no instrument flow rate information (other than the ideal flow stated in the instrument manual), it is impossible to perform a flow rate verification of the individual instrument, as required by Appendix A to 40 CFR Part 58. The NCUAMQMD does perform flow checks on the Grimm, but there is no approved method to allow such a flow check to be equivalent to a flow verification. Flow verification includes the calculation of bias, something which is mathematically impossible with only one measurement. The NCUAQMD request clarification from the EPA as to the meaning of flow verification as it is used in Appendix A - specifically, how a flow verification can be interpreted as a of the reading measured by a flow standard and the optimal flow stated in the instrument manual for the instrument being verified, and if this interpretation can be used for all flow verifications. The NCUAQMD notes that EPA s OAQPS has communicated that any certified standard that can measure the GRIMM s flow rate of 1.2 LPM may be used to perform flow checks, and that although there is no flow rate indicator on the screen, users are not precluded from performing flow checks. The NCUAQMD performs flow checks. However, the NCUAQMD is concerned about how to upload that flow check to the AQS database. The AQS database requires flow verifications, and thus a flow value recorded directly from the instrument itself is necessary. CARB has also been unable to upload flow check data from the Grimm to the AQS database for this same reason. The NCUAQMD requests EPA documentation specifically authorizing the procedure of simply uploading a number directly copied from the instrument manual, rather than generated from the instrument itself. Data Submission Requirements Data and Precision/Accuracy reports are submitted to CARB no later than 60 days after the quarter of record. The CARB uploads NCUAQMD data to the National Air Quality System Page 16 of 35

17 (AQS) no later than 90 days after the quarter of record. CARB submits the annual data certification no later than May 1 st of each year. No flow verifications on the NCUAQMD Grimm 180s have been uploaded to AQS. The California Air Resources Board attempted to audit the Grimm 180 in December of 2015 by measuring flow. Because there is not an instrument reading available to compare this measured flow to, reporting of CARB flow checks results has not taken place. Until a new EPA approved procedure on how to audit an instrument which gives no flow data is promulgated, CARB will only perform flow checks on the Grimm 180. Such flow checks cannot be legally uploaded to AQS. Data Availability The NCUAQMD s air quality data is available in the AQS database. It can also be obtained directly from the NCUAQMD in the form of monthly reports. Please contact the NCUAQMD at (707) to request copies of these reports. Page 17 of 35

18 Detailed Site Information Site Name: Jacobs The Jacobs site was established in December of It is located on the west side of Eureka and is expected to represent neighborhood scale air quality. AQS ID Latitude /Longitude (degrees) Location N W Alice Birney Elementary School Jacobs Address County Dist. to road Traffic count (AADT) Representative statistical area name Groundcover PEP audit? NPAP audit? PM 10 Flow audits PM2.5 Flow audits Gaseous audits Date of 2017 annual performance evaluation for gaseous instruments (CARB audit) Dates of two semi-annual PM10 flow audits conducted by CARB, occurring in 2017 Dates of two semi- annual PM2.5 flow audits, conducted by CARB, occurring in South Ave, Eureka Humboldt 50 1,104 (May 2018) Eureka, Arcata, Fortuna grass Information maintained by EPA Information maintained by EPA Performed every 2 weeks by NCUAQMD, Performed biannually by CARB Performed monthly by NCUAQMD, Performed biannually by CARB Following the requirement in QA Volume II, performance audits are performed annually by CARB May 23,2017 May 23,2017 December 12,2017 May 23,2017 December 12, 2017 Page 18 of 35

19 Jacobs Gaseous Onepoint control checks Gaseous instrument calibrations Representative Area Performed a minimum of once 14 days Performed bi-annually by CARB Humboldt County Micropolitan Statistical Area, Eureka-Arcata-Fortuna, suburban Pollutant O 3 NO 2 CO SO 2 PM 2.5 PM 10 Primary/QA Collocated/Other N/A Primary N/A N/A Primary Primary Parameter Code POC Basic Monitoring Objective Site Type NAAQS Population exposure NAAQS Population exposure NAAQS Population exposure NAAQS Population exposure NAAQS Population exposure NAAQS Population exposure Monitor Type SLAMS SLAMS SLAMS SLAMS SLAMS SLAMS Spatial scale Neighborhood Neighborhood Neighborhood Neighborhood Neighborhood Neighborhood Sampling method Instrument manufacturer and model Photometric EQOA Thermo 49i Chemiluminescence RFNA Thermo 42i Gas Filter correlation RFCA Thermo 48i Pulsed Florescence EQSA Thermo 43i Low Volume RFPS R&P 2000 EQPM Met One Bam1020 FRM/FEM/ARM FEM FRM FRM FEM FRM FEM Collecting Agency NCUAQMD NCUAQMD NCUAQMD NCUAQMD NCUAQMD NCUAQMD Analytical Lab N/A N/A N/A N/A BAAQMD N/A Reporting Agency CARB CARB CARB CARB CARB CARB Start date Dec 15, 2006 Dec 15, 2006 Dec 15, 2006 Dec 15, 2006 Dec 25, 2006 Jan 1, 2014 Current Sampling Frequency Sampling season Probe height Distance of lowvolume PM instrument from other PM instruments are >1 meter? continuous continuous continuous continuous 1:3 continuous Year round Year round Year round Year round Year round Year round NA NA NA NA Yes NA Distance from supporting structure Page 19 of 35

20 Distance from obstructions on roof Distance from obstructions not on roof Jacobs N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Pollutant O 3 NO 2 CO SO 2 PM 2.5 PM 10 Height of obstructions not on roof N/A N/A N/A N/A N/A N/A Distance from trees Distance to furnace or incinerator flue N/A N/A N/A N/A N/A N/A Distance between collocated N/A N/A N/A N/A N/A N/A monitors Unrestricted airflow (degrees) Probe material Teflon Teflon Teflon Teflon N/A N/A Residence time (seconds) Operation meets requirements of appendices A, B, C, D and E where applicable Will there be changes within the next 18 months? Is it suitable for against the annual PM2.5? N/A N/A yes yes yes yes yes yes No No No No No No N/A N/A N/A N/A Yes N/A Page 20 of 35

21 Site Name: Humboldt Hill The Humboldt Hill site was established in June 2011 from a nearby Title V Major Source permit condition. It is located on Humboldt Hill on the south side of Eureka and is expected to represent neighborhood scale air quality. AQS ID Humboldt Hill Latitude/ Longitude (degrees) Location Address County Dist. to road N W Humboldt Hill Summit 7333 Humboldt Hill Road, Eureka Humboldt 25 Traffic count Unknown, less than 50 Groundcover PEP audit? NPAP audit? PM2.5 Flow audits grass Information maintained by EPA Information maintained by EPA FRM: Performed monthly by NCUAQMD, Performed biannually by CARB FEM: Performed every two weeks Gaseous audits Date of 2017 annual performance evaluation for gaseous instruments conducted by CARB. Dates of two semi-annual PM2.5 flow audits by CARB occurring in 2017 Gaseous Onepoint control checks Gaseous Instrument Calibrations Representative Area Following the requirement in QA Volume II, performance audits are performed annually by CARB May 24, 2017 FRM method: May 24,2017 December 12,2017 Performed a minimum of once per 14 days Performed bi-annually by CARB Humboldt County Micropolitan Statistical Area, Eureka-Arcata-Fortuna, suburban FEM Method: FEM instrument does not provide a flow reading to compare with the audit instrument reading. Guidance is requested on how to upload flow verification data to AQS when the auditor has no instrument flow rate for. Page 21 of 35

22 Humboldt Hill Pollutant O 3 NO 2 CO SO 2 PM 2.5 PM 2.5 Primary/QA Collocated/ Other Parameter code N/A Primary N/A N/A Primary Other POC Basic Monitoring Objective Site Type NAAQS Population exposure NAAQS Population exposure NAAQS Population exposure NAAQS Population exposure NAAQS Population exposure NAAQS (to date, all data has been waivered, or is under a waiver application) Population exposure Monitor Type SPM SPM SPM SPM SPM SPM Spatial scale Neighborhood Neighborhood Neighborhood Neighbor-hood Neighbor-hood Neighbor-hood Sampling method Instrument manufacturer and model Photometric EQOA Thermo 49i Chemiluminescence RFNA Thermo 42i Gas Filter correlation RFCA Thermo 48i Pulsed Florescence EQSA Thermo 43i Low Volume RFPS R&P 2000 Light scatter EQPM Grimm 180 FRM/FEM/ ARM Collecting Agency FEM FRM FRM FEM FRM FEM NCUAQMD NCUAQMD NCUAQMD NCUAQMD NCUAQMD NCUAQMD Analytical Lab N/A N/A N/A N/A BAAQMD N/A Reporting Agency Start date Current Sampling Frequency Sampling season Probe height CARB CARB CARB CARB CARB CARB June 20, 2011 June 20, 2011 June 20, 2011 June 20, 2011 March 20, 2013 June 20, 2011 continuous continuous continuous continuous 1:3 continuous Year round Year round Year round Year round Year round Year round Distance of low-volume PM instrument from other PM instruments are >1 meter? NA NA NA NA Yes NA Page 22 of 35

23 Humboldt Hill Distance from supporting structure Pollutant O 3 NO 2 CO SO 2 PM 2.5 PM 2.5 Distance from obstructions on roof Distance from obstructions not on roof Height of Obstruction not on roof Distance from trees Distance to furnace or incinerator flue Distance between collocated monitors Unrestricted airflow (degrees) N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Probe material Teflon Teflon Teflon Teflon N/A N/A Residence time (seconds) N/A N/A Operation of monitor meets requirements of appendices A, B, C, D, and E, where applicable Will there be changes within the next 18 months? Is it suitable for against the annual PM2.5? yes yes yes yes yes no no yes yes yes yes yes N/A N/A N/A N/A yes No. Does not meet correlation requirements. Waiver application submitted for January2016 to December Page 23 of 35

24 Site Name: Weaverville The Weaverville site was established in It is located in downtown Weaverville near HWY 299 and is expected to represent neighborhood air quality. AQS ID Latitude/Longitude (degrees) N, W Location Address County Trinity County Courthouse 11 Court Street, Weaverville Trinity Dist. to road 21 meters to highway 299 Traffic count 3,450 AADT for HWY 299 (2016) Groundcover PEP audit NPAP audit PM2.5 Flow audits Date of annual performance evaluation (2017 CARB flow audit) 2017 semi-annual PM2.5 flow audits by CARB Representative Area Paved Information maintained by EPA Information maintained by EPA Weaverville Performed biweekly by NCUAQMD, Performed biannually by CARB August 1,2017 August 1,2017 December 11,2017 Rural, no MSA in Trinity County Pollutant PM 2.5 Primary/QA Collocated/ Other Parameter Code Primary POC 1 Basic monitor objective Site Type Monitor Type Spatial scale Air Pollution Data Population exposure SPM Sampling method 731 Instrument manufacturer and model FRM/FEM/ARM Collecting Agency Analytical Lab Reporting Agency Neighborhood Met One Bam1020 Non-FEM NCUAQMD N/A CARB Start date March 2015 Page 24 of 35

25 Weaverville Pollutant Current Sampling Frequency Sampling season Probe height Distance from supporting structure Distance from obstructions on roof Distance from obstructions not on roof Distance from trees Distance to furnace or incinerator flue Distance between collocated monitors Unrestricted airflow (degrees) Probe material Residence time Operation meets requirements of appendices A, B, C, D, and E, where applicable Will there be changes within the next 18 months? Is it suitable for against the annual PM 2.5? continuous Year round N/A N/A 15 N/A N/A 360 N/A N/A yes No No PM2.5 Page 25 of 35

26 Site Name: Crescent City The Crescent City site was established in It is located at the Crescent Elk Middle School. It is expected to represent neighborhood scale air quality. Crescent City AQS ID Latitude/ Longitude (degrees) N W Location Address County Dist. to road Crescent Elk Middle School 994 G Street Del Norte 64 meters to 9 th Street Traffic count 12,400 AADT HWY101 CRESCENT CITY, ON L STREET AT 9TH STREET (2016) Groundcover PEP audit NPAP audit Flow audit Date of 2017 annual performance evaluation (CARB audit) Dates of two semiannual flow audits occurring in 2017 Representative Area Paved/grass Information maintained by EPA Information maintained by EPA bimonthly by NCUAQMD Not audited. Instrument does not provide a flow reading to compare with the audit instrument reading. Guidance is requested on how to upload flow verification data to AQS when the auditor has no instrument flow rate to compare the audit instrument to. Not audited. Instrument does not provide a flow reading to compare with the audit instrument reading. Guidance is requested on how to upload flow verification data to AQS when the auditor has no instrument flow rate to compare the audit instrument to. Del Norte County, Micropolitan Statistical Area, Crescent City Urban Pollutant PM 2.5 Primary/QA Collocated/Other Other Parameter Code POC 1 Basic Monitoring Objectives Site Type Monitor Type Spatial scale Sampling method Instrument manufacturer and model FRM/FEM/ARM Collecting Agency Analytical Lab Reporting Agency NAAQS Population exposure SPM Neighborhood Light scatter EQPM Grimm 180 FEM NCUAQMD N/A CARB Start date April 2016 Current Sampling Continuous Frequency Sampling season Year round Page 26 of 35

27 Crescent City Pollutant PM 2.5 Probe height 7 Distance from supporting structure Distance from obstructions on roof Distance from obstructions not on roof Height of obstruction not on roof Distance from trees Distance to furnace or incinerator flue Height of stack Fuel burned Distance between collocated monitors Unrestricted airflow(degrees) Probe material 2 N/A N/A N/A 93 meters 49 meters 4 meters Diesel, intermittent, as determined by building needs N/A 360 N/A Residence time Operation meets requirements of appendices A, B, C, D, and E, where applicable Will there be changes within the next 18 months? Is it suitable for against the annual PM 2.5? N/A No Yes No. The Grimm 180 does not meet CFR requirements. Page 27 of 35

28 ATTACHMENT A Waiver Request for an FEM PM2.5 Grimm 180 located at Humboldt Hill Station Review of Network See Annual Network Plan, above. Review of data comparability of the PM2.5 continuous monitors A waiver for the data collected by the Grimm 180 located at Humboldt Hill (AQS ) from January 1, 2016 until Dec 31, 2017 is requested. The Continuous Monitor Comparability Assessment was run for the data set. Data did not meet minimum comparability requirements. The report, PM2.5 Continuous Monitor Comparability Assessment site , follows. Waiver Request Due to the failure of the Grimm 180 to correlate with an FRM Thermo 2000i PM2.5 instrument, the NCUAQMD requests an exclusion of PM2.5 data obtained from the Humboldt Hill site for the period December 29, 2015 through December 31, The NCUAQMD requests to upload this data under the code 88501, as it does not meet the minimum requirements for data recorded for AQI assessment. Page 28 of 35

29 PM2.5 Continuous Monitor Comparability Assessment Page 29 of 35

30 ATTACHMENT B Jacobs Station Relocation Documents NCUAQMD request letter: Page 30 of 35

31 Figure 1: Representation of the original Jacobs Station siting, and the relocated station siting. The Jacobs site was established in December of It is located on the west side of Eureka and is expected to represent neighborhood scale air quality. Jacobs AQS ID N N Latitude W W /Longitude ORIGINAL COORDINATES NEW COORDINATES (degrees) (Until April 21, 2017) (After April 21,2017) Alice Birney Elementary School Address County Dist. to road Traffic count (AADT) Representative statistical area name 717 South Ave, Eureka Humboldt (2007) a traffic study is currently being conducted, an updated AADT is expected for 2018 Eureka, Arcata, Fortuna Page 31 of 35

32 Jacobs Groundcover PEP audit? NPAP audit? PM 10 Flow audits PM 2.5 Flow audits Gaseous audits Date of 2017 annual performance evaluation for gaseous instruments (ARB audit) Dates of two semi-annual PM10 flow audits conducted by ARB, occurring in 2017 Dates of two semi- annual PM2.5 flow audits, conducted by ARB, occurring in 2017 Gaseous Onepoint control checks Gaseous instrument calibrations Representative Area grass Information maintained by EPA Information maintained by EPA Performed every 2 weeks by NCUAQMD, Performed biannually by ARB Performed monthly by NCUAQMD, Performed biannually by ARB Following the requirement in QA Volume II, performance audits are performed annually by ARB May 23,2017 May 23,2017 December 12,2017 May 23,2017 December 12, 2017 Performed a minimum of once 14 days Performed bi-annually by ARB Humboldt County Micropolitian Statistical Area, Eureka-Arcata-Fortuna, suburban Pollutant O 3 NO 2 CO SO 2 PM 2.5 PM 10 Primary/QA Collocated/Other N/A Primary N/A N/A Primary Primary Parameter Code POC Basic Monitoring Objective NAAQS NAAQS NAAQS NAAQS NAAQS NAAQS Site Type Population Population Population Population Population Population exposure exposure exposure exposure exposure exposure Monitor Type SLAMS SLAMS SLAMS SLAMS SLAMS SLAMS Spatial scale Neighborhood Neighborhood Neighborhood Neighborhood Neighborhood Neighborhood Sampling method Photometric EQOA Chemiluminescence RFNA Gas Filter correlation RFCA Pulsed Florescence EQSA Low Volume RFPS EQPM Instrument manufacturer and model Thermo 49i Thermo 42i Thermo 48i Thermo 43i R&P 2000 Met One Bam1020 Page 32 of 35

33 Pollutant O 3 NO 2 CO SO 2 PM 2.5 PM 10 FRM/FEM/ARM FEM FRM FRM FEM FRM FEM Collecting Agency NCUAQMD NCUAQMD NCUAQMD NCUAQMD NCUAQMD NCUAQMD Analytical Lab N/A N/A N/A N/A BAAQMD N/A Reporting Agency ARB ARB ARB ARB ARB ARB Start date Dec 15, 2006 Dec 15, 2006 Dec 15, 2006 Dec 15, 2006 Dec 25, 2006 Jan 1, 2014 Current Sampling Frequency continuous continuous continuous continuous 1:3 continuous Sampling season Year round Year round Year round Year round Year round Year round Probe height Distance of lowvolume PM instrument from other PM NA NA NA NA Yes NA instruments are >1 meter? Distance from supporting structure Distance from obstructions on N/A N/A N/A N/A N/A N/A roof Distance from obstructions not N/A N/A N/A N/A N/A N/A on roof Height of obstructions not N/A N/A N/A N/A N/A N/A on roof Distance from trees Distance to furnace or incinerator flue N/A N/A N/A N/A N/A N/A Distance between collocated N/A N/A N/A N/A N/A N/A monitors Unrestricted airflow (degrees) Probe material Teflon Teflon Teflon Teflon N/A N/A Residence time (seconds) Operation meets requirements of appendices A, B, C, D and E where applicable Will there be changes within the next 18 months? Is it suitable for against the annual PM2.5? N/A N/A yes yes yes yes yes yes No No No No No No N/A N/A N/A N/A Yes N/A Page 33 of 35

34 The Jacobs Station was relocated within sixty (60) feet of the old siting, so to reduce confusion the same AQS number was retained for the station. It samples the same air mass as when it was located on the original location. Please contact myself, or Wendy Caruso of my staff, with any questions. Sincerely, Brian Wilson APCO cc: Gwen Yoshimura Sylvia Vanderspek Mike Miguel Ken Stroud Aman Bain Wendy Caruso Page 34 of 35

35 EPA Response/Approval Letter: Page 35 of 35