2008 MONITORING NETWORK PLAN Introduction Since 1979 the air monitoring program has been producing an annual NETWORK REVIEW. The purpose of this report was to document that the agency was actively evaluating monitoring requirements and using resources effectively. Federal regulatory changes in December of 2006 altered this old grant requirement to require an annual monitoring network plan supplemented every five years by an assessment of the air quality surveillance system. This is the Montana Department of Environmental Quality’s (MTDEQ) second monitoring network plan. The objective of this report is to accurately describe the monitoring sites in the agency network, and identify their monitoring objectives. It should also describe any deviations in physical characteristics or operation from regulatory requirements. The report will also describe changes we anticipate making to the network in the coming year. A summary of existing network sites is provided in Table 3 of this document. Table 4 identifies site locations. Site descriptions are ordered from lowest to highest AQS number which is also alphabetically by county. Monitoring Requirements The minimum number of monitors required by federal regulation is specified in the series of tables copied from the Code of Federal Regulations and presented below. There is no required minimum number of monitors for carbon monoxide and nitrogen oxides. The table in Figure 1 identifies the requirements for ozone monitors. Table D–2 of Appendix D to Part 58— SLAMS Minimum O Monitoring Requirements 3 Most recent 3-year design value Most recent 3-year design value MSA concentrations ≥85% of any concentrations <85% of any population1,2 O NAAQS3 O NAAQS3,4 3 3 >10 million 4 2 4–10 million 3 1 350,000–<4 2 1 million 50,000– 1 0 <350,0005 Figure 1 – Ozone Monitoring Requirements 1 Montana has three MSAs with populations between 50,000 and 350,000. The design value for Billings was determined during 2005-2007 to be 0.059 ppm or 78.7% of the National Ambient Air Quality Standard (NAAQS). Measurements made in the Missoula MSA suggested a lower design value. No measurements of ozone have been made in Great Falls. The minimum number of required PM sites is established by the table in 10 Figure 2. None of Montana’s three MSAs meets the requirement for medium concentration, so no PM sites are required. 10 Table D–4 of Appendix D to Part 58. PM Minimum Monitoring Requirements (Number of Stations per 10 MSA)1 Population High Medium Low category concentration2 concentration3 concentration4,5 >1,000,000 6–10 4–8 2–4 500,000–1,000,000 4–8 2–4 1–2 250,000–500,000 3–4 1–2 0–1 100,000–250,000 1–2 0–1 0 1Selection of urban areas and actual numbers of stations per area within the ranges shown in this table will be jointly determined by EPA and the State Agency. 2High concentration areas are those for which ambient PM10 data show ambient concentrations exceeding the PM NAAQS by 20 percent or more. 10 3Medium concentration areas are those for which ambient PM10 data show ambient concentrations exceeding 80 percent of the PM NAAQS. 10 4Low concentration areas are those for which ambient PM10 data show ambient concentrations less than 80 percent of the PM NAAQS. 10 5These minimum monitoring requirements apply in the absence of a design value. Figure 2 – PM Monitoring Requirements 10 The table in Figure 3 below indicates that any of Montana’s three MSA’s with a PM design value exceeding 85% of the NAAQS requires a PM 2.5 2.5 monitoring site. Missoula County meets this requirement and has a PM 2.5 monitoring site at the Health Department. In summary, the number of air quality monitors required by regulation in an area is a function of population density and air quality. No population area in Montana has enough people to require more than one monitor for any pollutant where air quality is bad and to require any monitoring where air quality is good. MTDEQ has monitors in place where there are known air quality issues and continues to investigate suspect areas. 2 Table D–5 of Appendix D to Part 58. PM Minimum Monitoring Requirements 2.5 MSA Most recent 3-year design value Most recent 3-year design value population1,2 ≥85% of any PM NAAQS3 <85% of any PM NAAQS3,4 2.5 2.5 >1,000,000 3 2 500,000– 2 1 1,000,000 50,000– 1 0 <500,0005 1Minimum monitoring requirements apply to the Metropolitan statistical area (MSA). 2Population based on latest available census figures. 3The PM National Ambient Air Quality Standards (NAAQS) levels and forms are defined in 40 CFR part 50. 2.5 4These minimum monitoring requirements apply in the absence of a design value. 5Metropolitan statistical areas (MSA) must contain an urbanized area of 50,000 or more population. Figure 3 – PM Monitoring Requirements 2.5 MTDEQ’s air monitoring sites meet all of the EPA’s siting requirements with the few exceptions described below, and they are all operated to conform with EPA requirements for quality control and quality assurance for SLAMS sites. Monitoring Sites 30-013-0001 Great Falls-Overlook Park This site was established in 2001 to monitor carbon monoxide continuously. It is microscale representative, and its monitoring objective is to track compliance with the NAAQS for the “Limited Maintenance Plan” in the 10th Avenue CO nonattainment corridor. A continuous PM monitor was added to 2.5 the site during the spring of 2008 to provide near, real-time particulate data for use on the “todaysair” website. 30-013-1026 Great Falls-High School This site has been monitoring PM since January 2000. The 2.5 neighborhood scale site is near the center of the city, and was established to monitor population exposure to area PM emissions. The monitor is in the 2.5 corner of a large football field and about 5 meters from each of two roadways. While this is undesirably close to the roads, one dead-ends at the end of the block, and the other has very little traffic. 3 30-029-0007 Columbia Falls-Ball Park This collocated PM site began operating in 2006 and exists to 10 demonstrate continued compliance with the NAAQS in the Columbia Falls PM 10 nonattainment area. PM monitoring was added in 2008. The site is 2.5 neighborhood scale and located in the corner of a park between an industrial park to the North and a residential neighborhood to the South. A tree partially obstructs about 90 degrees to the East, and the monitors are closer than desirable to the adjacent roadways which are paved and have very low traffic volumes. 30-029-0009 Whitefish-Dead End This particulate site monitors both PM and PM . It is located at the end 10 2.5 of 10th Street near the point where US 93 crosses the Whitefish River. The site is representative at the neighborhood scale and was installed to provide continuing monitoring for the PM nonattainment area designated in 1993, and to assess 10 population exposure to fine particulate. It also provides continuous particulate data for the local burning control program. 30-029-0010 Kalispell-Moose’s Saloon This microscale carbon monoxide site is on the south side of Idaho Ave. near the intersection of Idaho & Main in downtown Kalispell. Exceedances of the CO NAAQS were measured across the street from this site in 1996, and subsequent studies have shown this to be the highest carbon monoxide area in Kalispell. The site was established in 2003 to monitor continuing compliance with the NAAQS. 30-029-0047 Kalispell-Flathead Electric This particulate site was installed in 1999 to consolidate particulate monitoring in Kalispell. The site is neighborhood scale and provides population exposure information for both PM and PM . It also provides continuous 10 2.5 particulate data for the county’s burning control program, and demonstrates continuing compliance with the NAAQS in the Kalispell PM nonattainment area 10 designated in 1990. 30-031-0006 Bozeman-Wastewater Treatment Plant This PM site is located at the north-west corner of Bozeman adjacent to 2.5 the wastewater treatment plant. It is neighborhood scale, and it was positioned to measure down-slope flow from Bozeman toward Belgrade. While the site does represent some population, it’s principle function is to provide information on fine particulate dynamics in the Gallatin Valley. Continuous PM monitoring 2.5 was added in early 2008 to provide near, real-time particulate data for use on the “todaysair” website. 30-031-0008 Belgrade-ConAgra 4 This PM site is located close to the center of the community. It is 2.5 neighborhood scale and provides exposure information for the population. This site consistently measures the highest values in the Gallatin Valley. Land use changes may force us from this site in the near future. 30-031-0013 West Yellowstone-Park Entrance This site monitors carbon monoxide and PM . It was established in 1998 2.5 to measure CO at the park entrance, and it followed the park entrance about ¼ mile into the park during the spring of 2008. It is microscale in its representation. Continuous PM monitoring was added in 2003. The site is very close to the 2.5 entrance roadway and it is surrounded by tall trees. Air flow at monitoring height is up and down the roadway. Results are relevant to only the immediate locale. This site is funded by the National Park Service, but operated to EPA requirements. 30-031-0016 West Yellowstone-City Center This site was established in 2007 to monitor community wide exposure to carbon monoxide and fine particulate. It is in the center of town and it is neighborhood scale in its representation. Like the Park Entrance site, this site is funded by the National Park Service, but operated like an EPA SLAMS site. 30-049-0018 Helena-Lincoln School This neighborhood scale site has been monitoring population exposure to particulate since 1989. It is currently measuring PM both continuously and at 2.5 three day intervals. 30-049-0026 Helena-Rossiter Pump House This neighborhood scale site is in the middle of an elementary school play field at the bottom of the Helena Valley. It exists to monitor population exposure to fine particulate and to track the impact of continuing development in the valley. The site has a long history of measuring PM , but it was switched to measuring 10 PM in January of 2007. 2.5 30-053-0018 Libby-Courthouse Annex This neighborhood scale site is on the roof of the Courthouse Annex in the center of Libby, MT. It has been in operation since 1987. It is currently measuring particulate for population exposure and compliance with the NAAQS in the PM and PM nonattainment areas. 10 2.5 30-063-0005 Missoula-Malfunction Junction This microscale site exists to track continuing compliance with the carbon monoxide NAAQS in the Missoula CO nonattainment area. It operates only during the winter quarters when Missoula is subject to inversions. 5 30-063-0021 Seeley Lake This neighborhood scale site was installed along the main corridor (US 83) through town to monitor population exposure to PM and PM . Data collected 10 2.5 since 2004 is inconclusive, but indicates that PM is occasionally high. 2.5 30-063-0024 Missoula-Boyd Park This neighborhood scale site has collected particulate data since 1981. It currently monitors PM continuously to demonstrate continuing compliance with 10 the NAAQS in the Missoula PM nonattainment area. 10 30-063-0031 Missoula-Health Department This neighborhood scale site is located on the roof of the city-county health department . It has monitored particulate since 1985. The site is currently a Speciation Trends PM site. It also samples PM and PM The 2.5 2.5 10. site’s objective is to monitor population exposure to particulate and compliance with the NAAQS. 30-081-0007 Hamilton-PS#46 This neighborhood scale site is located in parking spot number 46 in the sheriff’s lot at the corner of Madison and 3rd Street South. It has both continuous and FRM PM monitors. The site was established in 2005 less than a block 2.5 away from our former site on the Courthouse roof to monitor population exposure and compliance with the NAAQS. The move was made to accommodate continuous monitoring required for near-real-time reporting of smoke during the summer wildfire season. The site is on a paved lot within 5 meters of a gravel alley and Madison St. which is paved. The alley sees virtually no use, and Madison street is low volume. 30-089-0007 Thompson Falls-High School This site is located on the East side of Thompson Falls at the High School. It is neighborhood scale in its representation and it was established in 1999 to monitor population exposure to PM and PM and compliancewith the NAAQS. 10 2.5 Thompson Falls was designated nonattainment for PM in December of 1993. 10 30-093-0005 Butte-Greeley School This neighborhood scale site is located at an elementary school in a residential neighborhood on the north side of Butte near the current mining activity. The site monitors population exposure to particulate. Continuous PM10 monitoring provides response capability for the burning control program and monitors compliance with the NAAQS. PM2.5 compliance is measured with an FRM sampler. Butte was designated nonattainment for PM in 1990. 10 30-093-0009 Butte-Front Street This site is in the parking lot of the Butte-Silverbow Health Department office. It was established in 2007 and it is neighborhood scale representative. It provides continuous PM data for assessing population exposure. 2.5 6 30-111-0066 Billings-Coburn Rd. This neighborhood scale site is located on high ground south of the Conoco and Exxon refineries. It is a major receptor for SO and exists to monitor 2 compliance with the federal and state SO standards. 2 30-111-0085 Billings-St. Luke’s This micro scale carbon monoxide site is in downtown Billings at the corner of 2nd Ave. North and North 32nd Street. This site was installed to demonstrate Billings’ continuing compliance with the CO NAAQS. Continuous PM monitoring was added in the spring of 2008 to provide near, real-time 2.5 particulate data for the “todaysair” website. 30-111-0086 Shepherd-Bus Barn This neighborhood scale site was located to receive maximum ozone impact from Billings. It is about ten miles north-east of Billings in the Yellowstone River valley. It began monitoring nitrogen oxides and ozone in June of 2005. The values measured were too low to require continued monitoring, so the site was closed in January 2008. 30-111-1065 Billings-Lockwood Park This neighborhood scale particulate site is located at Lockwood Park on Old Hardin Road at the east end of Billings. It has monitored population exposure to PM since 1999. 2.5 All of these sites meet the requirements of 40 CFR part 58 Appendices A, C, and D. Three sites do not meet all of the siting requirements of Appendix E. Sites 30-013-1026 and 30-081-0007 are less than 15 meters from roadways and site 30-063-0021 has partially obstructed air flow. PM monitoring sites, representative of a smaller than neighborhood 2.5 spatial scale, are not eligible for comparison to the annual PM NAAQS. Data 2.5 from such sites is eligible for comparison to only the 24 hour PM NAAQS. The 2.5 only MTDEQ PM site of this nature is the microscale site at the west entrance 2.5 to Yellowstone National Park (30-031-0013). All other PM monitors can be 2.5 compared to the Annual NAAQS. If circumstances should make it necessary or desirable to relocate a violating PM monitor, the change would be discussed among an existing local 2.5 program, Air Quality Permitting, the Air Planning Section and the Air Monitoring Section. The Air Monitoring Section would seek public comment through the annual Monitoring Network Plan and would seek EPA approval for the change. No such change would ever be made without demonstrating that a replacement site produced comparably high values unless circumstances precluded such a comparison. Montana does not have any community monitoring zones or 7 anticipate creating one, so the impact of relocating a site on such zones is not relevant. Proposed Changes In May and June of 2008 MTDEQ reorganized continuous PM monitors 2.5 to add continuous monitoring to Great Falls, Bozeman, and Billings while retaining this capability where it already existed. The objective was to convert all data appearing on the agency’s “todaysair” website to PM and eliminate the 2.5 confusion associated with presenting a mixture of PM and PM data. The 10 2.5 todaysair web site was created to present near, real-time particulate information primarily during the summer wild fire season, and from its inception has presented all of the continuous particulate data available whether it was PM or 10 PM . While this is adequate for informing the public of the risks of the very high 2.5 particulate concentrations associated with summer fires, it has created confusion during other more normal seasons and circumstances. It was also decided that these three most populous cities in Montana should be added to the website because, even though they don’t have problems with attainment of the National Ambient Air Quality Standards, they can be heavily impacted by smoke during the summer wild fire season. As part of the above endeavor, we propose to add continuous PM2.5 monitoring to the Boyd Park site in Missoula. We hope to accomplish this during July, and complete the transition from presenting mixed particulate data on the near, real-time website to presenting only PM2.5 data. MTDEQ monitors carbon monoxide in four communities even though the measured values are low and either stable or declining (see Table 1). While Year Great Falls Kalispell Missoula Billings Max Hour Max 8 Hr Max Hour Max 8 Hr Max Hour Max 8 Hr Max Hour Max 8 Hr 1st 2nd 1st 2nd 1st 2nd 1st 2nd 1st 2nd 1st 2nd 1st 2nd 1st 2nd 1995 13.9 13.7 7.9 6.2 9.7 9.2 7.6 6.5 8.9 8.5 7.8 6.6 16.5 13.6 7.1 6.6 1996 21.9 19.1 8.5 5.4 17.4 13.4 11.4 11.1 6.7 6.7 5.8 5.6 14.8 11.1 6 4.7 1997 11.1 10 7.4 6.4 6.2 6.1 4.9 4.9 8.1 8.1 6.3 4.9 9.2 8.6 5.2 4.9 1998 10.3 8.7 5.3 4.5 6.6 6.5 5.3 5 5.7 5.6 4.7 4.7 13.3 12.8 5.9 4.8 1999 7.8 7.1 3.6 3.5 9.1 7.9 5.3 4.8 6 5.8 4.9 4.4 10 6.7 3.4 3.4 2000 6.7 6.5 4.6 3.6 8 7 4.3 4.3 5.4 4.9 3.9 3.3 10.6 8.2 5.1 4.9 2001 7.4 7.2 4.6 3.6 6 5.7 3.8 3.7 7 6.6 5.5 3.9 9 8.6 5.6 5.2 2002 7.3 5.5 3 2.8 5.4 5.3 3.4 3.3 5.7 5.2 4.6 3.6 8.9 8.5 5 4.9 2003 4.8 4.6 2.9 2.7 5 4.8 3.2 3 4.5 4.4 4 3.6 7.8 7.5 5.7 4.4 2004 7.2 5.7 3.2 2.4 5 4.7 3.2 2.9 3.9 3.6 3.2 2.9 8.1 6.8 4.4 3.7 2005 4 3.7 2 2 5.9 5.5 3.6 3.3 4.3 4.3 4.1 3.6 13.4 5.6 3.7 3.5 2006 3 2.8 2.2 1.7 5.3 4.6 3 2.6 3.1 3 2.5 2.4 5.9 4.9 2.7 2 Table 1 – Carbon Monoxide 8 these communities had problems with carbon monoxide in the past, those days have clearly passed. Unfortunately, regulations developed back then to control CO emissions also required monitoring to track progress, and no provision was made to ever discontinue monitoring. The agency is currently exploring its options for discontinuing this required but unnecessary carbon monoxide monitoring. At the end of June 2008 we propose to discontinue PM speciation 2.5 sampling in Libby. Speciation of fine particulate in Libby began over six years ago when it began to appear likely that Libby was not in compliance with the PM standard. Speciation results were useful in characterizing the problem and 2.5 in documenting the effect of the wood stove change-out, but that need has passed, and it is time to make this resource available elsewhere. We propose to begin PM speciation sampling at Butte-Greeley School on 9/01/08. The metals 2.5 content of fine particulate is a matter of considerable interest in Butte. We also propose to discontinue PM monitoring at the Missoula-Health 10 Department site at the end of 2008. A comparison of data from the two sites in Missoula (Health Department and Boyd Park) shows no real difference between them for either maximum daily values or annual averages. See Table 2. To continue monitoring PM at both sites would be a waste of resources. 10 Boyd Park Health Department 1st 2nd 3rd 4th 1st 2nd 3rd 4th Year Max Max Max Max Mean Max Max Max Max Mean 1995 83 81 77 69 24 67 53 49 46 26 1996 113 112 102 97 24 71 51 51 50 28 1997 88 88 70 65 21 78 55 49 48 26 1998 126 73 70 69 20 72 51 50 43 23 1999 60 55 42 42 17 46 43 42 38 20 2000 164 137 120 102 21 193 115 69 69 28 2001 91 72 69 68 19 63 55 47 45 21 2002 46 44 41 40 16 43 42 39 38 20 2003 109 100 54 54 24 134 116 110 107 21 2004 86 54 52 51 22 49 47 46 45 19 2005 85 58 54 51 22 57 52 52 50 18 2006 85 80 74 70 24 51 46 42 41 23 2007 138 124 87 87 24 129 54 52 46 24 Table 2 – Missoula PM 10 The above changes may occur. They reflect our current intensions. No changes will actually occur without additional discussions with EPA Region 8 and approval of a formal Network Modification Request. 9 Table 3 Existing Montana Ambient Air Monitoring Network AQS Number Site Parameter Method Frequency Type Spatial Location _______________________City-Name Scale Type* *H=high concentration, P=population exposure, S=source impact, B=background 30-013-0001 Great Falls-Overlook Park 42101-CO 0931 Continuous SLAMS Micro. H,P,S 88502-PM 7315 Continuous SPM Middle H,P 2.5 30-013-1026 Great Falls-High School 88101-PM 1422 1 in 3 SLAMS Neigh. H,P 2.5 30-029-0007 Columbia Falls-Ball Park 81102-PM 1253 1 in 6 SLAMS Neigh H,P,S 10 85101-PM (collocated) 10 88101-PM 1422 1 in 3 SLAMS Neigh H,P 2.5 30-029-0009 Whitefish-Dead End 88502-PM 7315 Continuous SPM Neigh. H,P 2.5 88101-PM 1422 1 in 3 SLAMS Neigh. H,P 2.5 81102-PM 1253 1 in 6 SLAMS Neigh. H,P 10 85101-PM 1253 1 in 6 SLAMS Neigh. H,P 10 30-029-0010 Kalispell-Moose’s 42101-CO 0931 Continuous SLAMS Micro. H,P,S 30-029-0047 Kalispell-Flathead Electric 88502-PM 7315 Continuous SPM Neigh. H,P 2.5 88101-PM 1422 1 in 3 SLAMS Neigh. H,P 2.5 81102-PM 1224 1 in 6 SLAMS Neigh. H,P 10 85101-PM 122 1 in 6 SLAMS Neigh. H,P 10 30-031-0006 Bozeman-Waste Water 88101-PM 1422 1 in 3 SLAMS Neigh. H,P 2.5 Treatment Plant 88502-PM 7315 Continuous SPM Neigh. P 2.5 30-031-0008 Belgrade-ConAgra 88101-PM 1422 1 in 3 SLAMS Neigh. H,P 2.5 10