2019-2020 Annual Monitoring Network Plan for the North Carolina Division of Air Quality

Volume 1

Addendum 1

February 24, 2020

North Carolina Division of Air Quality A Division of the North Carolina Department

of Environmental Quality Mail Service Center 1641

Raleigh, North Carolina 27699-1641

CERTIFICATION

By the signatures below, the North Carolina Division of Air Quality, DAO, certifies that the information contained in this 2019-2020 Annual Monitoring Network Plan Addendum is complete and accurate at the time of submittal to EPA Region 4. However, due to circumstances that may arise during the sampling year, some network information may change. A notification of change and a request for approval will be submitted to EPA Region 4 at that time.

Signature __ ~ _____ C&h-___________ Date i.- iY-2.02O

Patrick Butler Ambient Monitoring Section Chief, DAQ

S. ~A~<l t ~ 1gnature r//1 ( c ·

Michael Abraczinskas Director, DAQ

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Addendum 1. Wade Relocation Siting Analysis and Site Information Introduction

On October 3, 2019, Patrick Butler, Mitchell Revels, Steve Allen, Roger Caulder, Derrick House, James Stroup, Joette Steger, Jeff Gobel and Mike Lane, all with the North Carolina Division of Air Quality (DAQ), met at the Wade site in Cumberland County, North Carolina to evaluate the site to see if it still meets the siting criteria in Appendix E to 40 Code of Federal Regulations (CFR) Part 58. This site is one of two sites required for the Fayetteville metropolitan statistical area (MSA). Information about the existing monitoring station is provided in Table 1. Figure 1 shows an aerial view of the Wade site.

Table 1 North Carolina Wade Ozone Monitoring Location Information Site Name AQS Identifier Date Established Operator

Wade 37-051-0008 April 4, 1990 DAQ Fayetteville Regional Office

Figure 1. Aerial view of the Wade site

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As can be seen in Figure 1, the site is surrounded by trees on three sides. However, the trees are only obstacles resulting in an obstruction to air flow on two sides. There is a tree 10.5 meters to the west that obstructs 18 degrees of air flow. A row of trees 28.6 meters to the east obstruct an additional 61 degrees of air flow. Since the site has 281 degrees of unobstructed air flow it continues to meet the 40 CFR Part 58, Appendix E requirements of having 270 degrees of unobstructed air flow. However, since the site barely meets the 40 CFR Part 58, Appendix E siting requirements and DAQ plans to replace the monitoring shelter at the site, the DAQ decided to investigate other potential nearby site locations.

There is a park across Main Street from the current Wade site. The DAQ looked at several potential locations (orange circles in Figure 2) at the park. However, after speaking with the maintenance worker, DAQ decided DAQ would be unlikely to obtain permission to place a monitoring shelter in the park.

Figure 2. Aerial view of other potential sites investigated

Next, DAQ looked at the post office (purple circle in Figure 2) across the field from the current Wade site. The DAQ decided this location is perfect for relocating the Wade site as it is an open area, meets 40 CFR Part 58, Appendix E and is within site of the current Wade shelter (see Figure 3). In November, DAQ contacted the lease manager for the post office property to obtain permission to move the monitoring shelter 165 meters north of its current location to the post office property. However, the property owner did not want the ozone monitoring shelter placed on the property and declined to give DAQ permission to use the property.

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Figure 3. Location of the Post Office relative to the existing shelter

The DAQ also looked at a nearby fire station south of Wade. However, it appeared that the fire station might do practice burns for training at that site. Finally, the DAQ investigated District 7 Elementary School. On Dec. 20, Stephen Allen and Roger Caulder of DAQ met with Mr. Mark Whitley, Executive Director for Cumberland County Schools, at District 7 Elementary School. Mr. Whitley approved placing the relocated Wade monitor inside the fence where the old pump house is as shown in Figure 4.

Figure 4. Aerial view of the proposed site

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The proposed site at District 7 Elementary School is 2.23 kilometers southeast of the current Wade site as shown in Figure 5. The Cumberland County Board of Education agreed to this location on Feb. 11, 2020.

Figure 5. Location of proposed site relative to the current site

Table 2 lists the projected schedule of activities for relocating the site and operating it.

Table 2 Schedule of Activities Activity Estimated Completion Date

Identify a Potential Site Nov. 14, 2019 Obtain Permission from Property Owner Feb. 11, 2020 30-Day Public Comment Period Feb. 25 to March 26, 2020 Site Setup Feb. 25 to June 19, 2020 Submit Network Plan Addendum to EPA for Approval March 30, 2020

Obtain EPA Approval of Network Plan Addendum April 30, 2020 Equipment Installation and Calibration July 6 to July 16, 2020 Sample Collection / Analysis Hourly (every minute) Real-time Data Reporting Hourly to AirNow and DAQ Website

Data Verification Monthly, by end of 3rd Week of Following Month

Data Validation Monthly, within 59 Days after each Month

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Table 2 Schedule of Activities Activity Estimated Completion Date

AQS Submittals Within 90 days after each Quarter Ozone Performance Evaluations Annually Technical Systems Audit DAQ Annually, EPA Every 3 Years QA Report / Annual Certification Annually by May 1 of each Year Review of Siting Criteria Annually in late summer or early fall

Region 4 Requested Siting Information for the Wade Site Relocation The monitor affected by this relocation is the Wade ozone monitor, 37-051-0008-44201-

1. The DAQ operates this monitor to ensure that the air in the Fayetteville area complies with the national ambient air quality standards for ozone and to meet Appendix D to 40 CFR Part 58 requirements. Views from the proposed site looking north, east, south and west are shown in Figure 6 through Figure 9. As indicated in the pictures, the proposed area is open and free of trees or structures that could become obstacles that obstruct the air flow.

Figure 6. Looking north from the proposed location

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Figure 7. Looking east from the proposed location

Figure 8. Looking south from the proposed location

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Figure 9. Looking West from the proposed location

The proposed monitoring site is located 106 meters from the trees to the north, which are 25 meters tall. The tree to the east is 7 meters tall and 40 meters from the proposed monitoring site location. The tree line to the west is 75 meters from the proposed location. The pump house to the south is 31 meters from the proposed location. The proposed location is 48 meters west of the school building. None of the trees or buildings are close enough or tall enough to be an obstacle to air flow.

The nearest road is Smithfield Road located 81 meters to the south. As shown in Figure 10, this road reported an annual average daily traffic count of 770 in 2018. The proposed site is 347 meters southwest of Wade-Stedman Road, which has an annual average daily traffic count of 1500 in 2018 and 1500 meters southeast of I95, which had an annual average daily traffic count of 55,000 in 2017. The probe height for the proposed monitoring station will be the same as the probe height for the old monitoring station, approximately 4.4 to 4.5 meters.

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Figure 10. Average annual daily traffic counts (from DOT) near the proposed monitoring location

The Air Quality System identification number and street address for the site will change to: 37-051-0011 and 5721 Smithfield Rd, Wade, NC 28395. The new latitude and longitude is 35.148753 and -78.706831. The sampling and analysis method (AQS code 047) and operating schedule (hourly) will remain the same. The monitoring objective for the ozone monitor will continued to be highest concentration. Figure 11 shows the exceedance probability for the Fayetteville MSA indicating that higher ozone concentrations are most likely to occur in the area around Wade.

Figure 11. Probability of exceeding 70 ppb

The current Wade monitor serves an area of 4,054 square kilometers with a population of 184,259. Figure 12 shows the demographic makeup of this area. Based on 2014-2016 data, this monitor has less than a 10 percent probability of exceeding the 70 ppb standard. Figure 13

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shows the trends in the 4th highest 8-hour average ozone concentrations and design values for the Wade monitor.

Figure 12. Demographics for the area served by the existing Wade monitor

Figure 13. Ozone trends measured at the Wade site

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Based on the wind roses in Figure 14 through Figure 16, the new monitoring station is located downwind of Fayetteville during springtime and summer when the ozone concentrations are the highest (see Figure 17). The spatial scale of representativeness for the ozone monitor will be urban based on the location of the roadways and the amount of traffic on those roads. (See Table 1)

Figure 14. Wind rose for Fayetteville using data for the past 5 years

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Figure 15. Wind rose for Fayetteville during the spring season

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Figure 16. Wind rose for Fayetteville during the summer season

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Figure 17. Ozone daily Air Quality Index Values for the past three years

Table 1. Table E-1 of Appendix E to 40 CFR Part 58 - Minimum Separation Distance Between Roadways and Probes or Monitoring Paths for Monitoring Neighborhood and Urban Scale Ozone (O3) and Oxides of Nitrogen (NO, NO2, NOx, NOy)

This monitor will continue to be representative of the air in the Fayetteville MSA. Table 2 summarizes other factors DAQ evaluated when choosing the new location for the monitoring station. Location of permitted facilities are shown in Figure 18. Table 3 summarizes the EPA-required information for the proposed site.

Table 2. Other Considerations in Selection of the Relocated Wade Site Factor Evaluation Long-term Site Commitment The Cumberland school system is willing to provide DAQ with a

long-term lease agreement and does not plan to develop the current area

Sufficient Operating Space 30 meter radius area open of trees, buildings and roadways Access and Security Current building has not been vandalized. New location is near

the school and inside a fenced area. Safety Appropriate electrical permits will be obtained

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Table 2. Other Considerations in Selection of the Relocated Wade Site Factor Evaluation Power Overhead power is located along Smithfield Road. Environmental Control The new building does not have windows and is well insulated to

ensure that it will be able to maintain a consistent, stable shelter temperature.

Exposure The monitoring station is at least 40 meters from the driplines of trees and 30 meters from the nearest building that could be obstacles to air flow.

Distance from Nearby Emitters There are no permitted facilities within 4 kilometers of the site. Public Works Commission Butler-Warner Generation Plant, located at 2274 Custer Avenue in Fayetteville, 12.5 kilometers southwest of the proposed monitoring station, emitted 27.5 tons of NOx and 0.2 tons of VOC in 2017. The Goodyear Tire and Rubber Company, located at 6650 Ramsey Street in Fayetteville, 14.2 kilometers west northwest of the proposed monitoring station, emitted 36.7 tons of NOx and 138.5 tons of VOC in 2017.

Proximity to Other Measurements The proposed monitoring station is located about 23.7 kilometers northeast of the Fayetteville Regional Airport.

Figure 18. Location of proposed site relative to emission point sources

Table 3. Monitoring information for the relocated Wade site

AQS Site Id Number: 37-051-0011 Site Name: Wade-School Street Address: 5721 Smithfield Rd City: Wade Latitude: 35.148753 Longitude: -78.706831 MSA, CSA or CBSA represented: Fayetteville MSA Monitor Type: SLAMS

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Table 3. Monitoring information for the relocated Wade site

AQS Site Id Number: 37-051-0011 Operating Schedule: Hourly – March 1 through October 31, every year

Statement of Purpose: To measure the highest ozone concentrations in the Fayetteville MSA

Monitoring Objective: Highest ozone concentration Scale: Urban Suitable for Comparison to NAAQS: Yes Meets Requirements of 40 CFR Part 58, Appendix A: Yes

Meets Requirements of 40 CFR Part 58, Appendix C: Yes: EQOA-0880-047

Meets Requirements of 40 CFR Part 58, Appendix D: Yes, required by Appendix D

Meets Requirements of 40 CFR Part 58, Appendix E: Yes

Proposal to Move or Change: Monitoring will begin in June 2020

DAQ Request for Permission to Combine Ozone Data for Design Value Calculations

The DAQ requests approval to combine data from the current Wade ozone monitor, 37-051-0008-44201-1, with the relocated Wade-School ozone monitor, 37-051-0011-44201-1, for calculating a design value for a relocated site in accordance with 40CFR Part 50 Appendix U(2)(c):

“In certain circumstances, including but not limited to site closures or relocations, data from two nearby sites may be combined into a single site data record for the purpose of calculating a valid design value. The appropriate Regional Administrator may approve such combinations after taking into consideration factors such as distance between sites, spatial and temporal patterns in air quality, local emissions and meteorology, jurisdictional boundaries and terrain features.”

As shown earlier in Figure 3 and Figure 5, the Wade-School proposed site is 2.23 kilometers southeast of the Wade site. The terrain at both locations is flat, both locations are bounded by an agricultural field, there are no differences in exposure to area or point sources, and both monitors should monitor the same air mass. This request meets the relocation requirements of 40 CFR § 58. I 4(c)(6) and the data from these two monitors should be eligible to be combined for design value calculations as described in 40 CFR § 50 Appendix U(2)(c).