The UDAQ has released the Annual Monitoring Network Plan for 2023 to inform stakeholders of the current state and upcoming changes to Utah’s Air Monitoring Network. UDAQ has strategically added additional air monitoring stations on the Wasatch Front to monitor both Ozone and PM2.5. The following paragraphs highlight the new monitoring locations and their potential to influence air quality permitting approach in the future.
New Monitoring Sites
A new location for the Brigham City site was selected (near 350 West 1175 South), instruments have been installed and are being tested. The site will assess population exposure in this area and will help the forecasters with Ozone and PM2.5 predictions. The previous Brigham City monitor was operational for less than 2 years and reported only PM2.5. Throughout its operation, the monitor did not report PM2.5 levels exceeding the National Ambient Air Quality Standard (NAAQS) design value. However, NO2 levels at the station are an early indicator of future PM2.5 and ozone non-attainment and additional monitoring of both, as well as NO2 and VOCs was deemed necessary.
Enhanced Monitoring Program
Future new monitoring activities and/or sites are required in the Wasatch Front to meet Enhanced Monitoring Plan (EMP) requirements as the Wasatch Front was re-designated to Moderate nonattainment for Ozone. The UDAQ is currently working on the infrastructure for four to five additional Photochemical Assessment Monitoring Stations (PAMS) along the Wasatch Front in preparation for the forecasted increase in ozone levels. The stations are pending approval from the EPA, but selected locations include: Erda and Bountiful UDAQ monitoring sites, Environmental Quality Technical Support Center (near Salt Lake City International Airport), and University of Utah Meteorological Station (near Red Butte Garden). The location for a fifth station has not yet been selected. The sites will contain the following measurements:
- Hourly averaged speciated volatile organic compounds (VOCs) (PAMS target list compounds)
- Hourly averaged formaldehyde
- Hourly averaged mixing-height measurements
- Hourly average meteorological parameters
- True NO2 measurements and/or NOY measurements
There may be additional measurements included in the EMP that could include low-cost sensors and other parameters as UDAQ gets further along. Some of these additional measurements may be collected at existing monitoring sites or will be located at new sites as it’s determined what best meets the UDAQ data needs.
UDAQ predicts that the Wasatch Front is at risk of serious non-attainment for ozone in mid-2025. The current lack of ozone monitoring and non-attainment at existing monitors has triggered the need for an enhanced ozone monitoring plan. The PAMS program is designed with the objective to produce an air quality database to be used to evaluate and refine ozone prediction models. In addition, the program will assist to identify and quantifying the ozone precursors, establish the temporal patterns and associated meteorological conditions to assist and refine the control strategies. The Brigham City PM2.5 monitoring site is located strategically to assess changes in areas experiencing population growth and will further assist the UDAQ in optimizing the monitoring instruments in its network to account for the projected growth in Utah.
Impacts to Permitting
Additional monitors likely drive even more requests from UDAQ for state level modeling whether modeling thresholds are exceeded by the project or not. New background data will become available and need to be considered in future modeling analyses. Additionally, proposed emissions rates when permitting in areas with higher Ozone or PM2.5 background are anticipated to be evaluated more closely by UDAQ through BACT analysis to ensure the State Implementation Plan (SIP) reasonable further progress goals can be achieved.
If you would like to discuss the proposed updates to UDAQ and how they may impact your facility, please email Brian Mensinger in Trinity’s Utah office or call 801.946.7342.