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Fact Sheet 1. National Ambient Air Quality Standards (NAAQS):
Ozone (eight hour average): 75 parts per billion (ppb) PM2.5*: (24
hour average): 35 micrograms per cubic meter of air (ug/m3) *fine
particle matter less than or equal to 2.5 microns in diameter 2.
April 2014 NAAQS exceedances related to burning of rangeland:
KANSAS (source:EPA Air Data website
http://www.epa.gov/airquality/airdata/ad_data_daily.html) Date
Monitor Site Metro Area PM2.5 ug/m3 Ozone ppb 4/5/14 Health
Department Wichita 49.5* 4/5/14 Peck Sumner Co 50.6 4/5/14 K96
& Hydraulic Wichita 50.5 4/5/14 Glenn & Pawnee Wichita 42.5
4/11/14 Health Department Wichita 85 4/11/14 Peck Sumner Co. 79
4/11/14 Sedgwick Wichita 77 * Average of principal and co-located
monitors NEBRASKA (source: EPA Air Data website or the Nebraska
Dept. of Environmental Quality) Date Monitor Site Metro Area PM2.5
ug/m3 3/30/14 LLCHD - 3
monitors* Lincoln 36.5
4/6/14 LLCHD - BAM Lincoln 38.6 4/12/14 Bellevue Omaha 37.4
4/18/14 LLCHD - BAM Lincoln 60.5 * The Lincoln-Lancaster County
Health Department contains two federal reference monitors, one
sampling every sixth day co-located with another sampling every 3rd
day, plus a BAM continuous monitor.** On March 30, the measured 24
hour values were 38.7, 32.1 and 38.7 ug/M3 respectively, for an
average of 36.5 ug/M3. **The LLCHD operates a "beta attenuation"
continuous monitor (BAM) for the purpose of issuing health
advisories. This data is reported to Air Now for the Air Quality
Index but is not used for NAAQS compliance purposes. Bellevue is
also a continuous BAM monitor that is used for compliance
purposes.
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3. History of Acres Burned in the Flint Hills (Source, KDHE, May
29, 2014)
4. EPA Rules for locating air quality monitors. In general EPA
rules dictate that PM2.5 air quality monitors be placed primarily
in and around the largest population centers in a state and/or at
locations that are believed to be relatively close to a violation
(85%+ of the NAAQS "design value").1 Since EPA and KDHE have
apparently speculated that PM2.5 values in Flint Hills region do
not lie within 85% of the standard, the region, and points
downwind, would not qualify for a mandatory monitor under current
rules. Of course one might ask, if there have never been any such
monitors in this region, how would KDHE know what the design values
are? In any event EPA rules fail to anticipate that, in the month
of April each year, intensive range burning, combined with the
prevailing southerly winds and the north-south orientation of the
Flint Hills physiographic region, sends pulses of thick smoke
streaming to the north, subjecting rural residents and residents of
small towns and cities to a known health hazard. In the case of the
2014 event, the timely detection of PM2.5 exceedances from the
Flint Hills burning was possible only because Lincoln and Omaha are
large metropolitan areas which, on account of their large
populations, host continuous PM2.5 monitors. EPA considers
continuous monitors crucial for informing the public during air
pollution episodes via the Air Quality Index system and in support
of emergency situations like wildfires.1
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EPA rules also say, however, that in connection with a state's
annual monitoring plan, the EPA Regional Administrator is
authorized to approve the placement of PM2.5 monitors in other
settings where "there is reason to believe PM2.5 concentrations are
of concern." In addition a state may place a monitor in any
location of its choice without need for EPA approval.1 5. Other
Monitors in, or directly downwind of, the Flint Hills. KDHE
operates an IMPROVE monitor on the premises of the Tallgrass
Prairie National Preserve near Strong City in the Flint Hills. It
is part of a nationwide system designed to assess visibility and
haze. EPA allows a state to count an IMPROVE monitor as satisfying
its obligation to provide background and (long-range) transport
monitoring for PM2.5. While this filter-based monitor measures
PM2.5, it takes samples only every third day and data may not be
available for several months.2 Thus, it cannot be used, like a
continuous monitor, to detect a health hazard on a near real-time
basis. In their August 30, 2010 five-year monitoring plan KDHE said
they planned to add an NCore monitor to the Tallgrass Prairie
National Preserve site in the Flint Hills.3 It had been approved by
EPA in October of 2009. NCore is another national network of
monitoring sites that is designed in part to assess rural air
quality.4 The Ncore network is specifically designed to provide
timely reporting of data to the public through the AIRNow website
(www.airnow.gov) for air quality forecasting, and to support
scientific studies. NCore sites include continuous monitoring of
ozone and PM2.5 and would be capable of assessing air quality on a
near real time basis in the Flint Hills. However, based on
documents obtained from KDHE, the Department notified EPA Region 7
in early 2011 that they were no longer interested developing the
site due to funding and personnel shortages.5 EPA responded by
asking KDHE what they would need from EPA to proceed, and noted
that KDHE had expressed interest in modifying the site to run only
selected analyses.6 KDHE provided no additional documents
describing a response to EPA's request. Very recently EPA Region 7
confirmed that the proposed NCore monitor had not been installed,
and there is no timetable for if, or when, it will go ahead.7
Topeka hosts both a continuous ozone monitor and a continuous PM10
monitor, but its filter-type PM2.5 monitor operates only every
third day. There are three filter-type PM2.5 monitors in Wichita
that operate every third day and a co-located filter-type that
operates every sixth day. All of these operate on the same schedule
rather than being staggered to cover each day. In their latest
annual monitoring plan KDHE says they are "considering" adding a
combination, continuous PM10/PM2.5 monitor to their Topeka
monitoring site.5 6. Fine Particle Monitoring Coverage. During the
2009 - 2011 burn seasons, Wichita and Topeka together experienced
eleven ozone exceedances, but nearby filter-based PM2.5 monitors
took samples during only three of those episodes. In 2014 the
Topeka continuous ozone monitor, that is capable of detecting a bad
air day on a near real-time basis, did not approach the ozone
standard on the days when PM2.5 exceedances were experienced in
Lincoln and Omaha, Nebraska. That could be because the winds were
veering to the northwest over the Flint Hills, or it may have been
mostly cloudy which would have limited the formation of ozone from
the precursors present in the smoke. Not only is a continuous ozone
monitor an inadequate surrogate for a continuous PM2.5
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monitor but, in any event, the shut down of the Konza Prairie
monitor last year left no ozone monitor between Topeka and the
Cedar Bluff Reservoir west of Hays, a distance of 230 miles. The
continuous PM10 monitor in Topeka is also not able to detect a
dangerous elevation of PM2.5 fine particles. 7. KDHE Health
Advisories related to Flint Hills rangeland burning. The Smoke
Management Plan (SMP) (http://www.ksfire.org/) states that KDHE
will issue a general health advisory prior to the Flint Hills
burning season. The SMP also states " if conditions are favorable
for significant rangeland burning, a specific health advisory for
the following days is issued." In 2014 KDHE issued their general
advisory on Feb. 28, but despite the exceedances related to five
separate burn days in Kansas or southern Nebraska, we found no
other advisories issued by KDHE during the burn season
(http://www.kdheks.gov/news/). Nebraska authorities did issue
advisories when their monitors detected the problem on April 11
& 18.8
The lack of monitors in and around the Flint Hills during burn
season calls into question the results of any health study
conducted by state or federal agencies, because they will be unable
to accurately estimate the actual level of exposure suffered by
downwind human receptors. 8. Qualifications and contact information
for Dr. Magzamen,
http://www.cvmbs.colostate.edu/DirectorySearch/Search/MemberProfile/CVMBS/34735
9. Sierra Club Policy on rangeland burning in the Flint Hills. The
Sierra Club does not object to rangeland burning, if it is
conducted in a manner that avoids impacts to the public health and
avoids significant damage to wildlife habitat. The problem in the
Flint Hills is the wholesale burning of rangeland on just a few
days in April every year followed by a high density of cattle
grazing. Research has demonstrated that better alternatives are
available such as "patch burn" where a third of a ranch's land is
burned each year in rotation.
http://kansas.sierraclub.org/patch-burn-grazing-in-tallgrass-prairie/.
In addition, it is not necessary for ranchers to burn in the same
narrow time-window in April of every year, though challenges to
this conventional wisdom has generated a fierce debate.
http://cjonline.com/news/business/2014-10-11/ksu-severs-ties-author-controversial-prairie-burn-research-article
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10. Selected Smoke and Fire Maps, April, 2014 Fires and Smoke on
April 11, 2014
Fires and Smoke on April 18, 2014
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Smoke and Wind Direction on April 11, 2014: Cedar Bluff monitor
at west and Kansas City to east.
Source of graphics: NOAA
http://satepsanone.nesdis.noaa.gov/FIRE/fire.html) References: 1.
Fed. Register/Vol.71, No. 200/Tues, Oct 17, 2006/Rules and
Regulations, P. 61263 "Requirements for Operation of PM2.5
stations." 2. http://vista.cira.colostate.edu/improve/ 3. KDHE,
5-Year Ambient Air Monitoring Network Assessment , August 30, 2010
, available from search of KDHE website. 4.
http://www.epa.gov/ttn/amtic/ncore/networks.html 5. KDHE, 2011 –
2012 Ambient Air Monitoring Network Plan, July 2011. 6. Email from
Robert Nichols, EPA R7 to Tom Gross and Douglas Watson, KDHE, March
09, 2011. 7. Email from Lachala Kemp, EPA Region 7, to Craig
Volland of the Kansas Sierra Club, August 21, 2014. 8. Nebraska
Health Advisories
http://lincoln.ne.gov/city/mayor/media/2014/041114a.htm
http://lincoln.ne.gov/city/mayor/media/2014/041814a.htm
http://journalstar.com/news/local/air-quality-health-advisory-issued-because-of-smoke/article_09e365aa-7a34-514f-b152-377734409f6c.html