Modeling & Monitoring Update

1. Modeling & Monitoring Update Todd Rinck EPA Region 4, APTMD Fall 2016 Region 4 Air Directors’ Meeting St. Petersburg, Florida November 9, 2016

2. Alternative Model Approvals • Alternative model approval requirements are contained in EPA’s Guideline on Air Quality Models (40 CFR Part 51, Appx. W, Section 3.2.2) • EPA Regions approve alternative models, including AERMOD beta options. • Approvals must be done in consultation and concurrence with the Model Clearinghouse, which allows for national consistency in approvals and transparency with stakeholders. • NO2 Tier 3 proposals require RO approval, no Model Clearinghouse concurrence • Dec. 10, 2015 EPA memo clarified recommended/preferred model “beta options” • If a beta option in a EPA preferred model is used, then preferred model status is changed to alternative model and is subject to Appendix W, Section 3.2.2 requirements.

3. Modeling for SO2 DRR Sources Round 3 Designations required by December 2017 • All R4 states provided required Modeling Protocols and Monitor Siting information by the July 1, 2016, due date. Thank You! • R4 staff have reviewed, provided comments on Modeling Protocols for 50 DRR facilities • R4 staff are working with states to address issues identified in our comments • Modeling reports/results are due by January 13, 2017

4. Monitoring for the SO2 DRR Sources Round 4 Designations required to be complete by December 2020 • R4 approved/expects to approve monitors in 7 areas where states are choosing ambient monitoring to characterize impacts by 2020 (Round 4 designations) • 1 area in AL, 1 area in GA, 1 area in KY (2 sources-1 monitor), 4 areas in NC (maybe 5) • R4 reviewed modeling used to site SO2 DRR monitors. Siting followed the SO2 NAAQS Designations Source-Oriented Monitoring Technical Assistance Document • R4 monitoring and modeling staff worked closely with state staff to identify appropriate monitoring locations • R4 monitoring staff visited each proposed monitoring site with states staff

5. NATTS Updates • Final NATTS TAD was sent to agencies on October 25th • EPA received 1,200 comments on revision 2 of the TAD • A workgroup including SLT stakeholders addressed the comments • Plan is to disseminate comment resolution details • Compliance is expected by the end of October 2017 • Updates include: • VOCs – subambient vs pressurized • Siting criteria • Method Detection Limits (MDLs) • AQS guidance for reporting • Analyte identification guidance • Quality systems guidance & reqmts • Equipment calibration • Validation tables

6. Network Plan Technical Requirements • 40 CFR§58.10(a)(1) -- The plan shall include a statement of whether the operation of each monitor meets the requirements of appendices A, B, C, D, and E of this part, where applicable. • A recent Region 6 EPA IG report found: • “The annual plans did not provide evidence that each monitoring site met regulatory siting criteria.” • EPA “could improve its review process to better ensure that annual plans are more complete and accurate, to provide reasonable assurance that monitors are located in representative areas and are operated in accordance with EPA requirements.”

7. Network Plan Public Inspection and Comment • The recent Monitoring Rule Revision modified the network plan public inspection and comment requirements (40 CFR §58.10(a)(1)) • The annual monitoring network plan must be made available for public inspection and comment for at least 30 days prior to submission to the EPA and • The submitted plan shall include and address, as appropriate, any received comments.

8. Evidence of Meeting QA Requirements in Network Plans • Region 4 asks agencies to include a list of their QA documents and the approval dates in their annual network plans

9. Evidence of Meeting Siting Criteria in Network Plans • In the past, agencies have stated in their plans that all of their sites meet siting criteria. • Recent TSAs have found siting issues. • Region 4 is now requiring that agencies provide a minimal amount of information to verify that sites meet these criteria. *This tape measure is not NIST certified...probably.

10. Evidence of Meeting Siting Criteria in Network Plans • Photos: N, S, E, W • At a minimum, photos should be updated for each 5yr assessment. • Ideally photos should be updated each year • Date of last site evaluation • Ideally agencies should evaluate sites once a year • Include information in the plan: • Probe height • Distance to nearest obstructions • Corrective actions planned or taken to correct deficiencies

11. Questions?

12. CitySpace Air Sensor Research Project in Memphis, Tennessee • Participants and Collaborators: • EPA Regions 4, 6, and 7; EPA Office of Research and Development (ORD); Memphis and Shelby County Health Department; Mississippi Department of Environmental Quality, Arkansas Department of Environmental Quality; Memphis Area Transit Authority; University of Memphis • Objectives: • Field-test new, lower-cost PM sensors in the Memphis area. • Understand how this emerging technology can add valuable information about air pollution patterns in neighborhoods. Fact Sheet: https://www.epa.gov/air-research/cityspace-air-sensor-network-project-conducted-test-new-monitoring-capabilities

13. CitySpace Air Sensor Research Project in Memphis, Tennessee • Sensor pods were installed at 16 sites in October 2016, and will continue monitoring until February 2017 • Two additional sites to be installed in November • Each sensor pod continuously measures: • PM in various size increments • Wind speed, wind direction, temperature, and humidity • Monitoring locations were selected with input from the local community, and by using mapping tools developed by EPA’s Sustainable and Healthy Communities research program • Several monitors are co-located with regulatory PM2.5 monitors

14. Community AirSensor Network (CAIRSENSE) Project Overview • Participants: • EPA Regions 4, 1, 5, 7, and 8; EPA Office of Research and Development (ORD); EPA Office of Air Quality Planning and Standards (OAQPS); and Georgia Environmental Protection Division (EPD), Colorado Department of Public Health and the Environment; Jacobs Technology (ORD contract support). • Objectives: 1. Evaluate in situ the long-term comparability of several lower cost sensors of interest against regulatory monitors. 2. Determine the capabilities and limitations of a long-term multi-node wireless sensor network applied for community air monitoring, in terms of operational stability (communications, power) and long-term data quality under ambient conditions. Research findings available: https://www.epa.gov/air-sensor-toolbox/air-sensor-toolbox-resources-and-funding#RTF

15. CAIRSENSE Correlation matrix (Pearson correlation) of 12-hr average PM between sensors and co-located FEM SAFT-Egg 3 Dust SAFT-Egg 3 Dust Moderate to high correlation between most identical units SAFT-Egg 1 Dust SAFT-Egg 1 Dust SAFT-Egg 2 Dust SAFT-Egg 2 Dust SAFT-Shinyei 2 SAFT-Shinyei 2 SAFT-Shinyei 1 SAFT-Shinyei 1 SAFT- Dylos 1 S SAFT- Dylos 1 S SAFT- Airbeam 3 SAFT- Airbeam 3 SAFT- Airbeam 2 SAFT- Airbeam 2 SAFT- Airbeam 1 SAFT- Airbeam 1 SAFT- Dylos 3 S SAFT- Dylos 3 S SAFT- Dylos 2 S SAFT- Dylos 2 S FEM PM2.5 FEM PM2.5 SAFT- MetOne 3 SAFT- MetOne 3 SAFT- MetOne 1 SAFT- MetOne 1 SAFT- MetOne 2 SAFT- MetOne 2 Variable correlation with reference (r = -0.06 to 0.68) WSN-N4 Shinyei WSN-N4 Shinyei

16. SAFT-Aeroqual 2 SAFT-Aeroqual 2 SAFT-Aeroqual 1 SAFT-Aeroqual 1 CAIRSENSE Correlation Matrix of Hourly Average O3 between Sensors and Co-located FEM FEM O3 FEM O3 WSN N4-Aeroqual WSN N4-Aeroqual Strong correlation between identical units WSN N4- CairClip (-FEM NO2) WSN N4-CairClip (-FEM NO2) SAFT-AQMesh 2 SAFT-AQMesh 2 SAFT-AQMesh 1 SAFT-AQMesh 1 SAFT_CairClip 1 (-FEM NO2) SAFT_CairClip 1 (-FEM NO2) Variable correlation with reference (r = 0.15 to 0.95)

17. The following slides are topics that I expect Chet to cover, but in case he doesn’t address all of them we can include these slides. Otherwise, we can leave them out.

18. Proposed Revisions to Appendix W Guidelines • EPA Proposed Revisions to Appendix W on July 14, 2015 • Public Hearing held and Comment Period closed October 27, 2015 • Final revisions expected November 2016 – Currently in OMB review process • EPA’s OAQPS and Model Clearinghouse are responsible for the development and proposal of all preferred models or techniques per Appendix W, Section 3.1. • Major Proposed changes include: • Codifying the process of the Regional Offices consulting and coordinating with the Model Clearinghouse on all approvals of alternative models and techniques • For long-range air quality assessments, the EPA is proposing to remove CALPUFF as a preferred model • Incorporate current modeling techniques to address the secondary chemical formation of fine particle and ozone pollution from direct, single source emissions • To provide more flexibility and improve the meteorological inputs used for regulatory modeling

19. PM2.5 and Ozone Significant Impact Level (SIL) Guidance • Recommends PM2.5 and Ozone SILs and provides a stronger technical basis for SILs • Draft ozone and PM2.5 SIL guidance posted online on August 1, 2016, updated on August 8, 2016 • Guidance and Supporting documents (including the technical basis document) were made available for informal review and comment through September 30, 2016 • EPA plans to issue final guidance by the end on 2016 • Additional information available at the following website: https://www.epa.gov/nsr/webinar-draft-sils-guidance-august-24-2016 • Please contact Jennifer Shaltanis at OAQPS with any questions at 919-541-2580 or shaltanis.jennifer@epa.gov

20. Model Emission Rates for Precursors (MERPs) Guidance • SILs guidance will be complemented by the development of MERPs guidance • (NOx and VOC for ozone) and (NOx and SO2 for PM2.5) • Used as a tier 1 “screening tool” to determine if modeling is required • Intertwined with SILs • EPA has switched to near-term guidance for quicker response instead of a rulemaking as originally planned • Note: There will not be a single national number for MERPs • Guidance will provide recommended procedure for developing regional, state-specific MERPs • Draft MERPs guidance expected soon (review and comment) • Final MERPs guidance expected shortly after SIL guidance