Continuous PM 2.5 Monitoring Issues

1. Continuous PM2.5 Monitoring Issues National Air Quality Conference, Portland Oregon, April 6, 2008

2. U.S. PM Continuous Monitoring History • 1990 • First PM10 automated equivalent methods approved. • 1997 • PM2.5 NAAQS and monitoring rules • Classes of equivalency introduced; however, specifics not included for class III (i.e., continuous monitors) • First specific network requirements for PM2.5 continuous monitors – one per metropolitan areas over 1M people • 2001 • CASAC Workshop on accommodating emerging technologies into routine air monitoring networks • 2002 • Continuous Monitoring Implementation Plan developed and reviewed by CASAC • 2003 • AIRNOW goes public with reports and forecasts using PM2.5 continuous monitoring data • 2006 • EPA finalizes PM NAAQS and monitoring rules with several provisions for PM2.5 continuous monitors • 2008 • March 12 - EPA-ORD approves Met One BAM 1020 as a PM2.5 FEM

3. PM2.5 Continuous Mass Sites by Method TEOM FDMS BAM NEPHELOMETER

4. Questions of the Day • What key provisions of the monitoring regulations impact continuous PM2.5 monitoring? • What flexibility will EPA provide in the reporting and use of data from newly deployed FEM monitors? • How will the data from FEM’s and ARM’s be used to calculate design values? • What are the recommended best practices for operating and maintaining continuous PM2.5 monitors? • How can continuous PM2.5 monitors be used in support of emergencies and natural events? • How will State/local/Tribal agencies utilize approved monitors in their networks?

6. Regulations that affect PM2.5 continuous monitoring(October 2006 revisions)

7. PM2.5 Class III FEM Testing Requirements • Vendor driven process – submits application to U.S. EPA Office of Research and Development. • Three FRM samplers and three candidate FEM samplers for each test campaign. • Minimum of 23 valid sets of data per campaign (22 – 25 hours in duration for each sample). • Precision requirements for FRM and candidate FEM’s. • Total of 4 test sites (5 campaigns). • Criteria for multiplicative bias, additive bias, and correlation. • Candidate method must “pass” at each test location (seasons can be combined)

8. PM2.5 Class II and III Test Site Summary

9. Performance Criteria for Approval of Federal Equivalent Methods (PM2.5)

10. PM2.5 and PM10-2.5 Class II and III Methods Correlation Criteria • Correlation is r (not r2) • CCV is a measure of the spread of the sample concentrations

11. PM2.5 Federal Equivalent Method (FEM) Update • Met One BAM 1020 Approved • Two other instrument companies have stated they are testing candidate FEMs • EPA-OAQPS is making plans to develop supporting documentation for monitoring agencies who implement PM2.5 FEMs • Standard Operating Procedures based on expert use of the instruments • Let us know if you have advice/input on a FEM?

12. Approved Regional Methods (ARMs) for PM2.5 • A PM2.5 continuous method approved for use within a State, local, or Tribal agency used to meet multiple monitoring objectives such as NAAQS, Air Quality Index, and forecast validation. • Allows agencies to optimize their PM2.5 network with well performing (and currently deployed) continuous methods that may not perform well in all required FEM testing regions. • Monitoring Agency-driven Testing Process • Uses basically the same performance criteria as Class III methods. • Testing occurs at subset of sites in the network within which it’s intended to be used. • Approvals • Initial ARM application approved through EPA’s Office of Research & Development. • Subsequent applications for method in another agency’s network approved by EPA Regional Office. • All procedures (including proposed use of data transformations) must be fully described in Quality Assurance Program Plan accompanying ARM application. • OAQPS developed FEM/ARM tool to help with calculations

13. Implementation Issues with ARM Rule Language • Appendix C requires use of an inlet and separation device (if needed) that are already approved in either appendix L (PM2.5 FRM) or under Part 53 as an FRM or FEM. • OAQPS has determined that SCC (sharp cut cyclone) based test data from candidate ARM continuous monitors are not acceptable because the SCC was never an EPA-approved separator. • OGC shot down “functional equivalence” rationale. • Year of test data must be obtained using the VSCC (very sharp cut cyclone). • Doesn’t effect nephelometer-based ARM applications.

14. Other Requirements • Daily operating schedules for design value monitors within 5% of 24-hour NAAQS • Instituted to account for 98th percentile bias in 1-in-3 day FRM/FEM filter-based samplers • FEM or ARM monitors can be used to meet requirement • Continuous monitoring requirement (does not have to be FEM or ARM) – one half of required monitors – in addition to FRM/FEM filter-based samplers • Requirement is met with deployment of continuous FEM/ARM monitors

15. PM2.5 Continuous MethodsQA Requirements

16. Affect of adding FEM’s to QA Programs • Will need to identify FEM’s in Quality Assurance Project Plan • Regions may have different mechanisms for doing this • QA Requirements for FEM and FRM the same • Flow Rates (verification and audits) • Collocation • PEP Don’t confuse PM10 FEM requirements with PM2.5 FEM requirements

17. PM2.5 FEM Requirements (Yellow Area)

18. PEP Requirements All sites (FEM and FRM’s) added together then: • < 5 sites, 5 audits • > 6 sites, 8 audits • Must have each method designation audited each year • All samplers/monitors audited within 6 year period • Bias calculations (AMP255) performed on Primary Quality Assurance Organization (PQAO) level of aggregation, but can probably revise to method designation level • Annual PEP report will break out by method designation

19. Basic Rules – Using example FEM (A) • 15% collocation from each method designation (20* 0.15=3) • 50% of collocated must be with FRM; 50% with FEM. If there are an odd number of monitors • the FRM gets the extra (Section 3.2.5.2) • Precision calculation (AMP255) performed at PQAO level (aggregation of all method designations) FEM Collocation Requirement (Table A-3 40 CFR Part 58 App A) Extreme Example- One PQAO with FRM monitors (one method designation) and 3 FEM method designation in Network

20. Deploying Continuous FEM’s in the PM2.5 NetworkIssues for Monitoring Agencies to Consider **For Discussions Purposes at NAQC – Does not represent EPA Policy**

21. Transition Issues with Continuous PM2.5 FEM’s“Look Before You Leap”

22. Suggested Transition Strategy for Continuous PM2.5 FEM’s**For Discussions Purposes at NAQC – Does not represent EPA Policy** • Classify new FEM’s initially as Special Purpose Monitors (SPM’s) • However, cannot be used to meet minimum monitoring requirements if so classified • Data will not be used to augment FRM’s for a limited test period • Deploy with collocated FRM’s to meet or exceed QA requirements for collocation • Suggest multiple collocated sites with at least one site having a 1-in-3 day FRM • Data Reporting (following initial break-in period) • Suggest reporting FEM data as AQS parameter 88501 – Raw data – during test period. Keeps test data out of 88101 bin used for NAAQS comparisons. • Could also apply a pre-existing “FRM-like” correction for AIRNOW reporting, if necessary, and to support parameter 88502 – Acceptable PM2.5 AQI • EPA will not prevent initial classification as SLAMS and reporting as 88101 if S/L/T and Region agree this is the right thing to do. • Review data carefully (raw FEM versus FRM) for agreement that meets Class III criteria over test period • Then…………next slide…….. Note – all network modifications should be reviewed by the Regional EPA Office and documented in the Annual Monitoring Network Plan

23. Suggested Transition Strategy for Continuous PM2.5 FEM’s**For Discussions Purposes at NAQC – Does not represent EPA Policy** • After 1 year period as an SPM, review data status: • Agreement with FRM meets the Class III criteria -> Reclassify FEM(s) to SLAMS (data in play for augmentation, FRM shut-downs are possible). Report FEM as parameter 88101 following SLAMS classification. • Agreement with FRM does not meet the Class III criteria but can be corrected • Maintain SPM status for up to a second year • Further investigate reason(s) for differences while continuing to report FEM data as 88501 and 88502 • Consider the ARM or user modification option for transforming data with ultimate goal of conversion to SLAMS • Agreement cannot be corrected to meet Class III criteria • Discuss issues with vendor, S/L/T colleagues using same FEM, and Regional Office • Consider discontinuing operation and rethink further purchases of this method Note – all network modifications should be reviewed by the Regional EPA Office and documented in the Annual Monitoring Network Plan

24. Questions?