EPA Update/Discussion on the National Monitoring Strategy, and Other National Monitoring Issues

1. EPA Update/Discussion on the National Monitoring Strategy, and Other National Monitoring Issues Tim Hanley - EPA OAQPS WESTAR - Continuous PM2.5 Monitoring Workshop April 13th, 2005 Portland, Oregon

2. Agenda • Background • National Ambient Air Monitoring Strategy Development • Strategy Components • NCore Level II • Technology • Regulatory Changes • Communications and Outreach • Implementation Plan Summary • Monitoring Regulation Proposal Package • Resource Support for NMS Implementation • Technology Transfer and Training • PM coarse (PM10 - PM2.5) Notes • Speciation Program Notes • Draft PM2.5 Equivalency Criteria

3. Background: Major Themes and Objectives • Major Themes: • Multiple pollutant measurement infrastructure to support integrated air program management • The right data to support science and policy • Public Reporting • Flexibility to align resources to the most important monitoring now and in the future • Objectives: • Overall - Create a more responsive and value added network • Specific: Transition to a true multiple pollutant measurement (aerosols, gases, precursors and end products, criteria and non criteria) framework emphasizing rapid, near continuous data delivery….that supports (equally): • Public Reporting - S/L/T web sites & AIRNow • Review/Development of NAAQS/related health studies • Accountability for CAIR and other major programs (and AQ trends) • Strategy development (SIPs, CAIR+, etc.), e.g., model evaluation • Compliance (e.g., NAAQS comparisons for attainment/nonattainment) • Science support….(methods, atm. processes, health research) • Ecosystem assessment (new) This transition occurs from a historically layered single pollutant design emphasizing (and strongly perceived) as only serving a compliance objective.

4. Implications from NAS…CASAC…CAAAC • National Academy of Sciences Reports • Air Quality Management in the United States • Calls for broader multi-pollutant integration • Additional attention to air toxics and ecosystem/multimedia • Catalyzed new CAAAC S&T and Policy subgroups • Research Priorities for Airborne Particulate Matter • Advocate multi-pollutant measurement approaches • CASAC subcommittee on Monitoring • Strong endorsement • CAAAC S&T subgroup.. Draft Recommendations • Endorse EPA’s proposed national monitoring strategy and encourage regional monitoring strategies. The existing monitoring networks are top-heavy on compliance and light on addressing other monitoring objectives, especially control strategy development and accountability. A redistribution of monitoring resources may be necessary. • Collective message • EPA is relying on the strategy to demonstrate commitment to change

5. National Ambient Air Monitoring Strategy Overview – Why?

6. National Ambient Air Monitoring Strategy Development • October 2001 – 3 day workshop on National Monitoring strategy with States, locals, Tribes and EPA. • July 2002 – The National Monitoring Strategy Steering Committee met to discuss the first draft of the monitoring strategy document prior to release for review to the public • Sept 2002 – OAQPS Office Director S. Page releases document for review • OAQPS solicits comments on document through March 2003 • July 2003 – CASAC technical subcommittee meets to discuss draft strategy • Nov 2003 – CASAC provides comments to Administrator • April 2004 – Final Draft of NMS posted on AMTIC • December 2004 - CASAC Technical Subcommittee meets to review National Monitoring Strategy Implementation Plan

7. National Monitoring Strategy Major Components NCore Monitoring Network Network Assessments Technology Quality Assurance Monitoring Regulations Communications and Outreach NCore Level I Research Sites Ncore Level II Multi-pollutant Sites Manual Methods PM2.5 FRM, HNO3, NH3 Continuous Methods for: NO/NOy, SO2, CO, PM2.5, PMc Meteorology for: T, RH, WS, WD NCore Level III Strategy Components

8. Working with EPA Regions, State, and local agencies on first pass at NCore Level II site recommendations:

9. Technology • Three major technology needs identified as part of the National Monitoring Strategy: • Timely reporting of high quality, highly time-resolved ambient monitoring data; • Share all continuous O3, PM2.5, and PM10 data • Share all NCore level II continuous data • CO, SO2, NO/NOy • Meteorology • Collocated characterization of precursor gases • CO, SO2, NO, and NOy – pilot this year • Ammonia and Nitric Acid gases • Highly time-resolved, spatially rich PM2.5 data

11. New Procedures for Storing PM2.5 Continuous Monitoring data in AQS • Objective: • Store PM2.5 continuous monitoring data in AQS in a way that data users understand comparability to the FRM; therefore, providing greater utility and use of data. • Solution: • Need to delineate valid data that is FRM-like from valid data that is significantly different from the FRM. • Continue to store valid PM2.5 continuous monitoring data that is FRM-like as “PM2.5 at local conditions” - parameter code 88101. • Store valid raw data that is significantly different than the FRM as “PM2.5 Raw Data” - parameter code 88501. • Store valid data from instruments measuring “Total Atmospheric PM2.5” as parameter code 88500. • Memo explaining details is being prepared

12. Current and Planned Parameters for the AIRNow Data Management Center Current Parameters Precursor Gas Parameters Speciation Parameters Meteorological Parameters

13. Draft Federal Equivalent Method approval criteria for PM2.5 Continuous Monitors • Data Quality Objective process that links equivalency criteria to expected data quality in network • Extensive statistical investigation with EPA – OAQPS, EPA - ORD, RTI, and Battelle. • Expect to propose as applicable to both National Equivalency and Regional Approved Methods

14. Update on the development of precursor gas analyzers • Multiple companies identify having high sensitivity gas analyzers: • Thermo Environmental Instruments • API • Ecotech • EPA-OAQPS staff have met with all three companies - some on multiple occasions. • EPA OAQPS has a dedicated team working on precursor gas analyzers • Laboratory study is complete • Field Study about to begin • Testing trace gas analyzers with two commercial data management systems • ESC 8832 • Also worked with 8816 • Envidas • State/local/Tribal/CASTNet pilot of precursor gas analyzers this year Mention of commercial names does not constitute endorsement by EPA

15. EPA - OAQPS Trace Gas Products • Short written summaries of each method - have been distributed • Laboratory and field study designed to determine a number of performance characteristics - Study results are available from laboratory • Developing a Technical Assistance Document (TAD) on trace gas monitoring • work assignment with Battelle • building from existing knowledge and what were learning from the current commercially available trace gas analyzers • Soliciting review from 3rd party expert • SOP’s • Available on AMTIC web site - www.epa.gov/ttn/amtic/precur.html • applicable to each make and model our trace gas team is working with • will include separate SOP(s) on data management • Data Quality Objectives • scheduled for development this year • Data reporting changes necessary for receipt of data at: • AQS • AIRNow

16. National Monitoring Strategy - Regulatory Changes • 1) The draft regulations to support implementation of the National Monitoring Strategy are being recommended by staff. Ultimately, the EPA Administrator makes the final decision to actually propose any changes. • 2) Describe how the monitoring regulatory changes fit into the broader National Monitoring Strategy • 3) Provide information on the ambient monitoring strategy regulatory package: • - What are the major themes? • - What are the major changes to the ambient monitoring program? • - How was the proposal package was put together • - Who has provided input? • - Review and next steps?

17. How do the monitoring regulatory changes fit into the broader National Monitoring Strategy? National Monitoring Strategy Required Monitoring Activities By Regulation Non-regulated Activities, but provided for as part of NMS PM2.5 Monitoring Programs PM2.5 Monitoring Programs FRM/FEM Supp. Spec. Sites STN Continuous Speciation Continuous IMPROVE Class 1 Areas QA - PEP State Protocol Sites PM10 NCore Level II New Measurements Trace gases CO, SO2, NOy Ammonia Met: Ta, WS, WD, RH Nitric Acid Ozone Monitoring Programs Air Toxics Monitoring Ozone Monitoring NATTS PAMS Community Projects Meteorology S/L AT monitoring Ozone Precursors NCore Level 1 Research Sites Criteria Gases – CO, SO2, NO2 CASTNet Pb National Performance Audit Program Blue - 103 (fully) Funded Yellow – 105 (shared) Funded Green – Mixed Funding Purple – Not Funded Gold – Funded from S&T or EPM

18. What are the major themes of the Regulatory Changes? • Multiple monitoring objectives • Collocation for multi-pollutant characterization • Continuous monitoring • Improved spatial coverage • Divestment of unnecessary monitoring • Clean up monitoring regulations no longer applicable

19. What are the major changes to ambient monitoring regulations? • First major restructuring of ambient monitoring networks since 1970’s - Introduction of National Core Network (NCore) • Re-invention of QA program • New, statistically derived equivalency criteria for approval of PM2.5 continuous monitors • Revised minimum network requirements for O3 and PM2.5 sites based upon concentration and population of area

20. First major restructuring of ambient monitoring networks since 1970’s • National Air Monitoring Stations (NAMS) distinction goes away • Introduction of National Core Network (NCore) • State and Local Air Monitoring Stations (SLAMS) essentially become NCore level III • Some new and many existing sites with several collocated parameters become NCore level II: • PM2.5 (FRM and continuous), PM10, O3, CO, SO2, NO/NOy • Meteorology: WS, WD, Ta, RH • Urban and rural components at representative sites • No regulatory requirements for: • NCore level I

21. Re-invention of QA program • Emphasis on Data Quality Objective process to establish performance based standards • PM2.5 - Already exists • Ozone - Newly developed • Updated QA to be consistent with EPA Order 5360.1 • Quality Management Plan (QMP) • Quality Assurance Project Plan (QAPP) • Quality Assurance Lead for an agency • Removal of antiquated requirements on manual methods no longer being used. • Changes in gas audit concentrations lower limit of range to reflect improvements in air quality. • Change in frequency of required gas monitor precision checks to include confidence limits. • PM10 collocation requirement updated to be consistent with PM2.5 • Change in statistics for assessment of precision and bias. • New bias statistics for lead.

22. Who has provided input on the monitoring regulations? • National Monitoring Strategy Steering Committee • Included national leaders in ambient monitoring and air quality management • Provided initial recommendations for re-inventing monitoring program • Monitoring Rule Workgroup formed in 2001 • Included EPA OAQPS, Regions, States, Locals, & Tribes • Met in a workshop in the fall of 2001 and several times via conference calls until spring of 2004. • Reviewed and provided recommended changes to monitoring regulations in detail • Quality Assurance Workgroup provided re-invented QA section of regulation • Technology Workgroup led initial efforts on PM2.5 continuous monitoring • ORD/OAQPS team provided new national equivalency criteria

23. Monitoring Regulations Part 50 NAAQS And Reference Methods Part 53 Approval of Reference and Equivalent Methods Part 58 Monitoring Regulations Reductions in reporting Requirements to AQS for sampler support data Class III Equivalency for PM2.5 Continuous Monitors Reporting and Data Certification, Sample Frequency Quality Assurance Appendix A Methodology Appendix C Regional Approved Methods Network Design Appendix D What’s Covered in the Proposed Changes to the Monitoring Regulations

24. Review and Next Steps for Proposal Package • What review has occurred on the proposal package? • Spring 2004: • S/L/T/EPA - Regulatory review workgroup conference calls • OAQPS/EMAD review of preamble • Summer 2004: • Further developed preamble • Solicited input from OAQPS policy staff • Internal monitoring staff review of whole package • Fall 2004: • Part 53 sections on Class III equivalency added • Entire proposal package sent back out to EPA Regional Offices for final read by monitoring contacts • Winter 2004-2005 • Prepared document for Federal Registrar • Package sent to EPA Office of General Council for legal review • What are the next steps? • Finish ICR (costing out required monitoring) • Clearance from OAQPS • EPA workgroup clearance • Send to OMB • Clearance by EPA and proposal published

25. Overall National Monitoring Strategy Communications and Outreach • Extensive outreach over the last 3 years to variety of stakeholders through conference presentations – including the NAQC, teleconferences, and meetings. • AMTIC web site dedicated to the National Air Monitoring Strategy • http://www.epa.gov/ttn/amtic/monitor.html • Two Clean Air Scientific Advisory Committee (CASAC) dedicated subcommittee public meetings • July 2003 - http://www.epa.gov/sab/pdf/casacl04001.pdf • December 2004 – Subcommittee response being developed • Expected to include recommendations for outreach on NCore level II sites • Senior Management briefings in OAR including the Assistant Administrator last June. • NMS Flyer for distribution to the public posted last summer with hard copies to Main City Libraries with populations over 1M; States, local, and Tribal monitoring programs; and EPA Regional Offices. • http://www.epa.gov/ttn/amtic/files/ambient/monitorstrat/aqbrochure.pdf • Planning underway for future workshops and conferences • Many aware of the process and generally supportive. Concerns, when raised, are usually over the details and funding

26. Implementation Plan Summary • Phased implementation starting now and through 2007 • 2005 Pilot of precursor gas monitors with States/locals/Tribes • Modifications in Regulations (proposal in 2005) • Codification of NCore • New criteria measurement minimums for Ozone and PM2.5 • Introduction of new performance based approaches for monitor approval • Regional Approved Method for continuous PM2.5 mass • New national equivalency standards for PM2.5 mass • Restructuring of QA….more DQO and PBMS emphasis • Resource Support for NMS Implementation • Redistribution/modifications in STAG 103 PM2.5 Grants and PAMS 105 • Largely, but not entirely, across measurements, not States.. • Technology Transfer and Training • Focusing on new technologies, QA • In-house and outreach

27. Resource support for NMS Implementation • Unused Section 103 Funds • Memo from OAQPS Director S. Page to Regional Air Division Directors to support 4 activities: • PM2.5 continuous monitors • Data management and telemetry equipment • Precursor trace gas monitors for CO, SO2, NOy • PM measurements that support ambient diesel characterization • Many NMS activities are already underway • Development of 2005 Grant Guidance • Planned budget was $42.5M • Maintain critical components of PM2.5 monitoring network. • Investments and divestments are identified, consistent with the National Monitoring Strategy. See section 11 - implementation plan • First planned resources to support implementation of Pilot NCore level II sites • Issues: • Phase shift between EPA fiscal year and availability of funds in monitoring grants • Purchase of trace gas equipment if not designated as reference or equivalent

28. Challenges to Implementation • Communications • Despite substantial outreach, many stakeholders are unaware of how the changes will affect them. • Network Design Issues • Divestment of some FRM and Speciation Sites that may be locally important • NCore Level II design • Appropriate balance between urban and rural monitoring • Integration of CASTNet • Policy tensions..(somewhat resolved) • Shift toward information/science, perceived less compliance • ALA raised concerns • Need for support by OAR, Regions, CASAC,… • Regulations • Definition of a special purpose monitor • Ozone requirements may be perceived as reducing requirements in some areas • Resource Issues • Costing our monitoring programs goes beyond capital acquisition and O/M • Also includes local, regional, and national data analyses; and internal and independent QA • Moving STAG 103 funds from conventional monitoring to independent QA and data analysis • Reluctance to change (States and EPA) • Magnified by $$$ in monitoring • Significant lag between planning and turn-key operation of new monitoring programs • $$$ for Level 1 sites….serious • Outside of STAG…similar to Supersite program

29. PM2.5 Monitoring Network Implementation • PM2.5 FRM’s • Attainment Designations final in ’05 • Number of FRMs expected to decrease • FY ’03 = 1095 • FY ’04 = 990 • FY ’05 = 917 • Speciation Program • Number of Speciation sites expected to decrease • Mostly 1/6 sites • FY ’03 = 286 • FY ’04 = 251 • FY ’05 = 227 • PM2.5 continuous monitoring • AQI with PM2.5 went public on AIRNow web site - Oct 1, 2003 • Number of sites expected to increase • FY ’03 = 305 • FY ’04 = 451 • FY ’05 = 522

30. Maintaining Critical Components • High Value FRM Monitoring Sites. • Speciation Trends Network. • Continuous Monitoring Network. • IMPROVE. • Performance Evaluation Program and filter procurement.

31. New Investments • NCore level II technology investments for PM precursor gases. This includes high sensitivity gas monitors for CO, SO2, and NO/NOy; and site improvements. • Continued investment in PM2.5 continuous monitoring network. Note: many areas already have robust networks. • Telemetry and Data Management Systems to support more timely data reporting and automated validation of data. • Thru-the-probe audit operation of National Performance Audit Program (NPAP) for gas analyzer independent audits. This is to be leveraged with the PEP program. • State Directed Data Analyses - Provide resources through multi-state organizations or other avenues to meet data analysis needs that are of interest to State and local agencies.

32. National Monitoring Strategy - NCore Level II Precursor Gas Monitoring Implementation • FY ’04 – Initial precursor gas method development • OAQPS laboratory study of trace gas monitors • FY ’05 – Pilot NCore level II sites for CO, SO2, and NOy at: • OAQPS field study • State/local/Tribal agencies: • 22 sites have planned funding for FY ‘05 • OAP-OAQPS CASTNET collaboration at 3 sites • FY ’06 – Final Rule incorporating National Core Network (NCore) • First Phase of NCore level II implementation • FY ‘07 • Second phase of NCore level II implementation

33. Divestments • Low value FRM sites. • Largely redundant urban sites or areas that are already covered by continuous or IMPROVE monitoring and are well below the NAAQS. • Low value supplemental speciation sites. • Critical non-trends speciation sites should remain; however, many of the supplemental speciation sites will no longer be necessary for development of control strategies….note…priority on protecting rural locations and harmonization with IMPROVE • May need objective process for maintaining sites that have other important uses. For example: • supporting a local health study • source apportionment analysis to reduce emissions voluntarily

34. Technology Transfer and Training • Technology Transfer • EPA - AMTIC web site - www.epa.gov/ttn/amtic/precur.html • Availability of precursor gas SOP’s • method summaries • Developing • Technical Assistance Document (TAD) on precursor gases • Data Quality Objectives for precursor gas uses • EPA - AIRNow web site • Presentation from recent conference - includes overview of precursor gases • State/local/Tribal/OAQPS/OAP Pilot Conference Calls • Calls include spectrum of users from agencies new to these measurements to national experts in high sensitivity gas monitors. • 3 CASTNet pilot sites for precursor gases operational this Spring • Training • Planned and Proposed Training Mechanisms • Workshops - including hands-on with equipment • Precursor gas monitor workshops scheduled in May and June in RTP NC, more later... • Future? • Vendor, Satellite broadcasts, Web based - • Planning for Conference in 2006

35. Summary and Next Steps • 2006 Grant Guidance • Comments received on draft • OAR/OAQPS working on an updated version of the guidance • Monitoring Regulations • Expect proposal of revised monitoring regulations in support of National Monitoring Strategy this year. • Expect final revised monitoring regulations in 2006 • Technology • Pilot and training of precursor gas monitors this year • Need to develop methods for Ammonia and Nitric Acid • Use of AIRNow to support sharing precursor gas, continuous speciation, and meteorological data • New procedures for storing PM2.5 continuous monitoring data in AQS • Communications and Outreach • Working to engage EPA Air Division Directors and Air Program Managers • Scheduling meeting with Ambient Air Monitoring Steering Committee, June ‘05 • Need to engage State Air Directors • NCore Level II site selection • Need to engage multiple clients of data with initial list

36. PM Coarse (PM10 - PM2.5) Notes • Second draft of PM Staff Paper available - January 2005 • CASAC review meeting held April 2005 • EPA-ORD evaluating PM coarse methods • CASAC consultation occurred July 2004 • New field study with several modified methods scheduled to start April 2005 in Phoenix, AZ. - 28 samplers to be operated. • Expecting CASAC Subcommittee review in late summer • Methods Summary • Lots of support for continuous methods • Good correlation and precision between methods, • Some biases exist between methods • Difference method appears to be strong candidate for use as the method of comparison in performance based approach for approval of other methods • Supporting work underway • Development of network DQOs • Development of reference method and equivalent method approval criteria • Network Design team evaluating issues and options • EPA is working on a timetable according to consent decree negotiated with DOJ. • Proposal by December 20th, 2005

37. PM2.5 Speciation Program Notes • More interest in PM continuous speciation • Regions 2, 3, and 4. • Recent purchases include Thermo Sulfate and Sunset C analyzers • Working to make AIRNow capable of processing continuous speciation data • Evaluating options for IMPROVE and STN integration • Awaiting response from CASAC AAMM Subcommittee • Shipping study • Some sites complete • Data to be evaluated • Other sites only recently started • Contract laboratory costs

38. Draft Federal Equivalent Method approval criteria for PM2.5 Continuous Monitors • Data Quality Objective process that links equivalency criteria to expected data quality in network • Extensive statistical investigation with EPA – OAQPS, EPA - ORD, RTI, and Battelle. • Expect to propose as applicable to both National Equivalency and Regional Approved Methods

39. Draft Federal Equivalent Method approval criteria for PM2.5 Continuous Monitors • Basis of comparison is the FRM • FRM precision <= 7.5% • Determine Concentration Coefficient of Variation (CCV) • Used to determine required correlation • Candidate Sampler (the PM2.5 continuous monitor) • Precision <=15% - Collocation of two or more monitors of the same make and model • Correlation lower bound (Note correlation, not squared correlation) • 0.93 if CCV <0.3 • 0.87 + 0.2*CCV if 0.3 <= CCV < 0.4 • 0.95 if 0.4 <= CCV • Multiplicative Bias (the slope or alpha) - must fall between 0.90 and 1.10 • Additive Bias (the intercept or beta) is function of multiplicative bias • -0.529 to +3.17 for slopes of 0.90 • -3.991 to +0.530 for slope of 1.10

40. Potential New Correlation Criteria Correlation was modeled with CCV (population CV). It was determined that sites with larger ranges (e.g. 4 – 80 ug/m3, instead of 4-25 ug/m3) have higher CCV’s and higher expected correlation's between FRM and continuous methods. Existing correlation requirement is 0.97 Blue line represents potential new correlation criteria

41. Blue box represents existing criteria Red box represents potential new criteria

42. Analysis of available AQS data to potential PM2.5 equivalency criteria • Analysis Basics: • Data downloaded from AQS on 2/3/2005 • Dataset includes 4th quarter of 2003 to 3rd quarter of 2004 • Latest 4 quarters of data that are generally complete • Used collocated FRM/PM2.5 continuous monitoring sites where the continuous method was the same for the entire period • N >= 23 sample pairs • Continuous monitor >= 18 valid hours in each day • Used to provide larger data set • For actual equivalency testing you would match the same hours on both FRM and continuous methods • FRM range of 3 to 200 ug/m3. • Highest value was 101.7 ug/m3 • Analysis limitations: • Did not consider sample precision for either the FRM or continuous monitors • Some sites may not be representative of all seasons • Only considered data submitted to AQS – Did not attempt to reconcile data that may be submitted to AIRNow as corrected and AQS as raw.