Revisions to the NAAQS and Ambient Monitoring Regulations

1. Revisions to the NAAQS and Ambient Monitoring Regulations Mike Papp Office of Air Quality Planning and Standards NTF/NTAA Meeting April 17, 2007

2. Topics Covered • PM NAAQS Revisions • Revisions to the Ambient Monitoring Regulations • Important Dates in the Monitoring Rule • PM Methods • NCore Monitoring Requirements • Changes in QA Requirements • Other Monitoring Requirements • Corrections and One Other Change Areas highlighted in blue will not be discussed due to time

3. PM NAAQS Revisions

4. New National Ambient Air Quality Standards for PM

5. Designated PM2.5 Nonattainment Areas 1997 NAAQS 2001-2003 Design Values • Violates annual NAAQS (15.0 µg/m3) and 24-hour NAAQS (65 µg/m3) • Violates only 24-hour NAAQS (65 µg/m3) • Violates only annual NAAQS (15.0 µg/m3) 2003-2005 Design Values • 73 violating counties • All but 6 are located in nonattainment areas: Greenville, SC; Russell, AL (Columbus); Richmond, GA (Augusta); Fayette, KY (Lexington); Mecklenburg, NC (Charlotte); Mahoning, OH (Youngstown) • All counties in D.C. NAA are clean

6. PM2.5 - Trends There have been overall declines in average PM2.5 levels Annual Mean Trend, 1999 - 2005 • National decline of 8% from 1999 to 2005 … • 15% reduction ‘99 to ’04 • 7% increase ’04 to ‘05 • Largest reductions in Southern California where levels are highest (-26%) • Increases in Upper Midwest (+5% ’99 to ’05) and Industrial Midwest (+4% ’99 to ’05) • Declines partially attributed to Acid Rain program (SO2 reductions) • 2005 increases due in part to sulfate increases & meteorology µg/m3

7. PM2.5 NAAQS Changes Spatial Averaging 1997 Criteria • Minimum of 0.6 overall correlation among sites • No more than 20% difference in any site annual mean versus the spatial annual mean. • All SA sites should be affected by the same emission sources. 2006 Criteria • Minimum of 0.9 seasonal (quarterly) correlation among sites • No more than 10% difference in any site annual mean versus the spatial annual mean. • All SA sites should be affected by the same emission sources.(unchanged) Any area desiring to use spatial averaging to show attainment of the annual standard (15 µg/m3) must meet these new criteria (for 3 consecutive years)

8. Areas/Sites Violating NEW PM2.5 24-hour NAAQS – 2003-2005 Remember, before new 24-hour NAAQS, most violations related to annual NAAQS • Current nonattainment area violates NEW 24-hr NAAQS [32 areas] • Current nonattainment area meets NEW 24-hr NAAQS [7 areas] • Sites not in a current nonattainment area violate the NEW 24-hr NAAQS (59 sites) • The 59 violating sites in current attainment areas are in • 44 counties • 38 areas (34 MSA’s, 4 counties not in an MSA)

9. Expected Timeline for PM2.5 NAAQS Implementation

10. PM10 NAAQS – History Review • In 1997, EPA retained both 24-hour and annual PM10 standards at pre-1997 levels • Based on generally strong scientific support for retaining standards to protect against the effects of coarse fraction particles (PM10-2.5) • Proposed changing form of standard • Proposed method change (calculation at local temp. and pressure) • In 1999, US Court of Appeals for the D.C. Circuit vacated EPA’s PM 10 standard revision • Found PM10 to be a poorly matched indicator for coarse fraction particles because it includes fine particles • EPA did not appeal; reverted to 1987 standards • 50 µg/m3, annual average • 150 µg/m3, 24-hr average • Method went back to STP

11. PMcoarse – A Complicated Path • Health studies provided some evidence of differences in the effects of PMcoarse in urban areas vs. rural areas. • Coarse particles in urban areas • Are typically contaminated by urban mobile and industrial emissions • Coarse particles in rural areas • Are not so typically contaminated • EPA proposal • Switch to PM10-2.5 • Establish FRM/FEM rules and procedures • Restrict to urban areas (in effect) • Minimum numbers of monitors • Special rules on placement within an urban area

12. PMcoarse -Final Action • Finalized only some of the PM10-2.5 proposals • PM10-2.5 Federal Reference Method. • Procedures for designating PM10-2.5 Federal Equivalent Methods (e.g., continuous samplers). • PM10-2.5 monitoring only at about 75 NCore sites, including PM10-2.5 speciation (more sites than proposed). • Quality assurance procedures. • Retained existing PM10 network requirements. • Retained 24-hour PM10 NAAQS but revoked annual standard • Finalized monitor discontinuation criteria for criteria pollutants, including PM10. • All areas, no “urban” restrictions. (Same as since 1987.)

13. Revisions to the Ambient Monitoring Regulations

14. The Revisions Are Part of a Strategy • The “National Strategy” is really EPA’s strategy. • A plan for using EPA resources and authority to help achieve goals endorsed by EPA. • Informed by dialog with others. • Intended to be supportive of other organizations’ strategies. • Every other monitoring organization should also have its own strategy. • Its goals. • Its resources and authority.

15. Four Overarching Goals of the Strategy • Keep monitoring matched to evolving and diverse current air quality challenges. • Integrate or coordinate networks, where advantageous. • Use best new science/methods to • Get the best data. • Provide better access to the data, so it gets used to best benefit. • Match action plans to funding.

16. The Strategy Addresses More Than the Monitoring Rule • Urban Monitoring (Monitoring Rule) • NAAQS Networks • NCore Multipollutant Sites • Coarse PM • PAMS • PM speciation • Air Toxics • Near Roadway • Homeland Security • Rural Monitoring • IMPROVE (visibility) • CASTNET (dry deposition) • NADP and MDN (wet deposition) • Proposed Mercury dry deposition network • Tribal Monitoring

17. Ambient Air Monitoring Regulations - Major Components • Part 53 • Approval of reference and equivalent methods • Revised performance based criteria for PM2.5 and PM10-2.5 equivalent methods • Part 58 • Criteria for “Approved Regional Methods” for PM2.5 (revised) • Revised network minimums for O3 and PM2.5 based on population and design value • Existing PM10 network requirements retained. • Put more of the state/local network under Regional Office review/approval instead of HQ review. • 75 NCore multi-pollutant sites • 62 – 71 of them required, others negotiated. 55 urban, 20 rural. • Includes monitoring for PM10-2.5, • Waivers for NOy • Added PM10-2.5 speciation as an NCore station requirement. • Revised network minimums for Pb. • Network minimums go away for CO, SO2, and NO2. • Revisions to QA program • Updated Special Purpose Monitoring (SPM) provisions • Data reporting to AQS • PAMS network requirements

18. Important Dates in the Monitoring Rule NOTE: Tribes are not obligated, under CAA, to meet these dates. They are provided for informational purposes.

19. Effective December 18, 2006 • New criteria for approval of Federal Equivalent Methods for PM2.5 and PM10-2.5, and Approved Regional Methods. • New QA requirements for SLAMS. • New required numbers of PM2.5, PM10, Pb, and ozone monitors. • Removal of required numbers for CO, SO2, and NO2 (except if in SIP). • Criteria for removal of monitors above required number. • Conditions on use of SPM data. • Removal of required reporting of certain PM2.5 monitoring parameters. • PM10-2.5 probe heights. • Increased distance between roadways and NEW ozone monitors.

20. Effective January 1, 2007 • Every day PM2.5 samples at about 45 stations reading close to the new 24-hour standard. • Retention of low-volume PM10 and PM10-2.5 filters. • Start preparing blank PM2.5 filter data for submission to AQS. • Last chance to convert excess SLAMS to SPM status, without first meeting criteria for discontinuation.

21. Effective July 1, 2007 • Report PM2.5 filter blank data from Q1 to AQS. • Submit precision and accuracy data for Q1 of 2007 to AQS. • Not an explicit requirement in old rule, not all monitoring organizations have been reporting it. • Submit annual monitoring plan. • Similar to a current requirement for an annual data summary, but more required content. • Including plans for any additional required PM2.5, PM10, or ozone monitors under new required numbers of monitors by MSA. • State must make available to the public for 30 days before submission to EPA.

22. 120 Days After Annual Plan Submittal (about Nov. 1) • Regional Administrator must approve/disapprove the annual plan. • Requires opportunity for public comment, if the State did not provide a comment process. • Some changes, if in plan, require Administrator approval.

23. Effective January 1, 2008 • Start operation of any new required PM2.5, PM10, or ozone monitors. • About 13 new PM2.5 monitors • A few additional ozone monitors. • New PM10 monitors in approximately 8 MSAs. • Unless modified by the Regional Administrator.

24. Effective January 1, 2009 • New QA requirements apply to Special Purpose Monitoring stations using FRM, FEM, or ARM monitors. • Regional Administrator can approve an alternative for practicality reasons, if full QA not essential to monitoring objective. • Alternative QA plan means data not comparable to the NAAQS.

25. Effective July 1, 2009 • Plan for required NCore stations. Effective May 1, 2010 • Revised deadline for annual certification of data submitted to AQS. Effective July 1, 2010 • First 5-year network assessment. Effective January 1, 2011 • Operation of NCore stations.

26. PM Methods

27. Federal Reference Method Updates • EPA has finalized PM2.5 FRM improvements • Incorporation of changes to improve efficiency of monitoring network operations. • EPA has finalized PM10-2.5 FRM • Two concurrently operated low-volume samplers with one measuring PM10 and the other PM2.5.

28. Finalized PM2.5 FRM improvements as proposed • Very Sharp Cut Cyclone (VSCC) as an approved second stage separator for PM2.5. This would be in addition to the WINS • Use of Dioctyl Sebacate (DOS) oil as an alternative oil in the WINS VSCC

29. Day 0 Day 1 Day 2 Day 3 Day 4 Day 5 Day 6 Day 7 Day 8 Sample Days Previous Recovery Period New Recovery Period • Extended filter recovery extension time from 96 hours → 177 hours (7 days, 9 hours) • Modified filter transport temperature and post-sampling time requirements for final laboratory analysis; filter transport temperature maintained below average ambient temperature during sampling allows up to 30 days for post-sampling conditioning and weighing. Example; units in oC 30o 25o effective maximum Sample period temperature range 20o { 13o average for sample period 10o Acceptable range for up to 30 days post-sampling conditioning and weighing 4o minimum 0o

30. New Methodological Option: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 • 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. • Testing Criteria • 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 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.

31. PM2.5 – Sampling Schedule Rule now requires every day sampling (1/1) for key sites close to the NAAQS • A ‘key’ site is the highest one in a metro area; ‘close’ is within 5% (both based on 3-yr DV). • 34, 35, and 36 ug/m3 are within plus or minus 5 percent. • This will also help reduce random sampling bias (caused by unrepresentative sample days) • About 45 sites were required to start sampling daily as of January 1, 2007. Regional Office will figure which are affected.

32. Revocation of Minimum Monitoring Requirements: CO, SO2, NO2, Pb • Generally, the EPA Region can approve the shutdown of a monitor as part of the annual network review. • See 58.14 for specific provisions on discontinuing monitors. • Watch out for SIP commitments for specific monitors and/or contingency measures tied to monitoring triggers. • No minimums apply for CO, SO2, NO2. • Pb – required in areas where levels are still a concern. • 2 sites required in areas above the NAAQS. • 1 maximum exposure site • 10 Pb sites at NCore or urban air toxics sites for long-term trends; one per Region in most populated MSA/CSA.

33. NCore Monitoring Requirements

34. NCore Goals • Timely reporting of data to the public (e.g. AIRNOW, USA Today, etc.) • Support of development of emissions strategies • Accountability of emission strategy progress • Support of long-term health assessments • Compliance through establishing nonattainment/attainment areas • Support to scientific studies • Support to ecosystems assessments

35. New Monitoring Requirements:NCore Multi-Pollutant Network • Collocation of multiple pollutant and supporting measurements to meet many different objectives. • Robust suite of filter-based PM samplers. • Emphasis on continuous operating instruments. • Use of high-sensitivity precursor gas monitors. • Diversity of representative site locations. • Leverage with existing multipollutant networks. • Between 62 and 71 stations must be operational by January 1, 2011. Candidate NCore Site 361010003 Pinnacle Park, New York

36. Minimum NCore Network Requirements 1 Site 2 or 3 Sites (All fifty States, District of Columbia, Puerto Rico, Virgin Islands)

37. National Core (NCore) Multi-pollutant Sites • NCore Multi-Pollutant Network • Network plans due July 1, 2009 • Full network operational by January 1, 2011 • ~75 Sites Nationally: ~55 Urban Sites and 20 Rural Sites • 1-3 sites per State • States with 2-3 sites – CA, FL, IL, MI, NY, NC, OH, PA, TX. • Additional rural sites negotiated with States, NPS, Tribes, CASTNET • Pollutants • Particles • PM2.5 filter-based and continuous, speciated PM2.5, • PM10-2.5 FRM/FEM at 1:3 or continuous PM10-2.5 FEM, speciated PM10-2.5 • Gases • O3; high-sensitivity - CO, SO2, NO/NOy • Waivers for NOy in urban areas until NO2 method improves so that NOx and NOy differences are meaningful • Meteorology • Amb. Temp, WS, WD, RH • Over design of shelters for space and power consumption in anticipation of additional (voluntary) measurement systems is recommended.

38. Working Draft of NCore Multi-pollutant Candidate Sites

39. PM10-2.5 Monitoring Is a Required Part of NCore, But There Is Much Still To Be Decided and Done • PM10-2.5 Mass and Speciation are required, at 1:3 schedule • PM10-2.5 FRM (difference method) • Peer Reviewed by Clean Air Scientific Advisory Committee (CASAC). • Currently deployable but more useful as basis of comparison for FEM tests and for QA of other methods. • Does not collect a discrete coarse sample, limiting utility for speciation. • EPA is promoting the development of single-sampler FEM’s (and alternative FRM) that are more cost-effective to deploy and operate. • Data from recent ORD-lead field campaigns contributed to setting of PM10-2.5 FEM test criteria in monitoring rule. • EPA must develop guidance on coarse speciation • Develop needed AQS modifications to handle reporting of paired samples.

40. Expectations for PM10-2.5 Monitoring NetworksMonitoring Agency Action Items • Address NCore requirements with FRM’s or FEM’s. • Strategically deploy additional SLAMS PM10-2.5 monitors in urban and rural areas where data would be useful for NAAQS development and/or understanding air quality in areas where PM10-2.5 concentrations are relatively high. • Periodically review availability of excess PM2.5 FRM’s (due to introduction of continuous FEMs or ARMs) in support of additional PM10-2.5 monitoring. • Convert excess PM2.5 FRM’s to PM10c as part of PM10-2.5 FRM or FEM. • Consider introduction of continuous PM10-2.5 FEM’s at NCore and SLAMS to meet other objectives as monitors become available.

41. Current NCore Status • States have informally proposed approximately 70 sites • No sites have been given formal approval • Approximately 35 proposed sites in operation at some level • EPA is developing a website to assist in internal and external review of proposed sites • http://www.epa.gov/ttn/amtic/ncore/ • Provides access to meta-data, photos of site, metro-level maps, satellite maps. • Website is in “beta” stage and is currently password protected, contact cavender.kevin@epa.gov for username and password

42. Example Webpage for Proposed Site

43. NCore Approval Process • The Administrator must approve the NCore sites. • OAQPS is developing a web site to facilitate collaborative selection of sites and to provide meta data to eventual data users. • EPA Regions will consult with OAQPS regarding network design and implementation issues. • State/Local/Tribal programs will continue to work with EPA Regions during the NCore site selection process and implementation of approved sites.

44. Changes in QA Requirements NOTE:If the tribes would like its data to be considered in NAAQS determinations, it needs to meet the 40 CFR Part 58 Appendix A QA requirements.

45. Changes in the QA Regulations(40 CFR Part 58 Appendix A) • Ensured regs reflected current EPA QA policy and requirements • Combined Appendix A and B (PSD) • Established DQOs for PM10-2.5 , revised the DQOs for O3 • Removed SO2/NO2 manual audit checks

46. 97% monitors meeting this requirement now for ozone! MQOs for Gaseous Pollutants Will Change • Ozone to 7% CV +/- 7% Bias • Other gases will be changed to 10% in Guidance

48. New Statistics Changed Statistics (forms and levels of aggregation) • Confidence limits • PQAO for PM • Site level for gaseous pollutants • AMP255 Report performs new statistics • Performing in-depth review of Stats this year • OAQPS will run annually • Box–and-whisker plots included in annual summary • Guidance document available • Rationale and excel spreadsheet http://www.epa.gov/ttn/amtic/parslist.html

49. P&B Guidance and Data Assessment Statistical Calculator (DASC) Software

50. Expanded audit concentration levels for precursor gas monitoring “The evaluation is made by challenging the analyzer with audit gas standard of known concentration (effective concentration for open path analyzers) from at least three consecutive audit levels. The audit levels selected should represent or bracket 80 percent of ambient concentrations that are measured by the analyzer being evaluated. An additional 4th level is encouraged for those monitors that have the potential for exceeding the concentration ranges described by the initial three selected.”