Monitoring & Modeling Issues

1. Monitoring & Modeling Issues Richard A. “Chet” Wayland Office of Air Quality Planning & Standards Region 4 Air Directors’ Meeting Fall 2016 St. Petersburg, FL

2. Ambient Air Monitoring Regulation Update Major Updates Providing for Data Quality Consistency

3. Ambient Monitoring Rule – Key Changes • Reduced data certification requirements (now focused only on FRM/FEM data) • Reduced data reporting requirements (e.g., remaining auxiliary PM2.5 met data) • Eliminated Lead (Pb) monitoring at urban NCore stations • Required Annual Monitoring Network Plan comments to be collected at the state level and sent with ANP to EPA • Clarified period of increased PM2.5 sampling when triggered by DV’s (e.g., daily sampling when within 5% of 24-hour PM2.5 NAAQS)

4. QA Issues (risks) Uncovered in Recent (last 3 years) Technical Systems Audits (TSAs) • Not meeting CFR Criteria • Failing quality control • Poor documentation • Outdated QAPPs/SOPs • Not following SOPs/QAPPs • Inadequate chain of custody • Inadequate filing systems • Standards not certified • Causes data invalidation and data uncertainty leading to: • Increased risk of making incorrect NAAQS decisions • No NAAQS decision due to data being incomplete, and • Inability to defend the quality of data NOTE: 6 Regions had PM2.5 issues resulting in a significant amount of data invalidated

5. Outcome and Action Items from TSAs Theme- National Consistency • Revised QA Reg- See summary of March 2016 QA Revisions https://www3.epa.gov/ttn/amtic/40cfr53.html • PQAOs -Added Responsibility to Primary PQAO for oversight of consolidated locals • Revised 1-Point QC and Annual PE for gasses to perform checks at concentrations that are being measured. • QAPPs and QMPs Submission and Approval Dates reported to AQS • Eliminated QA requirements for Pb at non source NCore and PM10-2.5 • Participation in Ambient Air Protocol Gas Verification Program • Added NPAP Requirements • Annual Data Certification-All data evaluated the same way • More efficient process • Regions work with OAQPS on consistency of review/concurrence process • Revised PM2.5field and lab procedures (Method 2.12) –for consistent application • Training • Two PM2.5 Lab Training Courses in Region 4 and at National Ambient Air Conference • QA-101 at National Ambient Air Conf. including TSA Training and Regional Data Evaluations • Low level Annual Performance Audit Webinars – Help Monitoring Orgs get to lower conc. audit levels • Air Pollution Training Institute (APTI) 470 QA for Ambient Air- Working with MARAMA to review update course for 2017

6. Outcome and Action Items from TSAsTheme- National Consistency QA Handbook – (Revision early 2017) • Thorough Review • update of all sections to the regulations and best practices • Data Validation Templates • Moved important CFR criteria to critical criteria to reduce confusion about data validation • Provided more guidance on data rounding and quality control frequencies • TSA Revision • Workgroup developing a Technical Systems Audit Guidance Document to provide consistent guidance across all Regions – Completion early Spring • Consistent application of Findings, Concerns and Observations • More thorough review and inventory of monitors, standards and their ages • Review numbers of SPMs and non-regulatory monitoring • Review of internal QA management (QMPS and QAPPs) • Is there an independent QA function, and are they performing internal TSAs?

7. National Air Toxics Trends Sites (NATTS) Update • New NATTS Technical Assistance Document (TAD) • Revision 3 is finalized and was distributed on October 25, 2016 • Provides clear and updated technical direction for monitoring and analysis of NATTS pollutants. • Provides a consistent approach on MDL calculation for the NATTS program. • Can be used as a model or for reference for labs performing air toxics studies (art glass, Superfund, emergency response). • Allowing one year for implementation of the new TAD. • Adherence to the TAD will be referenced in the NATTS workplan template and is a grant condition for labs and sites in the NATTS program. • Providing training webinars for NATTS TAD late 2016 and early 2017

8. PAMS Network Modifications

9. Updates to PAMS Network Design • Major changes to the PAMS requirements were finalized in October 2015 as part of the ozone NAAQS review • We replaced the existing 20 year-old multi-site, enhanced ozone network design with an updated 2-part network design • Requiring PAMS measurements to be collocated with existing NCore sites in areas with population of 1 million or more irrespective of Ozone NAAQS attainment status • Results in a stable network of approximately 40 required sites with improved spatial distribution and reduced redundancy • Includes a waiver for historically low ozone areas • Includes an option to make PAMS measurements at an alternative location (e.g., an existing PAMS site) which may cross CBSA or even state boundaries • Require states with moderate or above ozone non-attainment areas and states in the Ozone Transport Region to develop and implement an Enhanced Monitoring Plan (EMP) • Provides support for flexible approaches for collecting data to understand ozone issues in new and existing high ozone areas

10. New and Existing PAMS Sites

11. PAMS Timeline and Milestones • PAMS plan due July 1, 2018 as part of Annual Network Plan • Consider moving this up to July 1, 2017 if waivers are needed! • PAMS monitoring at NCore sites will need to start by June 1, 2019 • Looking for some states to be early implementors and start getting equipment installed in 2017 and 2018 • EMPs submitted within two years of designations or by October 1, 2019, whichever is later

12. EPA Commitments • PAMS Funding reallocation • Start in 2017, and spread over multiple years • National Procurements for autoGCs, true NO2, and ceilometers • Guidance documents • Technical Assistance Document • Generic QAPP • SOPs for autoGCs, true NO2, and ceilometer • EMP Guidance • National QA Program • Training, Training, and more Training! • Data Validation/Reporting • AutoGC operation • Mixing height/Ceilometer

13. Near-road Monitoring

14. Revision to Near-road NO2 Requirements • Proposed to remove the requirement for near-road NO2 monitoring in CBSAs having populations between 500k and 1 million persons (Phase 3) • Agency received mostly supportive comments, but did get adverse comments from public health and environmental groups • Rule is written and undergoing review within the Agency • We hope to have the rule signed by end of the year

15. Region 4 Near-road Sites • There are 10 operational sites in Region 4 • Only remaining sites to become operational are the 2nd site in Miami CBSA and the Orlando site • Comparison of complete 2015 near-road NO2 concentrations to all non-near-road NO2 concentrations in the Region reveal that: • Near-road sites have the high DV for the annual standard in all of their respective CBSAs (high DV is 20 ppb from Atlanta’s Georgia Tech NR site) • Near-road sites have the high 98th percentile 1-hour daily maximum value in all of their respective CBSAs (highest value is 55 ppb from the Nashville NR site)

16. Appendix W, MERPS, and SILs

17. Regulatory Revisions to Appendix W: Schedule • On July 14, 2015, the EPA proposed to update to the Guideline on Air Quality Models • Published in the Federal Register (80 FR 45340) on July 29, 2015 • Docket ID No. EPA-HQ-OAR-2015-0310 • 90-day public comment window with 99 comments received from industrial stakeholders, federal/state/local government and tribal agencies, environmental groups, etc. • 11th Conference on Air Quality Modeling • August 12 and 13, 2015 at the EPA RTP, NC Campus • Conference focused on the proposed revisions to the Guideline • Served as public hearing for NPRM as part of public comment period • Transcripts and presentations posted to Docket and on the 11th Conference on Air Quality Modeling informational website http://www3.epa.gov/ttn/scram/11thmodconf.htm

18. Regulatory Revisions to Appendix W: Schedule • In the spring of 2016, the Guideline final rule was determined to be significant requiring OMB review. • The rulemaking package was submitted to OMB on August 30, 2016 with an anticipated 45 to 60 days review period. • Per this schedule, the final rule should be signed in the mid- to late-October 2016 timeframe. • The revised Appendix W will become effective 30 days after Administrator signature and will include a 1-year transition period as described in the preamble to the rule.

19. Appendix W: Main Proposed Actions • Science improvements to AERMOD Modeling System • ADJ_U* and LOWWIND3 options to address technical concerns and improve model performance under extremely light winds • Enhanced treatment of horizontal and capped stacks • Addition of a buoyant line source option • Updates to the NO2 screening techniques, including a new Tier 2 Ambient Ratio Method (ARM) and revised Tier 3 Plume Volume Molar Ratio Method (PVMRM) • AERSCREEN as the recommended screening model for simple and complex terrain for single sources • Proposed Long Range Transport (LRT) screening approach • Single-Source Impacts on Ozone and Secondary PM2.5 • Removal of BLP, CALINE, and CALPUFF as EPA preferred models

20. Proposed Actions: Single-Source Impacts on Ozone and Secondary PM2.5 • The EPA believes photochemical grid models are generally most appropriate for addressing ozone and secondary PM2.5, because they provide a spatially and temporally dynamic realistic chemical and physical environment for plume growth and chemical transformation. • Lagrangian models (e.g. SCICHEM) applied with a realistic 3-dimensional field of chemical species could also be used for single source O3 or PM2.5 assessments. • The EPA is proposing a two-tiered demonstration approach for addressing single-source impacts on ozone and secondary PM2.5. • Tier 1 demonstrations would use exiting information relating emissions and air quality impacts. • Tier 2 demonstrations would be case-specific. • The EPA is working toward guidance for Tier 1 and Tier 2 demonstration approaches.

21. Model Emissions Rate for Precursors: O3 and Secondary PM2.5 • EPA will provide technical guidance that will allow development of Tier 1 demonstration tools under Appendix W for PSD permitting. • A Modeled Emission Rate for Precursors (MERP) is a type of Tier 1 demonstration tool that would represent a level of increased precursor emissions that is not expected to contribute significantly to levels of ozone or secondarily-formed PM2.5. • Guidance would provide a framework on how to arrive at values for MERPs based on existing relevant modeling or newly developed area specific modeling from which source/states can utilize in their compliance demonstrations. The guidance would not endorse a specific MERP value for each precursor. • Draft guidance will be released for public comment in September. • Final MERPs guidance to coincide with the finalization of the SILs Guidance.

22. SILs Guidance Memorandum • The memorandum and supporting documents were posted for informal public review on August 1, 2016. https://www.epa.gov/nsr/forms/significant-impact-levels-ozone-and-fine-particles-prevention-significant-deterioration • Consisting of… • A guidance memorandum that describes how these values may be used in a PSD compliance demonstration • A technical basis document describing how EPA developed the SIL values for PM2.5 and ozone; and • A legal support document that discusses a legal basis that permitting authorities may choose to apply if allowing sources to use SILs • 60 days informal review and comment through September 30, 2016. • The guidance is not a final agency action and is not binding for industry, permitting authorities, or the public. • The guidance memorandum, technical basis and legal support documents are intended to be included in any permit record where the recommended SILs are used.

23. Recommended SIL Values *The permitting authority has discretion to interpret an annual impact between 0.2 µg/m3 and 0.3 µg/m3 as significant.

24. Future Modeling Work • Continue to improve science in AERMOD, specifically research coordination with ORD and stakeholders on: • Downwash algorithms • Mobile source modeling (RLINE) • Evaluation of Offshore & Coastal Dispersion Model (OCD) • Instrumented modeling techniques for photochemical models (secondary pollutants) • Regulatory and Policy Applications • SO2 Implementation • NATA • Further engagement with the stakeholder community leading up to the 12th Conference on Air Quality Models in 2018

25. Other Modeling Issues

26. Federal/State Technical Air Quality Collaboration Workgroup • Provides a forum for discussing technical work by states, MJOs/RPOs, and EPA related to air quality modeling for ozone, PM2.5, and Regional Haze • Topics include: • Base and future year emissions platforms for near-term regulatory modeling • Coordinating EGU projections (IPM/ERTAC) • Potential improvements to non-EGU stationary source emissions, projections, and control data • Improved efficiency in running MOVES • Global modeling to provide estimates of intercontinental transport • Model evaluation • Avenues for sharing data • Objectives of collaboration (1) Efficient use of resources (2) Transparency regarding technical data, analyses, tools, and techniques (3) Development of technically credible products

27. 2015 O3 NAAQS Transport Modeling • Purpose: Provide transport data that states can use in developing 110 SIPs and provide an opportunity for public comment on the transport data that EPA may use in future actions to address transport for the 2015 NAAQS. • Analytic year for 2015 ozone NAAQS transport modeling – 2023 • 2023 is the attainment year for moderate nonattainment areas. • Data set will include: • Design values projected to 2023 for individual sites; nationwide. • Identify nonattainment and maintenance receptors. • Contributions from 2023 emissions in each state to receptors; nationwide. • Detailed modeling data needed to project design values and to calculate contributions. • Timing – December 2016

28. Regional Haze Air Quality Modeling • EPA is planning to model a 2028 future year for the purpose of providing updated regional haze visibility impairment information for use by EPA and states. • The modeling will include PM source apportionment modeling (CAMx PSAT) to quantify the contributions to PM2.5 and visibility of emissions from various source sectors. • Example list of possible sectors to be tracked individually • EGUs, non-EGU point, onroad mobile, nonroad mobile, prescribed fires, wild fires, nonpoint oil and gas, residential wood combustion, rail….. • The regional haze modeling will be complete in early 2017.