national tribal forum on air quality conference - 2007 revisions to the naaqs and ambient monitoring...

National Tribal Forum on Air Quality Conference - 2007

Revisions to the

NAAQS and Ambient

Monitoring Regulations

Mike PappOffice of Air Quality Planning and Standards

NTF/NTAA MeetingApril 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


PM NAAQS Revisions


4

New National Ambient Air Quality Standards for PMPrevious Standards 2006 Standards

Annual 24-hour Annual 24-hour

PM2.5

(Fine Particles)

15 µg/m3

Annual arithmetic mean, averaged over 3 years(established in 1997)

65 µg/m3

24- hour average, 98th percentile, averaged over 3 years(established in 1997)

15 µg/m3

Annual arithmetic mean, averaged over 3 years

35 µg/m3

24- hour average, 98th percentile, averaged over 3 years

PM10

(Coarse Particles)

50 µg/m3

Annual average(established in 1987)

150 µg/m3

24-hr average,

not to be exceeded more than once per year on average over a three year period(established in 1987)

Revoked 150 µg/m3

24-hr average,

not to be exceeded more than once per year on average over a three year period


5

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)

2001-2003 Design Values

Designated PM2.5 Nonattainment Areas 1997 NAAQS

2003-2005 Design Values

73 violating countiesAll 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

1999 2000 2001 2002 2003 2004 2005

5

10

15

20

25

All Regions (374)Not in PM Region (8)Northeast (47)

Southeast (97)Industrial Midwest (113)Upper Midwest (24)

Southwest (18)Northwest (46)Southern California (21)

µg/

m3

Annual Mean Trend, 1999 - 2005 There have been overall declines in

average PM2.5 levels

• 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


7

PM2.5 NAAQS Changes Spatial Averaging

1997 Criteria1. Minimum of 0.6 overall correlation among sites

2. No more than 20% difference in any site annual mean versus the spatial annual mean.

3. All SA sites should be affected by the same emission sources.

2006 Criteria

1. Minimum of 0.9 seasonal (quarterly) correlation among sites

2. No more than 10% difference in any site annual mean versus the spatial annual mean.

3. 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

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)

Remember, before new 24-hour NAAQS, most violationsrelated to annual NAAQS

Areas/Sites Violating NEW PM2.5 24-hour NAAQS – 2003-2005


9

Expected Timeline for PM2.5 NAAQS Implementation

Dec. 2006 Effective date for revised 2006 PM2.5 NAAQS

Dec. 2007 States recommend designations for revised PM2.5 24-hour standard. Using ’04-’06 or ’05-’07

Dec. 2009 Final designations for revised PM2.5 24-hr std

April 2010 Effective date for revised PM2.5 24-hr std area designations

April 2013 State plans due for revised PM2.5 24-hr std.

April 2015- 2020

Attainment date for revised PM2.5 24-hr std


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.)


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 Strategy1. Keep monitoring matched to evolving and

diverse current air quality challenges.2. Integrate or coordinate networks, where

advantageous.3. Use best new science/methods to

– Get the best data.– Provide better access to the data, so it gets

used to best benefit.

4. 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


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


• 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


• 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

• Plan for required NCore stations.

Effective July 1, 2009

• Revised deadline for annual certification of data submitted to AQS.

Effective May 1, 2010

• First 5-year network assessment.

Effective July 1, 2010

• Operation of NCore stations.



PM Methods


27

• 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.

Federal Reference Method Updates


28

1.Very Sharp Cut Cyclone (VSCC) as an approved second stage separator for PM2.5. This would be in addition to the WINS

2.Use of Dioctyl Sebacate (DOS) oil as an alternative oil in the WINS

VSCC

Finalized PM2.5 FRM improvements as proposed


29

3. Extended filter recovery extension time from 96 hours → 177 hours (7 days, 9 hours)

4. 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.

Day 7

New Recovery Period

Previous Recovery Period

Sample Days

Day 8Day 6Day 5Day 4Day 3Day 2Day 1Day 0

20o

30o

10o

0o

Sample period

temperature range

25o effective maximum

13o average for sample

period

4o minimum

Example;units in oC

{Acceptable range for up to 30 days

post-sampling conditioning and

weighing


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.


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 361010003Pinnacle Park, New York


36

Minimum NCore Network Requirements

Pacific Ocean

-160°-170°-180°

-150°

-150°

-140° -130°

50°

60°

70°

Pacific Ocean

-160°

20

°

(All fifty States, District of Columbia, Puerto Rico, Virgin Islands)

1 Site

2 or 3 Sites

Gulf of Mexico

AtlanticOcean

PacificOcean

Canada

Mexico

-130°

-120°

-120°

-110°

-110°

-100°

-100° -90°

-90°

-80°

-80°

-70°

30°

30°

40°

40°


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 [email protected] 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.


Changes in QA Requirements

NOTE: If the tribes would like its data to be considered in NAAQSdeterminations, 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

MQOs for Gaseous Pollutants Will Change

• Ozone to 7% CV +/- 7% Bias• Other gases will be changed to 10% in Guidance

Ozone (2004-2005) Upper Bound CV

0.00

7.00

14.00

1 42 83 124 165 206 247 288 329 370 411 452 493 534 575 616 657 698 739 780 821

Individual Monitors

90%

Up

per

Bo

un

d C

V (

%)

97% monitors meeting this requirement now for ozone!


47

NO2 (2004-2005) Upper Bound CV

0

10

20

0 50 100 150 200 250 300 350

Individual Monitors

90%

Up

er B

ou

nd

CV

(%

)

SO2 (2004-2005) Upper Bound CV

0

10

20

0 50 100 150 200 250 300 350 400

Individual Monitors

90%

Up

per

Bo

un

d C

V (

%)

Carbon Monoxide (2004-2005) Upper Bound CV

0

10

20

0 50 100 150 200 250 300 350 400

Individual M onitors

90%

Upp

er B

ound

CV

(%)


48

New StatisticsChanged 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

Site:

Automated Methods

Manual Methods

{Enter Site ID or Name Here}

Step 3

DASC (Data Assessment Statistical Calculator)

Step 2

Pick a Pollutant

Step 1

Pick a Statistic to Calculate

SO2

Go To Worksheet

Precision Estimate

Bias Estimate

Absolute Bias EstimateAbsolute Bias Estimate

Semi-Annual Flow RateSemi-Annual Flow Rate

PM 2.5

PM 10

PM 10-2.5

NO2

O3

CO

Lead

One-Point Flow RateOne-Point Flow RatePM 2.5

PM10

PM 10-2.5

CV_ub (%) Bias (%)Meas Val

(Y)Audit Val

(X) d (Eqn. 1) 25th Percentile d_sqrd d_abs d_abs ^219.9 20 -0.500 -6.500 0.250 0.500 0.25020 20 0.000 75th Percentile 0.000 0.000 0.000 n st dev(d) st dev (d^2) sum(d_abs) "AB" (Eqn 3a)19.8 20 -1.000 -4.000 1.000 1.000 1.000 162 2.544 27.349 863.500 5.33019.9 20 -0.500 0.250 0.500 0.250 n-1 sum(d) sum(d^2) sum(d_abs^2) "AS" (Eqn 3b)20 20 0.000 0.000 0.000 0.000 161 -850.500 5507.250 5507.250 2.37020.1 20 0.500 0.250 0.500 0.25019.9 20 -0.500 0.250 0.500 0.250 Bias (%) (Eqn 3) Both Signs Positive19.9 20 -0.500 0.250 0.500 0.250 5.64 FALSE19.6 20 -2.000 4.000 2.000 4.000 CV (%) (Eqn 2) Signed Bias (%) Both Signs Negative19.6 20 -2.000 4.000 2.000 4.000 2.74 -5.64 TRUE19.7 20 -1.500 2.250 1.500 2.25019.6 20 -2.000 4.000 2.000 4.000 Upper Probability Limit Lower Probability Limit19.8 20 -1.000 1.000 1.000 1.000 -0.26 -10.2419.6 20 -2.000 4.000 2.000 4.00019.5 20 -2.500 6.250 2.500 6.25019.7 20 -1.500 2.250 1.500 2.25019.6 20 -2.000 4.000 2.000 4.00019.6 20 -2.000 4.000 2.000 4.00019.1 20 -4.500 20.250 4.500 20.25019.5 20 -2.500 6.250 2.500 6.25019.4 20 -3.000 9.000 3.000 9.00019.6 20 -2.000 4.000 2.000 4.00019.5 20 -2.500 6.250 2.500 6.25019.5 20 -2.500 6.250 2.500 6.25019.4 20 -3.000 9.000 3.000 9.00019.5 20 -2.500 6.250 2.500 6.25019.3 20 -3.500 12.250 3.500 12.25019.1 20 -4.500 20.250 4.500 20.25019.1 20 -4.500 20.250 4.500 20.25019.3 20 -3.500 12.250 3.500 12.25019.2 20 -4.000 16.000 4.000 16.00019.2 20 -4.000 16.000 4.000 16.00019.1 20 -4.500 20.250 4.500 20.25019.2 20 -4.000 16.000 4.000 16.000

Gaseous Assessments Site ID: Burdens Pollutant type: NOy API

NOy API Percent Difference

-14.000

-12.000

-10.000

-8.000

-6.000

-4.000

-2.000

0.000

2.000

4.000

6.000

8.000

Observations

Per

cen

t D

iffe

ren

ce


50

Expanded audit concentration levels for precursor gas monitoring

Concentration range, ppm Audit level O3 SO2, NO2 CO

1...... 0.02-0.05 0.0003-0.005 0.0002-0.002 0.08-0.10

2...... 0.06-0.10 0.006-0.01 0.003-0.005 0.50-1.00

3...... 0.11-0.20 0.02-0.10 0.006-0.10 1.50-4.00

4...... 0.21-0.30 0.11-0.40 0.11-0.30 5-15

5...... 0.31-0.90 0.41-0.90 0.31-0.60 20-50

“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.”


51

PM10 and PM2.5 Collocation Reductions/Changes

• Number of sites reduced from 25% to 15% • Sampling frequency 1-in-6 days to 1-in 12 days• Reduced cutoff values for keeping data when calculating precision statistics

– From 20 ug/m3 to 15 ug/m3 for PM10

– From 6 ug/m3 to 3 ug/m3 for PM2.5


52

PM10-2.5 Collocation Requirements

• Only some NCore stations will have to have two collocated PM10-2.5 samplers.

• Goal is 15% of each sampler model, nationally – Regional Administrator makes decision– Start with PQAOs with more than one NCore/PM10-2.5

site – PM10-2.5 collocation can count towards PM10 and PM2.5

collocation requirements.


53

Flow Rate Audit Changes

• Standardized PM monitoring flow rate audit and verification frequencies– Automated Methods

• Reduced PM2.5 audit requirements but increased PM10 requirements (effective now).

• Reduced PM10 and PM2.5 verification requirements

– Manual Methods• Decreased PM2.5 audit requirement but increased PM10• No Change to PM2.5 verifications but increased PM10


54

Revised Performance Evaluation Programs - PEP and NPAP

• Monitoring organization responsible for implementing adequate and independent audit programs– Any Agency implementation approach must meet adequacy

and independence criteria• Regions will accept monitoring organizations’ do-it-yourself

implementation based on these criteria– Or, Agency can opt for continued Federal implementation with

STAG funds


55

NPAP/PEP Implementation – Do-it-yourself or Federal?

• May 17, 2006- FY07 PEP/NPAP Implementation Memo to monitoring organizations.– Provided options for FY07 and requested statement of

intentions by July 15, 2006.• 1 new monitoring organization (NY) opting for PEP • 3 new monitoring organizations opting for NPAP (NY, TX,

FL)

• Similar memo generated each year for monitoring organization decision

• Tribes will work through the process this year (Thursday, Session 1C)


56

Adequate NPAP/PEP NPAP• Performing audits at a risk-

targeted 20% of monitoring sites/instruments

• Data submission to AQS• Development of a delivery

system that will allow for the audit concentration gasses to be introduced to the probe inlet

• Follow NPAP field/lab SOP critical performance criteria

• Use of audit gasses that are NIST certified and validated at least once a year

• Validation/certification with the EPA NPAP program through collocated auditing

• Incorporated in QAPP

PEP• Valid audits of 5 or 8 per PQAO

per year• Data submission to AQS• Use of independent personnel,

sampling devices (FRMs) and standards

• Follow PEP field/lab SOPs (e.g. for verifications, sample pick-up/delivery schedules, COC, lab criteria

• Follow PEP validation criteria• Participate in parking lot

collocations for comparability against PEP program

• Independent lab from routine• Incorporated into QAPP


57

Independent assessment - an assessment performed by a qualified individual, group, or organization that is not part of the organization directly performing and accountable for the work being assessed. This auditing organization must not be involved with the generation of the routine ambient air monitoring data. An organization can conduct the NPAP/PEP if it can meet the above definition and has a management structure that, at a minimum, will allow for the separation of its routine sampling personnel from its auditing personnel by two levels of management, as illustrated in the figure below.

Organizations planning to implement the NPAP/PEP must submit a plan demonstrating independence to the EPA Regional Office responsible for overseeing quality assurance related activities for the ambient air monitoring network.

Organization3rd Level

Supervision

Organization2nd Level Supervision

Organization 1st Level

Supervision

OrganizationPersonnel

QA Lab Analysis

Organization1st Level

Supervision


QA Field Sampling

Organization2nd Level

Supervision


Supervision

Organization Personnel

Routine Lab Analysis


Supervision


Routine Field Sampling

For PEP, labs mustalso be independent


58

PM2.5 Performance Evaluation Program (PEP) –Fewer Audits Required

• From 25% of sites 4 times a year to:– 5 audits for PQAOs with < 5 sites (15 over 3 years)– 8 audits for PQAOs with > 5 sites (24 over 3 years)

• Consolidation of PQAOs can reduce PEP audit costs

RESOURCES

STATISTICS


59

Changed Term “Reporting Organization” to “Primary Quality Assurance Organization”

• Will retain “reporting organization” role for another use• In most cases RO will equal PQAO• AQS is working with users to reduce burdens of adding this role

Old Rule (before 9/27/06) New Rule 3.0.3 Each reporting organization shall be defined such that measurement uncertainty among all stations in the organization can be expected to be reasonably homogeneous, as a result of common factors. (a) Common factors that should be considered by in defining reporting organizations include: (1) Operation by a common team of field operators (2) Common calibration facilities. (3) Oversight by a common quality assurance organization. (4) Support by a common laboratory or headquarters.

3.1.1 Each primary quality assurance organization shall be defined such that measurement uncertainty among all stations in the organization can be expected to be reasonably homogeneous, as a result of common factors. Common factors that should be considered by monitoring organizations in defining primary quality assurance organizations include: (a) Operation by a common team of field operators according to a common set of procedures; (b) Use of a common QAPP or standard operating procedures; (c) Common calibration facilities and standards; (d) Oversight by a common quality assurance organization; and

(e) Support by a common management, laboratory or headquarters.


60

PM QA Regulation Changes and Related Burdens

Method Coverage Minimum Frequency

Old Rule

Minimum Frequency

New Rule

Net Effect

Automated Methods

Flow rate verification PM2.5, PM10-2.5

Each sampler

Once every 2 weeks

Once every month

Decrease 12/unit

PM10, Each sampler Once every 2 weeks Once every month Decrease by 12/unit

Flow rate audit PM2.5, PM10-2.5

Each sampler

Once every Quarter

Once every 6 months

Decrease by 2 per unit

PM10, Each Sampler Once every year Once every 6 months Increase by 1 per unit

Collocated Sampling PM2.5, PM10-2.5

15%

Every 6 days

Every twelve days

Decrease by 30 per collocated unit

Performance Evaluation Program (PEP) PM2.5,PM10-2.5

See rule

25% of method designations 4 times per year

1. 5 valid audits for primary QA orgs, with < 5 sites 2. 8 valid audits for primary QA orgs, with > 5 sites

Decrease in overall national audits by ~25%

Manual Instruments

Collocated Sampling PM10-2.5, PM2.5 PM10, TSP,

15% Every 6 days Every 12 days Decrease by 30 per collocated unit

Flow rate verification PM10-2.5, PM2.5

Each sampler

Once every month

Once every month

No Change

PM10, TSP No verification Once every quarter** (Changed) Increase of 4 per unit

Flow rate audit PM10-2.5, PM2.5

Each sampler

Once every Quarter

Once every 6 months

Decrease by 2 per unit

PM10 , TSP Each sampler Once every year Once every 6 months Increase by 1 per unit

Manual Methods Lead

1. Each sampler 2. Analytical system

1. Include with TSP 2. Each quarter

1. Include with TSP 2. Each quarter

No Change

Performance Evaluation Program PM2.5,PM10-2.5

See rule

25% of method designations 4 times per year

1. 5 valid audits for primary QA orgs, with < 5 sites 2. 8 valid audits for primary QA orgs, with > 5 sites

Decrease in overall national audits by ~25%


Other Monitoring Requirements


62

AQS Data Submittal, Certification, and Archiving

• Quarterly ambient data reporting remains the same – within 90 days past the end of the quarter.– SO2, CO, O3, NO2, NO, NOX, NOY, Pb, PM10, PM2.5, PM10-2.5,

chemical speciation, meteorological data for NCore and PAMS.– Reduced requirements for supplemental PM2.5 records – only

sampler-generated average temperature and barometric pressure. – More explicit reference to reporting of precision and accuracy data in

§58.16.• 6-month Data Reporting – past the end of the quarter.

– VOC, and if collected, carbonyl, NH3, and HNO3

• New requirement for reporting field blank mass (micrograms) for PM2.5 filter based FRM/FEMs

• Data certification deadline moved up from July 1st to May 1st, beginning in 2010 (for data collected in calendar year 2009).

• New requirement for archiving filters from low-volume PM10 or PM10-2.5 samplers (in addition to existing PM2.5 requirement).


63

PM2.5 Federal Reference Method Data Reporting Requirements

Information to be ProvidedSource of

InformationUnits

Frequency of Reporting

Concentration Calculated µg/m3 Each sample

Average ambient Temperature for the sample period

Sampler O C Each sample

Average Barometric Pressure for the Sample Period

Sampler mm Hg Each Sample

Field Blanks Calculated µgEach collected field

blank

Flow rate, 5-min. average out of spec (FLAG)

Sampler On/off Only if applicable

Filter Temperature differential, 30-second interval out of spec.

(FLAG)Sampler On/off Only if applicable

Elapsed Sample Time, out of spec. (FLAG)

Sampler On/off Only if applicable

Note: other non-sampler flags may be necessary for reporting, as applicable.


Coming Soon – Corrections and One Other

Change


65

• Fix many small Federal Register print errors in equations and tables.

• Several instances of ambiguous, incorrect, and/or inconsistent wording in rule and preamble language, versus our intention.– Editorial changes are all in the direction of clarifying that the less

onerous interpretation of an unclear provision is the intended one, or of affirming current practices.

• New: Allow Regional Administrator modification of PM10 minimum monitoring requirements, like for PM2.5 and ozone already.– There are approximately 8 MSA’s where States (some with low

historical ambient PM10 levels) are now operating below the minimums listed in Table D-4. Includes Houston. TX.

• Anticipated Federal Register Notification in June– 30 day comment period

• Goal is to complete all changes in time for inclusion within the July 1, 2007 hard copy print of the Code of Federal Regulations.

• Adverse comment will delay closure on individual provisions.

Corrections and Changes- Direct Final

national tribal forum on air quality conference - 2007 revisions to the naaqs and ambient monitoring...

Documents