Review of the National Ambient Air Quality Standards for

Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Continuous PM2.5 Monitoring Issues National Air Quality Conference, Portland Oregon, April 6, 2008 Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 U.S. PM Continuous Monitoring History • • 1990 – First PM10 automated equivalent methods approved. 1997 – PM2.5 NAAQS and monitoring rules • Classes of equivalency introduced; however, specifics not included for class III (i.e., continuous monitors) • First specific network requirements for PM2.5 continuous monitors – one per metropolitan areas over 1M people 2001 – CASAC Workshop on accommodating emerging technologies into routine air monitoring networks 2002 – Continuous Monitoring Implementation Plan developed and reviewed by CASAC 2003 – AIRNOW goes public with reports and forecasts using PM2.5 continuous monitoring data 2006 – EPA finalizes PM NAAQS and monitoring rules with several provisions for PM2.5 continuous monitors 2008 – March 12 - EPA-ORD approves Met One BAM 1020 as a PM2.5 FEM • • • • • Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 PM2.5 Continuous Mass Sites by Method TEOM FDMS BAM NEPHELOMETER Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Questions of the Day • What key provisions of the monitoring regulations impact continuous PM2.5 monitoring? • What flexibility will EPA provide in the reporting and use of data from newly deployed FEM monitors? • How will the data from FEM’s and ARM’s be used to calculate design values? • What are the recommended best practices for operating and maintaining continuous PM2.5 monitors? • How can continuous PM2.5 monitors be used in support of emergencies and natural events? • How will State/local/Tribal agencies utilize approved monitors in their networks? Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Time 12:30 – 1:00 1:00 – 1:30 Topic Introduction and Agenda Review -Monitoring Regulations that affect PM2.5 continuous monitoring Data Handling and NAAQS Interpretation issues Instructor Lewis Weinstock - EPA Mark Schmidt - EPA Specific PM2.5 Continuous Methods (tips on configuration, operation, maintenance, calibration, audit, data interpretation) 1:30 – 2:00 2:00 – 2:30 2:30 – 3:00 3:00 – 3:30 Filter Dynamic Measurement System (FDMS) Beta Attenuation Monitor (BAM) Break Nephelometers End specific method sections Ron Stockett – MO DNR Mac McDougall – CA ARB Matt Harper – Puget Sound CAA 3:30 – 4:00 4:00 – 4:30 PM2.5 monitoring in support of emergencies and natural events (E-BAM) Discussion – How do agencies plan on utilizing FEM/ARM monitors in their networks? General Q&A on continuous PM2.5 issues – follow-ups Mac McDougall – CA ARB Nealson Watkins - EPA Dirk Felton – NY DEC Mike Gilroy – Puget Sound CAA Lewis Weinstock - EPA All instructors 4:30 – 5:00 Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Regulations that affect PM2.5 continuous monitoring (October 2006 revisions) Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 PM2.5 Class III FEM Testing Requirements • Vendor driven process – submits application to U.S. EPA Office of Research and Development. – Three FRM samplers and three candidate FEM samplers for each test campaign. – Minimum of 23 valid sets of data per campaign (22 – 25 hours in duration for each sample). – Precision requirements for FRM and candidate FEM’s. – Total of 4 test sites (5 campaigns). – Criteria for multiplicative bias, additive bias, and correlation. – Candidate method must “pass” at each test location (seasons can be combined) Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 PM2.5 Class II and III Test Site Summary Test Site A Los Angeles basin or California Central Valley B Western city such as Denver, Salt Lake City, or Albuquerque C D Northeastern or mid-Atlantic city Location Area Midwestern City Site Characteristics Relatively high PM2.5 nitrates, Cold weather, and semi-volatile higher elevation, organic winds, and dust pollutants Winter and Summer Winter Substantial temperature variation, high nitrates, wintertime conditions Winter High sulfate and high relative humidity Class III Field Test Campaigns Class II Field Test Campaigns Summer Site A or B, any season Site C or D any season Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Performance Criteria for Approval of Federal Equivalent Methods (PM2.5) Acceptance Limits for Slope and Intercept for PM2.5 Methods Class II 4 3 Class III Intercept, µg/m 3 2 1 0 -1 -2 -3 -4 0.8 0.9 1.0 Slope 1.1 1.2 Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 PM2.5 and PM10-2.5 Class II and III Methods Correlation Criteria Minimum Limits for Correlation Coefficient 0.99 Correlation coefficient, r 0.97 0.95 0.93 0.91 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 Concentration correlation coefficient, CCV • • Correlation is r (not r2) CCV is a measure of the spread of the sample concentrations Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 PM2.5 Federal Equivalent Method (FEM) Update • Met One BAM 1020 Approved • Two other instrument companies have stated they are testing candidate FEMs • EPA-OAQPS is making plans to develop supporting documentation for monitoring agencies who implement PM2.5 FEMs – Standard Operating Procedures based on expert use of the instruments • Let us know if you have advice/input on a FEM? Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Approved Regional Methods (ARMs) for PM2.5 • • • • A PM2.5 continuous method approved for use within a State, local, or Tribal agency used to meet multiple monitoring objectives such as NAAQS, Air Quality Index, and forecast validation. Allows agencies to optimize their PM2.5 network with well performing (and currently deployed) continuous methods that may not perform well in all required FEM testing regions. Monitoring Agency-driven Testing Process – Uses basically the same performance criteria as Class III methods. – Testing occurs at subset of sites in the network within which it’s intended to be used. Approvals – Initial ARM application approved through EPA’s Office of Research & Development. – Subsequent applications for method in another agency’s network approved by EPA Regional Office. – All procedures (including proposed use of data transformations) must be fully described in Quality Assurance Program Plan accompanying ARM application. – OAQPS developed FEM/ARM tool to help with calculations Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Implementation Issues with ARM Rule Language • Appendix C requires use of an inlet and separation device (if needed) that are already approved in either appendix L (PM2.5 FRM) or under Part 53 as an FRM or FEM. – OAQPS has determined that SCC (sharp cut cyclone) based test data from candidate ARM continuous monitors are not acceptable because the SCC was never an EPA-approved separator. – OGC shot down “functional equivalence” rationale. – Year of test data must be obtained using the VSCC (very sharp cut cyclone). – Doesn’t effect nephelometer-based ARM applications. Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Other Requirements • Daily operating schedules for design value monitors within 5% of 24-hour NAAQS – Instituted to account for 98th percentile bias in 1-in-3 day FRM/FEM filter-based samplers – FEM or ARM monitors can be used to meet requirement • Continuous monitoring requirement (does not have to be FEM or ARM) – one half of required monitors – in addition to FRM/FEM filter-based samplers – Requirement is met with deployment of continuous FEM/ARM monitors Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 PM2.5 Continuous Methods QA Requirements Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Affect of adding FEM’s to QA Programs • Will need to identify FEM’s in Quality Assurance Project Plan – Regions may have different mechanisms for doing this • QA Requirements for FEM and FRM the same – Flow Rates (verification and audits) – Collocation – PEP Don’t confuse PM10 FEM requirements with PM2.5 FEM requirements Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 PM2.5 FEM Requirements (Yellow Area) Table 1. Ambient Air Monitoring Measurement Quality Samples (Table A in 40 CFR Appendix A) -2 Method CFR Reference Coverage (annual) Automated Methods One-Point QC: for SO2, NO2, O3, CO Annual performance evaluation for SO2, NO2, O3, CO Flow rate verification PM10,PM2.5, PM10-2.5 Semi-annual flow rate audit PM10, PM2.5, PM10-2.5 Collocated sampling PM2.5, PM10-2.5 PM Performance evaluation program PM2.5,PM10-2.5 Section 3.2.1 Each analyzer Once per 2 weeks O3 Precision 7%, Bias + 7%. SO2, NO2, CO Precision 10% , Bias + 10% < 15 % for each audit concentration < 4% of standard and 5% of design value < 4% of standard and 5% of design value PM2.5, - 10% precision PM10-2.5- - 15% precision PM2.5, - + 10% bias PM10-2.5- - +15% bias Minimum frequency MQOs* Section 3.2.2 Section 3.2.3 Each analyzer Each sampler Once per year Once every month Section 3.2.4 Section 3.2.5 Section 3.2.7 Each sampler Once every 6 months 15% 1. 5 valid audits for primary QA orgs, with < 5 sites 2. 8 valid audits for primary QA orgs, with > 5 sites 3. All samplers in 6 years Every twelve days over all 4 quarters Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 PEP Requirements All sites (FEM and FRM’s) added together then: – < 5 sites, 5 audits – > 6 sites, 8 audits – Must have each method designation audited each year – All samplers/monitors audited within 6 year period – Bias calculations (AMP255) performed on Primary Quality Assurance Organization (PQAO) level of aggregation, but can probably revise to method designation level • Annual PEP report will break out by method designation Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 FEM Collocation Requirement (Table A-3 40 CFR Part 58 App A) Extreme Example- One PQAO with FRM monitors (one method designation) and 3 FEM method designation in Network Primary sampler method designation Total no. of monitors Total no. collocated (15%) No. of collocated FRM No. of collocated monitors of same method designation as primary FRM FEM (A) FEM (C) FEM (D) 20 20 2 12 3 3 1 2 3 2 1 1 n/a 1 0 1 Basic Rules – Using example FEM (A) • 15% collocation from each method designation (20* 0.15=3) • 50% of collocated must be with FRM; 50% with FEM. If there are an odd number of monitors the FRM gets the extra (Section 3.2.5.2) Precision calculation (AMP255) performed at PQAO level (aggregation of all method designations) Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Deploying Continuous FEM’s in the PM2.5 Network Issues for Monitoring Agencies to Consider **For Discussions Purposes at NAQC – Does not represent EPA Policy** Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Transition Issues with Continuous PM2.5 FEM’s “Look Before You Leap” Requirement SOP and QAPP modifications must be completed and operator staff trained Discuss network modifications with the Region prior to deployment Strongly recommended Insure understanding of Appendix N data augmentation rules Collocate first deployed continuous FEM with a filter-based FRM and plan additional pairings to quickly meet Appendix A requirements Suggest Carefully consider whether FEM’s should be placed at design value sites Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Suggested Transition Strategy for Continuous PM2.5 FEM’s **For Discussions Purposes at NAQC – Does not represent EPA Policy** • • • Classify new FEM’s initially as Special Purpose Monitors (SPM’s) – However, cannot be used to meet minimum monitoring requirements if so classified – Data will not be used to augment FRM’s for a limited test period Deploy with collocated FRM’s to meet or exceed QA requirements for collocation – Suggest multiple collocated sites with at least one site having a 1-in-3 day FRM Data Reporting (following initial break-in period) – Suggest reporting FEM data as AQS parameter 88501 – Raw data – during test period. Keeps test data out of 88101 bin used for NAAQS comparisons. – Could also apply a pre-existing “FRM-like” correction for AIRNOW reporting, if necessary, and to support parameter 88502 – Acceptable PM2.5 AQI – EPA will not prevent initial classification as SLAMS and reporting as 88101 if S/L/T and Region agree this is the right thing to do. Review data carefully (raw FEM versus FRM) for agreement that meets Class III criteria over test period Then…………next slide…….. • • Note – all network modifications should be reviewed by the Regional EPA Office and documented in the Annual Monitoring Network Plan Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Suggested Transition Strategy for Continuous PM2.5 FEM’s **For Discussions Purposes at NAQC – Does not represent EPA Policy** • After 1 year period as an SPM, review data status: – Agreement with FRM meets the Class III criteria -> Reclassify FEM(s) to SLAMS (data in play for augmentation, FRM shut-downs are possible). Report FEM as parameter 88101 following SLAMS classification. – Agreement with FRM does not meet the Class III criteria but can be corrected • Maintain SPM status for up to a second year • Further investigate reason(s) for differences while continuing to report FEM data as 88501 and 88502 • Consider the ARM or user modification option for transforming data with ultimate goal of conversion to SLAMS – Agreement cannot be corrected to meet Class III criteria • Discuss issues with vendor, S/L/T colleagues using same FEM, and Regional Office • Consider discontinuing operation and rethink further purchases of this method Note – all network modifications should be reviewed by the Regional EPA Office and documented in the Annual Monitoring Network Plan Ozone MonitoringQuality Conference - NAAQS National Air Options for Revised 2008 Questions?