Continuous PM2'5 Monitoring Issues

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Continuous PM2.5 Monitoring Issues
National Air Quality Conference, Portland Oregon,
April 6, 2008
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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

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PM2.5 Continuous Mass Sites by Method
TEOM
FDMS
BAM
NEPHELOMETER
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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 FEMs and ARMs 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?

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(No Transcript)
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Regulations that affect PM2.5 continuous
monitoring(October 2006 revisions)
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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
  FEMs.
• 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)

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PM2.5 Class II and III Test Site Summary
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Performance Criteria for Approval of Federal
Equivalent Methods (PM2.5)
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PM2.5 and PM10-2.5 Class II and III Methods
Correlation Criteria

• Correlation is r (not r2)
• CCV is a measure of the spread of the sample
  concentrations

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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?

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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 its intended to be used.
• Approvals
• Initial ARM application approved through EPAs
  Office of Research Development.
• Subsequent applications for method in another
  agencys 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

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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).
• Doesnt effect nephelometer-based ARM
  applications.

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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

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PM2.5 Continuous MethodsQA Requirements
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Affect of adding FEMs to QA Programs

• Will need to identify FEMs 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

Dont confuse PM10 FEM requirements with PM2.5
FEM requirements
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PM2.5 FEM Requirements (Yellow Area)
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PEP Requirements

• All sites (FEM and FRMs) added together then
• lt 5 sites, 5 audits
• gt 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

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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
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Deploying Continuous FEMs in the PM2.5
NetworkIssues for Monitoring Agencies to
Consider
For Discussions Purposes at NAQC Does not
represent EPA Policy
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Transition Issues with Continuous PM2.5
FEMsLook Before You Leap
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Suggested Transition Strategy for Continuous
PM2.5 FEMsFor Discussions Purposes at NAQC
Does not represent EPA Policy

• Classify new FEMs initially as Special Purpose
  Monitors (SPMs)
• However, cannot be used to meet minimum
  monitoring requirements if so classified
• Data will not be used to augment FRMs for a
  limited test period
• Deploy with collocated FRMs 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
• Thennext slide..

Note all network modifications should be
reviewed by the Regional EPA Office and
documented in the Annual Monitoring Network Plan
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Suggested Transition Strategy for Continuous
PM2.5 FEMsFor 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
  -gt 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
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Questions?