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

2. National Tribal Forum on Air Quality Conference - 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. National Tribal Forum on Air Quality Conference - 2007 PM NAAQS Revisions

4. National Tribal Forum on Air Quality Conference - 2007 4 New National Ambient Air Quality Standards for PM Previous Standards2006 Standards Annual24-hourAnnual24-hour PM 2.5 (Fine Particles) 15 µg/m 3 Annual arithmetic mean, averaged over 3 years (established in 1997) 65 µg/m 3 24- hour average, 98 th percentile, averaged over 3 years (established in 1997) 15 µg/m 3 Annual arithmetic mean, averaged over 3 years 35 µg/m 3 24- hour average, 98 th percentile, averaged over 3 years PM 10 (Coarse Particles) 50 µg/m 3 Annual average (established in 1987) 150 µg/m 3 24-hr average, not to be exceeded more than once per year on average over a three year period (established in 1987) Revoked150 µg/m 3 24-hr average, not to be exceeded more than once per year on average over a three year period

5. National Tribal Forum on Air Quality Conference - 2007 5  Violates annual NAAQS (15.0 µg/m 3 ) and 24-hour NAAQS (65 µg/m 3 )  Violates only 24-hour NAAQS (65 µg/m 3 )  Violates only annual NAAQS (15.0 µg/m 3 ) 2001-2003 Design Values Designated PM2.5 Nonattainment Areas 1997 NAAQS 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. National Tribal Forum on Air Quality Conference - 2007 6 PM 2.5 - Trends µg/m 3 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 (SO 2 reductions) 2005 increases due in part to sulfate increases & meteorology

7. National Tribal Forum on Air Quality Conference - 2007 7 PM 2.5 NAAQS Changes Spatial Averaging 1997 Criteria 1.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/m 3 ) must meet these new criteria (for 3 consecutive years)

8. National Tribal Forum on Air Quality Conference - 2007 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 violations related to annual NAAQS Areas/Sites Violating NEW PM2.5 24-hour NAAQS – 2003-2005

9. National Tribal Forum on Air Quality Conference - 2007 9 Expected Timeline for PM 2.5 NAAQS Implementation Dec. 2006Effective date for revised 2006 PM 2.5 NAAQS Dec. 2007States recommend designations for revised PM 2.5 24-hour standard. Using ’04-’06 or ’05-’07 Dec. 2009Final designations for revised PM 2.5 24-hr std April 2010Effective date for revised PM 2.5 24-hr std area designations April 2013State plans due for revised PM 2.5 24-hr std. April 2015- 2020 Attainment date for revised PM 2.5 24-hr std

10. National Tribal Forum on Air Quality Conference - 2007 10 PM 10 NAAQS – History Review In 1997, EPA retained both 24-hour and annual PM 10 standards at pre- 1997 levels –Based on generally strong scientific support for retaining standards to protect against the effects of coarse fraction particles (PM 10-2.5 ) 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 PM 10 to be a poorly matched indicator for coarse fraction particles because it includes fine particles EPA did not appeal; reverted to 1987 standards –50 µ g/m 3, annual average –150 µ g/m 3, 24-hr average –Method went back to STP

11. National Tribal Forum on Air Quality Conference - 2007 11 PM coarse – A Complicated Path Health studies provided some evidence of differences in the effects of PM coarse in urban areas vs. rural areas, which is plausible in light of composition differences. 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. National Tribal Forum on Air Quality Conference - 2007 12 PM coarse - Final Action –Finalized only some of the PM 10-2.5 proposals PM 10-2.5 Federal Reference Method. Procedures for designating PM 10-2.5 Federal Equivalent Methods (e.g., continuous samplers). PM 10-2.5 monitoring only at about 75 NCore sites, including PM10-2.5 speciation (more sites than proposed). Quality assurance procedures. –Retained existing PM 10 network requirements. –Retained 24-hour PM 10 NAAQS but revoked annual standard –Finalized monitor discontinuation criteria for criteria pollutants, including PM 10. –All areas, no “urban” restrictions. (Same as since 1987.)

13. National Tribal Forum on Air Quality Conference - 2007 Revisions to the Ambient Monitoring Regulations

14. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 15 Four Overarching Goals of the Strategy 1.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. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 17 Ambient Air Monitoring Regulations - Major Components Part 53 –Approval of reference and equivalent methods Revised performance based criteria for PM 2.5 and PM 10-2.5 equivalent methods Part 58 –Criteria for “Approved Regional Methods” for PM 2.5 (revised) –Revised network minimums for O 3 and PM 2.5 based on population and design value –Existing PM 10 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 PM 10-2.5, Waivers for NO y Added PM 10-2.5 speciation as an NCore station requirement. –Revised network minimums for Pb. –Network minimums go away for CO, SO 2, and NO 2. –Revisions to QA program –Updated Special Purpose Monitoring (SPM) provisions –Data reporting to AQS –PAMS network requirements

18. National Tribal Forum on Air Quality Conference - 2007 Important Dates in the Monitoring Rule NOTE: Tribes are not obligated, under CAA, to meet these dates. They are provided for informational purposes.

19. National Tribal Forum on Air Quality Conference - 2007 19 Effective December 18, 2006 New criteria for approval of Federal Equivalent Methods for PM 2.5 and PM 10-2.5, and Approved Regional Methods. New QA requirements for SLAMS. New required numbers of PM 2.5, PM 10, Pb, and ozone monitors by MSA, if lower than old. Removal of required numbers for CO, SO 2, and NO 2 (except if in SIP). Criteria for removal of monitors above required number. Conditions on use of SPM data. Removal of required reporting of certain PM 2.5 monitoring parameters. PM 10-2.5 probe heights. Increased distance between roadways and NEW ozone monitors.

20. National Tribal Forum on Air Quality Conference - 2007 20 Effective January 1, 2007 Every day PM 2.5 samples at about 45 stations reading close to the new 24-hour standard. Retention of low-volume PM 10 and PM 10-2.5 filters. Start preparing blank PM 2.5 filter data for submission to AQS. Last chance to convert excess SLAMS to SPM status, without first meeting criteria for discontinuation.

21. National Tribal Forum on Air Quality Conference - 2007 21 Effective July 1, 2007 Report PM 2.5 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 PM 2.5, PM 10, 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. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 23 Effective January 1, 2008 Start operation of any new required PM 2.5, PM 10, or ozone monitors. –About 13 new PM 2.5 monitors –A few additional ozone monitors. –New PM 10 monitors in approximately 8 MSAs. –Unless modified by the Regional Administrator.

24. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 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. Effective January 1, 2011

26. National Tribal Forum on Air Quality Conference - 2007 PM Methods

27. National Tribal Forum on Air Quality Conference - 2007 27 EPA has finalized PM 2.5 FRM improvements –Incorporation of changes to improve efficiency of monitoring network operations. EPA has finalized PM 10-2.5 FRM –Two concurrently operated low-volume samplers with one measuring PM 10 and the other PM 2.5. Federal Reference Method Updates

28. National Tribal Forum on Air Quality Conference - 2007 28 1.Very Sharp Cut Cyclone (VSCC) as an approved second stage separator for PM 2.5. 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. National Tribal Forum on Air Quality Conference - 2007 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 20 o 30 o 10 o 0o0o Sample period temperature range 25 o effective maximum 13 o average for sample period 4 o minimum Example; units in o C { Acceptable range for up to 30 days post-sampling conditioning and weighing

30. National Tribal Forum on Air Quality Conference - 2007 30 New Methodological Option: Approved Regional Methods (ARMs) for PM 2.5 A PM 2.5 continuous method approved for use within a State, local, or Tribal agency used to meet multiple monitoring objectives Allows agencies to optimize their PM 2.5 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. National Tribal Forum on Air Quality Conference - 2007 31 PM 2.5 – 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. National Tribal Forum on Air Quality Conference - 2007 32 Revocation of Minimum Monitoring Requirements: CO, SO 2, NO 2, 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, SO 2, NO 2. 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. National Tribal Forum on Air Quality Conference - 2007 NCore Monitoring Requirements

34. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 36 Minimum NCore Network Requirements (All fifty States, District of Columbia, Puerto Rico, Virgin Islands) 1 Site 2 or 3 Sites

37. National Tribal Forum on Air Quality Conference - 2007 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 PM 2.5 filter-based and continuous, speciated PM 2.5, PM 10-2.5 FRM/FEM at 1:3 or continuous PM 10-2.5 FEM, speciated PM 10-2.5 –Gases O 3 ; high-sensitivity - CO, SO 2, NO/NO y –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. National Tribal Forum on Air Quality Conference - 2007 38 Working Draft of NCore Multi-pollutant Candidate Sites

39. National Tribal Forum on Air Quality Conference - 2007 39 PM 10-2.5 Monitoring Is a Required Part of NCore, But There Is Much Still To Be Decided and Done PM 10-2.5 Mass and Speciation are required, at 1:3 schedule PM 10-2.5 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 PM 10-2.5 FEM test criteria in monitoring rule. EPA must develop guidance on coarse speciation –Method (dichot more direct approach than FRM) Development of dedicated multi-filter sampler? –Components? Similarities to STN sampling (carbon, metals, ions, crustal elements) Other analyses: pesticides, aeroallergens, endotoxins, other constituents? –Additional important sites for health research Develop needed AQS modifications to handle reporting of paired samples.

40. National Tribal Forum on Air Quality Conference - 2007 40 Expectations for PM 10-2.5 Monitoring Networks Monitoring Agency Action Items Address NCore requirements with FRM’s or FEM’s. Strategically deploy additional SLAMS PM 10-2.5 monitors in urban and rural areas where data would be useful for NAAQS development and/or understanding air quality in areas where PM 10- 2.5 concentrations are relatively high. Periodically review availability of excess PM 2.5 FRM’s (due to introduction of continuous FEMs or ARMs) in support of additional PM 10-2.5 monitoring. –Convert excess PM 2.5 FRM’s to PM 10c as part of PM 10-2.5 FRM or FEM. Consider introduction of continuous PM 10-2.5 FEM’s at NCore and SLAMS to meet other objectives as monitors become available.

41. National Tribal Forum on Air Quality Conference - 2007 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/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 passwordcavender.kevin@epa.gov

42. National Tribal Forum on Air Quality Conference - 2007 42 Example Webpage for Proposed Site

43. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 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 PM 10-2.5, revised the DQOs for O 3 Removed SO2/NO2 manual audit checks

46. National Tribal Forum on Air Quality Conference - 2007 46 MQOs for Gaseous Pollutants Will Change Ozone to 7% CV +/- 7% Bias Other gases will be changed to 10% in Guidance 97% monitors meeting this requirement now for ozone!

47. National Tribal Forum on Air Quality Conference - 2007 47

48. National Tribal Forum on Air Quality Conference - 2007 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 in draft Rationale and excel spreadsheet http://www.epa.gov/ttn/amtic/parslist.html

49. National Tribal Forum on Air Quality Conference - 2007 49 P&B Guidance and Data Assessment Statistical Calculator (DASC) Software

50. National Tribal Forum on Air Quality Conference - 2007 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.”

51. National Tribal Forum on Air Quality Conference - 2007 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/m 3 to 15 ug/m 3 for PM 10 –From 6 ug/m 3 to 3 ug/m 3 for PM 2.5 One required FRM/FEM has to be collocated with a continuous monitor, unless one of the required FRM/FEM monitors is itself continuous (in the future).

52. National Tribal Forum on Air Quality Conference - 2007 52 PM 10-2.5 Collocation Requirements Only some NCore stations will have to have two collocated PM 10-2.5 samplers. Goal is 15% of each sampler model, nationally –Regional Administrator makes decision –Start with PQAOs with more than one NCore/PM 10-2.5 site –PM 10-2.5 collocation can count towards PM 10 and PM 2.5 collocation requirements.

53. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 55 NPAP/PEP Implementation – Do-it-yourself or Federal? May 17, 2006- FY07 PEP/NPAP Implementation Memo to SLTs –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. National Tribal Forum on Air Quality Conference - 2007 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. National Tribal Forum on Air Quality Conference - 2007 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. For PEP, labs must also be independent

58. National Tribal Forum on Air Quality Conference - 2007 58 PM 2.5 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. National Tribal Forum on Air Quality Conference - 2007 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

60. National Tribal Forum on Air Quality Conference - 2007 60 PM QA Regulation Changes and Related Burdens

61. National Tribal Forum on Air Quality Conference - 2007 Other Monitoring Requirements

62. National Tribal Forum on Air Quality Conference - 2007 62 AQS Data Submittal, Certification, and Archiving Quarterly ambient data reporting remains the same – within 90 days past the end of the quarter. –SO 2, CO, O 3, NO 2, NO, NO X, NO Y, Pb, PM 10, PM 2.5, PM 10-2.5, chemical speciation, meteorological data for NCore and PAMS. –Reduced requirements for supplemental PM 2.5 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, NH 3, and HNO 3 New requirement for reporting field blank mass (micrograms) for PM 2.5 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 PM 10 or PM 10-2.5 samplers (in addition to existing PM 2.5 requirement).

63. National Tribal Forum on Air Quality Conference - 2007 63 PM 2.5 Federal Reference Method Data Reporting Requirements Information to be Provided Source of Information Units Frequency of Reporting ConcentrationCalculatedµg/m 3 Each sample Average ambient Temperature for the sample period Sampler O CEach sample Average Barometric Pressure for the Sample Period Samplermm HgEach Sample Field BlanksCalculatedµg Each collected field blank Flow rate, 5-min. average out of spec (FLAG) SamplerOn/offOnly if applicable Filter Temperature differential, 30-second interval out of spec. (FLAG) SamplerOn/offOnly if applicable Elapsed Sample Time, out of spec. (FLAG) SamplerOn/offOnly if applicable Note: other non-sampler flags may be necessary for reporting, as applicable.

64. National Tribal Forum on Air Quality Conference - 2007 64 Special Purpose Monitors (SPM) What is a SPM? –Monitor can be used for up to 24 months without being compared to NAAQS, (except violating monitors may be used for CO, SO 2, NO 2, and Pb when States request an existing non-attainment area be designated to attainment). –Designated in annual network plan and AQS. –Cannot be a monitor used to meet the minimum monitoring requirements. –Cannot be an existing SLAMS monitor, unless EPA approves the change. What applies to it? –Flexibility for network design, and probe and siting criteria. –QA and methods apply for FRM/FEM/ARM if site meets probe siting criteria; however, some QA requirements can be waived when logistically infeasible due to unusual site conditions and not essential to the monitoring objective. –Data submitted to AQS for FRM/FEM/ARM. Other –No prior approval needed to shut down an SPM.

65. National Tribal Forum on Air Quality Conference - 2007 65 Corrections Issue §58.20 Special Purpose Monitors (SPM) Preamble correctly says: “If the Regional Administrator has approved alternative quality assurance practices in place of the requirements of appendix A, the data from the affected SPM are not eligible for comparison to the relevant NAAQS.” Rule incorrectly says: “(c) All data from an SPM using an FRM, FEM, or ARM which has operated for more than 24 months is eligible for comparison to the relevant NAAQS, subject to the conditions of §58.30, unless the air monitoring agency demonstrates that the data came from a particular period during which the requirements of appendix A or an approved alternative, appendix C, or appendix E were not met in practice. Fix: Remove …..or an approved alternative……wording from rule language to clarify that data from such SPM’s would not be NAAQS comparable.

66. National Tribal Forum on Air Quality Conference - 2007 66 Other Monitoring Rule Changes PAMS Monitoring Program –Currently 109 stations in 25 Ozone non-attainment areas. –New requirements represent a reduction to about half the existing requirements. –Allows PAMS programs to be more customized to local data needs. Recommend keeping air toxics data users in mind if there are any reductions. Probe Siting –Increased set-back distances from roadways for new ozone sites. –Finalized middle-scale PM 10-2.5 height requirement.

67. National Tribal Forum on Air Quality Conference - 2007 Coming Soon – Corrections and One Other Change

68. National Tribal Forum on Air Quality Conference - 2007 68 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