Gordon Pierce
WESTAR Fall Business Meeting
Denver, CO
November 6, 2013
CSN Assessment
 Need to make the CSN network sustainable
 Currently 190 sites
 Objectives of CSN:
 Support PM2.5 implementation
 Support trends analyses
 Aid with health studies
 Need to:
 Leverage other resources (IMPROVE, PAMS, etc.)
 Redistribute resources to higher priority sites
 CSN assessment:
 Target 30% reduction in budget
 Assess network effectiveness and efficiency
 Develop recommendations by end of 2013
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PAMS Re-engineering
 EPA still looking at changing the PAMS network,
probably associated with next ozone NAAQS
 Now have consensus on a network design:
 NCore sites in ozone non-attainment areas
 State-directed enhanced ozone in non-attainment areas
 Required analytes:
 O3, NO, true NO2, NOy, hourly VOC, aldehydes, mixing
height
 Auto-GC evaluation will occur
 Need to update date analysis tools
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PM2.5 Monitoring Implementation
 Agencies need to list in annual network plans how
they are using continuous PM2.5 data
 FEM-like?
 Need to request that not to be used for NAAQS
comparisons (a template is now available)
 PM2.5 Continuous Monitor Comparability
Assessment Tool is available on web and has
recently been updated
 ORD is not working on PM methods at this time
 PM2.5 methods still have issues:
 Met-One BAM needs good grounding and is affected by
humidity
 Thermo 2025i has software issues
 Thermo TEOM 1405 has a new valve available
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Near-Road NO2
 Rule finalized to add 1-year to the implementation
timeline to sync with budget and available funds
 Phase 1 now required by 1/1/2014 (instead of 1/1/2013)
 Phase 2 now required by 1/1/2015 (instead of 1/1/2014)
 Problem: Funding for Phase 1 has all been allocated,
but sequestration has now affected available funds
for Phase 2
 Plan is to look at 2014 budget to find funds for 19 Phase 2
sites
 Will assess data after 1 or 2 years to see if need for
Phase 3 sites (500,000 MSAs) to see if need by
1/1/2017 or revise rules to eliminate
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Monitoring Rules
 EPA is starting to look at common-sense revisions
to monitoring rules in 2014
 Clarify QA (40 CFR 58 Appendix A)
 Reduce data certification requirements
 Clarify monitoring network plan requirements
 Revise NO2 network timeline
 Are trying to avoid OMB review, so will stay away
from hot-topics at this point
 Send any comments/suggestions to Lew Weinstock
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SO2 Technical Assistance Documents
 New TAD allows for use of actual emissions instead of
potential-to-emit
 In-house testing has showed that the model performs fairly
well
 Problems with TAD:
 Data requirements rule missing which would specify the
threshold of sources to look at
 Doesn’t address short-term peaking units
 No specifics on number of monitoring sites required
 5-minute exposures not addressed
 Monitor shut-down not addressed for when sources have major
emissions reductions or shut down
 Monitoring vs modeling timeframes are different
 Send comments to EPA
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Air Toxics
 Carbonyl measurements are problematic
 Formaldehyde is the #1 risk driver on NATA
 Existing sampling and analysis methods have known
issues
 Metals proficiency test samples are only provided
on quartz-fiber filters, but many agencies using
teflon filters for samples
 Many of the TO methods are out of date and should
be revised
 Possibly use some of the PAMS analysis funds to
work on carbonyl and other methods
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Lab Competency Policy
 Agencies required to have competency/certification
documentation if receive over $200,000
 Not supposed to be an additional burden
 Implementation being pushed back to 2014
 Labs do not have to be certified, but if they are, it
can be used as documentation to satisfy the policy
 QAPPs can be used as documentation to satisfy the
policy
 A list of acceptable documents is to be developed by
EPA
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Community/Citizen Monitoring
 Had some good discussions at the meeting
 Will be discussed in Hot-Topics session later
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 Next Monitoring Conference now set for
August 2014 in Atlanta
 Next MSC meeting December 4-5, 2013
in San Francisco
Questions?
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