AMBIENT AIR MONITORING NETWORK ASSESSMENT GUIDANCE

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AMBIENT AIR MONITORING NETWORK ASSESSMENTGUIDANCEAnalytical Techniques for Technical Assessments of Ambient AirMonitoring Networks

EPA-454/D-07-001February 2007AMBIENT AIR MONITORING NETWORK ASSESSMENTGUIDANCEAnalytical Techniques for Technical Assessments ofAmbient Air Monitoring NetworksPrepared by:Sean M. RaffuseDana C. SullivanMichael C. McCarthyBryan M. PenfoldHilary R. HafnerSonoma Technology, Inc.Petaluma, CaliforniaPrepared for:Kevin A. Cavender, Work Assignment ManagerAmbient Air Monitoring GroupContract No. EP-D-05-004Work Assignment No. 2-12U.S. Environmental Protection AgencyOffice of Air Quality Planning and StandardsAir Quality Assessment DivisionResearch Triangle Park, North Carolina

ACKNOWLEDGMENTSThe authors thank Kevin Cavender, the work assignment manager, for his assistance withthis project. We also acknowledge those involved with the National Analysis (Schmidt, 2001)and the preliminary regional assessments, particularly those performed by U.S. EnvironmentalProtection Agency Regions 3 and 5, upon which this document draws.iii

DISCLAIMERThis document provides guidance to EPA Regional, State, and Tribal air qualitymanagement authorities and the general public, on how EPA intends to exercise its discretion inimplementing Clean Air Act provisions and EPA regulations, concerning ambient airmonitoring. The guidance is designed to implement national policy on these issues. Section 110of the Clean Air Act (42 U.S.C. § 7410) and implementing regulations at 40 CFR part 58 containlegally binding requirements. This document does not substitute for those provisions orregulations, nor is it a regulation itself. Thus, it does not impose binding, enforceablerequirements on any party, nor does it assure that EPA may approve all instances of itsapplication, and thus the guidance may not apply to a particular situation based upon thecircumstances. EPA and State decision makers retain the discretion to adopt approaches on acase-by-case basis that differ from this guidance where appropriate. Any decisions by EPAregarding a particular State implementation plan (SIP) demonstration will only be made based onthe statute and regulations, and will only be made following notice and opportunity for publicreview and comment. Therefore, interested parties are free to raise questions and objectionsabout the appropriateness of the application of this guidance to a particular situation; EPA will,and States should, consider whether or not the recommendations in this guidance are appropriatein that situation. This guidance is a living document and may be revised periodically withoutpublic notice. EPA welcomes public comments on this document at any time and will considerthose comments in any future revision of this guidance document.Readers of this document are cautioned not to regard statements recommending the useof certain procedures or defaults as either precluding other procedures or information orproviding guarantees that using these procedures or defaults will result in actions that are fullyapprovable. As noted above, EPA cannot assure that actions based upon this guidance will befully approvable in all instances, and all final actions may only be taken following notice andopportunity for public comment.v

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FOREWORDThis document represents guidance for the assessment of technical aspects of ambient airmonitoring networks. It is designed to be flexible and expandable with additional types ofanalyses and examples as techniques are improved, enhanced, and more broadly applied. Itsintended audience includes EPA Regional, state, local, and tribal air quality planning agencies.Depending on their unique situations, users of this guidance may select one or more analyses, orthey may creatively modify one of the recommended analyses to facilitate a monitoring networkassessment.The contents of this document are summarized briefly in the following paragraphs: Section 1 summarizes the context of network assessments in general and this specificdocument, including background and key issues. Section 1 provides an overview of therequirements for network assessment contained in 40 CFR Part 58, and provides anoverview of the network assessment process. Section 2 expands on the procedures for network assessments. It introducesconsideration of the purposes of a monitoring network—i.e., a network’s mission. Thepurposes provide a basis for performing a network assessment. They are the benchmarksagainst which the strengths and weaknesses of the network are measured. Section 2continues with specific details for technical approaches to network assessments,including three general categories of analyses: site-by-site, bottom-up, and networkoptimization. Section 3 expands on the technical approaches introduced in Section 2. It includes aselection of two-page illustrations of analyses for network assessments. Section 4 provides information on the regulatory requirements for the discontinuation ofa monitor used in National Ambient Air Quality Standards (NAAQS) compliance. Thesection also provides procedures that can be used to determine if a monitor meets therequirements. Section 5 concludes this guidance document with a summary and recommendations forfurther development of network assessment guidance with an emphasis on expectedresults and resource requirements. More detailed descriptions of the techniques, andmore examples, could be added to future versions of this document as techniques arerefined and more broadly applied. Section 6 lists the references cited in this guidance document. Appendix A discusses project-level example applications of the technical approachesdiscussed in Sections 2 and 3.vii

TABLE OF CONTENTSPageSectionACKNOWLEDGMENTS . iiiDISCLAIMER .vFOREWORD . viiLIST OF FIGURES . xiLIST OF TABLES. xi1.INTRODUCTION. 1-11.1 Background and Key Issues. 1-21.2 Overview of Monitoring Network Technical Assessments. 1-22.APPROACH TO MONITORING NETWORK TECHNICAL ASSESSMENTS . 2-12.1 Identify Monitoring Needs . 2-12.2 Methods for Technical Assessment . 2-32.2.1 Overview . 2-32.2.2 Site-By-Site Analyses. 2-42.2.3 Bottom-Up Analyses . 2-52.2.4 Network Optimization Analyses . 2-63.METHOD SUMMARY SHEETS . 3-14.REMOVING A NAAQS COMPLIANCE MONITOR . 4-14.1 Attainment reached . 4-14.2 Consistently low concentrations relative to other monitors . 4-44.3 Monitors not measuring violations of NAAQS . 4-44.4 Monitors with siting issues . 4-44.5 Upwind monitors . 4-54.6 Logistical problems beyond agency control . 4-55.RECOMMENDATIONS . 5-16.REFERENCES. 6-1APPENDIX A: EXAMPLE APPLICATIONS . A-1ix

LIST OF FIGURESPageFigure3-1.Summary sheet front page example. 3-1LIST OF TABLESTablePage1-1.Descriptions and examples of steps involved in performing network assessments. 1-32-1.Typical purposes for ambient air monitoring networks . 2-12-2.Site-by-site analysis techniques . 2-42-3.Bottom-up analysis techniques . 2-62-4.Network optimization analysis techniques . 2-74-1.National Ambient Air Quality Standards. 4-24-2.Student’s t values . 4-34-3.Example computations for four CO monitoring sites . 4-3xi

1. INTRODUCTIONThe U.S. Environmental Protection Agency (EPA) finalized an amendment to theambient air monitoring regulations on October 17, 2006. As part of this amendment, the EPAadded the following requirement for state, or where applicable local, monitoring agencies toconduct a network assessments once every five years [40 CFR 58.10(e)].“(e) The State, or where applicable local, agency shall perform and submit to the EPARegional Administrator an assessment of the air quality surveillance system every 5 years todetermine, at a minimum, if the network meets the monitoring objectives defined in appendix Dto this part, whether new sites are needed, whether existing sites are no longer needed and canbe terminated, and whether new technologies are appropriate for incorporation into the ambientair monitoring network. The network assessment must consider the ability of existing andproposed sites to support air quality characterization for areas with relatively high populationsof susceptible individuals (e.g., children with asthma), and, for any sites that are being proposedfor discontinuance, the effect on data users other than the agency itself, such as nearby Statesand Tribes or health effects studies. For PM2.5, the assessment also must identify neededchanges to population-oriented sites. The State, or where applicable local, agency must submit acopy of this 5-year assessment, along with a revised annual network plan, to the RegionalAdministrator. The first assessment is due July 1, 2010.”This requirement is an outcome of implementing the National Ambient Air MonitoringStrategy (NAAMS, the most recent version is dated December 2005, U.S. EnvironmentalProtection Agency, 2005). The purpose of the NAAMS is to optimize U.S. air monitoringnetworks to achieve, with limited resources, the best possible scientific value and protection ofpublic and environmental health and welfare.A network assessment includes (1) re-evaluation of the objectives and budget for airmonitoring, (2) evaluation of a network’s effectiveness and efficiency relative to its objectivesand costs, and (3) development of recommendations for network reconfigurations andimprovements. EPA expects that a multi-level network assessment will be conducted every fiveyears (U.S. Environmental Protection Agency, 2005). Initial network assessments for theNAAMS were led by EPA and its 10 regional offices in 2001 through 2004 (U.S. EnvironmentalProtection Agency, 2003b). This initial assessment, as well as peer-reviews of the NAAMS bysubcommittees of the EPA Clean Air Scientific Advisory Committee (Hopke, 2003),(Henderson,2005), produced the recommendation that guidance for regional-scale network assessments beestablished.The NAAMS (U.S. Environmental Protection Agency, 2005), (U.S. EnvironmentalProtection Agency, 2005), (Clean Air Scientific Advisory Committee and National Ambient AirMonitoring Strategy Subcommittee, 2003) and documentation of the initial national- andregional-scale network assessments provide a valuable context and a summary of the keytechnical issues for network assessment guidelines. This document builds on the lessons learned1-1

in the NAAMS and focuses on providing guidance on analytical techniques that can be used forregional-scale assessments.1.1 BACKGROUND AND KEY ISSUESAmbient air monitoring objectives have shifted over time—a situation which hasinduced air quality agencies to re-evaluate and reconfigure monitoring networks. A variety offactors contribute to these shifting monitoring objectives: Air quality has changed—for the better in most geographic areas—since the adoption ofthe federal Clean Air Act and National Ambient Air Quality Standards (NAAQS). Forexample, the problems of high ambient concentrations of lead and carbon monoxide havelargely been solved. Populations and behaviors have changed. For example, the U.S. population has (onaverage) grown, aged, and shifted toward urban and suburban areas over the past fourdecades. In addition, rates of vehicle ownership and annual miles driven have grown. New air quality objectives have been established, including rules to reduce air toxics, fineparticulate matter (PM2.5),1 and regional haze. The understanding of air quality issues and the capability to monitor air quality have bothimproved. Together, the enhanced understanding and capabilities can be used to designmore effective air monitoring networks.As a result of these changes, air monitoring networks may have unnecessary or redundantmonitors or ineffective and inefficient monitoring locations for some pollutants, while otherregions or pollutants suffer from a lack of monitors. Air monitoring agencies should, therefore,refocus monitoring resources on pollutants that are new or persistent challenges, such as PM2.5,air toxics, and ground-level ozone and precursors, and should deemphasize pollutants that aresteadily becoming less problematic and better understood, such as lead and carbon monoxide(CO). In addition, monitoring agencies need to adjust networks to protect today’s population andenvironment, while maintaining the ability to understand long-term historical air quality trends.Moreover, monitoring networks can take advantage of the benefits of new air monitoringtechnologies and improved scientific understanding of air quality issues. Existing monitoringnetworks should be designed to address multiple, interrelated air quality issues and to betteroperate in conjunction with other types of air quality assessments (e.g., photochemical modeling,emission inventory assessments). Reconfiguring air monitoring networks can enhance theirvalue to stakeholders, scientists, and the general public.1.2 OVERVIEW OF MONITORING NETWORK TECHNICAL ASSESSMENTSAnalytical techniques to assess the technical aspects of monitoring networks fit within theoverall framework of regional network assessments discussed in the most recent version of theNAAMS (U.S. Environmental Protection Agency, 2005). The NAAMS briefly describes the1Particulate matter of less than 2.5 microns aerodynamic diameter.1-2

stepwise procedure for network assessments shown in Table 1-1. This document focuses onSteps 3 and 4: statistical analyses and objective situational analyses.In some cases, network assessments can be handled simply by answering one or morestraightforward questions. In others, detailed analytical techniques, such as those discussed inSection 2.2 and Section 3, are necessary. A thorough technical assessment will help informdecisions about reconfiguring a network. These decisions might include eliminating redundantmonitors, reducing or expanding the monitoring season, moving monitors to better locations,switching a site to different technology (e.g., finer temporal resolution), adding monitors to thenetwork, or switching a site to a different pollutant. In practice, a combination of several typesof analyses might provide the most useful information. Network assessment can be performed atmany levels (national, regional, local); however, the next level down may need to reassess theanalyses to ensure the correct decision, given local conditions.Table 1-1. Descriptions and examples of steps involved in performing networkassessments.StepDescription1Prepare or update a regional description,discussing important features that should beconsidered for network design2Prepare or update a network history thatexplains the development of the airmonitoring network over time and themotivations for network alterations, such asshifting needs or resources.3Perform statistical analyses of availablemonitoring data. These analyses can be usedto identify potential redundancies or todetermine the adequacy of existingmonitoring sites.4Perform situational analyses, which may beobjective or subjective. These analysesconsider the network and individual sites inmore detail, taking into account research,policy, and resource needs.56Suggest changes to the monitoring networkon the basis of statistical and situationalanalyses and specifically targeted to theprioritized objectives and budget of the airmonitoring program.Acquire the input of state and local agenciesor stakeholders and revise recommendationsas appropriate1-3ExamplesTopography, climate, population,demographic trends, major emissionssources, and current air quality conditionsHistorical network specifications (e.g.,number and locations of monitors bypollutant and by year in graphical ortabular format); history of individualmonitoring sitesSite correlations, comparisons to theNAAQS, trend analysis, spatial analysis,and factor analysisRisk of future NAAQS exceedances,demographic shifts, requirements ofexisting state implementation plans (SIP)or maintenance plans, density orsparseness of existing networks, scientificresearch or public health needs, and othercircumstances (such as political factors)Reduction of number of sites for aselected pollutant, enhanced leveragingwith other networks, and addition of newmeasurements at sites to enhanceusefulness of data

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2. APPROACH TO MONITORING NETWORK TECHNICAL ASSESSMENTSThis section provides guidance to the user for identifying monitoring needs andintroduces network assessment analyses.2.1 IDENTIFY MONITORING NEEDSBefore beginning a network assessment, the purposes of the network must be reviewedand prioritized. Networks are likely to be used to meet a variety of purposes, such as monitoringcompliance with the NAAQS, public reporting of the Air Quality Index (AQI), assessment ofpopulation exposure to pollutants, assessment of pollutant transport, monitoring of specificemissions sources, monitoring of background conditions, evaluating models, and possibly others.These purposes may be prioritized as primary or secondary and individual monitors within anetwork may serve different purposes. Each analytical technique selected to support a networkassessment must be chosen in view of the purposes of the overall network and its individualmonitoring sites. In addition, the resources invested in each analysis should be proportional tothe priority of the purpo

A network assessment includes (1) re-evaluation of the objectives and budget for air monitoring, (2) evaluation of a network’s effectiveness and efficiency relative to its objectives and costs, and (3) development of recommendations for network reconfigurations and improvements. EPA expects that a multi-level network assessment will be .

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