2023 Air Quality Monitoring Look Ahead
Posted: January 26th, 2023Authors: Dustin S.
In our 2022 Air Quality Monitoring Look Ahead, we looked at community organized low-cost monitoring networks, the continued use of Federal Reference Method (FRM) and Federal Equivalent Method (FEM) air quality monitoring, and funding for community partnerships for implementation of monitoring networks to reduce air pollution in communities that are disproportionately impacted by air pollution. Community-led monitoring networks will continue to expand in 2023 as there is an increased reliance on low-cost monitoring stations. The Inflation Reduction Act has earmarked funds to support the continued effort of advancing environmental justice and put the United States in line to achieve the Biden Administration’s climate goals. The funding includes the installation of more FRM and FEM equipment that could be installed in environmental justice areas or co-located with community-led monitoring networks as a reference point to aide in the validation of data.
In addition to additional funding for more ambient monitoring sites, changes may be in place for some FRM and FEM monitoring guidance. As discussed in Dan Dix’s PM2.5 Annual National Ambient Air Quality Standard (NAAQS) Proposed to be Lowered article, U.S. EPA is proposing to lower the standard from the current 12 micrograms per meter cubed (µg/m3) to a level between 9 µg/m3 and 10 µg/m3. Given the importance of the PM2.5 NAAQS updates, U.S. EPA has noted that they are proposing changes to PM2.5 monitoring requirements within 40 CFR Part 50 – National Primary and Secondary Ambient Air Quality Standards Appendix L – Reference Method for the Determination of Fine Particulate Matter as PM2.5 in the Atmosphere which outlines how to calculate the design value (background value) and data availability parameters. U.S. EPA indicated that these changes will improve the quality of data used and help in better characterizing air quality in communities that are at increased risk of PM2.5 exposure and health risk. In addition, U.S. EPA is proposing to add monitoring siting criteria to include specific requirements for monitors to be located in at-risk communities. While U.S. EPA is not proposing requirements to add new PM2.5 monitors they indicated there may be the need to add up to 10 additional PM2.5 ambient monitors to the current total of 1,000. The details of these proposals haven’t been announced at the time of this article’s posting, but the changes to monitoring requirements and data availability parameters may be announced with the finalization of a PM2.5 NAAQS threshold.
Fenceline monitoring requirements will continue to roll out in 2023. The U.S. EPA has delayed signing a proposed rule for the hazardous organic NESHAP (HON) from December 16, 2022 to March 31, 2023. It is still expected that the proposed revisions to HON will include Method 325A/B fenceline monitoring requirements. The U.S. EPA issued Clean Air Act (CAA) Information Collection Requests (ICRs) in 2022 for the Chemical Manufacturing and Coke Oven industries, both of which utilized U.S. EPA Methods 325A (Sampler Deployment and VOC Sample Collection) and 325B (Sampler Preparation and Laboratory Analysis) among other sample collection methodologies. ALL4 assisted clients in sample collection and reporting for both ICRs. Should your industry be issued an ICR, consent decree, or new rule requirement with monitoring components, it is important to be in action quickly regarding the planning and development of monitoring plans. The deadlines for meeting the monitoring timelines set by U.S. EPA for both the Chemical Manufacturing and Coke Oven ICRs did not offer much flexibility in scheduling and planning. Local community monitoring may also start showing up around your facilities. During the collection of monitoring data for one ICR effort, local funding was obtained to conduct Method 325A/B sampling in the community near the Facility where ALL4 was conducting monitoring.
There are many reasons your facility might want to consider being proactive around monitoring in 2023:
- addressing community or agency interest in your fenceline/fugitive emissions,
- comparing modeled concentrations with actual measured concentrations,
- obtaining more representative meteorological data for use in air dispersion models,
- evaluating the impacts of lower ambient standards,
- evaluating monitoring technologies in anticipation of upcoming regulatory requirements,
Note that ambient monitoring systems installed as a result of a rule or a consent decree may have a requirement for the collected data to be published (similar to the refinery fenceline monitoring data on U.S. EPA’s ECHO website).
ALL4 can help you with any of these items including deployment and operation of monitoring efforts. We can also help review and validate community led monitoring data as it is generally publicly accessible data. Please contact Dustin Snare or your ALL4 project manager for more information.