Analyzing Current Requirements and Technologies in Air Quality Monitoring

Transcription

1 Air & Waste Management Association THE MAGAZINE FOR ENVIRONMENTAL MANAGERS FEBRUARY 2009 Analyzing Current Requirements and Technologies in Air Quality Monitoring INSIDE: Greenhouse Gas Regulation under the Clean Air Act, p. 30

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3 A&WMA'S 102ND ANNUAL CONFERENCE & EXHIBITION JUNE 16-19, 2009 DETROIT, MICHIGAN CONFERENCE SPONSOR In these uncertain economic times, furthering your professional education, presenting and publishing your work, and networking with colleagues in the field have never been more critical. Join us in Detroit for the Air & Waste Management Association s 102nd Annual Conference & Exhibition (ACE) and discover the latest in environmental innovation, reestablish your professional relationships, and stay ahead of the game all while having some fun at ACE 2009! One of the most exciting parts of every Annual Conference & Exhibition is the bustling exhibit hall, filled with hundreds of exhibitors displaying the newest products and services. From instrumentation and testing services to control equipment and leading industry publications, our exhibitors have the environmental industry covered. Interested in exhibiting? Visit to find out more about this year s Exhibition. Mark your calendar now and stay tuned for additional details! Visit for more information.

4 Air & Waste Management Association THE MAGAZINE FOR ENVIRONMENTAL MANAGERS NEXT MONTH: Can the environmental industry survive the global economic downturn? Regulating Greenhouse Gases Under the Clean Air Act: An Industry Perspective by John Kinsman and Bill Fang, Edison Electric Institute A complicated web of litigation, regulation, and legislation is moving forward that could lead to the regulation of greenhouse gas (GHG) emissions under the Clean Air Act. Key decisions regarding GHG control could be made in 2009 by the new administration, the U.S. Congress, the courts, and states. This article takes a look at the hotly contested issue from the perspective of the power generation industry. Page 30 Features Current Issues in Air Quality Monitoring New technology and new requirements are changing U.S. air quality monitoring. In this month s EM, two feature articles discuss measurement of fine particles, a third covers the current status of coarse particle monitoring, and a fourth article introduces the work underway to meet the U.S. Environmental Protection Agency s (EPA) multipollutant monitoring requirements. Page 5 Finally, a Continuous FEM for PM2.5 by David Gobeli, Michael Meyer, Herbert Schloesser, and Thomas Pottberg, Met One Instruments Inc. Page 6 Is it Time to Upgrade the PM2.5 Federal Reference Method? by Dirk Felton, New York State Department of Environmental Conservation Page 10 PM Monitoring in Support of EPA s PM NAAQS by Joann Rice and Beth Hassett-Sipple, U.S. Environmental Protection Agency Page 16 Planning for NCore Monitoring by Jim McGaughey, Joette Steger, Mark Yirka, and Carlton Blakley, North Carolina Division of Air Quality Page 24 Cover photos: Top photo: Howard University at Beltsville, MD, MDE NCORE station, Thermo PM 2.5 sequential sampler. Field Tech: Chris Smith, Maryland Department of the Environment. Photographer: Dave Preece Middle left photo: a Tekran mercury analyzer and controller. Bottom photo: Tekran mercury monitor. Middle left photo: Tekran 2537B mercury analyzer and methane and total hydrocarbon analyzer. Photographer: Dirk Felton Middle right and bottom photos: Tekran 1130 and 1135 reactive gas and particulate mercury collector, PM-2.5 FRM, and a wet deposition mercury collector. Photographer: Dirk Felton Printed on Recycled Paper COLUMNS Inside the Industry How to Recession-Proof Your Business by Anthony Buonicore and Dianne Crocker IT Insight Balancing Business Needs and Information Security by Jill Gilbert ASSOCIATION NEWS Annual Conference Preview Students and Young Professionals: ACE Is the Place to be in June! Conference Highlights: Better Air Quality for Asian Cities by Miriam Lev-On and David Calkins In Memoriam Doug Wolf The Member Minute Mike Durham DEPARTMENTS Message from the President Letters EPA Research Highlights Washington Report News Focus IPEP Quarterly Advertisers Index Professional Development Programs JA&WMA Table of Contents Calendar of Events EM, a publication of the Air & Waste Management Association (ISSN ), is published monthly with editorial and executive offices at One Gateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA Air & Waste Management Association. All rights reserved. Materials may not be reproduced, redistributed, or translated in any form without prior written permission of the Editor. Periodicals postage paid at Pittsburgh and at an additional mailing office. Postmaster: Send address changes to EM, Air & Waste Management Association, One Gateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA GST registration number: Subscription rates are $265/year for nonprofit libraries and nonprofit institutions and $405/year for all other institutions. Additional postage charges may apply. Please contact A&WMA Member Services for current rates ( ). Send change of address with recent address label (6 weeks advance notice) and claims for missing issues to the Membership Department. Claims for missing issues can be honored only up to three months for domestic addresses, six months for foreign addresses. Duplicate copies will not be sent to replace ones undelivered through failure of the member/subscriber to notify A&WMA of change of address. A&WMA assumes no responsibility for statements and opinions advanced by contributors to this publication. Views expressed in editorials are those of the author and do not necessarily represent an official position of the Association. 2 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

5 em message from the president Monitoring and Measuring Where Our Profession Begins by Rick Sprott em awma.org ADVERTISING Malissa Goodman I ll admit a bias right up front: I m an analytical chemist. Hence, I tend to get a bit excited about instrumental analysis generally and air monitoring in particular! The theme of this month s EM is air monitoring technology. What could be more appropriate, as we see the U.S. Environmental Protection Agency (EPA) faced with a massive undertaking in determining how to monitor and measure greenhouse gas emissions? Add to that the agency s call in recent months for increased monitoring of air quality near schools and the expectation that the Obama administration will be pretty focused on the science of things. Monitoring is often the starting point for just about everything we do at least when it comes to figuring out solutions. And that is what our Association is all about. Even in these bleak economic times, I hope for a renaissance in monitoring and measuring. There needs to be a morsel left for monitoring and measurement investment in spite of the seemingly endless bailout line in Washington. Fine particulate matter (PM2.5) emission measuring is woefully short of funds. I vividly recall grilling Steve Page, the boss of EPA s Office of Air Quality Planning and Standards, at an Environmental Council of the States meeting in 2007 about when EPA was going to develop adequate emission factors for PM2.5 data desperately needed by states and businesses for implementation plans and permitting. He responded like a good soldier, but I knew the agency was fighting some difficult budget issues even then. The agency needs to find the means to invest now in monitoring and measuring across the board. That investment could then be leveraged with resources from states and the private sector. Industry has seen the writing on the wall for some time, in regard to carbon regulation. In the United States, Canada, and Mexico, states, provinces, and tribes have advanced carbon emission protocols ahead of federal action through efforts like The Climate Registry. And California Senator Barbara Boxer s requirement for EPA to require greenhouse gas reporting by June 2009 has definitely created some badly needed certainty. But reporting without a better monitoring and measuring infrastructure could lead us in the wrong directions. A&WMA s members have been at the forefront in this field for decades, and we will use that strength to work with government (at all levels), industry, consultants, and the public to advance technical solutions. We must also collaborate on reporting protocols that are credible, yet straight forward. Emission monitoring and high-quality estimation techniques are the key to providing a credible carbon currency. A&WMA has conferences in March and August related to greenhouse gas emissions and there are several other regional and affiliated meetings during the year. Check out all the currently scheduled events listed in the calendar on page 51 and online at Don t forget that monitoring and measuring (M&Ms!) is where it s at. Getting smart now will provide an edge for the future, even in today s economy. EDITORIAL Andy Knopes, CAE Editor Lisa Bucher Managing Editor EDITORIAL ADVISORY COMMITTEE A. Gwen Eklund, Chair TRC Ann McIver, QEP, Vice Chair Citizens Energy Group Ferdinand B. Alido Navistar Inc. John D. Bachmann Vision Air Consulting Jane C. Barton Patterson Consultants Prakash Doraiswamy, Ph.D. State University of New York at Albany Jennifer B. Dunn, Ph.D. URS Corp. Steven P. Frysinger, Ph.D. James Madison University John D. Kinsman Edison Electric Institute Ashok Kumar University of Toledo Miriam Lev-On, Ph.D. The LEVON Group Julian A Levy, Jr. Exponent Inc. Mingming Lu University of Cincinnati Charles E. McDade University of California at Davis Paul J. Miller Northeast States for Coordinated Air Use Management Dan L. Mueller, P.E. CDM Inc. Chris Pepper Jackson Walker S.T. Rao U.S. Environmental Protection Agency Daniel R. Weiss Duke Energy Indiana Susan S.G. Wierman Mid-Atlantic Regional Air Management Association PUBLICATIONS COMMITTEE Judith C. Chow, Chair Desert Research Institute A&WMA HEADQUARTERS Adrianne Carolla, CAE Executive Director Air & Waste Management Association One Gateway Center, 3rd Floor 420 Fort Duquesne Blvd. Pittsburgh, PA ; (fax) em@awma.org awma.org Copyright 2009 Air & Waste Management Association february 2009 em 3

6 em letters Dear EM, I was greatly disappointed in the articles on perchlorate risk and remediation (EM December 2008, pp ). The articles did not attempt to describe or evaluate any of the risk evaluations of perchlorate in drinking water. More information on perchlorate risk and the U.S. Environmental Protection Agency s (EPA) evaluations can be obtained from Wikipedia than from A&WMA s publication that purports to be the magazine for environmental managers. You did your readers a disservice when you did not address the circumstances under which remediation would be warranted. Robert F. Boland, P.E. Principal, Boland Environmental Management, LLC From the December Issue Coordinator: I appreciate the comments by Mr. Boland. I agree that more information on risk evaluations related to drinking water is available on the Internet. It appears that Mr. Boland expected a discussion focused on the various toxicological studies of perchlorate, and the state and federal regulatory agency risk evaluations for perchlorate derived from those studies. The purpose of the California Perchlorate Working Group (CA PWG) was to identify perchlorate releases that may have impacted drinking water wells. The perchlorate prioritization protocol developed by CA PWG demonstrates a practical, interagency response for rapidly assessing potential real-world exposures to perchlorate in drinking water. Although risk issues were briefly discussed in the article by Racca et al. (p. 27), CA PWG did not attempt to address risk assessment issues, toxicological evaluations, or remediation technologies. Toxicological evaluations and remediation technologies are subjects being addressed by others and the reader is advised to refer to various and plentiful literature studies on the two subjects. These documents include the Interstate Technology & Regulatory Council (ITRC) guidance found in the article by Racca et al. (p. 31) and the U.S. Department of Defense s Strategic Environmental Research and Development Program and Environmental Security Technology Certification Program (SERDP/ESTCP) initiative described in the article by Unger and Leeson (p. 22). Readers interested in the most recent discussions regarding the EPA reference dose for perchlorate are advised to read and/or comment on the Office of Inspector General s Scientific Analysis of Perchlorate, dated December This document is available online at recent.htm. The attempt during the preparation of the December 2008 issue was to focus on the aspects of perchlorate that are not readily available in the literature. Ashok Kumar Professor and Chairman, The University of Toledo Portable TDLAS Ambient Air The new Spectra-1 open path gas monitor series offers the performance you expect from a tuneable diode laser spectrometer. Detectable gases: CH4, CO2, NH3, HF, HCN, C2H2, C2H4, C2H6, others. Portable or Fixed Monitoring RS-232 Data Output USB Stick Data Downloading Greenhouse Gas Monitoring Onboard Data Storage 5 to +500 Meter Path Lengths $19, (Single Qty. Price) PKL Technologies Inc. (780) em february 2009 Copyright 2009 Air & Waste Management Association awma.org

7 em feature Current Issues in Air Quality Monitoring New technology and new requirements are changing U.S. air quality monitoring. In this issue of EM, two feature articles discuss the measurement of fine particles, a third covers the current status of coarse particle monitoring, and the final article introduces the work underway to meet the U.S. Environmental Protection Agency s (EPA) multipollutant monitoring ( NCore ) requirements. Fine Particle Monitoring To assess compliance with fine particle (PM2.5) air quality standards, EPA requires states to use filterbased Federal Reference Method (FRM) samplers. As documented by many studies (e.g., Chow et al. 1 and references therein), the FRM may lose semivolatile mass. Recent advances in monitoring enable real-time measurement of total PM2.5 mass, including the semivolatile component. 1-3 One such continuous method the Beta-Attenuation Monitor (BAM) was recently approved by EPA as a Federal Equivalent Method (FEM), while another method (the Filter Dynamics Measurement System) is pending designation. Gobeli et al. (page 6) summarize the federal equivalency designation of the BAM. Next, Felton (page 10) delves into the designation process, examining the differences between the FRM use in the designation process and as operated by state/local agencies, and questioning the continued use of the FRM. Continuous instruments typically measure higher concentrations than the FRM and allow almost immediate access to information on air quality. This difference could be important to sensitive individuals in areas subject to high particle concentrations. Coarse Particle Monitoring and New Federal Requirements for Multipollutant Monitoring During the 2006 review of the National Ambient Air Quality Standard (NAAQS), EPA considered, but did not adopt, a standard for coarse particles (PM10-2.5, particulate matter between 2.5 and 10 µm in aerodynamic diameter). EPA has now developed a new PM FRM, and Rice et al. (page 16) provide an update on coarse particle monitoring and ongoing research. EPA s NCore requirements will come into effect over the next few years, requiring significant investments by state/local agencies in advanced monitoring equipment. NCore sites will give researchers and the public a wide range of air quality data, facilitating multipollutant air quality management. McGaughey et al. (page 24) provide us with a first look at one state s efforts to meet the challenges of implementing these requirements. Final Thoughts We thank the authors for their contributions to this issue. EM hopes to cover monitoring issues each year and provide a forum for discussion of ongoing air quality monitoring issues. State and local agencies will be under a tight timeline over the next two years satisfying monitoring requirements for NCore and the new NAAQs for lead. For example, the lead NAAQS will require significant new monitoring to determine compliance. Half the new monitors are to be installed by January 2010 and the remainder in the following year. EM welcomes the submission of letters or articles on these and other air quality monitoring issues. Susan S.G. Wierman Executive Director Mid-Atlantic Regional Air Management Association swierman@marama.org Prakash Doraiswamy, Ph.D. Research Scientist Atmospheric Sciences Research Center State University of New York, Albany pxdorais@gw.dec.state.ny.us References 1. Chow, J.C.; Doraiswamy, P.; Watson, J.G.; Chen, L.-W.A.; Ho, S.S.H.; Sodeman, D.A. Advances in Integrated and Continuous Measurements for Particle Mass and Chemical Composition; J. Air & Waste Manage. Assoc. 2008, 58, Solomon, P.A.; Sioutas, C. Continuous and Semicontinuous Monitoring Techniques for Particulate Matter Mass and Chemical Components: A Synthesis of Findings from EPA s Particulate Matter Supersites Program and Related Studies; J. Air & Waste Manage. Assoc. 2008, 58, Solomon, P.A.; Sioutas, C. Continuous and Semi-Continuous Methods for PM Mass and Composition; EM April 2006, awma.org Copyright 2009 Air & Waste Management Association february 2009 em 5

8 em feature by David Gobeli, Michael B. Meyer, Herbert Schloesser, and Thomas Pottberg David Gobeli, Ph.D., is the product director for the BAM monitor, Michael B. Meyer is executive director, Herbert Schloesser, Ph.D., is vice president of the Particulate Air Business Division, and Thomas Pottberg is president and a principle, all with Met One Instruments Inc., Grants Pass, OR. dgobeli@metone.com. FINALLY, a Continuous FEM for PM2.5 The U.S. Environmental Protection Agency (EPA) first promulgated fine particulate matter (PM) as a criteria pollutant as part of the National Ambient Air Quality Standards (NAAQS) revisions in The indicator chosen for fine PM was PM 2.5, or the total mass concentration of PM less than or equal to 2.5 micrometers (µm) aerodynamic equivalent diameter. The final PM 2.5 rule established a strict definition of the PM 2.5 Federal Reference Method (FRM) sampler. 6 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

9 This gravimetric, low-volume (1m 3 /hr), filter-based (46.2- mm diameter polytetrafluoroethylene [PTFE] filter) FRM sampler was often referred to as the gold standard and is a hybrid based on a combination of design and performance specifications. Experience, however, would later indicate that the FRM sampler and associated filter handling and laboratory processing would not define a gold standard, but simply a method by definition for the determining PM2.5 by gravimetry. An extensive national PM2.5 air monitoring network was established between 1998 and The concept of the Class III Federal Equivalent Method (FEM) was also introduced as part of the 1997 rules. This FEM category opened the door for continuous and semicontinuous monitors to gain EPA method designation for use in the national PM2.5 air monitoring network. At the time of introduction of the Class III FEM concept, EPA opted not to provide specific test criteria, thus effectively slamming shut the door. It was not until 2006 that Class III FEM test criteria would finally be established, some nine years after the PM2.5 NAAQS rule was put forth. These test criteria were issued as part of EPA s September 2006 action to amend its national air quality monitoring requirements. 2 Because no PM2.5 FEM monitors existed for many years after PM2.5 regulations were introduced in 1997, those involved with regulatory compliance for PM had to rely, in large part, on manual PM2.5 FRM samplers. FRM samplers cannot provide real-time or near-real-time PM2.5 data. In addition, PM2.5 FRM samplers require far more human intervention than a PM2.5 FEM monitor would. Handling, storing, weighing, conditioning, and transporting of filters presents significant cost, quality, and logistical challenges for those entities involved in the design, funding, and quality control of PM2.5 monitoring programs. Since EPA regulations are often the basis for regulations outside the United States, the development of a PM2.5 monitor capable of obtaining FEM designation is likely to generate global interest. Clear and concise test procedures now exist that allow the manufacturers of continuous PM2.5 monitors to apply for and receive FEM designation. A beta attenuation monitor (BAM-1020 by Met One Instruments Inc.) has become the first to receive this regulatory approval. Presumably, instruments with such designation could be used instead of PM2.5 FRM manual, gravimetric samplers for enforcement and compliance purposes. Class III FEM Requirements The full details of the PM2.5 Class III FEM test requirements are published in the Code of Federal Regulations (CFR). 3 The test procedure requires that three of the candidate FEM method instruments be collocated with three single-channel FRM samplers to assess comparability. Five test campaigns at four test locations are mandatory. These locations are specified by EPA so that the tests provide challenging and diverse conditions in terms of aerosol character and climate, and include winter test sites in California, the Midwest, and higher elevation Western regions. Also required are summer test sites in the same California location and another in a Northeastern or Mid-Atlantic city. Each test campaign requires a minimum of 23 acceptable data sets with 24-hr PM2.5 concentrations in the range of micrograms per cubic meter (µg/m 3 ). Equivalency of the candidate monitor relative to the FRM is determined through strict additive and multiplicative bias requirements that statistically define an acceptance polygon. After the field tests are completed, a comprehensive FEM designation application is submitted by the applicant to EPA. The required application contents are described in detail in the aforementioned CFR. Once EPA receives the application package, it has 120 days to respond. If the response includes a request for additional information or testing the counter is reset to an additional 120 days, pending receipt of the new documents. It should be noted that although the FEM designation is for daily PM2.5 measurements, the application is required to contain hourly information from each candidate monitor in order to assess short-term precision and character of the method. Keep in mind that EPA only has a daily and annual NAAQS for PM2.5. There are a couple of subtle yet important requirements of the Class III FEM testing criteria. One is that a single channel (as opposed to a sequential) FRM sampler must be used during each field test campaign. In addition, EPA mandates that FRM filter samples be retrieved promptly and analyzed. FRM filters used in the regulatory air monitoring stations can be left in the sampler some hours after the end of the sample collection and before retrieval. Also, the filter mass measurement can occur up to 30 days after retrieval. These differences may introduce additional bias of the regulatory air monitoring stations FRM measurement relative to an approved FEM. The development of a PM 2.5 monitor capable of obtaining FEM designation is likely to generate global interest. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 7

10 Figure 1. Outside photo of a representative test site (FRMs shown on left, BAM-1020 inlets on right). Figure 2. Inside photo of a BAM-1020 at a representative test site. The FEM Candidate Background Beta attenuation is one method used routinely to monitor ambient PM continuously. The method was first developed more than 60 years ago as a process control instrument in the manufacturing of paper. Approximately 40 years ago, it was adapted for use in ambient particulate monitoring. 4 Indeed, a number of beta attenuation mass (BAM) monitors have received EPA PM10 FEM designation. The principle of operation of BAM monitors has been reported in detail elsewhere. 4-7 In general, high-energy electrons emitted through radioactive decay are known as beta rays. When matter is placed between a radioactive source and a device designed to detect beta rays, the beta rays are attenuated. The magnitude of the reduction in detected beta particles is a function of the mass of the absorbing matter between the beta source and the detector. For a BAM monitor, the absorbing mass is the collected PM. With the PM mass and the sample volume measured, the resulting PM mass concentration is determined. BAM-1020 Met One Instruments BAM-1020 monitor was put through EPA PM2.5 FEM test campaigns during winter/ summer from late 2006 into The BAM-1020 monitor uses a 14 C beta ray source that has a half-life of 5,730 years, thus the beta output of the unit remains extremely stable over the useable life of the monitor. The monitor was configured with an FRM-type PM10 size selective inlet, followed by a PM2.5 very sharp cut cyclone (VSCC) size fractionator. An integrated smart heater system maintained the sample filter relative humidity at or below 35% to be consistent with the FRM filter conditioning requirements. The sample filter spot is advanced once per hour. This helps eliminate the loss of volatile particle mass by minimizing undesirable artifact formation that may occur with a longer filter residence time. Test Procedure Siting The selected test winter sites were California (Bakersfield), Utah (Logan), and Michigan (Allen Park). The Bakersfield and Allen Park sites are used by the California Air Resources Board (CARB) and the Michigan State Department of Environmental Protection. The Logan site was at a local government authority and in close proximity to monitoring sites maintained and operated by the State of Utah. The summer test sites were California (Bakersfield) and Connecticut (New Haven, which is operated by the Connecticut Department of Environmental Protection). All sites were pre-approved by EPA. Photos of representative test site locations are shown in Figures 1 and 2. FRM Samplers Each of the four test sites used triplicate PM2.5 FRM samplers (PQ-200 by BGI Instruments Inc.) equipped with PM2.5 VSCC inlets, and each sampler was set up and calibrated according to manufacturers instructions. Samplers were sited such that their inlets were between 1m and 1.5m apart, in accordance with the CFR. All FRM samplers were deployed on the roofs of the shelters that contained the BAM-1020 candidate monitors. 8 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

11 Candidate Monitors At each of the three test sites, triplicate BAM-1020 monitors were deployed in temperature-controlled shelters and set up in accordance with the procedures set forth in the manufacturer s operating manual. Inlet tubes extended through the roofs of the shelters to permit sampling at the same elevation as the FRM samplers. Shelter temperatures were maintained at approximately 20 C for the duration of the test. Data Collection The FRM samplers and the BAM-1020 monitors were run daily. Start times varied from site to site. 23 valid hourly PM2.5 averages were used to generate each daily average for the BAM-1020 monitor (EPA test criteria allow hr for a valid daily average). FRM samplers were also run for 23 hours to permit filter replacement and servicing on a daily basis during the one-hour down time. For the most part, data collection was uninterrupted. Occasional days were missed due to power, site, or instrument issues. Data Validation FRM data were validated in accordance with the procedures set forth in the operation manual, weighing laboratory, and EPA quality assurance documents. Daily data sets consisted of two or three valid FRM results and two or three valid BAM daily averages, as specified in the CFR. To be considered valid data, FRM daily means of the triplicate samplers must have exceeded 3 µg/m 3. In addition, FRM results must pass an outlier test. No such outlier test was allowed for the BAM-1020 results. BAM-1020 data were qualified by verifying that no alarm flags indicating instrument malfunction occurred during measurement. Test Results A minimum of 23 valid, daily data sets were required for each test campaign (46 for the combined winter/summer location). Linear regressions were performed on each completed data set. The results of the linear regressions are shown in Table 1. In Table 1, n is the number of valid data sets collected at the test site, m is the slope of a linear regression of the BAM-1020 versus the FRM, b is the y-intercept in µg/m 3, and r 2 is the correlation coefficient. The data represent the mean of triplicate BAM-1020 monitors and the mean of the triplicate FRMs for each valid day. The multiplicative and additive biases observed at all test sites were within EPA acceptance polygon (see Figure 3). In addition, EPA requirements for precision were met at each of the test sites. Conclusion The BAM-1020 monitor became the first automated, continuous method to earn Class III FEM designation (EQPM ) on March 12, PM2.5 FEM monitors such as the BAM-1020 offer the ability to provide high time-resolved continuous data that more closely represent the PM2.5 to which humans are exposed. This is due to less time for interaction between the sample and surrounding environment and PM2.5 measurement closer to the time of human exposure. It is interesting to note that the gas-phase criteria pollutants are for the most part measured using only automated continuous reference or equivalent methods. The possibility now exists to augment or replace the PM2.5 FRM with the new automated continuous PM2.5 FEMs. em References 1. National Ambient Air Quality Standards for Particulate Matter. Final Rule; Fed. Regist. 1997, 62, National Ambient Air Quality Standards for Particulate Matter. Final Rule; Fed. Regist. 2006, 71, Ambient Air Monitoring Reference and Equivalent Methods. 40 CFR Part Williams, K.; Fairchild, C.; Jaklevic, J. Dynamic Mass Measurement Techniques. In Aerosol Measurement. Principles, Techniques, and Applications; Willeke, K., Baron, P., Eds.; Van Nostrand Reinhold: New York, 1993; pp Gleason, G.I.; Taylor, J.D.; Tabern, P.L. Absolute beta counting at defined geometries; Nucleonics 1951, 8, Lilienfeld, P. Design and operation of dust measuring instrumentation based on the beta-radiation method; Staub- Reinhalt Luft 1975, 35, Macias, E.S.; Husar, R.B. Highresolution online aerosol mass measurement by the beta attenuation technique. In Proc. 2nd Internat. Conf. on Nucl. Methods in Environ. Research; Vogt, J.R.; Meyer, W., Eds.; CONF , 1970; pp Table 1. Linear regression results. Site n m b r 2 Bakersfield, CA Logan, UT Allen Park, MI New Haven, CT Intercept, ug/m 3 Data Set Slope and Intercept, and Limits Slope Figure 3. EPA PM 2.5 acceptance polygon. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 9

12 em feature Is It Time to Upgrade the PM2.5 Federal Reference Method? 10 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

13 The fine particulate matter (PM 2.5 ) Federal Reference Method (FRM) has in many respects been a great success. When the method was implemented, there was some doubt that the state and local monitoring agencies that routinely provide air quality data would be able to manage a program, which often distinguishes one location from another by just a few µg/m 3. As it turns out, data from the FRM program are consistent, and have been successfully used to determine nonattainment boundaries, in studies of health effects and in the assessment of source contribution. So, is there a need to upgrade the PM2.5 FRM? The FRM method is a gravimetric, filter-based method. The answer, in part, may depend on the needs of the specific monitoring agency. The FRM program has high operational costs associated with the necessary field service and laboratory weighing, and a long delay between ambient measurements and when data are available. Newer automated instruments have a high initial cost, but they have the advantage of much lower operational costs and can provide data in near-real-time. Automated instruments designated as Federal Equivalent Methods (FEMs) can replace the instruments used for compliance monitoring and the instruments used to provide hourly data. Agencies use hourly data for public health messaging, source attribution studies, and PM2.5 forecasting. The use of FEMs can offer significant cost savings during these fiscally tight times. It is likely that FRMs will continue to have a place in monitoring networks where filter samples are necessary for component chemical analysis. Is There a Bias between the FRM and FEMs? One of the main problems with the current PM2.5 FRM is the lack of a physical standard to determine the accuracy of the measurement. Actual atmospheric PM2.5 is a combination of solids and liquids ranging from relatively nonvolatile species, such as ammonium sulfate, elemental carbon, and metallic compounds, to much more volatile components, such as organic carbon, water associated with hygroscopic aerosol species, and ammonium nitrate. The filter-based FRM measurement does not capture all of the volatile components of PM2.5. Some of this mass is lost from the filter due to evaporation during sampling, after sampling, and during the post-weighing process. In side-by-side comparisons, the FRM is sometimes biased high, but in the majority of cases, it is biased low in comparison to other measurement technologies. 1 The new continuous measurement technologies have an advantage over the FRM because they provide near-real-time hourly concentrations of PM2.5. This significantly reduces the opportunity for adsorption, or more likely, evaporation from the collection media before a measurement is made. The bias between the FRM and the newer continuous measurement technologies is difficult to characterize. 2 This is apparent in the shortcomings of the continuous data adjustment schemes that are designed to adjust the data from continuous instruments to more closely match the FRM data. Data adjustments are often attempted out of necessity because the FRM data are not usually available for days or weeks after sampling is completed. Most of these data adjustment techniques use previously collected data to determine the relationship between the measurements at similar locations and in similar meteorological conditions to adjust the continuous data in near-real-time. Invariably, these schemes fail because they cannot adequately predict the amount of mass lost from the FRM filter prior to final weighing. The amount of mass lost from the sampling filter is dependant on the amount of volatile PM components in the atmosphere during the sampling period, as well as the difference between the ambient conditions during the sampling period versus the conditions in the laboratory during final filter weighing. This means that the bias between the FRM and the continuous instruments tends to be greatest in areas with significant sources of local emissions in the summer months. The local emissions tend to provide a higher proportion of volatile PM2.5 and the warmer summer temperatures create favorable conditions for evaporation from the FRM s sampling filter during and after the sampling period. This combination makes the bias very significant in large urban areas in the warmer months when the PM2.5 concentrations tend to be elevated relative to other seasons. This bias has been discussed in many research papers, but the issue was not recognized as a problem in the regulatory framework until earlier this year when the U.S. Environmental Protection Agency (EPA) approved a Class III PM2.5 Federal Equivalent Method (FEM) instrument. It is a beta attenuation monitor (BAM), known as the BAM-1020 manufactured by Met One Instruments Inc. (Grants Pass, OR). Currently, the application for another by Dirk Felton Henry (Dirk) Felton is a Research Scientist III with the New York State Department of Environmental Conservation s Bureau of Air Quality Surveillance, Albany, NY. hdfelton@gw.dec.state.ny.us. Disclaimer: The views expressed in this article are those of the author and do not reflect the views and or policies of the State of New York. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 11

14 The use of FEMs can offer significant cost savings during these fiscally tight times. Class III FEM, a filter dynamic tapered element oscillating microbalance, known as the 1405 DF TEOM manufactured by Thermo Fisher Scientific (Franklin, MA), is pending at EPA and could be approved later this year. Problems with the FEM Approval Process The PM2.5 FRM is a design-based method. The attributes of the sampler, including every part from the inlet through to the bottom of the filter holder, is precisely prescribed in the Code of Federal Regulations (CFR). 3 This method of design philosophy has allowed multiple vendors to build FRM instruments that are reasonably consistent with one another for use at monitoring locations across the country and in all weather conditions. The design method philosophy cannot be carried over to continuous instrumentation because each of the vendors submitting applications uses a different measurement technique. The FEM method approval process is based, by necessity, on performance, rather than design. This means that a candidate FEM will only be approved if it can reasonably emulate the data from the filter-based FRM at a representative number of locations across the country. This would normally be an adequate technique to determine equivalency, however, for PM2.5, the continuous instruments are being compared to a reference method that is not itself compared to a physical standard and, in fact, only captures a varying percentage of the volatile components of the ambient PM2.5 mass. The PM2.5 equivalent method approval process is contained in the aforementioned CFR and is very similar to the process used for PM10 FEMs. The candidate instrument vendors must operate three filter-based FRM samplers and three candidate samplers at four locations for a minimum of 23 sample days per location. The locations are generally specified in the CFR and include areas that are intended to cover the varying mix of PM2.5 components found across the country, including cities in the West, Midwest, and Northeast. The fourth location is Los Angeles, or California s Central Valley, because it has relatively high concentrations of PM2.5, nitrates, and organic carbon. This site is the only one that includes both a summer and winter sampling campaign. The resulting data from these field campaigns are statistically compared to EPA s test specifications and a determination is made as to whether or not the candidate method is equivalent. The equivalency determination process seems straightforward enough, but there were a few details left out of the test protocols that have thrown the results of the process into jeopardy. The test specifications did not require that the vendors operate their comparison FRM samplers with a protocol identical to that used by state and local agencies. State and local agencies operate FRM samplers from midnight to midnight and typically leave the filter in the sampler for two to six days after the sampling period. The filters are subsequently removed, refrigerated, and sent to the lab for weighing under controlled temperature and relative humidity. The vendors were not allowed to use sequential samplers, so they operated their single-event, filter-based FRMs on a schedule more convenient for daily collection. They chose an hour each morning for filter exchange and immediately placed the filters in a chilled cooler for shipment to the lab. This was permitted under the test specifications, but eliminated the holding time that filters generally spend in samplers. This decreased the loss of volatile PM2.5 mass. Figure 1 shows the concentrations determined from the filter samplers collected by the candidate sampler vendors and the samples collected by the State of Connecticut Department of Environmental Protection (CTDEP) and the New York State Department of Environmental Conservation (NYSDEC) at the same locations. The sample collection periods differ by 9 or 10 hours because of the difference in the collection interval, but because these samples are collected every day, they should both average the same concentration over the entire campaign and have nearly the same high and low concentrations during episodes. As it turns out, the vendor FRMs collect approximately 8% more mass than the regulatory agency FRMs for the same period. More significantly, the bias between the vendor FRM concentrations and the regulatory agency FRMs is much greater on the days with the highest PM2.5. Figure 2 shows the difference between the vendor and regulatory agency FRMs, as well as the sorted FRM concentration for each day. The data in this plot were combined from the Met One equivalency test in New Haven, CT, and the Thermo Fisher equivalency test in Queens, NY. These tests were both conducted in July The linear regression indicates that the expected difference between the vendor and the state and local agency FRMs increases as the PM2.5 concentration increases. It is clear that this bias is much more significant on days when regulatory agencies are most likely to measure a concentration that exceeds the 24-hr PM2.5 National Ambient Air Quality Standards (NAAQS). Regulatory Implications for Using FEMs Regulatory agencies awaiting the designation of a continuous Class III FEM do not have to wait any longer. 12 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

15 This is good news for state and local air monitoring agencies that need to reduce staffing and program costs, as well as for the majority of agencies that routinely monitor PM2.5 concentrations well below the NAAQS. However, regulatory agencies that choose to use a PM2.5 Class III FEM at a compliance monitoring site could be surprised by higher than expected PM2.5 concentrations on days when the proportion of volatile PM2.5 is high. The PM hr NAAQS is in the form of a 98th percentile, which means that the standard could be exceeded with only a few high concentration days per year. So, the performance of the FEMs on these high concentration days relative to the FRM can potentially change the attainment status of an area. ug/m Daily State Agency and Daily Vendor Triplicate FRM Data: FEM Test New Haven, CT 6/23/07 6/27/07 7/1/07 7/5/07 7/9/07 7/13/07 7/17/07 7/21/07 Daily State Agency Collection and Daily Triplicate Vendor FRM Data: FEM Test Queens NYC Most agencies do not know whether the bias between the new FEMs and FRM is significant in their area. This problem is exasperated by the FEM tests, which cannot be used to predict how well the FEMs work in various parts of the country. EPA has addressed this issue through an implementation guidance memo for Class III FEMs. 4 The guidance describes how the FEMs can be used at a monitoring site for evaluation for up to two years collocated with a FRM. The problem with this guidance is that there is no advice for what to do if the FEM and the FRM do not compare well enough to meet the original equivalency specifications. One of the conclusions of the implementation memo is that state and local agencies should discuss the issue with their Regional EPA Office before the decision is made to operate a Class III FEM. How to Upgrade the FRM The Met One BAM and the Thermo Fisher 1405 DF work as designed, agree well with one another, and provide data that includes a higher proportion of the volatile mass than the FRM. The preferred way to address this difference is to modify the FRM, so that it retains substantially more of the volatile components of PM2.5. The successful elements of the FRM design, such as the size selective inlet and volumetric flow control, can all be left intact. The FRM needs to have the added ability to cool the sampling filter at the end of the sampling period. This could easily be done by incorporating a Peltier cooler to keep the filters cold after the sampling period has ended. A dryer may also have to be used to prevent condensation from occurring while the filter is in the sampler. The result of an improved FRM will be a PM2.5 dataset more consistent for regulators and more responsive to researchers needs. ug/m 3 Figure 1. Filter sampler concentrations collected in New Haven, CT, and Queens, NY. Notes: The top plot shows CTDEP FRM data (hollow diamonds), which tend to be lower than the triplicate vendor FRM data (filled triangles) and the vendor FEM data (crosses) during the summer FEM field campaign in New Haven, CT. The lower plot shows the FRM and FEM test data from Queens, NY. ug/m /1/07 6/5/07 6/11/07 6/17/07 6/23/07 6/29/07 7/5/07 7/11/07 7/17/ FEM Equivalency Test Data: Sorted PM-2.5 Concentration and Bias Bias = Vendor FRM - CT DEP and NYSDEC FRM data Sorted Conc and Bias Figure 2. The absolute value difference between the vendor and regulatory agency FRMs Notes: The plot shows the absolute value difference between the vendor and regulatory agency FRMs PM 2.5 concentration for each day of the two campaigns in the Northeast (filled squares). The PM 2.5 data (hollow diamonds) are sorted from lowest to highest. The linear regression (R 2 = 0.4) indicates that the expected difference between the vendor and the state and local agency FRMs increases as the PM 2.5 concentration increases. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 13

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17 Drug discovery & development elop Education & training research Survey research ch& &services Statistics ics research International nati development elop Economic & social research Advanced technology research Energy research Environmental research earc Health research Laboratory atory & chemistry services > Applying scientific ific solutions to environmental challenges. es. e Conclusion Beyond the regulatory implications of measuring more of the volatile components of PM2.5, there are other compelling reasons to use FEMs in place of the FRM. The FEMs provide hourly data which are, of course, more useful for pollutant tracking studies and for public reporting purposes; a vital mission for every air quality agency today. The FEMs also measure a quantity that is potentially more relevant for public health studies than the FRM. The original purpose for monitoring PM2.5 concentrations was to determine compliance with a health-based standard. What if the air quality standard was set based on a filter-based measurement not capturing the most harmful components of PM2.5? Since we know that there are health effects associated with relatively low PM2.5 concentrations, it seems we should be concerned if we may be missing a significant portion of PM2.5 on the highest concentration days. If there is, in fact, a stronger correlation with health effects with FEM data than with FRM data, it may be that we are underestimating the associated risk of living in urban areas. The Met One BAM and the Thermo Fisher 1405 DF represent a true technological advancement over filterbased samplers, the basis for FRM sampling for more than 30 years. As these new technologies get more widely deployed, users will come to expect high-quality hourly data that is consistent and comparable no matter what instrument or which monitoring agency provides the data. 24-hr filter-based FRM data are likely to become irrelevant unless upgraded to make the data at least consistent with these new technologies. em References 1. Schwab, J.J.; Felton, H.D.; Rattigan, O.V.; Demerjian, K.L. New York State Urban and Rural Measurements of Continuous PM 2.5 Mass by FDMS, TEOM, and BAM; J. Air & Waste Manage. Assoc. 2006, 56, Felton, H.D.; Rattigan, O.V. Modifying 50 ºC TEOM Data to be More FRM like for AQI Reporting using a Nonlinear Correction based on the Julian Day. Presented at the 2005 AAAR Meeting, February 7-11, 2005, Atlanta, GA (17PH-28). 3. Ambient Air Monitoring Reference and Equivalent Methods. 40 CFR Part Implementing Continuous PM 2.5 Federal Equivalent Methods (FEMs) and Approved Regional Methods (ARMs) in State or Local Air Monitoring Station (SLAMS) Networks ; Memorandum from Richard A. Wayland, Director, Air Quality Assessment Division, Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC, to Regional Air Division Directors, dated July 24, Acknowledgment The author thanks Met One Instruments Inc., Thermo Fisher Scientific, CTDEP, and NYS- DEC for providing data used in this article. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 15

18 em feature PM Monit in Support of EPA s PM by Joann Rice and Beth Hassett-Sipple Joann Rice is an environmental scientist in the Air Quality Assessment Division and Beth Hassett-Sipple is an environmental health scientist in the Health and Environmental Impacts Division, both with the U.S. Environmental Protection Agency s (EPA) Office of Air Quality Planning and Standards in Research Triangle Park, NC. rice.joann@epa.gov. Disclaimer: The views expressed in this article are those of the authors and do not necessarily reflect the views and policies of EPA. The article has been subjected to the agency s peer review and is approved for publication. Current National Ambient Air Quality Standards (NAAQS) for particulate matter (PM) use PM 2.5 and PM 10 as the indicators to provide protection against exposures to fine and coarse particles, respectively. PM 2.5 is the indicator for fine particles that generally refers to particles less than or equal to 2.5 micrometers (μm) in diameter. PM 10 is the indicator for coarse particles that generally refers to particles less than or equal to 10 μm in diameter. In a review of the PM NAAQS completed in 2006, 1 the U.S. Environmental Protection Agency (EPA) revised the level of the 24-hr PM 2.5 NAAQS to 35 μg/m 3 and retained the level of the annual PM 2.5 standard at 15 μg/m 3 to provide public health and welfare protection against exposures to fine particles. EPA also retained the primary and secondary 24-hr PM 10 standards at 150 μg/m 3 to continue to provide protection against exposures to thoracic coarse particles. Given that the available evidence did not suggest an association between long-term exposures to thoracic coarse particles at current ambient levels and adverse effects, EPA revoked the annual PM 10 standard. 16 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

19 toring M NAAQS As part of this NAAQS review, EPA proposed a new indicator for thoracic coarse particles defined to include particles between 2.5 and 10 μm in diameter, PM10-2.5, and qualified to focus on the mix of thoracic coarse particles generally present in urban environments. 2 For reasons discussed in the preamble to the final rule 1 and after extensive evaluation of the evidence, consideration of available alternative standards, advice and recommendations of Clean Air Science Advisory Committee (CASAC), and consideration of public comments, EPA concluded that retaining PM10 as the indicator for thoracic coarse particles was most appropriate. Although the standards for thoracic coarse particles do not use a PM indicator, the 2006 revisions to the PM NAAQS included a new Federal Reference Method (FRM) for the measurement of PM in ambient air. One of the reasons for not finalizing a PM standard in 2006 was the limited body of evidence on effects associated with thoracic coarse particles from studies using PM measurements. With the new PM FRM, researchers will likely include PM measurements in health and welfare studies to inform future reviews of the PM NAAQS. This new PM FRM also provides a basis for approving Federal Equivalent Methods (FEMs) and will be important in the development of PM speciation sampling methods. In 2006, EPA promulgated new requirements for PM monitoring at National Core (NCore) multipollutant monitoring sites beginning in The new PM monitoring network will support scientific studies to provide information valuable for future PM NAAQS reviews. These new monitoring requirements will be added to existing requirements for PM2.5 and PM10 monitoring. Since PM can be represented by the difference between PM10 and PM2.5 measurements with appropriate FRMs, data from existing PM10 and PM2.5 FRMs can also be leveraged to obtain measurements for PM Newly deployed monitors for PM mass and composition will add to the existing and very limited air quality database and increase the body of data available for assessing health effects associated with thoracic coarse particles from studies that use PM as a measure of thoracic coarse particles. This article describes a brief background on the NAAQS program, PM monitoring requirements, and PM monitoring to date. EPA is currently reviewing the PM standards. This article will also highlight the key PM monitoring issues raised in this current PM NAAQS review, and provide information on current actions and how the public can provide input into the ongoing PM NAAQS review process. NAAQS Background Two sections of the U.S. Clean Air Act (CAA) govern the establishment and periodic review of the NAAQS: Section 108, which requires that EPA issue air quality criteria (AQC) that will accurately NCore is a multipollutant network that integrates several advanced measurement systems for particles, pollutant gases, and meteorology. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 17

20 The CAA requires that EPA review the NAAQS at five-year intervals. Figure 1. Candidate NCore sites, as of October reflect the latest scientific knowledge useful in indicating the kind and extent of all identifiable effects on public health or welfare which may be expected from the presence of such pollutant in the ambient air, in varying quantities ; and Section 109, which requires EPA to set two types of NAAQS: primary (health-based) NAAQS that are to be ambient air quality standards, which in the judgment of the EPA Administrator, based on the AQC and allowing an adequate margin of safety, are requisite to protect public health; and secondary (welfare-based) NAAQS that are to be ambient air quality standards, which in the judgment of the EPA Administrator, based on the AQC, are requisite to protect public welfare from any known or anticipated adverse effects. Welfare effects, as defined by the CAA, include visibility impairment, as well as effects on wildlife, crops, vegetation, soils, water, and man-made materials. The CAA requires that EPA review the AQC and NAAQS at five-year intervals and promulgate new standards, as may be appropriate to ensure that they provide requisite health and environmental protection. NAAQS have been set for PM and five other common air pollutants: ozone, nitrogen dioxide, carbon monoxide, sulfur dioxide, and lead. PM NAAQS Monitoring Requirements In 2006, along with revising the PM NAAQS, EPA also finalized revisions to the ambient air monitoring regulations. 3 The final monitoring rule contains a requirement for PM mass and speciation monitoring at NCore multipollutant sites by January 1, 2011, with Annual Monitoring Network Plans due July 1, This rule increases the number of speciation monitoring sites from about 20 to 75 and shifts the focus from urban monitoring to both urban and rural monitoring locations. Manuallyoperated PM mass and speciation samplers must operate on at least a 1-in-3 day schedule and be collocated with PM2.5 speciation samplers at NCore sites. Since EPA is requiring PM mass and speciation monitoring primarily for scientific purposes, it is appropriate to have monitoring at a variety of urban and rural locations to increase the diversity of areas that will have chemical species data. NCore 4 is a multipollutant network that integrates several advanced measurement systems for particles, pollutant gases, and meteorology (see Figure 1). NCore puts emphasis on multipollutant monitoring, 18 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

21 continuous monitoring methods, and important pollutants previously not included in pollutant monitoring networks, such as reactive oxides of nitrogen (NOy) compounds. When completed, this modified network will meet a number of important needs that include improving data flow and timely reporting to the public; providing inputs for NAAQS compliance determinations; supporting the development of emissions strategies; improving inputs for evaluating accountability for control programs; and providing data to support scientific and health- and/or welfare-based research studies. PM Monitoring to Date The PM FRM, or approved FEMs if available, will be implemented for mass measurements at the required NCore stations by January 1, Despite this long period of implementation, there are already a number of collocated PM10 and PM2.5 low-volume FRMs operating across the country that are essentially providing the PM FRM measurement by the difference method. Twenty-four sites across four states (Iowa, North Carolina, Connecticut, and Montana) are currently collecting PM mass data to support special studies and monitoring implementation using collocated PM10 and PM2.5 samplers and posting these data into the EPA Air Quality System. PM speciation is required at NCore; however, there is currently no routine chemical speciation network for characterizing the specific components of thoracic coarse particles. A few PM speciation monitoring special studies are in progress to inform development of the PM speciation monitoring program. EPA continues to evaluate the performance of commercially-available dichotomous and continuous monitors to support PM mass and speciation monitor development. PM speciation monitoring will require the measurement of different species and possibly different sampling and analysis methods than currently used in the PM2.5 program. Therefore, EPA is in the process of planning a PM The FIRST U.S. EPA-designated continuous PM-2.5 monitor only from Met One Instruments The BAM-1020 particulate matter (PM) mass concentration monitor is the only unit of its kind to receive U.S. EPA s designation as a Class III Federal Equivalent Method (FEM) for PM-2.5 (EQPM ). An FEM for PM-10 as well, the BAM-1020 monitor provides continuous, hourly measurements for real time pollution alerts and regulatory and research applications faster than conventional samplers and without laboratory analysis. Rugged and dependable; field-tested for long-term, unattended use Easy to install, operate and maintain, and requires no site-selective adjustments Improved sensitivity and accuracy Manufactured in the United States and certified worldwide Met One Instruments, Inc. has been a world leader in the research, development and manufacture of meteorological instruments, particulate monitors, data loggers and environmental software for over 30 years. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 19

22 There is currently no routine chemical speciation network for characterizing the specific components of thoracic coarse particles. speciation monitoring pilot program with state/ local monitoring agency partners at a few locations. This pilot program will aid our understanding of the issues associated with PM speciation monitoring and help to determine the most appropriate strategy for long-term monitoring of PM species at NCore sites. Donate just 20 minutes a week and inspire the next generation of A&WMA members! MentorNet is seeking science and engineering professionals working in industry or government to mentor students and young professionals looking to break into the environmental field. Visit to get started. PM Monitoring Issues in the Current PM NAAQS Review The current PM NAAQS review will explore a number of policy-relevant issues associated with measuring and characterizing fine and thoracic coarse particles in ambient air. As part of the review process, EPA prepared an Integrated Review Plan (IRP) that presented the current design of the review and specified the schedule for the entire review, the process for conducting the review, and the key policy-relevant science issues that will guide the review. 5 Specific monitoring-related issues associated with measuring and characterizing fine and thoracic coarse particles in ambient air related to the review of the PM NAAQS were included in Section 7 of the IRP. EPA will draw upon the information presented in the PM Integrated Science Assessment (ISA) to inform the evaluation of appropriate monitoring methods and network design for PM, including consideration of the available information on probe siting criteria that could best support the current or alternative PM standards. The PM issues related to monitoring network design, sampling methods, and data reporting were provided in the IRP and are summarized below. The minimum number of required monitors for PM is stated in the U.S. Ambient Air Monitoring Regulations. 3 EPA negotiates with state air agencies to determine the total number of monitors needed to represent an area s air quality. The requirements for PM mass and speciation monitoring at NCore sites include a provision for both urban and rural monitoring locations. Issues related to the PM network design that will be examined in the current PM NAAQS review include consideration of factors to identify the size of a PM mass and speciation monitoring network that would be sufficient to spatially characterize urban and rural areas (e.g., number of monitors, geographic distribution); identification of additional sampling and statistical techniques that are available to help determine the minimum number of PM monitors needed across an area to adequately assess issues of spatial and temporal variability; consideration of criteria to inform appropriate monitor placement for thoracic coarse particle characterization of PM10-2.5, including the distance relative to sources, measurement scale, and inlet height; and whether data from PM monitors located nearly adjacent to sources should be excluded from comparison with a potential PM NAAQS. Sampling method issues for consideration include identification of new information that is available to inform options and technologies for sampling and analysis of components of thoracic coarse particles; operational experiences learned in the PM2.5 speciation network and the multisite evaluations of PM monitors that would be useful to inform sampler design and laboratory analysis methods being considered for PM speciation; PM speciation sampling artifacts that may be encountered; sampling methods or technologies that are available and appropriate for collection of particles for PM speciation; whether the collection 20 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

23 and qualitative/quantitative analysis of biological materials is appropriate; and if time-resolved measurements are needed to evaluate the evidence for a causal relationship between observed health outcomes and ambient thoracic coarse particle concentrations. Related to an expected increase in the number of low-volume PM10 samplers with the transition to PM measurement by the difference method, information on precision and bias from high- and low-volume PM10 samplers should be evaluated to demonstrate whether a significant advantage for low-volume samplers exists and whether a phase-out of high-volume samplers for PM10 should be considered. Public Input into the NAAQS Review Process Since the last PM NAAQS review, EPA has made a number of changes to the process that it uses to review the NAAQS. These changes focus on addressing key policy-relevant issues and timeliness, consideration of the most up-to-date scientific information in the decision-making process, distinctions between scientific and policy judgments, and characterization of uncertainties in scientific and technical information. In making these changes, EPA consulted with CASAC and considered public comments. 6 The new process is being applied to the current PM NAAQS review and contains four major components: the IRP, an ISA, a risk and exposure assessment, and a policy assessment/rulemaking. Several opportunities in the NAAQS review process provide for both CASAC and public comments on each of the major products or outputs from the review, including solicitation of public comments on the proposed rule. Figure 2 provides a flow diagram of the current process and indicates points where CASAC review and public comment are requested. With respect to the current PM NAAQS reviews, recent milestones completed include a final IRP 5 issued in March 2008 and a first draft ISA 7 released in December We anticipate a proposed rulemaking in early 2011, with final rulemaking in late 2011 to complete this review. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 21

24 Figure 2. Current NAAQS review process. Conclusion Although the standard for thoracic coarse particles does not use PM as the indicator, a new FRM for PM was promulgated and provides a basis for approving FEMs and promotes collection of scientific data to support future PM NAAQS reviews. The FRM will also be important in the development of PM speciation sampling methods. PM mass and speciation monitoring at NCore sites is not required until January 2011; however, some monitoring for special purposes is in place to help inform the development of long-term PM monitoring programs. monitoring program. EPA is developing an implementation plan for a thoracic coarse particle speciation network that will be part of the NCore network. The current PM NAAQS review will explore a number of key policy-relevant issues associated with measuring and characterizing fine and thoracic coarse particles in ambient air. EPA will draw upon scientific information developed during this review to inform the evaluation of appropriate PM monitoring methods and network design. em Initially, PM mass monitoring is being done by state agencies using existing low-volume PM2.5 and PM10 FRM sampling systems. A few PM speciation monitoring special studies are in progress to inform development of the PM speciation References 1. National Ambient Air Quality Standards for Particulate Matter; Fed. Regist. 2006, 71, (October 17, 2006). 2. National Ambient Air Quality Standards for Particulate Matter; Fed. Regist. 2006, 71, 2620 (January 17, 2006). 3. Revisions to Ambient Air Monitoring Regulations; Fed. Regist. 2006, 71, (October 17, 2006). 4. National Core Multipollutant Monitoring Network. See 5. Integrated Review Plan for the National Ambient Air Quality Standards for Particulate Matter; EPA 542/R ; U.S. Environmental Protection Agency: Washington, DC, March 2008; available at 6. Review of the National Ambient Air Quality Standard (NAAQS) Process. See 7. Integrated Science Assessment for Particulate Matter: First External Review Draft; EPA/600/R ; U.S. Environmental Protection Agency: Washington, DC, December 2008; available at 22 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

25 First comprehensive revision since 1992 Air Pollution Engineering Manual Second Edition Eight years in the making, this second edition is a vital source of information on air pollution control issues for industries worldwide affected by regulations, including the Clean Air Act. Learn about the latest emission factors and control measures for reducing air pollutants. Read about the fundamental technological and regulatory information you need to comply with recent air pollution standards for industry and government. View more than 500 detailed flowcharts and photos. Utilize the extensive listing of Internet resources. Order Now! Member price $168 Nonmember Price $178 Experts from diverse fields cover: biological air pollution control emission control methods for a multitude of industries, ranging from wood processing and brick, ceramic and pharmaceutical manufacturing to graphic arts, metallurgy, waste and wastewater changes in emission factors for each source category, including particulate matter updated MACT regulations and technologies, and more! This book is a must for industry and government professionals, and a great gift for recent or soon-to-be graduates! To place your order: Online at (secure site) onlinelibrary@awma.org Call A&WMA Publications Order Department at , ext Order Number OTHP-01R: Air Pollution Engineering Manual, Second Edition Edited by Wayne T. Davis, Ph.D., University of Tennessee Copyright April 2000, John Wiley & Sons Inc. Shipping costs additional. Another Premier Publication from Air & Waste Management Association Connecting the World s Leading Environmental Professionals

26 em feature Planning for NCore Monitoring by Jim McGaughey, Joette Steger, Mark Yirka, and Carlton Blakley Jim McGaughey and Carlton Blakley are environmental chemists with the Ambient Monitoring Section, Dr. Joette Steger is the project and procedures branch supervisor of the Ambient Monitoring Section, and Mark Yirka is an electronics technician with the Electronics and Calibration Branch of the Ambient Monitoring Section, all with the North Carolina Division of Air Quality in Raleigh, NC. The U.S. Environmental Protection Agency s (EPA) National Ambient Air Monitoring Strategy National Community Representative (NCore) program is a network that is currently under development. It is being designed to promote a true, multipollutant monitoring infrastructure for future multiple pollutant-based air program management initiatives. When complete, NCore will meet a number of important data needs, including improved flow and timely reporting of data to the public; continued determination of National Ambient Air Quality Standards (NAAQS) compliance; improved development of emissions control strategies; enhanced accountability for the effectiveness of emission control programs; and more complete information for scientific, public health, and ecosystem assessments em february 2009 Copyright 2009 Air & Waste Management Association awma.org

27 NCore will consist of three levels of monitoring sites: Levels 1, 2, and 3. Level 1 sites will be few in number and will be research oriented. Level 2 sites will be the backbone of the network and will integrate several advanced measurement systems for particles, inorganic gases, and meteorology, and will consist of approximately 75 sites located mostly in urban areas. These sites are to provide measurements that are representative of well-mixed air regimes that are not overly influenced by local source emissions or topographical phenomena and will focus on the implementation of high-sensitivity gaseous monitors for carbon monoxide (CO), sulfur dioxide (SO2), and total reactive oxides of nitrogen (NOy) precursors to ozone (O3) and particulate matter (PM) formation. Level 3 sites will focus primarily on specific pollutants, such as O3 and PM, and may number more than ,3 The proposed monitoring types for the NCore sites are provided in Table 1. Final site selection is not required until July 1, 2009, and these sites are not required to be in operation until January 1, This date seems to be far into the future, but not so when considering that the NCore monitoring plan is due July 1, The following discussion addresses the activities that the North Carolina Division of Air Quality (NCDAQ) has begun for an NCore site and is planning to accomplish in the next year. The topics listed below are those that the NCDAQ has initially targeted. As we began addressing each topic, questions arose that were not covered in sufficient detail in currently available EPA materials. Site Selection It is anticipated that most NCore sites will be in urban areas (representing a parcel with dimensions of approximately 5 50 km). This requirement is discussed in the latest EPA Code of Federal Regulations (effective December 18, 2006) in 40 CFR Part Many states may already have an active site that is part of their State and Local Air Monitoring Stations (SLAMS) network and meets this EPA requirement, as is the case with NCDAQ. The specific location of the site must meet the monitor siting requirements, including distance from roads, buildings, and trees. Additionally, the site monitors must be positioned to meet minimum/maximum distances from each other and have probe inlets at specific heights above the ground. PM monitors are typically positioned in an open area with individual environmentally controlled outdoor shelters, while continuous gaseous monitors are housed in a temperature-controlled building or a small walk-in structure. It was necessary for NCDAQ to modify our existing site to meet all of the NCore requirements. First, it was necessary to move some trees and remove others. This required some negotiation with adjacent property owners. Second, we constructed a groundlevel 16x16 feet wooden deck on which the particulate monitors will be positioned. This allows sufficient room to incorporate up to nine individual monitors, as well as the quarterly EPA PM2.5 Federal Reference Method (FRM) audit monitor. The need for sufficient electrical power was also considered and separate 20-amp circuits were installed. Monitor Selection Monitors for the measurement of PM are either filter-based (manual) or continuous. Filter-based methods are FRMs and will not be addressed here. Several continuous PM monitors are available and have been in use for many years. Two of the most commonly used units are the tapered-element oscillating micro-balance (TEOM) manufactured by Thermo Environmental and the beta attenuation monitor (BAM) manufactured by Met One Instruments. The Met One BAM 1020 has just recently received EPA approval as a Federal Equivalent Method (FEM), 4 while the TEOM is currently under consideration for FEM. NCDAQ has several TEOM 1400A/B units in operation and is currently evaluating three BAM 1020 units in a comparison study with collocated FRM and TEOM units. The gaseous monitors to be used, in particular, are redesigned monitors for SO2, CO, and NOy. These monitors are available from at least two manufacturers and are described in detail in the EPA technical assistance document. 2 These monitors are termed trace level and are capable of measuring sub-parts per billion (ppb) levels of SO2 and NOy and low parts per million (ppm) levels of CO. Measuring concentrations at these low levels brings additional monitoring and quality control challenges. An example of one such quality control activity is the determination of the method detection limit (MDL). 2 The MDL determination is required initially at deployment and then annually thereafter, and requires the collection of at least seven data sets of concentration values at a level that is approximately Monitors for the measurement of PM are either filter-based or continuous. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 25

28 Generating accurate and reproducible low-level concentration of calibration gases can be a challenge. Table 1. Proposed NCore monitor types. Parameter PM 2.5 Speciation (PM Fine) PM 2.5 FRM mass (PM Fine) Continuous PM 2.5 mass PM (10-2.5) mass (PM Coarse) PM (10-2.5) mass (PM Coarse) Speciation Carbon Monoxide (CO) Sulfur Dioxide (SO 2 ) Ozone (O 3 ) Total reactive nitrogen oxides (NO y ) Ammonia (NH 3 ) Nitric Acid (HNO 3 ) Surface Meteorology 2.5 to 5 times the noise level of the instrument. The data are to be collected at equally spaced intervals over a period of no less than five days. If the instrument is being used to generate data to support the NAAQS requirements, then imposing this additional quality control requirement may require some logistical adjustment to a normal operating schedule. Calibration Challenges Generating accurate and reproducible low-level concentrations of calibration gases can be a challenge. As a result, NCDAQ was required to evaluate the configuration of our current gas dilution calibrators as to the selection of the proper mass flow controllers (MFCs). One criterion invoked was the selection of properly sized MFCs to be used within 5 95% of the operating range. A second criterion was the selection of MFCs that were compatible with our existing calibrators. We selected a 50-standard cubic centimeter per minute (sccm) MFC for the introduction of the calibration gas and a 20- standard liter per minute (slpm) MFC for the diluent gas (i.e., pollutant-free air). Operating at the lower end of the 50-sccm MFC for the calibration gas and the upper end of the 20-slpm MFC for the diluent gas, we were able to consistently achieve the low concentration levels required (i.e., <10 ppb SO2). To calibrate the gas dilution calibrators, the flow rates generated by the MFCs must be periodically Comment Organic and elemental carbon, major ions, trace metals (24-hr average every third day) 24-hr average (daily or every third day) 1 hr average 24-hr/day/7-day/week Waiting for EPA standard Waiting for EPA standard Continuous trace-level monitoring (i.e., <1 ppm) Continuous trace-level monitoring (i.e., < 10 ppb) Continuous monitoring Continuous trace-level monitoring (i.e., <40 ppb) Under consideration Under consideration Wind speed and direction, temperature, and relative humidity verified to an accuracy of ±2%. Thus, the identification of a National Institute of Standards and Technology (NIST) traceable flow meter was the next challenge. After an extensive search and technical discussions with various manufacturers, NCDAQ selected electronic, digital mass flow meters (MFMs) with ranges of 0 20 slpm and sccm. Additional NIST-certified flow calibration points were requested from the manufacturer to bracket our flow range needs. These electronic MFMs also provide the means to collect and store the resulting flow readings electronically for download to a software spreadsheet to provide additional reporting flexibility. An additional challenge was the generation of highly purified pollutant-free air to be used for zeroing the trace-level instruments and preparing gaseous standards with the gas dilution calibrators. The generation of this clean zero air is critical to the operation of the trace analyzers that are to be used with the NCore program. The latest information provided by EPA at the most recent Precursor Gas Workshop, June 5 6, 2007, 3 states that zero air should contain concentrations of CO, SO2, and NOy that are less than the lower detectable level (LDL) for each instrument. These levels are: 40 ppb for CO; 0.1 ppb for SO2; and 0.05 ppb for NOy. Thermo Environmental Model 111 Zero Air generators are currently being used by NCDAQ to generate a constant supply of purified air for use 26 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

29 with non-trace-level analyzers. In this system, CO, SO2, and NOy are scrubbed from a supply of compressed ambient air using canisters of Purafil (oxidizes NO to NO2), charcoal (removes NO2 and SO2), and Hopcolite (removes CO), connected sequentially in the order described. Additionally, water vapor is removed using silica gel. The silica gel is changed as needed (indicated by color change), while the other materials are changed annually. A capillary bleed has been installed to allow a constant low flow of air through the system when not requiring air for calibration. There are two issues that need to be addressed regarding the operation of the trace-level monitors: how to generate zero air to meet these NCore criteria and how to verify that the levels meet the criteria. Our approach is to evaluate the current configuration of the Model 111 and then attempt to make improvements, if necessary. NCDAQ plans to accomplish these tasks as follows:! Set up a Model 111 with fresh reagents. Prepare a second set of reagents connected in series as described above and attach to the outlet of the Model 111. Connect the outlet of the second set of reagents to the inlet of the gas dilution calibrator. Allow this configuration to generate zero air for 24 hours to condition the Remove the second set of reagents, connect the Model 111 to the calibrator and introduce zero air to each type of trace-level instrument. Allow the zero air to flow to the analyzers for a period sufficient to allow the readings to stabilize, set the instrument zero, and record the next 30 one-minute averages. This test is typically performed at a low flow rate (nominally 0.5 lpm). Calculate the average concentration of the 30 values. # Repeat #2 after adjusting the flow rate from the calibrator to be nominally 15 lpm (high flow rate). $ To the outlet of the Model 111, connect the second set of reagents and then connect the outlet of this second set to the calibrator. Introduce zero air to each type of trace-level instrument, repeating the low and high flow tests as described above. % At the 95% confidence level, statistically evaluate the data sets to determine if there is a difference awma.org Copyright 2009 Air & Waste Management Association february 2009 em 27

30 Make the Online Library Your First Stop for Air Quality Information! A&WMA offers members and nonmembers access to a wealth of technical environmental information through its Online Library. The library allows users to search, purchase, or download a range of more than 11,000 products offered by A&WMA, including the latest technical books, CDs, and educational materials, as well as thousands of papers and articles from A&WMA conference proceedings, the Journal, and EM. Below is a sampling of the air quality monitoring technology information that is currently available through A&WMA s Online Library. Visit the Online Library today at secure.awma.org/ OnlineLibrary. Don t forget that A&WMA members receive discounts on most items in the Online Library. Symposium on Air Quality Measurement Methods and Technology Published 2008 by A&WMA A&WMA Order Code: CP-178-CD Ambient Air Pollution by Paolo Zannetti, Dhari Al-Ajmi, Saud Al-Rashied Published 2007 by EnviroComp Institute A&WMA Order Code: IMO-162-CD Fundamentals of Air Pollution, Fourth Edition by Daniel Vallero Published 2007 by Academic Press A&WMA Order Code: QEP-03 Air Quality Modelling: New Methods for a New Reality Proceedings Published 2004 by A&WMA A&WMA Order Code: VIP-130-CD Air Quality, 4th Edition by Thad Godish Published 2004 by CRC Press A&WMA Order Code: DS-157 Air Pollution Control: A Design Approach, Third Edition by C. David Cooper, F.C. Alley Published 2002 by Waveland Press, Inc. A&WMA Order Code: DS-107 Canadian Clean Air Policy Conference Published 2002 by A&WMA A&WMA Order Code: VIP-109 Guideline on Air Quality Models Conference: A New Beginning Published 2001 by A&WMA A&WMA Order Code: VIP-107-CD Air Pollution Control Technology Handbook by Karl B. Schnelle, Jr., Charles A. Brown Published 2001 by CRC Press A&WMA Order Code: DS-90 Air Pollution Engineering Manual by Wayne T. Davis, Editor Published 2000 by John Wiley & Sons A&WMA Order Code: OTHP-01R Continuous Emission Monitoring, Second Edition by James Jahnke Published 2000 by John Wiley & Sons A&WMA Order Code: DS-83 between the two averaged values for single scrubbing/two flow rates, dual scrubbing/two flow rates, and single scrubbing versus dual scrubbing. Review the data to determine if dual scrubbing is better than single scrubbing and if higher flow rates produce poorer quality zero air. ^ Compare the Model 111 (in either single or dual scrubbing mode) zero air to an independent source. This independent source can be a cylinder of commercially available Ultra Pure Zero Air with additional scrubbing, such as described above, or purified air produced by the NCDAQ hydrocarbon lab with similar scrubbing. & Once it is determined which configuration provides the cleanest air, that system will be designated as the system to be used for the generation of zero air at the NCore site and for conducting performance audits. Other Issues EPA recommends that the concentration data generated by the gaseous analyzers be collected in a digital format. Analog signals are subject to small voltage fluctuations as the result of being near or exposed to external electromagnetic fields. This can be problematic when trying to measure 28 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

31 Think you have what it takes to tackle real-world environmental problems? THE ENVIRONMENTAL CHALLENGE INTERNATIONAL 2009 How would you handle a garbage dispute between two cities? If you re a college student and you think you re up to the challenge, take part in the Air & Waste Management Association s (A&WMA) Environmental Challenge International! Here s how it works. We give you an environmental problem, then you build a team, examine the problem, study the issues, and generate and present a practical solution at A&WMA s 102nd Annual Conference & Exhibition in Detroit, MI, June 16-19, Over $15,000 was awarded to the winning teams last year, so don t miss your chance to participate! Visit to view the problem and register your team. concentrations in the low-ppb range. Other advantages of using a digital format include monitors can be interconnected using serial cables, thus reducing the amount of wiring; instrument diagnostics can be polled in addition to concentration data; data system values always match the analyzer values; and the layout facilitates remote access capabilities. Conclusion The deadline of January 1, 2011, to have the NCore sites operational seems a long way off. However, each state agency should initiate the planning process and develop a timeline to address various topics such as site location, site preparation, monitor selection, preparation of quality assurance plans, and monitor the evaluation and generation of low-ppb concentrations for instrument calibration, as soon as possible. The most valuable lessons learned to date by NCDAQ have been related to the operation of the gaseous monitors and the ancillary functions of calibration, calibration verification, and the generation of zero air. We feel certain that additional information and guidance will be forthcoming as each state agency and EPA work through these issues over the next two years. em References 1. Ambient Air Quality Surveillance. 40 CFR Part Technical Assistance Document for Precursor Gas Measurements; EPA-454/R ; U.S. Environmental Protection Agency: Washington, DC, 2005; available online at 3. EPA Precursor Gas Workshop: NCore Multi-Pollutant Site Implementation Training, June 5 6, 2007, Research Triangle Park, NC. See 4. Gobeli, G.; Meyer, M.; Schloesser, H.; Pottberg, T. Finally, a Continuous FEM for PM 2.5 ; EM February 2009, 6. Acknowledgment The authors thank Hoke Kimball and Dr. Arun Shendrikar of NCDAQ for their continuing work in planning and implementing the various aspects of this project. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 29

32 em feature by John Kinsman and Bill Fang Regulating Greenhouse Gases Under the Clean Air Act An Industry Perspective John D. Kinsman is senior director of environment and William L. Fang is deputy general counsel and climate issue director, both with the Edison Electric Institute in Washington, DC. A complicated web of litigation, regulation, and legislation is moving forward that could lead to the regulation of greenhouse gas (GHG) emissions under the Clean Air Act (CAA). Key decisions regarding GHG control could be made in 2009 by the new Administration, the U.S. Congress, the courts, and states. Massachusetts vs. EPA The U.S. Supreme Court issued its landmark decision in Massachusetts vs. EPA in April 2007, 1 on the topic of regulating motor vehicle GHG emissions, holding that the U.S. Environmental Protection Agency (EPA) must decide whether to make an endangerment finding (i.e., a finding that GHGs are air pollutants that cause or contribute to air pollution that endangers public health or welfare), make a finding of no endangerment, or provide some reasonable explanation as to why it cannot or will not exercise its discretion. EPA seemingly was on the verge of proposing a finding when Congress passed, and the President signed into law in December 2007, the Energy Independence and Security Act of 2007, 2 which set a mandatory renewable fuel standard requiring producers to use at least 36 billion gallons of biofuel in 2022, and a national fuel economy standard of 35 miles per gallon by At the same time, there was a growing realization of the substantial implications for stationary sources due to regulating motor vehicle GHG emissions under the CAA. Congress has followed these developments closely. During a March 13, 2008, hearing of the House Select Committee on Energy Independence and Global Warming, 3 Chairman Edward J. Markey (D-MA) lamented EPA s lack of progress in responding to the court decision, and numerous members of Congress have pushed for a decision since. Seventeen states tried to accelerate an EPA response via a January 23, 2008, letter to EPA, 4 and California, plus other petitioners in Massachusetts vs. EPA, filed a writ of mandamus petition with the D.C. Circuit Court of Appeals, 5 which asked the court to order EPA to make an endangerment finding within 60 days, which the court rejected. Subsequently, EPA announced in spring 2008 that it would implement a regulatory information-gathering process through an Advance Notice of Proposed Rulemaking (ANPR), 6 which is discussed below. California Waiver On December 19, 2007, EPA Administrator Stephen L. Johnson denied California s petition for a waiver to set its own carbon dioxide (CO2) limits for new automobiles, claiming that California s climate change situation is not compelling and extraordinary compared to that of other states. A final notice was published in the Federal Register on March 6, Members of the California congressional delegation were particularly unhappy with the decision. Led by California, numerous states have appealed EPA s decision, which will be heard by the D.C. Circuit Court of Appeals as California vs. EPA (No ), with final briefs due on March 6, States The battle over policy-making on GHGs also continues in individual states, particularly regarding the permitting of new fossil-fuel power plants. For example, on June 30, 2008, a Superior Court judge in Georgia ruled that CO2 is subject to regulation under the CAA and a Best Available Control Technology (BACT) analysis is needed regarding the 1200-MW coal-based Longleaf plant. 8 Subsequently, the Georgia Court of Appeals agreed to review the ruling. Meanwhile the Governor of Kansas rejected a permit application for expansion of a coal-based plant by Sunflower 30 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

33 Electric Corp. 9 and several environmental groups are pursuing a well-organized campaign opposing new plants. On the other hand, some states have found, echoing EPA, that GHGs are not regulated under the CAA. For example, the Arkansas Department of Environmental Quality granted a draft permit for the 600-MW ultra-supercritical coal-based John W. Turk plant, 10 which is being appealed. Congress Congress has held four hearings focused on the California waiver, Massachusetts vs. EPA, or on the strengths and weaknesses of regulating GHGs under the CAA. An April 10, 2008, a hearing of the House Subcommittee on Energy and Air Quality 11 featured the strong words of Rep. John Dingell (D-MI), who said that if Congress fails to act, lawsuits will force EPA to regulate GHGs under the CAA; regulating GHGs under the CAA could cause a glorious mess and shut down or slow down industry and the economy; and it would be insane to leave this judgment to the long and complex regulatory and litigation process, which could amount to 100 rulemakings and thus no certainty. Other witnesses claim that, although congressional action would be far preferable, the CAA can be made to work. Besides its oversight activities, Congress is considering the role of the CAA in legislative proposals. For example, the proposed climate change discussion draft language of Reps. Dingell and Rick Boucher (D-VA) 12 would deny the use of National Ambient Air Quality Standards (NAAQS) and hazardous air pollutant (HAPs) CAA provisions to regulate GHGs, while declaring that New Source Review (NSR) and prevention of significant deterioration (PSD) would not apply to GHGs. Executive Branch, Including EPA The executive branch is considering the scientific links between climate change and air quality, as well as regulation of GHG under the CAA and other laws. Studies and reports by EPA and other government agencies have identified possible impacts of climate change on air quality, primarily higher temperature causing increased ozone concentrations (e.g., up to 10 parts per billion by 2050), called by some a climate penalty. 13 There have been calls for states and EPA to start considering the impacts of climate change as they develop their strategies for meeting NAAQS, despite the facts that climate change impacts on air quality are uncertain and would be small in the near term. EPA is in the process of declining to promulgate GHG performance standards for petroleum refineries and Portland cement plants, although the final refinery decision is the subject of several petitions for review before the D.C. Circuit Court of Appeals. 14 In addition, in 2006, EPA declined to set a CO2 New Source Performance Standard (NSPS) for utility and industrial boilers. This decision was being heard by the D.C. Circuit Court of Appeals (No ), but, after the Massachusetts vs. EPA decision, the agency took the rule back on voluntary remand on September 24, 2007 (with no schedule for action). 15 EPA s Environmental Appeals Board (EAB) the final agency decision-maker on administrative appeals under all major environmental statutes is considering several cases involving GHGs and the CAA, most significantly the Sierra Club s challenge of the PSD permit for the Bonanza plant of Deseret Power Electric Cooperative. Sierra Club challenged EPA Region 8 s decision not to require BACT for CO2 control. On November 13, 2008, the EAB remanded to Region 8 the permit, finding that the regional office erred in concluding that it was required, as a result of a historical EPA interpretation on this issue, to decide that it had no authority to impose a BACT limit for CO2. The EAB added that we recognize that this is an issue of national scope that has implications far beyond this individual permitting proceeding, and that EPA should consider a national response. The EAB also found that the statute does not dictate whether the agency must impose a BACT limit for CO2 in the permit. 16 EPA Administrator Johnson issued a memorandum on December 18, 2008, to EPA s Regional Administrators in response to the EAB Deseret decision, finding that the regulatory term regulated NSR pollutant and the statutory term subject to regulation under the Act apply only for those pollutants subject to actual emission controls requirements under the CAA or EPA regulations. 17 As a result, as of December 18, EPA regions and states could issue PSD permits without considering BACT for CO2. Numerous environmental groups filed a petition for reconsideration, arguing that it is Congressional action could yield GHG benefits more quickly than CAA regulation. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 31

34 The NSPS approach shows the greatest promise if implemented in a cap-and-trade manner. a de facto final rule that required notice and comment rulemaking and that it is not in accordance with the CAA, and have sought review of the memo by the U.S. Court of Appeals for the District of Columbia Circuit. Other power plant cases involving CO2 control before the EAB include Northern Michigan University (for a 10-MW circulating fluidized-bed boiler), with oral arguments held October 22, 2008; the EPA Region 9 permit for the New Mexico Desert Rock facility on Navajo land; and the Seminole Generating Station in Florida. Among these cases, claims are made that GHGs already are regulated under the CAA (due to Section 821 monitoring under the 1990 CAA Amendments, EPA landfill gas NSPS regulations, EPA approval of a Delaware state air quality plan, and appropriations language that requires EPA to develop an economy-wide GHG emissions registry). 18 On July 30, 2008, EPA published in the Federal Register its ANPR asking for input on regulation of GHGs under the CAA, with comments due November The notice is unique in that it includes comments opposing such action from other government agencies, such as the Departments of Agriculture, Commerce, Transportation, and Energy, and the Council on Environmental Quality. In a preface, EPA Administrator Johnson states that the CAA is ill-suited for the task of regulating global greenhouse gas emissions. Some environmental groups and academics believe that although congressional action would be far preferable, the CAA can be made to work. Industry groups generally contend that the CAA is the wrong tool for achieving effective GHG regulation, for the reasons described below. An Industry Perspective Only comprehensive legislation can balance GHG reductions with economic efficiency, funding, and incentives for technology development, and avoid any overlap among multiple federal statutory authorities and state climate law and policies. Congressional action could yield GHG benefits more quickly than CAA regulation, given the long time frames necessary to complete all aspects of CAA regulation and the certainty of long litigationrelated delays. Furthermore, if CAA regulation were less flexible than congressional legislation, it could cause increased global GHG emissions by forcing energy-intensive industries to shift operations to countries that have no mechanism for regulating GHGs, or that use energy less efficiently. Also, regulations under the CAA likely would not provide the certainty needed to make the enormous investments needed to bring about emissions reductions, because they would rely on uncertain, novel interpretations of the CAA to bring about preferred outcomes. Regulating GHGs under CAA stationary source (Title I) programs has many uncertainties and pitfalls. For example, regarding NAAQS, this approach makes little sense for GHGs because states have little or no control over the level of GHGs in the atmosphere, and thus no control over their ability to attain compliance with a NAAQS. Further, the NAAQS attainment deadlines would be unworkable for GHGs, and the standard-setting process does not allow for costs and feasibility to be considered when setting the standards. If this approach were to be pursued, setting only a secondary NAAQS would be more scientifically justified and allow greater regulatory flexibility. Regarding NSPS, this approach would not apply economy-wide, meaning that EPA s response would be only partial and would not likely achieve the least-cost GHG reductions. Section 111 regulations could lead to very costly controls because EPA has stated that systems need not be actually in use or achieved in practice at potentially regulated sources or even at a commercial scale. Further, when considering efficiency improvements, EPA ignores the fact that such activities would trigger the CAA s NSR requirements. If such problems could be minimized, the NSPS approach shows the greatest promise if implemented in a cap-and-trade manner. Regarding HAPs, of all of the primary stationary source control programs in Title I, Section 112 carries the most inflexible and stringent requirements for regulated sources. Were EPA to regulate GHGs under any major provision of the CAA, the domino effect implications under the PSD and NSR nonattainment programs likely would be severe. There would be an enormous increase in the number of construction and modification activities that would trigger PSD review, with tremendous manpower and financial burdens on permit applicants and on state and local permitting authorities. Further, it is not clear what would be 32 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

35 considered BACT for GHG purposes. Similarly, application of Title V monitoring and permitting requirements to sources based on their GHG emissions would create similar administrative problems as in the PSD context. In addition, regarding Title V fees, revenues would be grossly excessive for what is needed to process permits for GHG sources. Although EPA discusses several regulatory options for mitigating some of the effects, the agency s legal theories are uncertain and would be challenged in court and Beyond The future holds great uncertainty regarding how GHGs will be dealt with under the CAA. EPA under the Administration of President Obama will have the tasks of evaluating the public comments on the ANPR and responding to the Massachusetts vs. EPA decision regarding endangerment. An advisor to President Obama has been reported to support regulation of GHGs under the CAA if Congress has not acted within 18 months. President Obama also reportedly would grant the California waiver. EPA could consider regulating sectors such as petroleum refiners, cement kilns, and power plants using NSPS and could reconsider its interpretive memorandum in response to the EAB Deseret decision. The EAB will hear additional cases involving GHG regulation under the CAA. If and when GHGs are regulated under the CAA, new and modified sources could be affected almost immediately under PSD requirements, and soon thereafter through Title V permitting requirements. Meanwhile, Congress will consider legislation that will be linked to the CAA in unknown ways. We strongly believe that comprehensive federal legislation is preferable to the use of the CAA for accomplishing our nation s climate goals, because well-designed climate legislation can consider GHG emissions reductions economy-wide within the context of the current and projected economic situation, the availability of technology, the reliability of the country s power sector and energy supply, and other relevant factors that do not readily fit in a CAA context. Finally, with continued federal uncertainty, states and regions will take regulatory and legislative actions further addressing GHGs on a patchwork basis, with fossil-fuel power plants among the most likely affected regulated entities. em Were EPA to regulate GHGs under any major provision of the CAA, the domino effect implications likely would be severe. References 1. The State of Massachusetts et al. vs. U.S. Environmental Protection Agency, U.S. Supreme Court No Argued November 29, 2006 Decided April 2, See 2. Energy Independence and Security Act of 2007, Pub.L , December Select Committee on Energy Independence & Global Warming hearing, Massachusetts vs. U.S. EPA Part II: Implications of the Supreme Court Decision, March 13, See 4. See for a copy of the letter, dated January 23, See for press release announcing the petition. 6. Advance Notice of Proposed Rulemaking: Regulating Greenhouse Gas Emissions under the Clean Air Act; EPA-HQ-OAR ; U.S. Environmental Protection Agency: Washington, DC, July 11, See 7. California State Motor Vehicle Pollution Control Standards; Notice of Decision Denying a Waiver of Clean Air Act Preemption for California s 2009 and Subsequent Model Year Greenhouse Gas Emission Standards for New Motor Vehicles. Final Notice; Fed. Regist. 2008, 73 (45), See 8. Longleaf Energy Associates vs. Friends of the Chattahoochee, Docket No. OSAH-BNR-AQ , Georgia Superior Court, June 30, See 9. Swanson, E. Energy Debate, Round 2: Kansas Legislature Likely to Consider Coal-Fired Plants Again This Year; Dodge City Daily Globe, January 7, See See Audubon(Consolidated)/ _Exhibit_2_ADEQ_Response_to_Comments.pdf. 11. House Subcommittee on Energy and Air Quality hearing, Strengths and Weaknesses of Regulating Greenhouse Gas Emissions Using Existing Clean Air Act Authorities, April 10, See Climate Change Draft Legislation, dated October 7, See See Environmental Integrity Project vs. EPA, Nos , (D.C. Cir. 2008). 15. See See C8C D8096E A7/ $File/Remand...39.pdf. 17. See More information on each of the cases currently before the U.S. Environmental Protection Agency s Environmental Appeals Board can be found online at Advance Notice of Proposed Rulemaking: Regulating Greenhouse Gas Emissions under the Clean Air Act; Fed. Regist. 2008, 73, (July 30, 2008). See awma.org Copyright 2009 Air & Waste Management Association february 2009 em 33

36 em inside the industry by Anthony Buonicore and Dianne Crocker Anthony J. Buonicore, P.E., DEE, QEP, is chairman and CEO of the Buonicore Group, a real estate and environmental risk management consulting company. ajb@edrnet.com. Dianne P. Crocker is managing director of the Market Research Group at Environmental Data Resources Inc. (EDR) in Milford, CT. dcrocker@edrnet.com. How to Recession-Proof Your Business News about the economy seems to get worse by the day. In the latest bit of dismal news, reports are circulating that today s recession is the longest and most severe the United States has seen since the end of World War II. To avoid setting a new record, recovery would need to take root by this coming May, and the latest forecasts make that scenario an unlikely one. Commercial real estate transactions are forecast to be down one-third below 2008 levels, property values continue to fall, record-high job losses are being posted, and there s virtually no credit being extended to anyone could turn out to be one of the toughest years we ve faced in the environmental consulting world in a long time, and there s unfortunately not much we can do about it. What s an environmental consultant to do? Either sit around lamenting how slow business is, or focus on the things we can control. Below is a list of tips for surviving the recession and positioning your firm for growth. Increase Client Outreach Consulting is above all a relationship-driven business. That means you ve got to actively cultivate meaningful relationships with a great deal of personal outreach by being there for your clients, touching base periodically, and bringing value to your communications. You can do this in any of a number of ways, including sending articles of interest on key industry topics, alerting clients to upcoming webinars or conferences, and sharing new expertise that you or your firm have obtained. This type of communication can be much more valuable in today s market than just picking up the phone to ask an old client, Do you have any work for me? Also, when the market does pick back up again (and it will it always does), there s a good chance clients will remember you for reaching out in an informative way during the downturn. Find the Bright Spots There are a number of environmental issues that are gaining momentum right now. At the top of the list are climate change, energy efficiency, and greenhouse gas emission reductions. Recent studies indicate that companies that score well on various environmental metrics also demonstrate above-average return on investment and stock performance. So, even as the U.S. government recently failed to pass legislation limiting carbon emissions, U.S. companies, led by giants like General Electric, Wal-Mart, Google, and DuPont Chemical, have been launching new green initiatives. Environmental concerns have suddenly emerged as a dominant driver of global corporations, signaling a new level of seriousness about sustainability, which opens up myriad opportunities for environmental consultants. Green building and Leadership in Energy and Environmental Design (LEED) certification is another area getting a great deal of attention. More than 100 cities already have their own climate change/green building initiatives, approximately half of which have specific green building requirements. What this means to your clients is that if they are refinancing or buying a building, they need to pay attention to whether the building complies with applicable local green building initiatives. Opportunities are already emerging for consultants to verify LEED principles and LEED certification strategies for builders, lenders and investors; analyze the financial impact of LEED certification; provide professional opinions on sustainability features of buildings and the cost to maintain performance; and provide compliance assistance related to local green codes and ordinances. Now is the time to build expertise in new areas so that your firm has the skill set it needs to stay competitive as new markets gain traction. A number of consultants are pursuing LEED 34 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

37 accreditation so that they possess the skills necessary to meet client needs in these areas. Reactivate Past Clients It s likely that you have clients whom you have worked with once and then never had contact with again. And it may not be because the client was dissatisfied with your service. Instead, those clients may not be aware of the other services you have to offer that they could use. E-newsletters can be an extremely effective way of keeping past, present, and even future clients up to date on what your company is doing, the latest trends impacting their business, and new areas of expertise. Avoid Competing on Price In a recession, price competition becomes even more pronounced. Avoid playing this game at all costs. Stack the cards in your favor by being unique in a way that clients value. It could be that you re the only consultant in the area offering a one-stop shop or who can guarantee results on a quick turnaround or offer some specialized local expertise. Maybe you have stellar referrals from past clients that your competitors do not. Whatever it is, make your offer unique and don t compete on price. Once you lower your prices, it is very difficult to raise them when the market recovers. Engage Existing Employees When business is down, it can be tempting to cut labor costs by laying off staff. This should be done as an absolute last-resort measure. Do everything you can to make sure employees are engaged and committed to their job despite the tough economic climate. Focus your limited resources on keeping and rewarding key talent. These are the people you need most now to get you through the difficult times. When the market improves, your firm will need to be able to meet clients demands without having to go out looking for qualified staff to fill positions vacated during the recession. Keep Recruiting Quality Consultants Similarly, maintain your recruitment stance during the recession. You may not be actively looking for new hires, but if you discover excellent candidates, it still might make sense to recruit. Plus, you want your staff and prospective new hires to view your firm as a successfully growing one, even during difficult times. Resist the Temptation to Slash Marketing The economy is going to continue to struggle. This means fewer projects overall being fought over by the same number of consulting firms. Stealing market share away from the competition should therefore be your primary focus. If you stop marketing altogether, your firm will not be noticed. Do everything you can to make marketing efforts more efficient and cost effective. And, give priority to plans designed to generate short-term revenue, as well as position the firm for longer term opportunities. Get Linked-In There are a number of business networking sites in all kinds of fields, including real estate, architecture, and environmental consulting. It s a free way to get your name out there, get in touch with prospective clients, and keep up with market trends. The best thing about them is that they re typically free. They merely require some upfront time to connect with other professionals, prospective clients, and industry insiders. Unless your company is already recession-proof, these are some things you should be thinking about now to keep it going. It will be time well spent! em REACH OVER 8,500 ENVIRONMENTAL PROFESSIONALS EACH MONTH! EM readers are industry leaders with buying power. Contact Malissa Goodman at mgoodman@awma.org, or , to find out how advertising in EM can get your company the exposure it needs in Now is the time to build expertise in new areas like LEED to stay competitive. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 35

38 em it insight Balancing Business Needs and Information Security by Jill Barson Gilbert Jill Barson Gilbert, QEP, is president of Lexicon Systems, LLC. We use smart phones and handheld devices to stay connected when out of the office and flash drives to take files on the road. We log onto wireless networks and routinely back up notebook computers onto small, portable hard drives. We export data from enterprise databases to spreadsheets for further analysis or reporting. We want information at hand 24/7 for decision support, yet the technologies that make it accessible can let sensitive information leave the organization. Information security, part of a growing strategic initiative called data governance, is a top business priority. A Fine Balance Information technology (IT) lets us work and collaborate in ways that we could not have imagined just a few years ago. Networks, hardware, and software provide anytime, anywhere access and data portability. We use networks to deploy, access, and use information, software applications, and resources. The amount of information grows each year, and we extend access to users within and outside of our organizations. Good data governance requires increased diligence in protecting information. The challenge is to provide access to information, applications, and systems, while balancing the acceptable level of risk and optimizing costs (see Figure 1). Enterprise information is a precious commodity that helps businesses gain competitive advantage. Likewise, IT can provide an advantage. As environment, health, and safety (EH&S) managers, as with other business functions, we must protect information assets from security vulnerabilities. We want to avoid threats such as e-discovery, business interruption, fines, and other legal actions that can result from information theft or loss. Leaky Pipes Think of information management as a system of reservoirs and pipes to deliver data when someone turns on the tap. Then consider that parts of the systems are not on a preventive maintenance schedule, so leaks may occur. Further, system users may fill a to-go cup with some of the information. Most organizations suffer from data leakage, much of it unintentional. Data leakage can occur when notebook computers, smart phones, and other portable gadgets are lost or stolen. Data leakage can result from transporting data on CDs, flash drives, and portable hard drives or transposing data from one system to another. Portable data storage particularly unsecured devices opens the door to e-discovery (see IT Insight E- Discovery Rules Reach Beyond Litigation, EM August 2007, p. 24). Transparency Thousands of internal and external EH&S compliance requirements call for good data governance or, to put it in terms that EH&S professionals understand, managing information from cradle to grave. We must know where the information resides, who has access to it, who modifies it and when, and what is reported. We strive for total data transparency (i.e., a single version of the truth). Common practices like using spreadsheets and one-off databases, using local hard drives, portable hard drives, and flash drives defeat transparency. Potential business risk from data leakage makes a good case for using secure enterprise software. Information resides in a single database armed with security, backup, and recovery measures. People who need to access the information are issued a user ID and password. This works well, until someone decides to export data from the enterprise application to a spreadsheet. With today s robust 36 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

39 ad hoc reporting tools and dashboards, this should not be necessary. , Internet, and the World Wide Web A 2005 study by research company IDC found that Web browsing is the single largest threat to information security. An EH&S professional s daily routine includes the Internet. We try to access a Web site, only to have it blocked. We find an article that can be viewed, but not downloaded. As long as software contains security vulnerabilities, hackers will continue to generate malware. As viruses, Trojans, and other malware make enterprise information vulnerable to theft or attack, we have security software in place. Keeping up with malware generally conveyed via , the Internet, and the World Wide Web is an uphill struggle. An entire industry exists, whose purpose is to identify malware, write programs to combat it, and distribute malware databases daily. Computer Associates, McAfee, and Symantec are some of the vendors who combat malware. Until recently, the chief method to address the issue was to blacklist identified threats. This reactive approach has limitations; its effectiveness depends on identifying the malware before it invades computers and networks. Today, several vendors sell whitelisting software that takes a proactive approach (see sidebar Malware 101 opposite). Data Governance Helps Manage Risk Sound data governance is the best way to manage risk associated with information. Organizations must develop, implement, and enforce data governance policies and procedures. They must educate staff particularly those who access the information about information access and security. And organizations must keep physical security, hardware, and software controls up to date. It does not matter how good your information security solutions are, unless they are active, up-to-date, and their use is enforced. The Information Age and its technical capabilities have inherent risks. EH&S professionals must implement and enforce data governance policies and procedures to manage these risks, while balancing the needs of different stakeholders to access and share information. em Figure 1. IT must address multiple, often conflicting, business goals. Source: Sun Microsystems Inc., The Complete Buyer s Guide for Identity Management, October Malware 101 Malware is not defective software, but software developed for malicious purposes. Here are a few common terms: Malware: short for malicious software, a program or file designed to damage or disrupt a system, such as a virus, worm, or a Trojan horse. A general term used by computer professionals to mean a variety of forms of hostile, intrusive, or annoying software or program code, computer viruses, worms, Trojan horses, most rootkits, spyware, dishonest adware, crimeware, and other malicious and unwanted software. Computer virus (virus): a computer program that can copy itself and infect a computer without permission or knowledge of the user. Viruses usually corrupt or modify files on a targeted computer. Trojan horse (Trojan): malware that appears to perform a desirable function but, in fact, performs undisclosed malicious functions. A worm or a virus may be a Trojan horse. Computer worm (worm): a self-replicating computer program that uses a network to send copies of itself to other computers on the network, possible without user intervention. A worm does not need to attach itself to an existing program and usually causes harm to the network, if only by consuming bandwidth. Antivirus software: tracks and quarantines harmful objects based upon blacklisting and active scanning for known threats and suspicious behavior. Blacklisting: an IT security approach where a black list identifies banned applications and other executable programs. Whitelisting: an IT security approach where a white list identifies safe applications and executables. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 37

40 em annual conference preview Students and Young Professionals: ACE Is the Place to be in June! A&WMA s 2009 Annual Conference & Exhibition (ACE) is the perfect place for students and young professionals (YPs) to get the latest technical information and have their voices heard by industry leaders and A&WMA leadership. In these uncertain economic times, there has never been a more urgent need for current and future environmental professionals to network with colleagues in the field, present and publish work, and further their professional education. Need assistance funding your trip? Help A&WMA and work as a session monitor to receive discounted conference rates. Visit the ACE Web site for more information or to download the monitor registration form. ACE2009 ACE 2009 is the perfect place to do all of these things while also having a great time! The YP and student programs for 2009 have just the right mix of intensive technical sessions and courses, and relaxed social and networking events. Whether you re looking for career advice, technical knowledge, or a new contact or two, ACE is the place to be in June. Get Recognized Exceptional students and YPs have many opportunities at ACE to be rewarded for their work. Each year, a deserving YP is awarded the Outstanding Young Professional Award at the annual Honors and Awards Luncheon. Master s and doctoral students can participate in the Platform Paper Award program, and be nominated for the first-ever Master s and Doctoral Thesis Awards. Undergraduate, master s, and doctoral students can participate in the Student Poster Contest, and build their professional portfolios and win great prizes by participating in one of ACE s most exciting events, the Environmental Challenge International (ECi), a team competition that asks student teams to develop a multidisciplinary solution to a real-life environmental issue. This year s ECi asks student teams to solve a garbage dispute between two dueling cities. If you think you re up to the challenge, visit ACE2009 to find out more about this problem. Over US$15,000 in prize money was awarded last year, so don t miss your chance to participate! Advance Your Career Careers and job opportunities are always on the minds of YPs and students hoping to break into the field. With the worldwide economic instability impacting all job markets, networking and seeking advice from professionals has taken on renewed importance. ACE is a great place to gain valuable career advice and to make connections that could lead to jobs in the future. Driving Environmental Progress: What Can Students Do? A&WMA s High School Essay Contest A&WMA s 2009 High School Essay Contest gives students nationwide in grades 9 12 the chance to share their thoughts on environmental issues and win great prizes. Essays can be up to six pages in length, and should describe the role that students can play in driving environmental progress. The author of the best essay will win US$400, receive a first-place certificate, and have an excerpt of their essay published in EM. Awards will be announced during the Student Awards Ceremony and Reception at ACE. Essays are due on Earth Day, April 22, Visit for more information. 38 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

41 If you re looking for personalized advice, bring your resume to the conference and join Julie Sharp, an associate professor at Vanderbilt University, for a resume critique. YPs are invited to attend Shifting Gears A YP Panel Discussion on Career Options, and to join a career coach and a panel of young professionals. Hear personal stories from professionals who have changed careers as they share the positive and negative aspects of making the jump. Throughout the week there are plenty of opportunities for students and YPs to mingle with seasoned veterans and exchange career advice and business cards. Don t Forget to Have Fun Though we encourage attendees to soak in as much technical information as possible during the conference, we know that attending your choice of the over 500 technical sessions offered at ACE can get overwhelming. Make sure that you get all of the technical information you came for, while also making time to kick back and relax with your peers. This year s conference offers plenty of fun social opportunities for all attendees, including some designed just for students and YPs! End a busy day at ACE and join your fellow students and YPs for dinner and drinks at one of Detroit s finest brew pubs, the Detroit Beer Company, located in the heart of the theatre and stadium district. Relax and mingle with your peers from around the world while enjoying some of the local flavor of Detroit. Another exciting event just for students and YPs is the kayak tour through the Rouge River. Offered on Monday and Friday, this seven-mile excursion will give participants a unique view of the Ford Rouge Plant, Zug Island, and other local industrial sites. These are just a sampling of the events offered at ACE, so be sure to visit to find out more about this year s conference. em Save on expenses and time in 2009 Attend one of A&WMA s e-learning courses and enhance your professional knowledge from the comfort of your ownhomeoroffice! A&WMA s e-learning courses run throughout the year and cover a wide range of timely industry topics. Courses include: Boilers, Process Heaters, and Air Quality Requirements NOx Control for Industrial and Utility Applications Environmental Practices Review Internal Environmental Auditor Relax and mingle with your peers from around the world while enjoying some of the local flavor of Detroit. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 39

42 em association news by Miriam Lev-On and David Calkins Miriam Lev-On, The LEVON Group, LLC, and David Calkins, Sierra Nevada Air Quality Consultants, are Co-Chairs of A&WMA s International Affairs Committee. E- mail: miriam@levongroup.net; davecalkins@comcast.net. Better Air Quality for Asian Cities 2008 (BAQ 2008) November 12 14, 2008 Bangkok, Thailand Key Organizers: Bangkok Metropolitan Administration (BMA), Thailand Pollution Control Department (PCD), Clean Air Initiative for Asian Cities (CAI-Asia), Asian Development Bank, United Nations Environment Program (UNEP), United Nations Economic and Social Commission for Asia and the Pacific Supporting Organizations: A&WMA, U.S. Environmental Protection Agency (EPA), U.S. Agency for International Development (USAID), Health Effects Institute (HEI), International Energy Agency (IEA) Conference Highlights: Better Air Quality for Asian Cities 2008 The BAQ conferences have become the most significant gatherings to address air quality management in Asia. More than 1000 people from 43 countries participated in the 2008 conference. Approximately 30% of the participants came from outside Asia. Asian delegations included representatives from China, India, Indonesia, Nepal, Pakistan, Philippines, Vietnam, Sri Lanka, and the host country, Thailand. The BAQ 2008 technical program featured plenary sessions, along with subplenary sessions and working group sessions for more interactive and in-depth discussions. A total of 225 presentations were given, spread over three days. The Second Governmental Meeting on Urban Air Quality in Asia was convened alongside the technical conference, creating an opportunity for interaction among key national and local government officials, academia, development agencies, and nongovernmental organizations. During the two days preceding the conference, sponsoring organizations, including A&WMA, organized preconference workshops with a focus on projects to enhance air quality management in Asia. Air Quality and Climate Change The theme of BAQ 2008, Air Quality and Climate Change: Scaling Up Win-Win Solutions for Asia, was directly related to the recommendation of the Intergovernmental Panel on Climate Change to integrate air quality management and climate change policies. The conference was organized around three main streams: air quality management and climate change; transport and climate change; and stationary sources and indoor air pollution. seems to resonate with both national governments and local air quality stakeholders in the region, as they see such integration as an opportunity to leverage resources and advance progress. The major perspectives from the different sessions were highlighted during the closing session. These included linkages between local air quality and climate change are beginning to be better understood, but the issue of scale (local vs. global concern) has resulted in a disconnect between the groups that address these; interactions between air quality and climate change need to be considered, and synergies identified; adopting a co-benefits approach offers win-win solutions; and voluntary agreements can produce measurable improvements in air quality. A summary report of BAQ 2008, published by the International Institute for Sustainable Development, provides a more comprehensive summary of the conference (see ymbvol159num1e.pdf). All conference presentations, press releases, and reports can be found on the conference Web site, The key phrase of co-benefits of managing air quality and climate change in an integrated fashion was repeated numerous times throughout the conference sessions and presentations. This concept A&WMA s Activities in Asia A&WMA s international activities aim to promote the Association s goals of being recognized as the source of credible environmental information and Photo: Skyline of Bangkok Thailand. 40 em february 2009 awma.org

43 knowledge, as well as being a leader in creating strategic partnerships to advance the collective success of the environmental community. A&WMA s activities during BAQ 2008 were designed to make attendees aware of the Association as a resource they can turn to for valuable information on various air quality and waste management issues. In addition to hosting an Association booth, as a supporting organization, A&WMA helped organize and chair a preconference workshop and conference session. Several A&WMA members, including President C.V. Mathai and A&WMA Board member Judith Chow, gave presentations. In addition, A&WMA s International Affairs Committee Co- Chair, David Calkins, and member Alan Gertler, worked on the reporting committee and played key roles in the conference s final plenary session. A&WMA s activities in Asia over the past several years have focused on professional development. These activities have included a collaboration with EPA on a training workshop on stationary source emissions inventories (at BAQ 2006) and a trip to Beijing (in 2007) by A&WMA s Professional Development Chair to conduct a training needs assessment for the Chinese EPA (SEPA), in collaboration with CAI-Asia. For BAQ 2008, A&WMA worked with CAI-Asia to expand the China needs assessment effort and organize a joint workshop for all Asian countries on training needs on air quality management in Asia. The workshop was held on November 10, 2008, at the main conference venue in Bangkok, Thailand. Over 40 people attended the workshop, including representatives of EPA, the World Bank Institute, governmental aid agencies, academia, and members of CAI-Asia and country networks. Participants came from Australia, China, Germany, India, Indonesia, Israel, Nepal, the Netherlands, New Zealand, Pakistan, the Philippines, Sri Lanka, Thailand, Vietnam, and the United Kingdom. The workshop discussed barriers to air quality management training and capacity building in Asia, thematic content and training delivery mechanisms for different target groups, and how to design a sustainable training system and scale up training efforts in Asia. The workshop enabled a wide-ranging discussion among participants, and included presentations by training providers and a summary of a mini-survey conducted by CAI-Asia to assess countries views and highlights by Asian local country networks representatives about their training needs. Future Collaboration A&WMA has a longstanding collaboration with CAI-Asia and its country networks. This includes A&WMA s presence at previous BAQ meetings and CAI-Asia s participation in A&WMA annual conferences and specialty conferences. A&WMA s International Affairs Committee will be working with CAI-Asia in the future to act on the common themes and recommendations. Future collaboration with EPA on training is expected. All future activities and plans will depend on the availability of funding. It is perfectly clear that when undertaking collaborative efforts especially in the international arena continuity and persistence are essential. A&WMA s multi-year collaborative effort with CAI- Asia and its BAQ gatherings is starting to bear fruit in terms of recognition of how A&WMA, via its organizational model, resources, and access to air quality experts, can contribute to professional development in emerging economies. Although the benefits from such activities cannot always be immediately quantified, they are invaluable to enhancing the Association s reputation and advancing its products and services to both governmental and nongovernmental participants. Ultimately, such efforts are essential to meeting the Association s goals of sharing its knowledge and becoming a recognized contributor in advancing the environmental profession worldwide. em A Brief History of BAQ Conferences BAQ 2002: December 4 16, 2002, in Hong Kong, addressed air quality monitoring, control of stationary source pollution, motor vehicle emissions control, institutional arrangements for air quality management, and climate change. BAQ 2003: December 17 19, 2003, in Manila, the Philippines, addressed air quality monitoring and management, institutional capacity, mobile sources, and stationary sources. BAQ 2004: December 6 8, 2004, in Agra, India, concluded with commitments from 11 countries to take specific steps to improve their air quality. BAQ 2006: December 13 14, 2006, in Yogyakarta, Indonesia, included the First Governmental Meeting on Urban Air Quality in Asia, which discussed common challenges in urban air quality management and ways to harmonize methods and standards on urban air quality management in the region. awma.org february 2009 em 41

44 em epa research highlights Two ETV centers focus exclusively on verifying technologies related to air: the Air Pollution Control Technology Center and the Greenhouse Gas Technology Center. Verifying New Technologies for Air Pollution and Greenhouse Gases In an ever-increasing number of areas, the potential for aligning market forces with environmental protection is growing. Many venture capitalists point to the development of green technologies as one of the few bright spots in a slowing economy. New technologies for preventing, controlling, and monitoring air pollution and greenhouse gases are among the most attractive targets. One of the biggest hurdles to successfully bringing new technologies into the marketplace, however, is developing the credible, high-quality performance data that purchasers, regulatory bodies, financiers, and vendors require before investing in new technologies. To help new technologies enter a risk-adverse marketplace, the U.S. Environmental Protection Agency (EPA) established the Environmental Technology Verification (ETV) Program. The ETV Program Established in 1995, the goal of the ETV Program is to accelerate the acceptance of new environmental technologies entering the marketplace by supplying data verifying their performance. The program is managed by EPA s National Risk Management Research Laboratory (NRMRL), part of the agency s Office of Research and Development. NRMRL engineers and scientists provide oversight of verification tests, assuring the credibility of the program as a whole, including quality assurance processes and data. ETV verification establishes or proves the truth of performance of a technology under specific, predetermined criteria and testing protocols. Verification reports and statements are free and open to the public through the ETV Web site, The ETV Program operates through a number of public private partnerships between EPA and private, nonprofit testing and evaluation organizations. Working together, technical experts from EPA and their partners develop efficient and quality-assured protocols and test plans for verifying technology performance. ETV partners are responsible for planning and performing the verification tests, as well as developing verification reports and statements designed to effectively communicate test results to interested stakeholders and end-users. Technology Verification Centers ETV operates verification centers that test technologies across a broad range of categories. The centers operate with the assistance of stakeholder committees whose members are drawn from diverse backgrounds, such as state and local regulatory agencies, industry, academia, environmental groups, and investment companies. Stakeholders help prioritize environmental technology needs, identify commercially available products that meet those needs, and develop test plans. Once a technology category has been prioritized for verification, a call for vendors is announced and vendor applications are received. Then, input from stakeholders is incorporated into a test/quality assurance plan that is reviewed by participating vendors and EPA representatives. An appropriate test location(s) is selected and the equipment is tested using procedures outlined in the test/quality assurance plan. A verification report and statement are developed by the ETV centers and reviewed by EPA, the participating vendor, and peer reviewers. Vendors and others in the private sector, as well as federal, state, and local government agencies share costs to complete protocols and verifications. Verification Centers for Air Two ETV centers focus exclusively on verifying technologies related to air: the Air Pollution Control Technology Center and the Greenhouse Gas Technology Center. Air Pollution Control Technology Center (APCT). Operated in cooperation with RTI International, APCT verifies the performance of commercial-ready technologies designed to control stationary and mobile air pollution sources and to mitigate the effects of air pollutants. Control technologies APCT addresses include diesel engine emission control devices, outdoor wood-fired hydronic heaters, dust suppression and soil stabilization products, paint overspray arrestors, and indoor pollution mitigation products. APCT readily shares its findings with stakeholders and potential users of tested technologies. The APCT Web site, posts the names of stakeholder group and technical panel members, as well as the minutes from their meetings, verification protocols, test/quality assurance plans, verification reports, verification statements, recent publications, and other relevant documents. To date, APCT has verified the performance of 52 technologies and posted the verification results on its Web site. 42 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

45 The center also maintains a database of contact information of more than 900 air pollution control technology developers, vendors, and other interested parties. Please contact APCT through the Web site to be added to the database. Greenhouse Gas Technology Center (GHG). Operated in cooperation with Southern Research Institute, GHG provides independent performance testing of technologies that produce, mitigate, monitor, or sequester greenhouse gas emissions. Since 1997, GHG has located promising greenhouse gas mitigation and monitoring technologies, subjected them to independent, third-party performance testing, and provided the results to the public free of charge. The center has completed or initiated verifications of 36 environmental technologies, such as microturbines, fuel cells, and ground-source heat pumps for distributed generation; and fuel additives for increased fuel efficiency. For more information on these technologies or on the center, visit the GHG Web site at Other Verification Centers While APCT and GHG focus their efforts exclusively on investigating technologies for air, other ETV verification centers include air technologies as part of a broader suite of verification efforts. The Advanced Monitoring Systems Center (AMS), operated in cooperation with Battelle, verifies the performance of commercial-ready technologies that monitor contaminants and natural species in air, water, and soil. The center tests both field-portable and stationary monitors, as well as innovative technologies that can be used for site characterization. To date, AMS has verified 60 technologies for monitoring air contaminants such as ammonia, particulate matter, hydrogen sulfide, dioxin, and others. The AMS Web site is Other ETV centers include the Drinking Water Systems Center, the Water Quality Protection Center, and the newlyformed Materials Management and Remediation Center. International interest in verification is growing. In addition to the U.S. ETV Program led by EPA, Canada, the European Union, Japan, Korea, the Nordic countries, and the Philippines have developed fully operating or pilot verification programs. Additional countries have also expressed interest in developing verification programs. Learn More About ETV Sharing research results and outcomes with interested stakeholders and end-users is one of ETV s primary goals. The ETV Web site provides verification reports and statements, protocols and test plans, stakeholder information, meeting summaries, and other important resources. In addition, ETV distributes monthly newsletters using the program s listserv, ETVoice, to inform subscribers about the availability of new information on recent technology verifications, future events, vendor solicitations, and highlights of the ETV Program. To join the listserv, send a blank to join-etvvoice@lists.epa.gov. Teresa Harten, Abby Waits, Scott Fogle, and Patrick Hurd contributed to this month s column. It was written by Aaron Ferster, Science Writer-Editor with EPA s Office of Research and Development in Washington, DC. em For more information on the research discussed in this column, contact Deborah Janes, Public Information Officer, U.S. Environmental Protection Agency (B205-01), Office of Research and Development, Research Triangle Park, NC 27711; phone: ; janes.deborah@epa.gov. Disclaimer: Although this text was reviewed by EPA staff and approved for publication, it does not necessarily reflect official EPA policy. In Memory of A&WMA Member Douglas A. (Doug) Wolf Doug Wolf joined the Association in September 2000 and was an active member of the Genesee Finger Lakes Chapter, part of the Niagara Frontier Section, until the time of his death in November Doug was a senior environmental project engineer with Corning Inc. in Corning, NY. He loved the outdoors, was an avid hunter, and a motorcycle enthusiast. Doug is survived by his wife Sabra and daughter Jamie. In lieu of flowers, the family has requested that donations be made to Jamie s college fund. The Chapter has agreed to match donations to the fund up to US$500. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 43

46 em washington report Report Shows Rise in Emissions, Decrease in GHG Intensity Greenhouse gas (GHG) emissions from the energy and industrial sectors increased by 1.4%, or million metric tons, from 2006 to 2007, according to an annual report released by the Energy Information Administration (EIA), the statistical arm of the U.S. Department of Energy. The report noted that most of the increase came from an increase in emissions of carbon dioxide. GHG intensity, a measure of how much GHG is used per million dollars of domestic product, decreased by 0.6% from That decrease is the smallest since According to the report, GHG intensity has decreased an average of 2.1% per year since 2002, for a total of 9.8% from 2002 to President Bush set a goal of reducing GHG intensity 18% by While GHG emissions increased 1.4% from 2006 to 2007, economic output increased 2% during the same time, the report said. Carbon dioxide emissions increased by 1.3% for a total of million metric tons in The report attributes the rise to several factors, including weather requiring more days of heating or cooling than in A tax on GHG emissions combined with other emissionsreducing measures is the best way to reduce GHG concentrations, according to NASA s James Hansen. NASA Scientist Calls Carbon Tax Best Way to Curb GHGs A tax on GHG emissions combined with other emissions-reducing measures is the best way to reduce GHG concentrations to a safe level, said James Hansen, NASA s top climate scientist, at a briefing hosted by the Environmental and Energy Study Institute. A cap-and-trade program is the central element of the congressional bills that have gained traction over the past year. However, Hansen and other speakers said a cap-and-trade program offers too many opportunities for manipulating the system, would be too expensive, and would not provide sufficient incentive for technological innovation. The speakers suggested an upstream carbon tax one that would be levied on the producers of oil, gas, and coal rather than on those who use the fuels. A carbon tax has long been trumpeted by economists as the solution that would make the most sense economically, but politically, the cap-andtrade system has received more attention. Some have argued that a cap-and-trade system is better for the environment than a carbon tax. Hansen said benefits of the tax would outweigh the costs. DOJ Says EPA Has Authority to Order Defense Site Cleanups A letter from the U.S. Department of Justice (DOJ) confirming the U.S. Environmental Protection Agency s (EPA) authority to issue cleanup orders to the U.S. Department of Defense (DOD) means that federal facilities long in need of remediation will get the attention they need, an EPA official said. Susan Bodine, assistant EPA administrator for solid waste and emergency response, said DOD and EPA have been unable to reach a federal facilities agreement on the cleanup of installations on EPA s National Priorities List of Superfund sites. Those sites include Fort Meade in Maryland, Maguire Air Force Base in New Jersey, and Tyndall Air Force Base in Florida. In May, DOD wrote a letter to the DOJ asking the attorney general to resolve a dispute with EPA concerning four orders issued by EPA under the Resource Conservation and Recovery Act and the Safe Drinking Water Act. EPA issued final orders to the Pentagon in 2007 ordering cleanups of the sites. DOD argued that EPA did not have the legal authority to compel the cleanup. But in the letter to the DOD, Steven G. Bradbury, principal deputy assistant attorney general, quoting the U.S. Code, wrote that EPA is permitted to issue such orders as may be necessary to protect public health and the environment. Federal facilities agreements are required under the Comprehensive Environmental Response, Compensation, and Liability Act, and they are enforceable by EPA. em Compiled by Mark Williams The Bureau of National Affairs, Inc. 44 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

47 em news focus Jackson Pledges Review of EPA Policies Lisa Jackson, named by President-Elect Obama as the new U.S. Environmental Protection Agency (EPA) Administrator, pledged Jan. 14 to conduct expedited reviews of a range of existing agency policies and suggested that she would reverse many of them, but she resisted making specific commitments. Testifying before the Senate Environment and Public Works Committee, Jackson said that, if confirmed, she would commit to a review of EPA s refusal to grant California a Clean Air Act (CAA) waiver to implement its own greenhouse gas (GHG) emissions limits for vehicles very soon after taking the job, and that science and the law would be her criteria for deciding whether to reverse the decision. Jackson said she would not prejudge the issue. Obama has pledged to reverse the Bush administration decision to block the California standards. In a wide-ranging hearing before the Senate committee, Jackson touched on a number of issues ranging from climate change to air and water pollution, and she responded to questions regarding White House review of EPA regulatory actions. Jackson also addressed issues related to the Superfund program. Committee Chairman Barbara Boxer (D-Calif.) said she will seek unanimous Senate consent to discharge Jackson s nomination from the committee for a floor vote by Jan. 20, when Obama takes office, or shortly thereafter. The committee also heard from Los Angeles Deputy Mayor Nancy Sutley, chosen by Obama to head the White House Council on Environmental Quality. Jackson to Explore CAA Rules Addressing Jackson, Boxer asked if the EPA Administrator-designate would commit to using all the tools available in the CAA to reduce GHG emissions. Yes, Jackson said. I look forward to working with EPA staff to explore ways to reduce emissions. In contrast to President Bush, Obama supports legislation to cap GHG emissions and establish an emissions trading system. His advisers have also indicated he will initiate CAA regulation of GHGs, a step strongly resisted by the Bush administration, in the face of a Supreme Court order to make a determination on whether to regulate emissions (Massachusetts vs. EPA, 127 S. Ct (U.S. 2007)). Sen. Thomas Carper (D-Del.) asked Jackson if she would drop an EPA petition to the U.S. Supreme Court seeking review of a federal appeals court decision that overturned an agency rule setting up a trading system for mercury emissions from power plants (EPA v. New Jersey, U.S., No , 10/17/08). Mercury Rule Criticized Jackson said the EPA regulatory scheme for mercury did not comply with the CAA. Under her leadership, she said, the agency will work to fashion new regulations that would address effective mercury emissions reductions and hot spots, or areas with particularly high pollution. Jackson would not commit to dropping the Supreme Court petition, though, saying she welcome[d] an opportunity to look at the case. She said EPA ethics lawyers told her she may make decisions on the mercury lawsuit, even though she played a principal role in launching the lawsuit that brought down the EPA mercury rule. Until October, Jackson was commissioner of the New Jersey Department of Environmental Protection. New Jersey was the principle plaintiff in the case. CAIR Will Be Reviewed Jackson also said she would look at the Clean Air Interstate Rule (CAIR) with an eye toward making it stronger. The U.S. Court of Appeals for the District of Columbia Circuit in 2008 overturned CAIR, saying the rule, which established an emissions trading system to reduce nitrogen oxide and sulfur dioxide emissions from power plants in 28 states and the District of Columbia, did not comply with the CAA. The court modified its order in December, leaving CAIR in place temporarily until EPA makes the changes to the rule ordered by the court (North Carolina vs. EPA, D.C. Cir., No , rule remanded 12/23/08). Jackson said New Jersey is on record saying that more emissions reductions are possible through CAIR. As EPA Administrator, she said would look at the rule and see if it could be strengthened. Priorities would be to restore EPA s role in protecting health and the environment, take a hard look at the mercury rule and CAIR, and address climate change. >>Lisa Jackson, EPA Administratordesignate awma.org Copyright 2009 Air & Waste Management Association february 2009 em 45

48 The United States should take the first step and China very quickly follow in curbing GHG emissions. >>Steven Chu Energy Secretarydesignate Asked by Carper what her top clean air priorities would be, Jackson replied: to restore EPA s role in protecting health and the environment, to take a hard look at the mercury rule and CAIR, and to address climate change. by Steven D. Cook and Linda Roeder, BNA Chu Says United States Must Take Lead on Curbing GHGs The United States must take the lead in curbing GHG emissions under the next international climate deal before China, India, and other poorer developing nations accept emissions curbs of their own, President-Elect Obama s choice for energy secretary said Jan. 13. The United States should take the first step and China [must] very quickly follow in curbing emissions, Steven Chu, director of the Lawrence Berkeley National Laboratory, told the Senate Energy and Natural Resources Committee. If China doesn t follow, then we will have to re-look at this, Chu said at the confirmation hearing. Chu, who was warmly received by committee Democrats and Republicans alike, said it is imperative that the next international climate agreement include the United States and China because together, the two countries release more than 50% of the world s annual GHG emissions. China, the United States, and more than 180 other countries are to negotiate international emissions reductions throughout 2009 and have agreed to sign on to a new climate deal at a U.N. climate change conference in Copenhagen in December. If the U.S. and China don t get this right, then we can t move forward in combatting climate change, Chu said. He called climate change a growing and pressing problem, adding that it is now clear that if we continue on our current path, we run the risk of dramatic, disruptive changes to our climate in the lifetimes of our children and grandchildren. Chu said both countries are currently in a standoff position, with the United States in recent years insisting that China take on emissions cuts in any future climate deal, which would succeed the mandatory emissions curbs of the Kyoto Protocol. China, on the other hand, argues that the United States and other wealthier nations should cut emissions first, given that they have emitted the bulk of GHG emissions already in the atmosphere. China Action a Likely Sticking Point While it is up to the incoming Obama administration to negotiate U.S. commitments under of the next international climate agreement, the treaty still will need to be ratified by two-thirds of the Senate. Sen. Evan Bayh (D-Ind.), who is to join the energy committee in the 111th Congress, said the Senate would not approve any agreement that initially commits the United States to emissions curbs but not China. That approach will not be approved by us, Bayh said. He added that China does not have a great track record in honoring other agreements, including those protecting intellectual property. Chu said he recognized that China, India, and other developing countries have to be part of the solution in addressing climate change, but they will need assistance from wealthier countries to deploy low-carbon energy sources and improve energy efficiency. Chu also reiterated Obama s support for a capand-trade system that would cap and over time reduce U.S. GHG emissions and require industry to hold permits, or allowances, for each ton of GHGs they emit. He also pledged to work closely with Carol Browner, a former EPA Administrator whom Obama has selected to coordinate climate and energy issues for the White House. Sen. Bob Corker (R-Tenn.) said Browner should be asked to appear before the Senate energy committee at a later date to discuss the next administration s plans in the climate change arena. by Dean Scott, BNA EPA Limits Aggregation of Emissions to Reduce Use of NSR EPA announced a final rule Jan. 12 that limits some of the circumstances under which New Source Review (NSR) pollution control requirements apply to industrial facilities. The final rule retains existing rule language, but the preamble states that we are finalizing an interpretation of the existing rule language with respect to our policy on aggregation. NSR requires sources to install modern pollution controls when they make plant modifications that increase emissions. Equipment replacement projects often increase emissions because they allow 46 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

49 plants to operate for longer periods. The final rule contains an interpretation of existing rules saying different modifications at the same source should be aggregated to determine if new source review applies only when those different projects are substantially related, either from a technical or an economic standpoint. Scott Segal, director of the Electric Reliability Coordinating Council, said the rule stops the practice in EPA enforcement efforts of combining emissions from small projects at a source to push the source over the emissions threshold triggering NSR requirements. EPA proposed a rule in 2006 that sought to define the circumstances under which emissions increases from different modification projects at the same plant could be aggregated into one project. Environmental Coalition Opposed Proposal A coalition of environmental groups filed comments in 2006, saying that the proposed language limiting aggregation of emissions invites facilities to escape [NSR] by disaggregating related projects emissions will increase as more facilities take advantage of this new loophole. NSR applies for projects that increase emissions by 100 or 250 tons per year, depending on the source category. If several emissions increases from several separate modifications at the same source are aggregated, it could push the source over the new source threshold, triggering permitting and emissions control requirements. The proposed rule s definition stated that [p]rojects occurring at the same stationary source that are dependent on each other to be economically or technically viable are considered a single project. In the final rule, EPA said, we have concluded that the terms economically viable and technically viable, and what is meant to be economically or technically dependent, are difficult to define clearly and should not be adopted as regulatory bright lines. The agency said it is, therefore, not finalizing the proposed aggregation rule and is not adopting the descriptions of technical and economic viability and dependence that it proposed in We believe the statements made in this notice better explain the NSR Aggregation policy and enable permitting authorities and sources to better implement the current rule text without revision, the final rule said. Debottlenecking Provisions Withdrawn EPA withdrew provisions in the proposed aggregation rule that would have counted emissions increases only at the specific emissions unit being modified. Under this provision, known as debottlenecking, emissions increases in other units resulting from the modification would not have been counted. EPA also withdrew netting provisions that would have eliminated a requirement for sources to conduct a sourcewide survey to see if a plant modification would increase emissions. The survey would not have been required if the source determined that emissions increases would not be significant. In Next Month s Issue Special Focus: The Economy Is the recent downturn in the global economy having an effect on the U.S. environmental industry? With articles from several industry experts, EM considers what effect if any the economy is having on the various sectors of the environmental industry. Also look for Energy Efficiency EM looks at aging facilities and the pollution equipment decisions manufacturers must face to make their operations more energy efficient. PM File EPA Research Highlights Member Minute And a preview of the 2009 Annual Conference. News Focus is compiled from the current edition of Environment Reporter, published by the Bureau of National Affairs Inc. (BNA). For more information, visit awma.org Copyright 2009 Air & Waste Management Association february 2009 em 47

50 em ipep quarterly In comments on the proposal, the Natural Resources Defense Council, American Lung Association, and other environmental groups criticized the agency s proposal, saying that sources would decide themselves whether emissions increases would be significant, and they would not be required to keep records. The final rule says that projects are substantially related, when they are interconnected physically or operationally, or when the benefit of one project would be significantly reduced without the other project. Projects could not be aggregated if they occurred more than three years apart. Industrial and power-sector sources can now perform important maintenance activities at one time without worrying about possibly violating the NSR program, Segal said. The rule also provides certainty for industries in that it constrains EPA enforcement from reaching back and including past projects into present or future project in an effort to allege NSR violations. However, S. William Becker, executive director of the National Association of Clean Air Agencies, said, The final rule appears to contain the same serious defect as the proposal, namely that there are no reporting or record-keeping requirements that mandate the source share the basis for its aggregation conclusion with the reviewing authority. State and local permitting authorities are likely to face an uphill battle checking the source s determinations in the absence of regulatory reporting requirements, Becker said. by Steven D. Cook, BNA em EM Advertiser (www) page American Ecotech (americanecotech.com) , 27 Lakes Environmental Software Inc. (weblakes.com) Back Cover Met-One Instruments Inc. (metone.com) PKL Technologies Inc. (pkltechnologies.com) RTI International (rti.org) Since its inception in 1993, the Institute of Professional Environmental Practice (IPEP) has certified more than 1500 environmental professionals. IPEP s main certification is the Qualified Environmental Professional (QEP) credential. Candidates for the QEP certification must have a minimum of five years of relevant professional experience, and must pass a two-part written examination. Part I addresses general environmental science. Part II is taken in one of four practice areas: air quality; water quality; waste management; or environmental science, management, and policy. Senior environmental professionals with more than 15 years of relevant experience may qualify for the QEP credential by oral examination. In addition, IPEP offers the Environmental Professional Intern (EPI) credential for young and aspiring environmental professionals, particularly college seniors and recent graduates. EPI candidates are required to take only Part I of the QEP examination in general environmental science. EPIs then have up to seven years in which to take Part II and achieve full QEP certification. The QEP and EPI certification confirms that the recipient has demonstrated, through a rigorous application and examination process, a broad understanding of the environment and environmental issues. As a proud supporter of IPEP and the QEP and EPI certification, A&WMA congratulates the newest* QEPs and EPIs on their outstanding achievement. em QEPs Camilo Cruz, Atlanta, GA Chad Daniel, Des Moines, IA Craig Lugowski, Denver, CO Clare Lunn, Westford, MA Muneer Ahmad Nagoo, Jubail, Saudi Arabia EPIs Holly Shoup Bruch, Pipersville, PA Matt Kraus, Pittsburgh, PA Prabhat Lamichhane, Cincinnati, OH Andrew Martin, Charlotte, NC Erik Moral, Houston, TX Howard Redfearn, Mansfield, TX Lenn Roberts, Baltimore, MD *QEPs and EPIs certified after November 30, 2008, will be acknowledged in the May 2009 edition of IPEP Quarterly. The Institute of Professional Environmental Practice (IPEP) is a member of the Council of Engineering and Scientific Specialty Boards (CESB), an independant organization that accredits engineering, scientific, and technology programs. For more information about IPEP and the QEP and EPI certification, contact Certification Services Coordinator, IPEP, 600 Forbes Ave., 339 Fisher Hall, Pittsburgh, PA 15282; phone ; fax: ; ipep@duq.edu; web: 48 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

51 em professional development programs The below course is being held in conjunction with the specialty conference, First International Greenhouse Gas Measurement Symposium, March 22 24, 2009, San Francisco, CA. For more information about this conference, go to MARCH 22 (8:00 A.M. 5:00 P.M.) AIR-130: Emission Measurement Techniques for Greenhouse Gases (GHGs) from Area and Fugitive Sources Instructors: Drs. Ram A. Hashmonay, ARCADIS, and Eric Crosson, Picarro This course will review in detail open-path and point monitoring instrumentation capable of detecting greenhouse gases (GHGs), such as carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, hydro fluorocarbons (HFCs), and chlorofluorocarbons (CFCs). Among the techniques described are: open-path Fourier transform infra-red (OP-FTIR), open-path tunable diode laser absorption spectroscopy (OP-TDLAS), and cavity ringdown (CRD) techniques. This course will also discuss various measurement configurations for measuring emission fluxes of GHGs from area and fugitive sources. Call for Abstracts A&WMA Specialty Conferences Guideline on Air Quality Models: Next Generation of Models October 26 30, 2009 Raleigh, NC This conference will provide a technical forum for environmental professionals to share experiences with the proposed revisions to the U.S. Environmental Protection Agency s (EPA) Guideline on Air Quality Models. The Guideline is required for use in the preparation of state implementation plans, federal construction permits, and many state permits. EPA has adopted AERMOD and CALPUFF as the refined models for routine modeling applications. The user community is gaining experience with these models and further advances in modeling techniques and meteorological databases will be reported at this conference. In addition, advanced models used in international or specialized situations will be discussed. Abstracts (of 300 words or less) are invited in the following areas: AERMOD, CALPUFF, next-generation modeling techniques, regulatory application of models, long-range transport issues, and meteorology. Abstracts must be submitted for review via A&WMA s online abstract management system by April 24. Authors will be notified of paper acceptance by May 22. Draft JOURNAL FEBRUARY 2009 VOLUME 59 Listed below are the articles appearing in the February 2009 issue of the Journal. For ordering information, go to or call In This Month s Issue... Real-World Vehicle Emissions: A Summary of the 18th Coordinating Research Council On-Road Vehicle Emissions Workshop Chloride Behavior in Washing Experiments of Two Kinds of Municipal Solid Waste Incinerator Fly Ash with Different Alkaline Reagents The Effect of Oxygen on the Kinetics of the Thermal Degradation for Rice Straw A Method for Estimating Mass-Transfer Coefficients in a Biofilter from Membrane Inlet Mass Spectrometer Data Carbonyl Compounds and Toxicity Assessments of Emissions from a Diesel Engine Running on Biodiesels Effect of E85 on Tailpipe Emissions from Light- Duty Vehicles Research on Transportation-Related Emissions: Current Status and Future Directions Transport Mechanisms of Coarse, Fine, and Very Fine Particulate Matter in Urban Street Canopies with Different Building Layouts Effect of Air Pollution Controls on Black Smoke and Sulfur Dioxide Concentrations across Ireland Intercomparison of Clean Air Status and Trends Network Nitrate and Nitric Acid Measurements with Data from Other Monitoring Programs Kinetic Modeling on the Adsorption of Vapor- Phase Mercury Chloride on Activated Carbon by Thermogravimetric Analysis An Interval Mixed-Integer Semi-Infinite Programming Method for Municipal Solid Waste Management awma.org Copyright 2009 Air & Waste Management Association february 2009 em 49

52 manuscripts are due by July 31, and final manuscripts by September 11 to be incorporated into the proceedings. Receipt of the final extended abstract is a mandatory prerequisite for presentation at the conference. More information is available online at Harmonizing Greenhouse Gas Assessment and Reporting Processes August 31 September 2, 2009 Baltimore, MD This conference will provide a forum for discussing advances in greenhouse gas (GHG) emission estimation methods, emission inventories, and reporting. The conference aims to examine the convergence of mandatory and voluntary reporting initiatives, as well emerging technical and policy issues. Abstracts ( words) are being sought for presentation on all aspects of GHG estimation and reporting, including emerging GHG reporting initiatives, GHG estimation methodology development, mandatory/voluntary reporting initiatives, standards for registering and verifying GHG emission inventories, and accounting for GHG emission reductions. Please submit your abstract to Carrie Hartz at chartz@awma.org. Abstracts must be received by February 20. Authors will be notified of paper acceptance by March 20. Draft extended abstracts are due May 1, and final extended abstracts (for online publication) are due August 7. Receipt of the final extended abstract (3 5 pages) is a mandatory prerequisite for presentation at the conference and inclusion in the proceedings. Visit the conference Web site at for more information. International Conferences Cosponsored by A&WMA Energy Efficiency and Air Pollutant Control (Wroclaw2009) September 21 25, 2009 Wroclaw, Poland The Energy Efficiency and Air Pollutant Control Conference, hosted by the Wroclaw University of Technology, organized by the Wroclaw Faculty of Environmental Engineering, and cosponsored by A&WMA, is the first scheduled international conference on energy efficiency and the control of air pollutants from coal-fired power generation. Abstracts are invited with regard to fundamental research on energy efficiency (in industry, in buildings, combined heat and power systems, indoor climate control systems, climate change mitigation) and air pollutant control (sulfur dioxide, nitrogen oxides, PM, mercury, carbon dioxide, multipollutants). Special issues to be published post-conference in two peer-review journals The Journal of Air & Waste Management Association and Environment Protection Engineering are planned with conference contributions. More information is available online at 19th Annual Conference of the International Society of Exposure Science (ISES): Transforming Exposure Science in the 21st Century November 1 5, 2009 Minneapolis, MN Researchers are invited to submit abstracts and symposia proposals on the full spectrum of human and ecological exposure science. Research on the following important exposure science issues are of particular interest, including global exposure issues (e.g., climate change, disaster relief, and sustainable/alternative energy), local/regional exposure issues (e.g., urban planning, green, and sustainable development), and emerging and high-impact exposure issues (e.g., epigentics and exposure, genomic markers of exposure, and exposure biology). Preference will be given to abstracts that focus on linkages, population-based studies, and methods for improved exposure and dose characterization across the source-tooutcome continuum. Symposia proposals and paper abstracts may be submitted electronically at Symposia proposals should provide an overview of the symposia and explain how the presentations address a coherent, integrated theme. Each symposium will be 90 minutes and should include an appropriate number of presentations (i.e., 2 6) that allow time for the presentations and audience participation. Innovative symposia formats are encouraged. The proposal should contain an abstract of no more than 500 words and provide a list of the individual presentation topics, speakers and affiliations, and a short description of each presentation. Proposals are due February 20. Paper abstracts of no more than 300 words are due May 1. Complete information regarding abstract and symposia requirements and deadlines can be found online at em 50 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

53 em calendar of events 2009 FEBRUARY 18 Geologic Sequestration Research Activities and EPA Requirements Webinar, 2:00 4:00 p.m. Eastern MARCH Building Energy 2009, Boston, MA; First International Greenhouse Gas Measurement Symposia, San Francisco, CA th International Conference on Air Quality Science and Application (Air Quality 2009), Istanbul, Turkey MAY 7 8 Practical Sustainability, St. Louis, MO Joint Conference: International Thermal Treatment Technologies and Hazardous Waste Combustors, Cincinnati, OH Canadian Indoor Air Quality Conference, Montreal, Quebec JUNE A&WMA s 102nd Annual Conference & Exhibition, Detroit, MI AUGUST Aug 31 Harmonizing Greenhouse Gas Assessment Sept 2 and Reporting Processes, Baltimore, MD SEPTEMBER 1 2 Climate Conference, Baltimore, MD Ambient Air Monitoring and Dispersion Modeling for Oil and Gas Exploration and Production, Centennial, CO Energy Efficiency and Air Pollutant Control, Wroclaw, Poland; OCTOBER International Air Quality VII Conference, Arlington, VA; Guideline on Air Quality Models: Next Generation of Models, Raleigh, NC NOVEMBER 1 5 International Society for Exposure Science (ISES) 2009 Annual Conference: Transforming Exposure Science in the 21st Century, Minneapolis, MN 2010 JUNE A&WMA s 103rd Annual Conference & Exhibition, Calgary, Alberta, Canada AUGUST Aug 30 Power Plant Air Pollutant Control Mega Sept 2 Symposium, Baltimore, MD SEPTEMBER CALGARY 2010 ENERGY AND ENVIRONMENT th World Congress of the International Union of Air Pollution Prevention Associations (IUAPPA): Achieving Environmental Sustainability in a Resource Hungry World, Vancouver, British Columbia, Canada Events sponsored and cosponsored by the Air & Waste Management Association (A&WMA) are highlighted in bold. For more information, call A&WMA Member Services at or visit the A&WMA Events Web site: To add your events to this calendar, send to: Calendar Listings, Air & Waste Management Association, One Gateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA Calendar listings are published on a spaceavailable basis and should be received by A&WMA s editorial offices at least three months in advance of publication. awma.org Copyright 2009 Air & Waste Management Association february 2009 em 51

54 em association news A&WMA has provided me access to all of the different stakeholder perspectives that have helped me anticipate new policies that will impact my business. Tell Us What Makes You Tick! The Member Minute is a great way to share your experiences, work, and accomplishements with A&WMA s membership and EM readers. Want to see your photo and story highlighted in EM, or do you want to recommend someone to be featured? Just your contact information to EM Managing Editor Lisa Bucher at lbucher@awma.org for consideration. Minute The Member Each month, this page profiles a different A&WMA member to find out what makes them tick at work and at home. Michael D. Durham, Ph.D. President ADA-ES Inc. Littleton, CO A&WMA Member Since 1975 Rocky Mountain States Section Association leadership roles held: Chair, Rocky Mountain States Section ( ); Chair, National Technical Committee on Control of Particulate Matter and Acid Gases ( ); Chair, Emission Control Division ( ) Association honors and awards received: Sensenbaugh Award for Air Pollution Control Technology (2001) em: What inspired you to become an environmental professional? Durham: As an undergraduate studying aerospace engineering, I first got interested in environmental issues when I performed an analysis of emissions from jet engines as my senior project. I then refocused my academic studies and received master s and Ph.D. degrees in environmental engineering. What environmental leader do you admire most and why? Dr. Dale Lundgren was an internationally recognized expert in air pollution control long before the original Clean Air Act in He was not only my thesis advisor at the University of Florida, but my first employer in the environmental field as a consultant. Dr. Lundgren taught me that with solid engineering fundamentals, there were no bounds to the breadth of projects to be pursued and if there wasn t an available answer to a problem, then invent one. This attitude has stayed with me and led to the startup of two successful air pollution control companies and a dozen patents. What advice would you give to students and/or young professionals just starting out in the field? The environmental field is constantly changing as a result of continuously improving technologies. New entrants to this field will likely experience several significant changes in directions throughout their careers. Therefore, I would recommend that, as they hone their technical skills, they keep a keen eye on changing political, economic, and societal trends that will define new challenges and opportunities. What does A&WMA membership mean to you? Environmental issues are multidimensional, constantly evolving, and require access to the latest information on new technologies and emerging policies. A&WMA has provided me access to all of the different stakeholder perspectives, from scientists and government agencies to environment groups, consultants, and industry end users, that have helped me anticipate new policies that will impact my business. Are you currently working on any interesting projects? My company has started scaling-up carbon capture technology that we are developing for existing coal-fired boilers. Technology will be needed to help these plants meet pending regulations to address climate change. There are a number of challenges to developing a solution that can be applied to the massive volumes of gases that must be treated and still be practical relative to the impact on the cost of electricity. How do you like to let off steam? For excitement, I climb mountains (over 40 14,000 ft peaks to date), ride my road and mountain bikes through the hills of Colorado, and heli-snowboard in Canada. For relaxation, I get away with my wife and dogs to our ranch in rural Colorado that is totally off the grid (solar powered, no phone or cell service), where I make up projects to do with my tractor (Mike is pictured above with his three dogs). 52 em february 2009 Copyright 2009 Air & Waste Management Association awma.org

55 PROFESSIONAL DEVELOPMENT OPPORTUNITIES VISIT FOR MORE INFORMATION. First International Greenhouse Gas Measurement Symposium A&WMA's First International Greenhouse Gas Measurement Symposium will provide a forum for discussion on novel concepts in greenhouse gas (GHG) emission source measurement, measurementbased modeling, surrogate-monitoring assessment in the context of future compliance, verification, and emission trading strategies. Industrial plant operators, regulators, instrument suppliers, and researchers should not miss this opportunity to exchange ideas and review the application of measurement-based approaches for GHG emissions quantification with industry experts. An associated professional development course will be offered. Practical Sustainability As increased attention is being paid to climate change, energy dependency, and greenhouse gas emissions, expectations are rising for organizations to implement energy and carbon management strategies. Join industry experts for Practical Sustainability to discuss how organizations are measuring and demonstrating sustainability in ways that make business sense both financially and culturally, while also meeting the growing expectations of shareholders, customers, and the general public. Joint Conference: International Thermal Treatment Technologies & Hazardous Waste Combustors The Joint Conference: International Thermal Treatment Technologies (IT3) & Hazardous Waste Combustors (HWC) will provide a forum for the exchange of state-of-the-art technical information on thermal treatment technologies and issues related to combustion of hazardous waste. Practical applications of technical and scientific advances will be presented by experts from the international community involved with thermal treatment technologies for the management of wastes that include: hazardous, radioactive, mixed, munitions, medical/pharmaceutical, and municipal. This conference will have a particular focus on hazardous waste management including HWC MACT status and policy updates, emission studies, testing and monitoring approaches, and risk assessment updates. March 22-24, 2009 San Francisco, CA May 7-8, 2009 St. Louis, MO May 18-22, 2009 Cincinnati, OH EXHIBIT SPACE AVAILABLE EXHIBIT SPACE AVAILABLE UPCOMING WEBINARS February 18, p.m. Eastern Geologic Sequestration Research Activities and EPA Requirements Carbon sequestration is predicted to play an important role in reducing carbon dioxide emissions and diminishing global climate change. Join industry experts to explore all aspects of geologic carbon sequestration, including proposed techniques, concerns of underground injection, and the EPA s Underground Injection Control requirements. February 25, p.m. Eastern Aiming for Change: NACAA's Air Quality Recommendations to the Obama Administration Get an insider s glimpse of potential environmental developments of the Obama administration! On December 16, 2008 the National Association of Clean Air Agencies (NACAA) met with the Obama transition team to discuss and make recommendations on air quality issues. Find out how the recommendations were developed, how they were received, and how they may influence future policy.

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