r/EPA
February 2008
Executive Summary
to the Evaluation
of Air Toxics
Monitoring in
EPA Region 9
Final Report
Promoting Environmental Results
•« >
Through Evaluation
-------
Acknowledgements
This evaluation was performed by Ross & Associates Environmental Consulting, Ltd.,
under contract to Industrial Economics, Inc. The evaluation was prepared for the U.S. EPA
Office of Policy Economics and Innovation (OPEI), Evaluation Support Division; the U.S.
EPA Office of Air Quality Planning and Standards (OAQPS), Air Quality Assessment
Division; and the EPA Region 9 Air Toxics Monitoring Program. The EPA team guiding
development of this evaluation was comprised of James Hemby, EPA OAQPS; Michael
Jones, EPA OAQPS; Meredith Kurpius, EPA Region 9; and Michelle Mandolia, EPA
OPEI. The Ross & Associates evaluation team was comprised of Timothy Larson, Jennifer
Major, and Nicole Wigder.
This report was developed under the Program Evaluation Competition, co-sponsored by
EPA's Office of Policy Economics and Innovation and the Office of the Chief Financial
Officer. To access copies of this or other EPA program evaluations, please go to the EPA
Evaluation Support Division website located at http:www.epa.gov/evaluate.
-------
Executive Summary to the Evaluation of Air Toxics
Monitoring in EPA Region 9
Hazardous Air Pollutants (HAP), also known as air toxics, are pollutants that are known or
suspected to cause cancer and other serious conditions including damage to respiratory,
immune, and neurological systems, as well as having negative reproductive and
developmental effects on those who are exposed at sufficient concentrations and durations.
The Environmental Protection Agency (EPA) and a number of state and local agencies and
tribes (SLT) across the United States (US) have air toxics monitoring experience extending
back more than two decades. Building on this breadth of experience, EPA initiated the
national air toxics monitoring program in 1998, which provided a consistent platform for
continued air toxics monitoring activities across the nation.
EPA Region 9—comprised of SLTs in Arizona, California, Hawaii, and Nevada—has one
of the largest and most well-developed sets of air toxics monitoring programs in the
country. EPA Region 9 has also been cited as having areas with the highest level of risk
from air toxics. This evaluation effort was launched to assess the design and
implementation of locally- and nationally- funded air toxics monitoring activities across the
region and identify ways in which program effectiveness can be improved based on the
experiences of SLTs throughout EPA Region 9 and EPA Program Managers and staff. We
conducted this review to pursue four key objectives:
1. Characterize air toxics monitoring programs across EPA Region 9, including
identification of SLT objectives as well as those of EPA Region 9.
2. Assess the design of EPA Region 9's air toxics monitoring programs and the extent
to which they meet stated objectives.
3. Distinguish ways in which EPA Region 9's monitoring programs contribute to the
objectives of the national air toxics monitoring program and areas for improvement.
4. Identify potential performance metrics for evaluating air toxics monitoring
programs at national and regional levels.
To conduct this evaluation, we reviewed and analyzed key documents including various
studies, reports, and strategic planning documents; interviewed officials from EPA
headquarters and EPA Region 9; interviewed officials from nine Region 9 SLTs; and
analyzed data from EPA's Air Quality System (AQS) database.
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9
-------
This Executive Summary provides an overview of the major findings from the evaluation
effort and includes recommendations for advancing the effectiveness and efficiency of air
toxics monitoring activities in EPA Region 9. The full report contains additional detail,
including a section describing current air toxics monitoring activities across EPA Region 9,
detailed descriptions of the evaluation findings, and several appendices with supporting
information.
The findings and recommendations presented in this report reflect the ideas and opinions of
the EPA and SLT officials that contributed to the evaluation. In general, this report
includes those ideas and opinions that were expressed by more than one party, rather than
presenting a comprehensive description of all ideas provided by the contributing officials.
This report is not intended to provide a full evaluation or audit of any SLT's air toxics
monitoring program or of the national air toxics monitoring program. Rather, the report
looks across the Region 9 agencies to identify and assess current air toxics monitoring
activities, and to identify ideas that can be used to inform ongoing improvements to
national, state, local, and tribal air toxics monitoring programs.
The six findings summarized in this Executive Summary are presented to indicate common
air toxics monitoring challenges experienced by EPA and Region 9 SLT officials, and are
intended to be used as a basis for continued discussions on how to improve air toxics
monitoring regionally. Following the findings are five recommendations, based on the
findings in this report and from a January 31, 2008 meeting between EPA headquarters,
EPA Region 9, and Region 9 SLT officials, that provide ideas for improving air toxics
monitoring communication, collaboration, and coordination in EPA Region 9 and
nationally.
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9
-------
Key Findings
Finding 1: There Is a Significant Amount of Consistency in Air Toxics Monitoring
Objectives across Agencies in EPA Region 9 with the National Objectives, although
Differences in Program Design and Implementation Reflect Variation in Priorities across
These Objectives.
Officials from EPA headquarters, EPA Region 9, and SLTs in EPA Region 9 agree that the
overarching goal of current national, state, tribal, and local air toxics monitoring programs
is to reduce human health risks caused by exposure to air toxics. The objectives in EPA's
2004 National Monitoring Strategy achieve this goal through a dual emphasis on NATTS
program sites and community-scale monitoring efforts. Objectives set by SLTs within EPA
Region 9 are highly consistent with EPA's air toxics monitoring objectives: three SLTs in
the region maintain NATTS program sites and all of the SLTs in EPA Region 9 that have
received community-scale monitoring grants manage these efforts consistent with the
objectives detailed in the 2004 National Monitoring Strategy. The data resulting from
these NATTS program sites and community-scale monitoring efforts provides a picture of
the distribution of air toxics concentrations at and between NATTS program sites in the
region. In addition, some SLTs in EPA Region 9 are working towards objectives which
complement and expand on the current scope of objectives listed in the EPA strategy.
However, SLTs in the region vary in the relative emphasis they place on the NATTS
program, their own trends networks, and various local-scale monitoring efforts, reflecting a
balance between nationally- and locally- funded air toxics monitoring efforts. The
patchwork of SLT air toxics monitoring activities across EPA Region 9 largely reflects the
varying emphasis on specific program objectives, as well as the relative priority of air
toxics compared with other air quality and environmental issues at each agency.
Finding 2: National and SLT Trends Monitoring Networks Are Complementary Efforts,
although SLTs Have Experienced Challenges with Participation in the NATTS Program that
Differ from Challenges They Face in Their Own Air Toxics Monitoring Efforts.
National ambient monitoring networks and SLT trends monitoring networks are
complementary efforts that jointly provide data on the prevalence of air toxics in EPA
Region 9 and across the nation. Most of the air toxics monitoring in Region 9 is not part of
the national monitoring network, rather, these monitoring activities are independent efforts
managed by SLTs. The SLTs in EPA Region 9 participating in the NATTS program have
received substantial benefits from the program, but have also encountered unanticipated
set-up and analytical challenges that in some cases exceeded the resource needs covered by
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9
-------
EPA funding. Most of the NATTS sites in EPA Region 9 were established at sites where
air toxics monitoring was already being conducted by experienced districts with well-
developed methods. These methods differed from EPA's methods, setting up a challenge
for the SLTs in conforming to the national methods. Joining the NATTS program
necessitated redesign of the SLTs' methods and retraining of agency personnel. In
addition, these SLTs were faced with the decision of whether to switch all their air toxics
sites or just the NATTS program sites to the EPA methods. In addition, both EPA and SLT
officials noted that many of the challenges associated with past participation in the NATTS
program are direct results of the program being relatively new, and are similar to
challenges encountered at the infancy of other large-scale monitoring programs. These
officials cited a need to learn from the experiences of the early implementers of the NATTS
program.
Finding 3: Short-Term and Community-Scale Air Toxics Monitoring Projects Play an
Important Role in Characterizing Air Toxics and Their Health Effects in EPA Region 9, while
Presenting Unique Resource and Management Challenges for SLTs.
SLTs in EPA Region 9 have undertaken a variety of short-term and community-scale air
toxics monitoring projects in addition to participation in broader local, state, tribal, and
national trends monitoring networks. Short-term and community-scale air toxics
monitoring projects greatly contribute to the characterization of air toxics at the local level
and provide a means for performing risk assessments, identifying source air toxics emission
profiles, and evaluating new monitoring methods. These air toxics monitoring projects
provide unique opportunities for SLTs to collaborate with a variety of community
stakeholders and educate the public on air toxics issues, but can also prompt public scrutiny
of agencies' abilities to diminish air toxics concentrations. Some SLTs fund short-term and
community-scale air toxics monitoring projects through a variety of state, local, and tribal
funding mechanisms, while others receive community-scale air toxics monitoring grants
from EPA. Agencies that have received EPA grants welcome the opportunity they provide
to collect and analyze air toxics data and acknowledge the benefits of the grant program,
such as informing and motivating mitigation strategies. SLTs expressed a desire to use
grant funds to perform further analyses and public communication than has been conducted
in previous grant cycles. These agencies also noted aspects of the community-scale and
other short-term funding structures that can hinder their ability to effectively use the grant
funds to their full benefit.
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9
-------
Finding 4: The Complex Nature of Air Toxics Monitoring Increases Data Quality and
Cross-Agency Data Comparability Challenges.
EPA, state, local, and tribal agencies all strive to develop and utilize methods and quality
control procedures that will ensure high quality air toxics data that can be used for a variety
of national, state, tribal, and local activities such as rulemaking, modeling, and mitigation
efforts. Because the national air toxics monitoring program is relatively new, fewer time-
tested methods and procedures exist than do for criteria pollutants, and therefore, for
certain pollutants, there is significant variation across sampling and laboratory methods and
QA/QC procedures employed by SLTs in EPA Region 9. EPA has sought to foster
standard approaches for ensuring data quality and comparability through the guidance
provided in the air toxics TAD, TO- and IO- compendiums, and PT testing available to all
agencies, and some EPA Region 9 SLTs have also led methods development efforts to
foster collaboration between SLTs in the region. Despite EPA efforts, individual SLTs
cited difficulties in navigating the available options and balancing national, state, tribal,
and local needs. In addition, some SLTs questioned the need for and value of adhering to
national standard approaches for non-NATTS monitoring sites.
Many EPA and SLT officials interviewed for this report cited the complexity of air toxics
monitoring and laboratory procedures as the root cause of the majority of the data quality
and comparability challenges encountered in EPA Region 9. These officials noted that
EPA and each SLT in EPA Region 9 can be impacted by the data quality and comparability
challenges encountered by their agency as well as by the challenges encountered by
collaborating SLTs and contractors. EPA is involved in a number of national air toxics
analyses, modeling efforts, and risk assessment activities that can be negatively impacted if
any SLT contributing data to these efforts experiences data quality or comparability
challenges. Similarly, SLTs that analyze data collected by other agencies, such as CARB,
and SLTs that rely on other agencies or contractors for laboratory analyses, such as ADEQ,
can be negatively impacted if these collaborating entities encounter data quality and
comparability challenges.
Due to these potential effects of data quality and comparability challenges, EPA and SLT
officials noted the benefit of clearly defining the issues which have arisen in the past in
order to prompt proactive discussions on air toxics data quality and comparability
challenges, with the goal of continually improving the quality of data used for local and
national analyses, risk assessments, and modeling activities. Figure 1 outlines the major
factors affecting air toxics data quality comparability described in this and subsequent
findings and Appendix M describes an analysis of a selection of 2006 AQS data that
demonstrates some of the data comparability challenges described below.
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9
-------
Figure 1: Factors Affecting Air Toxics Data Quality and Comparability
| Sampling |
Data Analysis
And Reporting
Equipment
Sampling Procedures
Availability of Raw Data
And Metadata
Data Quality and
Comparability Issues
Finding 5: Agencies across EPA Region 9 Expressed Strong Interest in Expanding Cross-
Agency Communication, Information Sharing, Collaboration, and Training Related to Air
Toxics Monitoring.
EPA Region 9 SLTs expressed an interest in enhancing communication and collaboration
related to air toxics monitoring priorities, methods, results, and trends within their region
and within the larger national framework. Currently existing communication and
collaboration forums address some of the region's needs but there is a desire for a more
cohesive collaboration strategy that consolidates and enhances the current systems.
Specifically, Region 9 SLTs see a need for improvements to the available guidance and
resources, enhancements to the current set of national and regional communication forums,
and improvements to training tools. SLT officials noted the important role for EPA
headquarters and EPA Region 9 at both the national and regional levels to provide
leadership and foster coordination among agencies engaged in air toxics monitoring. At the
same time, EPA and SLT officials observed that there are opportunities for SLTs in Region
9 to enhance communication and information sharing among peers.
Finding 6: Air Toxics Monitoring Data Is Being Used and Analyzed to Varying Degrees
Across EPA Region 9, and There Is a General Sense that Increased Attention Is Needed to
Effectively Expand the Use of the Data for Program Planning and Accountability.
Much attention over the past decade has focused on expanding efforts to monitor ambient
air toxics concentrations, and there is a general sense that greater attention is needed for
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9
-------
analyzing and using air toxics monitoring data. SLTs undertake varying levels of data
analysis and EPA has had a national monitoring effort underway for the past several years.
EPA and SLT officials generally asserted that additional efforts are needed to maximize the
value of monitoring data. At the state and local level, agencies in California have
substantial experience in analyzing, using, and reporting ambient air toxics data for
purposes of program accountability and planning. Other SLTs are generally at the early
stages of beginning to analyze and use collected data. EPA and SLT officials noted that
any efforts to further analyze air toxics data at the national and regional levels will likely
be led by EPA and a select number of SLTs in the region.
Recommendations
Recommendation 1: Enhance Opportunities for Regional and National Information
Sharing, Communication, and Coordination on Air Toxics Monitoring Methods and
Results.
Enhanced communication opportunities within EPA Region 9 would provide SLTs an
opportunity to share ideas and best practices and to coordinate with EPA on air toxics
monitoring methods. Specifically, a regional technical air toxics committee could greatly
enhance SLTs' abilities to collaborate and coordinate on air toxics topics. At the January
31, 2008 meeting, EPA and regional SLTs discussed formation of such a committee
structured in the following ways:
• EPA Region 9 program officials would coordinate initial formation of the
committee, which would include representatives from regional SLTs and EPA
Region 9.
• The committee would hold quarterly conference calls and call agendas would be set
by the committee members.
• The committee would meet in-person once a year.
• Responsibility for hosting, organizing, or presenting on specific conference calls or
at in-person meetings would rotate among SLTs.
• Conference calls and meetings would be used to share information on past or future
air toxics studies within the region and to discuss technical topics, such as methods.
• Some or all conference calls would be web broadcast, allowing officials from SLTs
across the nation to join the discussions and learn from Region 9's experience.
• An EPA headquarters liaison would either attend the quarterly conference calls and
meetings or would be briefed by the EPA Region 9 representative following the
discussions.
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9
-------
Potential discussion topics for the regional technical air toxics committee could include:
• Sampling and laboratory analysis challenges for specific air toxics (e.g., acrolein or
diesel particulate matter).
• Integration of regional information collection and storage systems (e.g., integration
of Laboratory Information Management Systems with other data management
systems).
• Information sharing mechanisms for air toxics data, methods, and study results
(e.g., websites, databases, clearinghouses, message boards, andblogs).
• National, regional, state, local, and tribal objectives and priorities for air toxics
monitoring (see Recommendation 2).
• Scoping and innovative funding opportunities for community-scale air toxics
monitoring projects (see Recommendation 3).
• Data comparability needs and solutions to common data comparability challenges
(see Recommendation 4).
• Air toxics data analysis and use (see Recommendation 5).
In addition, EPA could support Region 9's communication and information sharing efforts
through enhancements to the EPA Region 9 and TTN AMTIC websites. For example, EPA
could consider the following website improvement ideas to help disseminate air toxics
information to SLTs in Region 9 and nationally:
• More clearly articulate national and regional air toxics monitoring objectives and
provide ready access to detailed information on EPA-funded monitoring efforts, the
data collected through these efforts, and resulting final reports and analyses.
During these enhancements, EPA could consider adding more explanatory text to
the main pages of the websites, so that users can access summary information
without downloading large reports.
• Improve ability to access information by air toxics themes (e.g., pollutants or
source types) or to search EPA websites by common air toxics key words.
• Improve access to the data contained in the AQS database. This could be achieved
through continued improvements to current user interfaces such as AQS Discoverer.
• Provide access to user-friendly spreadsheet tools that enable SLTs to benchmark
their air toxics monitoring data against annual averages from other SLTs and/or
NATTS locations.
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9
-------
• Identify and provide contact information for air toxics experts (e.g., representatives
from EPA, Northeast States for Coordinated Air Use Management (NESCAUM),
academia, and EPA Region 9 SLTs).
• Add training resources (e.g. audio and visual presentations on air toxics topics).
In addition, officials from EPA and SLTs in EPA Region 9 could coordinate to help
develop agendas for future national Air Toxics Data Analysis Workshops and National Air
Monitoring Conferences. Many SLTs in the region are involved in innovative air toxics
monitoring projects and could use their experience to help inform agenda planning for
these meetings.
Recommendation 2: Increase Communication and Alignment of Regional Air Toxics
Monitoring Program Objectives and Elevate Importance of Linking Air Toxics
Monitoring to Emissions Reductions.
Further communication about air toxics monitoring program objectives could help SLTs in
EPA Region 9 better understand regional priorities and could facilitate completion of
monitoring activities that address these priorities. For example, many Region 9 SLTs have
indicated interest in more consistently identifying the links between air toxics monitoring
efforts and actual emission reductions within air districts, and in communicating these
achievements to the public. Region 9 SLTs could discuss this and other enhancements to
regional priorities at the quarterly meetings of the EPA Region 9 technical air toxics
committee.
In addition, regional SLTs could work with EPA Region 9 to better understand the
connections between the national air toxics monitoring program objectives and regional
objectives. The National Air Toxics Program Logic Model could be used as a tool for
understanding the connections between each agency's objectives and anticipated
monitoring program outcomes, and to better understand the national objectives specific to
the NATTS program and the community-scale monitoring grant program. These
discussions of objectives could help Region 9 SLTs and EPA better understand future
directions for air toxics monitoring programs and identify any needed enhancements to
regional or national objectives.
Recommendation 3: Enhance Scoping of Local-Scale Air Toxics Monitoring Efforts
and Communication about These Activities to Improve Alignment with National,
Regional, State, Local, and Tribal Objectives.
Further scoping and preparation for local-scale air toxics monitoring efforts could help
SLTs in EPA Region 9 focus their activities to better reflect national, regional, state, local,
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9
-------
and tribal objectives. For example, SLTs could further scope their local-scale monitoring
efforts by clearly identifying the extent of monitoring that will be conducted, the objectives
of the monitoring effort, the anticipated impacts of the monitoring on the local community,
and how that community will be involved in the monitoring process and any mitigation
efforts that may result from the monitoring. It may also be important for SLTs to more
clearly articulate the links between the monitoring effort and actual air toxics reductions.
For example, SLTs could identify key stakeholders—such as regulators and source
representatives—as part of their scoping efforts and describe the ways in which these
parties could contribute to air toxics mitigation efforts if monitoring shows evidence of
significant levels of toxics emissions. SLTs could also more clearly articulate the levels of
risk at which mitigation or other actions are needed, as well as the levels at which
monitoring will conclude. In some cases the regulators or stakeholders may be the federal
government, and engaging the appropriate federal Branch and Division early in the scoping
process may help align expectations and maximize mitigation opportunities. To better
involve local sources and encourage voluntary mitigation efforts, SLTs could also consider
broader incorporation of source attribution studies (e.g., through the use of local emissions
inventories and receptor modeling) as part of their local-scale monitoring efforts.
Enhancements to EPA's current community-scale air toxics monitoring grant program
could further focus SLT air toxics monitoring efforts on identified air toxics monitoring
objectives. For example, new applicants during a given grant cycle could be encouraged
to focus on particular themes that tie directly to current national objectives for problem
identification, trends analysis, and science support, while giving equal weight to the review
of applications that aim to complete activities outside the selected themes. Potential
themes could be developed around specific source types or monitoring and methods
development for specific air toxics. These themes could include near-roadway effects,
goods movement, micro-scale chrome platers, diesel particulate matter, hexavalent
chromium, acrolein, and naturally-occurring asbestos. In addition, EPA could help SLTs
further scope their community-scale monitoring efforts by more clearly articulating
national objectives for community-scale monitoring activities and how these may differ
from objectives of other air toxics monitoring programs (e.g., the NATTS and PAMS
programs) in the grant program guidelines.
Further communication about local-scale monitoring activities could also enhance Region
9's ability to meet identified air toxics monitoring objectives. For example, regional SLTs
and EPA Region 9 could collaborate to share the results of regional local-scale monitoring
projects through agency websites by posting documentation on study designs, objectives,
and results. Adding key word searches to these websites would also facilitate access to
information on past air toxics monitoring studies. In addition, SLTs could increase public
communication efforts at the conclusion of air toxics monitoring efforts to further enhance
the public's understanding of the results of the monitoring efforts and any mitigation
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9 10
-------
measures resulting from the monitoring. EPA could also enhance the distribution of EPA-
funded monitoring study results by providing communication links to other federal
agencies and offices concerned with air toxics, such as the Federal Highway Administration
and EPA Office of Transportation and Air Quality.
Additionally, EPA Region 9 and SLTs within the region could collaborate to enhance
SLTs' abilities to conduct future local-scale air toxics monitoring studies. For example,
these agencies could open a regional dialogue aimed at understanding funding options for
local-scale air toxics monitoring projects. Officials from these agencies could share ideas
for funding opportunities from all available sources—including federal, state, local, tribal,
and private options—and discuss best practices for securing funding for mid-term
community-scale monitoring projects. In addition, SLTs could optimize these discussions
by identifying potential collaborative projects that could distribute resource needs between
several agencies.
Recommendation 4: Collaborate to Identify Solutions to Common Data Quality and
Comparability Problems and Develop Tools to Enhance Data Usability.
EPA Region 9 and SLTs in the region could use the regional technical air toxics committee
to discuss the common data comparability issues documented in this report, including
methods, detection limits, QA/QC procedures, and other technical topics relevant to air
toxics of concern in the region (including those compounds currently outside the scope of
the NATTS program). For example, at the January 31, 2008 meeting EPA and SLT
officials from Region 9 expressed interest in discussing standard approaches for setting
MDLs for specific compounds, differences in AQS reporting procedures for agencies with
higher or lower MDLs, seasonal issues affecting data comparability, co-located data
reporting precision, needs for future round robin and through-the-probe audits, and
common series of data flags for AQS reporting. It may also be necessary for the
participants in these technical committee discussions to agree on a decision-making
framework to use during these meetings so that all parties follow the same process when
there are disagreements on methods development or other technical issues.
EPA and Region 9 SLTs could also open a broader dialogue on the differences in data
comparability needs at national, regional, and local levels. For example, EPA headquarters
representatives could join a Region 9 technical air toxics committee meeting to discuss
national needs for data comparability and how these may differ from the needs of some
SLTs. This dialogue could help EPA and SLTs understand objectives and priorities at
varying levels and identify priority data comparability challenges to address. While data
quality issues are of great importance to both EPA and SLTs, EPA should remain sensitive
to the fact that data comparability across districts is generally a higher priority to EPA than
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9 11
-------
SLTs. The following three options for national data comparability were identified during
the January 31 meeting:
1. Find consensus from all agencies on a consistent set of national standards for air
toxics monitoring and implement these standards at all agencies;
2. Rely solely on NATTS data for establishing national trends; or
3. Conduct in-depth data analysis that assesses data quality and comparability of each
site prior to inclusion in trends analyses.
SLTs in EPA Region 9 expressed an interest in working towards uniform monitoring
methods but cannot currently commit to following national standards at non-NATTS sites;
therefore, option 1 should be considered a potential goal that cannot yet be implemented.
In the meantime, options 2 and 3 remain viable alternatives that have little direct impact on
SLTs. This dialogue between EPA and SLTs on data comparability could also provide an
opportunity to discuss methods requirements for major air toxics programs, such as
NATTS, PAMS, and PM speciation studies. Considering these programs together could
provide opportunities for resource savings.
In addition, EPA and Region 9 SLTs could discuss needs for an air toxics laboratory
certification program. At the January 31, 2008 meeting, SLT officials in EPA Region 9
suggested that all laboratories should meet EPA's National Environmental Laboratory
Accreditation Program standards, and expressed a desire to open a conversation with EPA
on extending this accreditation standard as a national air toxics grant requirement.
EPA could support Region 9's efforts to address common data comparability challenges by
continuing to support national air toxics data analysis and providing SLTs with tools to
assist in data comparability challenges. For example, EPA could consider the following
ideas:
• Enhance efforts to further analyze the national air toxics datasets and share this
information with SLTs (e.g., via teleconference or webcast). This analysis could be
conducted and documented in a method similar to the analysis conducted by EPA
contractors on the UATMP data.
• Develop and provide access to user-friendly tools that enable SLTs to benchmark
their air toxics monitoring data against annual averages from other SLTs. For
example, provide training on AQS Discoverer specifically tailored for air toxics
staff or user-friendly spreadsheet tools.
• Expand the availability of online training resources.
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9 12
-------
• Assist SLTs with accessing NIST standards and/or develop a national stockpile of
these standards.
Recommendation 5: Explore Methods for Using Air Toxics Monitoring Data to
Evaluate Programs and Their Ability to Address Monitoring Objectives.
Data analysis and use could be highlighted during Region 9 technical air toxics committee
discussions. In particular, EPA and Region 9 SLTs could discuss how each agency
currently uses air toxics data, how they would like to use data in the future, how data is
being used by other SLTs across the nation, best practices for data analysis, common
QA/QC challenges associated with data analysis, best practices for benchmarking and
comparing datasets, and potential changes to current practices or mechanisms that could
facilitate further data analysis and use in the future. The SLTs in EPA Region 9 could use
these meetings to highlight analysis of compounds prevalent in the region, and could web
broadcast their discussions to assist other SLTs nationwide. In addition, regional SLTs
could work with EPA to identify important national data analysis efforts and provide web
broadcasts on these topics.
EPA could also support broader use of air toxics data on a national level by continuing to
explore approaches for using air toxics monitoring data to evaluate national air toxics
programs and their results, and to respond to the 2004 air toxics program PART
assessment. For example, EPA could enhance efforts to fully implement the Measure
Implementation Plan for using air toxics monitoring data to develop a risk-weighted
performance measure. EPA could also use the annual goal-setting and performance
measure process that is part of EPA's Annual Commitment System to support a more
collaborative process of tracking and communicating air toxics monitoring program
implementation. EPA's Air Toxics Monitoring Program Logic Model could be used to
inform the development of program implementation performance measures.
Executive Summary to the Evaluation of Air Toxics Monitoring in EPA Region 9 13
------- |