r/EPA
February 2008
         Executive Summary
         to the Evaluation
         of Air Toxics
         Monitoring in
         EPA Region 9
         Final Report
         Promoting Environmental Results
         •«	>
         Through Evaluation

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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.

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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

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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

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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

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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

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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

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              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

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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

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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

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    •   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

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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
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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
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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.
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    •   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

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