Technical Note
Guidance for Photochemical Assessment Monitoring Stations (PAMS) Required
Network Implementation Plans and Enhanced Monitoring Plans (EMPs)
This guidance and the following two attachments represent templates for consideration for
implementation plans for the (1) Required Monitoring Network PAMS site (at certain NCore
sites) and (2) for the EMPs required for moderate or higher nonattainment areas (NA) and states
within the Ozone Transport Region (OTR). These templates should help in the development of
implementation plans that should be included in the annual monitoring network plan as required
by 40 CFR 58.10.
For higher population NCore sites (i.e., those in Core Based Statistical Areas (CBSAs) greater
than 1,000,000), the Required Monitoring Network Implementation Plan must include the final
site location, the types of instruments to be installed, and frequency of measurements that will be
made. The Required Monitoring Network Implementation Plans should state the methods and
procedures that will be followed as stipulated in the final PAMS rule, national PAMS Quality
Assurance Program Plans (QAPP), and the PAMS Technical Assistance Document (TAD). The
expected auto gas chromatograph (GC) monitoring systems will require a level of
expertise which may not be currently available to monitoring agencies. Early planning is crucial
to meeting deployment and measurement deadlines.
The final ozone national ambient air quality standards (NAAQS) rule has waiver provisions
which allow monitoring organizations which have low concentrations of ozone (as defined in the
rule) to request a waiver from implementing PAMS at an otherwise required NCore site entirely1,
or to make PAMS measurements at alternative locations such as existing PAMS sites or existing
National Air Toxics Trends Station (NATTS) sites11. In addition, while it is expected that auto
GCs will be used for VOC measurements in order to report hourly measurements, there is an
opportunity to seek a waiver and instead collect three 8-hour canister samples, once every three
days111. In addition, a monitoring organization may request that it utilize data from a nearby
meteorological station rather than establish its own™. Monitoring organizations must request a
waiver from any deviation described above. The waivers will be in the form of a one or two
page technical memo that describes the need and rationale for the waiver, and any other requisite
supporting information including alternative locations (such as existing PAMS sites), and/or
proposed alternative measurement procedures (see end notes to this memo in this regard). The
waiver will be submitted to the EPA Regional Administrator for review and approval. Waivers
may be submitted with the required Annual Monitoring Network Implementation Plan or as a
standalone document, if agreed to by the local EPA Regional Office.
• Monitoring organizations should submit the draft Implementation Plan for required
PAMS locations and any waivers to EPA Regional Offices by May 1, 2017, along with
their draft Annual Monitoring Network Plan (AMNP). This will ensure that a 30 day
public notice is provided, and EPA may provide comments during that time. Final
Implementation Plans should be submitted by July 1, 2017, along with the AMNP.
NOTE: The regulation requires that the draft Implementation Plans be submitted by
Julyl, 2018; however, in order to be operational by June 1, 2019, it is recommended
that the organizations submit their Implementation Plans by May 1, 2017.
• As with all AMNPs, the EPA Regions will have 120 days to review the waivers and the
proposed PAMS Implementation Plans, and provide a formal response to the state's plan
(and waiver if proposed), no later than October 31, 2017 (Based on the submission of the
final AMNP by July 1, 2017).
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All 03 moderate (and worse) NA areas and states in the OTR must develop and implement EMPs
These EMPs must include the final site location, the types of instruments to be installed, and the
frequency of measurements that will be made at the site. They should also identify the rational
for proposed measurements, and in the case of EMP sites within the OTR, must take into account
interstate and interregional transport of ozone and ozone precursors.
• Monitoring organizations should submit the draft EMPs for areas in the OTR and
moderate NAsto EPA Regional Offices by May 1,2018, along with their draft AMNP.
This will ensure that a 30 day public notice is provided, and the EPA can provide
comments during that time. Final EMPs should be submitted by July 1, 2018, along with
the AMNP.
NOTE: The regulation requires these EMPs be submitted by October 1, 2019 (or two
years following the effective date of a designation to a classification of Moderate or
above 03 NA whichever is later). We recognize that some areas may not know if
they are moderate nonattainment areas until after that date, and the dates described
here may need to be pushed back by exactly one year to accommodate that
possibility. However, for areas in the OTR, to ensure (possible) continuity of existing
measurements, and for a variety of other logistical and programmatic considerations,
we recommend this earlier submittal date of July 1, 2018.
• As with all AMNPs, the EPA Regions will have 120 days to review the proposed EMPs,
and provide a formal response to the state's plan, no later than October 31, 2018. (Based
on the submission of the final AMNP by July 1, 2018).
While not a comprehensive list, EMP may include: additional 03 sites; additional NOx or NOy
sites; additional VOC/carbonyl measurements (different time periods, different locations and
different precursors); or enhanced upper air measurements. EPA encourages that all EMPs be
developed in consideration of and in coordination with other nearby PAMS/ EMPs. In the OTR,
EPA intends that this coordination should occur and include all states in the OTR. For the states
in the OTR, EPA encourages a comprehensive EMP with well-defined objectives.
References
1 Appendix D of 40 CFR Part 58, 5(f) allows an otherwise required NCore site from implementing PAMS if the ozone
design value is less than 85% of the NAAQS, and the area is not considered important regarding upwind or
downwind nonattainment areas. States/ locals which have such an area should consult with the local EPA Regional
Office. Such an area would need to submit a request to the EPA Regional Administrator and include a discussion of
design values in the area, and all areas nearby- including a discussion of the closest ozone nonattainment area(s),
and its relationship (or lack thereof) to air quality in the area seeking a waiver. That request should be part of the
AMNP described above, and EPA would approve (or disapprove) the request when it acts on the AMNP. Any
alternative method of seeking such a waiver should be agreed with the appropriate EPA Regional Office.
" Appendix D of 40 CFR Part 58, 5(c) allows for the collection for required PAMS measurements at an alternative
location. For areas considering such a request, it must be demonstrated that the alternate location will provide
representative and useful data for regional or national tracking of trends in ozone precursors. For example, it may
be a nearby location that has measured PAMS compounds in the past, and could be beneficial from a trends
perspective. Any request should meet the specific requirements of the rule, be included in the AMNP, and to be
acceptable, be approved by the EPA Regional Administrator.
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Appendix D of 40 CFR Part 58, 5(d) provides that the EPA Regional Administrator may grant a waiver from
continuous VOC measurements to allow for speciated VOC measurement as three- 8 hour averages on every third
day during the ozone season. EPA will consider waivers where precursor concentrations are low, or for other
logistical or programmatic constraints. In considering approval of a waiver, the EPA Regional Administrator will
consider the ability to compare and utilize other nearby PAMS (and EMP) locations to ensure the data collected
can be used in a useful manner. Any request should meet the specific requirements of the rule, be included in the
AMNP, and to be acceptable, be approved by the EPA Regional Administrator.
'"Appendix D of 40 CFR Part 58, 5(e) provides that the EPA Regional Administrator may grant a waiver allowing
representative meteorological data from nearby monitoring stations to be used to meet the meteorological
measurements required. To be acceptable, a request must provide for the location of the alternative
measurements, a detailed description of the appropriateness and representativeness of the location relative to
PAMS location, assurance that the data will always be available, and ensure that the data meet appropriate EPA
quality assurance requirement for those measurements. Any request should meet the specific requirements of the
rule, be included in the AMNP, and to be acceptable, be approved by the EPA Regional Administrator.
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PAMS Monitoring Implementation Network Plan
Example
Monitoring Organizations Required to Operate at NCore Sites
(Insert monitoring organization) formerly operated two Photochemical Assessment
Monitoring Stations (PAMS) sites in the air monitoring network in 2015, at the (Insert
Location) and (Insert Location) sites. However, the recently revised monitoring rule (80
FR 65292; October 26, 2015) requires PAMS measurements June 1 through August 31
at NCore sites that are located in Core-Based Statistical Areas (CBSAs) with
populations of 1,000,000 or more.
Network Decision
|[]| The NCore site located at (Insert Location) will serve as the location of the
required PAMS site and will measure the following parameters described
below. An Inventory of equipment used at the site(s) is provided in attachment 2
_] We request a waiver from implementing PAMS at an otherwise required NCore site
entirely, or to make PAMS measurements at alternative locations such as existing PAMS
sites or existing NATTS sites. Rationale for this waiver is provided in Waiver attachment
Auto GC Decision
Volatile organic compounds (VOCs) - A complete list of the targeted compounds are
found in Table 1.
We will measure hourly speciated VOC measurements with an auto-gas
chromatograph (GC) using (insert manufacturer).
[] We request a waiver to allow three 8-hour samples every third day as an
alternative to daily hourly speciated VOC measurements at locations (insert
locations). Rationale for this waiver is provided in Waiver Attachment
Meteorology Measurements Decision - Note: EPA is suggesting the use of
ceilometers for determining mixing height, however other types of meteorological
equipment that provide for an indication of mixing height can be proposed
Will measure wind direction, wind speed, temperature, humidity, atmospheric
pressure, precipitation, solar radiation, ultraviolet radiation, and mixing height.
We have elected to use the following instrumentation to measure the parameters
described above: (insert equipment models and manufacturer) .
We request a waiver to allow meteorological measurements to be obtained from
other nearby sites. Rationale for this waiver is provided in Waiver attachment
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Other Required Measurements
o Carbonyls - Carbonyl sampling at a frequency of three 8-hour samples on a one-
in-three day basis (-90 samples per PAMS sampling season) using (insert
sampler and analytical manufacturer). A complete list of the target carbonyl
compounds may be found in Table 1. The TO-11A test method, as used in the
National Air Toxics Trends (NATTS) program1 will be used.
o Nitrogen Oxides - Will monitor for NO and NOy (total oxides of nitrogen) in
addition to true NO2. The true NO2 is required to be measured with a direct
reading NO2 analyzer, cavity attenuated phase shift (CAPS) spectroscopy or
photolytic-converter NOx analyzer. We have elected to use (insert type and
manufacture1) for the true N02 measurement. NO and NOy will be measured
using a {insert manufacture/).
Table 1 PAMS Target Compound List
I'riorilx ('oiiipomids
(>|>1 iomil ('oiiipomids
1
1,2,3-trimethylbenzenea
19
n-hexaneb
1 1.3,5 -trimethylbenzene
19
m-diethlybenzene
2
1,2,4-trimethylbenzenea
20
n-pentane
2
1-pentene
20
methylcyclohexane
3
1-butene
21
o-ethyltoluenea
3
2,2-dimethylbutane
21
methylcyclopentane
4
2,2,4-trimethylpentaneb
22
o-xylene a'b
4
2,3,4-trimethylpentane
22
n-decane
5
acetaldehydebc
23
p-ethyltoluenea
5
2,3-dimethylbutane
23
n-heptane
6
acetonecd
24
Propane
6
2,3-dimethylpentane
24
n-nonane
7
benzenea,b
25
propylene
7
2,4-dimethylpentane
25
n-octane
8
c-2-butene
26
styrene a'b
8
2-methylheptane
26
n-propylbenzenea
9
ethaned
27
tolueneab
9
2-methylhexane
27
n-undecane
10
ethylbenzeneab
28
t-2-butene
10
2-methylpentane
28
p-diethylbenzene
11
Ethylene
11
3-methylheptane
29
t-2-pentene
12
formaldehydebc
12
3-methylhexane
30
a/p-pinene
13
Isobutane
13
3-methylpentane
31
1,3 butadieneb
14
Isopentane
14
Acetylene
32
benzaldehydec
15
Isoprene
15
c-2-pentene
33
carbon tetrachlorideb
16
m&p-xylenesab
16
cyclohexane
34
Ethanol
17
m-ethyltoluenea
17
cyclopentane
35
Tetrachloroethyleneb
18
n-butane
18
isopropylbenzeneb
Source: Revisions to the Photochemical Assessment Monitoring Stations Compound Target List.
U.S. EPA, November 20, 2013
aImportant SOAP (Secondary Organic Aerosols Precursor) Compounds
b HAP (Hazardous Air Pollutant) Compounds
c Carbonyl compounds
d Non-reactive compounds, not considered to be VOC for regulatory purposes
1 See NATTS Technical Assistance Document for TO-11A method.
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PAMS Monitoring Implementation Network Plan
Example
Monitoring Organizations Not Required To Operate At NCore Sites
(Insert monitoring organization) formerly operated (x#) Photochemical Assessment
Monitoring Stations (PAMS) sites in its air monitoring network in 2015, at the (Insert
Location) and (Insert Location) sites. The recent revised ozone NAAQS rule1 requires
PAMS measurements at NCore sites that are located in Core-Based Statistical Areas
(CBSAs) with populations of 1,000,000 or more. Since (Insert monitoring organization)
NCore sites are located in CBSAs with populations less than one million, this
requirement does not apply (insert monitoring organization). (In some cases, a State
may have an NCore site that requires PAMS measurements, but additional "Enhanced
Monitoring" sites are necessary to adequately characterize the problem.) States with
moderate or above ozone non-attainment areas and states within the Ozone Transport
Region (OTR) are required to develop and implement Enhanced Monitoring Plans
(EMPs). These EMPs are intended to provide monitoring organizations with the
flexibility to implement additional monitoring to suit the needs of their area such as,
additional ozone, ozone precursor and/or meteorological monitoring activities. (For an
area in the OTR- include the following: In developing this plan, we have coordinated
with all other States (and DC) in the OTR and EPA Regions 1, 2, and 3. As a
contiguous area of interregional transport, we have agreed to the spatial distribution of
these monitoring locations, as well as the type and frequency of the air quality (and
other measurements) to include.)
(Insert monitoring organization) has determined the EMP measurement options will
include (but are not limited to) additional ozone air measurement at {insert location),
upper air measurements (insert location), measurements of total VOC or
enhanced/reduced amount of VOCs/carbonyl species (identify), additional nitrogen
dioxide monitoring (insert location), and additional meteorology/boundary layer
measurements. This required EMP reflects local needs within the context of interstate,
interregional transport of ozone and ozone precursors.
180 FR 65292; October 26, 2015
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Attachment 1 Waiver Requests and Rationale
Waiver from implementing PAMS at an otherwise required NCore site (waiver
could be either in its entirety, or to be at a different location)
Rationale for this waiver
Auto GC Waiver Request
We request a waiver to allow three 8-hour samples every third day as an
alternative to daily hourly speciated VOC measurements at locations (insert
locations).
Rationale for this waiver
Meteorological Waiver Request
We request a waiver to allow meteorological measurements to be obtained from
other nearby sites.
Rationale for Waiver
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Attachment 2 Equipment Inventory
(Example)
Region
2
State
New York
AOS ID
36-081-0124
CBS A
ew York-Newark-Jersey City, NY-NJ-PA
Parameter
Category
Detail
Site
Is the AQS site ID listed above the expected PAMS Core site
location?
No
What is the status of the decision for the expected PAMS Core
site location (not started, draft, or final)?
Not Started
Is there an alternate PAMS Core site location selected?
Yes
Identify type of alternative site (existing PAMS, NATTS, etc)
Existing PAMs
Alternate site AQS ID (if known)
36-005-0133
Mixing Height
Isthere an existing functional ceilometer or other similar
instrument available for use?
No but State Installing Network
current location (at future PAMS Core site, at other site, not
applicable)
instrument type (ceilometer, radar profiler, etc)
manufacturer
model
date purchased
comments
Mesonetwill include:
Auto GC
Isthere an existing AutoGC available for use?
Yes
current location (at future PAMS Core site, at other site, not
applicable)
At Site
manufacturer
Agilent/Markes
model
7890A/Unity Air Server 2
date purchased
04/2016//07/2015
Does it have a service contract?
GC under warranty/Working on AC
for Markes now
comments
True N02
Isthere an existing true N02 instrument available for use?
No
current location (at future PAMS Core site, at other site, not
applicable)
instrument type (photolytic conversion, cavity ringdown, CAPS,
etc)
manufacturer
model
date purchased
comments
NOx analyzer at site
Carbonyls Sampling
Isthere an existing sequential carbonyls sampling unit or
similar instrument available for use?
Yes
current location (at future PAMS Core site, at other site, not
applicable)
In storage at Rensselaer, Site has
two channel unit now.
manufacturer
Atek
model
8000
date purchased
2012
comments
Carbonyls Analysis
Does the site currently have a support laboratory for
carbonylsor plans to use a support laboratory?
Yes, in house
laboratory name
NYSDEC Air Resources Laboratory
comments
Barometric Pressure
instrument type (aneroid barometer, etc)
Yes - Electronic
manufacturer
Vaisala
model
WT520
date purchased
comments
UV Radiation
instrument type (UV radiometer, etc)
No
manufacturer
model
date purchased
comments
Solar Radiation
instrument type (pyranometer, etc)
No
manufacturer
model
date purchased
comments
Precipitation
instrument type (tipping bucket, weighing, etc)
Electronic Gauge - Weighing
manufacturer
ETI Instrument Systems
model
NOAH IV
date purchased
2011
comments
Data in NADP Database
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