6/25/2020	CSN & IMPROVE Protocol Assessments - More Information

I&1CSN & IMPROVE Protocol Assessments: More Information

Frequently Asked Questions

1.	What was the CSN Assessment?

The CSN Assessment was an assessment of the Chemical Speciation Network that took place in 2014
to create an optimized network that meets primary monitoring objectives and can also be
financially sustained.

2.	What was the IMPROVE Protocol Assessment?

The IMPROVE Protocol Assessment was an assessment of the IMPROVE Protocol sites that took place
in 2015. These sites are considered CSN supplemental sites where the monitoring agencies chose to
operate them as IMPROVE sites when the CSN was established. These sites were excluded from the
2014 CSN Assessment because it only considered sites utilizing the CSN national contract laboratory
for shipping, handling and analysis. In 2015, it was determined that these sites should also be
assessed using the same objectives based approach and nearly identical evaluation criteria as the
CSN assessment.

3.	Why were assessments necessary?

Assessments were performed to ensure that a key national monitoring network was designed and
operated in a manner to reflect current air quality issues and to address the CSN budget shortfall
that was due to increasing contract laboratory and shipping costs.

4.	What changes were considered in the assessments to reduce costs?

Several options were considered in an effort to address the budget shortfall. These included
reducing the sample frequency across the network to 1 -in-6 days, defunding sites, reducing the
number of icepacks included in sample shipments, reducing the carbon blank frequency, eliminating
the CSN PM2.5 mass measurement, and reducing the number of elements reported in the network.

5.	What were the differences between the CSN Assessment and the IMPROVE Protocol Assessment?

The CSN and the IMPROVE Protocol Assessments used the same objectives based approach, and
nearly identical scoring criteria. Due to the fact that NH4 is not collected at the IMPROVE Protocol
sites, it was not included in the correlation with major species scoring in the decision matrix. For
this reason, the 5 applicable "major species" were worth 0.2 points in the CSN Assessment, and the
4 applicable "major species" were worth 0.25 points in the IMPROVE Protocol Assessment. Also, the
IMPROVE Protocol Assessment did not evaluate model bias and error should a site be removed due
to staffing availability. Rather, we relied on feedback from stakeholders to raise this concern should
they feel the site was necessary for modeling purposes.

6.	What changes were implemented as a result of the assessments and when?

The following changes were implemented as a result of the assessment:

° CSN PM2.5 mass measurement was eliminated at sites collocated with an FRM in October, 2014.
o 38 CSN sites were defunded and monitoring discontinued by February 2015.

° 3 CSN sites reduced sample frequency in February 2015.

° The number of icepacks included in CSN shipments was reduced during cooler months

(October-March) beginning October 2014. This will continue on an annual basis.

° Carbon backup filter blanks in the CSN were eliminated in January 2014 and carbon field
blanks in the CSN were reduced to once a month at 26 representative 1 -in-3 day sites and 23
representative 1 -in-6 day sites in February 2015.
o 8 IMPROVE Protocol sites were defunded and monitoring discontinued by January 2016.

7.	Rather than defunding sites, why wasn't the sample frequency reduced to 1-in-6 across the
network?

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Sample frequency was not reduced across the network because it was determined that a reduction
in sample frequency from 1 -in-3 to 1 -in-6 results in an increase in uncertainty in the annual mean.
Also, the Code of Federal Regulations Title 40 Part 58.12 requires NCore and STN sites to operate on
at least a 1 -in-3 day sampling frequency.

8.	How has the size of the network changed as a result of the assessment?

In early 2014, the CSN consisted of 174 sites utilizing the national contract laboratory, 38 IMPROVE
Protocol sites and approximately 15 other sites using various state and local laboratories. As of
January 2016, the CSN consists of 136 sites utilizing the national contract laboratory, 30 IMPROVE
Protocol sites, and the approximately 15 other sites remain. Of the 136 CSN sites using the CSN
national contract, 4 were recommended for defunding but the monitoring agency chose to continue
operations using other funds.

9.	What happens to CSN monitoring equipment at sites that have been defunded?

It is the discretion of the state or local monitoring agency. Agencies responsible for multiple CSN
sites may benefit from having spare instrumentation on hand to replace equipment needing repair.
The equipment can also be used in special studies or shared with other agencies in need.

10.	What happens to IMPROVE Protocol monitoring equipment at sites that have been defunded?

The maintenance crew associated with the IMPROVE program removes the equipment so it can be
used as necessary to support the remaining program.

11.	Why are the majority of the defunded sites located on the east coast?

The majority of the sites are located on the east coast because that is where the highest density of
sites were located. The sites on the east coast had a greater chance of correlating well for the
primary PM2.5 constituents with a nearby site because of this higher density.

12.	Were low concentration and/or regional background sites targeted?

No, low concentration and/or regional background sites were not "targeted" for defunding.

However, the IMPROVE network is typically relied on for providing concentrations at rural,
background sites. During the feedback process, sites that were recommended for defunding that
were identified by stakeholders as providing valuable information (e.g., background sites being used
to inform SIPs in neighboring non-attainment areas) was taken into consideration before any
network changes were implemented. Prior to the CSN Assessment, 28 sites had a 2010-2012 annual
design value less than 8 |Jg/rn3- After the CSN Assessment, 25 of these 28 sites remain.

13.	In the past, I used the CSN PM2.5 mass measurement to validate any unusual FRM mass
measurements at my site. Now that I no longer have CSN mass, how can I validate unusual FRM
mass measurements.

The CSN species data can be used to validate unusual FRM mass measurements by comparing the
sum of species to the FRM mass measurement. Sum of species being the sum of all measured
elements, ions, and organic and elemental carbon species. Optionally, mass could be reconstructed
using the measured species and reconstructed mass can be compared to the FRM mass
measurement, historical FRM mass measurements and/or mass measurements from nearby
continuous monitors to determine whether the FRM value is an outlier. Reconstructed mass can be
calculated as follows:

Reconstructed mass = soil + ammonium nitrate + ammonium sulfate + 1.6*OC + EC
Soil = 2.2(Al) + 2.42(Fe) + 1.63(Ca) + 2.49(Si) + 1.94(Ti)

Ammonium nitrate = 1.29 * nitrate
Ammonium sulfate = 4.125 * elemental sulfur

14.	How can I validate my CSN species data without a CSN mass value or on a day when my FRM mass
data were not available?

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CSN species data can be validated by comparing the sum of species or reconstructed mass to
historical sum of species and mass measurements at the particular site. Historical trends for
individual species should also be used to help identify outliers. In addition, nearby continuous or
FRM monitors can provide the ability to ground-truth measurements on the occasion that FRM data
is not available at a particular site.

15.	A site scored less than 2 points in the decision matrix but was ultimately funded. Why?

While the primary objectives and decision matrix scoring took many parameters into consideration,
we were aware that other important uses of the chemical speciation data for sites could have been
missed. For this reason, feedback was requested from EPA headquarters, regional staff, state and
local monitoring agencies, researchers, academics and communities before making any changes to
the network. As a result of these "intangibles" and feedback, 31 CSN and IMPROVE Protocol sites
continued to receive funding due to various reasons that otherwise would have been defunded
based solely on scoring. Some examples of intangibles/feedback that could cause a site to continue
to receive funding include those located in an environmental justice area, data being used in an
active SIP, and/or located in a potential nonattainment area.

16.	What happened to the funds that were saved?

The funds that were saved have been used to address the budget shortfall. Any additional funds
available will be used to reinvest in the network. After the CSN shipping, handling, and laboratory
analysis contracts award in September 2015, the final cost to support the network is being
determined, and decisions regarding reinvestments are forthcoming.

17.	What types of reinvestments are being considered?

There are many reinvestments that have been discussed, including daily speciation and continuous
measurements in select areas, new measurements and measurement technologies, equipment
upgrade and replacement and new sites in areas with emerging air quality issues. It is important to
note that savings available for reinvestment are still being determined following the CSN shipping,
handling, and analysis contract awards and recalculations of the cost of the network. Also, it is
important to note that savings available for reinvestment will decrease annually as laboratory
contract costs continue to increase.

18.	Will the IMPROVE network be doing a similar assessment?

Yes, the IMPROVE Steering Committee will be evaluating the IMPROVE network to determine what
changes need to be made to create and maintain a financially sustainable network going forward.

Assessment Timelines

Chemical Speciation Network Assessment Timeline


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(Click for full size)

CSN NETWORK

ASSESSMENT

TIMELINE

2015
JAN

APR

MAY

JUN

JUL

AUG

SEP_

OCT.

NOV.

DEC

MAR

2014
JAN

FEB

DEC

NOV

OCT

SEP

AUG

JUL

2013
JUN

Shared CSN Assessment
process and early assessment
recommendations with
NACAA MSC

Revised CSN Assessment
approach and conducted analysis

Shared revised
recommendations at NAAMC
in Atlanta, GA (Aug 11—15)

Briefed AQAD, OAQPS & OAR
management on comments received
and revised recommendations

Requested feedback from all state,
local, regional, university and
research communities by the end of
the month so revisions could be
made to recommendations

Shared CSN Assessment process and initial
recommendations on ORD sponsored
webinar and at HEI annual conference

Shared CSN Assessment process and
initial recommendations with EPA
Regions, NACAA and AAPCA

Briefed AQAD, OAQPS & OAR
management on CSN Assessment
process and initial recommendations

CSN Assessment Team
created and began
working on strategy

Conducted additional analysis and
finalized initial recommendations

In September 2015, a new CSN
contract was awarded for the
network. It was split into two
pieces - Amec Foster Wheeler is
now responsible for shipping,
handling and gravimetric analysis
and University of California at
Davis is responsible for laboratory
analysis. Determination of savings
and reinvestments is ongoing.

Implemented remaining CSN Assessment
recommendations

•	38 sites defunded

•	4 sites funded externally

•	3 sites reduced sample frequency

•	Reduced carbon blank frequency

Shared final decisions with EPA regions

Implemented CSN Assessment recommendation
to reduce icepacks in shipment during cooler
months (Oct 1 - Mar 31)

Finalized and implemented CSN Assessment
recommendations regarding the elimination
of CSN PM2.5 mass measurement (last
measurement collected Sept. 29)

Finalized CSN Assessment recommendations
regarding defunding, reduction in sample
frequency, reduction in blank frequency, and
reduction in icepacks in shipment

Briefed AQAD, OAQPS & OAR management
on final outcomes of CSN Assessment

IMPROVE Protocol Assessment Timeline
(Click for full size)

IMPROVE PROTOCOL
NETWORK
ASSESSMENT
TIMELINE

Feedback received from
SLT monitoring agencies
and EPA regions

Received feedback from
IMPROVE Steering
Committee

2016
JAN

Implemented IMPROVE Protocol
Assessment recommendations
(8 IMPROVE Protocol Sites defunded)

Conducted analysis of IMPROVE
Protocol sites and developed
early recommendations APR

2015
JAN

Shared early
recommendations
with AQAD
management

Shared IMPROVE Protocol
Assessment process and initial
recommendations with the
IMPROVE Steering Committee

Briefed EPA Regions with IMPROVE
Protocol sites recommended for
defunding. EPA Regions shared initial
recommendations with affected state,
local and Tribal (SLT) monitoring agencies.

Conducted additional analysis and
finalized initial recommendations.
Shared information with AQAD
management and EPA Regions.

Shared final recommendations
at the 2015 IMPROVE Steering
Committee Annual Meeting

Shared final recommendations
with AQAD management, EPA
Regions and the NACAA Monitoring
Steering Committee. EPA Regions
shared final recommendations with
affected IMPROVE Protocol sites.

IMPROVE Protocol
Assessment began

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Acronyms

•	AAPCA - Association of Air Pollution Control Agencies

•	AQAD - Air Quality Assessment Division

•	Br - Bromine

•	Ca - Calcium

•	CSN - Chemical Speciation Network

•	Cu - Copper

•	DV - Design value

•	EC - Elemental Carbon

•	EPA - Environmental Protection Agency

•	Fe - Iron

•	FEM - Federal Equivalent Method

•	FRM - Federal Reference Method

•	HEI - Health Effects Institute

•	IMPROVE - Interagency Monitoring of Protected Visual Environments

•	K - Potassium

•	MDL - Minimum detection limit

•	MSC - Monitoring Steering Committee

•	Na - Sodium

•	NACAA - National Association of Clean Air Agencies

•	NATTS - National Air Toxics Trends Station

•	NCore - National Core Multipollutant Monitoring Stations

•	NEI - National Emissions Inventory

•	NH4 - Ammonium

•	N03 - Nitrate

•	OAQPS - Office of Air Quality Planning and Standards

•	OAR - Office of Air and Radiation

•	OC - Organic Carbon

•	ORD - Office of Research and Development

•	PAMS - Photochemical Assessment Monitoring Stations

•	PM2.5 - Particulate matter with a diameter of 2.5 micrometers or less

•	S - Sulfur

•	Si - Silicon

•	SIP - State Implementation Plan

•	SLT - State, Local, and Tribal

•	S02 - Sulfur Dioxide

•	S04 - Sulfate

•	STN - Speciation Trends Network

•	VOCs - Volatile Organic Compounds

•	Zn - Zinc

Acknowledgements

The following people were involved with the analysis and helped determine recommendations.
CSN Assessment Team:

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Beth Landis, Joann Rice, Lewis Weinstock and Tim Hanley - EPA OAQPS
Adam Reff, Neil Frank and Liz Naess - EPA OAQPS
Tesh Rao - EPA OAQPS
Jim Kelly - EPA OAQPS
Beth Palma - EPA OAQPS
Beth Hassett-Sipple - EPA ORD
Alan VanArsdale - EPA Region 1
Daniel Garver - EPA Region 4
Rich Poirot - NACAA

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