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- 1 APPENDIX C 

# PM2.5 Continuous Monitor Comparability Assessment and Request for Waiver

Introduction The SCAQMD monitoring program has historically operated PM2.5 continuous monitors primarily to support forecasting and reporting of the Air Quality Index (AQI). These monitors supply data every hour to update the AQI on our web site as well as national web sites such as
A ir Now (www.airnow.gov). SCAQMD has been using these monitors since the early part of the last decade as the PM2.5 monitoring program was implemented . Over the last few years, a
number of PM2.5 continuous monitors have been approved as Federal Equivalent Methods (FEMs). By utilizing an approved FEM, an y subsequent data produced from the method may be eligible for comparison to EPA’s health based standard known as the NAAQS. The primary advantage of operating a PM2.5 continuous FEM is that it can support the AQI, while also supplying data that are eligib le for comparison to the NAAQS. Thus, a network utilizing PM2.5 continuous FEMs can potentially lower the number of filter

- based FRMs operated in the network, which are primarily used for comparison to the NAAQS. These filter

- based FRMs are
resource intens ive in that they require field operations as well as pre

- and post

- sampling laboratory analysis which results in data not being available for approximately 2

- 4 weeks after sample collection.

The SCAQMD monitoring program has been evaluating PM2.5 continu ous FEMs over the past several years. Although the PM2.5 continuous FEMs are automated methods, these methods still require careful attention in their set

- up, operation, and validation of data. Once enough data was collected, we began to evaluate the perfo rmance of these methods compared to collocated FRMs. That evaluation is explained further below and includes our request regarding the use of the data
from these methods.

Request for Exclusion of PM2.5 Continuous FEM data from Comparison to the NAAQS The network technical requirements for requesting exclusion of data from comparison to the NAAQS are identified in 40 CFR §58.11(e). These requirements re fer to the performance criteria

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- 3 described in Table C

- 4 to subpart C of part 53. To accommodate the differences in how routine monitoring agencies operate their networks, several additional provisions are described in §58.11(e). When a topic is not addressed in §58.11(e), then the test specifications from table C

- 4 applies.

As shown in the Table below, the slope s of the regression between collocated FRM and FEM measurements at the Anaheim, Central Los Angeles, North Long Beach, South Long Beach, and
Rubidoux (POC 3) stations are higher than 1.1, which is outside the test specification indicated
in §53 Table C

- 4 (i .e. slope = 1 ± 0.1). Although the slope criteria was met, t he intercept of the regression relationship between FRM and FEM data at the Burbank , Rubidoux (POC 9) and Mira Loma monitoring sites does not meet the test specifications of between 15.05

- (17.32 × slope), but not less than

- 2.0; and 15.05

- (13.20 × slope), but not more than +2.0 (also indicated
in §53 Table C

- 4).

Thus, in accordance with the PM NAAQS rule published on January 15 th 

### , 2013 (78 FR 3086) and specific to the provisions detailed in §5 8.10 (b)(13) and §58.11 (e), SCAQMD is requesting that data from the all of the SCAQMD FEM PM2.5 monitors be set aside for comparison to the NAAQS. While SCAQMD is working to optimize the monitoring instrumentation to meet all of our monitoring objectives , the performance is not yet at a point where the comparability of the
PM2.5 continuous FEMs operated in our network compared to collocated FRMs is acceptable. After assessing the comparability of the PM2.5 FEMs to the collocated FRMs for our network,
the sites listed below do not meet the comparability requirements. Detailed one

- page assessments from which the information described below was obtained are included at the end of this section.

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- 4 Table

– Request for Exclusion of PM2.5 Continuous FEM Data

Site Name City Site ID Cont POC Cont Method Description PM 2.5

Cont Begin Date PM 2.5

Cont End Date Continuous/

FRM Sampler Pairs Per Season Slope

(m) Intercept

(y) Meets Bias Requirement Correlation

(r)

Sites with PM

2.5 continuous FEMs that are collocated with FRMs

Anaheim Anaheim 06

- 059

- 0007 3 Met

- One BAM

1020 w/VSCC 01/01/

201 2 12/31/

201 4 Winter = 24 6

Spring = 251 Summer = 229 Fall = 259 Total = 9 79 0.99 4.66 No 0. 87

Burbank Burbank 06

- 037

- 1002 3 Met

- One BAM

1020 w/VSCC 01/01/

201 2 06 / 30/

2013 Winter = 25 0

Spring = 2 36 Summer = 187 Fall = 172 Total = 845 1. 05 5.24 No 0.88

Central Los Angeles Los

Angeles 06

- 037

-

1103 3 Met

- One BAM

1020 w/VSCC 01/01/

20 10 09/29/

2011 Winter = 138

Spring = 75 Summer = 95 Fall = 90 Total = 398 1.2 7 1.35 No 0.90

9 Met

- One BAM 1020 w/VSCC 10/01/

201 2 12/31/

201 4 Winter = 247

Spring = 244 Summer = 237 Fall = 236 Total = 964 1.16 5.12 No 0.84

North Long Beach Long

Beach 06

- 037

-

4002 3 Met

- One BAM

1020 w/VSCC 01/01/

201 1 09 /3 0 /

201 3 Winter = 214

Spring = 228 Summer = 255 Fall = 175 Total = 872 1.16 2.23 No 0.94

South Long Beach Long

Beach 06

- 037

-

4004 3 Met

- One BAM

1020 w/VSCC 01/01/

201 2 12/31/

201 4 Winter = 195

Spring = 251 Summer = 223 Fall = 189 Total = 858 1.2 5 0. 50 No 0.93

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- 5 Riverside/ Rubidoux Rubidoux 06

- 065

- 8001 3 Met

- One BAM

1020 w/PM2.5 SCC 01/01/

201 2 01/31/

201 4 Winter = 256

Spring = 248 Summer = 260 Fall = 257 Total = 812 1.1 2 2.86 No 0.62

9 Met

- One BAM 1020 w/VSCC 01 /02/

201 2 12/31/

201 4 Winter = 233

Spring = 237 Summer = 260 Fall = 253 Total = 983 1. 03 3.43 No 0.86

Mira Loma Mira Loma 06

- 065

- 8005 3 Met

- One BAM

1020 w/VSCC 01/01/

201 2 12/31/

201 4 Winter = 262

Spring = 253 Summer = 25 2 Fall = 2 48 Total = 10 15 1. 02 4. 59 No 0.90

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Period of Exclusion of Data from the PM2.5 Continuous FEMs The above table details the period of available data by monitor on which the request to exclude
PM2.5 continuous FEM data is based. Per EPA Regional Office approval, these data will be
entered int o EPA’s AQS database in a manner where the data are only used for the appropriate monitoring objective(s) (i.e., use data for just the AQI). Additionally, SCAQMD will continue to load any new data generated for the next 18 months (intended to represent the period until
December 31 of 201 6 ) in the same manner or until such time we request and receive approval from the EPA Regional Office to change the status of these monitors.

PM2.5 Continuous FEM data for Reporting the AQI While the analysis supports the request for the monitors above not be used for comparison to the NAAQS, the data are of sufficient comparability to collocated FRMs that they be used for public AQI reporting. Therefore, with EPA Regional Office approval we will report these data on our web site and to AIRNow (www.airnow.gov). As such, data submitted to EPA’s AQS database will be under “acceptable AQI” reporting (i.e., parameter code 88101) so that data users will know that these data are appropriate for use in AQI calculations, but not NAAQS comparison.

Assessments The following one

- page assessments are locations where our agency has collocated PM2.5 FRM and continuous FEM monitors. Each of these assessments is represented in the “ Table

– Request for Exclus ion of PM2.5 Continuous FEM Data” above.

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- 7 

# Anaheim
(FRM POC: 1; FEM POC: 3)

### C

- 6 

# Burbank
(FRM POC: 1; FEM POC: 3)

### C

- 6 

# Central Los Angeles
(FRM POC: 1; FEM POC: 3)

### C

- 10 

# Central Los Angeles
(FRM POC: 1; FEM POC: 9)

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- 11 

# North Long Beach
(FRM POC: 1; FEM POC: 3)

### C

- 12 

# South Long Beach
(FRM POC: 1; FEM POC: 3)

### C

- 13 

# Rubidoux
(FRM POC: 1; FEM POC: 3)

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- 15 

# Rubidoux
(FRM POC: 1; FEM POC: 9)

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- 15 

# Mira Loma
(FRM POC: 1; FEM POC: 3)