Pennsylvania s 2015 Ambient Air Monitoring Network Plan. Comment/Response Document

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1 Pennsylvania s 2015 Ambient Air Monitoring Network Plan Comment/Response Document July 2015 Tom Wolf, Governor Commonwealth of Pennsylvania John Quigley, Secretary Department of Environmental Protection 1

2 Comment and Response Document Concerning Pennsylvania s 2015 Annual Air Monitoring Network Plan On May 16, 2015, the Pennsylvania Department of Environmental Protection (Department or PA DEP) published a notice in the Pennsylvania Bulletin concerning public inspection of Pennsylvania s 2015 Ambient Air Monitoring Network Plan (hereinafter Network Plan). (45 Pa.B. 2343). The plan outlines the air monitoring program history, provides an overview of the air monitoring network and discusses in detail monitoring sites, methods and equipment. Two sections of the plan deal with past and anticipated monitoring activities for a period of 18 months. In the 2015 Network Plan, the Department outlines the agency s continued commitment to conduct federally required ambient air monitoring as well as to assess air quality impacts related to shale gas activities in Pennsylvania, in both the southwestern and Northern Tier regions of the Commonwealth. The PA DEP has retained the Houston site in Washington County (originally installed as part of the Marcellus Long-Term Monitoring Project) as part of its permanent NO 2 monitoring network, and installed a PM 2.5 monitor in Tioga County. The Department also plans to install carbonyl samplers at the Mehoopany (Wyoming County) and Springville (Susquehanna County) monitoring stations, and establish a new SLAMS monitoring site in Fayette County. The Department has installed an ozone monitor at its regional background site, Arendtsville (Adams County), and plans to establish an additional Adams County monitoring site near Gettysburg, PA. Due to a loss of EPA funding, the Department discontinued six of its supplemental PM 2.5 speciation sites, while retaining seven. Two additional speciation monitors were added to the Chester and Marcus Hook (Delaware County) monitoring sites. PM 2.5 and speciation data from these sites will allow the Department to further evaluate elevated PM 2.5 levels measured at the Chester site. The Department also plans to relocate the PM 2.5 monitor from Lehigh Valley (Northampton County) to Allentown (Lehigh County), and initiate metals sampling at the existing Ellwood City (Lawrence County) monitoring site. Notice of the availability of the proposed Network Plan for public review and comment was published in the Pennsylvania Bulletin on May 16, 2015 (45 Pa.B. 2343). The public comment period on the proposed Network Plan closed on June 16, This document summarizes the written comments received during the 30-day public comment period from a number of commentators. Most comments received demonstrate concern about the effects of natural gas drilling and/or power plant emissions on air quality and public health. Comment summaries and the Department s responses follow the list of commentators. 2

3 List of Commentators for Pennsylvania s 2015 Ambient Air Monitoring Network Plan 1. Emily Krafjack, Connection for Oil, Gas, and the Environment in the Northern Tier (C.O.G.E.N.T), Wyoming County 2. Vera Scroggins, Susquehanna County 3. Roy Bennett, et al., Mehoopany Creek Watershed Association,Wyoming County 4. Audrey Gozdiskowski, [location not given] 5. Dr. Steve Hovan, Indiana University of Pennsylvania, Indiana County 6. John Baillie, Group Against Smog and Pollution (GASP), Allegheny County COMMENTS AND RESPONSES. The identity of each commentator making the comment is indicated by the assigned number in parentheses after each comment. Comments Regarding Air Quality Monitoring in the Northern Tier Counties of Pennsylvania 1. Comment: The commentator expresses appreciation of the Department s installation of a PM 2.5 monitor in Tioga County. The commentator also appreciates the data which is coming out of the VOC monitor in Springville Township, Susquehanna County, noting that this data is helpful in determining levels of harmful substances such as benzene and toluene. When levels of these and other VOCs have been elevated, the commentator appreciates the extra work of the Department s actions to investigate further. The commentator also strongly supports the Department s intention to add carbonyl samplers to the Mehoopany and Springville sites. (1) Response: The Department appreciates all of the positive comments regarding the increased monitoring activity across the Northern Tier and all areas affected by shale gas activities. During the past few years, the Department has been proactive in listening to citizen concerns about air quality issues, and has responded by conducting investigations, performing special studies, and installing monitors as circumstances have warranted. Monitoring activities have increased at the Tioga County and the Towanda (Bradford County) sites and, as the commentator noted, carbonyl sampling will be commencing at both the Springville (Susquehanna County) and Mehoopany (Wyoming County) sites. Monitoring data obtained from these sites can provide information to determine and characterize the regional air quality impacts from drilling activities and compressor stations. Recently, there has been an attempt to right-size the statewide air monitoring network to discontinue monitors across the Commonwealth where the data show no long-term compliance issues with the NAAQS and move them to areas where there are concerns, such as across the Northern Tier and other areas affected by shale gas activities. 2. Comment: The commentator recommends that the Springville monitoring location be retained as a permanent site and to expand the pollutants monitored at the site. The commentator indicates that the data obtained by the VOC monitor at Springville thus far 3

4 has provided valuable information for evaluation and characterization of air quality impacts in the area, and would continue to be a worthwhile asset, as shale gas activities continue to expand in the region. In addition, in light of the elevated benzene and toluene levels measured at the Springville monitoring site, and due to proposed and ongoing construction of other natural gas facilities and power plants across Susquehanna County, the commentator recommends the placement of a PM 2.5 monitor at Springville. (1) (4) Response: The Department plans to retain all sites currently operational in the Northern Tier counties for the foreseeable future. The Department continues to analyze the data obtained from these sites, as well as meteorological data across the Northern Tier, to evaluate the impacts of shale gas activities in the region, including the Springville and Mehoopany air toxics monitoring sites. Based on an analysis of the criteria pollutant data collected to date, the Department has found concentration levels of all pollutants monitored in the north-central region so far to be below National Ambient Air Quality Standards (NAAQS). All of the data collected from the Susquehanna, Bradford, and Tioga County monitoring sites (along with data from all of the Department s monitoring sites) is posted on the Department s web site at At this time, the Department does not intend to install additional PM 2.5 monitors at existing monitoring stations in the Northern Tier. However, due to the development of Marcellus Shale gas related activities across PA, the Department will continue to analyze if additional monitoring, including for particulates and VOC, will be necessary to ensure that the public s health is protected in all areas of the Commonwealth. 3. Comment: The commentators recommend that the VOC monitor in Mehoopany remain in place for another year, and that a PM 2.5 monitor be installed at the site, due to increased incidences of health problems, as well as in light of expansion of shale gas operations in the area. Wyoming County has the highest concentration of VOC emissions within the Northern Tier region. In addition, several new VOC point sources are slated to be installed in the near future. VOCs may be absorbed by PM 2.5 and thus impact the level of fine particulates in the region. (1) (3) (4) Response: As noted in the Department s response to comment #2 above, the Department continues to evaluate and expand on permanent monitoring as well short-term air quality projects across the Northern Tier, as the expansion of drilling activities and compressor stations continue, and will maintain a presence in the area for the foreseeable future including the Mehoopany VOC sampler. At this time, the Department does not plan to install a PM 2.5 monitor at the Mehoopany site. The Department will, however, continue to analyze data from Mehoopany and other nearby sites to determine if additional 4

5 monitoring is needed, including for particulates and VOCs, to ensure that the public s health is protected in all areas of the Commonwealth. 4. Comment: The commentator recommends that the Department install a VOC monitor at the Tioga County site. VOCs may be absorbed by PM 2.5 and thus impact the level of fine particulates. In order to further evaluate the air quality impacts with regard to the VOC component of PM 2.5, the installation of a VOC monitor at the Tioga County site is recommended as a complement to the PM 2.5 monitor currently operating at the site. (1) Response: As noted in the Department s response to comment #2 above, the Department continues to evaluate and expand on permanent monitoring as well short-term air quality projects across the Northern Tier, as the expansion of drilling activities and compressor stations continue, and will maintain a presence in the area for the near future. At this time, the Department does not plan to install a VOC monitor at the Tioga County site. The Department will, however, continue to analyze data from Tioga and other nearby sites to determine if additional monitoring is needed, including for particulates and VOCs, to ensure that the public s health is protected in all areas of the Commonwealth 5. Comment: The commentator requests that the Tioga County site be included in the EPA s AirNow database as well as AQI alerts for action days for PM 2.5 and ozone. Currently, the Department does not issue alerts in this region for Air Quality Action Days. However, data obtained from the Tioga County monitoring site indicated several days in 2014 for which the AQI met the threshold for an action day. (1) Response: During the past several years, the Department has expanded its AQI forecasts in the Scranton-Wilkes Barre, State College and Williamsport areas. When the Department issues Air Quality Action Days for either ozone or PM 2.5, the Department is forecasting that conditions will reach Code ORANGE or higher based on EPA s Air Quality Index (AQI) scale. As outlined on EPA s AirNow website ( the Code ORANGE threshold, which is considered to be unhealthy for sensitive groups, has an AQI scale rating of 101 or higher. During 2014, the Tioga monitoring site did not measure values meeting the threshold for an AQI rating of 101. During 2014, the Tioga site measured ten days as moderate (AQI above 50), with the remaining days qualified as good. Data currently available continues to be analyzed for a more complete assessment of air quality across the region. The Department will continue to analyze the recently monitored ozone and PM 2.5 concentrations and work toward developing an understanding of how the pollutants react to and interact with the Northern Tier region s topography, land utilization and meteorology. Due to the lack of meteorological data in the Northern Tier, the process to evaluate the meteorological impacts is challenging. It is the meteorological impacts with respect to the air quality levels that are critical to developing an accurate forecast. In 5

6 light of the public comments received, the Department is examining the feasibility of developing a forecast for ozone and PM 2.5 for additional Northern Tier counties. 6. Comment: The commentator recommends that the Department analyze forthcoming emissions data from the Panda Liberty Natural Gas Electric Power Plant to determine if any additional monitoring is needed in Bradford County. In addition, emissions data on all well pads be reported into the emissions inventory. (1) Response: With regard to emissions inventories, the processes and requirements for emissions reporting are not addressed in this plan. 7. Comment: The commentator recommends that funding be increased to the Department to allow for public health protection in all rural areas across Pennsylvania affected by shale gas activities. (1) Response: The Department intends to focus on areas of need, including rural areas, and will continue to use the annual assessment and public comment process to examine where to best utilize its resources. 8. Comment: The commentator stresses the need for 24/7 monitoring of VOCs and formaldehyde at compressor stations in Susquehanna County. She notes that while VOCs are being monitored at Springville, this is only a 1 in 6 day canister sample, and the data is not real-time hourly data. The commentator is concerned that the 1-in-6 day schedules, as well as the sample duration being an average over 24 hours, does not allow for the capture of VOC spikes that may occur over several hours, or during days when no sampling is conducted. (2) (3) Response: The Department appreciates the concerns of the commentator. As noted in the response to comment #2 above, the Department continues to evaluate and expand on permanent monitoring as well short-term air quality projects across the Northern Tier, as the expansion of drilling activities and compressor stations continue, and will maintain a presence in the area for the foreseeable future. During the next year, the Department plans to commence systematic carbonyl sampling at the Springville (Susquehanna County) monitoring site. Formaldehyde is a carbonyl compound and the method by which the Department is collecting the data (Method TO-11a) is designed specifically to measure formaldehyde in ambient air. Seven other carbonyls will also be monitored. The Department s air monitoring network for toxics is designed for systematic ambient air sampling to estimate annual mean concentrations of select hazardous and toxic air pollutants for the purpose of risk/hazard assessment screening and long-term trend analysis. The Department does not feel continuous VOC monitoring is warranted at the Springville monitoring station. As current data is analyzed and compared to other 6

7 monitoring stations both in the Commonwealth and nationally, the Department will evaluate if more periodic VOC monitoring would be needed. 9. Comment: The commentator expresses appreciation for the Department s installation of a VOC sampler in the Mehoopany Creek Watershed, as well as the Department s intent to install a carbonyl sampler at this location. (3) Response: The Department thanks the commentator for the positive comments regarding the installation and planned installation of monitors at the Mehoopany site. 10. Comment: The commentator comments on the need for Air Quality Index (AQI) monitoring and forecasting for Wyoming County, owing to the large percentage of sensitive populations living in Wyoming County. The commentator expresses concerns that more regional forecast areas, such as the Scranton-Wilkes-Barre forecast area some 30 miles distant, are not adequate characterizations for Wyoming County. (4) Response: The Department appreciates the concerns of the commentator. As noted in the Department s response to comment #5, data currently available from the Northern Tier Counties continues to be analyzed for a more complete assessment of air quality across the region. As analysis of the data becomes more complete and the Department gains a better understanding of how to accurately forecast air quality in these regions, the Department will examine the feasibility of developing a forecast for ozone and PM 2.5 for additional Northern Tier counties. 11. Comment: The commentator expresses concerns that the 1-in-6 sampling protocols are not adequate to capture short-term spikes, or elevated values occurring on days not sampled. The commentator requests 24/7 real time monitoring for PM 2.5, formaldehyde, and VOCs at the Springville and Mehoopany sites, as well as VOC monitoring near the silica plant in Tunkhannock. (4) Response: As noted in the Department s response to comments #2 and #8, the Department continues to evaluate the existing network and, when warranted, will expand the monitoring network to accommodate identified monitoring needs. As development of unconventional natural gas resources continues in the northeastern and north central regions of the Commonwealth the Department will maintain a monitoring presence in the area. The Department will continue to analyze data from Mehoopany and other nearby sites to determine if additional monitoring is needed. Comments Regarding Air Quality Monitoring in Indiana, PA 12. Comment: The commentator expresses the need for increased monitoring in the Indiana, PA area. Installing an additional monitoring site in Indiana, PA would enhance the 7

8 limited monitoring performed at the current Shelocta and Strongstown monitoring sites, and allow the Department to better characterize air quality impacts from the operation of two power plants located upwind of the area. In particular, no PM 2.5 monitoring is currently performed at either of these two sites. As the Indiana, PA area is located in the geographical center of shale dry gas development, but has only a limited amount of gas development to date, monitoring in this area provides the Department with an opportunity to develop a baseline air quality profile that can be used to more accurately characterize air quality impacts that would be measured once heavy development occurs within the area. The commentator notes that this monitoring would be a benefit to IUP in terms of research and scientific study and that the university would be able to offer the services of its faculty for data analyses. In addition, there is proposed construction of a natural science complex at the university where an air monitoring station could be incorporated. (5) Response: The Department appreciates the concerns of the commentator, and the offer of a collaborative monitoring effort. The Department does partner with universities and colleges on a limited basis to provide expanded monitoring in the Commonwealth. The Department will work on developing a relationship with Indiana University of Pennsylvania over the next several years and is open to expansion of monitoring in Indiana County, via partnership with the university. The Department appreciates the commentator s point regarding PM 2.5 monitoring downwind of coal-fired power plants, and will examine the feasibility for installing a PM 2.5 monitor at the Strongstown monitoring site. The Shelocta monitoring site, is a source-oriented site, specifically located to measure maximum lead concentrations from the nearby Keystone Generating Station, and as such is not suitable to measure area-wide impacts on PM 2.5 levels. 13. Comment: The commentator expresses the need for SO 2 monitoring downwind of the Cheswick Power Plant in Allegheny County, as it is a major source for SO 2 emissions and no monitors exist directly downwind of this facility. (6) Response: The Department appreciates the concerns of the commentator. With regard to SO 2 monitoring, the US EPA s SO 2 data requirements rule is planned to be finalized in Fall The emission and population thresholds outlined in the new SO 2 data requirements rule will be used to determine if and where additional SO 2 monitoring is needed. Although the Cheswick power plant is located in Allegheny County, the Department expects that modeled maximum concentrations will occur outside of the county (due to its location with respect to the county boundaries). Once the final SO 2 data requirements rule is published in the Federal Register, the Department will undergo an analysis of all qualified sources, including Cheswick, which is expected to meet the 8

9 emission/population threshold selected by EPA. The Department will include additional information on the forthcoming SO 2 analyses in its 2016 Annual Network Plan. 14. Comment: The commentator recommends that the Charleroi site be moved, or a new site installed, downwind of the newly-reactivated Monessen Coke plant, and monitor for SO 2, PM 2.5 and air toxics. The newly-reactivated Monessen Coke plant operates as a major source for SO 2 and an area source for HAP.(6) Response: The Department will examine the feasibility installing a new monitoring site downwind of the Arcelor Mittal facility in Monessen. 15. Comment: The commentator requested the Department to install a PM 2.5 monitor at its Strongstown monitoring site, downwind of the Keystone Generating Station (Armstrong County), Homer City, Conemaugh and Seward Generating Stations (Indiana County), which are coal-fired power plants. (6) Response: The Department appreciates the concerns of the commentator. With regard to SO 2 monitoring, the US EPA s SO 2 data requirements rule is planned to be finalized in Fall The emission and population thresholds outlined in the new SO 2 data requirements rule will be used to determine if and where additional SO 2 monitoring is needed. Once the final SO 2 data requirements rule is published in the Federal Register, the Department will undergo an analysis of all qualified sources which is expected to meet the emission/population threshold selected by EPA. The Department will include additional information on the forthcoming SO 2 analyses in its 2016 Annual Network Plan. 9