Context Corner Edition 3 – Calibrations and Concentrations
In this installment, we share directly from a recent conversation with a community member.
January 17, 2024
By Carrie Crumpton, CNX Vice President of Environmental Strategy
Recently a member of our Westmoreland County community reached out to us with questions about our Radical Transparency monitoring and public disclosure effort. They are excellent questions, and we've summarized that conversation as our first Context Corner installment for 2024.
Thank you for your inquiry regarding CNX’s Radical Transparency program. Our inclusion of a third-party data cloud to provide an unabridged data stream to our collaborative partners in the PADEP is a key element of our transparency efforts and allows for regulatory review and confirmation of the data we publish for stakeholder review. Additionally, the third party provides quality assurance and quality control, not only for the data, but in the selection, operation, calibration, and maintenance of monitoring equipment in this program. Below, we have paraphrased your questions and provided detail that we hope will demonstrate our commitment to the region and concerns of our neighbors.
Does CNX perform calibrations on the monitoring equipment?
Quality assurance and quality control for the Radical Transparency program are performed by a third party consultant in order to ensure unabridged data as well as the opportunity for unbiased regulatory review and confirmation. The third party reports the data to the PA Department of Environmental Protection and CNX. They also select, operate, calibrate, and maintain the monitoring equipment
CNX selected the third-party consultant, in part, due to their development and maintenance of their own ambient monitoring Quality Monitoring Plan (QMP) that describes their quality control program for ambient air monitoring services. Their QMP was audited by the United States Environmental Protection Agency (EPA) in 2023 and approved for the operation of State and Local Air Monitoring Stations (SLAMS). Under their guidance, CNX’s monitoring network is being developed following procedures prescribed by the Quality Assurance Requirements for Monitors Used in Evaluations of National Ambient Air Quality Standards (40 CFR 58, Appendix A), which are the same requirements the PADEP and ACHD must follow in our regional SLAMS. Additionally, CNX has developed a Quality Assurance Project Plan (QAPP) that is currently undergoing review by the PADEP. The QAPP will provide the foundation of all our procedures and, once final, will be expanded to guide our activities at all locations.
To meet regulatory standards, CNX has chosen MetOne Instruments’ model BAM-1022 for PM2.5 monitoring. The BAM 1022 is designated a Class III Federal Equivalent Method (EQPM-1013-209) and collects PM2.5 at a precisely controlled sample flow rate, using beta rays to continuously determine the mass concentration of PM2.5. As this device is essentially weighing a solid sample, there are no gaseous calibrations. Instead, after site installation, the consultant performs a site acceptance test that includes equipment and measurement data checks, initial sensor and equipment calibrations, communication equipment checks, and other applicable QC checks, which include a multi-point flow rate calibration/calibration verification check to ensure the proper flow, and an initial 72-hour zero background test.
During operation, all monitoring, sampling, and test equipment used for data generation or sample collection is periodically calibrated to maintain performance within specified limits. Calibrations are conducted using transfer standards that can be traced to national standards maintained by the National Institute of Standards and Technology (NIST.)
Regarding BTEX sampling, CNX has selected a method that collects a sample on the surface of a specially treated material that is prepared by a laboratory. After 14-days of sampling, the sample is returned to the laboratory for analysis. The installation and sampling procedures are subject to a variety of QA/QC measures and calibrations are performed on the analytical side of the program. The laboratory ensures accuracy through their internal quality program and maintains certifications through state and national environmental laboratory accreditation programs.
How do you explain the difference in concentrations between project site readings and official sources?
The PM2.5 readings from each monitoring location is compared to PADEP monitoring stations that are chosen based on proximity, similarity in land use, and population density. Since PM2.5 is a byproduct of a variety of activities, one of which being fuel combustion, it is not unreasonable to expect areas having high population density, heavily travelled roadways, and industrialized river valleys to see higher concentrations of PM2.5 than those observed in the rolling farmlands of Washington and Greene counties.
Since PM2.5 is also transported regionally, monitoring sites will see contributions from sources located far upwind. CNX elected to install two PM2.5 monitors at each site, one situated upwind of each site, based on prevailing winds, and the other downwind. Even though we are comparing our results to regional compliance monitors, we expect slight differences in concentration due to local variations. Our upwind monitors provide a localized background reading while the downwind monitors provide differences that can be attributed to contributions from the site.
Our current monitoring site results are being compared to the PADEP Holbrook monitoring Station. A quick review of the PADEP 2023 Annual Ambient Air Monitoring Network Plan (available here) shows annual average PM2.5 concentrations at Holbrook ranging from a high concentration of 7.9 micrograms per cubic meter (μg/m3), in 2021, to a low of 4.6 μg/m3 in 2016. The hourly readings of raw data CNX has been reporting are within this range and may be adjusted when fully reviewed.
Do you plan to implement monitoring at any Mamont or Bell Point (Westmoreland County) area facilities?
With the commencement of this program, we are installing monitors at each of our production facilities as the next planned phase of development is initiated. What does this mean? In short, if a facility is not currently outfitted with monitoring devices, we will install monitors at the site before the next development phase begins and perform monitoring there continuing through all remaining phases of development and a minimum six months of the production phase.
Our plans include any site currently being developed, including the facilities you mention, as well as our Mamont Compressor Station. Based on our current schedule, our near-term plans include startup of monitoring before hydraulic fracturing at the MAM16 well pad and, on the MAM15 well pad, shortly after electrical power is available. Additionally, we are currently working with the PADEP to obtain access in this area to install a DEP-owned and operated monitoring station at a future well pad that will include monitoring for up to a year before well pad construction is started and serve as the upwind monitoring device for that site.
Thanks for the opportunity to respond to your questions. We look forward to answering more questions from the community in 2024.