February 5, 1998
PM 2.5 Monitoring
David Kee, Director
Air and Radiation Division, Region 5
John S. Seitz, Director
Office of Air Quality Planning and Standards
Thank you for this opportunity to provide input on (1) the ability of the States in Region 5 to deploy and operate the PM 2.5 network, (2) the number of proposed monitoring sites by State, (3) early estimates for the types of monitors to be purchased by the National Contract and (4) views on merging the PM 2.5 and visibility networks.
Ability of the States to deploy and operate the PM 2.5 network
The States in Region 5 are committed to implementing the network and have been involved in the multiple activities that comprise this undertaking since the PM 2.5 standard was promulgated in July 1997. They do have significant uncertainty, however, as to whether they will be able to establish the network on the rigorous timetable that USEPA has established.
One concern shared by all of the States in Region 5 centers on funding. Despite the promise of future funding, the States have had to carry out preliminary network design activities with staff, that because of decreases in allocations over the last few years, were already overburdened with the requirements of their existing monitoring networks. States are pleased that the 103 grant process will be used to fund the PM 2.5 program, including personnel costs. States are skeptical, however, that 103 grant dollars will be made available to them by March 1998. They indicate that even if this timetable is maintained, it may be difficult to hire and train staff for field and laboratory operations in a timely fashion, if at all. Several States have expressed interest in the availability of Federal interpersonnel agreements, or other vehicles for obtaining personnel for this program.
Some special circumstances exist in Region 5 which may deter the timely development and operation of PM 2.5 monitoring.
Michigan is under a full time equivalent (FTE) cap, and, as such, the Michigan Department of Environmental Quality will not be able to add the positions necessary for operation of the new network. They are investigating the use of limited-term positions and contract services.
Indiana is similarly unable to hire any new personnel that will be necessary for the operation of the PM 2.5 monitoring network. They are investigating use of temporary or contract employees, as well as developing a reprioritization of their monitoring goals.
Minnesota Air Pollution Control Agency is currently undergoing reorganization, and despite available funds it is unlikely that they will be able to hire new staff for at least six months.
Another concern shared by the States is the tenuous balance among all of the critical elements that are essential to successful deployment and operation of the PM 2.5 network. States are not optimistic that adequate funding will be available by March 1, 1998, that the timely distribution of PM 2.5 monitoring equipment will begin, as scheduled, by June 1, 1998, and that the PM 2.5 monitoring equipment will perform in an acceptable fashion in the field. If any one of these elements does not occur on schedule, the target number of monitors to be implemented, which for Region 5 in FY 98 is approximately 172, may not be achieved. States believe that EPA has not done a good job to date of providing PM 2.5 information and guidance in a timely fashion that reflects milestones that States must meet. Furthermore, States have stated that equipment manufacturers have indicated to them that the June 1, 1998 delivery date for PM 2.5 monitoring equipment is unrealistic.
The States have concerns about their ability to select the monitor vendor of their choice if they participate in the National Monitor Procurement Contract. The States have indicated that if they receive monitors from multiple vendors, it will add an unnecessary complexity to their already intense monitoring program. They will be required to develop multiple standard operating procedures and quality assurance plans as well as train field personnel in the operation, maintenance and troubleshooting of multiple monitor designs at a time when they are already being asked to perform the herculean task of deploying a large monitoring network in a very short time period. They will also need to maintain spare parts inventories for several monitor brands.
In addition, because they will be required to collocate 25% of the monitors of each brand and type, their internal Quality Assurance program will become unnecessarily more complicated.
Another concern shared by the States is the anticipated switch from 103 grants to 105 grants for funding the PM 2.5 program after two years. States believe that the PM 2.5 program is very expensive and have stated that it is unlikely that there will be sufficient State funds for the State match as required by the 105 grants.
The number of proposed monitoring sites by State
The States have indicated that they plan to operate approximately the number of sites that EPA has proposed. In some cases, they plan to include a few more sites than proposed, and in other cases, they plan to include a few less sites than proposed. Information that is available to date is as follows:
Number of Sites Proposed by EPA
Number of Sites Proposed by State
I would like to point out that the draft allocation of monitoring sites for Region 5 shows that there are five PM 2.5 monitoring sites that were purchased with FY 97 funds, four in Ohio and one in Michigan. Neither Ohio nor Michigan made any commitment to PM 2.5 monitoring in their FY 97 grant agreements, and neither State has purchased a PM 2.5 monitor to date. It is essential that the allocation of funding for PM 2.5 reflect this information.
Early Estimates for Types of Monitors to be purchased by the National Contract
The States have provided preliminary information on the types of monitors they wish to purchase through the national procurement contract (Attachment). They emphasize that this information is subject to change because their network designs are still in the very early planning stage.
The information is also based on guidance that for QA purposes, 25% of the monitors must be collocated with a like monitor so that a sequential sampler must be collocated with a sequential sampler and a single event sampler must be collocated with a single event sampler.
Views on Merging the PM 2.5 and Visibility Networks
I believe that in addition to being an effective use of resources, the data collected in support of the Regional Haze program will provide invaluable insight into regional transport of fine particulate matter. States had no adverse comments on merging the PM 2.5 and Visibility Networks. There is concern, however, about added resources that will be necessary to implement the Regional Haze program, particularly as it will require State matching funds at the same time as the PM 2.5 program begins operating under the 105 program.
Thank you, once again, for this opportunity to provide input on issues that can affect the successful operation of the PM 2.5 monitoring program. If you have any questions, please contact me or Maryann Suero of my staff at (312) 886-9077.
For further information, contact:
This Information Last Modified On:
09/18/2008 03:58 PM