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Correspondence


Document
March 13, 1997

Dennis Drake, DirectorAir Quality Division
Michigan Department of Environmental Quality
Hollister Building
P.O. BOX 30473
Lansing, Michigan 48909-7973
Dear Mr. Drake:


This letter provides the Region 5 response to your 1997 air quality monitoring plan submitted
in its original form on October 30, 1996. Over the past couple of months, my staff has had a
number of productive discussions with your staff regarding continued clarifications and
modifications of your original proposal.


At this point in time, Region 5 is giving partial approval to Michigan's modified air quality
monitoring network under the provisions of 40 CFR Part 58 25. In general, the monitoring
networks are acceptable. There are some concerns, however, with certain portions of the
ozone and carbon monoxide (CO) monitoring networks. These concerns are described in
more detail later in this letter. With the exception of the portions of the air quality monitoring
networks about which these concerns are expressed, Michigan's air quality monitoring network
is approved.


Region 5 is pleased with Michigan's participation in the Enhanced Ozone Monitoring Program
with the operation of a site in Holland. This site adds valuable downwind transport information
to the Lake Michigan ozone evaluation efforts. Region 5 is pleased to note that Michigan is
operating an NOy instrument at this site and is considering the use of an automated GC for
collection of volatile organic compounds data. Both Illinois and Indiana have had good success
with the automated GC's they have been operating and have provided valuable data which
otherwise would not have been achievable without the use of these instruments.


Region 5 notes that no changes to the sulfur dioxide (SO2) or particulate monitoring networks
are planned for 1997. The status quo for these networks should work fine for this year.
Significant attention should be paid to these networks over the next couple of years, however.
The SO2 monitoring program is likely to undergo significant changes with many of the
population oriented monitors being looked to as candidates for shutting down to save costs
but also with some attention being paid to stepping up monitoring for short term peaks around
targeted point sources. Particulate monitoring will be subject to significant changes if the
proposed changes to the particulate air quality and monitoring regulations are finalized.
Michigan needs to be making aggressive moves to prepare to have fine particulate monitors
operating by January of 1998. Coinciding with the expansion of the fine particulate monitoring
network, the PM10 monitoring network will be looked to for discontinuation of some sites also
for resource savings. Region 5 looks forward to working closely with the State of Michigan and

with Wayne County in targeting the monitors for discontinuation.

During 1996, a special purpose industrial ozone monitor was operated in Mecosta Co. This
site produced useful data for evaluating the overall scope of ozone pollution in the western part
of Michigan's lower peninsula. Michigan had committed to operating an ozone monitor in a
rural portion of this area of the State as part of the directed monitoring portion of its Fiscal Year
1997 grant agreement. In the original version of the 1997 monitoring network proposal, there
was discussion regarding the potential for the operation of an ozone site in partnership with the
American Lung Association in Evart, Michigan which would have fulfilled this monitoring need.
At this point, however, Region 5 understands that Michigan is not likely to operate an ozone
monitor in the portion of the State which would have been represented by the Evart site.
Region 5 believes that this lack of monitoring creates a gap in the data which will be
increasingly important under the proposed ozone standard if promulgated.


The Bay City/Saginaw/Midland area is also a portion of the State where there are concerns
due to a lack of ozone monitoring data. This area is currently classified as having incomplete
data but is subject to discussions regarding a reclassification. This effort has been
complicated by the lack of monitoring data for the area. It is the position of Region 5 that any
maintenance plan for this area must include a monitoring plan to establish a monitoring record
that ensures the area counties maintain the ozone standard. Discussions with your staff have
indicated that a likely location for a monitor to represent this area would be Sebewaing. From
a technical standpoint, this location makes sense. However, since Sebewaing is outside of the
boundaries of the Bay City/Saginaw/Midland area, special consideration must be given. In
order for this location to be acceptable for fulfilling the requirements of the maintenance plan,
acknowledgment that this monitor is representative of the air quality for the Bay
City/Saginaw/Midland status area should be explicitly given. Preferably this would be done in

both future air quality monitoring network plans and in the maintenance plan itself.

The carbon monoxide monitoring network for Detroit continues to be an area of attention for
Region 5. The recent loss of the CO monitoring site in the Evergreen Park area of Detroit to
severe vandalism creates a significant gap in this monitoring network. My staff have been in
close contact with the air quality monitoring personnel in Wayne County and are aware of the
commendable progress which has been made to secure a replacement for this site. The lack
of a solid explanation for the consistently high readings at the Evergreen site (relative to other
CO monitoring sites in Detroit), however, makes this network revision a difficult one to
evaluate. Region 5 staff will likely need to visit Detroit to provide a first hand evaluation of the
new site. Region 5 would also like to work with you and Wayne County to conduct a CO
saturation study using portable battery operated samplers to provide comparative data for the
area next winter. Region 5 has a number of these samplers which we can loan to Wayne
County to assist in this study. Region 5 looks forward to working closely with both your staff and

Wayne County to document that the new site is a quality replacement for the previous site.

Overall, Region 5 is pleased with the quality monitoring program operated by the State of
Michigan and Wayne County With the potential revisions to the National Ambient Air Quality
Standards, air quality monitoring networks are certainly entering an era of challenging
changes. Region 5 is looking forward to working closely with the State of Michigan and Wayne
County to re-design the air quality monitoring networks to meet future priorities. Among the
areas that Region 5 will focus review for the 1998 monitoring network design are ozone
networks and the southwest Detroit and surrounding suburbs near the heavily industrialized
area in this part of Wayne County


Thank you for the chance to review the 1997 air quality monitoring network plans for the State
of Michigan and Wayne County If you have questions or comments on our review, please
contact Mr. William Damico at (312) 353-8207 or by e-mail at
damico.william@epamail.epa.gov.


Sincerely yours,

/s/

David Kee, Director

Air and Radiation Division

cc:
Ronald D. Kooistra, P.E., Unit Chief
Air Monitoring Unit
Michigan Department of Environmental Quality


Wendy R. Barrott, Director
Air Quality Management Division
Wayne County Department of the Environment



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This Information Last Modified On: 09/18/2008 03:58 PM