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EPA Home > Region 5 > Air > Correspondence


March 13, 1997

Donald Theiler, Director
Bureau of Air Management
Wisconsin Department of Natural Resources
P.O. Box 7921
Madison, Wisconsin 53707-7921

Dear Mr. Theiler:

This letter is in response to your letter of December 9, 1996, regarding the annual review of
Wisconsin's Air Monitoring Network and the subsequent conference call on December 17 to
discuss the contents of that letter and a follow-up letter dated December 13. As always,
Region 5 is encouraged by the thorough job of network planning performed by the State of
Wisconsin and the efforts undertaken to keep the U.S. Environmental Protection Agency
informed of your network plans.

The documents provided described the monitoring plans for criteria pollutant monitoring and
total suspended particulate (TSP) monitoring. Plans for monitoring of organic compounds,
meteorology and other ozone precursors at Photochemical Air Monitoring Stations (PAMS)
are not described in the documents. The PAMS monitoring plans were discussed during the
conference call, so comments are being made on this portion of the network, however, review
can only be made of the National Air Monitoring Stations (NAMS), State and Local Air
Monitoring Stations (SLAMS) and Special Purpose Monitoring stations (SPM) networks.

Region 5 is pleased with the NAMS, SLAMS, and SPM monitoring programs for the criteria
pollutants (i.e. carbon monoxide (CO), 10 micron particulates (PM10), nitrogen dioxide (NO2),
sulfur dioxide (SO2) ozone (O3), and lead) as well as TSP and fine particulate monitoring
(PM2.5) being operated by the State of Wisconsin. Therefore, I am approving these portions of
the monitoring network. Without being able to review the PAMS portion of the monitoring
network, I cannot give full approval to the Wisconsin monitoring program for meeting the
requirements of 40 CFR Part 58.

Region 5 is particularly pleased with the proactive approach to the fine particulate monitoring
program. The planned network of a minimum of four and possibly as many as seven PM2.5
monitors for 1997 is very encouraging. The mixture of dichotomous and Partisol along with
PM10 and TSP samplers at various sites should provide very valuable research information
which will aid in the planning of the PM2.5 monitoring network among other analyses. Funds
allocated for funding PM2.5 monitoring efforts in Fiscal Year 1997 were included in the 105
grant allocation already made to Wisconsin. Discussions about portions of the Fiscal Year
1998 105 grant allocation to direct to PM2.5 monitoring efforts are currently ongoing. We
further look forward to learning about the operation of PM2.5 instruments along with Wisconsin
during the coming year. Specifically, we would like to participate in any training on monitor
set-up and calibration provided by the manufacturer.

The TSP and SO2 monitoring networks were identified as potential targets for reductions in
order to save money for other programs under the re-engineering program. Region 5 supports
these areas as likely places for cost savings. Wisconsin has also reduced its roadway
oriented lead monitoring network to only one monitor. Under plans currently being considered,
the requirement for the remaining roadway oriented lead monitor may be removed. Only 20 or
so roadway oriented lead monitors (one in each of the 20 largest cities) are anticipated to be
required for trends purposes. Region 5 would like for Wisconsin to consider reporting the peak
5-minute averages from some of the remaining point source oriented SO2 monitors in addition
to the hourly averages.

The only area of some concern is the PAMS network. Three monitoring sites have been
operating well already in Wisconsin. However, the alternative PAMS monitoring plan agreed to
by the Lake Michigan States and Wisconsin's monitoring portion of the State Implementation
Plan (SIP) call for Wisconsin to begin operating a fourth site at Wind Point this year. Region 5
understands that it will not be possible to place the site at Wind Point, but has not heard plans
yet from Wisconsin to locate this monitoring site at an alternative location. This lack of
compliance with the PAMS sampling plan and the SIP is a source of concern.

Region 5 is also not sure what Wisconsin's plans are for collecting non-methane hydrocarbon
data at the University of Wisconsin-Milwaukee site. Hourly readings collected by automated
GC by both Illinois and Indiana have proved to be reliable and valuable. Consideration of this
change in operations should be given during the PAMS re-engineering discussions to take
place this year. We look forward to participating in discussions regarding other changes to
operations including phasing in NOy monitoring in place of NOx monitoring.

Overall, Region 5 is very pleased with the monitoring program in Wisconsin. We are aware
that this program is facing some real challenges in the coming years in terms of implementing
monitoring networks to collect data for the new fine particulate standard anticipated to be
promulgated, continued operation and expansion of the PAMS monitoring networks, and
possible expansion of ozone networks into rural areas subject to transport. Therefore, we look
forward to a year of continued close interaction with Wisconsin as tough decisions are made.

Thank you for the chance to review the 1997 monitoring network for the State of Wisconsin. If
you have questions or comments on our review, please contact Mr. William Damico at (312)
353-8207 or by e-mail at

Sincerely yours,


David Kee, Director
Air and Radiation Division

cc: Bruce C. Rodger, Operations Unit Leader
Air Monitoring Section
Bureau of Air Management

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