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SUBJECT: Implementation of PM 2.5 Monitoring Network

   FROM: David Kee, Director
Air and Radiation Division, Region 5

     TO: John S. Seitz, Director
Office of Air Quality Planning and Standards

I would like to express my concern and that of the Region 5 States about the time frame for establishing the PM 2.5 Monitoring Program given the delivery delay to the States of monitors purchased through the national procurement contract.

I appreciate your efforts and those of your staff in facilitating the delivery of the required equipment to the States. Without the development of the national procurement contract, States would now be in the multi step process of purchasing the monitors through their State contract procedures. Along with the States, however, we understood that monitors ordered through the national procurement contract would be delivered in June 1998, or at least would begin to be delivered in June 1998.

As you are aware, Michigan and Wisconsin will begin to receive their monitors in July, with the remainder of the monitors scheduled to be delivered in August and September. Unfortunately, this means that nearly 80 percent of the monitors designated for Region 5 will not be delivered until September or later.

Several factors will affect whether the States will be able to deploy all of their Fiscal Year 1998 monitors by the end of December 1998. The States have little hands-on familiarity with the monitoring equipment. States were each given one of the prototype samplers earlier this year, but none were given the model that they will ultimately have in their networks. This will impede the development of their Standard Operating Procedures, Quality Assurance Project Plans, and training for field operators. States also have their own requirements for monitor acceptance testing, which in most cases is much more rigorous than that required by the Environmental Protection Agency for the States participating in the national procurement contract. These State requirements call for monitors to be operated in a controlled environment, often their laboratory, for up to several weeks of continuous operation, before the managers will release the equipment to the field.

Due to the delay in monitor delivery and to dissatisfaction that Indiana is not scheduled to receive the instrument model of its choice, Indiana has chosen to withdraw from the national procurement contract. I am grateful that you have been flexible regarding participation in this contract.

My staff is working with your staff to make the transfer of funds back to Indiana as quickly as possible, so that Indiana can purchase its monitors directly from its desired vendor.

I fully recognize that every effort is being made in the case of Minnesota to have all 19 monitors delivered to the State by the end of September 1998, because of their climate. In addition to struggling with the threat of cold weather and the copious amounts of snowfall they get in late fall, however, Minnesota will also be struggling with a workforce shortage. Due to their recent reorganization, Minnesota’s Air Division will lose five full time equivalents (FTEs) reducing the staff to twelve FTEs. Because of these exigencies, it will be difficult for Minnesota to have all the required sites operational by January 1, 1999.

Furthermore, Illinois and Ohio will have two of the ten largest fine particulate networks in the nation. The schedule shows that their equipment is due to be delivered during September and October 1998, despite the fact that both of these States are likely to experience cold weather and significant snowfall by mid-November. The States have advised us that even if monitors could be installed as soon as they are received, the time and resources required would still be a limiting factor in having the required number of sites operational by the deadline.

I realize the need to have the required number of sites established by December 31, 1998. Despite the constraints in time and resources, however, I am confident that the States will make their best effort to have as many sites as possible operational by January 1, 1999, and that sites that are not deployed by this date will be established as soon as possible during the first part of 1999. My staff will continue to work with and aid the States in any manner possible to ensure that all required sites are established expeditiously in accordance with the States’ abilities and resources.

If you would like to discuss this matter, please contact me or have your staff contact Maryann Suero, of my staff, at (312)

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