UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 OFFICE OF THE ADMINISTRATOR SCIENCE ADVISORY BOARD May 28, 2001 EP A-S AB-C AS AC-COM-01 -003 Honorable Christine Todd Whitman Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 Subj ect: Exploring Opportunities for Accommodating Emerging Technologies for Continuous Monitoring in Routine Air Monitoring Networks - A Commentary Stemming from a CASAC/Agency Workshop Dear Governor Whitman: The Subcommittee on Particle Monitoring (hereafter, the "Subcommittee") of the Clean Air Scientific Advisory Committee (CASAC) held a public workshop at EPA's Environmental Research Center in Research Triangle Park, NC on Monday, January 22, 2001. The purpose of this workshop was to explore opportunities for accommodating emerging technologies into routine air monitoring networks. The workshop was advertised and convened to provide states and associations of states, vendors and manufacturers of monitoring equipment, and EPA staff with an opportunity to share information and discuss emerging technologies and the implications of considering continuous monitoring in EPA's regulatory monitoring program. To help set the stage for this workshop, staff of the Agency's Office of Air Quality Planning and Standards (OAQPS) produced a brief "white paper" entitled Particulate Matter Monitoring Technology: Revisiting method equivalency and accommodating continuous and other advanced methods. This discussion paper, along with invited presentations and public comments were the starting point for discussions at the workshop. The Subcommittee's role was twofold. First, to serve as an agent for convening the workshop and attracting appropriate experts; and, secondly, to provide a sounding board and source of advice to the Agency on whether it should consider continuous monitoring as part of its regulatory program. After listening to the presentations and the extensive discussion at the workshop, the Subcommittee concluded that EPA should move aggressively forward to bring continuous ------- monitoring into the regulatory monitoring program. To do so we make the following recommendations to EPA: a) Perform a statistical analysis following a Data Quality Objectives (DQO) type process to ascertain what level of precision will be required in the continuous monitors to yield the same information on area-wide average concentrations as a minimum Federal Reference Sample (FRM) PM2.5 sampler network because greater data completeness for lower precision measurements can provide the same level of confidence as a smaller number of more precise measurements. b) Develop an approach to empower and encourage states or associations of states to qualify continuous samples on a local to regional basis. It is probably best to start with an expanded Correlated Acceptable Continuous (CAC) monitor process that would justify a significant reduction in the amount of concurrent FRM PM2 5 monitoring for sites well above or below the regulatory standard concentration. There is again a statistical question concerning whether the relationship between continuous monitors and FRM values could be checked by periodically rotating an FRM around the network or whether there would need to be an FRM at each site but operating at a lower frequency than 1 day in 3. c) Involve the states/local agencies in the determination of the cost savings for various options while ensuring that the data quality is appropriate for making critical management decisions. d) Whenever possible, site the continuous monitor/FRM pairs at speciation sites, so that there will be chemical composition data available to help interpret and understand differences between sampler values that may be observed. e) Because there are strong possibilities that future changes to the PM national ambient air quality standards (NAAQS) will occur, consideration needs to be made such that the outcome of these analyses can be appropriately applied to future monitoring needs (e.g., PM coarse). f) The current monitor testing that is part of the on-going supersite activities can be expected to provide a much better characterization of the recently developed continuous mass and chemical species monitors. The Subcommittee urges the Agency to make full use of these results as they become available to modify their approach to obtain maximal utility and efficiency in the PM monitoring program through the use of continuous monitors. By this summer (2001), the Subcommittee would like EPA staff to prepare a work-in-progress document that provides preliminary ideas for implementation of these recommendations. The Subcommittee would then be available to review the progress attained, and provide further advice, as appropriate. ------- This Subcommittee report was reviewed and approved by the statutory CASAC at a public teleconference meeting held on May 14, 2001. We look forward to working with the OAQPS staff on this important process of making the Particulate Matter (PM) monitoring network more cost effective while maintaining the quality of data for decision making purposes. Sincerely, /S/ Dr. Philip Hopke, Chair Clean Air Scientific Advisory Committee ------- U.S. Environmental Protection Agency EPA Science Advisory Board Clean Air Scientific Advisory Committee CHAIR Dr. Philip Hopke, Robert A. Plane Professor, Department of Chemical Engineering, Clarkson University, Potsdam, NY Also Member: Research Strategies Advisory Committee Executive Committee FORMER CHAIR Dr. Joe Mauderly, Vice President, Senior Scientist, and Director, National Environmental Respiratory Center, Lovelace Respiratory Research Institute, Albuquerque, NM SAB MEMBERS Dr. John Elston, Administrator, Office of Air Quality Management, State of New Jersey Department of Environmental Protection and Energy, Trenton, NJ Dr. Frederick J. Miller, Director, Respiratory and Neurotoxicology Research Program, Chemical Industry Institute of Toxicology, Research Triangle Park, NC Dr. Arthur C. Upton, Clinical Professor, CRESP-UMDNJ, Robert Wood Johnson Medical School, New Brunswick, NJ Dr. Sverre Vedal, Professor of Medicine, University of British Columbia, Respiratory Division, Vancouver, BC Canada Dr. Barbara Zielinska, Research Professor, Desert Research Institute, Reno, NV SCIENCE ADVISORY BOARD STAFF Mr. A. Robert Flaak, Designated Federal Officer, US EPA, EPA Science Advisory Board, 1200 Pennsylvania Avenue, NW, Washington, DC ------- U.S. Environmental Protection Agency EPA Science Advisory Board Clean Air Scientific Advisory Committee CASAC Subcommittee on Particle Monitoring* CHAIR Dr. Philip Hopke, Robert A. Plane Professor, Department of Chemical Engineering, Clarkson University, Potsdam, NY Also Member: Research Strategies Advisory Committee Executive Committee CASAC MEMBERS Dr. John Elston, Administrator, Office of Air Quality Management, State of New Jersey Department of Environmental Protection and Energy, Trenton, NJ OTHER SAB MEMBERS Dr. Morton Lippmann, Professor, Nelson Institute of Environmental Medicine, New York University Medical Center, Tuxedo, NY Member: Executive Committee CONSULTANTS Dr. Petros Koutrakis, Professor, Department of Environmental Sciences, School of Public Health, Harvard University, Boston, MA Dr. Debra L. Las kin, Professor, Department of Pharmacology & Toxicology, Environmental & Occupational Health Sciences Institute, Rutgers University, Piscataway, NJ Dr. JoAnn S. Lighty, Associate Dean, University of Utah, Salt Lake City, UT Dr. Peter McMurry, Professor and Head, Department of Mechanical Engineering, University of Minnesota, Minneapolis, MN Dr. Kimberly Prather, Professor, University of California, Department of Chemistry, University of California, Riverside Dr. Warren H. White, Senior Research Associate, Chemistry Department, Washington University, St. Louis, MO Dr. George T. Wolff, Principal Scientist, General Motors Corporation, Detroit, MI Mr. Melvin Zeldin, Assistant Deputy Executive Officer, Science and Technology Advancement, South Coast Air Quality Management District (SCAQMD), Diamond Bar, CA SCIENCE ADVISORY BOARD STAFF Mr. A. Robert Flaak, Designated Federal Officer, US EPA, EPA Science Advisory Board, 1200 Pennsylvania Avenue, NW, Washington, DC ------- Ms. Diana Pozun, Program Specialist, US EPA, EPA Science Advisory Board, 1200 Pennsylvania Avenue, NW, Washington, DC * Members of this SAB Panel consist of a. SAB Members: Experts appointed by the Administrator to serve on one of the SAB Standing Committees. b. SAB Consultants: Experts appointed by the SAB Staff Director to a one-year term to serve on ad hoc Panels formed to address a particular issue. c. Liaisons: Members of other Federal Advisory Committees who are not Members or Consultants of the Board. d. Federal Experts: The SAB charter precludes Federal employees from being Members of the Board. "Federal Experts" are federal employees who have technical knowledge and expertise relevant to the subject matter under review or study by a particular panel. Ill ------- NOTICE This report has been written as part of the activities of the EPA Science Advisory Board, a public advisory group providing extramural scientific information and advice to the Administrator and other officials of the Environmental Protection Agency. The Board is structured to provide balanced, expert assessment of scientific matters related to problems facing the Agency. This report has not been reviewed for approval by the Agency and, hence, the contents of this report do not necessarily represent the views and policies of the Environmental Protection Agency, nor of other agencies in the Executive Branch of the Federal government, nor does mention of trade names or commercial products constitute a recommendation for use. Distribution and Availability: This EPA Science Advisory Board report is provided to the EPA Administrator, senior Agency management, appropriate program staff, interested members of the public, and is posted on the SAB website (www.epa.gov/sab). Information on its availability is also provided in the SAB's monthly newsletter {Happenings at the Science Advisory Board). Additional copies and further information are available from the SAB Staff [US EPA Science Advisory Board (1400A), 1200 Pennsylvania Avenue, NW, Washington, DC 20460-0001; 202-564-4546]. IV ------- |