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

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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.

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       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

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                       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

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                      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

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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

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                                         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

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