Comments
on
PMcoarse
monitoring
requirements
and
Appendix
O
 
Federal
Reference
Method
The
first
comment
goes
back
to
the
proposed
standard
and
its
subjective
nature.
EPA
consistently
defines
what
they
want
to
regulate
as
a
subset
of
particles,
not
only
in
terms
of
size
(
2.5
to
10
microns
in
size)
but
also
in
terms
of
kind
alternatively
defined
in
three
ways:
1.
This:
focus
on
coarse
particles
associated
with
sources
typically
found
in
urban
areas
is
derived
from
the
available
epidemiological
studies,
which
examined
exposure
to
unenriched
natural
crustal
materials,
as
well
as
dosimetric
evidence
and
toxicological
studies.
2.
Not
this:
These
studies
did
not
support
the
association
of
health
effects
with
PM10­
2.5
concentrations
resulting
from
the
suspension
by
wind
of
uncontaminated
natural
crustal
materials
of
geologic
origin.
3.
Not
this:
available
evidence
does
not
support
either
the
existence
or
the
lack
of
causative
associations
for
community
exposures
to
coarse
particles
from
agricultural
or
mining
sources.

4.
This:
PM10­
2.5,
qualified
so
as
to
include
any
ambient
mix
of
PM10­
2.5
that
is
dominated
by
sources
typically
found
in
urban
environments,
such
as
resuspended
dust
from
high­
density
traffic
on
paved
roads,
industrial
sources,
and
construction
activities,
5.
Not
this:
exclude
any
ambient
mix
of
particles
that
is
dominated
by
rural
windblown
dust
and
soils
and
agricultural
and
mining
sources.

(
Bold
terminology
is
repeated
many
places)
in
monitoring
and
the
preamble,
etc.
It
doesn't
sound
like
fire
(
silvicultural)
is
in
either
part
 
not
particularly
included,
not
excluded.
Agricultural
burning
might
get
a
"
by",
but
the
emphasis
of
the
exclusion
is
more
on
crustal
material.
But
the
map
of
the
monitor
locations
(
p
15)
seems
to
show
the
effect
of
the
PM10
values
from
wind
borne
dust/
soil
in
addition
to
just
population.
EPA
mentions
perhaps
using
the
source
codes
to
better
characterize
the
sources
of
interest.
We
recommend
that
approach
rather
than
singling
out
fire
for
example
as
"
in",
"
out",
or
"
unclear".

Second
Comment:
The
question
to
me
is
whether
the
monitoring
requirements
are
set
up
to
really
focus
on
urban
areas
and
if
they
are
going
to
avoid
less
populated
areas
that
might
include
farms
and/
or
forested
areas
that
might
need
to
have
fire
as
a
treatment.
The
proposal
is
a
complicated
proposal
based
on
three
types
of
monitors:
one
close
to
sources,
one
close
to
concentrations
of
people,
and
one
in
more
suburban
areas.
That
also
has
some
principles
in
addition
that
relate
to
US
Census
block
groups
and
population
density.
The
proposal
is
for
clusters
of
block
groups
with
a
similar
density
of
greater
than
500
persons
per
square
mile
in
communities
greater
than
50,000
persons
in
size.
The
monitor
locations
are
more
likely
to
be
located
with
a
population
basis
like
the
PM2.5
monitors
which
have
median
density
of
2,306
persons
per
square
mile
(
p33).
The
wildland
urban
interface
(
WUI)
burning
that
the
Forest
Service
is
doing
in
conjunction
with
other
agencies
based
on
the
emphasis
in
the
Healthy
Forest
Restoration
Act
is
on
the
edge
of
some
of
these
communities.
The
Smoke
Management
programs
that
are
in
place
would
apply
and
not
the
Natural
and
Exceptional
Events
Policy.
Some
mitigations;
States
have
to
get
their
monitoring
plans
approved;
one
of
the
principles
is
that
monitoring
"
on
the
fence
line"
would
not
be
used
for
regulatory
purposes
for
PMcoarse.
EPA
is
clear
about
the
urban
emphasis,
but
should
clarify
how
if
at
all
small
farm
and
WUI
might
be
inadvertently
included.

Third
Comment:
There
is
some
rural
monitoring
allowed,
but
EPA
wants
to
tie
it
to
two
other
monitoring
networks:
CASTNET
(
PM2.5
speciated)
and
IMPROVE
(
Forest
Service
Operates
many
of
these)
(
visibility,
PM10
and
2.5
speciated).
EPA
should
specify
if
there
would
be
changes
in
the
protocols
to
be
closer
to
the
PM
coarse
monitors.

Fourth:
Speciation
monitors
are
proposed
in
addition.
It
is
not
clear
what
species
will
be
monitored
for
or
if
it
is
basically
like
the
CASTNET
sites.
EPA
should
specify
if
there
are
different
filter
requirements
and
what
chemicals
they
will
be
looking
for.

Finally:
The
EPA's
proposed
Federal
Reference
Method
is
the
subtraction
method
taking
simultaneous
PM10
(
specially
adapted
and
improved),
and
PM2.5,
weighing
the
filters
and
subtracting
the
weights
to
get
the
weight
of
PMcoarse.
SAFE­
TEA
specifically
requires
EPA
to
develop
a
separate
device
to
monitor
PMcoarse
and
not
use
the
difference.
EPA
makes
a
case
on
why
they
have
to
propose
this
while
they
develop
such
a
monitor.
EPA
should
include
two
things,
an
analysis
of
how
much
the
improved
PM10c
monitor
will
be
over
the
PM10
existing
monitors,
and
more
information
on
other
methodologies
considered.
