UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

New England Regional Laboratory 

11 Technology Drive, North Chelmsford, MA 01863 

November 13, 2015 

Christine Kirby, Director, Division of Air and Climate Programs 

Bureau of Waste Prevention 

Department of Environmental Protection 

One Winter Street 

Boston, MA 02108 

Dear Ms. Kirby: 

Thank you for your submission of the Massachusetts 2015 Annual Monitoring Network Plan 

which was submitted to us in final form on October 14,2015. We appreciate that you addressed 

the comments we provided to you on July 29, 2015. I am also aware of the letter you sent to 

Robert Judge on November 10,2015 regarding discontinuing lead monitoring in Springfield. 

EPA New England has evaluated your plan and finds that your plan meets the minimum 

requirements of 40 CFR Part 58. 

We acknowledge the following modifications and future plans which you articulated as follows 

(in italics): 

P1·oposed Network Changes 

• MassDEP closed the Boston -Long Island ozone site (25-025-0041) in October 2014 due to 

the removal of the bridge to the island 

• MassDEP closed the Amherst ozone site (25-015-0103) in June 2014 when site 

conditions could no longer support monitoring. 

• MassDEP added PM1o and PM1o-lead monitoring to the Springfield- Liberty Street site 

(25-0 13-00 16) and closed the Springfield- Main Street (25-0 13-2009) P Mw and P M2.5 

site at the end of June 2014. 

• lvfassDEP closed the Boston- City Square (25-025-0027) PMw and PM2.s site at the end 

of2014. 

• MassDEP discontinued CO monitoring at the Boston -Kenmore Square (25-025-0002) 

site at the end of2014. MassDEP has installed anAutosampling GC (for Toxic VOCs) at 

that location. 

• Constellation Generation Company, LLC closed its private monitoring site in Boston at 

the end of June 2014. 

• MassDEP closed the Adams/MI. Grey/ock ozone site (25-023-4002) at the end of the 2014 

ozone season due to the dijjiculty and cost of required improvements needed at the site, 

MassDEP already was planning to close this site, and is in the processing of finding a 
comprehensive population-oriented ozone and P M2.s site in Berkshire County to consolidate 

and replace the Adams site and two P M2.s monitoring sites currently located in Pittsfield. 

• MassDEP is not processing data for the Newburyport and Ware PAMS sites in 2015 to 

enable MassDEP to catch up on a data backlog. MassDEP would process the data for 

these sites again beginning in 2016, depending on new monitoring requirements 

associated with a revised ozone standard, expected to be final in October 2015. 

• MassDEP is in the process of locating a second Boston Area near-road N02 site in the 

vicinity of the Route 495/Route 3 intersection north Of Boston. 

• MassDEP plans to install a second FEM PM2.s monitor at Boston- Von Hillern Street 

(25-025-0044) for Quality Control and Assurance purposes. 

• MassDEP plans to discontinue FEM Plv.hs monitoring at the Milton- Blue Hill site (25-

021-3003) at the end of2015. 

Per the discussion in the above paragraph, all network modifications that involve discontinuation or 

moving of ap.y sites is subject to EPA approval, even if the remaining network meets EPA's 

minimum requirements. Regarding the recent request to no longer measure lead in Springfield at 

the end of2015, we understand and support the request; and note those measurements are beyo.Q.d 

what is required to meet federal air monitoring obligations. Since this was not included in your 

proposed plan, I would encourage you to include that in next year's proposed Annual Network Plan 

in case there are public concerns that neither MassDEP nor we are aware of regarding the need to 

continue, or resume, monitoring for lead at this location. In light of possible future state and federal 

budget restrictions, we encourage MassDEP to consider further savings measures and discuss those 

opportunities with the EPA prior to implementation. 

EPA has finalized its Data Requirements Rule for the l~Hour Sulfur Dioxide Primary 

National Ambient Air Quality Standard (NAAQS) on August 21, 2015 (80 FR 51052), and 

provided detailed monitoring and modelling guidance for implementing the S02 standard. EPA 

looks forward to future dialogue with MassDEP regarding any additional monitoring that it may 

be consider relative to the fmalized DRR. We also note your acknowledgement that the Harrison 

Avenue (25-025-0042), Boston- Kenmore Square (25-025-0002), and Springfield- Liberty Street 

(25-013-0016) sites have been approved as among the 40 N02 monitors intended to help protect 

communities that are susceptible or vulnerable to N02 related health effects pursuant to 40 CFR 

Part 58, Appendix D, section 4.3.4(a). 

Further, consistent with 40 CFR 58.ll(e), I am approving the exclusion ofPM2.scontinuous data 

from one of your continuous PM2.s monitors. Thank you for your submission of the 

Demonstration ofPM2.s Comparability included in this Plan. As you know, this included your 

analysis of your continuous PM2.s Federal Equivalent Methods (FEMs) as compared to 

collocated PM2.s Federal Reference Methods (FRMs). This comparison is required under 40 

CFR Part 58.1I(e) for any cases where PM2.s continuous FEM data should not be used in 

comparison to the NAAQS. 

Y au discussed the 13 continuous PM2.s FEM monitors your network. Y au indicated that 

MassDEP will use data from its FEM monitors for comparison to the NAAQS, with the 

exception of the new FEM monitors at Greenfield - Veterans Field since this monitor has less 

than 24 months of data (as provided under EPA regulation), and the FEM monitor at Springfield 

- Liberty Street because this monitor continues to not have acceptable data comparability with 
the collocated FRM monitor. In the case of Springfield- Liberty Street, the analysis shows that 

the performance is outside of the acceptable range. Since you have demonstrated that this 

monitor does not meet requisite performance criteria, but you believe this data is acceptable for 

AQI purposes, we agree the data from this monitor should be reported using parameter code of 

88502, indicating that this data is appropriate for AQI use, but not for comparison to the National 

Ambient Air Quality Standard (NAAQS). Should you determine this data not be of acceptable 

quality for neither AQI reporting or for comparison to the NAAQS, parameter code 88501 

should be used. You should continue reporting to the same parameter code when generating any 

new data with the PMz.s continuous FEMs. (Note that the network design requirements for PMz.s 

remain in effect. Your agency will be required to operate FRMs or other FEMs at all required 

sites to be used for comparison to the NAAQS.) If you determine that the continuous monitor 

approved for exclusion is operating within acceptable ranges, it should be coded as 88101, and 

the next Annual Network Plan should describe that change. 

The monitors specifically identified as not appropriate for NAAQS comparison since 2010 

follow (sites will be coded as 88502, as eligible to be reported for AQI purposes, but not 

NAAQS compliance): 

I) 25-013-0016 Liberty Street- Springfield 

2) 25-011-2005 Veterans Field- Greenfield 

Regarding future annual monitoring network plans, please identify the PMz.s continuous FEMs 

and any pre-FEM continuous monitors in use or planned for use in your network. Your plan 

should clearly indicate the PMz.s continuous monitors in your network, and whether they have 

already been approved (pursuant to this or other approval letter) to be excluded from comparison 

to the NAAQS. To maintain such waivers, each subsequent Annual Network Plan must detail 

the PMz.s continuous FEMs, where they are located, and the monitoring objectives that they will 

support (i.e., eligible for use with the NAAQS and/or AQI) for the coming year. We also 

recommend that an assessment oftlle most recent three years of data for all collocated 

FRM/continuous FEM monitors be included in each subsequent annual plan where the 

m·onitoring agency wishes to continue to exclude such data from comparison to the NAAQS. 

Since this approval for exclusion of data covers two monitors, tills should be reassessed next 

year, along with any newer continuous PMz.s monitors that may have operated for more than 24 

months. Specifically, next year, the Greenfield monitor will have operated for more than 2 

years, and MassDEP should reevaluate the Liberty Street- Springfield monitor. 

We also urge you to move forward in replacing the Adams ozone monitor and in relocating 

PM2.5 monitoring fi:om their current locations in Pittsfield. We stand ready to assist you identify 

appropriate locations. As we suggested in our July 29, 2015 public comments on your plan, and 

as our staffs discussed in person on November 12, 2015 we believe there are a number of 

locations in western Massachusetts' valleys which may benefit from PM2.5 air quality 

measurements. 

As you know, EPA has been conducting an assessment oftl1e IMPROVE Protocol Sites in an 

effort to optimize the Chemical Speciation Network (CSN) and create a network that is 

sustainable going forward. As a result of this assessment, EPA is recommending defunding a 

number of monitoring sites- including the Ware- Quabbin Summit site (25-015-4002). Any 

changes are recommended to take place in January 2016. 

Finally, in this approval, I recognize that MassDEP has finished the process of identifying a 

suitable location for a second near-road monitoring station in the Boston CBSA near the Route 

495/ Route 3 intersection north of Boston. As you know, 40 CFR Part 58.10(a)(iv) requires that 
this site begin operation by January I, 2015. EPA is committed to work with you expeditiously 

to assist you in meeting this requirement. 

With this letter, I am approving your Annual Network Plan. We will work with our 

Headquarters offices to address the portions of the plan which would require their attention, most 

notably monitoring associated with NCore, IMPROVE, PAMS, and STN. 

EPA-New England appreciates your partnership in conducting ambient air monitoring. We look 

forward to working with you to continuously improve the quality of ambient air in 

Massachusetts. If you have any questions or comments regarding this network review, please 

contact Bob Judge at (617) 918-8387. 

irector 

Office of Environmental Measurement and Evaluation 

EPA New England 

cc: Glenn Keith, MassDEP