To: "Fitzsimmons, Sean [DNR]" <Sean.Fitzsimmons@dnr.iowa.gov>, 

Cc: David Mintz/RTP/USEPA/US@EPA, Lewis Weinstock/RTP/USEPA/US@EPA, Rhonda 

Thompson/RTP/USEPA/US@EPA, 

Bcc:

Subject: RE: Comment from Sean Fitzsimmons of Iowa DNR on proposed revisions to 40 CFR 50 

Appendix P section (2)(b)

Sean,

Thank you for your reply. As we consider all the comments on the rule, this clarification of your concern 

will be helpful.

Phil Lorang, Group Leader

Air Quality Analysis Group, AQAD, OAQPS, EPA

919-541-5463

"Fitzsimmons, Sean [DNR]" Phil, Thanks for responding to my voic... 04/06/2010 12:07:59 PM

From: "Fitzsimmons, Sean [DNR]" <Sean.Fitzsimmons@dnr.iowa.gov>

To: Phil Lorang/RTP/USEPA/US@EPA

Cc: Rhonda Thompson/RTP/USEPA/US@EPA, Lewis Weinstock/RTP/USEPA/US@EPA, David 

Mintz/RTP/USEPA/US@EPA

Date: 04/06/2010 12:07 PM

Subject: RE: Comment from Sean Fitzsimmons of Iowa DNR on proposed revisions to 40 CFR 50 Appendix 

P section (2)(b)

Phil,

Thanks for responding to my voice message, and clarifying the intent of the 

proposed rule.

Our concern, also expressed in Iowa's comments to the docket, was that the 

proposed rule did not appear (to us) to allow substitution of data from a 

secondary monitor in cases when the primary monitor did not produce valid 

data. If this were the correct interpretation of the proposed rule, it is our 

opinion that this provision would undermine the scientific basis of the 

attainment decision, as it would not make full use of the data gathered at the 

monitoring site.

In my opinion, the possible modification to the proposed text that appears 

below clarifies the intention of the proposed rule and addresses our concern.

Thanks,

Sean Fitzsimmons Ph.D.

Lead Worker

Ambient Air Monitoring Group

Iowa DNR

 

-----Original Message-----

From: Lorang.Phil@epamail.epa.gov [mailto:Lorang.Phil@epamail.epa.gov] 

Sent: Wednesday, March 31, 2010 4:37 PM
To: Fitzsimmons, Sean [DNR]

Cc: Thompson.Rhonda@epamail.epa.gov; Weinstock.Lewis@epamail.epa.gov; 

Mintz.David@epamail.epa.gov

Subject: Comment from Sean Fitzsimmons of Iowa DNR on proposed revisions to 40 

CFR 50 Appendix P section (2)(b)

Sean,

Thank you for your phone message regarding your concern with the

proposed revision to 40 CFR 50 Appendix P section (2)(b). Your phone

message indicated that you wish to not be prohibited from submitting

data from a second, collocated ozone monitor on an hour-by-hour or

day-by-day basis if the primary monitor is not operating or has not

produced valid data. You interpreted the proposal as prohibiting you

from doing that, which was not necessarily the intention behind the

proposal.

Can you let me know whether in your opinion the possible modification to

the proposed text that appears below would address this concern? Please

be aware that your response to this e-mail will be added to the public

docket for the rulemaking.

(b) (i)When two or more ozone monitors are operated at a site, the state

may in advance designate one of them as the primary monitor. If the

state has not made this designation, the Administrator will make the

designation, either in advance or retrospectively.

 (ii) There are two allowed approaches a state may follow for

submitting ozone data to EPA from multiple monitors.

 (A) The state may submit data from each physical monitor using a

 distinct value for the Pollutant Occurrence Code (POC) data

 element in the Air Quality System (or the equivalent data element

 in any successor to the Air Quality System). However, in this

 approach, if one monitor has physically replaced another

 instrument permanently at some point in time, data from the two

 instruments will be submitted under a single POC. If the state

 has taken this approach, then design values will be developed

 using only the data from the primary monitor/POC, if this results

 in a valid design value. If data from the primary monitor do not

 allow the development of a valid design value, data solely from

 the other monitor(s)/POC(s) will be used in turn to develop a

 valid design value, if this results in a valid design value. If

 there are three or more monitors/POC(s), the order for such

 comparison of the other monitors will be determined by the

 Administrator. The Administrator may combine data from different

 monitors/POCs in different years for the purpose of developing a

 valid primary or secondary standard design value, if a valid

 design value cannot be developed solely with the data from a

 single monitor/POC. However, the Administrator will not combine

 data from two or more monitors/POCs in the same year at the same

 site in an attempt to meet data completeness requirements, except

 when the state has switched the designation of the primary monitor

 from one monitor/POC to another during the year.

 (B) Alternatively, the state may submit data from the primary

 monitor under a certain value for the POC for hours when valid

 data have been obtained from the primary monitor, and submit data

 from a secondary monitor under that same value for the POC for

 hours when and only when valid data have not been obtained from

 the primary monitor. Under this approach, the state submits any
 redundant data from the secondary (or third) monitor under a

 second (or third, etc.) POC value for hours when the primary

 monitor has produced valid data. If the state has taken this

 approach, then design values will be developed using only the data

 from the primary POC, if this results in a valid design value. If

 the data from the primary POC does not result in a valid design

 value, no valid design value can be determined.

(I think this gives you the gist of this idea. I realize it isn't

perfect regulation writing to be putting data submission requirements

into part 50 (they belong in part 58). We may shift some of this into

part 58, assuming we settle on this approach.)

Phil Lorang, Group Leader

Air Quality Analysis Group, AQAD, OAQPS, EPA

919-541-5463