One commenter said that “this isn’t acceptable for the Northeast and Mid-atlantic Corridor, which requires monitoring of the move over boys this old man show you how to be veteran american flag shirt complicated transport from a number of large metropolitan areas within the region.” One commenter recognized that the EPA had intended to allow states to make use of EMPs to handle upwind and downwind data needs, however raised considerations that
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precursors, the EPA believes that autoGCs are an applicable method for gathering VOC information at most urban locations. However, canister sampling could also be more appropriate in areas with low VOC concentrations. While the basic rules of autoGC technology have not changed, the hardware and software program of contemporary autoGCs are tremendously improved over that obtainable on the time of the unique PAMS necessities. Based on recommendation from the CASAC AMMS, the EPA initiated an move over boys this old man show you how to be veteran american flag shirt evaluation of current autoGCs potentially appropriate for use within the PAMS community. Based on the preliminary results, the EPA believes that typical web site operators, with acceptable training, may have the talent necessary to operate a contemporary autoGC successfully. Considering the advances in autoGC expertise, the added value obtained from hourly data, and the proposed move of PAMS measurements to NCore sites in O3 nonattainment areas, the EPA proposed to require hourly speciated VOC sampling in any respect PAMS websites. The EPA famous that this proposed requirement would effectively forestall using canisters to gather speciated VOCs at the required PAMS sites however that canister sampling may continue to be an applicable method for accumulating speciated VOCs at other areas as a part of discretionary monitoring designed inside the EMPs. At the time the unique PAMS requirements had been promulgated, the canister choices were included as a result of the EPA recognized that the applied sciences necessary to measure hourly common speciated VOCs concentrations had been comparatively new and may not have been appropriate for broad community use.
At that point, GCs designed for laboratory use had been outfitted with auto-samplers designed to “entice” the VOC compounds from a fuel sample, after which “purge” the compounds onto the GC column. The EPA did not imagine that autoGCs were universally appropriate as a result of technical ability and energy necessary at the moment to properly function an autoGC. Although, as mentioned in comment and summarized above, we believe there are good causes for not tying the requirement for fixed PAMS websites to O3 attainment status, we proceed to imagine that requiring PAMS measurements in areas that traditionally have had low O3 concentrations is unlikely to provide data of serious value to warrant the expense and energy of constructing such measurements. Therefore, we now have included a provision that may allow a monitoring company to acquire a waiver, primarily based on Regional Administrator approval, in situations the place CBSA-broad O3 design values are equal to or lower than 85% of the eight-hour O3 NAAQS and where the site is not considered an essential upwind or downwind web site for other nonattainment areas. The EPA chosen eighty five% as the brink for this waiver provision because it has been used traditionally to identify places needing extra monitoring for each the O3 and PM2.5 NAAQS. The EPA will work with the monitoring agencies and the Regions to help ensure constant implementation of this waiver provision. The EPA famous in the proposal that the dimensions and locations of the proposed required PAMS community is delicate to the level of the revised O3 NAAQS and future O3 concentrations. We recognize and agree that if present downward tendencies in O3 concentrations proceed, many initially required sites could now not be required to make PAMS measurements soon after the websites had been installed. Non-required sites could possibly be closed, quickly after being installed, at the state’s discretion. We agree this may result in an inefficient use of assets. We additionally notice that if these websites had been closed following a possible reclassification to attainment, the lack of these websites could result in a community with poor spatial protection. Therefore, the EPA is making adjustments to the proposed revisions to the network design to enhance the soundness of the fixed site network. As explained beneath, the final necessities are based on options for which we requested comments in the proposal and the comments we now have obtained. A number of issues had been additionally raised with the proposed network design. Several commenters stated that the proposal “would drastically scale back the PAMS community in the Northeast.”