One commenter said that “this isn’t acceptable for the Northeast and Mid-atlantic Corridor, which requires monitoring of the advanced transport from a number of massive metropolitan areas within the area.” One vintage dog chihuahua company bath soap wash your paws poster commenter recognized that the EPA had intended to allow states to use EMPs to handle upwind and downwind knowledge needs, but raised
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The unknown bias from the NOz compounds is undesirable when making an attempt to understand O3 chemistry. However, the EPA agrees that there could also be locations the place an autoGC will not be the most acceptable technique for VOC measurement and that it’s applicable to allow for canister sampling in restricted conditions. Accordingly, the EPA is including a waiver option to permit three 8-hour average samples each third day instead in instances where VOCs aren’t nicely measured by autoGC as a result of low concentrations of vintage dog chihuahua company bath soap wash your paws poster target compounds or the place the predominant VOC compounds cannot be measured using autoGC know-how (e.g., creosote in excessive desert environments). This alternative sampling frequency was selected to be according to the sampling frequency selected for carbonyls, which is discussed later on this preamble. While the EPA believes that the proposed transition to hourly speciated VOC sampling is the suitable technique to take advantage of improved know-how and to broaden the utility of collected information, we are additionally aware of the additional rigidity that the proposed mandatory use of autoGCs could have for monitoring companies, particularly those who have experience with and have established efficient and dependable canister sampling packages.
Therefore, the EPA requested touch upon the proposed requirement for hourly VOC sampling as well as the vary of options that might be appropriate in lieu of a strict requirement. Measurement of speciated VOCs essential to O3 formation is a key aspect of the PAMS program. The present PAMS necessities allow for a number of options in measuring speciated VOCs at PAMS sites which include hourly measurements using an computerized gasoline chromatograph (“autoGC”), eight 3-hour samples every day using canisters, or one morning and one afternoon pattern with a three-hour or much less averaging time every day using canisters plus continuous Total Non-methane Hydrocarbon measurements. EMPs could be reviewed and accredited by the EPA Regional Administrator as part of the annual monitoring plan evaluate process. One commenter recommended that the “EPA detail the necessities of the EMPs for ozone nonattainment areas in future implementation steering.” One commenter stated that the “EPA ought to present some coordination between regional places of work and technical guidance to state agencies that might be of help in developing and executing the EMPs.” The requirements for the EMPs have been intentionally left quite basic in order to maximize the flexibility for states in figuring out their specific knowledge needs. Regional approval of the plans is required to make sure the improved monitoring planned will be commensurate with grant funds offered for EMPs. Nonetheless, the EPA understands the necessity for steerage on creating EMPs and commits to working with monitoring businesses and the regions to develop applicable guidance on growing and reviewing EMPs. By including the PAMS measurements to present NCore websites, vital efficiencies could be obtained which ought to further scale back the costs of the mounted web site network as NCore websites currently make lots of the PAMS measurements. Furthermore, including the additional PAMS measurements (e.g., speciated VOCs, carbonyls, and mixing height) to present NCore sites will improve our capability to evaluate other pollutants (e.g., air toxics and PM2.5). A number of considerations have been additionally raised with the proposed network design. Several commenters stated that the proposal “would drastically scale back the PAMS community in the Northeast.”
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