Air Pollution: EPA's Actions to Resolve Concerns with the Fine
Particulate Monitoring Program (Letter Report, 08/12/1999,
GAO/RCED-99-215).

Pursuant to a congressional request, GAO reviewed the National Academy
of Sciences March 1998 report on the Environmental Protection Agency's
(EPA) plans to monitor particulate matter smaller than 2.5 microns
(PM2.5), focusing on: (1) EPA's actions in response to the Academy's
concerns with the planned PM2.5 monitoring program; and (2) the
challenges that state and local agencies face in establishing and
operating the PM2.5 monitoring program, as well as EPA's response to
these challenges.

GAO noted that: (1) EPA has taken a number of actions to address the
concerns raised in the Academy's March 1998 report, including allocating
57 percent of its monitoring budget to efforts designed to better
understand PM2.5 scientific uncertainties--a primary concern in the
Academy's report; (2) although one of the Academy's concerns was that
the agency was moving forward rapidly with too narrow a focus on
mass-only monitors, EPA continued its rapid deployment of over 800
mass-only monitors by December 31, 1998, on the basis that 3 years of
monitoring data were needed to determine attainment with the standards;
(3) agency officials also explained that they deployed these monitors in
response to presidential and congressional directives to expedite the
monitoring network, as well as extensive public comments regarding the
thousands of premature deaths and serious illnesses annually from PM2.5
pollution; (4) the officials also said that they deployed these monitors
only after the monitors and the network design were peer-reviewed; (5)
largely due to EPA's rapid deployment of mass-only monitors, state and
local agencies have encountered problems operating nearly one-third of
their monitors--problems that have increased labor costs and impacted
the agencies' ability to meet EPA's data quality requirements; (6) the
officials explained that, due to EPA-imposed time constraints, they had
to purchase mass-only monitors based on prototype design and
manufacturer specifications without full field evaluation under actual
operating conditions; (7) while deployment was rapid, EPA officials said
the agency's monitor certification process was followed and that EPA has
taken other actions to help states address these challenges, including
requesting warranty extensions from the affected manufacturers and
increasing funding for operation and maintenance activities; (8)
however, state and local agencies remain concerned that the future
deployment of the more complex and costly speciation monitors without
adequate field testing would present even greater challenges; and (9) as
a result, EPA has reevaluated its monitoring plans and delayed
deployment of the more complex and costly speciation monitors an
additional year--to December 2000--to allow more time for field testing.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-99-215
     TITLE:  Air Pollution: EPA's Actions to Resolve Concerns with the
	     Fine Particulate Monitoring Program
      DATE:  08/12/1999
   SUBJECT:  Hazardous substances
	     State-administered programs
	     Air pollution control
	     Environmental monitoring
	     Environmental research
	     Operational testing
IDENTIFIER:  EPA Fine Particulate Matter Monitoring Program

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Cover
================================================================ COVER

Report to the Chairman, Subcommittee on VA, HUD, and Independent
Agencies, Committee on Appropriations, House of Representatives

August 1999

AIR POLLUTION - EPA'S ACTIONS TO
RESOLVE CONCERNS WITH THE FINE
PARTICULATE MONITORING PROGRAM

GAO/RCED-99-215

EPA's Fine Particulate Monitoring Program

(160462)

Abbreviations
=============================================================== ABBREV

  ALAPCO - Association of Local Air Pollution Control Officials
  CARB - California Air Resources Board
  CASAC - Clean Air Science Advisory Committee
  CENR - Committee on Environment and Natural Resources
  EPA - Environmental Protection Agency
  FRM - federal reference method
  HUD - Department of Housing and Urban Development
  IMPROVE - Interagency Monitoring of Protected Visual Environments
  NARSTO - North American Research Strategy for Tropospheric Ozone
     (and Aerosols). 
  NAS - National Academy of Sciences
  NRC - National Research Council
  O&M - operation and maintenance
  ORD - Office of Research and Development
  PM10 - coarse particles 10 microns and smaller
  PM2.5 - fine particulate matter smaller than 2.5 microns in
     diameter
  SAB - Science Advisory Board
  STAPPA - State and Territorial Air Pollution Program Administrators
  VA - Department of Veterans Affairs

Letter
=============================================================== LETTER

B-282851

August 12, 1999

The Honorable James T.  Walsh
Chairman, Subcommittee on VA, HUD,
 and Independent Agencies
Committee on Appropriations
House of Representatives

Dear Mr.  Chairman: 

In July 1997, the Environmental Protection Agency (EPA) established
new ambient air quality standards for particulate matter smaller than
2.5 microns (PM2.5)--fine particles about 1/30\th of the thickness of
a human hair and which, according to EPA, cause tens of thousands of
premature deaths annually.  These fine particles are a complex
mixture of acids, metals, carbon, and other potentially harmful
airborne substances.  Because the health risks of the components
comprising the PM2.5 mixture are poorly understood, EPA is both
implementing the PM2.5 standards and investigating scientific
uncertainties associated with these components.  As part of
implementing the new standards, in 1997 EPA announced plans for a
more than $50 million nationwide network of 1,500 PM2.5 monitoring
sites to be deployed by December 31, 1999.  EPA's plans also called
for over 90 percent of these sites to use monitors that measure only
the total mass of fine particles collected over a 24-hour period. 
Such ï¿½mass-onlyï¿½ monitors, while required for determining areas that
exceed the PM2.5 standards, provide limited data to address the
scientific uncertainties about the health effects and health risks of
the components comprising the PM2.5 mixture.  Other, more expensive
and complex monitors are needed to help address these scientific
uncertainties. 

In March 1998, the National Academy of Sciences (Academy) issued a
report\1

that questioned EPA's PM2.5 monitoring plans, calling the agency's
plans misdirected and insufficient to address important data gaps and
scientific uncertainties.  While EPA is currently fully funding the
network, state and local agencies are responsible for establishing
and operating the monitoring sites.  In view of the Academy's report,
you asked us to describe (1) EPA's actions in response to the
Academy's concerns with the planned PM2.5 monitoring program and (2)
the challenges that state and local agencies face in establishing and
operating the PM2.5 monitoring program, as well as EPA's response to
these challenges. 

--------------------
\1 Research Priorities for Airborne Particulate Matter:  Immediate
Priorities and a Long-Range Research Portfolio, Committee on Research
Priorities for Airborne Particulate Matter, National Research
Council, National Academy of Sciences (Mar.  1998). 

   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

EPA has taken a number of actions to address the concerns raised in
the Academy's March 1998 report, including allocating 57 percent of
its monitoring budget to efforts designed to better understand PM2.5
scientific uncertainties--a primary concern in the Academy's report. 
For example, EPA reduced the number of planned mass-only monitoring
sites by more than 21 percent and substantially increased the number
of sites and frequency of analyses at the more complex monitoring
sites that identify the components of the PM2.5 mixture.  Although
one of the Academy's concerns was that the agency was moving forward
rapidly with too narrow a focus on mass-only monitors, EPA continued
its rapid deployment of over 800 mass-only monitors by December 31,
1998, on the basis that 3 years of monitoring data were needed to
determine attainment with the standards.  Agency officials also
explained that they deployed these monitors in response to
presidential and congressional directives to expedite the monitoring
network, as well as extensive public comments regarding the thousands
of premature deaths and serious illnesses annually from PM2.5
pollution.  The officials also said that they deployed these monitors
only after the monitors and the network design were peer-reviewed. 

Largely due to EPA's rapid deployment of mass-only monitors, state
and local agencies have encountered problems operating nearly
one-third of their monitors--problems that have increased labor costs
and impacted the agencies' ability to meet EPA's data quality
requirements.  For example, the six state and local agencies we
contacted had monitors fail to operate in very cold weather, filters
contaminated from leaky seals, and data lost due to monitor computer
failures--problems they attribute to inadequate field testing of
these monitors before deployment.  The officials explained that, due
to EPA-imposed time constraints, they had to purchase mass-only
monitors based on prototype design and manufacturer specifications
without full field evaluation under actual operating conditions. 
While deployment was rapid, EPA officials said the agency's monitor
certification process was followed and that EPA has taken other
actions to help states address these challenges, including requesting
warranty extensions from the affected manufacturers and increasing
funding for operation and maintenance activities.  However, state and
local agencies remain concerned that the future deployment of the
more complex and costly speciation monitors without adequate field
testing would present even greater challenges.  As a result, EPA has
reevaluated its monitoring plans and delayed deployment of the more
complex and costly speciation monitors an additional year--to
December 2000--to allow more time for field testing.  While these are
steps in the right direction, this report contains a recommendation
that EPA ensure that future monitors successfully pass full field
testing before large-scale deployment is permitted. 

   BACKGROUND
------------------------------------------------------------ Letter :2

Unlike most other pollutants that EPA regulates, PM2.5 is a complex
mixture of airborne particles and gases that interact physically and
chemically, vary significantly by region and locality, and can be
transported hundreds of miles by the wind.  PM2.5 particles are
primarily formed by the combustion of coal, oil, gasoline, diesel,
and wood from such sources as power plants, industrial facilities,
cars, trucks, and wood stoves.  According to EPA, adverse health
effects have been linked statistically to exposure to the aggregate,
or ï¿½mass,ï¿½ of fine particles smaller than 2.5 microns, but many
scientists are concerned that one or more components of the PM2.5
mixture may be more toxic than others or that certain physical or
chemical characteristics of the components may be more important to
human health than the total particle mass.  As a result, EPA is faced
with the dual tasks of both implementing the 1997 standards\2 for
particle mass and simultaneously investigating the health, exposure,
and atmospheric uncertainties associated with the PM2.5 mixture. 
According to the Director of EPA's Emissions, Monitoring, and
Analysis Division, this was an ambitious technical challenge
unprecedented in EPA's history. 

Different types of monitors are required to address these different
regulatory and research goals, and, according to EPA, all of the
currently available monitors have limitations if used alone; however,
the agency believes that collectively these various monitors provide
appropriate and useful information.  Table 1 provides information on
the five types of monitors EPA plans to use in its revised PM2.5
monitoring network. 

                                         Table 1
                         
                           Types of Particulate Matter (PM2.5)
                                         Monitors

                                                                         Annual operation
                                     Number of sites                     and maintenance
Monitor type      Description        planned\a         Capital costs\b   costs\c
----------------  -----------------  ----------------  ----------------  ----------------
Mass-only         Agencies weigh     1,094             $17,000 to        $11,900 for 1-
(Compliance)      filters in                           $22,200           in-6 day
                  laboratory before                                      sampling to
                  and after a 24-                                        $36,900 for
                  hour sampling                                          daily sampling
                  period to collect
                  total PM2.5 mass;
                  particles
                  collected in
                  accordance with
                  EPA-approved
                  method; primary
                  focus on
                  population
                  centers.

Speciation        Use several        301               $23,000           $30,200 for 1-
                  different inlet                                        in-6 day
                  tubes and                                              sampling to
                  different filters                                      $137,200 for
                  to collect                                             daily sampling
                  suspected harmful
                  components of the
                  PM2.5 mixture,
                  such as acids,
                  metals, and
                  organic carbon;
                  subsequent
                  analysis of fine
                  particles in
                  laboratory.

IMPROVE\d         Similar to         108               $23,000           $30,200
                  speciation
                  monitors in
                  design (collects
                  particles on
                  three different
                  filters);
                  monitors located
                  in national parks
                  and wilderness
                  areas; monitors
                  collect
                  background
                  readings and
                  transport data
                  for PM2.5
                  program.

Continuous        In lieu of         137\e             $20,000           $6,000 to $8,000
                  filters, this
                  design uses an
                  internal
                  analytical
                  apparatus to
                  instantaneously
                  analyze the
                  particles passing
                  through the
                  sampler.

Supersite\f       Uses prototype     4 to 9\g          $1.0 to $3.5      (included in
                  and research-                        million,          prior column)\h
                  grade monitors,                      (includes O&M
                  as well as one or                    costs and data
                  more of the above                    analyses)
                  monitors, to
                  conduct intensive
                  fine particle
                  analyses of the
                  complex PM2.5
                  mixture,
                  population
                  exposure
                  patterns, and
                  emissions source
                  characterization
                  and
                  identification.

=========================================================================================
Total                                1,500
-----------------------------------------------------------------------------------------
\a Figure based on revised ambient air monitoring network plans as of
May 1999 (range of planned mass-only compliance sites nationwide is
1,050 to 1,100). 

\b Capital costs for speciation, IMPROVE (defined below), and
Supersite monitors are best estimates as of May 1999, including
one-time site setup costs such as those for utility hookups. 

\c Operation and maintenance (O&M) costs include the estimated costs
of site operations, filters, laboratory analysis, and data reporting
(all O&M costs are estimates since 1 full year of operation will not
be completed until Dec.  31, 1999). 

\d The Interagency Monitoring of Protected Visual Environments
(IMPROVE) program is a joint effort with the Department of the
Interior, Federal Land Managers, and state and local agencies. 

\e Continuous and speciation monitors are generally colocated with
other monitors. 

\f These sites actually use a combination of advanced monitoring
techniques to understand the complex PM2.5 mixture. 

\g Supersites will be coordinated with ongoing state and local agency
monitoring efforts to optimize data uses. 

\h Detailed estimates of O&M costs for these monitoring sites are
still under development. 

While mass-only monitors are essential for measuring total particle
mass--which is necessary to determine if a state or local area is in
compliance with the PM2.5 mass standards--they provide limited data
to help address scientific uncertainties.  For example, mass-only
monitors, by themselves, are insufficient for a comprehensive
assessment of the sources contributing to fine particle pollution. 
However, EPA officials noted that data on PM2.5 mass does help with
some scientific research and that PM2.5 mass is a likely contributor
to adverse health effects.  Although they are among the more precise
PM2.5 monitoring devices available, in some instances mass-only
monitors underestimate the fine particle mass because they lose
unstable components of the PM2.5 mixture as the temperature rises
during the day.  Also, as shown in table 1, the capital costs for
mass-only monitors vary significantly.  This cost difference depends
mostly on whether the monitor's filter must be manually changed after
a single 24-hour sampling period or whether the monitor can
electronically change filters for multiple sampling periods.  A
schematic of a typical mass-only monitor is shown in figure 1.  These
monitors, which are generally about 2 to 2.5 meters high, must have
unobstructed air flow for a minimum of 2 meters in all directions,
with the air inlet located from 2 to 15 meters above ground level.\3

   Figure 1:  Schematic of a
   Typical PM 2.5 Mass-only
   Monitor

   (See figure in printed
   edition.)

\a Air temperature is recorded electronically by the monitor's
computer. 

\b The filter exchange mechanism for sequential monitors uses either
a rotating filter cassette or a pneumatic tube exchange system. 

Source:  GAO Illustration based on EPA-supplied information. 

Mass-only monitors are not the only monitors with limitations.  The
speciation and IMPROVE monitors also lose unstable, volatile
components of the PM2.5 mixture as the temperature rises during the
day.  Continuous monitors are needed to obtain the more frequent
readings that portray human exposures, but these monitors also have
limitations.  EPA officials said that continuous monitors are an
acceptable indicator tool when used in combination with other
monitors, but they produce inaccurate readings in some circumstances,
especially in humid conditions.  For example, continuous monitors do
not provide data on the variety of chemicals that make up the PM2.5
mixture, and some also lose volatile components of the mixture to a
greater degree than do other monitors. 

Because all of the currently available monitors have limitations, EPA
officials have developed another monitoring approach--known as
supersite--that describes the agency's most intensive efforts to
understand the complex PM2.5 mixture in various regions of the
nation.  As explained in table 1, supersites use prototype and
research-grade monitors, along with one or more of the other
monitors, to conduct intensive fine particle analyses of the complex
PM2.5 mixture, population exposure patterns, and emissions source
characterization and identification.  Because of the high cost of
supersites--from $1.0 to $3.5 million per site--fewer than 10
supersites will be established nationwide.  Supersites may operate
from less than 1 to more than 5 years.  According to agency
officials, the supersites part of the PM2.5 monitoring program is
still in the developmental phase. 

While fiscal year 1999 funding for the PM2.5 monitoring program was
$65.7 million (including $50.7 million for state and local grants,
plus an additional $15.0 million for the supersites program), EPA
estimates that--after establishment--ongoing expenses for the PM2.5
monitoring program will be about $42.5 million annually.  Although
the overall network is designed, overseen, and currently fully funded
by EPA, state and local air quality agencies are responsible for
establishing and operating the monitoring sites, including taking
periodic samples, handling and transporting the samples, conducting
laboratory analyses, ensuring data quality, and reporting the data to
EPA and the states.  Equally important, state and local agencies are
responsible for developing strategies to achieve and maintain the
PM2.5 standards, including identifying and controlling PM2.5
emissions sources.  According to EPA, the agency will assume full
funding for the PM2.5 network until such time as the Congress
determines that states should contribute to the operation and
maintenance of the network.  At that point, states will be expected
to provide approximately 40 percent of the total funding needed to
operate the program, assuming a traditional grant funding approach. 
Under traditional grant funding, EPA covers about 60 percent of
program expenses, and state and local agencies provide matching funds
sufficient to cover 40 percent of program costs.  Such a funding
arrangement is generally known as a 60/40 match.  While the PM2.5
monitoring program is the most expensive EPA has ever asked state and
local agencies to implement, the decisions to be made based on the
PM2.5 data are also envisioned to be very expensive.  For example,
EPA estimates that industry will spend about $8.6 billion annually to
control PM2.5 emissions beginning in 2008.  Full compliance with the
PM2.5 standards is expected no later than 2012.  EPA's next review of
the PM2.5 standards is scheduled for 2002.  According to agency
officials, subsequent reviews should occur at intervals no longer
than 5 years thereafter. 

--------------------
\2 On May 14, 1999, a three-judge panel of the U.S.  Court of Appeals
for the District of Columbia vacated the PM10 standard for coarse
particles and remanded to EPA the PM2.5 standards for fine particles
(American Trucking Ass'ns, Inc.  v.  EPA, Nos.  97-1440 & 97-1441
(D.C.  Cir.  May 14, 1999)).  After further briefing, on June 18,
1999, the court decided not to vacate the PM2.5 standards at this
time.  On June 28, 1999, EPA appealed the May 14 decision to the full
court of appeals and hopes to sustain the standards that were
remanded.  As of the date of issuance of this report, EPA's PM2.5
standards are still in place, and EPA is continuing with the
deployment and operation of the PM2.5 fine particle monitoring
program. 

\3 These monitors must meet EPA-specified design, performance, and
operational requirements as provided in 40 CFR, Part 50, App.  L
(July 18, 1997 Federal Register). 

   EPA HAS TAKEN ACTIONS TO
   ADDRESS THE ACADEMY'S CONCERNS
------------------------------------------------------------ Letter :3

EPA made numerous changes in its PM2.5 monitoring program to address
the concerns raised in the Academy's March 1998 report.  For example,
in response to the Academy's concern that EPA's planned program was
too heavily oriented toward mass-only monitors, EPA reduced the
number of planned mass-only monitoring sites from 1,392 to 1,094
sites, about a 21-percent reduction.  This change allowed EPA to
increase the number and frequency of analyses at the more expensive
speciation monitoring sites and to more than double the number of
continuous monitoring sites planned--actions that should help the
agency better address the health, exposure, and atmospheric
uncertainties of PM2.5.  After these changes, EPA's revised plans
called for 57 percent of the PM2.5 monitoring budget to be devoted to
monitoring efforts designed to better understand PM2.5 scientific
uncertainties.  EPA's responsiveness to the Academy's earlier
concerns was commended by several members of the Academy and the
Clean Air Science Advisory Committee (CASAC)\4 in a public session in
November 1998.  Table 2 summarizes eight key concerns in the
Academy's 1998 report and the actions EPA has taken to address them. 

                                         Table 2
                         
                         Summary of EPA's Actions to Address the
                                  Academy's Key Concerns

                                                                                 Concern
                                                                                 addresse
Description of key concern    Summary of EPA's actions                           d
----------------------------  -------------------------------------------------  --------
1. EPA is moving forward      EPA reduced the number of mass-only monitors       Partiall
rapidly with too narrow a     planned from 1,392 to 1,094; increased the number  y
focus on mass-only            and frequency of analyses at 54 speciation sites;
monitoring.                   increased the number of continuous monitors from
                              62 to 137; added plans for up to 9 supersites (an
                              increase of $15 million in EPA's monitoring
                              budget); however, EPA continued with rapid
                              deployment of 823 mass-only monitors by Dec.
                              31,1998.

2. Planned network may not    Changes in planned network allowed EPA to          Yes
adequately support research   increase fiscal year 1999 monitoring funds for
on health effects, exposure   health effects, exposure, and atmospheric
assessment, and atmospheric   modeling research by $21.5 million (a 42-percent
modeling.                     increase); revised plan now allocates 57 percent
                              of $65.7 million in fiscal year 1999 monitoring
                              funds to monitoring efforts to help address these
                              research issues.

3. Plans to collect           EPA used $3.1 million of funds planned for the     Mostly
speciation samples once       mass-only monitoring program to increase the
every 6 days will not         frequency of speciation sampling from one sample
provide useful data for       every 6 days to daily sampling at 10 major urban
improving health risk         sites, and from one sample every 6 days to one
assessments.                  sample every 3 days at 44 other sites; efforts to
                              increase sampling frequency at another 40
                              speciation sites is under review; regarding
                              remaining 208 sites, EPA officials recognize that
                              having more frequent data is better, but said all
                              data, including samples collected once every 6
                              days, will be useful to scientific community.

4. EPA should make greater    EPA used $3.4 million of funds planned for the     Yes
use of continuous monitors    mass-only monitoring program to increase the
to help determine human       number of continuous monitoring sites from 62 to
exposures and facilitate      137, a 121-percent increase in continuous
time-series epidemiological   monitoring sites nationwide.
studies.

5. Mass-only monitors will    EPA's revised plans call for speciation sites to   Yes
likely not measure some       use three types of filters (teflon, nylon, and
important components of the   quartz) to measure components of the PM2.5
PM2.5 mixture, such as        mixture, such as nitrates, organic compounds,
nitrates and organic          sulfates, metals, and other components of the
compounds.                    PM2.5 mixture; also, 108 IMPROVE sites in
                              national park and wilderness areas will use these
                              three filters.

6. Future research results    EPA's revised plans provide a better relative mix  Yes
may indicate mass-only        of monitoring sites to help the agency both
monitors are not measuring    implement the 1997 standards for particle mass
the most biologically         and investigate the health, exposure, and
important aspects of          atmospheric uncertainties associated with the
particulate matter.           PM2.5 mixture.

7. Specific objectives,       Objectives, conditions, number, and siting         Yes
operating conditions,         criteria for the mass-only monitoring network
number, and location of       were peer reviewed in August 1996; first 54
monitors should be            speciation sites, 108 IMPROVE sites, and 2
independently peer-reviewed   initial supersites were peer-reviewed in November
prior to implementation.      1998; EPA has announced plans to have the
                              remaining 248 speciation sites peer-reviewed.

8. Interface between          EPA established steering committee to coordinate   Mostly
monitoring and research on    its PM2.5 monitoring activities with others
particulate matter still      involved in similar activities (federal, state,
largely uncoordinated and     local, and multinational associations; academia,
fragmented.                   nonprofit advisory bodies, others); efforts to
                              establish procedures ensuring optimization of
                              PM2.5 data collection activities continue.
-----------------------------------------------------------------------------------------
As shown in table 2, EPA continued with the rapid deployment of over
800 mass-only monitors by December 31, 1998.  Although the Academy
was concerned that the agency was moving forward too rapidly with too
narrow a focus on mass-only monitors, EPA officials explained that
they continued with the rapid deployment of these monitors for
several reasons.  First, they explained that the agency needed 3
years of data to make reliable determinations of those areas that
exceed the new standards and that the agency received extensive
public comments regarding the estimated 15,000 premature deaths
annually from fine particles.  They also said that EPA deployed these
monitors in response to a July 1997 presidential directive to
expedite the deployment of the network and a provision in the
Transportation Equity Act for the 21\st Century requiring compliance
monitors be installed by December 31, 1999.  Additionally, they said
that the agency deployed these monitors only after both the monitors
and the network design were peer-reviewed, and that the number of
mass-only monitoring sites is comparable to other ambient air
monitoring programs. 

EPA officials pointed out that the agency had planned to deploy 1,500
monitoring sites over a 3-year period (beginning in fiscal year
1999), with about 20 percent deployed the first year, 40 percent the
second year, and the remaining 40 percent the third year.  However,
in July 1997, EPA condensed its deployment schedule from 3 to 2
years, with over half of the 1,500 monitoring sites to be deployed by
December 31, 1998.  As will be discussed in the next section, some
state and local agencies' experiences indicate that the rapid
deployment of these monitors has not been without problems. 
Nonetheless, even with the early problems encountered, EPA officials
believe the PM2.5 mass-only monitoring network will be producing
quality data earlier than had EPA used its originally planned 3-year
deployment schedule.  (Additional information on the status of EPA's
actions to address the Academy's concerns is provided in app.  I.)

--------------------
\4 CASAC is a permanent subcommittee of the Science Advisory Board
established by the Clean Air Act Amendments of 1977. 

   STATE AND LOCAL AGENCIES FACE
   IMPLEMENTATION CHALLENGES
------------------------------------------------------------ Letter :4

State and local agencies face both near-term and long-range
challenges in establishing and operating the PM2.5 monitoring
program.  These challenges include correcting various operational
problems with mass-only monitors, resolving data gaps caused by a
lack of spare monitors, ensuring the full testing of future monitors
before deployment, and obtaining sufficient state and local resources
to pay for their share of the program.  EPA has actions under way or
planned to mitigate these challenges.  Among other things, EPA is
working with state and local agencies and affected manufacturers to
remedy the remaining operational problems with monitors, providing
funding for spare monitors, and developing a deployment schedule that
will provide additional time for field testing of the more complex
speciation monitors yet to be deployed.  As of May 1999, the network
was 91-percent complete, which EPA officials told us represents a
significant amount of success, considering the enormousness of the
task and their historical experiences with implementing a major new
monitoring program of this magnitude.  However, about 9 percent of
the network that was supposed to be operational by December 31, 1998,
was still not operating after more than 4 months. 

      MONITOR OPERATIONAL PROBLEMS
      HAVE AFFECTED DATA QUALITY
---------------------------------------------------------- Letter :4.1

While funding for the PM2.5 monitoring program is a long-term concern
of state and local agencies, their most immediate challenge has been
correcting the operational problems they have experienced with the
mass-only monitors that were to be deployed by December 31, 1998. 
According to a May 1999 EPA survey, state and local agencies
nationwide have had operational problems with about 30 percent of the
monitors deployed to date.  For those monitors that have experienced
problems, figure 2 shows the types of obstacles that state and local
agencies have experienced. 

   Figure 2:  Obstacles to PM 2.5
   Monitor Operations for the
   First Quarter, 1999

   (See figure in printed
   edition.)

Source:  EPA's Office of Air Quality Planning and Standards. 

As shown in figure 2, while monitor malfunctions have been the single
largest challenge for state and local agencies, other challenges have
included site installation problems (such as obtaining leases to use
property), state procurement delays, and state hiring limitations. 
Because data quality reports for first quarter monitoring activities
are not due until July 1, 1999, it is too early to tell the
nationwide impact of these problems.  However, we contacted six state
and local agencies that, collectively, operate 218 of the 823
monitoring sites deployed, or about one-fourth of the sites that were
to be established by December 31, 1998, to discuss their monitoring
experiences and the impact of monitor problems on data quality.  As
shown in figure 3, each of the six state and local agencies that we
contacted have experienced significant operational problems with one
or more of their mass-only monitors since January 1, 1999--problems
they believe have impacted their ability to meet EPA's PM2.5 data
quality requirements for the first quarter of 1999. 

   Figure 3:  Percentage of
   Monitors With Operational
   Problems Potentially Impacting
   Data Quality During the First
   Quarter, 1999

   (See figure in printed
   edition.)

*South Coast Air Quality Management District (California). 

Source:  GAO illustration based on estimates supplied by officials of
six state and local agencies. 

Among the more significant problems state and local agencies have
encountered are the following: 

  -- Filter cassettes jammed in very cold weather, resulting in lost
     data and causing state and local agencies to operate their
     monitors in manual mode, which increases labor costs. 

  -- Monitor access doors were improperly sealed, allowing dust into
     the monitor, contaminating the filter, and resulting in voided
     and incorrect filter readings. 

  -- Monitor cooling fans pulled in dust containing coarse mode
     (greater than 2.5 microns) and other unwanted particles,
     potentially resulting in incorrect readings. 

  -- Software for the automated multiday samplers had problems,
     resulting in lost data because the most recent readings
     overwrote previous readings. 

  -- Troubleshooting instructions provided to state and local
     agencies were insufficient, which precludes technicians from
     making simple repairs on-site and requires monitors to be
     shipped back to the manufacturer, thus causing more data to be
     lost in the interim. 

Some officials in the six state and local agencies we contacted said
that the rapid deployment and the number of monitors needed exceeded
manufacturers' short-term production capacity.  For example, in
addition to being nearly 2 months later than expected, officials of
the California Air Resources Board's (CARB) Monitoring and Laboratory
Division\5 told us that 5 of the 120 monitors they received arrived
at their offices already in need of repair.  In conducting initial
acceptance testing on these monitors, the CARB staff found that some
monitors had wiring problems, and, in some cases, parts within the
sampling tube had not been anodized, a process that coats the
interior wall of the sampling tube so that particles pass through
freely and do not adhere to the walls of the tube.  Georgia,
Illinois, and the South Coast Air Quality Management District (a
local program in California) also had monitors delivered later than
EPA had planned.  According to EPA, the late deliveries were due to
the length of time EPA needed to get final versions of the monitors
and full documentation from the manufacturers, thus delaying testing
and approval for use in the PM2.5 monitoring program.  Although New
York's monitors were received on time, two monitors failed initial
acceptance testing and had to be sent back to the manufacturer for
repairs; according to New York officials, data were lost in the
meantime. 

While getting monitors installed and operating is a major step, it
does not ensure data quality.  For example, a monitoring expert with
California's South Coast Air Quality Management District--who is also
a member of CASAC and Chair of the Association of Local Air Pollution
Control Officials (ALAPCO)\6 Monitoring Committee--told us he is
concerned about the quality of data being recorded by these first
monitors.  In March 1999, according to this member, the District
found that over 40 percent of the field blanks--filters used to
identify contamination inside the monitoring device in the actual
field environment--had shown excessive accumulations of dust. 
Officials from Illinois and New York also told us they are concerned
they will not meet the data quality requirements for several
monitoring stations for the first quarter of 1999, and some expressed
concern about the second quarter of 1999 as well.  Additionally, an
unknown factor, they said, is how well these monitors will perform in
hot, humid, or dusty summertime conditions.  EPA officials said that,
if such additional problems occur, they will work with the state and
local agencies and the manufacturers to resolve any problems as
expeditiously as possible.  Additionally, EPA officials pointed out
that it is primarily due to the agency's extensive PM2.5 quality
assurance program--instituted before the mass-only monitors were
deployed--that state and local agencies have been able to identify
some of the operational problems in the deployment of the monitoring
network. 

State and local agency officials said that manufacturers have been
repairing monitors under their warranty provisions.  While some said
the problems experienced are not unusual for a major new monitoring
program of this magnitude, others believed differently.  For example,
Illinois officials said the equipment malfunctions were severe, and
the decision to rapidly deploy the majority of the nationwide network
in the first year now meant ï¿½massive equipment redesigns and
retrofits.ï¿½ While EPA officials agreed that some monitor repairs have
been necessary, they disagreed with Illinois' characterization of
these problems as massive.  The officials noted that both EPA
headquarters and regional offices have been assisting the affected
state and local agencies in resolving these early program problems. 
For example, because of the magnitude of the problems encountered, in
April 1999 EPA's contracting officer sent letters to the mass-only
monitor manufacturers requesting full warranty coverage for an
additional 3 months to ensure that the manufacturers' repairs have
been successful.  EPA officials said the problems encountered did not
surface in the agency's initial testing and that the manufacturers
have cooperated in repairing monitors under their 1-year warranty
provisions.  EPA has also provided state and local agencies with new
options for meeting their data quality requirements in the interim
while manufacturers work to correct equipment problems, and the
agency has increased its funding estimates for monitor operation and
maintenance activities, including labor costs. 

--------------------
\5 CARB's Monitoring and Laboratory Division performed initial
acceptance testing for Arizona, Hawaii, and district offices in
California. 

\6 ALAPCO is a trade association for local air pollution programs. 

      SOME DATA LOST BECAUSE SPARE
      MONITORS WERE NOT AVAILABLE
---------------------------------------------------------- Letter :4.2

An additional concern relates to the lack of spare monitors. 
According to state and local agency officials, EPA did not initially
provide funding for spare monitors.  Therefore, as monitor
operational problems have occurred, data have been lost while
monitors are shipped back to the manufacturers for repairs. 
According to CARB officials, provisions should have been made for
about 10 percent more monitors to be used as spares, given the
agency's plans for widespread deployment in the first year. 
Similarly, New York air quality officials said that, without spare
monitors, they found it necessary to cannibalize two monitors in
order to obtain spare parts in an attempt to increase the number of
valid samples. 

EPA officials agree that initial grants (fiscal year 1998) for the
purchase of PM2.5 monitors did not include funds to purchase spare
monitors.  In their opinion, it was more important initially to get
the compliance monitors set up and operational at as many sites as
possible in the first year, and then later to buy any spare monitors
that might be needed.  The officials pointed out that, in designing
the program, they believed that spare monitors would more likely be
needed after the first year when, due to wear and tear, monitors may
need major repairs.  However, after the early experiences, they said
EPA took steps to rectify the problem by approving funds for the
purchase of spare monitors in state and local agency grants (fiscal
year 1999) for the next round of purchases.  EPA has also provided
state and local agencies with options for meeting data quality
requirements, such as allowing less frequent sampling at problem
sites in the interim and using valid results from similar time
periods next year to fill current data gaps. 

      FULL TESTING OF MONITORS NOT
      COMPLETED BEFORE WIDESPREAD
      DEPLOYMENT
---------------------------------------------------------- Letter :4.3

Most of the state and local air quality monitoring officials we
contacted believe EPA's deployment of the mass-only monitors was too
optimistic and that a slower schedule would have been better.  In
their opinion, slower deployment would have allowed the
identification of monitor problems before the bulk of the monitors
were operating in the field.  They attribute many monitor
difficulties to EPA's expedited deployment of mass-only monitors
without adequate operational testing performed under actual field
conditions for a full annual cycle before their widespread
deployment.  Some of the officials said that they informed EPA before
deployment that the agency was moving too quickly to authorize the
PM2.5 mass-only monitors and that they disliked having to purchase
the monitors based on prototype design and manufacturer
specifications without seeing a production model in operation. 

Based on the PM2.5 monitoring program's level of complexity and the
sensitivity of the measurements, the state and local agencies said
they wanted sufficient time to evaluate a few monitors over different
seasons and in actual field conditions before making large-scale
purchases.  For example, CARB officials noted that their agency
commented early on that they were concerned about the adequacy of the
mass-only monitors and the lack of full field testing.\7

Similarly, New York officials said that the majority of the problems
related to the deployment of the monitoring portion of the PM2.5
program have resulted from the compressed time frame for
implementation.  The officials believe that in addition to extensive
design development, laboratory testing, and preliminary all-season
field testing, the program should have been phased in gradually. 
Georgia, Illinois, and Texas officials also expressed concern that
the deployment schedule was too ambitious, especially considering the
sensitivity of the new PM2.5 monitoring system and past problems
experienced with deploying new monitoring systems for other air
pollutants.  Most suggested that an alternative ï¿½go slowï¿½ approach
would have saved time and money by eliminating the need for state
employees to ship defective monitors back to the manufacturer or to
remove and ship defective parts back to the manufacturer.  EPA
officials acknowledged that this slower approach was preferred by the
monitoring community but said other factors--namely public health
concerns--were considered in their decision to expeditiously deploy
the mass-only monitors.  According to EPA, the agency recognized
state and local agencies' concerns about the deployment schedule, but
EPA relied on testing under the monitor approval process rather than
delay the deployment in order to test monitors over a full annual
cycle of conditions. 

More importantly, some state and local agency officials are concerned
that deployment of the more complex and costly speciation monitors
without adequate field testing would present even greater challenges
than they have faced to date.  To help preclude similar problems with
future monitors, the officials suggested that EPA take a slower
approach to approving the remaining monitors to ensure that they
operate properly under all conditions and all seasons before their
widespread use is undertaken.  According to EPA officials, the agency
recently reevaluated its PM2.5 monitoring plans and has extended
deployment of the more complex and costly speciation and other
monitors an additional year--to December 2000--to allow more time for
field testing by state and local agencies, as well as completion of
additional work sponsored by EPA in fiscal year 1999. 

--------------------
\7 Full field testing is an evaluation of the monitor under actual
field conditions where temperature, humidity, and other factors, such
as season of the year, are not simulated. 

      STATE AND LOCAL AGENCIES
      FACE FUTURE RESOURCE
      CHALLENGES
---------------------------------------------------------- Letter :4.4

State and local agency officials are generally pleased that EPA has
been fully funding the program so far; however, they are concerned
about their ability to match the federal grant in future years.  With
ongoing program costs expected to exceed $42 million annually, the
PM2.5 monitoring program is the most expensive air monitoring program
for a single pollutant in EPA's history, according to agency
officials.  Once the monitoring program is established and
operational, state and local agencies must provide matching funds to
operate the PM2.5 monitoring program--a requirement that presents
significant challenges to them in the future, they said, given the
other air quality programs for which they already must provide
matching funds. 

Some state and local agencies we contacted are uncertain about the
amount of matching funds they will have for PM2.5 activities in
future years.  Resource challenges, they believe, could cause them to
have to reduce the number of PM2.5 monitoring sites they will be able
to operate when they have to pay for 40 percent of the program costs. 
The agencies believe that a technological breakthrough in monitor
design is needed to reduce their operating costs.  Such a
breakthrough occurred in the PM10 program\8 when a continuous PM10
monitor was developed.  EPA officials are aware that this is an
expensive program and have said the agency is relying on the current
appropriations authority that provides for full federal funding of
the PM2.5 program through its demonstration phase.  The extension of
this authority for full funding will mitigate the near-term impact on
state and local agencies, they said, and provide an opportunity for
advances in monitor design in the intervening years, which could
reduce the resource burden state and local agencies will face.  The
development of a continuous mass monitoring system is a high priority
for EPA's Office of Research and Development (ORD), which has a goal
of an improved monitor by the end of 2001.  EPA allocated about
$200,000 to such efforts in fiscal year 1999, with increases in
funding anticipated for 2000 and 2001.  According to ORD officials,
this is an appropriate level of federal funding because, due to
market incentives, private industry manufacturers are already heavily
involved in their own research and development of continuous PM2.5
monitors.  EPA also noted that an important part of future budget
planning will be a review of the availability of new monitoring
methods and other scientific advancements, as well as an examination
of actual costs for program elements not yet fully implemented. 

--------------------
\8 The PM10 monitoring program was established in 1987 to monitor for
coarse particles 10 microns and smaller. 

   CONCLUSIONS
------------------------------------------------------------ Letter :5

EPA made numerous changes in its PM2.5 monitoring program to respond
to the concerns raised by the National Academy of Sciences; however,
the agency continued with the rapid deployment of over 800 mass-only
monitors without full field testing.  This decision led to numerous
operational problems discovered only after the monitors were
deployed, resulting in some lost and questionable data and
unanticipated operational and maintenance expenses.  While steps are
under way to address current problems, future problems with the other
more complex and expensive monitors--if they occurred--would impact
data quality, increase labor costs, delay needed health protections,
and eventually erode public confidence in the network.  To help
prevent similar problems from occurring in the future, EPA is
delaying its planned deployment of speciation monitors for 1 year to
allow more time for field testing.  While the additional field
testing may identify problems before the monitors are deployed, we
believe that EPA should not place an arbitrary time limit on its
field tests and should take whatever time is necessary to ensure that
future monitors successfully pass full field testing before
large-scale deployment is permitted. 

   RECOMMENDATION
------------------------------------------------------------ Letter :6

We recommend that the Administrator, Environmental Protection Agency,
ensure that all remaining monitors planned for the PM2.5 network
undergo and successfully pass full laboratory and full field testing
and evaluation under actual operating conditions to ensure that the
monitors meet data quality objectives before large-scale deployment
of these monitors is authorized. 

   AGENCY COMMENTS
------------------------------------------------------------ Letter :7

We provided a draft of this report to the Environmental Protection
Agency for its review and comment.  The agency generally agreed with
the overall message of the report, noting that it provides a fair and
balanced depiction of EPA's efforts to implement the PM2.5 monitoring
program.  Specifically, EPA agreed with our conclusion that no
arbitrary time limit should be imposed on testing the remaining
monitors planned for the PM2.5 monitoring network; however, EPA did
not comment on our recommendation.  EPA also suggested several
changes to clarify information in the report, and we incorporated
these comments where appropriate.  Appendix III contains the full
text of the agency's written comments and our responses. 

---------------------------------------------------------- Letter :7.1

We conducted our review from October 1998 through June 1999 in
accordance with generally accepted government auditing standards. 

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 15 days after the date of this report.  At that time, we will
send copies of this report to the Honorable Carol M.  Browner,
Administrator, Environmental Protection Agency, and other interested
parties.  We will also make copies available to others upon request. 

If you have any questions regarding this letter, please contact me or
David G.  Wood at (202) 512-6111.  Key contributors to this report
were William F.  McGee, James R.  Beusse, Philip L.  Bartholomew, and
Richard A.  Frankel. 

Sincerely yours,

Peter F.  Guerrero
Director, Environmental
 Protection Issues

EPA'S ACTIONS TO ADDRESS CONCERNS
WITH THE PM 2.5 MONITORING PROGRAM
=========================================================== Appendix I

In its March 1998 report,\1

the National Academy of Sciences (Academy) raised eight key concerns
about the ambient air monitoring part of the Environmental Protection
Agency's (EPA) PM2.5 program.  Academy representatives said that EPA
has made significant changes to the PM2.5 program to address many of
the key concerns presented in its report.  Information on EPA's
actions to address these concerns is discussed in this appendix. 

1.  EPA appeared to be moving forward rapidly with too narrow a focus
on PM2.5Federal Reference Method mass-only monitoring

EPA has made significant efforts to broaden its monitoring program
focus by involving the scientific community in the speciation and
supersite network planning.  For example, since the Academy's 1998
report, EPA has sought expert external scientific advice on the
siting, sampling, and measurements needed to address health,
exposure, and atmospheric research questions and jointly sponsored a
workshop with over 200 individuals to further involve the scientific
community in EPA's planning for the speciation and supersite
monitoring networks.  As a result, the agency reevaluated its
monitoring plans and decided to slow down the rollout of the
speciation monitors and supersites pending greater input from the
scientific community.  EPA also reduced the number of mass-only
monitors planned from 1,392 to 1,094 and increased the number and
frequency of analyses at 54 speciation sites.  EPA also more than
doubled the number of continuous monitoring sites, from 62 to 137,
and added plans for up to 9 supersites--an increase of $15 million in
EPA's PM2.5 monitoring budget.  Additionally, EPA tripled the types
of analyses to be performed at 108 Interagency Monitoring of
Protected Visual Environments (IMPROVE)\2 sites located in national
parks and wilderness areas, requiring these monitors to use three
different filters instead of the previous single-filter approach. 
After these changes, EPA's revised plans allocated 57 percent of
$65.7 million in fiscal year 1999 PM2.5 monitoring funds to efforts
designed to better understand PM2.5 scientific uncertainties. 

EPA continued to move forward rapidly with the PM2.5 mass-only
monitoring network, largely because of extensive public comments
regarding the estimated 15,000 premature deaths annually from fine
particles, a July 1997 presidential directive to expedite the
network, and a provision in the Transportation Equity Act for the
21\st Century calling for completion of the compliance portion of the
network by December 31, 1999.  EPA officials pointed out that, prior
to these inducements, the agency had planned for the 1,500 monitors
to be deployed over a 3-year period, with about 20 percent deployed
the first year, 40 percent the second year, and the remaining 40
percent the third year.  However, in July 1997, EPA condensed its
original deployment schedule from 3 to 2 years, with over half of the
1,500 monitors to be deployed by December 31, 1998.  EPA officials
said they were required by regulation to establish a minimum of about
850 federal reference method (FRM) mass-only sites for a complete
nationwide network.  About 823 FRM mass-only monitors were supposed
to be fully operational by December 31, 1998, with the remainder to
be installed by December 1999. 

2.  The relative mix of planned monitoring sites may not adequately
support health effects, exposure, and atmospheric modeling research
efforts

Since the Academy's report, EPA has reduced the number of planned FRM
mass-only sites from 1,392 to 1,094.  EPA's revised allocation of
fiscal year 1999 PM2.5 monitoring funds allocates about $28.5 million
to FRM mass-only monitoring; $17.2 million for speciation monitoring;
$5.1 million for continuous monitoring; and $15.0 million for
supersite monitoring.  EPA has delayed the deployment of these
supersites in order to more fully integrate supersite planning with
its research needs for health risk, exposure assessment, and
monitoring advances.  Intensive supersite monitoring efforts may run
from less than 1 to more than 5 years and are estimated to cost from
$1.0 to $3.5 million per site.  EPA officials believe this allocation
of funds strikes an appropriate balance between regulatory and
research needs, taking into consideration that this is the first time
that EPA's regulatory program has ever designed an ambient air
monitoring program both to determine compliance and to address
scientific uncertainties about a pollutant. 

The $15.0 million in science and technology funds EPA received in
fiscal year 1999 to conduct intensive research monitoring efforts at
four to nine supersites was to be used for scientific purposes, but
EPA had tremendous discretion in how the $50.7 million in state and
local agency grant funds was allocated.  By reducing the number of
FRM mass-only sites from 1,392 to 1,094, EPA was able to shift about
$6.5 million to other efforts.  About half, or $3.1 million, of these
funds will be used to increase the number and frequency of analyses
performed at speciation sites from sampling once every 6 days to
sampling no less often than once every 3 days at 54 speciation sites. 
Similarly, about $3.4 million of these funds will be used to increase
the number of continuous monitoring sites from the 62 originally
planned to 137 sites.  In addition to helping satisfy regulatory
program needs, such as identifying likely PM2.5 sources and assessing
control strategy effectiveness, the more frequent speciation analyses
and additional continuous monitors will help support health effects,
exposure, and atmospheric modeling research efforts, according to EPA
officials. 

3.  The current plans for the speciation of particulate matter once
every 6 days will not provide useful data for improving risk
assessments

A reduction in the number of planned FRM mass-only sites allowed EPA
to improve other aspects of the PM2.5 monitoring program.  For
example, EPA will use about $3.1 million of mass-only funds to
increase the frequency of speciation sampling from 1 sample every 6
days to daily sampling at 10 major urban area sites, and from 1
sample every 6 days to 1 sample every 3 days at 44 other speciation
sites.  Additionally, agency officials are considering ways to
increase the sampling frequency at another 40 speciation sites
located near supersites, with a goal of sampling at least once every
3 days.  With respect to the remaining 208 speciation sites where
samples will be collected once every 6 days, EPA officials recognize
that more frequent data is better, but said that all speciation
data--including samples collected once every 6 days--will still be
useful to the scientific community. 

4.  EPA should make greater use of continuous monitors to help
determine human exposures and facilitate time-series epidemiological
studies

EPA plans to use about $3.4 million of mass-only monitoring funds to
increase the number of continuous monitoring sites from 62 to 137--a
121-percent increase in the number of continuous monitoring sites
planned.  According to agency officials, these additional continuous
monitors should help determine human exposures and facilitate
time-series epidemiological studies. 

5.  FRM mass-only samplers will likely not measure some important
parameters (nitrates and organic compounds)

EPA officials said the FRM mass-only monitor's limitations were
recognized early, but no single sampling device is currently able to
accurately measure airborne fine particulate matter.  They noted that
many factors influenced the decision to use the FRM sampler,
including the need to balance sampler cost, ease of use, and ability
to produce reproducible measures that can be quality assured.  The
FRM mass-only sampler also produces data most comparable to the
historical epidemiological data base on which the PM2.5 standards are
based, and loses fewer constituents than most other monitors,
according to EPA officials.  They also noted that the speciation
monitors should measure nitrates and organics, and that the choice of
the FRM mass-only monitor was peer-reviewed and approved by the Clean
Air Science Advisory Committee (CASAC)\3 Technical Subcommittee for
Fine Particle Monitoring in August 1996.  The agency's revised plans
call for speciation sites to use three types of filters (teflon,
nylon, and quartz) to speciate nitrates, organic compounds, sulfates,
metals, and other components of the PM2.5 mixture.  Additionally, the
108 IMPROVE sites in national park and wilderness areas will use
these three filters. 

6.  Future research results may indicate that the monitors are not
measuring the most biologically important aspects of particulate
matter

EPA officials said that they recognize that future research results
may show that the PM2.5 monitors are not measuring the most
biologically important aspects of particulate matter.  However, they
believe this determination is years away, and--as noted
previously--their assessment of their 1997 regulation is that PM2.5
mass should be monitored at a minimum of about 850 sites. 
Additionally, they pointed out that PM2.5 may be a confounding
co-contributor to adverse health effects, and measuring PM2.5 mass
may be the most cost-effective, long-term surrogate measure for a
nationwide network.  To help address this Academy concern, as noted
previously, EPA significantly revised the relative mix of sites to
better support health, exposure, and atmospheric modeling research. 

7.  Specific objectives, operating conditions, number, type, and
location of monitors should be thoroughly and independently
peer-reviewed prior to implementation

EPA officials said they planned to have these aspects of the PM2.5
monitoring program independently peer-reviewed prior to
implementation.  For example, the basic FRM mass-only monitoring
network composed of about 1,094 sites was peer reviewed and approved
by the CASAC Technical Subcommittee for Fine Particle Monitoring in
August 1996.  More recently, this subcommittee also peer-reviewed and
approved 54 speciation network trends sites, 108 IMPROVE sites, and 2
test supersites in November 1998.  EPA plans for the remaining 248
sites to be peer-reviewed before implementation. 

8.  Interface between monitoring and research on particulate matter
is still largely uncoordinated and fragmented

According to EPA officials, the agency coordinates its PM2.5
monitoring program internally through a steering committee jointly
headed by representatives of the agency's program and research
offices.  Externally, EPA coordinates its PM2.5 monitoring program
with key federal programs and activities involved in similar work. 
These include the North American Research Strategy for Tropospheric
Ozone organization, composed of EPA, National Oceanic and Atmospheric
Administration, the Department of Energy, and over 50 other public
and private institutions; the Health Effects Institute; as well as
the IMPROVE steering committee, comprised of EPA, National Park
Service, Forest Service, Fish and Wildlife Service, Bureau of Land
Management, the Western States Air Resources cooperative, and
Northeast States for Coordinated Air Use Management.  EPA also
coordinates with the State and Territorial Air Pollution Program
Administrators/Association of Local Air Pollution Control Officials
(STAPPA/ALAPCO) PM2.5 committee, the National Academy of
Sciences/National Research Council's Committee on Research Priorities
for Airborne Particulate Matter, and the Science Advisory Board's
CASAC Technical Subcommittee on Fine Particle Monitoring.  According
to agency officials, they recognize that coordination with some other
federal and nonfederal agencies and organizations could be improved
and have recently established a formal cross-federal coordination
group under the Committee on Environment and Natural Resources to
coordinate EPA's PM2.5 monitoring and research activities with the
National Institute of Environmental Health Sciences; the National
Institute of Occupational Safety and Health; the departments of
Energy, Defense, Agriculture, and Health and Human Services; the
National Oceanic and Atmospheric Administration; the National
Aeronautics and Space Administration; and others.  EPA is still
developing procedures to ensure optimization of PM2.5 data collection
activities. 

--------------------
\1 Research Priorities for Airborne Particulate Matter:  Immediate
Priorities and a Long-Range Research Portfolio, Committee on Research
Priorities for Airborne Particulate Matter, National Research
Council, National Academy of Sciences (Mar.  1998). 

\2 IMPROVE is a joint effort with the Department of the Interior,
Federal Land Managers, and state and local agencies. 

\3 CASAC is a permanent subcommittee of the Science Advisory Board
established by the Clean Air Act Amendments of 1977. 

OBJECTIVES, SCOPE, AND METHODOLOGY
========================================================== Appendix II

The Chairman, Subcommittee on VA, HUD, and Independent Agencies,
House Committee on Appropriations, asked us to describe (1) EPA's
actions in response to the National Academy of Sciences' concerns
with EPA's planned PM2.5 monitoring program and (2) the challenges
that state and local agencies face in establishing and operating the
PM2.5 monitoring program, as well as EPA's response to these
challenges. 

To describe the actions EPA has taken in response to key concerns
identified in the Academy's March 1998 report, we obtained and
reviewed EPA's, states', and local agencies' reports, guidance
documents, memorandums, and financial data showing the changes that
were made.  We also interviewed officials from the Academy; the
Science Advisory Board's Clean Air Science Advisory Committee; EPA's
Office of Air Quality Planning and Standards; EPA's Office of
Research and Development; and 5 of EPA's 10 regional offices; six
state and local agencies; and the State and Territorial Air Pollution
Program Administrators/Association of Local Air Pollution Control
Officials (STAPPA/ALAPCO) to gain a better understanding of the
actions the agency has taken. 

To understand the challenges that state and local air monitoring
agencies face in establishing and operating the PM2.5 program, we
interviewed officials from five states and the nation's largest local
program, as well as their respective EPA regional offices.  These
state and local programs were selected to provide a nationwide
representation of the environmental conditions under which the PM2.5
monitors would be expected to operate.  The selected states were
California, Georgia, Illinois, New York, and Texas, and the local
program was California's South Coast Air Quality Management District. 
The selection of these six state and local programs was coordinated
with EPA and STAPPA/ALAPCO, both of which agreed before we contacted
these agencies that they represented a good cross section of PM2.5
monitoring program experiences.  Collectively, these six state and
local agencies operate 218 of the 823 monitoring sites that were to
be deployed by December 31, 1998, or about one-fourth of the sites. 
We asked representatives from these programs about their experiences
with the monitors, including sampling, sample handling and transport,
laboratory analysis, and data reporting.  We also asked if they had
any recommendations they believe would improve the program.  We also
interviewed officials from the national organization that represents
state and local air monitoring programs to gain nationwide
perspective on the experience that their other members have had with
the PM2.5 monitoring program.  Additionally, we obtained information
from several regional organizations that represent state and local
air monitoring agencies to gain a regional perspective on PM2.5 air
monitoring experiences and issues.  We also interviewed EPA
headquarters and regional officials to identify any ongoing or
planned mitigating actions to help state and local agencies address
the challenges they face in establishing and operating their PM2.5
networks. 

We conducted our review from October 1998 through June 1999 in
accordance with generally accepted government auditing standards. 

(See figure in printed edition.)Appendix III
COMMENTS FROM THE ENVIRONMENTAL
PROTECTION AGENCY
========================================================== Appendix II

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The following are GAO's comments on EPA's letter dated July 8, 1999. 
They are numbered in accordance with the numbered comments in EPA's
letter. 

GAO'S COMMENTS

1.  This sentence was amended to state that mass-only monitors are
required for determining areas that exceed the PM2.5 standards, since
it is EPA's own regulations that require their use. 

2.  EPA's views have been added to this section of the report. 

3.  As suggested, we added the term ï¿½speciationï¿½ to clarify that the
more complex and costly monitors that have yet to be deployed are
speciation monitors. 

4.  We agreed with this comment and have revised the report
accordingly. 

5.  We changed footnote 2 to update the status of court rulings about
EPA's particulate standards and the status of EPA's appeals. 

6.  This sentence was clarified to show that state and local agencies
received $50.7 million of the $65.7 million in PM2.5 monitoring funds
for fiscal year 1999 and that EPA's supersites monitoring effort
received $15.0 million of these funds. 

7.  See comment 4. 

8.  See comment 4. 

9.  The statements suggested by EPA have not been included because
this section already appropriately addressed these issues. 

10.  This section was clarified to show that state and local agencies
nationwide have had operational problems with about 30 percent of the
monitors deployed and, for those monitors that have had problems, the
types of obstacles that state and local agencies have experienced. 

11.  See comment 4. 

12.  EPA views have been added to this section and attributed to EPA. 

13.  See comment 12. 

14.  See comment 4. 

15.  See comment 4. 

16.  EPA's agreement with our conclusions has been noted in the
agency comments section of the report. 

17.  See comment 4. 

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