Review of the Air Quality Criteria Document for Particulate Matter

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Page 3-54, lines 10-15: Point out that CEMs are available to look at SO 2 . Other pollutants couldbe done if it were important (like needing verification for trading rights).Page 3-55, lines 18-21: Later in the chapter, it is pointed out that the EI gives average emissionsrather that the specific emission rates needed for modeling. It would be better to start thatdiscussion here.Page 3-56: Biogenic sources are important for precursors for SOA. What is known about thoseemission inventories. How good is BIES?Chapter 4This chapter should be complemented for making clear distinctions between the effects of fineand coarse particles.Page 4-8, lines 19-28: The outflow of Asian dust to the mid-Pacific is now thought to be acritical source of micronutrients to the phytoplankton there. There should be a note of the workof Bob Duce and coworkers in this area.Chapter 5This chapter is very weak on describing what is known regarding the exposure to PM 10-2.5 . SinceChapter 6 highlights the epidemiology of PM 10-2.5 separate from PM 2.5 and PM 10 , it is importantthat there be parallel coverage of the exposure in this chapter to set the scene for that discussion.Page 5-54- 5-55, What can be said more definitively about the penetration efficiency of PM 10-2.5 ?How does this affect our ability to relate PM 10-2.5 to total exposure and thus to adverse healtheffects? There needs to be a focused section on this issue comparing and contrasting thedifference between PM 10-2.5 and PM 2.5 in this respect.Pages 5-66, lines 23 - 26: UNMIX is rather different from PMF. It uses an eigenvector analysiswhich has been shown to provide non-optimal data point weighting because it fundamentallyassumes homoscedastic data that is generally a poor assumption.Page 5-92, lines 14 to 20: Is this discussion only about PM 2.5 or about both PM 2.5 and PM 10-2.5Page 5-92, lines 25-31: Because of the poorer penetration of coarse particles and the much largerspatial inhomogeneities, there will be much larger errors in the exposure estimates for coarse.There needs to be a discussion of this problem here.Chapter 6Given the variability of PM 2.5 /PM 10 , there needs to be a discussion of whether or not the study ofPM 10 will really provide any insights into the quantitative risk assessment of PM 10-2.5 .Chapter 7No commentsChapter 8There is no real discussion of organic aerosol mechanisms. The work that has been done is veryimportant and useful, but there are other types of particles particularly primary and secondaryorganics. Since we can only separate and identify the specific compounds in about 20% of theorganic mass under the best of conditions, it makes it very difficult to fully characterize thetoxicological properties of these particles. It is very difficult to generate secondary organicaerosol in the lab and thus, providing reproducible conditions for exposing animal models isdifficult.A - 3
Page 8-1, lines 26-28: Combustion aerosol are rarely “dominant” particle types. In most of thecountry, the dominant fine particle types are secondary aerosols. They do often derive fromcombustion generated SO 2 , NO x , and some organic compounds, but there are also importantbiogenic precursor compounds. Thus, there needs to be some rewording of this sentence.Page 8-87: There is no separate discussion of the toxicology of coarse particles even to say thatnothing is know regarding the toxicology of such particles.Chapter 9Page 9-10, lines17 to 29: This data is very outdated. The needs to be examination of theextensive data showing the frequent presence of an Aitken mode in rural aerosols as well as theoccasional nuclei mode as well.Section 9.3 has no discussion of coarse mode sampling.Section 9.3.2.3: why is there a discussion of spatial variability of PM 2.5 without paralleldiscussions of PM 10 and PM 10-2.5 ?Frederick Miller, PhDChapter 6 - General Comments:The chapter in its current form represents an extensive review of the available literature fromepidemiological studies on the effects of particulate matter. The organization of the chapter intothe major subheadings is appropriate. As one reads the chapter, there is a tendency for the PM 2.5effects to be discussed in great detail and for the conclusion to be drawn that PM 2.5 is of more concernthan PM 10-2.5 . However, as the chapter develops, studies are presented showing the potential for coarseparticles to have an effect. The balance of this discussion should be examined in particular as it is broughtforth to the synthesis chapter.Throughout the document values of PM 2.5 and PM 10-2.5 are presented. However, the document fails tomake clear when PM 2.5 is a derived measurement vs. a direct measurement. This is critically importantfor standard setting purposes as correlation analyses provide different weight of evidence on averagevalues compared to direct measurement. To help the reader in evaluating the strengths of the differentstudies, under Study Description it would be of value to simply indicate if measurements on exposurelevels are direct or derived measurements.Specific Comments:p. 6-20 The Schwartz (2000c) study in the table reports a PM 2.5 mean of 15.6 mg/m 3 .The study was conducted using data from 1979 1986. Were PM 2.5measurements available in the late 1970s? How was the mean for PM 2.5arrived at?p. 6-23 The entry for the Smith study under Results and Comments brings up the topicof threshold. No discussion of this study follows until page 6-247. It is not clearwhy the emphasis in the discussion of Table 6-1 should be restricted to multicitystudies, particularly when individual studies bring up topics that areimportant for standard setting such as the concept of threshold, the statisticalaveraging time, or additional potential sensitive subpopulations.p. 6-53 The figure presented here shows that 10 of 13 PM 2.5 studies and 4 of 13 coarsemode studies show statistical significance. While this gives greater emphasis tothe importance of both the fine and the coarse mode for standard setting, thediscussion in the text does not bring this point out as strongly as it should be.For example, in the section on crustal particle effects on page 6-56, the studiesare discussed with a tendency for not showing an effect and little discussion isinvolved for the four studies that did demonstrate effects of coarse modeparticles.p. 6-77, l. 8 26 The slant towards interpretation of PM 2.5 and relative dismissal of theimportance of the coarse mode is continued in this section here on fine andA - 4
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the chapter. Many of the poor quali
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illustrated using a figure from Kel
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tied back to the base-line health s
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Günter Oberdörster, PhDChapter 7
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efficiencies as well as the ratio o
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The title of this section is also s
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old and young rats and mice used on
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passive use values as opposed to us
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Specific Comments:Page 5-19, lines
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Chapter 9 - General CommentsThis ch
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George Taylor, PhDAir Quality Crite
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atmospheric stressors associated wi
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Review of the Air Quality Criteria Document for Particulate Matter

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