Summary of Comments and Responses on the December 1984 Proposed Revisions to the Guideline on Air Quality Models July 1986 Source Receptor Analysis Branch Monitoring and Data Analysis Division Office of Air Quality Planning and Standards Environmental Protection Agency ------- Table of Contents Summary of Comments and Responses on the December 1984 Proposed Revisions to the Guideline on Air Quality Models Page OVERVIEW 1 1.0 INTRODUCTION 1-1 2.0 OVERVIEW OF MODEL USE 2-1 3.0 RECOMMENDED AIR QUALITY MODELS 3-1 3.1 Preferred Modeling Techniques 3-2 3.2 Use of Alternative Models 3-8 3.3 Availability of Supplementary Modeling Guidance 3-13 4.0 SIMPLE-TERRAIN STATIONARY-SOURCE MODELS 4-1 5.0 MODEL USE IN COMPLEX TERRAIN 5-1 6.0 MODELS FOR OZONE, CARBON MONOXIDE AND NITROGEN DIOXIDE 6-1 6.1 Discussion 6-1 6.2 Recommendations 6-2 6.2.1 Models for Ozone 6-2 6.2.2 Models for Carbon Monoxide 6-5 6.2.3 Models for Nitrogen Dioxide (Annual Average) 6-8 7.0 OTHER MODEL REQUIREMENTS 7-1 7.1 Discussion 7-1 7.2 Recommendations 7-1 7.2.1 Fugitive Dust/Fugitive Emissions 7-1 7.2.2 Particulate Matter 7-3 7.2.3 Lead 7-4 7.2.4 Visibility 7-5 7.2.5 Good Engineering Practice Stack Height 7-6 7.2.6 Long Range Transport 7-9 7.2.7 Modeling Guidance for Other Government Programs .. 7-10 8.0 GENERAL MODELING CONSIDERATIONS 8-1 8.1 Discussion 8-1 8.2 Recommendations 8-1 8.2.1 Design Concentrations 8-1 8.2.2 Critical Receptor Sites 8-2 8.2.3 Dispersion Coefficients 8-5 8.2.4 Stability Categories 8-8 ------- 8.2.5 Plume Rise 8-9 8.2.6 Chemical Transformation 8-15 8.2.7 Gravitational Settling and Deposition 8-16 8.2.8 Urban/Rural Classification 8-17 8.2.9 Fumigation 8-18 8.2.11 Calibration of Models 8-19 9.0 MODEL INPUT DATA 9-1 9.1 Source Data 9-1 9.2 Background Concentrations 9-4 .9.3 Meteorological Input Data 9-8 9.3.1 Length of Record of Meteorological Data 9-8 9.3.2 National Weather Service Data 9-11 9.3.3 Site Specific Data 9-12 9.3.4 Treatment of Calms 9-19 10.0 ACCURACY AND UNCERTAINTY OF MODELS 10-1 11.0 REGULATORY APPLICATION OF MODELS 11-1 11.1 Discussion 11-1 11.2 Recommendations 11-1 11.2.1 Analysis Requirements 11-1 11.2.2 Use of Measured Data in Lieu of Model Estimates 11-3 11.2.3 Emission Limits 11-5 APPENDIX A. SUMMARIES OF PREFERRED AIR QUALITY MODELS A.O INTRODUCTION A-l A.2 CALINE3 A-2 A.4 RAM A-2 A.5 ISC A-2 A.6 MPTER A-3 APPENDIX B. SUMMARIES OF ALTERNATIVE AIR QUALITY MODELS B.3 APRAC-3 B-l B.9 IMPACT (Sklarew) B-l B.I 2 MESOPLUME B-l B.18 SCSTER B-l B.24 RTDM (Version 3.00) B-2 REFERENCES R-l GLOSSARY OF COMMENTERS APPEARING IN DOCKET A-80-46 G-l ------- Summary of Comments and Responses on the December 1984 Proposed Revisions to the Guideline on Air-Quality Models OVERVIEW Background The Guideline on Air Quality Models was originally published in April 1978. It was incorporated by reference in the regulations for the Prevention of Significant Deterioration of Air Quality in June 1978. The purpose of the guideline is to promote consistency in the use of modeling within the air management process. Consistency is a primary goal of the 1977 Clean Air Act Amendments. The guideline provides model users with a common basis for estimating pollutant concentrations, assessing control strategies and specifying emission limits. In October 1980, EPA proposed changes to the Guideline on Air Quality Models and solicited comments on the changes. More than 80 comments were submitted. EPA responded to the comments resulting from the draft guideline and a summary of both the comments and the EPA responses is contained in a document entitled "Summary of Comments and Responses on the October 1980 Proposed Revisions to the Guideline on Air Quality Models," February 1984. A copy of this document as well as all supporting reports is available for review in Docket A-80-46. As a result of public comment, the guideline was further revised. On December 7, 1984 [49 £R 48018], EPA announced the availability of the "Guideline on Air Quality Models (Revised)" for further public comment. Oral comments were presented by interested parties during the Third Conference on Air Quality Modeling held in Washington, DC in January 1985. Proceedings ------- of these hearings were transcribed verbatim. Written comments were received until April 30, 1985. The purpose of this document is to summarize those comments and to present EPA responses to the major issues. Summary of Comments In 1977, the "Guideline on Air Quality Models" was the subject of a public hearing process in connection with promulgation of regulations for the Prevention of Significant Deterioration. In 1984, EPA proposed to change the reference in 40 CFR 51.24 and 40 CFR 52.21 from the 1978 edition of that guidance to the "Guideline on Air Quality Models (Revised)" to be completed and dated when the proposed changes become final and are promulgated Several issues were identified in the Federal Register announcement: 0 Specific changes to 40 CFR 51 and 52 0 Revised format of the guideline 0 Recommendations for ozone models 0 Proposed changes to preferred models 0 Improving performance evaluations, especially for ozone models 0 Modeling uncertainty 0 Degree to which State or local regulatory agencies can have authority to use nonguideline models 0 Degree of oversight or approval authority retained by EPA. Sixty-six commenters responded. The Glossary for this document lists the name of these commenters and indicates the docket reference number of the entire text of the individual submittals. Over 450 separate comments were extracted from these submittals and were later condensed and organized by topic. Many commenters suggested changes to specific sections of the guideline; at least one comment was received on every section of the proposed ------- revisions. Most comments were very technical in nature and quite detailed. The comments were varied; some were very specific while others were very general. In nearly all comments, the issue of consistency versus flexibility was inherent. The commenters on the proposed revisions can be separated into three major categories: private sector and industrial associations, State and local air management agencies, and Federal-Government representatives. By far the largest number of comments came from private industry. Although some of these industrial commenters voiced general support for the guide- line, several were critical of specific aspects of EPA guidance. However, recommendations to EPA were contradictory; some suggested that modeling analyses should be reviewed on a case-by-case basis while others said that guidance was not detailed enough and that further guidance was necessary. The Federal Agency comments supported the need for consistency and provided suggestions for changes to the proposed revisions or suggested improvements to EPA procedures. Comments were received from four EPA regions and have been resolved internally. Comments from State and local agencies were numerous. They appeared to support the concept of the guideline although not necessarily the complete content. EPA Responses to Comments As the comments were received, it was evident that not only had comments been submitted on the eight highlighted issues, but the entire proposal had been considered by most of the commenters. It was impractical to organize the responses by those eight issues. Therefore, the summary was organized by topic and the topics listed in the order of the chapter and section that appears in the guideline. Summarizing and characterizing the comments ------- themselves required some interpretation in order to place them in manageable response categories. Whenever possible the exact words used by the commenter were used in the comment summary. However, in many instances it was necessary to re-word or substantially condense the comment. Every effort was made to maintain the exact meaning of the ccmmenter. Following the summary of comments on each separate topic, the EPA response to those comments is given. Where there are subtopics in the comment summary, the response may be separated into subparagraphs. At the end of each comment summary, the primary commenters1 name(s), in abbreviated form, is used and a key to these abbreviations is shown in the Glossary. Not every commenter who may have alluded to that issue is necessarily listed with the comment summary, However, all issues have been addressed. ------- 1.0 INTRODUCTION Comment Summary (Model Accuracy and Consistency) A number of commenters urged the Agency to place model accuracy ahead of model consistency. They argued that use of the most accurate models should be promoted and that the need for consistency was overstated. Con- sistency is not always possible, thus flexibility/adaptability should not be sacrificed. The various commenters also noted that (1) the regulatory program should not require use of a single model, (2) use of a single model was based on an arbitrary selection process, and (3) this selection made the Agency very inflexible in allowing use of nonguideline models, especially those involving advances in technology. Furthermore, one comenter urged that Regional Offices use a consistent framework for modeling decisions. (AISI, AMC, APCA, API, DS, IPL, MSUS, SOC) EPA Response EPA's position is not that the "same answer" is preferable to the "best answer". The model that most accurately estimates concentrations in the area of interest is always sought. However, it is clear from the needs expressed by the States and EPA Regional Offices, by many industries and trade associations, and also by the deliberations of Congress, that uniform proce- dures in the selection and application of models and data bases should also be sought. Consistency ensures that air quality control agencies, affected industries, and the general public have a common basis for estimating pollutant concentrations, assessing control strategies and specifying emission limits. Such consistency is not, however, promoted at the expense of model and data base accuracy. The modeling guideline provides a uniform basis for selection of the most accurate models and data bases for use in air quality assessments. The ulti- mate goal of modeling guidance is to ensure that the best possible scientific procedures are implemented for operational use. Suitable mechanisms have been provided to ensure that the realism, flexibility, accuracy and best technical judgements, can be provided in a framework that satisfies the Clean Air Act 1-1 ------- requirements. This has been attempted through the general nature of guideline requirements,2 guidance on model demonstrations,3,4 and the operation of a Model Clearinghouse.5 Those activities are also intended to ensure consistency in the overall procedures that are followed by EPA Regional Offices. EPA has also solicited models from all model developers and since the inception of the program has considered over 25 non-EPA models.6 Where appro- priate, those models are recognized in the revised guideline. The limitations under which those models are used should be part of the initial protocol estab- lished between the applicant or model user and the appropriate EPA Regional Office. Based on its assessment of these models, EPA has designated certain models as "preferred". This is consistent with requirements of Sections 301 (a) (2) (A) of the Clean Air Act requiring EPA to promulgate regulations to "assure fairness and uniformity in the criteria, procedures, and policies applied by the various regions in implementing and enforcing the Act," Section 165(e)(3){D) concerning PSD, and more general requirements to demonstrate the adequacy of State Implementation Plans. The criteria for designating those models are discussed under comments in Section 3.1 dealing with "Basis for Model Selection." The designated standard models are frequently the EPA developed models and the ones recommended for specific uses in the guideline. However, as stated in the guideline, the model applied to a given situation should be the one that is most accurate in simulating atmospheric transport and dispersion in the area of interest. The PSD regulations specifically make allowance for the use of nonguideline techniques and the framework for consistent Regional Office decisions is already functioning. 1-2 ------- Comment Summary (Wording Changes) Several commenters recommended specific wording changes in Chapter 1. Those changes are listed below. Page 1-1, Lines 11 to 12--The sentence should be revised to retain the wording of the 1978 guideline: "Rather, it should serve as a basis by which air quality managers, supported by sound scientific judgment, have a common measure of acceptable technical analysis," Page 1-1, Line 13--The statement, "Due to limitations in the spatial coverage . . ." should be changed to read, "Due to limitations in the spatial and temporal coverage . . . ." Page 1-1, Line 21--Change the word "suitable" to "preferable." Page l-l--The second paragraph should be changed to state that . . . "monitoring and modeling data should be used in a complementary manner, with due regard for the strengths and weaknesses of each." Page 1-2, Lines 16 to 23--The following text should be added at the end of line 23. "The model that most accurately estimates concentrations in the area of interest is always sought. However, designation of specific models is needed to promote consistency in model selection and application. Such consistency is not, however, promoted at the expense of model and data base accuracy. This guide provides a consistent basis for the selection of the most accurate models and data bases for use in air quality assessments." Page 1-3, Lines 8 to 10--The sentence starting on line 8 should be changed to: "In all cases, the model applied to a given situation should be the one that provides the most accurate representation of atmospheric transport, dispersion, and chemical transformations in the area of interest." Pages 1-3, Lines 12 to 20--The Regional Meteorologists' workshops should be held not only to ensure model consistency but also to "promote the use of more accurate air quality models and data bases." (APCA, CONE, SOC, UARG) EPA Response EPA agrees with all of these suggested word changes and has included them in the final text of the guideline. 1-3 ------- 2.0 OVERVIEW OF MODEL USE Comment Summary (General) One commenter recommended that model estimates only be made by those with the requisite technical competence. Several other commenters recom- mended specific wording changes in Chapter 2. Those changes are listed be!ow. Page 2-2, Line 15--Change the sentence to read: "Air quality models are applied with the least degree of uncertainty in areas with relatively simple topography. Page 2-2, Lines 16 to 17--This sentence should be reworded to read: "Air quality models have been most accurately applied to simulations of long term averages in areas with relatively simple topography." Page 2-3, Line 12--An explanatory sentence should be added as follows: "Further, it should be recognized that under some sets of physical circum- stances and accuracy requirements, no present model may be appropriate." Page 2-5, Lines 2 to 4--The sentence concerning physical modeling should be revised to read: "Nevertheless, physical modeling may be useful for com- plex flow situations, such as building, terrain or stack downwash conditions, plume impact on elevated terrain, diffusion in an urban environment, or diffusion in complex terrain." Page 2-6, Line 6--EPA should state that "If screening techniques show impacts that do not approach or exceed PSD or NAAQS standards, then no further refined modeling will be necessary." (APCA, CDH, NYEC, SOC, SRP) EPA Response EPA agrees that competent and experienced personnel are a requirement for modeling. EPA staff are highly trained in this area. A routine audit program to test the adequacy and improve State modeling programs has been implemented. EPA agrees with all of the suggested word changes and has included them in the final text of the guideline. 2-1 ------- 3.0 RECOMMENDED AIR QUALITY MODELS Comment Summary (General) Several commenters recommended specific wording changes in Chapter 3. Those suggested changes are listed below. 1. Page 3-4, lines 5 to 7--The text should be revised to read "Models found to be clearly superior based on an evaluation using che same data bases as used to evaluate the preferred models will be proposed for inclusion as preferred models in future guideline revisions." 2. Page 3-4, add--"The modeler/meteorologist exercising the preferred model should state the degree of accuracy and precision that is expected in the given application, using standard statistical terminology. Such state- ment will provide the regulatory decision-maker with a more meaningful basis for his decisions." 3. Page 3-7—Use the term "at least as accurate as" wherever the term "equivalent" appears. The term then becomes self explanatory. Suggest delet- ing the third paragraph entirely and substituting "more accurate performance" for the term "superior performance" in last paragraph. 4. Page 3-8--Change 3a to read: "Performance evaluations of the model in similar circumstances have shown that the model is no less accurate or precise, or." Change "superior" to "more accurate and precise" whenever it appears in 3b. 5. Chapter 3--The Interim Procedures should not be cited if they have not been peer reviewed. (APCA, IPL, SRP, SOC) EPA Response 1. This change will be adopted. 2. The thrust of these words is already included at the end of Chapter 10. No change will be made. 3 and 4. The suggestions to substitute "at least as accurate as" for "equivalent" and "no less accurate" for "not biased toward underestimates" indicate that the commenters have misunderstood the intent of these statements (as discussed under comments in Section 3.2 dealing with "Equivalency and Alternative Models"). No action will be taken. However, in Chapter 3 the words "performs better than" will be used in lieu of either "more accurate" or 3-1 ------- "superior" to maintain consistency with terminology in the Interim Procedures for Evaluating Air Quality Models (Revised.)4 5. The Interim Procedures document has been subjected to EPA's review requirements and published as an EPA report. It will continue to be cited. 3.1 Preferred Modeling Tecnniques Comment Summary (Basis for Model Selection) Several commenters requested supplemental information on the basis for selecting models (identified in Appendix A of the guideline) as preferred for specific regulatory applications. The basis for selecting these models over others is not evident, especially since there is no clearly superior model for some applications. Also, the evaluations are not sufficiently extensive, nor are any of the models accurate enough to justify using some models as the basis for judging others. Further evaluations of rural and urban models were requested due to limitations of the previous studies; in particular it was suggested that selected factors be further evaluated, especially the Me Elroy-Pooler dispersion coefficients which were based on data from the same location as the urban evaluation. Additional documentation concerning the previous studies was also requested. One commenter stated that numerous procedural changes in the guideline which significantly affect predicted concentrations have been neither supported on a technical basis nor peer reviewed concerning model accuracy. (APCA, CMA, DS, IPL, ODEQ, SUC) EPA Response EPA agrees that there is no clearly superior model for the various categories in which preferred models are identified. The models listed in Appendix A were selected because (1) they are at least as accurate as other available models; (2) in at least one case, a unique approach to specific analysis problems is provided (e.g., ISC for industrial complexes); (3) they have been widely used for regulatory applications in the past (similar models identified in Appendix B have been used for a much narrower set of applications); (4) they form the current basis for control regulations for many sources in many parts of the country and their selection results in a minimum disruption of those regulatory programs; (5) they have been widely released through 3-2 ------- UNAMAP? or through other means by government agencies and are readily available at nominal cost; and (6) their wide use and current basis for regulatory programs have resulted in high public familiarity with these models. The reader should note, as indicated previously (under comments in Section 1.0 dealing with "Model Accuracy and Consistency") that where consistent techniques can be used within the context of obtaining the most accurate estimates, they are encouraged by the CAA and by various governmental and industry parties. The thrust of EPA's evaluations has not been to judge other models, but to establish the relative accuracy of models, one to the other. As a result, the models recommended by EPA have been found to be at least as accurate as, if not better than, other available models. They thus form a sound basis for a regulatory air quality program. Where the equivalency of models is at issue (as discussed under comments in Section 3.2 dealing with "Equivalency"), a test is implemented to determine if the models provide the same concentration estimates. If the estimates are not the same, then a mechanism to determine the best model has been provided.4 While more extensive evaluations of all models are desirable, the best data bases available at the time have been used to evaluate the EPA preferred models. In all cases the data bases were selected in coordination with the Steering Committee of the AMS/EPA Cooperative Agreement. Documentation of the evaluations and of the peer scientific reviews were extensive and have been widely distributed; no further documentation is appropriate or plannedS-13. These detailed analyses have tended to affirm the relative accuracy of EPA modelsJ4,15 Furthermore, other data bases^6^7 have tended to support the findings of EPA's evaluations. Those model evaluations prior to 1982 for all models in Appendices A and B that were documented by the developers have been summarized in an EPA report.18 Nevertheless, EPA plans further 3-3 ------- evaluations, especially for rural, urban, and complex terrain models as time and resources allow. However, the further evaluation of urban models suggested by one commenter must wait for another data base such as the EPRI-sponsored Indianapolis field experiment.^ All models were operated for the urban evaluation as specified by the developers and any further adjustment and evaluation for the same data-base would constitute "tuning" a model for that data base. Also, it should be noted that the McElroy-Pooler coefficients were developed for the same city, but not for the data base used in the evaluation; thus, the "tuning" implied by the commenter does not exist. Contrary to one commenter1s statement, the procedural model changes that are proposed (e.g. wind speed profile exponents) have a technical basis and have been reviewed for accuracy. In most cases those changes were proposed or reviewed by EPA's Office of Research and Development and were subjected and supported by comments at public hearings held in 1980. The technical basis, regulatory impact, sensitivity and accuracy of the proposed changes were thoroughly documented and made available in Docket A-80-46 as part of information publically released prior to the 1985 public hearing (appendices to Summary of Comments and Responses) J In most cases, the sensitivity analyses and accuracy assessments showed little change from current practice. Where a more extensive change does occur, public comments are being assessed and are discussed elsewhere in this document. Comment Summary (Texas Models) Several commenters argued that the Texas Models (TEM-8A and TCM-2) should be retained in the guideline as preferred models. These models are viewed as meeting EPA's criteria for selection, are economical to run and have not been shown to be inferior to other models. Concern was also expressed that failure to include these as preferred models would have an adverse effect on the consistency of PSD permitting analyses where the Texas Models are currently used. Other commenters variously suggested (1) that an option to 3-4 ------- use these models should be granted; (2) that they are adequate for pre-permit review in "flat terrain" States, and (3) that these models were not treated properly in the urban model evaluation. (APCA, ARCO, CC, DS, EPNG, TACB) EPA Response EPA carefully considered the Texas Models as discussed on page 110 of the Summary of Comments and ResponsesJ The models were evaluated in a manner consistent with similar models and were subjected to peer scientific reviews. No substantive difference was found between TCM and other similar models for annual average urban applications. However, even though reviewers found it difficult to distinguish among the models evaluated, some differences were apparent for TEM. For short-term urban applications TEM had a notably greater bias towards overestimating observed concentrations than did RAM. For rural applications, TEM tended to underestimate 24-hour S02 concentrations for which the NAAQS apply; CRSTER and MPTER were relatively unbiased. While the Texas models have been widely used in the State of Texas, they have not been used extensively to set emission limits for sources in other parts of the country. Thus, even though these models may satisfy criteria such as public familiarity, cost, and availability, they would change the basis for regulation in most parts of the country; such a change could not be justified given their statis- tical performance relative to those models currently recommended in Appendix A. The fact that the Texas Models are included in Appendix B, rather than with the preferred models in Appendix A, should have no impact on consistency of PSD permitting analyses in the State of Texas. EPA has met with Texas State representatives and indicated that there is no intention to preclude the use of these models in that regulatory program. These models will be 3-5 ------- tested by the State of Texas using an agreed upon protocol, and their use will be allowed in -that state if these models can satisfy the demonstration requirements. In the interim, these models may continue to be used there because of long use and historical precedent. The issue concerning the urban model evaluation is discussed in this section under comments dealing with "Basis for Model Selection." Comment Summary (Implementation of New Models) Several commenters indicated that criteria EPA will use to replace a preferred model with a new model are not clear. EPA was urged to make pro- visions in the guideline for use of new models, for improvements to existing models, and for models that are otherwise more appropriate in specific cases. The proposed list of preferred models should not remain static. Also the criteria to include other models should not be so heavily weighted in favor of the current models that new models are faced with an undue burden to prove superiority, or that state-of-the-art advances are inhibited. One commenter suggested criteria that should be considered when deciding the superiority of a new model, including: (1) performance measures that are more concise and emphasize the ratio of predicted to observed values and the mean square error; (2) comparisons at the upper end of the concentration frequency distribution that are unpaired in space or time; and (3) a limit of one or two data sets for sites typical of those to which the model is to be applied. This last commenter also indicated that, for the above three criteria, if another model performs as well or better than a preferred model listed in Appendix A, then that model should also be given guideline status. (API, EPNG, MSUS, SOC, UARG). EPA Response The guideline generally states that, in addition to the six items listed in the Federal Register (45 FR 20157),6 new models will also be subjected (1) to a performance evaluation which includes the data base(s) used in the original EPA evaluation and (2) to a peer scientific review. Models found to perform better for general applications will be proposed 3-6 ------- for recognition as a preferred model. The three criteria suggested by one commenter are a viable starting point and are generally consistent with criteria that EPA has considered in past analyses. However, they cannot be used as the sole criteria; the soundness of the scientific principles in models must be left to the judgment of peer reviewers. Since the scientific community has not yet identified performance standards for models, the Steering Committee for the AMS/EPA Cooperative Agreement has been asked to identify factors that should be considered in establishing improved model performance. It is not possible to be more specific about the criteria that will be used to replace a preferred model. In fact, it may take several experiences with new models before a specific formal procedure can evolve. One example of why the development of this process must proceed with care is the PPSP model (listed in Appendix B of the guideline). This model implements many of the improvements suggested by the peer review of rural models.H However, when tested against the Clifty Creek data base,8 the model systematically overestimated the highest concentrations. This clearly illustrates the fallacy of any assumption that a new model with "a more credible scientific basis" is necessarily a more accurate model. EPA has made provisions in the guideline for adding new and improved models. EPA encourages the use of these provisions and does not intend to place an undue burden on new models or delay state-of-the-art advances that are appropriate for implementation. Provisions include (1) use of models for case-specific applications following procedures outlined in Interim Procedures for Evaluating Air Quality Models (Revised),4 and (2) addition of new models based on the general criteria identified above. The criteria are int.ended to provide an even-handed technical assessment of models so as 3-7 ------- to select that which is most appropriate for the applications considered. As stated in the guideline, it is not intended that the currently preferred models are to be permanently used to the exclusion of others. The most accurate estimates are always sought. Thus, where a new or improved model is found to be better than a preferred model through the evaluation and review process, it will be used to replace the preferred model or to fill a niche not covered by the preferred models. However, including models just because they are found to be "as good as" a preferred model, adds neither to the accuracy of the estimates nor to the uniformity fostered by the CM and can only lead to regulatory confusion. 3.2 Use of Alternative Models Comment Summary (Equivalency) Several commenters addressed the issue of "equivalency" between air quality models. The comments fell into three general categories. First, several commenters said that equivalency of 2% (difference between proposed and preferred models) was too stringent and that this criteria is not even satisfied by models in Appendix A. Alternative measures of equivalency were suggested including those between 5% and 50%, those with statistical tests, and those based on a wider set of temporal and spatial concentration comparisons. Second, other commenters implied that the concept of equivalency was invalid for determining the acceptability of a model and tended to preclude the use of improved or alternative models. Third, three commenters indicated that because of the inaccuracy of models and data bases, agreement within 2% was within the "noise level" of estimates provided by models and was therefore meaningless. (APCA, API, CC, CITG, DS, IEPA, MSUS, NYEC, OEPA, SOC) EPA Response As stated on page 60 of the Summary of Comments and Responses, EPA has never required numerical agreement as a prerequisite to using a nonguideline model. In dealing with an alternative nonguideline model, EPA is proposing that a showing be made that the alternate performs better than the recommended 3-8 ------- model. This is a procedure not unlike that suggested by the American Meteorological Society in the Woods Hole Workshop Report.20 However, in response to requests from developers, EPA proposed criteria to identify equivalent models, or models so nearly identical to those that are preferred that they can be treated for practical purposes, as recommended models. It is from this latter proposal which is not a requirement, but is meant to be a reasonable response to requests from model developers, that much confusion about "equivalent" models and "numerical agreement" has resulted. Neverthe- less, three model developers successfully showed that when specific options in their models are used, essentially identical estimates to those from recom- mended models in UNAMAP (Version 5) can be achieved. Equivalence to recommended models in UNAMAP (Version 6) will now be necessary, however. To show that models are equivalent, or their estimates are nearly identical , fairly stringent criteria are necessary. Since the individual algorithms in most air quality models are well known and reproducible with high precision, differences greater than 10% are certainly significant. The preferred models in Appendix A, where a comparison is appropriate, are equivalent to each other; minor discrepancies have been reconciled for this promulgation. Also, the comments about use of statistical tests and the use of a wider set of concen- tration comparisons have merit. The way in which these criteria would be used, though, was not made clear by the commenters. These additional criteria would also make it more difficult to show equivalency, and would increase the likeli- hood (as suggested by other commenters) that a minor artifact in the way the models operate would preclude a demonstration of equivalency to each other. Therefore, EPA will continue to use the maximum and the highest, second-highest concentrations as a sufficient demonstration of equivalency. Similarly, since no commenter directly refuted the basis for the 2% equivalency criteria, nor 3-9 ------- provided any data for an alternative, the 2% criteria will be maintained. If in a special case the 2% criteria is found to be unreasonable, it will be reassessed on a case-specific basis. The commenters who are concerned that 2% is within the "noise level" of model estimates are correct. However, thay have failed to recognize (1) the regulatory need for a single, consistent modeling technique (as discussed under comments in Section 1.0 dealing with "Model Consistency vs Accuracy"), and (2) that equivalency as used here does not preclude the use of better models. Thus, the need to be able to distinguish between models, or vice versa, to identify models that provide essentially identical estimates, remains and is discussed below. Comment Summary (Alternative Models) A number of commenters addressed the circumstances and criteria under which alternatives to the preferred models may be used. In several cases these comments overlap the issues of consistency and equivalency which are addressed elsewhere. In general the commenters felt that Section 3.2.2 concerning alternative models is too restrictive, burdensome, and incomplete. As long as an alternative model uses the same basic theories as a preferred model, a statistical performance evaluation or an equivalency test are unnecessary given the inherent inaccuracies of the preferred models; not all the preferred models have been subjected to such an elaborate evaluation. This function should be decentralized to the Regional Offices. One commenter suggested that the burden of the equivalency test could be lessened if the equivalent models and the appropriate options were listed by EPA; also EPA was urged to allow simple changes to models without a full equivalency demonstration provided the change did not affect the concentration algorithms. Other commenters recommended that (1) an applicant be allowed to demonstrate the superiority of alternative models following the procedures on page 3-8 of the guideline (2) guidance be given on how physical modeling can be used to evaluate mathematical models, and (3) where a preferred model does not exist, no requirement for conservative estimates should be imposed. (ADEM, AMC, APCA, EPNG, MSUS, SOC, UARG, WDNR) EPA Response The purpose of Section 3.2.2 is to provide an objective and technically sound means for determining the acceptability of an alternative model for a 3-10 ------- regulatory application. Selection of the best technique is always encouraged. However, demonstrating that an alternative model is both appropriate and performs better than other models is a substantial undertaking requiring major investment of time and resources. That is why options are provided for demonstrating (1) equivalency to a-preferred model (as discussed under comments in this section dealing with "Equivalency"), (2) performance better than a preferred model, or (3) a reasonable level of performance where no preferred model exists. The basis for these demonstrations is the Interim Procedures for Evaluating Air Models (Revised) which basically follows recommendations of the American Meteorological Society.20 Given the need for consistency in the models used and the original basis for selection of the preferred models, which is discussed elsewhere, no further options seem available. Thus, the requirements of Section 3.2.2 appear to be technically sound; within the limit of other requirements, they are not restrictive, burdensome, or incomplete. The Interim Procedures document^ provides a complete basis for documenting the superiority of a given model and its use is encouraged. Development of protocols to identify procedures and statistical tests is a major component of this documentation. The use of protocols is encouraged; experience gained from past use of such protocols has been summarized .21 The thrust of the demonstration procedure is to encourage first-hand communications between the source and the State or EPA Regional Office; the role of the Model Clearing- house is one of general guidance and review. The Interim Procedures document is appropriate whenever there are differences between models that affect the concentration estimates. Just because models use the same general theories similar concentration estimates are not insured (as discussed in Section 1.0 under comments dealing with "Model Consistency vs Accuracy"), and the need 3-11 ------- for a statistical evaluation to determine the more accurate model is not eliminated. Where on-site data bases are not available, off-site data may be considered on a case-specific basis, under limited circumstances documented in the Interim Procedures. Finally, it should be noted that all models included as preferred models have been subjected to evaluations comparable in detail to those suggested in the Interim Procedures, if not by the "letter" of that document. Non-EPA models that met the equivalency test based on comparison of results from recommended models in UNAMAP (Version 5) are MPSDM, PLUMES, and SCSTER. Contrary to the implications of one commenter, a successful demonstration of equivalency for COMPTER has not been completed, although the developer has been given that opportunity by EPA. Since EPA does not control future changes to these models which must maintain equivalence with improvements in EPA's recommended models and more models may meet the test at a later time, the list of equivalent models and options suggested by one commenter would quickly become dated. However, EPA Regional Offices are kept informed about models that have been shown to be equivalent. Further, it is the responsibility of the Regional Office to determine those tests that are required for minor input and output changes. Frequently a full equivalency test will not be necessary but, even if required, the tests are rudimentary and normally require no more than 10 simple model runs encompassing a variety of source and climatic conditions. Guidance on the use of fluid" modeling techniques is available.22-24 However, the technical community has little experience with use of such techniques to evaluate mathematical models. Thus, any formal guidance on how physical modeling can be used to evaluate mathematical models is premature. 3-12 ------- The requirement that an alternative model is not biased toward underestimates, particularly where there is no preferred model, is necessary to ensure that the NAAQS are met. This is not meant to require that a grossly conservative model be used in lieu of one that is much less biased and slightly underestimates design concentrations. However, compensation for the underestimates must be provided; some means for doing this nave evolved with applications of the Interim Procedures and are documented in a supplement21 to that report. 3.3 Availability of Supplementary Modeling Guidance Comment Summary (Model Clearinghouse) Several commenters specifically endorsed the concept of a modeling center or clearinghouse and urged that it include a formal advisory group that arbi- trates modeling disputes. One commenter recommended that the clearinghouse should provide guidelines and technical assistance and relegate final decisions to EPA Regional Offices. Finally, a commenter felt that States should be free to make minor deviations from the guidance where technically appropriate and to consult EPA in complex situations. (ADEM, ADHS, APCA, CMA) EPA Response Jointly between the Model Clearinghouse of the Office of Air Quality Plannng and Standards and the User's Network for Applied Modeling of Air Pol- lution (UNAMAP) managed by the Office of Research and Development, the func- tions of a clearinghouse for models are satisfied. The formal role of EPA's Model Clearinghouse is to ensure consistency and technical adequacy of specific modeling analysis. UNAMAP provides codes, user's guides and servicing for a wide variety of air quality model applications. However, the Regional Administrator is responsible for approval of any modeling technique used. State deviations from the guideline concerning use of models for SIPs and PSD are generally reviewed and approved by the EPA Regional Office; if the 3-13 ------- deviation is significant, a review by the Clearinghouse for conformance with modeling policy may be requested. The Model Clearinghouse is always available for consultation on complex issues. Also, refer to pages 79 and 80 of the Summary of Comments and Responses.1 Regulatory requirements for advisory groups tena to be burdensome for both regulatory agencies ana the regulated industry. Although EPA has • previously established advisory groups (SAB, CASAC, etc.), they are intended to meet broad regulatory needs. Detailed administrative requirements must be met in establishing such groups and the resource requirements to maintain them are extensive. The time lost in using an advisory group to arbitrate modeling disputes could result in undue delays in the decision-making process and subsequent major costs to industry. Given resolution of a dispute by such a group, the courts would be open for further argument if one of the parties were not willing to accept the advisory group findings. For these reasons, the formal use of advisory groups seems to be neither appropriate nor practical in this instance. Nevertheless, EPA recognizes the need for review by the scientific community and has entered into a cooperative agreement with the American Meteorological Society (AMS). Although a formal advisory procedure is not used, the AMS through this agreement provides review and comment on the scientific basis for the models, procedures and data bases required in regula- tory processes. An example of the advisory aspects of the agreement are found in the AMS publication entitled "Air Quality Modeling and the Clean Air Act: Recommendations to EPA on Dispersion Modeling for Regulatory Applica- tions. "25 EPA has subsequently initiated programs to implement many of these recommendations. In conclusion, it appears that many of the positive 3-14 ------- contributions that a formal advisory group could make are being satisfied through the AMS/EPA cooperative agreement, without introducing the liabili- ties that can accompany such groups. Comment Summary (Regional Meteorologists Workshops) Several coimnenters argued that any changes in modeling policy or "clarifications" resulting from the Regional Workshops on air quality model- ing should be subjected to public comment and rulemaking before being implemented. Otherwise, such workshops should be made open to the public. Others urged State participation and conducting workshops within individual Regions. Several suggested that a periodic newsletter should be published releasing new information from the Workshops, Model Clearinghouse and the Conference on Air Quality Modeling. Finally, one commenter expressed concern about the impact of guideline revisions on previous decisions. (APCA, CMA, FDER, KC, KOCH, MCC, MSUS, ODEQ, SOC, TVA, UARG, WC) EPA Response As stated in the modeling guideline, all changes to that guidance will follow a formal rulemaking process. Prior regulatory decisions are normally "grandfathered" and should not be affected by such changes or additions. The purpose of the Regional Workshops is to ensure that guidance is properly interpreted and applied. If as a result of such a workshop, model- ing guidance and techniques are added or changed, these will be reflected in the guideline and the rulemaking process will be followed as the commenters suggested. However, if the result is to clarify procedures or make helpful instructions, standard means of communication within EPA and with the States, including appropriate policy memoranda, will be used. To improve these communications, active participation by State representatives in these workshops has been initiated, and is encouraged. Pre- or post-workshops at the Regional/State level are also encouraged. 3-15 ------- To allow an efficient working atmosphere for these gatherings, they are limited to EPA and State representatives who have a primary responsibility for air quality impact assessments relating to SIPs and PSD. However, every effort will be made to disseminate information of public interest as quickly as possible. Due to resource limitations, EPA does not have any immediate plans for a modeling newsletter. As a minimum, distribution of information will continue to be through NTIS, Federal Register notices, Docket A-80-46, and early communications between the source and EPA/State authorities; these latter com- munications are specifically encouraged in the guideline. All modeling guidance and supporting information (including proceedings of all the Conferences on Air Quality Modeling) have been made publically available through these mechanisms. 3-16 ------- 4.0 SIMPLE-TERRAIN STATIONARY-SOURCE MODELS Comment Summary (Consistency Among Preferred Models) One commenter suggested that EPA make certain model features consistent in all preferred models. The commenter stated that in CRSTER, the calculated effective stack height is reduced, by an amount equal to the elevation of each receptor point above the stack base, before being compared to the mixing height at that point. As a result, if a receptor is elevated sufficiently, a plume that originally rose aoove the mixing height can be artificially reintroduced into the mixed layer. A physically impossible result often is the calculation of very high concentrations at the elevated receptor, but no concentrations at all at another nearby receptor that might be only a few meters lower. This problem does not exist in MPTER. (MES) EPA Response To foster consistency in the preferred models, the treatment of mixing height in all EPA preferred models will be made to conform with MPTER and this modification will be available in UNAMAP Version 6. In fact, all preferred models with similar applications, as defined in Table 4.1 of the guideline, have been modified to be internally consistent and the equivalence established, as appropriate. Comment Summary (Differences Between Short- and Long-term Models) Many commenters indicated that different annual concentration estimates will result depending on whether long term or short term models are being used. In particular, the ISCLT and ISCST models were mentioned because of the cost savings in running ISCLT over ISCST. The difference in predicted concentrations is due to the data input requirements, i.e. short term models require hourly meteorological data while long term models can use joint fre- quencies. Comments varied, however, on this recommendation to EPA. Some suggested that ISCLT (and CDMQC) be used for predicting monthly, seasonal and annual average concentrations for complicated sources or urban areas, while another suggested that it is more productive from a labor and resources stand- point to allow for the option of using ISCST to obtain long term averages if ISCST was already used for short term analyses. (APCA, CDH, NDDH, WCHD, SOC) EPA Response EPA recognizes that the two different meteorological data input require- ments mentioned above will result in different concentrations. Each model was developed for a specific type of application. Table 4-1 indicates 4-1 ------- a preference for ISCLT for estimating long term concentrations, however the use of ISCST will be acceptable. Consequently, for long term applications the user should evaluate the capabilities of each model in relation to the problem at hand. If the modeler is interested in modeling complicated sources for a pollutant for which short-term standards (i.e., 3-nour or 24-hour) are applicable, ISCST'may be used for all averaging times. Con- versely, if the modeler is interested in such sources for a pollutant for which long-term standards alone are applicable (i.e., quarterly or annual), then ISCLT should be used. Comment Summary (Modifications to Preferred Models) Several commenters recommended modifications to the preferred models. One recommended that EPA implement a rural version of the CDMQC Model. Others recommended that EPA develop an urban version of BLP and develop a refined model for shoreline and offshore sources. One commenter recommended that ISC be modified to include urban dispersion coefficients. Another recommended that EPA add to ISC an algorithm which accurately simulates the behavior of buoyant emissions from roof monitors of industrial complexes. (APCA, JCPL, AISI). EPA Response EPA does not recommend using the COM model for rural applications; ISC is the preferred model for these aplications. EPA is not planning to develop an urban version of BLP because EPA did not develop the BLP model and it is the responsibility of the model developer to make this change. The BLP model developer has been advised of revisions to EPA's preferred models so that similar modifications might be made at the choosing of the developer; however, there has been no indication that a change is planned. EPA has conducted preliminary analyses of models for shoreline sources,26 but further work is necessary before a model can be recommended for regulatory applica- tions. A model dealing with offshore sources has been developed by the 4-2 ------- Department of the Interior, Minerals Management Services (50 £R 12248). This model, the Offshore and Coastal Dispersion Model, will be submitted by EPA under a supplemental notice of proposed rulemaking for public comment in 1986. The model is being considered for inclusion in the revised modeling guideline as a preferred model. (Please also refer to comments in Section 7.2.7 dealing with "Other Governmental Programs"). The ISC model is being modified to include the RAM model urban dispersion coefficients and is proposed in this guideline as a refined model for compli- cated sources in urban areas ( refer to Table 4-1). EPA has no plans to modifiy ISC to simulate buoyant emissions from roof monitors. For simulating buoyant emissions from aluminum reduction plants, or other similar applications, the BLP model is the preferred model. Comment Summary (Changes to List of Preferred Models) Several commenters suggested that EPA make changes to the list of preferred models and their organizational content. A couple of these suggested phasing out CRSTER; one suggested substituting for it with MPTER or ISCST and the other said that there is no good basis for recommending CRSTER. Another said that the MPTERU model should be a preferred model for urban applications and should give identical results to RAM when both models have the exact inputs. Another stated that more than one preferred model per category should be listed in Table 4-1. Another suggested that for preferred models, the limitations and proper applications should be clearly discussed in Chapter 4. (NYEC, NYCP, IPL, CARB). EPA Response The CRSTER model is less time consuming to set up and substantially less expensive to execute than the other two models mentioned. Therefore, phasing out CRSTER cannot be justified at the present time, since it provides concentration estimates equivalent to those from MPTER and ISCST for single point sources. Also, the MPTER model is being modified by EPA to incorporate urban dispersion coefficients. The urban option of MPTER gives results equivalent to RAM for point sources. 4-3 ------- Table 4-1 does list several EPA models that yield equivalent results when applied according to EPA recommendations (please also refer to comment responses in Section 3.2 dealing with "Equivalency"). EPA's recommendations on the proper applications of the preferred models is discussed throughout the guideline, including Appendix A where many of the details of the features of the recommended models are presented. Comment Summary (New Screening Models) A few commenters recommended that EPA modify existing screening models-. One recommended that the PTPLU and PTCITY screening models be modified to permit concentration predictions from multiple spatially separated sources and not only a source at a single location. EPA should recommend how to locate receptors and define worst case meteorology for these models. Another recommended that EPA modify PTPLU to give concentrations at user-input downwind distances and to run on a minicomputer. Another comment suggested that EPA modify the wind speed ranges for each stability class in PTPLU so they would be the same as those used in the refined models. One comment wanted a description of the PTCITY model included in the guideline. (APCA, FDER» IPL, NYEC). EPA Response An iterative application of these models, or a model such as MPTER, with a qualified individual looking at the output and designing a subsequent run if more information is required, is a better utilization of resources. Determining receptor locations and defining worst case meteorology requires judgement of a trained meteorologist, in consultation with the Regional Meteorologist, on a case-by-case basis. With respect to modifying PTPLU and PTCITY to give concentrations at user-input downwind distances, such a change is unnecessary since MPTER can be used easily for this purpose. 4-4 ------- As to the third comment, EPA plans to modify the wind speed ranges in PTPLU to correspond to those in refined models. The PTCITY model will be combined in PTPLU-2 and will be made available in UNAMAP Version 6. A description of screening models is generally not included in the guideline but is included in the UNAMAP model package. Comment Summary (Miscellaneous) There were a few other miscellaneous comments. One suggested that the guideline should either fully cover urban SIP modeling or reference documents that do. Another recommended retaining the option to use CDM/Larson's analysis techniques for determining 24-hour concentrations of TSP. Use of preferred models may not provide better results for short-term calculations of TSP. Another suggested that simple terrain be redefined to some specific level below stack top elevation. (ADHS, IEPA, APCA). EPA Response A discussion on urban SIP modeling is available in several places in the revised guideline. Case-by-case discussion of modeling concerns with the Regional Office regarding specific urban areas is encouraged. EPA disagrees that the CDM/Larson's analysis technique gives better results for short term modeling of TSP concentrations. Since the comment did not contain any validation data supporting its claim, there is no basis for modifying EPA's proposal. RAM has been evaluated and its performance documented. EPA defines simple terrain to be an area where terrain features are all lower in elevation than the top of the stack of the source. The com- menter did not provide any analysis indicating how simple terrain should be redefined. 4-5 ------- 5.0 MODEL USE IN COMPLEX TERRAIN Comment Summary (Model Development) Many commenters suggested that EPA place a high priority, accelerate its development efforts and recommend a refined complex terrain model based on current research and review of candidate models because there is an immediate need. Some of the commenters recommended that EPA routinely allow the use of alternative, more realistic complex terrain models on a case-by- case basis without validation as long as the source can demonstrate that the model theoretically simulates the physics of plume behavior in hilly terrain and the model is not biased towards underestimation. Another com- menter asked how an alternate model can be evaluated since no reference model is available for complex terrain. (API, TVA, NYEC, ADHS, EPNG, OEPA, PPL) EPA Response EPA appreciates the interest expressed in developing a suitable model for complex terrain applications, and has conducted over the last five years the Complex Terrain Model Development (CTDM) program.27,28 The goal of this EPA/ORD program is to develop reliable atmospheric dispersion models that are applicable to large pollutant sources located in complex terrain. EPA has explained earlier the complexity of the problem on page 41 of the Summary of Comments and Responses.1 As with other scientific endeavors, it is difficult to accelerate research. Completion of the research project is not expected before 1986. EPA encourages the use of better alternate complex terrain models subject to the requirements for consistency (please refer to comments in Section 1.0 dealing with "Model Consistency and Accuracy"). The use of a second or alternate model for technical evaluation when no reference model is available is fully described in Section 2.7 of the Interim Procedures.4 Comment Summary (RTDM) Numerous commenters, notably from the utility industry, recommended that EPA include the Rough Terrain Diffusion Model (RTDM) as a preferred model in Appendix A. Among the reasons cited by those recommending the model are that 5-1 ------- the model has general acceptance of the modeling community and that EPA's complex terrain model evaluation program has shown RTDM to have the best overall statistical performance of all complex terrain models considered. One comment stated that EPA should designate RTDM as either a screening tech- nique or a refined model; RTDM's superiority to VALLEY and Complex I should be recognized. EPA should allow use of RTDM in cases when VALLEY and COMPLEX I predict that there will be an air quality impact problem. (UARG, TVA, ERT, MSUS, TEGP, WC, PENE) EPA Response EPA has reviewed the performance evaluation of the RTDM model based on additional information submitted during the public comment process. EPA will issue a supplemental notice of proposed rulemaking that will seek public comment on including RTDM with specific default parameters as a third level screening model in the guideline. Full detail of the rationale for this action will be given in a Federal Register notice. Modifications to the text in the guideline will be proposed to reflect this change. RTDM can not be considered as a refined model because of its tendency to substantially underpredict concentrations as will be described in the above Federal Register notice. Comment Summary (Treatment for Receptor Height) Several commenters questioned the rationale for using a simple terrain model on those receptors below plume height in complex terrain. One asked how plume height should be established. If plume height is to be calculated on an hourly basis using the standard model algorithm, substantial effort would be required to address model selection on an hour-by-hour and receptor basis. Two commenters questioned this approach from the physical sense and stated that the atmospheric forces in complex terrain which cause increased dispersion should effect concentrations at receptors below plume height as well as above plume height. Recommendations to EPA included: (1) using an average (constant) stable plume height for the entire year; (2) using the complex terrain model only and specifically COMPLEX I which has been found to overpredict maximum concentrations and, therefore, is sufficiently con- servative; and (3) requiring the use of a simple terrain model with terrain cut off at stack top when the only receptors above stack top are large distances from the source being modeled. Three commenters addressed the issue of when to recommend complex terrain modeling. One recommended that complex terrain modeling should be required whenever a receptor is above the legally permitted stack height. Another said that complex terrain modeling should be performed when the receptor 5-2 ------- height is near the plume height. Another suggested that complex terrain models should be applied for receptors at elevations between stack height and plume height and that concentrations at all receptors above stack height should be used in determining maximum source impacts. One commenter recommended that a conservative estimate of the potential temperature gradient (e.g. 0.035°K/m for F stability) be used for calculating the critical streamline height. Plumes below this height should follow the VALLEY 10m plume/terrain approach, while for plumes above this height a refined modeling aoproacn should be used. (MES, CMA, APCA, NROC, CDH, NDDH, MMES, NYEC, ODEQ) EPA Response EPA has recommended the use of complex terrain screening models until research produces a refined model . Treatment of a situation where a receptor on terrain is higher than actual stack height is uncertain. Perhaps the present research activities will enable EPA to recommend a refined model (such as CTDM) for those cases. However, in the absence of such an answer, EPA recommends bracketing the highest concentrations by using both simple and complex terrain models for receptors between stack height and plume height. This technique would eliminate the need to determine the height of the plume on an hourly basis, but would yield the worst case impact. This method is accurate yet more simple than that proposed by the commenters. The recommendation to use an average stable plume height for the entire year is not supported by any data. The second recommendation to rely on COMPLEX I model results alone may result in underpredictions at receptors on terrain between stack height and effective plume height. This model has not been evaluated for receptors below stack height. The third recommendation to cut off terrain at "large distances" is ambiguous since that distance cannot be accurately defined. The definition of complex terrain, and thus when to use complex terrain modeling, has been earlier explained on page 34 of the Summary of Comments and 5-3 ------- Responses^ and is reflected in guidance contained in the guideline. The commenters do not present technical data to support any changes in the definition of complex terrain. An accurate calculation of the critical streamline height is one of the goals of the present research activities. When such a method is developed and adequately tested, it will be incorporated in cne refined complex terrain model. The conservative estimate of the potential temperature gradient suggested by one commenter for calculating the critical streamline height is incorporated in the version of RTDM under consideration as an additional screening technique. Comment Summary (Modifications to Screening Models) Several commenters suggested that EPA modify the screening models COMPLEX I and VALLEY to make them less conservative and easier to use. Two of these indicated that in the COMPLEX I model, the complex terrain option, IOPT(25) should not equal 1 in all circumstances because it overpredicts by a factor of 5. One of these two comments suggested only that EPA test COMPLEX I with IOPT(25) equal to 2 or 3. The other comment recommended that, until the CTDM model is available, IOPT(25) is set to 1 for true valley applications, i.e., impaction on a tall mountain range. If an isolated mountain exists, or if the maximum terrain elevation is near the effective stack height, then set IOPT(25) to 2 or 3, whichever produces the higher concentration. The comment further suggested that the Regional Meteorologist make the decision whether or not to use this procedure. One commenter suggested that the guideline should be reworded to state "for screening analyses using VALLEY or COMPLEX I, full ground reflection should always be used and a sector of 22 1/2° should be used unless represen- tative, valid, site specific data of adequate temporal resolution demonstrate that a broader or narrower sector is appropriate. Any such changes in sector width would not affect the status of these models as preferred models." Another comment recommended that EPA modify VALLEY to use NWS or on-site meteorology to determine the maximum number of consecutive hours in which the wind direction remains in a 22 1/2° sector with Class F stability and use this maximum number of hours rather than 6 hours. One commenter stated that the current form of the VALLEY model is difficult to use, easy to make mistakes with and should be modified. Receptors should not be restricted to the unusual grid with its scaling factor. Meteorological input should be hourly data for short-term estimates instead of a frequency distribution and have a set of default inputs for the 24-hour estimates. 5-4 ------- Furthermore, the assumption of a level plume (at constant elevation) and sector averaging should apply to all stability categories. Another comment suggested that the impingement treatment in VALLEY and COMPLEX I is only applicable where steep terrain is inbedded in a uniform vertical temperature structure. The use of these models, the comment stated, should be limited to instances where these conditions are confirmed. (KC, MMES, APCA, ADHS, NCNR). EPA Response EPA has recommended the use of the VALLEY and COMPLEX I models only as screening techniques to determine concentrations from the impact of plumes on hillsides. Setting the complex terrain option IOPT(2b) at 1 yields this desired goal. On the other hand, option 3 assumes no "reflection" from the ground (the estimates are half of those obtained from a standard application of the Gaussian model algorithm). Also, neither option 2 nor 3 are physically realistic and the commenter has not provided data to support this recommenda- tion. Any changes to these models that will result in a decrease in the conservativeness alone cannot be allowed as a substitute to developing an accurate or refined model. As stated in the guideline, the present state of knowledge on the interaction of plumes with complex terrain needs much improvement, and thus there is no basis to support using options 2 and 3. Furthermore, the commenters did not present any new data to support their recommendations. Use of refined models, when developed, should remove the concern for conservativeness that is present in the screening models. The suggested word changes are consistent with the current content of Section 5.2.1.4, with one major exception. The change implies that disper- sion rates in the models can be changed without demonstrating the soundness of this change following the Interim Procedures. Since this is inconsistent with Section 3.2.2 of the guideline (as discussed in this document under comments in Section 3.2 dealing with "Alternative Models"), no action will 5-5 ------- be taken on the word change. Furthermore, there is no need to modify the VALLEY model as the second commenter has suggested because if on-site data are available, they may be used in COMPLEX I. Also, if on-site data are available, they can be used to specify a different worst case assumption than that assumed in VALLEY. EPA will modify COMPLEX I to include an option equivalent to VALLEY. This would eliminate the commenter's concern with the receptor grid and scaling factors. It is already possible to input hourly meteorological data in COMPLEX I and no further change there is required. EPA does not agree with the comment that VALLEY and COMPLEX I should be limited to steep terrain and has provided its recommendation on the use of these models in the guideline. The commenter did not provide any data to support this claim or refute the EPA position. The issues of level plumes and impingement are the subject of EPA's research program, and no changes will be made until that program is completed. Comment Summary (Guidance on Screening Models) Several commenters indicated the need for further guidance when using COMPLEX I and VALLEY screening models. One suggested that COMPLEX I should be slightly modified by EPA to replace VALLEY as the primary screening technique. The user could input the same meteorological assumptions as the VALLEY model, use a 0.25 multiplication factor to convert 1-hour to 24-hour concentrations and use a wind speed independent of height for F-stability. Another commenter suggested that both VALLEY and COMPLEX I should be replaced by SHORTZ. Another said that if only a few receptor points around a source are above stack height, and preliminary screening indicates that they are not likely to be critical receptors, consideration should be given to "chopping-off" the receptors at the stack height and evaluating the source with a refined simple-terrain model. One commenter recommended that if the VALLEY model indicates a violation, a second level screening must be mandated instead of "may be used" as is now recommended by EPA. Two commenters thought that the guidance on page 5-4, paragraph 4 which discusses the use of receptor grids for VALLEY modeling is confusing. One very often cannot tell whether a receptor lies above or below the plume 5-6 ------- centerline height. One will not know whether the worst-case receptor was missed unless modeling with greater resolution, both vertically and horizon- tally is performed. A couple of commenters suggested there is a lack of guidance when model- ing for unstable or neutral periods in a second-level screening analysis. They noted that the discussion in Section 5.2.1 references stable conditions only. When COMPLEX I (or SHORTZ) is utilized, computations will include neutral and unstable periods when long-term averages are computed. One commenter requested the use of the complex terrain algorithm in the BLP model as an alternate screening technique to VALLEY and COMPLEX I when treating emissions from aluminum plants which emit pollutants from short stacks and roof vents atop short buildings. Another commenter asked EPA to recommend a complex terrain modeling technique for industrial sources subject to building downwash in rural areas because the recommended screening models do not incorporate building downwash algorithms. Furthermore, COMPLEX I cannot treat area sources, such as fugitive emissions, and VALLEY is not recommended for seasonal or long-term applications. The comment proceeded to recommend that modest terrain be ignored and that ISCST and ISCLT be considered because the down- wash algorithm mixes the plume rapidly so that concentrations are not likely to be higher on elevated terrain than they are at flat terrain receptors. In severe terrain, the comment recommended using the long-term version of VALLEY. (MES, NCNR, NDDH, MMES, MCC) EPA Response EPA recommends using the COMPLEX I model as a second-level screening technique when hourly on-site meteorological data are available. COMPLEX I uses VALLEY as its basic algorithm but incorporates a half-height correction for unstable plumes, adjusts wind speed with height and uses hourly wind data as input. EPA plans to modify COMPLEX I as suggested by the commenter. How- ever, replacement of VALLEY and COMPLEX I with SHORTZ is unwarranted at this time since the SHORTZ model is a second-level screening technique for urban areas where there are multiple stack, building and area sources. Also this model did not perform better than COMPLEX I in the complex terrain evalua- tion.10 Because of the relative complexity of SHORTZ, EPA cannot justify denying the use of VALLEY when only a simple screening model is desired. 5-7 ------- The suggestion of "chopping-off" terrain if only a few receptors are above stack height is partially consistent with EPA's recommendations for receptors located between stack height and plume height. However, use of simple terrain models in complex terrain could result in predicting arbitrarily lower ground leva! concentrations. That is why EPA recommends applying both flat terrain and complex terrain models in cases when there are receptors above stack height and selecting the highest predicted concentrations. The fact that there are only a few receptors cannot mitigate this situation. There is no basis for making the word change regarding second level screening as the commenter suggests because other alternatives may be avail- able to the source without using a second level screening model. For example, the source may reduce emissions until the predicted violation is no longer present. Also, there may not be sufficient data available, such as one year of on-site data, to warrant using a second level screening model. A more conservative technique than that recommended is always an acceptable basis for determining emission limits. The location of receptors is established by first calculating final plume height and comparing it to receptor terrain height. A fixed polar grid may not include all the peaks in terrain and would need to be modified to include additional receptors if they are within 10 meters from the center- line of this final plume height. This problem will be mitigated by the planned modification to COMPLEX I to include an option equivalent to VALLEY. The discussion in the guideline has been limited to the stable condition because this condition is the most likely to yield the highest ground level concentrations for rural isolated sources. The formulations in the models will be revised as knowledge about the behavior of the atmosphere in complex 5-8 ------- terrain increases and will be reflected in recommendations concerning any refined model. For urban sources, guidance concerning neutral or unstable conditions can implicitly be found in second-level screening models. The complex terrain algorithm in the BLP model requires the use of terrain correction factors. According to EPA evaluations, the choice of terrain correction factors can have a significant effect on the estimated second-high short-term concentration and thus the allowable emission rate. Please refer to Appendix H of the Summary of Comments and Responses^ for a discussion of these evaluations. Because of this uncertainty, EPA does not recommend the BLP complex terrain algorithm for use, regardless of stability class. Due to lack of applicable technical information, EPA can not recommend a complex terrain modeling technique for industrial sources as the commenter suggests, but will accept a suitable model on a case-by-case basis. The definition of "modest terrain" is very subjective and the use of a simple terrain model could result in predicting arbitrarily low ground level concentrations. Where the highest concentrations are shown to be near stack base elevation in the wake, immediately downwind of a source complex, ISC may be used. However, the feasibility of routinely using ISC in lieu of COMPLEX I, as the last commenter suggested, can not be evaluated since the commenter did not provide any data to substantiate this claim, nor made reference to studies in scientific journals. Comment Summary (SHORTZ/LONGZ) Several commenters said that EPA has not justified specifying SHORTZ and LONGZ for urban complex terrain applications. Two commenters pointed out that the plume rise formulas and dispersion coefficient functions in SHORTZ and LONGZ are different from those used in other EPA preferred models for urban areas. Another commenter suggested that a few changes are warrented to 5-9 ------- enhance the utility of the models. One, it is desirable to install an option that would allow the user to produce an hourly file of concentrations that could be post-processed vi a a program such as CALMPRO to eliminate the effects of calm winds and to produce high-five tables for each averaging period. Two, an option is needed to select days to be included in the analysis, as is possible with other guideline models. Three, the SHORTZ/LONGZ meteorological data input formats should be modified to make them identical to those of all the other models so that the same pre-processed meteorological data sets can be used. (API, IPL, OEPA, APCA, SOC, AISI) EPA Response EPA recommends the SHORTZ/LONGZ model as a second level screening technique for urbanized complex terrain areas because it provides a more refined model than VALLEY; a better technique has not been submitted for evaluation. Thus, this model fills a special niche. Evaluation studies are cited in the SHORTZ/LONGZ user's manual. Although some of the options are different from similar options in other EPA models, the SHORTZ/LONGZ model has not been evaluated with these EPA options. Nor does EPA believe it appropriate to require a developer to change the options without such an evaluation. EPA agrees that the utility of these models would be enhanced if the commenter's suggestions were implemented. However, at the present time, the vast majority of EPA's resources in this area are being used to develop a refined model for complex terrain. If the commenters, or other interested parties, are interested in making the recommended changes, EPA will provide any technical guidance that may be necessary. Comment Summary (Miscellaneous) A couple of commenters indicated that paragraph 5 on page 5-4 of the guideline should be more specific about how meteorological data should be reviewed for spatial and temporal representativeness. A single site in complex terrain is seldom ever representative of general conditions. One commenter recommended that EPA provide additional guidance on the formulation and evaluation of hybrid models involving a combination of a wind field model and a diffusion model. (MFCS, NYEC, APCA) 5-10 ------- EPA Response EPA acknowledges that establishing spatial and temporal representativeness is difficult in a complex terrain setting and therefore has not issued any detailed guidance on how to determine representativeness. Consultation by experienced meteorologists with EPA Regional Offices is appropriate. Please refer to page 48 of the Summary of Comments and Responses^ for further dis- cussion on this position. EPA can not give any guidance on hybrid models involving a combination of a wind field model and a diffusion model because such modeling is still in the research phase. However, EPA does not want to preclude applications of this method on a case-by-case basis. 5-11 ------- 6.0 MODELS FOR OZONE, CARBON MONOXIDE AND NITROGEN DIOXIDE 6.1 Discussion Comment Summary (Reactive Pollutants) One commenter indicated that stationary sources need to be isolated from mobile and area sources before point source models referred to in Sections 4 and 5 of the guideline can be used. Two commenters suggested further guidance be given on selection of HO2 to NOX ratios from monitoring data for areawide urban modeling of N02- Another commenter stated that guidance is needed for estimating the ozone impact of rural VOC point sources on nearby nonattainment areas. (APCA, SOC, ADHS, CDH) EPA Response EPA does not agree that stationary sources need to be isolated from other sources before they can be treated as point sources. EPA intends that point source models as discussed in Sections 4 and 5 of the guideline are to be used for estimating the air quality impact of CO and NOX emissions from stationary sources in urban areas. This has been clarified in the revised guide- line. Section 6.2.3 provides additional guidance on how NOX concentrations are to be converted to N02 concentrations. EPA requirements regarding quality assurance procedures, site selection, and data capture should be adhered to in the measurement of annual average N02 concentrations. These are spelled out in 40 CFR Part 58. Since N02 is measured as the difference between NOX and NO, there are no special * requirements for N02 to NOX ratios beyond those for the measurement of N02« EPA recognizes the need for guidance regarding the potential impact of rural VOC point sources on urban ozone concentrations in nonattainment areas, as well as small urban areas on themselves. Reactive plume models have been developed which may serve as suitable analysis tools under some circumstances 6-1 ------- (refer to Appendix B of the guideline). Until such time as specific guidance is developed based upon an evaluation of available techniques, modeling techniques will be considered on a case-by-case basis. Any such techniques must consider the chemistry of the specific organic compounds emitted and the interaction between the point source plume and other sources of VOC and NOX emissions. 6.2.1 Models for Ozone Comment Summary (Urban Airshed Model) Several commenters requested justification for selection of the Urban Airshed Model as the preferred model. (APCA, SOC, OEPA) EPA Response The Urban Airshed Model is the most widely applied and evaluated photochemical dispersion model in existence. EPA believes the evaluation studies referenced in Appendix A of the guideline represent sufficient justification for the selection of the Urban Airshed model as the preferred model. Comment Summary (EKMA) One commenter suggested that EPA develop a modeling approach which accounts for year-to-year fluctuations in the meteorological potential for ozone formation so that such fluctations do not lead to changing control requi rements. Another commenter suggested that EPA modify EKMA to factor in or account for anomalous meteorological conditions such as unusually high temperature and that EPA consider procedures for predicting the probability of attain- ment using estimates of model uncertainty. One commenter noted the sensi- tivity of EKMA to certain input parameters and, in light of this, suggested that the reliability of EKMA needs to be investigated. Another commenter questioned the validity of applying EKMA except in urban areas dominated by motor vehicle emissions and suggested the use of PLMSTAR or RPM-II instead. One commenter indicated alternatives to EKMA for determining individual point source impacts are needed and mentioned PLMSTAR and RPM-II as possible models but suggested that simplified screening techniques need to be developed. (OKIG, API, ADEM, CARB, UARG) 6-2 ------- EPA Response EPA fully recognizes the influence of meteorological conditions on ozone concentrations and the effects that year-to-year meteorological variations might have on determining allowable emissions of hydrocarbons and nitrogen oxides. In this regard, EPA is examining possible means for explicitly treating meteorological, fluctuations relative to a more long-term climatolo- gical condition. Until this procedure is developed and evaluated, EPA continues to recommend the present approach used with EKMA in which three successive years are selected for modeling. This provides a base period with meteorological conditions that are broadly representative of several years. Thus, year-to-year fluctuations are considered implicitly and the dominance of any single year in determining control requirements is somewhat mitigated. EPA is considering modifications to EKMA which would more completely reflect the role of ambient temperature and additional phenomena. However, as described in Appendix A to the Guideline on Air Quality Models, the Urban Airshed Model (UAM) is a preferred model for cases where there is interest in modeling day-specific meteorological conditions in a more comprehesive manner. UAM is a data intensive model which treats day-specific meteorolo- gical conditions including wind speed, temperature, solar radiation, atmospheric stability, and mixing height. EPA will consider the methodologies suggested by the commenter for predicting the probability of attainment once decisions have been made on how such information might be used in the regulatory process. EPA agrees that EKMA can be sensitive to certain input parameters, and these have been identified in EPA guidance documents on the use of EKMA as 6-3 ------- cited in the Guideline on Air Quality Models (see for example "Guideline For Use of City-Specific EKMA in Preparing Ozone SIPs," EPA-450/4-80-027). These guidelines indicate those model inputs that should be measured and the inputs for which default values will suffice. These recommendations arose from evaluations conducted with EKMA as suggested by the commenter. EPA believes that EKMA is an acceptable approach in a variety of urban areas. Although the EKMA approach originally relied on a photochemical mechanism developed to characterize motor vehicle exhaust, EKMA can now be used with the most recent version of the Carbon-Bond Mechanism.29 This mechanism has been widely evaluated against smog chamber simulations of surrogate urban atmospheres and has been successfully employed in photochem- cal dispersion modeling of actual urban areas. PLMSTAR and RPM-II are point source models and as such are inappropriate by themselves for areawide urban ozone applications. For these applications, the Urban Airshed Model is preferred, although EKMA may also be used. EPA does not regard EKMA as an appropriate method for assessing ozone impacts from individual point sources and, therefore, EKMA is not an accept- able approach in this instance. EPA does not recommend a preferred model for VOC point sources at this time. As indicated in Appendix B of the guideline, there is no specific recommendation for the use of PLMSTAR or RPM-II. These models may be applied on a case-by-case basis. EPA acknowl- edges the need for screening techniques for estimating potential ozone impacts from VOC point sources. 6-4 ------- 6.2.2 Models for Carbon Monoxide Comment Summary (CO Line Source Models) Most commenters supported the use of CALINE3 as the preferred line source model. Two commenters suggested*approval of all future versions of CALINE. Two other commenters suggested that both CALINE3 and HIWAY-2 should be listed as preferred models. One commenter suggested that recommendations for CO modeling approaches be delayed until completion of EPA's current evaluation program and that program be limited to tracer data evaluations. One commenter suggested that the discussion of data needs for line source models on page 9-4 of the guideline be made more general to ensure that the data needs of the preferred model, CALINE3, match those mentioned. (WDNR, CDOT, FHA, NYCP, GMC) EPA Response Each revision of CALINE must be evaluated to determine the appropriateness of modifications before the model can be approved by EPA for general use. Automatic inclusion of revisions of CALINE without first evaluating the performance, technical adequacy, and effect of such revisions would not be responsible. For example, CALINE4 is more difficult to use than CALINE3 because it requires some inputs for which data is not routinely available, such as sigma theta. Thus, since the concentrations given by the two models differ very little, the use of CALINE3 is recommended. Although the differences between CALINE3 and HIWAY-2 in terms of theory, data needs, and results may not be substantial, CALINE3 is more widely used throughout the modeling community and has provided a broader basis for CO control strategies. Thus, because of its widespread use, CALINE3 is listed as the preferred model. Accuracy would not be increased by including models not found to be better and would only lead to "shopping" for the model which gives results closer to desired concentrations. An evaluation to test 6-5 ------- the relative performance of the CO models is underway and will be forwarded for peer scientific review. EPA's program for evaluation of mobile source CO models is intended to review specific applications of the techniques under investigation. The process of completing this review, making recommendations, and soliciting public comment will require more time. The Agency believes that sufficient information based on completed performance evaluations, past use and famili- arity exists at this time to support the recommendations made. In addition, EPA intends that the model evaluation program be a continuing process. However, there is a need to prescribe a recommended model at this time. Finally, EPA's current program for evaluation of mobile source impacts relies on data bases containing both carbon monoxide air quality data as well as appropriate tracer studies. The Agency recognizes the potential effect.of background interference and believes that the process of data selection in the model evaluation process ensures the proper use of such data and therefore believes that it is proper to include results from both types of analyses when evaluating the performance of such models. The data needs for line source models mentioned on page 9-4 of the guideline are general and match those required for CALINE3, with the excep- tion of pollutant emissions where the (grams per second per meter) will be dropped. Detailed information on data requirements for CALINE3 are intended to be obtained from the user's guide. Comment Summary (CO Model for Special Situations) Two commenters suggested that EPA specify the model or technique to use to evaluate occurrences when monitors have measured exceedances of the CO 8-hour ambient standard in the late night and early morning hours over a 6-6 ------- wide area. These exceedances are not related to specific "hot-spots." (FDER, ADHS). EPA Response EPA recognizes that these exceedances occur and is investigating suitable models to handle them. The most appropriate approach may involve use of urban area modeling requiring considerable resources and technical expertise. Guidance will be expanded at a future time as the information base on the best and most cost effective approaches evolve. If a suitable model is available for a specific application and the data and technical competence for its use are available, then such a model should be considered. Comment Summary (Techniques for Intersections) Several commenters suggested that the guideline specify a technique for modeling intersections. One commenter suggested the use of the Intersection Midblock model, while another recommended the use of the Texin model. (ADHS, FHA, NYDOT, NYEC, DOT). EPA Response EPA agrees with this comment and will revise the model guideline to indicate that Worksheet 2 of the "Guidelines for Air Quality Maintenance Planning and Analysis Volume 9 (Revised): Evaluating Indirect Sources" be used to determine modal (acceleration, deceleration, idling, and cruise) emission factors for input to the preferred dispersion model, CALINE3, when intersections are modeled. The Intersection Midblock Model is not recommended because it uses the outdated HIWAY dispersion model. TEXIN has a simplified version of MOBILE2 built into the model and can handle only simplified intersections. The version of MOBILE2 built into TEXIN does not allow the consideration of Inspection/Maintenance controls. In addition, the simplfied treatment of intersections does not allow the con- 6-7 ------- sideration of certain transportation control measures. Therefore, TEXIN is not recommended for regulatory analysis. 6.2.3 Models for Nitrogen Dioxide (Annual Average) Comment Summary (Stationary Source Models) One commenter requested additional guidance on the use of Appendix A models for N02« Another commenter recommended the ISCLT model. (APCA, HMES). EPA Response Additional guidance for selection of suitable Appendix A models for stationary sources is covered in Sections 4 and 5 of the guideline. These sections should be referred to in selecting a single source dispersion model for use with the three-tiered screening approach for point sources or a multiple source dispersion model for urban areas. The ISCLT model can be used for either a first or second level screening analysis for point sources in those situations for which it is recommended, as discussed in Section 4 of the guideline. Comment Summary (Ozone Limiting Method) One commenter requested additional guidance on the use of the Ozone Limiting Method. Another suggests that more refined techniques be recognized in the guideline as alternatives to the Ozone Limiting Method. Another com- menter questions the use of the Ozone Limiting Method for determining annual average concentrations from point sources. (APCA, EPNG, API, NYCP) EPA Response The Ozone Limiting Method is described in the reference cited in the guideline. EPA believes that more refined techniques have yet to be shown to be more suitable for point source applications.30 The commenter does not identify alternative techniques for EPA to evaluate. However, as stated in the guideline, more refined techniques may be used on a case-by-case basis. 6-8 ------- Comment Summary (N02 to NOX Ratios) One commenter requested guidance on the use of N02 to NOX ratios when future emission controls may alter the baseline ratios derived from ambient measurements. (APCA) EPA Response When future emission controls are expected to substantially alter N02 to NOX ratios on an annual basis, more refined modeling techniques can be considered on a case-by-case basis. As stated in the guideline, photo- chemical dispersion models may be applied in situations that require more refined techniques. 6-9 ------- 7.0 OTHER MODEL REQUIREMENTS 7.1 Discussion Comment Summary One commenter suggested that the guideline state or reference topics for which special regulatory program guidance documents have been prepared. If such documents have not been prepared, then some interim form of guidance should be provided in the guideline. (SOC) EPA Response Section 7 highlights several program areas important to modelers. It is not the purpose of this guideline to serve as a compendium of information because these programs are subject to change and references may become out- dated. Such changes and any new guidance are subject to public review and comment under the rules pertaining to the specific program. 7.1 .2 Fugitive Dust Comment Summary Many commenters recommended that EPA provide more guidance on fugitive dust emissions estimation and modeling procedures. One said that fugitive emissions should not be considered routinely, but only where the specific information is available and it is likely that such emissions could be mak- ing a significant air quality impact. Another said that since the release of fugitive emissions is unique to each plant, emission factors developed in a generic manner will not be representative. One submitted a couple of reports on fugitive emissions from utility sources and suggested that they be referenced in the guideline. Another suggested that EPA develop emission factors for the forest product industry. With respect to modeling, these commenters suggested that the upcoming PM-|Q modeling efforts will require a need for particle size distribution data, wind erosion rates, and fugitive modeling techniques that include multiple-hour transport and accumulation. One asked if naturally occurring dust sources should be modeled. Another stated that the discussion of fugi- tive dust should be separated from fugitive emissions because fugitive dust is different in terms of both physical and chemical properties. By inserting the second paragraph between the first and third, EPA has implied that ISC is recommended for modeling fugitive dust. This model should not be recom- mended for any modeling where deposition is important because the ISC treatment of deposition places a discontinuity in the Gaussian distribution at the surface, a fundamental error which has no theoretical or empirical 7-1 ------- basis, and prevents it from giving accurate predictions. Another said that for fugitive emissions from haul roads, the CALINE3 model should be recom- mended instead of ISC. One other comment suggested that EPA incorporate some methodology to treat pit retention in any model for mining operations. (APCA, TVA, ADHS, ADEM, UARG, AMC, BAAQ, MMES, DPC, WC, OEPA) EPA Response If actual source-specific emissions data are available, ^rtese data may * be used. However, if these data are unavailable, guidelines on characterizing fugitive dust emissions given in EPA's AP-42 pub!ication^l should be used. This recent Fourth Edition includes new fugitive emission factors for unpaved, paved urban and industrial paved roads (Sections 11.2.2, 11.2.5 and 11,2.6, respectively). When estimates of emissions for load handling operations are desired, AP-42 contains fugitive emission estimates based on studies conducted for EPA at twelve major coal fields in Western states. Since AP-42 is EPA's official vehicle to publish emission factors, users of AP-42 emission factors should make sure that the most recent updated factors available are being used. EPA has reviewed the submitted publications by utility sources but finds that since certain portions are not in accord with information in EPA publica- tions, they are not appropriate as references. Emission factors for the forest product industry are given in Chapters 10 and 11 of AP-42. EPA agrees that guidance is needed to model fugitive emissions from non-traditional sources. EPA has developed guidance on characterizing PM-JQ fugitive emissions from such sources.32*33 Until such guidance has been promulgated, it is inappropriate to provide further air quality dispersion modeling guidance. Naturally-occurring dust sources are a component of background and are estimated from monitored data representative of the site. Area source emissions are another component of background and are established from air quality modeling. 7-2 ------- The ISC model has been evaluated in terms of its deposition algorithm, against three deposition experiments.34 Results show that at least 80 per cent of the ISC model calculations were within a factor of. two of the experimental values. EPA agrees that there are several deposition algorithms available in the literature. Moreover, scientific understanding of the mechanisms involved in deposition is increasing. EPA plans to evaluate further the category of complex industrial source models over the next two years and will subsequently make recommendations concerning such models as the commenter recommended. EPA does not agree with commenter1s suggestions to reorganize the text. The ISC model may be used to model fugitive dust sources such as coal and ash storage piles as discussed in the user's manual for this model. EPA has not received any information demonstrating that CALINE3 performs better than ISC for haul roads. Thus, where haul roads are reasonably con- sidered part of an industrial complex, the ISC model is recommended for use. EPA is currently developing a methodology and model algorithm for treating pit retention of particles during mining operations.35,36 This effort is proceeding in cooperation with the National Coal Association. However, a suitable data base against which the algorithm can be tested has not yet developed. EPA will report its findings as this project proceeds. 7.2.2 Participate Matter Comment Summary One commenter suggested the use of chemical and physical analysis of particulate matter samples in addition to or in place of source receptor models while another recommended the use of receptor models. Two comments requested clarification as to whether the ISC model should be used in all urban modeling when particle settling and deposition are involved. (SOC, MMES, ODEQ, NYCP) 7-3 ------- EPA Response The use of chemical and physical analysis is not required for routine modeling applications but can be used on a case-by-case basis when special situations arise. The suitability of using receptor modeling is addressed in the responses to comments in Chapter 11; EPA encourages receptor modeling as an adjunct to dispersion modeling. The ISC model should generally be limited to analyses of industrial source complexes in either urban or rural areas. Although the model has not been evaluated in terms of its performance for an entire urban area, v/hen particle deposition and settling are involved, it employes standard algorithms applicable to urban areas. In conjunction with the PM]Q NAAQS program, EPA is developing a short term model for urban areas which.will treat dry deposition, sedimentation and first-order chemical transformations including aerosol formation. Performance evaluations are underway and the model should be available in late 1986. 7.2.3 Lead Comment Summary One commenter recommended that the text which states that CALINE3 is unable to account for particle deposition be changed because optional deposition and settling algorithms are, in fact, included. Another stated that lead can be accurately modeled using CALINE3 and APRAC-3 models with simple modifications. Another questioned the significance of using 4.0 yg/m^ as a cut-off value since the NAAQS for lead is a quarterly average of 1.5 yg/m3. One recommended that models for estimating ambient lead levels must be able to account for deposition and long term (three month) impacts. (DOT, MMES, OEPA, NYEC) EPA Response EPA agrees with the first comment and has corrected the text on page 7-5. However, CALINE3 and APRAC-3 have not been evaluated in terms of modeling 7-4 ------- quarterly lead concentrations from automobile sources along roadways. Until such evaluations are undertaken and reviewed, ISCLT is the recommended approach. EPA agrees that models for estimating ambient lead levels must be able to account for deposition and ISCLT does so. The 4.0 pg/m3 cut-off value is obtained from 40 CFR 51.83 which was subjected to prior public comment and rulemaking. (Also see 42 FR 63U87). 7.2.4 Visibility Comment Summary Three comments stated that the guideline should provide guidance on choosing the appropriate visibility models and input parameters (e.g., observer geometry, type of background, etc.) that give worst-case visual impacts. One of these coments recommended that the guideline outlined in 1980 (40 CFR 51.300-307) for modeling visibility should either be presented or mentioned in this section (ADHS, CDH, MMES). EPA Response The visibility regulations anticipate that the minimum requirements-for worst-case visual impacts are determined by analogy from visually observing sources of the same character as the proposed new sources. The state-of- the-art in visibility models at the time of regulatory development did not permit the Agency to require such analyses. States are, however, encouraged to use the results of visibility modeling analyses when available, but are not required to approve or disapprove a source permit on the basis of specific modeling results. It is not appropriate to list in Appendix A of the guideline any visibility models until such modeling is required by the regulations. However, when modeling is done, models listed in Appendix B may be used. EPA believes that visibility model inputs for worst case impacts are best determined on a case-by-case basis, especially given the 7-5 ------- variety of Class I areas and special concerns that Federal Land Managers may express. The text will be revised to include direct reference to the regulation. 7.2.5 GEP Stack Height Comment Summary (Stack Height Credit) One commenter recommended that EPA require downwash modeling if the stack height that a source claims for purposes of receiving credit is less than the GEP height. Another said it is unreasonable to require an analysis for stacks only marginally less than GEP height. A minimum value, such as H + L, should be established. One comment recommended that when simulating actual air quality (e.g., for model validation), the actual stack heights should be used; but when setting emission standards, GEP height should be employed. Another suggested that modeling existing point sources at GEP height precludes the validation of model results by use of ambient measure- ments, particularly in the case of tall stacks. The model should be verified for existing stack heights by use of actual monitoring data before it is used to model GEP stack height releases. One commented that if EPA is relying on the downwash algorithm to identify the need for additional control measures involving an existing stack, it should also be willing to accept the algorithm in lieu of a fluid model to justify a stack height increase. One commenter asked if the wakes due to nearby terrain obstacles should be considered in the building downwash analysis.(NRDC, FDER, MCC, MMES, OEPA) EPA Response Section 123 of the Clean Air Act, as well as 40 CFR 51 revised in July 1985, defines good engineering practice (GEP) stack height. Many of the comments presented above have been addressed in the Response to Comments document for that rulemaking and are available in Docket A-83-49. A brief response is given below. When the stack height of a source is below what EPA has set as GEP, downwash is suspected to occur and ambient standards or PSD increments may be violated. The modeling guideline requires downwash analysis for sources with stacks less than the height defined by EPA's refined formula for determining 7-6 ------- GEP heights. There is no rational basis to exclude stacks "marginally less than GEP height" as the commenter desires. For a more detailed explanation of all the requirements please refer to the Guideline for Determination of Good Engineering Practice Stack Height.23 EPA agrees that modeling existing point sources at GEP height may preclude the validation of model results by use of ambient measurements in the future; however, no model evaluations thus far have been conducted in this manner and EPA is working to develop strategies to address this problem. EPA requires the use of fluid modeling for sources who wish to receive a greater stack height credit that can be provided by the applicable formula. Control measures may be based on the results of the downwash algorithm if downwash is the controlling meteorological condition. Criteria for when wakes due to nearby terrain obstacles may be considered in the overall downwash analysis are given in the regulation and described in the Guideline for Determination of Good Engineering Practice Stack Height.23 The downwash algorithm in ISC assumes downwash does not occur for any stack that meets the height criterion. Wind tunnel results indicate that the excess concen- tration associated with not meeting that criterion may range from 20% to 80%. Since the GEP regulations specify 40%, only a wind tunnel demonstration can determine the stack height at which that criterion is satisfied. EPA is very concerned that credit for increasing stack height not be granted without a comprehensive demonstration. Comment Summary (Modify ISC Downwash Algorithm) Several comments suggested improvements to the ISC model algorithm for treating building downwash. A couple recommended that the building dimensions used in the model should be made directionally dependent, i.e., for each wind direction the model should be able to specify a different set of cross- wind building dimensions. Also, EPA should limit or reduce the extent of the downwash analysis for wind speeds less than some designated critical wind speed. Another stated that the ratios of stack height to building height 7-7 ------- often do not occur within the range for which the ISC downwash routine was developed and recommended that either downwash routine be modified or these stacks be exempt from downwash analysis. A couple of commenters stated that the downwash algorithm has not been properly validated and should not be required for use. One of these stated that recent measurements have demonstrated the performance error in the ISC downwash algorithm and that the new downwash algorithm in BLP model be recommended. One commenter recommended that more guidance should be provided OR what screening models to use for sources with less than GEP stacks located in complex terrain while another suggested that the detailed downwash screen- ing procedure contained in the "Regional Workshop on Air Quality Modeling" be included in the guideline. (APCA, TVA, ADEM, AISI, WC, AMC, CDH) EPA Response EPA agrees that using building dimensions in the ISC model that are dependent on the wind direction as the commenter suggests appears to be technically sound and plans to propose for public comment a modified version of ISC recently submitted to the Agency that contains this improvement. However, there is no technical justification for arbitrarily reducing the extent of downwash for any wind speed because downwash has been shown to occur in field studies with wind speeds as low as 1.8 m/s.37 As stated earlier, stacks can not be arbitrarily exempted from a GEP/downwash analysis because this is part of the stack height regulation. EPA agrees that obtaining additional data bases to allow further valida- tion of the ISC algorithm is desirable. However, existing evaluations provide adequate support for using the algorithm, although underpredictions are indicated. Evaluations of the BLP downwash algorithm are much more i limited. As noted above, EPA plans to propose a modification to the ISC downwash algorithm sponsored by the American Petroleum Institute. Evaluation studies indicate superior performance of this algorithm, although generally higher air quality estimates result from its use. 7-8 ------- For sources in complex terrain with less than GEP stack height, the impact analysis should determine which situation e.g., terrain impaction, stability category A, or downwash, etc. produces the highest concentration estimate for downwash. The emission limit should be determined therefrom. Because the guideline does not contain a description of any screening model, the reference to the Regional Workshop report for the downwash screening procedure is sufficient. 7,2.6 Long Range Transport Comment Summary A few commenters suggested that EPA should recommend appropriate long- range transport models (LRT). A few others, however, disagreed. One stated that since the use of such models could not be recommended for regulatory applications, any reference to these models should be deleted. Another stated that the accuracy of Gaussian models decreases after 20 to 30 km and they are inaccurate to use to 50 km. Another suggested that EPA specify a maximum distance at which such models may be used to determine the impact on a Class I area. One commenter recommended that a significant impact on a Class I area be defined as 5%'of the applicable PSD increment or some other specific value. Then, any source located more than 50 km from a Class I area whose impact falls below the significance level at a distance of 50km or less could be exempt from the requirement for LRT modeling. This would limit the number of sources subject to the case-by-case selection of a model to only those which it is most justified. The commenter also stated that it is burdensome to require the Federal Land Manager, the EPA Regional Office, and the PSD permitting authority to confer on procedures for evaluat- ing the long-range impacts of all projects subject to PSD review, within 100 km distance from a Class I area. A few commenters asked for text clarification. One stated that the last sentence of the first paragraph is unclear. A couple questioned the last sentence in the second paragraph. There have been no field studies on LRT in complex terrain and this makes the evaluation and use of these models according to Section 3.2 procedures impossible in some cases. Another stated that the first sentence in the second paragraph is unclear since EPA does not intend to allow the use of LRT models for regulatory applications to determine the effects of S02 emissions from sources in one region on ambient levels of another pollu- tant (e.g., sulfates, TSP) or on deposition level in another region. (TVA, APCA, NYEC, CDH, ADHS, MMES, CHEV, PHC, ASRC, IEPA, FDER) 7-9 ------- EPA Response EPA is currently in the process of evaluating eight short-term, LRT models againsj two data bases. These are: TVA's (ARRPA) model; ERT's (MESOPUFF, MESOPUFF II, MESOPLUME) models; North Dakota's (MSPUFF) model; Combustion Engineering's (HTDDIS) model; Dames & Moore's (RADM) model, and SAI's (RTM-II) model. A description of some of these models is included in Appendix B of the revised guideline. The Department of Energy is also evaluating several other LRT models against a third data base. Pending a review of these and other evaluation studies reported in the literature, EPA intends to prepare a guidance document on the application of LRT models for appropriate regulatory issues at some future date. EPA is also developing plans to evaluate, and if necessary, improve LRT models applicable to determining Class I area impacts for PSD sources. Models for LRT applications should use meteorological data of sufficient spatial coverage to overcome the difficulties mentioned by the commenter. EPA disagrees with the comment that there should be no reference to LRT models in the guideline since such models are needed under the Clean Air Act, and Section 165 of this act does not specify any distance limitation beyond which the air quality impact of a source on a Class I area need not be determined. Using any specific value, such as 5% of the applicable PSD increment, to exempt sources has no basis in the current regulation and is not a subject for consideration in this rule-making. Instead, the regulation specifies significant emissions as the means of exempting sources from PSD review. The Clean Air Act requires the inclusion of the Federal Land Manager, the State agency and the EPA in reviewing sources that may impact Class I areas. -i A change has been made to clarify the last sentence of the first paragraph. The first sentence of the second paragraph will be clarified. 7-10 ------- 7.2.7 Modeling Guidance for Other Government Programs Comment Summary One commenter recommended that the guideline provide a listing by refer- ence of the air quality modeling requirements of all other Federal agencies. Another suggested that since the State normally has jurisdiction in PSD permit applications, text should be changed to state that in Class I areas, the FLM should consult with the State(s) involved on all modeling questions. One commenter requested that EPA include the Offshore and Coastal Dispersion (OCD) Model as a recommended model for application to sources located over water or in nearshore coastal areas. (APCA, MMS, CHEV, SRP) EPA Response The guideline does reference the air quality models used by some other Federal agencies; however, the applicant should review the modeling require- ment with the government agency in question. The role of the Federal Land Manager (FLM) with respect to handling air quality impacts on Class I areas is defined in Clean Air Act such as in Section 160, 169A, etc. EPA regula- tions require the State to consult with the FLM regarding PSD permit appli- cations. EPA will propose in a supplementary notice of proposed rulemaking to include the OCD model as an Appendix A model in the guideline. The model would be limited in application to off-shore oil/gas facilities and their on-shore impact. 7-11 ------- 8.0 GENERAL MODELING CONSIDERATIONS 8.1 Discussion Comment Summary One commenter stated that the guideline should allow more sophisticated treatment of the mixing height phenomena than the Holzworth method. Another requested guidance on how mixing heights should be considered when on «?I>P data are used. (ADHS, MMES) *>"-:> ite EPA Response Several methods are available in the literature for the calculation of mixing heights. To date, no comparative analyses have been presented to EPA in terms of the effect on model results. Therefore, a change is not warranted until such analyses have been done. Although EPA will continue to use the CRSTER user's guide method for the calculation of mixing heights this does not preclude the use of other systems or the use of on-site data Other systems and on-site data will be evaluated on a case-by-case basis EPA is also presently investigating a new approach to develop hourly mixing height for future air quality models that use on-site turbulence information 8.2.1 Design Concentration Comment Summary A few commenters requested that EPA define what is meant by "highest second-highest short term concentration and provide further guidance on how to determine this design concentration, i.e. whether it includes short term background values, and whether it was determined for each year separately or for the combined period. One commenter recommended that EPA should count the second-highest concentration in the receptor network as the design con- centration. Emissions should be rolled back to prevent exceedance at the second-high receptor in the network. One comment suggested that the EPA explicitly state how the PSD increment consumption should be calculated using air quality models. (NRDC, NYCP, MMES) EPA Response The design concentration is the sum of the short-term background value (except for PSD) and the highest, second-highest source impact. EPA deter- 8-1 ------- mines the highest, second-highest short term concentration by (1) ranking the predicted concentration at all receptors (2) selecting the second-high- est value at each receptor and (3) subsequently selecting the highest of the values identified under (2). For annual averages, the source impact is determined for each year separately, and the highest value is selected. EPA considers the commenter's recommendation to consider the second-highest concentration in the receptor network as the design concentration to be inconsistent with the NAAQS. EPA recommends modeling short-term PSD increment consumption on both a spatially and temporally consistent basis. The maximum amount of PSD incre- ment consumed must be determined by modeling the net changes in emissions (between the baseline and future cases) sequentially for each time period with at least a full year of meteorological data. The^ resulting maximum impacts of this type of analysis specify the maximum amount of increment consumption at each receptor. Please also refer to responses to comments in Section 11.2.3. It is not feasible to provide more explicit guidance; only broad principles can be stated in the guideline. A case-by-case determination is needed. 8.2.2 Critical Receptor Sites Comment Summary (Ambient Air) There were several recommendations that the guideline specifically define the areas accessible to the general public where the NAAQS and PSD increments apply and, hence, where receptors should be located. Some suggested that text be added stating receptors need not be placed within plant property while another stated that inherently, the receptor array is limited by the operational definition of "ambient air." A couple of comments addressed the issue of locating receptors within 100 meters from a stationary source. One suggested that no receptors be 8-2 ------- placed within 100 meters because of the limitations of the dispersion parameters. However, the other recommended that EPA allow placing receptors within 100 meters of the source, but said that EPA should propose the most appropriate way to estimate concentrations within this distance. (APCA, TVA WDNR, ADHS, FDER, NYCP) EPA Response The placement of receptors in all ambient air locations (as defined in 40 CFR 50.1(e)) should be considered. It is EPA's policy (outlined in a letter from Costle to Randolph on December 19, 1980) that the exemption from ambient air is available only for the atmosphere over land owned or controlled by the source and to which public access is precluded by a fence or other physical barriers. Therefore, for modeling purposes the air everywhere outside of contiguous plant property to which public access is precluded by a fence or other effective physical barrier should be considered in locating receptors. Specifically, for stationary source modeling, receptors should be placed anywhere outside inaccessible plant property. For example, receptors should be included over bodies of water, over unfenced plant property, on buildings, over roadways, and over property owned by other sources. For mobile source modeling (i.e., CO modeling), receptors should continue to be sited in accordance with Volume 9 of the "Guideline for Air Quality Maintenance Planning." EPA will continue to review individual situations on a case-by-case basis to ensure that the public is adequately protected and that there is no attempt by sources to circumvent requirements of Section 123 of the Clean Air Act. The EPA model RAM currently allows receptors to be located beginning at 1 meter from any source where that is necessary to meet the ambient air criteria. EPA is planning to introduce this capability into the regulatory option for all of its models. However, because the ISC model is not appro- 8-3 ------- priate for estimating concentrations within the cavity region of buildings, receptors within this region will be precluded from the calculation. Comment Summary (Receptor Density) There were several comments for additional guidance on how to locate receptors and determine receptor grid size and spacing. One stated that the geometric progression method to determine the downwind distance of receptor rings should not be used, but a better method is needed. This method should also show how to locate receptors that will determine the combined maximum concentrations produced by two or more sources. Also, the definition of "large sources" for receptor location purposes should be in terms of total heat input or emission rate. Another commenter stated that it is burdensome, costly and unnecessary to require the use of too many receptors and recommended that in flat terrain cases where there are no complicating source factors, EPA should accept fewer than 400 receptors. In complex terrain or other, more compli- cated cases, EPA should not require more than 400 receptors, as long as this set includes many receptors that showed significant impacts in previous modeling efforts. As to receptor spacing, one comment suggested a maximum receptor spacing of 100 meters be used for final modeling of high impact locations. A couple of other commenters suggested that the location and number of receptor sites be determined from the results of a screening model. (APCA, WDNR, SOC, UARG, ODEQ) EPA Response Due to the subjective nature of judgments about the location of the highest concentration, the guideline provides only general direction and allows for a reasonable amount of flexibility. More detail is provided on page 101 of the Summary of Comments and Responses.1 The geometric progression method was a specific method recommended by EPA.3 This technique has limitations, as the commenters point out, and is therefore not being considered further. EPA believes that no additional generic guidance is required and that the final decision on the choice of critical receptor sites should be arrived at between the applicant and the regulatory reviewing authority on a case-by-case basis using good professional judgement. 8-4 ------- 8.2.3 Dispersion Coefficients Comment Summary (Averaging Period) Some commenters stated that the Pasquil1-Gifford (P-G) rural horizontal dispersion coefficients are based on 10-minute averages and should not be used to represent hourly averages. To remedy this, some comments suggested the use of empirical averaging-time conversion factors to produce one hour averages while others suggested that EPA conduct an additional rural model evaluation study to determine whether these P-G coefficients should be increased to represent 60-minute averaging times. One commenter suggested the use of the Brookhaven dispersion coefficients instead of the P-G coeffi- cients. Another stated that dispersion coefficients developed from site- specific studies should be given preferential use over the P-G or any other non-site specific coefficients. (API, AMC, DS, APCA, SOC, PEPC, IPL) EPA Response EPA does not recommend the general use of empirical averaging-time conversions for periods of less than 1-hour because they are limited to the data set from which they are derived. Acceptance of such a technique is provided for on a case-by-case basis. Until better data become available, the P-G coefficients will continue to be used in their present form. Since the models are typically used for estimating values toward the extremes in the distribution, assumptions typifying extremes for the hourly concentrations are justified. Model evaluation by Turner38 indicates that the second-highest estimates based on sigmas assumed to represent 1-hour averages, although having considerable scatter, appear to have little bias. Also, EPA compared the results of using the P-G coefficients with other alternatives, such as the Brookhaven dispersion coefficients, on concentration estimates as documented in Addendum D to Appendix H of the Summary of Comments and Responses.1 The P-G coefficients performed best. Furthermore, dispersion coefficients derived from site-specific studies may be used for air quality impact analyses at these sites if an evaluation demonstrates better performance in a model than when using an EPA recommended model. 8-5 ------- TEM Is an example of a model that utilizes an empirical averaging-time conversion factor. However, when evaluated,8 this model did not perform as well as the EPA models that do not use this factor. This further detracts from the credibility of this suggested.empirial method of adjusting the 10-minute averages. Comment Summary (McElroy-Pooler Dispersion Coefficients) Several commenters stated that the McElroy-Pooler (M-P) dispersion coefficients are not appropriate for elevated buoyant sources in an urban environment. According to these commenters, the EPA sponsored RAM model evaluation is unreliable because the study lacked a good area source emissions inventory and the air quality monitoring locations were inappro- priate. Some commenters suggested that EPA conduct an additional urban model evaluation program with monitors placed within 2 km of major point sources with tall stacks. Another commenter recommended that EPA await the results of an Electric Power Research Institute sponsored field experiment for eval- uating urban plume dispersion planned for 1985 in Indianapolis. Other commenters suggested that the entire model should be validated and quoted an EPA statement that an improvement in one component of a model will not necessarily improve overall model performance. Since the only model for which any validation data for the M-P curves has been presented in RAM, M-P dispersion curves should not be substituted into models already validated with P-G dispersion coefficients unless the performance with M-P coefficients has been demonstrated to be superior. One commenter stated that the reference to the M-P coefficients in the CRSTER and MPTER models are inappropriate since these models should be confined to rural applications. (APCA, SOC, NYEC, UARG, CONE) EPA Response These coefficients were derived from the best scientifically validated data available. Urban model evaluations39*40 indicate model under-estimates of extreme concentrations, especially under unstable conditions. In the EPA model evaluation study, RAM did not consistently show a tendency for over or underprediction of peak values. The urban dispersion coefficients in the other EPA models are the same as in RAM. No alternative to the M-P coeffi- cients has been presented by the commenters. 8-b ------- EPA also agrees that additional urban model evaluation is desirable with several close-in monitors as suggested. In the EPA urban model evalua- tion study, only one monitor was available that was close to a large source. Pending the availability of high quality monitoring data close in to a large urban point source, EPA will consider additional model evaluation studies and encourages others to conduct them. Comment Summary (Turbulence Intensity) Some comments stated that dispersion coefficients should be based on direct measurement of turbulence intensity and suggested that EPA place high priority on developing guidance on how dispersion coefficients should be computed from measurements of turbulence intensity. The Mineral Manage- ment Service's Over Water Dispersion Model has implemented the direct tur- bulence measurement concepts to characterize over water and land dispersion. However, one comment said that EPA should retain the position that the collection and use of such data are optional. (SOC, CHEV, UARG, CMA, APCA, WC) EPA Response The use of dispersion coefficients based on direct measurements of turbulence may be preferable to the use of discrete stability classes. However, this involves highly subjective technical procedures and no consistent methodology has evolved from the scientific community. Thus, EPA has begun research to develop such a scheme, through its Office of Research and Development, for relatively flat terrain to estimate dispersion using horizontal and vertical fluctuation statistics measured or estimated for the effective height of the plume. Pending completion of this program, models of this kind must be tested and evaluated before they can be endorsed for regulatory use. In the interim, the proposed dispersion coefficients will continue to be used. 8-7 ------- Comment Summary (Buoyancy Induced Dispersion) According to one comment, the use of Buoyancy-Induced Dispersion (BID) should be limited to single or multiple point sources with buoyant plume rise and not to complex sources or multiple source/urban applications where its use could be considered enhanced dispersion. (NYEC) EPA Response BID is only being applied to point sources and EPA guidance is consistent with the comment. 8.2.4 Stability Categories Comment Summary (Split Sigmas) There were several comments suggesting an alternative approach to the Turner scheme for determining stability classification when on-site measurements of horizontal and vertical turbulence intensity are available. Specifically, the "split sigma" approach was recommended to independently characterize horizontal and vertical stability classes. One commenter recommended that the refined models should be re-evaluated with this classi- fication scheme and if the revised models predict more accurately than the currently preferred models, these revised models should be adopted as the. preferred models. Several different approaches, however, were presented as to how to determine these stability categories. One commenter suggested that the guideline provide recommendations on characterizing over water stability. (API, AMC, CONE, APCA, SOC, UARG, CARB) EPA Response The Turner classification is a widely used scheme because it can be simply applied to National Weather Service data. There has been no convincing demonstration that other stability classification schemes allow more accurate concentration estimates to be made. EPA is presently developing a method to avoid calculating stability categories altogether and allow for use of the on-site turbulence data directly in the Gaussian equation. This program is in the development stage at this time and extensive testing is required before it can be released to the public. 8-8 ------- There has been no convincing demonstration that split sigmas allow more accurate concentration estimates to be made as described on page 14 of the Summary of Comments and Responses.! Recently the Minerals Management Service^l has released the OCD model which can treat dispersion over water bodies. EPA plans to propose for public comment the incorporation of this model in Appendix A of the revised guideline. (Please refer to responses in Section 7.2.7). EPA will continue to assess experience gained from model validation studies in this area and will issue guidance when sufficient experience is gained. 8.2.5 Plume Rise Comment Summary (Bjorklund and Bowers Algorithm) EPA's proposed use of the Bjorklund and Bowers (B-B) stack-tip downwash algorithm received numerous comments that recommended not adopting this algorithm. Some objected to the use of this algorithm because the study from which this method was devised is semi-empirical and does not explicitly con- sider the physics of the downwash process. Even so, some comments agreed with the use of the B-B method for Froude number less than 1.0. However, they noted ambiguity in the documentation for Froude number between 1 and 3. Other comments stated that this algorithm has its greatest impact on plume size determination for smaller buoyant sources and would cause the model to calculate no plume rise at all for a source when the wind speed exceeds the exit velocity. This, however, they noted is contrary to public literature. Some commenters stated that this algorithm represents a radical departure from previous EPA guidance on this issue and that this change may invalidate some of EPA's validation studies of the preferred guideline models. Many suggested that EPA not change its previously used stack-tip downwash algorithm until the models incorporating this algorithm have been sufficiently validated. One stated that EPA's sensitivity study presented in Addendum E does not con- stitute a true validation study. Another suggested that a sensitivity study was applied to one model only and not to the other models that EPA is proposing to incorporate this algorithm. Others noted that EPA has previously suggested that improving any single model algorithm does not necessarily ensure better model results. Instead, the entire model as revised must be evaluated in accordance with the "Interim Procedures" document. The commenter suggested that EPA should follow its own policy on the proposed (B-B) stack-tip downwash algorithm change and evaluate all preferred models. Another commenter further stated that stack-tip downwash should not be invoked when building wake effects are being simulated with a downwash model. (API, UARG, APCA, SOC, ISBH, CMA, NYEC, ODEQ, TEGP, MMES). 8-9 ------- EPA Response EPA has proposed the use of the Bjorklund and Bowers42 stack-tip downwash algorithm (developed originally by Cramer43 to replace the Briggs44 stack-tip downwash equation now in use in the EPA air quality models. A number of responses to this proposal have been received. Many of the commentors objected to the Bjorklund and Bowers algorithm due both to its semi-empirical basis and- to the lack of testing which had been done using that equation. Arguments favoring the use of the Bjorklund and Bowers algorithm are based, in part, on evidence that the downwash effects on final plume height are substantially greater than is accounted for by the Briggs equation, and that tests with the ISC and SHORTZ models show very little bias in the ground level concentrations. It is well known that stack-tip downwash occurs when the wind speed becomes large relative to the stack gas exit velocity. According to Bjorklund and Bowers,42 their stack-tip downwash algorithm is a semi-empirical correc- tion to the plume rise which "is based on a combination of visual observations of plume behavior, the results of wind tunnel studies reported by Briggs44 comparisons of concurrent calculated and measured short-term and long-term ground level S02 concentrations in Lansing [MI], Allegheny County [PA], and elsewhere, analysis of the Bringfelt4^ plume rise data, and limited compari- sons of calculated and measured plume rises for two coal-fired power plants (Bowers and Cramer, 1976)." It is not entirely clear whether the effects being treated by these correction formulas are in fact stack-tip downwash effects, building downwash effects, or both. The Briggs stack-tip downwash equation currently used in the EPA models does not reduce the calculated plume height sufficiently to account for the plume height reduction and higher concentrations noted by Bjorklund and Bowers42 and others. 8-10 ------- It should be noted that stack-tip downwash includes both a lowering of the height of the plume immediately after it leaves the stack, and a decrease in the plume rise. The latter results from shear effects and increased plume size in the turbulence in the lee of the stack. The Briggs equation accounts for the reduction in initial height only. The Bjorklund and Bowers algorithm explicitly accounts for the reduction in plume rise. However, most of the data on which the Bjorklund and Bowers equation was developed and tested include building downwash effects. The stack height (hs) to building height (hb) ratios for those data sets are between 1.2 and 2.5. It is not entirely clear whether the observed increased concentrations are due to stack-tip downwash or to building downwash. The Huber and Snyder46 downwash correction implicitly includes stack-tip downwash effects.47 H. E. Cramer Co.43 states that, for the DOW data, both the Cramer (Bjorklund and Bowers) stack-tip downwash correction and the Schulman and Scire48 building downwash correction yield significant and very similar improvements in the correspondence between calculated and observed concentrations. In the same report the authors state that "the Cramer,49 stack-tip downwash correction appears to account for the combined effects [of building downwash and stack-tip downwash] if the stack height to building height ratio is greater than or equal to about 1.2." The sample size is, however, very limited. Thus, the current EPA recommended approach, using the Briggs44 stack-tip downwash correction and the Huber and Snyder46 building downwash correction, almost certainly accounts for the combined effects of building and stack-tip downwash for cases where the hs to hb ratio is less than 2.5. Larger plants with a hs to hb ratio greater than 2.5 are not treated by the Huber and Snyder approach. These plants generally have high stack gas exit velocities so that stack-tip downwash is unlikely to result in significant air quality impacts. 8-11 ------- Smaller plants are the most severely affected by the Bjorklund and Bowers algorithm; however, little or no testing of the algorithm has been done with small plants. Thus, on re-evaluation, we are withdrawing the proposal to recommend the use of the Bjorklund and Bowers^? stack-tip downwash algorithm in the preferred models. In doing so, we note the following: 0 For hs to hj., ratios less than 2.5, the Huber and Snyder building downwash equations treat the stack-tip downwash case implicitly. 0 For the remainder of the cases, the larger sources are unlikely to have a stack-tip downwash problem, while smaller sources may have such a problem not addressed by the current EPA approach. 0 The Bjorklund and Bowers42 stack-tip downwash algorithm has not been adequately tested, if at all, on such smaller sources. In the interim, EPA continues to recommend the use of Briggs^4 stack- tip downwash correction for those cases when the use of stack-tip downwash is appropriate and is considering other methods for future use. Comment Summary (Plume Penetration) One commenter recommended that EPA re-evaluate the assumption that plume rise penetrates the mixing layer, and reformulate its models to take into account the tendency of the mixing layer to suppress plume rise. Another commenter recommended that EPA should provide for partial plume penetration of the elevated stable layer to overcome the tendency to predict zero concentration for some hours when substantial concentrations are measured. Another recommended that plumes should have considerable plume rise (e.g. greater than 15% of the mixing height) before their impacts are neglected. Less buoyant plumes, the comment added, should carry a fraction of the plume within the mixing height layer. (NRDC, APCA, SOC, ODEQ) EPA Response There have been several formulas reported in the scientific literature which have addressed the treatment of partial plume penetration. However, 8-12 ------- these formulas have not given better results in model validation studies. Recently, EPA examined the performance of the PPSP model where partial penetration of buoyant plumes into the capping inversion is a distinguishing feature of this model50. Generally the results show that concentrations estimated by PPSP are almost uniformly higher than the measured SUj data values. Until such an improved formula is developed, EPA recommends continu- ing the use of the existing method. Comment Summary (Gradual Plume Rise) A couple of comments dealt with whether or not to allow for use of gradual plume rise in non-complex terrain. One cited the need for this method in urban areas where there are many close-in elevated receptors (buildings) and using final plume rise will cause large underpredictions of the actual impacts on these receptors. Another recommended that the gradual plume rise option should not be allowed because there is insufficient data to verify the procedure. (NYCP, CHEV) EPA Response There have been no validation studies demonstrating the accuracy of the gradual plume rise formula at these close-in receptor sites. Small errors in the gradual plume rise formula could significantly influence concentrations near plume centerline at these nearby receptors. EPA is not recommending the general use of gradual plume rise for estimating effective height because of uncertainty regarding dispersion (plume growth) under such conditions. Comment Summary (Plume Rise) A couple of comments suggested that EPA incorporate plume rise enhance- ment into the models for industrial source complexes where there are multiple adjacent stacks. One of the comments suggested using the algorithm proposed by Briggs while the other suggested that EPA first establish protocols and then test the revised models for performance relative to currently preferred models. A couple of commenters suggested that EPA re-examine the stable pi rise formula used in the RAM Model since this model does not account for 8-13 ume ------- the urban heat island effect at night. The approach used by urban CRSTER, urban ISC, and COM is more consistent with research findings on lapse rates in cities and EPA should modify the RAM model to make it consistent with the other three. (APCA, SOC, AISI, UARG, CONE) EPA Response Although plume rise may be enhanced when there are multiple adjacent stacks, enhancement of buoyancy due to merging of effluents from these stacks should consider relations of wind direction and line of stack orienta- i tion. Although theories exist to consider this phenomenon, such as the Briggs technique mentioned in the comment, quality data to justify the specific procedures included in such a model are not available. EPA agrees with the second commenter as to the need for evaluating this phenomenon and will consider the merits of applicable on-site studies on a case-by-case basis. EPA is investigating stable flow over urban areas. When this reaearch is completed, EPA may make recommendations on changes to the stable plume rise formula. Comment Summary (Building Downwash) One comment recommended that for treatment of building downwash, the existing version of ISC (based on Huber's method) should be used for sources with tall stacks. For sources with short stacks, the building downwash algorithm in ISC should be replaced with the Schulman and Scire method which is used in BLP model. Another comment asked for more research on plume rise from shorter stacks and unique sources such as flares. (API) EPA Response The Industrial Source Complex (ISC) model is being significantly modified by industry (i.e. American Petroleum Institute) for applications 8-14 ------- involving stacks subject to downwash. Extensive testing is underway prior to being considered for recommendation by EPA as a preferred model for these applications. If accepted, this modification will replace existing algorithms. EPA agrees that more research on plume rise from unique sources such as flares is needed and encourages those affected industries to pursue such studies. 8.2.6 Chemical Transformation Comment Summary Several commenters requested a different method of treating SC>2 and 1% half life than the present transformation scheme of a 4-hour half life for SOg only. One of these comments recommended the transformation scheme contained in the MMS OCD model where transformation for both S02 and NOg is based on latitude, season, and time of day. Another comment asked how should days with appreciable precipitation be modeled for pollutants like S02- (SOC, MMES) EPA Response The transformation scheme used in the OCD model is based on data obtained over bodies of water and there has been no convincing demonstration that this technique is valid for rural or urban applications. EPA will continue to assess experience gained from model validation studies of the OCD and other models and will issue guidance when sufficient experience is gained. The basis for the present transformation scheme is given on pages 29 and 104 of the Summary of Comments and Responses.1 The 4-hour half life has been used for a long time; a better assumption has not been universally adopted. However, EPA accepts the use of a different half life on a case- by-case basis if on-site data are available. There is no recommended half life for N02 (please refer to Section 6.0 and 6.2.3 of the guideline). EPA 8-15 ------- models do not explicitly consider the effects of precipitation on S02 removal. Any removal is assumed to be included in the decay term. 8.2.7 Gravitational Settling and Deposition Comment Summary Two commenters stated that the gradient-transfer model' by Rao for calculating particle deposition appears to be more physically realistic than ISO's method and is included in several UNAMAP 5 models (MPTER-DS and PAL-DS). The comment suggested that ISC model be modified to incorporate this method or withhold a recommendation of any modeling technique including ISC for fugitive dust until more research is completed. Another comment said that based on their theoretical analysis, the settling-deposition algorithm in the ISC model may overpredict concentrations by a factor of 3.7. The comment also added that the ISC model fails to account for pit retention which may introduce an additional overprediction factor. Together, these cumulative systematic errors may cause a combined overprediction of TSP concentrations of a factor of 3.8. (CDH, BAAQ, AMC, NCA) EPA Response EPA has recommended only the specific particle deposition algorithm in ISC. The model by Rao, i.e., MPTER-DS, has not yet been sufficiently eval- uated using ambient data and it is premature to recommend this technique. Listing a model in UNAMAP does not infer that the model is necessarily approved for regulatory applications. EPA's evaluation of the ISC model, as a whole, indicates a net underprediction when the deposition option is used based on actual data. EPA is presently sponsoring research that should help determine the percent retention of particulate matter in surface coal mines.36 once an algorithm is developed, it must be validated with field data before it can be recommended for regulatory applications. 8-16 ------- 8V2.8 Urban/Rural Classification Comment Summary There were a number of comments questioning the merit of the Auer land- use scheme. One suggested that it should be deleted because it is arbitrary. Another stated that the Auer scheme was not based on investigations of tur- bulence or dispersion and that there have been no studies that demonstrate a direct relationship between Auer's urban land-use classes and observed tur- bulence or dispersion. Further, the comment added, Auer makes no reference to a "3km radius circle about the source" or to "50 percent or more" of the area being in urban land uses for a region to be classified as urban. Another comment stated that the population density procedure would make suburban areas and towns urban, when previously these areas were modeled as rural. One commenter, however, did recommended the use of the Auer scheme. A number of comments requested more guidance on how to model or classify areas in between rural and urban. One suggested that sources that are several kilometers from the heart of the urban area but are still in the overall major metropolitan area should be modeled as rural sources. For such sources, the comment recommended using concentrations derived from MPTER or rural RAM super imposed on the concentrations resulting from separate modeling of the urban sources. Another comment suggested that EPA develop a hybrid model reflecting transition between rural and urban dispersion based on plume location. As to area classification, one comment suggested that the described classification procedures would classify urban area sources located next to large water bodies as rural. Another suggested that there is no good procedure for urban or rural classification and that this can be best made by performing an on-site visit and then a rational evaluation of the area characteristics. (API, SOC, NYEC, APCA, UARG, OPEA, NYEC) EPA Response The Auer land-use classification scheme has been documented based on technical arguments as discussed on page 28 of the Summary of Comments,and Responses.1 EPA welcomes research results from field studies that more reliably identify urban boundaries. In the interim, EPA, sees no basis for change in guidance at this time because no viable alternative has been proposed. EPA is sympathetic to the commenters assertion that the population density procedure may mis-classify suburban areas. That is why the Auer land use scheme is recommended as the first method of choice while the population density is the second method of choice. 8-17 ------- As to the commenters request for guidance on how to classify areas between rural and urban, EPA recommends that the whole urban area should be considered as one entity. Otherwise, the use of such procedures as the commenter has suggested would result in a complicated and arbitrary analysis. EPA presently has no plans to develop a hybrid model as described by the commenter, but will assist in examining technical accuracy and regulatory applicability if such a model is submitted by developers. EPA's research on estimating dispersion directly from fluctuation statistics should overcome artificial urban-rural differences. As to area classification, some subjectivity is always present in simple rules of thumb. Therefore, once an area is identified as being potentially within an urban boundary, EPA recommends early discussion between permit granting authority and the applicant, including an on-site visit if possible to resolve many issues including final area classification. 8.2.9 Fumigation Comment Summary Two comments requested improved guidance on inversion break-up fumigation because of the importance of this phenomenon for certain model applications. (ADHS, MMES) EPA Response EPA agrees that models dealing with plume fumigation phenomena are needed. However, no method has been convincingly demonstrated with monitored data. In the interim, other techniques such as the manual calculation method shown in the Turner Workbook may be used. 8-18 ------- 8.2.11 Calibration of Models Comment Summary Two comments recommended the use of calibration factors in situations where all modeling techniques significantly underpredict or when nearby ambient air quality data are available. (CITG) EPA Response Calibration for short-term air quality concentrations is not recommended for various reasons as outlined on page 71 of the Summary of Comments and Responses.^ 8-19 ------- 9.0 MODEL INPUT DATA 9.1 Source Data Comment Summary (Change Definition of Emission Rates) Several comments said that the use of maximum emission rates for every hour throughout the year is unrealistic and overestimates air quality impacts. This conservative assumption is further compounded by the probability of occurrence of a specific wind speed, wind direction and stability class. As an alternative, one suggested that EPA should model proposed new sources at maximum emissions, while using actual emissions for other nearby sources. Two suggested that actual hourly operating conditions should be used instead of design capacity. Another suggested that the maximum operating rates should be used only when a more representative rate cannot be defined. Otherwise, the highest historical (e.g., three year) operating rate for the averaging time being evaluated should be used. For example, the impact on a 24-hour standard would be modeled using a 24-hour average emission rate. Another recommended that EPA revert to the practice of identifying a single critial load condition in a screening analysis and then using the critical load (rather than both partial and maximum load) in refined modeling. A few comments stated that, for multi-source applications when several plants in a system are being modeled, the modeling should recognize any system-wide limitations on load. The probability of a combination of 100% load at each source (and 50 to 75% constant maximum loads) with worst case meteorological conditions is mathematically almost impossible. One recom- mended using hourly load data consistent with the meteorological record or selecting an appropriate seasonal capacity. One comment said that the description of long-term emissions (on page 5-4, paragraph 3) does not indicate the type of modeling study to which it relates. For instance, the PSD regulation describes the "actual emissions" as the average rate, in tons per year, at which the unit actually emitted the pollutant during a two year period which precedes the particular date and which is representative of normal source operation. The text in the guide- line refers to maximum emissons based on 3 years. One comment said that guidance should be provided to define the phrase "future time period" during which growth of emissions should be considered. This phrase appeared on page 9-4 of the guideline. (API, TVA, UARG, SOC, CMA, MCC, OEPA, CONE). EPA Response According to 40 CFR 51.22, EPA is required to adopt "emission limitations and other measures necessary for attainment and maintenance of any national standard." To achieve this, stationary source control strategies for State implementation plans (SIP's) must be determined using the maximum emission 9-1 ------- rate allowed under the federally enforceable permit. The actual emission rate may be used only if it is federally enforceable. This requirement applies to the source(s) subject to the SIP emission limit evaluation, nearby sources, and other sources that contribute to the background concen- tration of sulfur dioxide (SO?), To ensure attainment and- maintenance of the ambient standards, as provided for in Section 110 of the Clean Air Act, actual or design capacity {whichever is greater) should be used to simulate operating conditions of the source(s) subject to evaluation and nearby sources. The possible interacting impact at the same receptor is thus accounted for. Other operating conditions may be used only if they are federally enforceable permit conditions. Load conditions used as model input should ensure maintenance of the ambient standard during all operating conditions. For other than nearby sources that contribute to the background concentration of $03, annual levels determined when the source actually operates, averaged over the most recent 2 years may be used (See Comments on Section 9.2). For the prevention of significant deterioration of air quality, Section 163 of the Act requires that "each applicable implementation plan shall contain measures assuring that . . . maximum allowable concentrations of [sulfur oxide] . . . shall not be exceeded." For this reason, dispersion model results should be based on the operating and meteorological conditions that cause the highest ground-level concentrations of $03. Because the model input data must represent worst-case conditions, no system-wide limitations on load can be recognized. The guideline text on evaluating SIP's for compliance with long term ambient standards has been revised and a table added which incorporates the following: Annual and quarterly emission limits should be tested using 9-2 ------- the maximum al lowab'le emission limit or other federally enforceable permit limit. For source(s) under evaluation and nearby sources, the operating conditions used should represent actual or design capacity (whichever is greater) or another federally enforceable permit condition averaged over the most recent 2 years. For other sources, actual annual operating levels averaged over the most recent 2 years should be used. The future time period during which the impact of growth on emissions should be considered is the period during which known or anticipated growth is expected to occur. Any new source construction or existing source reconstruction or modification that has been proposed for the area being evaluated and that has the potential to affect emissions in that area should be included. In area-wide analyses, the data by which' the standard must be attained defines the future time period. Comment Summary (Use of Statistical Emission Rates) A few commenters indicated that they disagreed with the use of fixed maximum emission rates and that the use of statistically based methods and variable emission rates should be encouraged. One suggested that EPA should adopt the ExEx method or allow new sources in multiple source areas to model their emissions at maximum capacity and the existing sources at historical capacity usage. While the latter is not as rigorous as the former (probabi- listic) approach, it does provide a more probable description of an emission scenario than current practice. Another suggested the use of average emission rates or some statistical approach which would account for emission rate variations. Use of statistical probabilities in air quality analysis is gaining some acceptance as demonstrated by a recent court decision (Kamp vs Hernandez). One commenter recommended a statistical approach in dealing with mining emissions because a mining operation is a complex array of sources, some of which are simultaneous, and some of which are not and the peak activity level may not occur simultaneously with the worst meteorological conditions. (API, SOC, CHEV, AMC) EPA Response The EPA is currently investigating the use of statistically based methods and variable emission rates. Thus far, no such approach has been approved for use in mathematical air quality modeling sources to determine 9-3 ------- compliance with ambient air quality standards because statistical modeling methods do not provide a mechanism for evaluating the sources against short term ambient standards. Also, the deterministic nature of the models presently used to test emission limits is consistent with the deterministic nature of the standard. Currently, compliance with ambient standards should be-determined using maximum allowable emission rates at actual operating levels or design capacity (whichever is greater) to assure attainment and maintenance of the ambient standard. The use of statistical probabilities in air quality analysis is addressed in the response to comments in Chapter 10 dealing with "Model Uncertainty." 9.2 Background Concentrations Comment Summary (Single Sources) Several comments asked EPA for more guidance on determining background concentrations for isolated single sources. One comment agreed with the Option One technique of determining background concentrations (described in the guideline), but usually the meteorological data needed to carry it out are not available. Also, in attempting to use this technique, users have experienced difficulty in characterizing the "meteorological conditions of concern" in a way that allows monitoring days to be selected for averaging. The comment recommended that in the absence of sufficient data to employ Option One, the annual mean concentration at the selected background monitor- ing site (or the average annual mean concentration over the background monitoring network) be used as an estimate of the background concentration for all averaging periods. Another commenter said that the second option is complicated and experience has produced situations where background concen- trations calculated by this method are actually higher than the measured impact at a site. The comment suggested that EPA consider, as the background, the minimum concentration reported at any monitor within the regional monitor- ing network. Or, EPA can adopt one of the following methods: First, EPA can specify that if the background exceeds the measured concentration that results from using the EPA-recommended calculational method, the background should be set at less than or equal to the measured concentration. Another option would be not to factor into any modeling analysis those measured concentrations in the non-impacted sector which are unusually high and are most probably due to local conditions. The final option would be to set background at a given monitor in an amount not to exceed the average concen- tration at that monitor when the source is impacting the same monitor. Another comment stated that Option One may not be viable in complex terrain, or complicated flow patterns and where there is indirect transport 9-4 ------- of pollutants. One comment stated that Option Two should explicitly state how to determine background concentrations for various averaging times as in Option One. (FDER, UARG, MCC, DPC) EPA Response Guidance on determining background concentrations is by necessity made general because of the complexity and variety of modeling situations. This flexibility allows for a case-by-case determination in consultation with the Regional Office. Therefore, only a brief response to the above comments can be given. The meteorological conditions of concern are those conditions that result in determining the highest, second-highest concentration (i.e. neutral stability and 4-6 meters per second, or stable conditions with 2-3 meters per second, etc.). During these conditions, background is determined and then averaged over the period of record. When sufficient data are not available to employ this method, as the commenter asks, then a case-by-case determination in consultation with the Regional Office is needed. The other two options presented by the commenter can not be made into general guidance because they employ arbitrary criteria. Again, EPA recommends a case-by-case analysis of the problem. In complex terrain, it must first be determined that the data available are representative of the site. If data are not applicable, as the commenter suggests, then the entire modeling analysis, not just background determination must be reviewed with the Regional Office. As to the second comment, averaging times for Option Two should be the same as those in Option One. Comment Summary (Multi-Sources) Several comments also asked EPA for more guidance in determining background concentrations in multiple source areas. Two comments stated that the proposed procedures are complex and unworkable in dense urban areas with many hundreds or thousands of relatively small sources and 9-5 ------- recommended tnat the procedures for treating these sources be determined on a case-by-case basis. Two comments recommended: (a) characterize the meteorology of the periods of predicted highest combined impact from the sources being modeled; (b) identify similar periods from the most recent representative period of air quality monitoring and model these periods using coincident hourly emissions and meteorological data; (c) subtract the explicit coincident impact; (d) the resulting short term concentrations are ranked and the highest of these is used as the representative background value. Another comment stated that for modeling nearoy sources, tne text should be modified and made consistent with Section 9.2.1. For evaluation against annual standards the term "worst case emissions" should be replaced by "maximum historical emissions during the last 3 years" as stated on page 9-4. Sources permanently shut down should not be included. For evaluation against short term standards, it is unrealistic to model all sources at maximum allowable emissions. Only a realistic worst case emission scenario should be required. (APCA, UARG, CONE) EPA Response Guidance on determining background concentrations in multiple source areas is as explicit as can be stated. In urban areas where there are numerous sources and source categories, a case-by-case determination in consultation with the Regional Office is needed. It is unclear how the approach (a through d) recommended by the commenters fits in with the guidance i.e., whether it is a replacement or supplemental or on a case-by- case basis. Nor was any proof presented that this approach was any better than that given in the guideline. The text in Section 9.2.3 has been revised to maintain consistency with previous sections, and a new Table 9-1 has been added to further clarify the data input requirements for nearby and other background sources. Nearby sources should be explicitly modeled only when they are "expected to cause a significant concentration gradient" and when they are "few in number.1 The resulting modeled concentrations should be used in concert with ambient monitoring data to determine concentrations of S02 due to all background 9-6 ------- sources in the vicinity of the source or sources being evaluated. For evaluation against annual standards, as the commenter suggests, nearby sources should be modeled using maximum allowable emissions at actual operating conditions averaged over the most recent 2 years. Short term emission limits should be evaluated using maximum allowable emissions at actual operating conditions for all hours of each time period under consideration. If operation does not occur for all hours of the time period and the source operation is constrained by a federally enforceable permit condition, an appropriate adjustment to the modeled emission rate may be made. EPA agrees that sources permanently shutdown should not be included. Comment Summary. (Miscellaneous) One commenter recommended that to ensure that a health-related NAAQS will not be exceeded, the proposed method of using the average background concentrations that occur during meteorological conditions of concern should be replaced by using the highest background concentration that occurred during meteorological conditions of concern. Another commenter said that receptor modeling should be included as a method for determining background concentrations. (CDH, ADHS) EPA Response The commenter's suggestion to use the highest background concentrations would result in a very conservative estimate of a source's impact. The commenter did not provide any analysis to support this position. EPA believes that its approach is rational and is better suited for practical applications. Receptor models may be used to determine background concentrations on a case-by-case basis. Please refer to comment responses in Section 11.1 on "Receptor Models." 9-7 ------- 9.3 Meteorological Input Data 9.3.1 Length of Record of Meteorological Data Comment Summary (Use Less Than Five Years) Many commented that the requirement for five years of NWS meteorological data- seems excessive. One said that three years of CRSTER modeling is nearly as effective in identifying peak concentrations as five years and the loss of accuracy is insignificant compared to uncertainty of the model calculation itself. For example, the ISC model is very expensive to run and furthermore, downwash conditions would occur so frequently that one is certain to find maximum concentrations in three years of modeling that are virtually as large as maximum values obtained using five years of data. Another urged EPA to devise screening procedures to identify the critical meteorological conditions which produce maximum concentrations. Procedures should be promulgated to select just those cases with potential for producing maximum concentrations. Another stated that when three years of data are available, the highest second highest concentration may be used. However, another commenter said that the use of five years of data in which to pick a maximum level results in an effective standard of not to exceed more than once in five years and recommended the use of two years of NWS data instead. One commenter recommended that if at least one year of quality assurable data are available, the guideline should require its use. The source's option of using the most beneficial result of either on-site or NWS data should be eliminated. However, another said that the modeler should have the discretion to select which year or years of data are most appropriate for the application. One of the commenters said that the language of all portions of the guideline should be consistent in requiring that not more than five years of data be used in any modeling analysis using off-site data and not more than one year of data when on-site data are used. However, another commented that one year of on-site data should be demonstrated to be representative of the worst short term impacts over a five year period. Another commenter suggested that the guideline allow flexibility for use of older NWS data when the use of hourly data are appropriate. (TACB, MES, AISI, UARG, NYCP, MSUS, CITG, CARB, WDNR) EPA Response The length of record should be adequate for EPA to determine the adequacy of the emission limitations. EPA has presented its analysis and rationale for the use of five years of NWS or one year of on-site data on pages 45-50 of the Summary of Comments and ResponsesJ Results from recent investi* 9-8 ------- gations support that conclusion.51 The commenters have not presented any data to support their claim that three years (or two years) of data are as climatologically representative and sufficient to protect the NAAQS as five years of data. The cost of modeling can not be used as the sole reason for using less than five years of data; the deterministic nature of the standards require EPA to make certain that the standards are never violated (please refer to response to comments in Section 9.1 on "Use of Statistical Emission Rates"; and "Use of Best Estimates" in Chapter 10). Furthermore, the requirements for consistency (refer to comment responses on page 1-1) do not allow EPA to accept results from one model (e.g. ISC) with less data while more data are required for input into another model. The use of screening procedures as a first level conservative estimate is recommended in the guideline. However, the use of screening procedures to reduce the number of hours to be modeled, as the commenter suggests, is not recommended because there is a great deal of uncertainty in arriving at such a screening method, especially when more than one source is being modeled. EPA agrees with the commenter and has changed its guidance to recommend that if at least one year of quality assured on-site data are available, they are preferable to NWS data and should be used. EPA is consistent in stating that at least five years of NWS or one year of on-site data is required in any modeling analysis. Up to five years of on-site data should be used if available and valid. EPA has examined the issue of determining representativeness of one year of on-site data to five years of NWS data and has concluded that a scientifically available method does not exist at this time. Considering the cost of acquiring quality- 9-9 ------- assured on-site data and the lead time required for this effort, it is not feasible to recommend a longer period of record. As to the age of the NWS data record, EPA recommends that the most recent, readily available and consecutive five year period of record should be used, provided that an earlier period has not been identified already by a permit granting authority to contain the controlling period (i.e., has the worst case impact). Comment Summary (Differentiate by Size) A few commenters suggested that the decision of what record length to choose should be related to the plant size. One of these comments said that it was unclear whether to use five years of meteorological data in all cases or only in the case of a large source, with consideration given to the uncertainties involved in cases when less than five years of data are used. If the exact location of the controlling concentrations is not important, one year of data may be used when the predicted concentration is less than one-half of the standard. Another commenter said that requiring the use of five years of data is a waste of resources for the majority of sources which are small and consume only a fraction of an applicable PSD increment or NAAQS. Another said that for large sources (e.g., 500 MW power plant), one year of on-site data is preferable but should not be required for small sources in uncomplicated terrain where the nearest NWS station may adequately represent local conditions. (FDER, ADEM, MMES, OEPA) EPA Response EPA recommends that (1) five years of data should be used (no limitation on source size) and (2) for large sources, e.g., a 500 MW plant, five years of NWS data or at least one year of site-specific data are required. This implies that the use of five years of NWS data is the norm, but on occasion an exception for a small source might be justified. EPA rationale has been previously stated on pages 45-50 of the Summary of Comments and Responses.! If a source cannot demonstrate compliance with a screening model, the five years of NWS data should be used in a refined model analysis. The commenter has not provided any data to explain how cl imatological variability is 9-10 ------- addressed if less than five years of NWS data are used. For the majority of small sources that the other commenter refers to, the question of length of meteorological record never arises because these sources will most likely pass the screening test and further refined analysis would not be necessary. If the screening analysis indicated the possibility of a violation, then a full analysis using five years of NWS or one year of site-specific data is necessary. 9.3.2 National Weather Service Data Comment Summary One commenter recommended that the guideline discuss how mixing depth data are obtained from NWS upper air stations. A few comments noted that the NWS wind measurements are averages for a few minutes estimated by the observer and that fluctuations during the hour are not reflected by those short observation times. The guideline seems to prefer NWS data to on-site data, which are better. EPA should provide infor- mation on the sensitivity of modeling results to the use of NWS data versus on-site data. A couple of other comments recommended that meteorological data from other sources (companies, universities, FAA and military stations) should not be excluded if they are equivalent in accuracy and detail to NWS data, particularly if these sources are closer than the nearest NWS site. One commenter urged EPA to allow the continued use of off-site NWS data, at least until the numerous difficulties are resolved concerning the use of on-site data, (e.g., until turbulence data can be input directly into the model). (APCA, SOC, WCHD, ADHS, UARG, MCC) EPA Response A discussion of how mixing height is determined is available in the documents cited in the guideline and the report by Holzworth.52 EPA recognizes the expense involved in collecting and processing site- specific data and has allowed the use of NWS.data which are much less costly. The technical community has not performed a sensitivity analysis to determine model differences when using NWS versus on-site data and none has been presented for review by EPA. Site-specific data are preferred and 9-11 ------- should be used when available. Equivalent meteorological data sets such as those from Department of Defense or FAA, if appropriate, may be used in lieu of NWS data and text will be changed to reflect this comment response. EPA does not agree with the commenter's statement that there are unresolved difficulties concerning use of on-site data. EPA is continuing to develop techniques to improve the method of input of on-site data into the EPA models (e.g., the use of turbulence parameters directly into the model) and will issue guidance when these techniques have been adequately tested. 9.3.3 Site Specific Data Comment Summary (Alternate Stability Classes and Sampling Rates) A couple of commenters recommended that the guideline indicate that alternative stability categorization schemes can be used on a case-by-case basis. Stability determination made with turbulence intensity are not com- parable to, nor should be judged by, the subjective P-G-T method. A few commenters stated that the requirement of a sampling frequency of once per second (3600 per hour) presents significant memory requirements for monitoring stations that store many parameters since most data acquisition systems do not allow different sampling frequencies for different parameters. Not only is this requirement burdensome, but also it is unnecessary. Studies have shown that the sampling interval could be increased to up to 10 seconds without sacrificing more than one percent in the accuracy of sigma E calcula- tions, (APCA, SOC, UAR6) EPA Response EPA's research program has not yet resulted in recommending alternative stability categorization schemes such as classifying atmospheric dispersion directly from wind turbulence measurements, nor were such criteria recommended by the commenters. Until uniform criteria are developed and tested in a dispersion model, EPA preferred models continue to use the existing methods. However, the use of alternative stability categorization schemes in dispersion modeling is acceptable subject to an evaluation on a case-by-case basis. 9-12 ------- Criteria for such an evaluation are given in the Interim Procedures {please refer to comment responses in Section 3 dealing with "Implementation of New Models"). In response to the comments on sampling frequency, EPA is changing its guidance on data sampling frequency and averaging method and will modify the text accordingly. EPA recommends that the hourly standard deviation of the horizontal wind direction (sigma-A) be based on four 15-minute averages SO that the effect of plume meander can be accounted for. However, 360 samples are needed during each 15-minute period. According to the EPA workshop,53 "three hundred and sixty or more samples will estimate the hourly standard deviation within 5-10%." This is consistent with the results of other researchers. For the standards deviation of the vertical wind direction (sigma-E), EPA continues to recommend an hourly average with at least 360 samples; a higher frequency of sampling is encouraged. Comment Summary (Other Measurement Methods) One commenter suggested the use of doppler acoustic soundings as an acceptable method for determining wind parameters at stack height because the technology is proven and offers substantial cost and safety advantages over tall towers. Another recommended the use of net radiometer instruments for stability class determination. These instruments are reliable, correlate well with diural cycles and cloud cover and would best correlate with the Turner insolation method. One commented that guidance for instrument measure- ments for stability recommended for urban areas is lacking. One commenter recommended that all atmospheric dispersion model estimates should be corrected to standard temperature and pressure (STP) because the ambient air quality standards are given in terms of STP. It is a mistake not to recommend this correction for STP because, depending on elevation, not correcting modeled concentrations to STP would allow the ambient standards to be exceeded by between 10 and 30 percent. (CDH, UARG, NYCD) EPA Response Based on an evaluation of wind measurements by doppler sodar,54 £PA accepts the use of doppler sodar (subject to quality assurance requirements) 9-13 ------- to measure average wind speed and direction but not for determining sigma-A or sigma-E values. The use of net radiometer measurements a]one for determin- ing stability class is insufficiently tested; thus, it is premature to recommend the use of this method until further experience is gained. However, the use of these and other new methods of on-site meteorological measurements will be considered on a case-by-case basis. Guidance for determining atmos- pheric stability in urban areas is the same as that in rural areas. Given the manner in which the $02 ambient air quality standards are written, and to be consistent with the handling of monitoring data, some States have suggested that model estimates should be corrected to STP. From a historical standpoint, EPA has not recommended correcting model estimates to STP. However, if a State wishes to make the STP correction, EPA has no objections, since the State has the right to be more stringent than EPA. Comment Summary (Stability Classification Scheme) Several comments questioned the order of preferrence for the stability classification. One said that sigma-E measurements should not be placed above sigma-A as a means of calculating stability class given the difficulty and uncertainty involved in measuring sigma-E. Wind direction meander should not be presented as a significant problem with sigma-A measurements. Another recommended that all three sigmas be measured and used to independently classify both vertical and horizontal dispersion. Another objected to using the sigma-E method of determining stability categories because the stability class limits were not selected on the basis of any comparison between sigma-E values and Turner stability classes. Sigma-E values as recommended by EPA will often indicate category A stability conditions, but visual observations of power plant plumes during such hours reveal no tendency for behavior characteristics of category A conditions. EPA should not recommend this technique for determining stability classifi- cation until further comparisons and evaluations are conducted. One recommended that the preferred method of determining stability category should be changed in the order of site specific measurements used (e.g. change the order on page 9-17 so that number 3 is first, followed by 2, 1 and 4). Stability determined from on-site data should never be smoothed because this negates one of the main purposes of collecting on-site data 9-14 ------- which is to measure what actually occurs at the site. If those data are used for some other area, it is "off-site" for that application, and thus should be smoothed for that application. However, another comment recommended that stability data derived from on-site measurements should be smoothed in a manner consistent with the CRSTER preprocessor so that the stability class from hour to hour changes no more abruptly than by one class. Still another recommended a different order of preference than that given on page 9-17 (i.e. change the order so that number 1 is followed by 4, 2 and 3). On-Site information on cloud cover, etc. is almost never available and this in itself should not force the use of on-site data with nearby NWS data last in the order of preference since the latter method will give better representation of the categories than the. sigma-A or sigma-E methods. The sigma-A method is preferred because of familiarity, past use and improvements in monitoring. One stated that the EPA recommendation of a temporary program of stability class spot-checks of on-site data is futile since there is little correspondence between the various methods except possibly in the overall frequency distribution of the classes. Another comment asked that since Pasquill defined nighttime as the period from one hour before sunset to one hour after dawn, but Turner's algorithm defines nighttime as being between sunset and sunrise, which definition is appropriate. Also, since Pasquill based his work on the neutral hour (D) preceding and following nighttime while Turner classifies these hours as C, which procedure should be followed. (CDH, UARG, SOC, NCNR, NYEC, UOF) EPA Response Although both sigma-E and sigma-A are of importance in estimating the impact of point sources, sigma-E determines how near the source an elevated plume will have maximum impact and consequently the magnitude of that impact. To make estimates with the current models (which derive dispersion parameter values from a stability class), EPA gives emphasis to best estimating sigma-E rather than sigma-A. Therefore, methods closely related to vertical dispersion, i.e. Pasquill stability classification and vertical fluctuation measurements, are preferred over methods more closely related to horizontal dispersion, i.e. horizontal fluctuations. EPA does not present wind direct- ion meander as a significant problem with sigma-A measurements; only that wind direction meander must be considered in the calculation. EPA does not 9-15 ------- object to the measurements of all three sigmas on a case-by-case basis. How- ever, the use of these parameters for a split-sigma approach is not recommended, A preferred method for determining atmospheric stability is shown on new pages 9-21, 22 of the guideline. There is no need to compare statiblity class limi.ts between sigma-E values and Turner stability classes. EPA prefers classifying stability based on Turner's method using site-specific data. If those data are unavail- able, then EPA prefers three other schemes shown, in the order of preference, in the guideline. With respect to correlating the stability categories based on sigma-E with visual observations of power plant plumes, the comment neglected to mention whether or not these parameters were extrapolated to the same height. The conclusion reached by the comment may have resulted because of the change in parameters with height. EPA is not planning to change the preferrence order of determining stability category in the guideline for the reasons stated above. Also seen in the comments, the commenters are divided in their recommendations on a preferred method. With respect to the smoothing of hour-to-hour variations in stability as measured by sigma-A, EPA accepts smoothing of these variations so that the stability class from hour-to-hour changes no more abruptly than one class. This approach is comparable to that used for • determining P-G stability from cloud cover data. When measured sigmas are used as direct turbulence inputs to models (and stability class is not calculated), the actual hour-to-hour variations in turbulence should be used. Commenters1 recommendations are varied; it appears that there is no consistent recommendation for characterizing stability categories. EPA's rationale is still valid; the Pasquil 1-Gifford method is preferred, and 9-16 ------- methods based on on-site measurements are more preferred than those based on off-site data. EPA's research program on dispersion coefficients is designed to eliminate the need for determining stability classification entirely and instead use on-site turublence da'ta directly in the dispersion model. Thus, many of the difficulties noted by these comments will be overcome as future models become operational. The concept of a spot check is only a suggestion to ensure that data collected are of highest quality. The text in the guideline has been modified. As noted in the Workbook of Atmospheric Dispersion Estimates, EPA continues to apply the objective system of classifying stability from hourly meteorological observations based on the method published by Turner.55 EPA recommends that the stability class does not change by more than one class during each consecutive hour and therefore, the commenter's second argument is not recommended. Comment Summary (Wind Direction Meander) Several commenters said that it is inappropriate to eliminate the wind direction meander contribution to sigma-A. Such wind direction meander contributes to the effective horizontal dispersion of the plume but does not bear any relationship to the vertical dispersion. Use of split sigmas would eliminate this concern. Meander can be overcome by the use of micropro- cessors with sufficiently small sampling time, and running 5-minute averages summed and averaged over a one-hour period. However, another comment said that the standard averaging time for the determination of hourly average sigmas should be 15-minutes regardless of meander because these sigma ranges are based on experiments averaging 10 to 15-minutes. (APCA, SOC, NYEC, CONE) EPA Response Estimation of stability class from hourly sigma-A without eliminating meander will result in overestimation of the frequency of unstable stability classes especially classes A and B, resulting in increased frequencies of 9-17 ------- estimated large ground-level impacts from elevated sources. There is no long term meander in the vertical. That is why EPA is justified in recommend- ing this technique. EPA can not accept the recommendation to use split sigmas (please refer to response to comments in Section 8.2.4 dealing with "Split Sigma.") EPA recommends the use of four 15-min.ute averages to get an hourly average. The commenter did not supply any data to justify the use of a 5-minute averaging time to obtain an hourly average. The last comment to use only one 15-minute average is not practical because the models compute hourly averages. The issue of averaging times for sigma ranges was addressed in the response to comments in Section 8.2.3 dealing with "Averaging Period." Comment Summary (Miscellaneous) One commenter suggested that EPA clarify that the limitations on the possible stability categories in the footnotes of Tables 9-2 and 9-3 are necessary in order to ensure conformance of the sigma-method stability classes to the P-G classes. However, the occurrence of stable conditions during daytime hours is not uncommon in real situations such as in complex terrain. Another commenter said that the corrections to the Table 9-2 and 9-3 ranges for surface roughness considerations should not be based on the average roughness length. For situations with large roughness differences surrounding the site (e.g., river and forests) the use of average roughness can lead to erroneous stability cases. Thus the roughness correction should be made wind direction sector dependent. Furthermore, the roughness length should be determined within 1 km of the instrument tower and not within 1 to 3 km as recommended by EPA. One commenter said that the sigma-A and sigma-E stability classification schemes, as presented in Table 9-2 and 9-3 are inconsistent with respect to D stability during the day. If sigma-A is used and wind speed exceeds 6 m/s, then stability class D should be assumed. However, sigma-E has no dependence on wind speed, so if high wind speeds are observed during the day then stabiTl" class D will not automatically be assumed. The comment recommended that Table 9-2 for sigma-A be more clearly presented. (NYEC, MMES) EPA Response There are limitations to any method for deriving a stability class. The occurrence of stable conditions during daytime hours is possible during 9-18 ------- some situations. However, until another method is shown to be superior, EPA contiues to recommend the Pasquill-Gifford-Turner method for categorizing atmospheric stability which has been used for the last 15 years. EPA has recommended the use of surface roughness corrections because of previous public comment (please refer to pages 50-55 of the Summary of Comments and Responses J) The. procedure for determining the roughness correction for a given site is general and should be applied with care in situations where there are large roughness differences surrounding the site similar to those noted by the commenter. There is usually no need to make roughness correction dependent on the wind direction sector. However, such a determination may be made on a case-by-case basis. Determining roughness length within 1 km of the tower, as the commenter suggested, is unjustified since this distance is too short to allow the roughness modification to atmospheric flow from reaching a steady-state condition. A distance of 3 km is more appropriate (See reference 59 in the revised guideline). As to the inconsistency in the tables, the appropriate footnote has been revised to state that during the daytime, conditions are neutral for 10-m wind speed equal to or greater than 6 m/s. 9.3.4 Treatment of Calms Comment Summary One commenter suggested that EPA modify CALMPRO to make its final report easier to read when predicted concentrations from ISC are included. The final report should include the source group number and receptor location. Another suggested that software be modified to a cut-off speed less than or equal to 1 m/s to allow easy automation of the entire procedure. A couple of commenters asked EPA to clarify how wind direction Is treated. One asked why the assignment of wind direction is treated differently between on-site and NWS data! Another said that guidance should require a case-by-case evaluation any time wind speeds are less than 3 m/s. Another agreed with EPA's method when NWS data are used. A couple of commenters said that many periods of high observed air quality exceedances are observed during calm winds and disregarding calm 9-19 ------- winds during these periods is unrealistic. Another said that if the total number of noncalm hours is less than 18 for 24-hour averages, less than six for 8-hour averages, or less than three for 3-hour averages, concentrations determined for these periods should be disregarded. Another said that eliminating calm hours from consideration could lead to inadequate data recovery for some NWS data and that a better scheme is needed. EPA should allow the use of alternative procedures to determine hourly averages, such as subdividing the hour into shorter averaging times, if data are available. *i One commenter said that a definition of indeterminate should be included in the guideline (e.g., the wind direction should be defined indeterminate when the hourly average wind speed is below the response threshold of the wind vane). Another asked for more specific guidance for handling stagnation episodes rather than on a case-by-case basis. (AISI, WDNR, FDER, UARG, UOF, ADHS, APCA, NYEC, CDH). EPA Response The procedures which make up the CALMPRO processor for handling calms are being incorporated into the recommended EPA preferred models MPTER, CRSTER, RAM, and ISCST. As the commenter suggests, the calm treatment, as implemented in ISC, will be applied to the source and source group contri- butions as well as the total concentration. The various tables will be adequately labeled. Each of the four models is normally run using prepro- cessed (by RAMMET) NWS data. Calms are not explicitly identified in the RAMMET preprocessed data, since all calm cases are assigned, for modeling purposes, a speed of 1.00 m/s and a direction identical to that of the previous hour. The calms treatment takes advantage of this procedure to identify those hours which were originally calm. Specifically, any hour with a wind speed of exactly 1.00 m/s and wind direction identical to the previous hour is treated as calm. This procedure is not appropriate for on- site data. For these data, observations less than 1 m/s should be input as 1 m/s and the corresponding wind direction is used. EPA does not agree with the commenters statement that a case-by-case determination is needed whenever wind speed is less than 3 m/s. The definition of calm winds is 9-20 ------- related to the instrument threshold and most present day instrumentation has a threshold of 1 m/s. Gaussian models are not valid for calm conditions. Even though it may be physically unrealistic to disregard calm winds, as the commenter suggests, it is the only option available since there is no meaningful way to account for this condition. Until a satisfactory method is provided in the scientific literature, EPA will continue with the practice of disregarding model concen- trations when wind speeds are calm. EPA does not agree with the commenter who suggests deleting entire periods when less than the desirable amount of data exists. Data should be used whenever available. The commenter did not present any evidence to prove that the EPA method is incorrect. EPA agrees with the commenter that eliminating too much data from the record is undesire- able, however, all valid data should be used. The commenters suggestion to subdivide the hour into shorter averaging times, when such data are available, may be acceptable on a case-by-case basis. EPA agrees to incorporate the definition of indeterminate, that the commenter suggested, in the guideline. EPA is not aware of any model or analysis methodology available in the scientific literature that has been evaluated and demonstrated as being capable of handling stagnation episodes. The synoptic conditions and mesoscale circulations possible within a stagna- tion episode result in a truly complicated modeling problem. 9-21 ------- 10.0. ACCURACY AND UNCERTAINTY OF MODELS Comment Summary (Discussion of Accuracy/Uncertainty) Several commenters requested a clearer distinction between the accuracy and uncertainty of models. One commenter recommended that this discussion take place earlier in the guideline, i.e., Chapter 2, and that accuracy of models should be clearly documented. Other commenters asked for clarifica- tion of the effect of averaging time on accuracy and uncertainty associated with models since the reference provided (i.e., Hanna) was for hourly concentrations only. (APCA, CMA, MCC, NYEC) EPA Response The terms "uncertainty" and "accuracy," although not associated with precise definitions as applied to air quality models, have been defined in the guideline. They are frequently used interchangeably without objection by technical experts. Several workshops/conferences have been sponsored by EPA which dealt with these issues; a clear definition has not evolved. Generally, "accuracy" is a statistical expression of the results of com- paring estimates and observations, e.g., bias and scatter. "Uncertainty," which encompasses "accuracy," is a more general expression of those factors that influence "accuracy" and how much the resulting estimates depart from "truth." A clearer distinction in these terms does not appear possible at this time. Variations in model accuracy for various averaging times is well documented elsewhere (see discussion in Section 3.1 concerning "Basis for Model Selection") and there is not a need for further elaboration in the guideline. The Hanna reference in the chapter on model uncertainty re- fers to variations between estimates and observations for 1-hour estimates; extension to other averaging times is not intended by the guideline commentary. EPA has given careful consideration to the general discussion of model accuracy and its placement in the guideline text. Location earlier in the 10-1 ------- text and more extensive intertwining would be desirable. However, it was found that this major topic cuts across all techniques used and requires a separate chapter. Located elsewhere in the guideline text, it would interfere with the clarity of guidance on appropriate models and data bases for specific regulatory programs. Reports on the accuracy of each model included in the guideline are identified and referenced in the model summaries. Thus, further documenta- tion of model accuracy seems unnecessary at this time. Comment Summary (Performance Measures) Several commenters recommended that model evaluation schemes should be simplified and that statistical performance measures should be reduced, standardized and documented in the guideline. Emphasis should be on tests that evaluate performance at the high end of the concentration frequency distribution and redundant statistical tests should be eliminated. Two commenters felt the evaluation should focus on the design value, or second highest concentration. Other commenters suggested that emphasis should be given to (1) use of the entire frequency distribution, (2) use of the mean square error, (3) use of variance ratios and (4) use of confidence limits in uncertainty determination. One comment approved of EPA's model performance program but suggested that future model evaluations should include sources that have stack and processes different from a power plant. One comment suggested the use of empirical adjustments (calibration) to improve the fit between observed and predicted values and provide zero bias. (APCA, CMA, NYEC, PEPC, SOC, TACB) EPA Response EPA agrees that it would be desirable to propose simplified and standardized model evaluation schemes in the guideline. However, there has • not been sufficient experience with model evaluation at this time to provide such guidance in order to eliminate all redundancy. The AMS workshop on judg- ing models also suggested that it was premature to take such a step. Through additional guidance from the AMS and a variety of evaluation exercises EPA is beginning to focus on the usefulness of selected tests. These tests tend to be at the high end of the frequency distribution. However, tests 10-2 ------- for a wider range of concentrations including perhaps the entire frequency distribution may also be of use for some applications. Tests for the second- highest value have been used, but not to the exclusion of other analyses since they do not satisfy the criteria for robustness in statistical testing, Thus it seems prudent to await further experience from EPA's model evalution program, before standardized guidance is attempted. The mean square error is a powerful statistical test. However, it is based on paired observed and predicted concentrations and does not allow the type of comparisons suggested by other commenters and used by EPA for the upper end of the frequency distribution. Variance ratio analysis is another useful tool that would supplement, but not replace, other tests already being used. Confidence limits are available for use as a result of the model evaluation programs already completed. EPA agrees that models should be evaluated for point sources other than power plants and will consider such sources in future evaluations. The use of adjustment factors to reduce bias can not be recommended because of the arbitrary nature of such adjustments. Comment Summary (Use of Best Estimates) Several commenters recommended that decision-makers be allowed to depart from the "best estimate" and not be required to use conservative estimates which lead to inefficient controls and results in costs which are not proportional to the risks. One commenter requested that multi- point rollback and the ExEx methodology in setting emission limits be addressed in the guideline and their use be authorized. Another commenter questioned the use of inaccurate models where multiple sources are involved and where space and time comparisons are important because this will lead to holding the wrong source responsible. (API, DOE, SOC, UARG) EPA Response The purpose of the guideline is to develop the "best estimate" for use by the decision maker, i.e., the design concentration estimated by a model 10-3 ------- recommended in this guideline or an alternate model of known accuracy. However, given a lack of (1) substantial precedent, (2) proven techniques for quantifying uncertainty, (3) procedures for using uncertainty information, and also given the requirement for uniformity in Section 301 of the CAA, it is not likely that decision-makers will depart significantly from the best estimate. Multi-point rollback is a narrowly approved application to smelters and is not consistent with the more widely used techniques recommended in the guideline. The ExEx methodology, originally developed for large coal-fired power plants, appears to be inconsistent with the current deterministic form of the $62 standard and has never been approved by EPA. Thus, it does not appear appropriate to extend the use of either technique in the guideline. It is true that point source Gaussian dispersion models do poorly in space and time comparisons. As noted in Chapter 10 of the guideline, due to inherent uncertainty, it is unlikely that even a "perfect" model would do well for such comparisons. Thus, it does not appear that a change in preferred models would improve this deficiency. Where monitoring or other techniques show inaccurate estimates, the guideline (Chapter 11) allows for the use of alternate approaches to set emission limits. 10-4 ------- 11.0 REGULATORY APPLICATION OF MODELS 11 .1 Discussion Comment Summary (Receptor Models) One comment endorsed the use of receptor models to set emission limitations where meteorological dispersion conditions are difficult to characterize appropriately and where accurately and completely quantifying emissions is impossible. (AISI) EPA Response The use of receptor models to assess control strategies for particulate matter is discussed in the PM1Q SIP guideline.32 Like dispersion modeling, usefulness of receptor modeling is limited in the situations where the emission characteristics of an area are difficult to define. Properly applied, receptor models are most effective when used in concert with dis- persion models to provide important new information to regulatory agencies on an emissions inventory and on source specific impacts calculated by a dispersion model. Complete documentation and guidance on receptor models is provided in several EPA publications.56'60 11.2.1 Analysis Requirements Comment Summary (Selection of Significant Receptors) A few comments suggested the use of significant receptors rather than all receptors when remodeling sources. One of these questioned the need to model all previous receptor sites and suggested that it is sufficient to select just those receptors needed for a rigorous worst-case impact analysis. Another said that to require'applicants for PSD permits to model all receptors considered in previous permit applications when the sources are separated by an appreciable distance can result 1n far more receptors than is reasonable or necessary. The area of analysis should be restricted to that where the impact of the new source or modification is expected to be significant. Another recommended using a set of 400 receptors including significant, but not all, receptors from previous applications. A rn.miP of comments requested more specific guidance on what constitutes "all source' " ?eqS™ for PSD modeling because that will depend on location, s?ze Snd Expected impact. One said that much of the contribution from "all sources" is background. 11-1 ------- Another comment suggested that the guideline address the use of the significance levels for air quality impact as a screening procedure for ambient air quality analysis. For sources whose air quality impact is insignificant, no further analysis should be required to demonstrate compliance with the NAAQS or PSD increments. If a source impact is found to be less than the significance levels, an emission inventory for other sources in the area would not have to be developed nor additional modeling performed. (APCA, SOC, NYEC, UARG, CONE, ADEM) EPA Response Reasonable efforts to estimate the maximum impact of the new source, as well as the maximum impact, or increment used, of all sources considered, are necessary. However, guidance on subjective judgment of what receptors to use cannot be recommended in a regulatory program because of ambiguity in defining what is significant. EPA recommends early discussion between the applicant and regulatory control agencies. Selecting receptors based on a worst-case modeling analysis alone is not recommended because screening models do not require wind data which determines the location of the most heavily affected receptors. When refined models are subsequently used, the area of maximum impact may well be different and the coincident area of maximum impact of the source with other nearby sources will vary. The complexity of selecting appropriate receptors in PSD applications is acknow- ledged by EPA and the guideline has provided a general direction to allow for a reasonable amount of flexibility. Further explanation of EPA's rationale is found on page 99-102 of the Summary of Comments and Responses.1 • "All sources" generally refers to those which have been included in previous PSD analyses and for which joint impact with the new source is possible. The sources considered will depend on their location relative to the source being modeled. Therefore, good judgment in selection of sources and receptors and the early discussion with control agencies referenced 11-2 ------- above are required. The contribution from all other sources not explicitly considered could be classified as background. However, as the number of "background" sources contributing to use of the PSD increment grows, their impact should be explicitly considered (See Section 9.1 and specifically Table 9-1 of the revised guideline on how to mode] "nearby" background sources vs. "other" background sources). Careful consideration must be given to the problem and a case-specific analysis conducted, as appropriate. There is no need to address significant levels for air quality impact because they are already identified elsewhere in regulations dealing with PSD, bubbles, etc. Screening models can be used to estimate impact of a specific source, or source category, on the significance levels, as appropriate (Refer to Chapter 2 of the guideline). No further analysis is required if the screening showed that the source impact is below the significance level. When multi-source impacts are involved, screening techniques may be of limited utility. EPA recommends remodeling all sources with each new application, unless the State has an increment tracking procedure which would make this unnecessary. 11.2.2 Use of Measured Data in Lieu of Model Estimates Comment Summary (Reliance on Measured Data) A few commenters recommended that for existing sources which already have ambient monitoring networks meeting EPA requirements actual measurements should be Preferred over model estimates. One year of ambient monitoring at a Kiel's m x mum impact point should be adequate One stated that EPA has relected certain air quality analyses because of the design of the monitoring network Another requested guidance on how monitor siting should be performed toTocaie £1^0? 2«1mum impact if a model. Is not appropr ate to a specific aoo ication Another said that the proposed requirement to identify the most impo tanl JndividuaTsources as a condition for using measured data cannot be met In urbl!I areas and recommended deleting criteria (d) from page 11-5. Another commenter said that the States are nearly equally divided on the questtS;^whether both air quality data and modeling or Jir quality data alone should be used for determining attainment status. Should EPA begin 11-3 ------- requiring air quality modeling as part of the attainment demonstration, it is clear that many areas will have^ to be modeled which have not been scrutinized previously using that procedure. One comment asked EPA to define a "regional site" which can be used when there are no monitors in the vicinity of an isolated single source. (MSUS, APCA, MCC, CONE, OEPA) EPA Response Where models are available and appropriate, modeling is the preferred method for determining emission limitations, consistent with Clean Air Act requirements. In some cases when the modeling technique available is only a screening technique, the addition of air quality data to the analysis may lend credence or replace model estimates. Suitable criteria are provided in Section 11.2.2 of the guideline. The design of the air quality monitoring network can be questioned if there are not sufficient monitors present, if the monitors are not located in areas that are likely to include the maximum impact for the various pollutants and emission sources or if the monitoring period is short or unrepresentative of typical meteorological conditions; modeling with multiple years of data provides a superior set of information. However, if monitoring data show a value higher than the modeled value, the monitoring data should be used if the source inventory is proven to be correct. There is no basis for deleting item (d) because the analysis must allow impact of the most important individual sources to be identified, if more than one source or emission point is involved. The use of monitor siting to locate points of maximum impact is a highly subjective procedure for which EPA does not propose guidance. However the location of those monitors must be based on information developed from prior monitoring, preliminary model estimates, experience, etc.; the other alternative is to establish a comprehensive network which allows the maximum site to be bracketed. 11-4 ------- EPA acknowledges that identifying the most important individual sources in an urban area is difficult and case-by-case discussion with the Regional Meteorologist is needed. This identification, however, is not impossible as the commenter implies since techniques such as tracer gas, receptor analysis, etc. could be used. It is current EPA regulatory policy that redesignation from nonattainment to attainment, requires valid air quality data showing no NAAQS violations and must be supplemented with a demonstration that an approved SIP control strategy which provides for attainment has been implemented. Where only the most recent four quarters of data showing attainment are available, a state- of-the-art modeling analysis must be provided which quantifies that the SIP strategy is sound and that actual enforceable emission reductions are responsible for the air quality improvements. It is not anticipated that the promulgation of the guideline will result in the need for new air quality modeling demonstrations. The definition of a background regional site is given on page 9-8 of the guideline and should represent (1) the impact of all sources not modeled because of small size, and (2) natural background concentrations. 11.2.3 Emission Limits Comment Summary (Miscellaneous) One comment stated that the guideline recommends that the averaging time for the design concentration be determined from the ratio of predicted concentration (P) plus background (B) to the applicable NAAQS(s). The averaging time with the highest ratio (P+B)/S identifies the most limiting emission standard for large multi-source areas and not for a.single source. The limiting emission standard for a single source is determined by calcu- lating (S-BJ/P for each averaging time and setting the emission standard from design concentration that minimizes this ratio. 11-5 ------- One comment suggested deleting the "temporal and spatial" modeling procedures for PSD but supported thisjjse for the emission trading policy. Another stated the method for calculating the PSD increment consumption is not clearly stated and should not require the use of sequential modeling. The comment suggested the use of screening models for this application. One comment stated that with the exception of ozone, there is no provision in the regulations which allows consideration of the frequency with which NAAQS are exceeded over a number of years in determinations of compliance and the statement on paragraph 2 should be clarified. (APCA, FDER, MMES, NYEC). EPA Response 40 CFR Part 51 .13(e)(2)(i) defines the following equation to determine the fractional reduction needed to attain a standard: (P+B)-S. The S-B ~P T" formula cited by the commentors is the fraction of emissions which will yield attainment and is calculated simply by taking 1 minus (reduction formula). Thus, the constraining standard is that which results in the maximum degree of reduction (or, conversely, the minimum S-B ratio). The text in the P guideline will be changed accordingly. The methodology for spatial and temporal calculation of PSD increments is consistent with EPA's interpretation of the Clean Air Act and definition of increment and baseline concentrations in the PSD regulations. The methodology is also consistent with the manner in which the total concentra- tion is calculated for comparison with ambient standards and is consistent with the method used to calculate incremental concentrations for Level II emissions trades. The application of screening models has been addressed elsewhere in the guideline. In addition, screening models are used for individual sources, not when multiple increment-consuming sources are involved. Paragraph 2 in this section of the guideline has been changed to reflect the commenters clarification. 11-6 ------- APPENDIX A. SUMMARIES.OF PREFERRED AIR QUALITY MODELS A.O INTRODUCTION Comment Summary One commenter suggested that EPA identify what changes or revisions have been made to the models listed in Appendix A. Another disagreed with the statement in the introductory paragraph and said that very little cost .information is provided, and very little information on accuracy, other than what is identified in Section 10, is presented. One commenter suggested that EPA provide a "hardwired" optional version of each recommended model as part of the next UNAMAP distribution. Another recommended that UNAMAP models be modified to allow for computation of both geometric and arithmetic annual averages to correspond to the appropriate NAAQS. (TEXA, MES, MMES) EPA Response Changes and additions to models listed in Appendix A will be clearly indicated in supplements to user's guides for these models. It is unclear. what cost information the second commenter is referring to. The reference to cost in the introductory paragraph of Appendix A refers to the cost of obtaining the model and is given wherever the model developer provided that information. The accuracy of the various models is indicated by reference to the model validation studies listed in section "n" of each model summary description. Any further documentation would be redundant. EPA is planning to develop a hardwired regulatory option in each recommended EPA model as part of the next UNAMAP distribution (Version 6). The suggestion to allow computing geometric averages will not be implemented since this value can be approximated by using assumptions about the frequency distribution of the concentrations. A.2 CALINE3 Comment Summary One commenter stated that the listing of the TEXIN model publication (Messina, et al.) in the CALINE3 model description section is confusing. A-l ------- Further, the Texas work is based on a modified version of CALINE3 which is not generally available. A separate section dealing with the TEXIN model was suggested. (DOT) EPA Response EPA will reword the description of the CALINE3 model and delete the reference to TEXIN (please refer to comment responses in Section 6.2.2 dealing with "Models for Carbon Monoxide"). A.4 RAM Comment Summary One commenter recommended that an option be included to allow the user to position a polar grid of receptors around a specific coordinate as is allowed in the MPTER model. Another noted that the model description refers incorrectly to the RAM model's application to rolling terrain and fails to mention the output of annual average concentrations.(MMES, NYEC) EPA Response EPA believes that the present treatment of receptor locations is adequate because receptors can be placed at any location chosen by the user. EPA does not plan to implement the commenters suggestion due to the substantial modi- fication of the model code that would be required. Also, EPA will eliminate the reference to rolling terrain in the RAM model description, since RAM only treats flat terrain, and will add a note to the model description that the model prints out annual average concentrations. A.5 ISC Comment Summary One commenter recommended that no receptor elevations be input into ISC while the effects of building downwash are being simulated. It is further recommended that ISC be explicitly restricted to flat terrain because it is overly conservative in terrain less than stack height. Another suggested that ISC be modified 1) to accept receptor locations with both coordinates for each receptor input together, 2) to treat building orientation relative to the wind direction, and 3) to automatically truncate terrain to stack A-2 ------- height as recommended by EPA for certain situations. The last three suggest- ions are labor saving changes, and do not affect the resulting concentration estimates. (WDNR) EPA Responses Since the Huber and Snyder downwash algorithm used in ISC only increases plume size and does not lower plume center!ine height, EPA believes that it is reasonable to allow treatment of elevated receptors. EPA does not agree with the commenters claim that the ISC model is overly conservative and the commenter provided no data to support this claim. The American Petroleum Institute has asked EPA to allow the use of a modified ISC downwash algorithm because the present algorithm underpredicts concentration for sources with short stacks. EPA will implement two of the recommended modifications in the next revision of the UNAMAP models (Version 6). EPA will propose in a Federal Register notice changes to the ISC model which will allow orientation of the building with respect to the wind to be accounted for in building downwash calculations. A.6 MPTER Comment Summary One commenter suggested that the MPTER output be formatted to display the input data with more significant digits, corresponding to the input data format. Another suggestion was that the user be permitted to specify pollutants in addition to S02 and particulates to improve readability of the model printout. Also, it was suggested that MPTER gets a 366 day matrix like CRSTER and ISCST so that the user could select the days to be modeled from a year of data Another commenter noted that MPTER prints out annual concen- trations and that this should be noted in the model description. (MMES, NYEC) EPA Responses EPA will change the MPTER output format as suggested by the commenter. EPA believes the suggestion to specify additional pollutant names is not A-3 ------- v/orthwhile. MPTER can currently be run for any continuous period from one hour to one year and no modification to allow an individual day to be specified is necessary. EPA does not plan to add the 366 day matrix because this will require a substantial coding modification to the model. EPA will correct the model description to reflect that MPTER prints out annual concentrations as the last comment suggested. A-4 ------- APPENDIX B. SUMMARIES OF ALTERNATIVE AIR QUALITY MODELS B.3 APRAC-3 Comment Summary One commenter noted that APRAC-3 cannot use data output from the Urban Transportation Planning System (UTPS) travel forecasting models currently used by many states, the comment also noted the lack of evaluation studies and suggested EPA consider deleting APRAC-3 as an alternative model. (FHA) EPA Responses EPA agrees that there is a continuing strong need for coordination in modeling and evaluation activities among transportation and air quality planning efforts at the State, local and federal levels. Where a metropo- litan area or a State is using the UTPS or other transportation modeling package, and is seeking to perform air quality analyses, EPA is more than willing to work with the appropriate agencies and FHWA to resolve any specific analytical difficulties on a case-by-case basis. The inclusion of a model in Appendix B of the guideline does not constitute a recommendation for its use, nor does it imply that the model has been evaluated. If a user wishes to substitute a model from Appendix B for a recommended model, the request for the substitution to be permitted must be supported with appropriate validation studies, as described in Section 3.2 of the guideline. B.9 IMPACT (Sklarew) This model has been withdrawn at the request of the model developer. B.I 2 MESOPLUME This model has been withdrawn at the request of the model developer. B.I8 Multi-Source (SCSTER) Model Comment Summary Several corrections to the description of the SCSTER model were supplied by its developer. (SCS) B-l ------- EPA Response These corrections will be made to the model description. B.24 RTDM (Version 3.00) This model has been withdrawn at the request of the model developer. B-2 ------- REFERENCES 1. Environmental Protection Agency, 1984. Summary of Comments and Responses on the October 1980 Proposed Revisions to the Guideline on Air Quality Models. U.S. Environmental Protection Agency, Research Triangle Park NC. (Docket A-80-46, Reference No. II-G-5). 2. Environmental Protection Agency, 1978. Guideline on Air Quality Models. EPA Publication No. EPA 450/2-78-027. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 288-783). 3. Environmental Protection Agency, 1982. Regional Workshops on Air Quality Modeling: A Summary Report. EPA Publication No. EPA 450/4-82-015. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 83-150573). 4. Environmental Protection Agency, 1984. 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(NTIS No. PB 85-244135) > 17. Bowne, N. E. and R. J. Londergan, 1983. Overview, Results and Conclusions for the EPRI Plume Model Validation and Development Project: Plains Site. EPRI EA-3074. Electric Power Research Institute, Palo Alto, CA. 18. Moore, G. E., T. E. Stoeckenius and D. A. Stewart, 1982. A Survey of Statistical Measures of Model Performance and Accuracy for Several Air Quality Models. EPA Publication No. EPA-450/4-83-001. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 83-260810). 19. Consolidated Edison Company, 1985. Written Comments on the November 1984 Draft Revision of the Guideline on Air Quality Models, p. 8. (Docket , Reference No. IV-D-40). 20. Fox, D. G., 1981. Judging Air Quality Model Performance. Bulletin of the American Meteorological Society, 62(5) :599-609. 21. Environmental Protection Agency, 1985. Interim Procedures for Evaluating Air Quality Models: Experience with Implementation. EPA Publication No. EPA-450/4-85-006. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 85-242477). 22. Environmental Protection Agency, 1981. Guideline for Fluid Modeling of Atmospheric Diffusion. EPA Publication No. EPA-600/8-81-009. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 81-201410). R-2 ------- 23, 24. 25. 26. 27. Environmental Protection Agency, 198S. Guideline for Determination of Good Engineering Practice Stack Height (Technical Support Document For the Stack Height Regulations), Revised. EPA Publication No. EPA 450/4- 80-023R. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 85-225241). » Environmental Protection Agency, 1981. Guideline for Use of Fluid Modeling to Determine Good Engineering Practice (GEP) Stack Height. EPA Publica- tion No. EPA-450/4-81-003. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 82-145327) American Meteorological Society, 1981. Air Quality Modeling and the Clean Air Act: Recommendations to EPA on Dispersion Modeling for Regula- tory Applications. Boston, MA. Sethu Raman, S., 1985. Analysis and Evaluation of Statistical Coastal Fumigation Models. Final Report Submitted to Office of Air Quality Planning and Standards, Environmental Protection Agency, Research Triangle Park, NC. Schiermeier, 1983. Preprints, 6th Lavery, R. F., B. R. Greene, B. A. Egan, and F. A. The EPA Complex Terrain Model Development Program. ., »r. , „„ Symposium on Turbulence and Diffusion, March 15-22, 1983, Boston, Massachusetts. American Meteorological Society, Boston. 28. Schiermeier, F. A., T. F. Lavery, D. G. Strimaitis, A. Venkatram, B. R. Green and B. A. Egan, 1983. EPA Model Development for Stable Impingement on Elevated Terrain Obstacles. Proceedings, 14th International Technical Meeting on Air Pollution Modeling and Its Applications, Copenhagen, Denmark 29 Environmental Protection Agency, 1984. Guideline for Using the Carbon Bond Mechanism in City - Specific EKMA. EPA Publication No. EPA 450/4- 84-005. (NTIS No. PB 84-198910). ?n YnrkP M A ?t al Evaluation of Short-Term N02 Plume Models for Point Souses EPA Publication No. EPA-600/4-81-079. U. S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 82-234329) 31. Environmental Protection Agency, 1985 Compilation of Air Pollutant Emission Factors Fourth Edition. EPA Publication No. AP-42. U.S. Environmenta? ?rotation Agency, Research Triangle Park, NC (NTIS No. PB-275525). 32. Environmental Protection Agency, 1984. PM10 SIP Development Guideline. D?aft for Public Comment. U.S. Environmental Protection Agency, Research Triangle Park, NC. 33< r_..,- *,i D.m-ortinn Aaencv, 1985. Control Technology for Sources Contra?; No. ea-oHaSi: U.S. Environmental Protection Agency, Research Triangle Park, NC. R-3 ------- 34. Environmental Protection Agency, 1981. An Evaluation Study for the Industrial Source Complex (ISC) Dispersion Model. EPA Publication EPA-450/4-81-002, U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 81-176539). 35. Environmental Protection Agency, 1985. Dispersion of Airborne Particulates in Surface Coal Mines, Data Analysis. EPA Publication EPA 450/4-85-001, U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 85-18b411). 36. TRC Environmental Consultants, 1985. Continued Analysis and Derivation of a Method to Model Pit Retention. Draft Final Report for U.S. Environ- mental Protection Agency, Research Triangle Park, NC. 37. Engineering-Science, 1980. Field Validation of Atmospheric Dispersion Models for Natural Gas Compressor Stations. Final Project Report Prepared for Pipeline Research Committee of the American Gas Association Engineering-Science, Arcadia, CA. 38. Turner, D. B. and J. S. Irwin, 1982. Extreme Value Statistics Related to Performance of a Standard Air Quality Simulation Model Using Data at Seven Power Plant Sites. Atmospheric Environment 16:1907-1914. 39. Turner, D. B. and J. S. Irwin, 1985. The Relation of Urban Model Performance to Stability. Proceedings 14th International Technical Meet- ing on Air Pollution Modeling and Its Applications, Copenhagen, Denmark. 40. Turner, D. B., J. S. Irwin, and A. D. Busse, 1985. Comparison of RAM Model Estimates with 1976 St. Louis RAPS Measurements of Sulfur Dioxide. Atmospheric Environment 19(2):247-253. 41. Department of the Interior, Minerals Management Services, 1985. Oil and Gas and Sulfur Operations in the Outer Continental Shelf, 30 CFR Part 250. Federal Register, 50(60):12248-12249. 42. Bjorklund, J. R. and J. F. Bowers, 1982. User's Instructions for the SHORTZ and LONGZ Computer Programs. EPA Publication Mo. EPA-903/9-82- 004a,b, U.S. Environmental Protection Agency, Region III, Philadelphia, PA. 43. Cramer, H. E., Company, Inc., 1982. Tests of the Briggs (1974) and Cramer, et al. (1975) stack-tip downwash corrections and the Schulman and Scire (T9"80) Building Downwash Correction using the Huber, et al. (1980) Data Set. Technical Note, H. E. Cramer Company, Inc., SaTtTake City, UT. 44. Briggs, G. A., 1974. Diffusion Estimates for Small Emissions, in ERL, ARL, USAEC Report ATDL-106. U.S. Atomic Energy Commission, Oak Ridge, I n« 45. Bringfeld, B., 1968. Plume Rise Measurements at Industrial Chimneys. Atmospheric Environment, 2(6):575-598. R-4 ------- 46. Huber, A. H. and W. H. Snyder, 1976. Building Wake Effects on Short Stack Effluents. Preprint Volume for the Third symposium on Atmospheric Turbulence, Diffusion and Air Quality, Americam Meteorological Society, Boston, MA, pp. 235-242. 47. Bowers, J. F., J. R. Bjorklund, and C. S. Cheney, 1979. Industrial Source Complex (ISC) Dispersion Model User's Guide, Volume 1. EPA Publication No. EPA-450/4-79-030. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 80-133044). 48. Schulman, L. L. and J. S. Scire, 1980. Bouyant Line and Point Source (BLP) Dispersion Model User's Guide. ERT Document No. P-73Q43, Envir mental Research & Technology, Inc., Concord, MA. 50. 51 52. 53. 54. 55. ron- 49. Cramer, et al., 1975. Diffusion Model Calculations of Long-term and Short-term Ground-level S02 Concentrations in Allegheny County, Penn- sylvania. EPA Publication No. EPA-903/9-75-018. U. S. Environmental Protection Agency, Region III, Philadelphia, PA. (NTIS No. PB 245262), Environmental Protection Agency, 1982. Evaluation of Rural Air Quality Simulation Models, Appendix G, Statistical Tables for PPSP. EPA Publica- tion No. EPA 450/4-83-003. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 83-182758). Petersen, W. B. and J. S. Irwin, 1985. Climatological Variability in Modeled Maximum Concentrations. Atmospheric Environment, 19(5): 739-742. Holzworth, G. C., 1972. Mixing Heights, Wind Speeds, and Potential for Urban Air Pollution Throughout the Contiguous United States. Office of Air Programs Pub. No. AP-101. U.S. Environmental Protection Agency, Research Triangle Park, NC. Strimaitis, D., G. Hoffnagle and A. Bass, 1981. On-Site Meteorological Instrumentation Requirements to Characterize Diffusion From Point Sources: Workshop Report. EPA Publication No. EPA 600/9-81-020. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 81-247223). Kaimal, J, C., J. E. Gaynor, P. L. Finkelstein, M. • ' wind Measurements Evaluation of U.S. Department of Commerce, E. Graves, and T. J. by Four Doppler Sodars. NOAA, Boulder Atmospheric Lockhart, 1984. An Report Number Five. Observatory, CO. Turner D B 1961. Relationships Between 24-Hour Mean Air Quality Measurements and Meteorological Factors in Nashville, TN. JAPCA, 11: 483-489, 56 Environmental Protection Agency, 1981. Receptor Model Technical Series VolumeT Overview of Receptor Model Applications to Particulate Source Apportionment? EPA Publication No. EPA-450/4-81-016a. U.S. Environmental P?o?ect°on Agency, Research Triangle Park, NC. (NTIS No. PB 82-139429). R-5 ------- 57. Environmental Protection Agency, 1981. Receptor Model Technical Series Volume II: Chemical Mass Balance. EPA Publication No. EPA 450/4-81-016b. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 82-187345). 58. Environmental Protection Agency, 1983. Receptor Model Technical Series Volume III: User's Manual for Chemical Mass Balance Model. EPA Publica- tion No. EPA 450/4-83-014. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 83-264622). 59. Environmental Protection Agency, 1983. Receptor Model Technical Series Volume IV: Summary of Particle Identification Techniques. EPA Publica- tions No. EPA 450/4-83-018. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 84-103340). 60. Environmental Protection Agency, 1983. Receptor Model Technical Series Volume V: Source Apportionment Techniques and Considerations In Combin- ing Their Use. EPA Publication No. EPA 450/4-84-020. U.S. Environmental Protection Agency, Research Triangle Park, NC. (NTIS No. PB 84-241173). R-6 ------- GLOSSARY OF COMMENTERS APPEARING IN DOCKET A-80-46 Abb. Commenter Docket Number OKIG Ohio-Kentucky-Indiana Regional Council of Govt. IV-D-1 WDNR Wisconsin Department of Natural Resources IV-D-2 DOT Department of Transportation, Division of Engineering Services IV-D-3 WCHD Wayne County Health Department Air Pollution Control Division IV-D-4 ADHS Arizona Department of Health Services IV-D-5 CDH Colorado Department of Health IV-D-7 NDDH North Dakota State Department of Health IV-D-8 MMS Minerals Management Service IV-D-9 ISBH Indiana State Board of Health IV-D-10 GMC General Motors Corporation IV-D-11 NYDOT New York Department of Transportation IV-D-12 UARG Utility Air Regulatory Group ITV"?"IJ EPNG El Paso Natural Gas Company IV-D- 5 CC Cabot Corporation Ij-D- 6 FHA US Department of Transportation, Federal iv-u-i/ Highway Administration SOC Standard Oil Company (Indiana) },, ~5~ ix CDOT California Department of Transportation IV-D-20 PSCN Public Service Company of New Mexico IV~P~™ SCS Southern Company Services \lnll ADEM Alabama Department of Environmental Management IV-D-25 AISI American Iron and Steel Institute \l~n £ UARG Utility Air Regulatory. Group TunoQ API American Petroleum Institute IV-D-28 AMC American Mining Congress T\/ n ™ CMA Chemical Manufacturers Association IV-D-30 MCC Magma Copper Company TJ n ?i MMES Martin Marietta Environmental Systems IV-D-32 OEPA Ohio Environmental Protection Agency IV-D-33 ^r^a^ent of Natural Resources 1^35 IPL Indianapolis Power and Light Company IV-D-36 PEPC Potomac Electric Power Company iv-u-j/ NYEC New York Department of Environmental Conservation V-D-38 PENE Pennsylvania Electric Company |V-u-jy CONE Consolidated Edison Company of New York V-D-40 KC Kennecott Copper TV D 42 CHEV Chevron, USA < TV n d^ MSUS Middle South Utilities iv-u-ij G-l ------- Abb. Commenter Docket Number DOE Department of Energy IV-G-7 TVA Tennessee Valley Authority IV-G-8 NYEC New York Department of Environmental Conservation IV-G-10 NCNR North Carolina Department of Natural Resources and Comm-unity Development IV-G-11 FDER Florida Department of Environmental Regulations IV-G-12 TAC3 Texas Air Pollution Control Board IV-G-13 APCA Air Pollution Control Association IV-G-14 UARG Utility Air Regulatory Group IV-G-15 ERT Environmental Research & Technology IV-G-17 API American Power Institute IV-G-18 CMA Chemicals Manufacturers Association IV-G-19 DS Diamond Shamrock/Texas Chemical Council IV-G-20 PEPC Potomac Electric Power Company IV-6-21 MES Meteorological Evaluation Services, Inc. IV-G-22 KC Kennecott Copper IV-G-23 NRDC Natural Resources Defense Council IV-G-24 G-2 ------- Abb. Commenter Docket Number ODEQ Oregon Department of Environmental Quality IV-H-1 TEGP Texas Eastern Gas Pipeline Company IV-H-2 WC Weyerhaeuser Company IV-H-3 CITG Citgo Petroleum Corporation IV-H-4 PHC Peabody Holding Company IV-H-5 BAAQ Bay Area Air Quality Management District IV-H-6 TEXA Texco Inc. . IV-H-7 ASRC Atmospheric Science Research Center IV-H-8 NCA National Coal Association IV-H-9 CITG Citgo Holding Company IV-H-10 UOF University of Florida IV-H-11 IEPA Illinois Environmental Protection Agency IV-H-12 JCPL Jersey Central Power & Light Company IV-H-13 DS Diamond Shamrock IV-H-14 PPL Pennsylvania Power & Light Company IV-H-15 KOCH Koch Refining Company IV-H-16 SRP Salt River Project IV-H-17 CARB California Air Resources Board IV-H-18 NYCP City of New York Dept. of Environmental Protection IV-H-19 TVA Tennessee Valley Authority IV-H-20 UARG Utility Air Regulatory Group IV-H-21 OEPA Ohio Environmental Protection Agency IV-H-22 ARCO ARCO Petroleum Products IV-H-24 CONE Consolidated Edison Company of New York IV-H-25 UARG Utility Air Regulatory Group IV-H-26 OEPA Ohio Environmental Protection Agency IV-H-27 6-3 ------- |