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

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                           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

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           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

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           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

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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

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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

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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.

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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
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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.
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     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

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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.
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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
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"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
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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

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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
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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
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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
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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

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 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
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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





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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


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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

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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.
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      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
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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
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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.
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     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.
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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

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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
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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.

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     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.
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     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.
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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
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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


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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
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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.
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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
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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


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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.
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     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
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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

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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)
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     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.
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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

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 (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)

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     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
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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.
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     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
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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
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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

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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.
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     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.
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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

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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.
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     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)
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     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

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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
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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
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 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
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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

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     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

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     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.
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      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.
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  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-

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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
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 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-
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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.
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     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.
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     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.
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     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.
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     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

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      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

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     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

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     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.

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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,
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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

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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

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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

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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

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      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

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     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.
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     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.^
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 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


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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
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 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

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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

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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

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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
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 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."
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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*
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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-
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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
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 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
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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.

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 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)
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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


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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
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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
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 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

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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


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 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

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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
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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.
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 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

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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

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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

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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.
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 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

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     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

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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

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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

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      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.
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     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

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 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

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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

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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

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     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

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  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.  Interim  Procedures for Evaluating
      Air Quality Models  (Revised).   EPA Publication No.  EPA 450/4-84-023.   U.S.
      Environmental  Protection Agency, Research  Triangle  Park, NC. (NTIS No.
      PB 85-106060).

  5.  Environmental  Protection Agency, 1981 .  Model  Clearinghouse:   Operational
      Plan.   Staff Report.   U.S.  Environmental Protection  Agency, Research
      Triangle  Park, NC.   (Docket Reference  No.  II-G-6).

  6.  Environmental  Protection Agency,  1980.  Guideline on  Air Quality Models.
      Federal Register, 45(61): 20157-20158.

  7.  Environmental  Protection Agency,  1983.  User's Network  for Applied
      Modeling  of  Air Pollution (UNAMAP), Version 5  (Computer  Programs on Tape).
      National  Technical  Information  Service, Springfield,  VA. (NTIS No. PB
      83-244368) .

  8.  Londergan, R.  J., D. H.  Minott,  D. J. Wackter, T. Kincaid and D. Bonitata,
      1982.   Evaluation of Rural  Air  Quality Simulation Models.  EPA Publication
      No. EPA-450/4-83-003.  U.S.  Environmental  Protection Agency, Research
      Triangle  Park, NC.  (NTIS No. PB 83-182758).

  9.   Londergan, R. J., D. H.  Minott, D. J. Wackter and R. R. Fizz,  1983.
      Evaluation of  Urban Air  Quality Simulation  Models.  EPA Publication No.
      EPA-450/4-83-020.   U.S.  Environmental  Protection Agency, Research Triangle
      Park, NC.  (NTIS No. PB 84-241173).

10.   Londergan, R. J. and D. J. Wackter, 1984.   Evaluation of Complex  Terrain
     Air Quality Simulation Models.   EPA Publication No.  EPA-450/4-84-017.   .
      U.S. Environmental   Protection Agency,  Research Triangle Park, NC.  (NTIS
      No. PB 85-119485)
American Meteorological  Society, 1983.   Synthesis  of the  Rural  Model
Reviews   EPA Publication No.  EPA-600/3-83-108.   U.S.  Environmental
tect ion 'Agency, Research Triangle Park,  NC.  (NTIS  No.  PB  84-121037).
11
                                                                         Pro-
                                     R-l

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12.  American Meteorological Society, 1984.  Review of the Attributes and
     Performance of Six Urban Diffusion Models.  EPA Publication No.  EPA 600/S3-
     84-089.  U.S. Environmental Protection Agency, Research Triangle Park, NC,
     (NTIS No. PB 84-236850).

13.  White, F. D., Ed., and J. K. S. Ching, R. L. Dennis and W. H. Snyder, 1985.
     Summary of Complex Terrain Model Evaluation,  EPA Publication No. EPA 600/
     3-85-060.  U.S. Environmental Protection Agency, Research Triangle Park, NC.
     (NTIS No. PB 85-236891).

14.  Cox, W. M., and J. A. Tikvart, 1985.  Assessing the Performance Level of
     Air Quality Models,  Paper presented at the 15th International  Technical
     Meeting on Air Pollution and Its Application, NATO/CCMS, St.  Louis, MO.

15.  Cox, W. M., G. K. Moss, E. Baldridge, and J. A. Tikvart, 1985.   Evaluation
     of Rural  Air Quality .Simulation Models, Addendum B:  Graphical  Display of
     Model  Performance Using the Clifty Creek Data Base.  EPA Publication No.
     EPA-450/4-83-003b.  U.S. Environmental Protection Agency, Research Triangle
     Park,  NC.

16.  Cox, W. M., and G. K. Moss, 1985.   Evaluation of Rural  Air Quality
     Simulation Models, Addendum A:   Muskingum River Data Base.  EPA Publica-
     tion No.  EPA-450/4-83-003a.  U.S.  Environmental Protection Agency,
     Research  Triangle Park, NC. (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

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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

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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

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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

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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

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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

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 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

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