Summary of Comments and Responses  on  the September 1986
Supplemental  Proposal  to Revise the Guideline  on  Air Quality Models
                             April  1987
                  Source Receptor  Analysis  Branch
               Monitoring and Data Analysis Division
            Office of Air Quality  Planning  *ȣ  Standards
                  Environmental  Protection  Agency

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                            Table of Contents

Summary of Comments and Responses on the September 1986 Supplemental  Proposal
              to Revise th*1 Guideline on Air Quality Models

                                                                     Page
  I.  Introduction	«	    1
 II.  Rough Terrain Diffusion Model  (RTDM) - Model Status 	    4
III.  Rough Terrain Diffusion Model  (RTDM) - Data Input 	   13
 IV.  Industrial Source Complex (ISC) Model 	   17
  V.  Offshore and Coastal Dispersion (OCD) Model	   23
 VI.  AVACTA II Model 	   27
VII.  References 	   28
      Appendix A
      Appendix B

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I.  Introduction
    The Guideline on Air Quality Models(Revised)^  was published in July
1986.   The purpose of the guideline is to promote  consistency in the use of
air quality models within the air management process.  The guideline provides
model  users with a common basis for estimating pollutant concentrations,
assessing control strategies and specifying emission limits.
    During the public comment period on the above  guideline,  EPA received
requests to consider several additional new modeling techniques.  However,
some developers did not submit those models to EPA until much later.  Due to
insufficient time for public review, these models  could not be included in
the revised guideline.   In a separate regulatory proposal  on  September 9,
1986,  EPA sought public comment on four additional models (51 FR 32180).
These four additions, if promulgated in a final  rule-making notice, will
require modifications to the Guideline on Air Quality Models(Revised).  EPA
has placed in Docket A-80-46 for public examination all the technical
support material received on these four models and draft changes to the
guideline text.  The changes show where and how these four models would be
incorporated in the guideline should they be adopted.  Written comments
were sought by October 9, 1986.  However, due to requests from several
groups, the comment period was extended until December 9 (51  FR 37418).
Both Federal Register notices are contained in Appendix A of  this document.
The purpose of this document is to summarize the comments received and to
present EPA responses to the major issues raised by the commenters on this
supplemental proposal.

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Summary of Comments
     All comments received on this proposal are available from Docket
A-80-46 items V-D and V-H .   Names of organizations that submitted written
comments as well as their assigned docket reference number are shown in
Appendix B of this document.  Although a total of 31 items are listed, many
of the early submittals are only a request for an extension of the comment
period.  The comments can be divided into the following separate categories:
     -  whether to use the Rough Terrain Diffusion Model (RTDM) as a third
        level screening technique for complex terrain applications;
     -  what the meteorological  input requirements of the RTDM model should be;
     -  whether to adopt the American Petroleum Institute's (API) modifications
        to the Industrial  Source Complex (ISC) model;
     -  whether to adopt the Offshore and Coastal  Dispersion (OCD) model  as
        a preferred model  for applications to sources located over water.
No comments were received on the proposal concerning the inclusion of AVACTA  II
as an alternative model in Appendix B of the guideline (i.e., for use on  a
case-by-case basis).
EPA Responses to Comments
     The summary of responses is organized according to the above categories.
In some instances, summarizing the comments themselves required some inter-
pretation.  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 comments.  In those Instances, every
effort was made to maintain  the exact meaning of the commenter.  Following
the summary of comments on each separate topic, the EPA response to these
comments is given.  Where there are subtopics in the comment summary, the

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response is separated into subparagraphs.   Guidance and editorial  changes
associated with the resolution of these issues are incorporated in thp
appropriate sections of the guideline and  are published as Supplement  A
(1987) to the "Guideline on Air Quality Models (Revised)."

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 II.   Rough  Terrain  Diffusion  Model  (RTDM) - Model Status
      Comment  Summary  (Approve RTOM)
      The  majority of  commenters  urged  EPA to adopt  its  proposal  on the  use
 of RTDM as  a  third-level  screening model for use in  rural complex terrain
 applications  because  of  superior performance over other existing models
 such  as the COMPLEX I model and  because  it is a step forward.  Some of
 these commenters also generally  requested that EPA adopt the RTDM model as
 a refined model  (i.e., can be used on  a  generic basis with site-specific
 data)  for inclusion in Appendix  A of the guideline because of technical
 merit.

      EPA Response
      Based  on the comments, EPA  maintains its proposal  to recommend RTDM
 with  specified default options as a third-level screening model  for esti-
 mating air  quality  impact from stationary point sources in rural complex
 terrain; less sophisticated screening techniques remain available as an
 initial or  a  second-level screen.  However, EPA's review of available
 studies demonstrates that RTDM,  as a refined model  with full  on-site data,
 can substantially underpredict concentrations.   Since no new analysis was
 presented by the commenters to alter this conclusion, EPA does  not agree
 with the commenter's proposal  to adopt RTDM as  a refined model  in Appendix
 A of the guideline at this time.   RTDM with full  on-site data may be used
 as a  refined model  on a case-by-case basis by following the demonstration
 criteria described in Section 3.2.2 of the guideline.
     Comment Summary (Technical  Changes)
     While arguing for their position to  adopt  RTDM, the commenters  also
 suggested several technical  changes:
     -  there should be an option to use  the stack  top wind  speed for
determining plume rise and the plume height  wind  speed for determining dilution;
     -  since RTDM results 1n  a  very narrow plume width prediction,  receptors
 should be spaced more closely  to  unequivocally  locate the maximum concentration;

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     -  EPA should recommend applying RTDM for any terrain above stack top
and not require dual  modeling for terrain in between stack top and plume
centerline.
     EPA Response
     The RTDM model, when used as a third-level screen, is designed to
accept as input, measured winds at only one height.  EPA recommends that
wind data input to RTDM should be based on fixed measurements at stack top
height.  For stacks greater than 100m, the measurement height may be limited
to 100m in height relative to stack base.  This recommendation is broadened
to include wind data representative of plume transport height where such
data are derived from measurements taken with remote sensing devices such
as SODAR.  Note that RTDM already uses wind speed at stack top to calculate
the plume rise and the critical dividing streamline height, and the wind
speed at plume transport level to calculate dilution, as the commenter
desires.  The default values for the wind speed profile exponents, shown in
Table 5-2 of the guideline revisions as IDILUT=1, are used in the model  to
extrapolate the wind speed from the measured height to other heights.   Addi-
tional  guidance on the routine use of measured (site-specific) wind speed
profile exponents is not possible at this time due to limitations in the
availability of such data and lack of experience in their application
within the technical community.  Where such data are available, they may be
considered on a case-by-case basis after consultation with the appropriate
EPA Regional Office.
     The receptor spacing requirements for RTDM have been clarified in the
guideline text by Indicating the need for detailed review of the site's
topography, carefully exercised judgement, and consultation with the EPA

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Regional Office.  Due to the site-specific nature of this evaluation, how-
ever,  receptor spacing can not be precisely prescribed on a generic basis.
     Because RTDM is considered here to be a complex terrain screening model,
its use in a situation where a receptor is on terrain above stack height
must remain consistent with guidance provided for other screening models.
In the absence of a refined model, EPA recommends bracketing the highest
concentrations by using both simple terrain and complex terrain models for
receptors between stack height and plume height.  Please see Section 5.0
of the guideline^ for a more detailed explanation of this method.  When a
refined model such as CTDM is implemented, this approach will be re-examined.
This point has been explained in the prior public comment summary document2
and is not an issue in this rulemaking.

     Comment Summary (Do Not Approve RTDM)
     One corronenter opposed EPA's proposal  to even adopt RTDM as a screening
model because:
     -  RTDM does not address other phenomena where high concentrations
can occur (e.g., on the lee side of hills, or during fumigation and stagna-
tion conditions in deep valleys).   The highly conservative nature of the
currently approved complex terrain screening models compensates to some
extent for not addressing any of these phenomena.
     -  EPA's Complex Terrain Dispersion Model  (CTDM)  is now at an advanced
stage of development;
     -  both the Westvaco and Widows Creek data bases  show a substantial
number of instances in which the concentrations  at specific  monitoring
stations were underpredicted by RTDM, as proposed.  RTDM has not been suf-
ficiently tested to ensure protection of the ambient air quality standards
and it 1s possible that the model  was "tuned" to perform better on the
Westvaco data base.

     EPA Response
     EPA agrees that the RTDM model  does not address all  meteorological
phenomena 1n complex terrain.   That  1s  why EPA  has recommended  the use of

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RTDM as a screening technique until research produces a refined model.  The
goal of the modeling guidance is to ensure that the best possible scientific
procedures are implemented for operational use.  From the information pre-
sented to EPA through the public comment and review process, it is apparent
that RTDM as proposed by EPA, with assigned predetermined values irrespective
of site-specific conditions, is more accurate, while still  providing con-
servative estimates.  It is also based on better scientific theory^ than
existing complex terrain screening models.
     The commenter did not provide credible scientific data to sustain the
argument that a model must be as highly conservative to encompass concentra-
tions produced by all meteorological phenomena such as lee  side effects,
fumigation, and stagnation.  Existing screening models were never intended
to address these phenomena nor do they have the necessary "physics" to do
so.  The commenter appears to be arguing for disallowing the use of RTDM
because it is less conservative and may result in less stringent emission
limits than those provided by current models.  EPA has anticipated the need
for improved complex terrain models and has conducted over  the last five years
the Complex Terrain Model Development program3,4.  The goal  of this research
program is to develop reliable atmospheric dispersion models that are appli-
cable to large pollutant sources located in complex terrain.  RTDM, which deals
with stable plume impaction, is a step in this direction.   Research programs to
consider other phenomena such as lee side effects and stagnation are underway o(
are being considered by EPA's Office of Research and Development and by others.
Until this research can fully address how to model  these phenomena, the use
of RTDM with specified default parameters as proposed is the best available

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method.  To fill a void in knowledge, EPA is encouraging the placement of
monitors at locations where these other phenomena are suspected to cause a
violation of the NAAQS (e.g., potential lee side effects downwind of the
Lovett Generating Station operated by Orange & Rockland Utilities).
     Although the CTDM model is in an advanced stage of development, approval
of RTDM as proposed should not be affected.  RTDM is not competing with CTDM.
Adopting RTDM presents an opportunity to improve EPA's present screening
techniques for modeling in complex terrain.  The CTDM model, which is still
in a research and development mode, is a more physically realistic model.
Once CTDM is fully operational, experience in its use, data requirements,
etc. will still be needed.  When this experience is gained, EPA may propose
CTDM as a refined air quality model.   Nevertheless, there will  still  be a
need for a reasonably accurate, yet simple screening model  that yields con-
servative concentration estimates, which is the role filled by the RTDM
model.
     The various tests of the RTDM model have been summarized and referenced
in the EPA proposal (51 FR 32180) and the reports describing the details  of
these tests have been placed in Docket A-80-46.  EPA believes these tests
provide an adequate demonstration of this model's ability,  with specified
default parameters, to provide sufficiently accurate but consistently con-
servative concentration estimates.  Rather than limit the issue of accuracy
to a receptor-by-receptor basis as suggested by the commenter,  EPA's  position
has always been that the performance of any model, whether  for complex ter-
rain or some other application, should be based on the ability to predict
highest concentrations on a network-wide basis.  EPA has found  that under
and overprediction varies from site to site.  This has been demonstrated
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for even the widely used flat terrain model MPTER.  In applying models to
evaluate attainment of short-term deterministic ambient standards or PSD
increments, EPA has always examined whether the highest, second-highest value
in the network, not the value at a specific monitoring site1 is within the
NAAQS limits.  For this type of application RTDM is conservative.
     The possibility of "tuning" the model was raised by EPA as a cautionary
remark to the model developer at the time RTDM was being developed.   Sub-
sequent scientific review^ by the American Meteorological  Society-EPA Steering
Committee on the performance of eight complex terrain dispersion models con-
curred that the RTDM model was a clear choice.  Additional  evaluation of the
performance of this model  was made by one of the commenters on this  proposal
(Docket Item V-D-19).   This evaluation also showed that this model  is more
accurate than the COMPLEX  I screening model.
     Comment Summary (Model Performance)
     One commenter provided data to show  that when applied  to the Widows
Creek plant, RTDM in the specified default mode was more accurate than
EPA's COMPLEX I model.  RTDM also provides conservative estimates for 10 of
12 possible combinations of available meteorological  data.   The commenter's
suggestions for mitigating the two situations with underestimated concentra-
tions include requiring a  multiyear (e.g., 3 years) analysis or multiplying
the predicted concentrations by a correction factor (e.g.,  1.2). The need to
use a correction factor does not diminish RTDM's superiority over COMPLEX I.

     EPA Response
     EPA appreciates the commenter's data on the performance of the  RTDM model
at the Widows Creek plant.  Much useful  information was obtained from this
analysis.  However, because of the limited terrain height compared to plume
height at this facility, the analysis could not determine the performance of
the peak concentrations expected during plume impaction which would  occur
when the plume Intercepts  high terrain.   When the highest,  second-highest

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concentration is used in assessing potential violations of short term NAAQS,
RTDM's predicted concentrations are consistently closer to the corresponding
measurements than COMPLEX I regardless of which of the 12 meteorological
data sets are used as input.  Meanwhile, the underpredictions for RTDM are
within the error margin associated with other Gaussian models.  As stated
in the guideline^ (page 10-3), "errors in highest estimated concentrations of
+_ 10 to 40 percent are found to be typical, i.e., certainly well within the
often-quoted factor-of-two accuracy . . . ."  On the other hand, substantial
overpredictions by RTDM, greater than this margin of error, occurred with most
of the meteorological data combinations that could have been selected.
     The commenter's suggestions to apply "correction factors" to concentra-
tion estimates from RTDM, if only one year of data is used, is contrary to
EPA's modeling guidance (Please see Section 8.2.11 of the guideline1).  EPA
is sympathetic to the commenter's suggestion to increase the period  of data
record to 3 years if this improves confidence in the model prediction.
However, while urging up to 5 years of on-site data, the guideline does not
require using more than one year where a longer period of record for on-site
data 1s not available.
     Comment Summary (Impact Assessment)
     One commenter stated that the proper basis for assessment of the impact
of RTDM's approval  1s not current emission limits but rather the alternative
emission limits that would result from applying currently approved EPA rough
terrain models to sources whose limits are not now based on approved models.
EPA must compare the allowable emissions from such sources, when modeled  with
currently approved  rough terrain models, to the emissions allowed by RTDM in
order to fairly present the net Impact of approving RTDM.  The commenter
claimed that there  would be a greater total  Increase 1n emissions than
calculated by EPA.
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     EPA Response
     EPA does not agree with the commenter's statement that emission limits
based on currently approved EPA complex terrain screening models should have
been used for all sources in evaluating the impact of the RTDM model.  In
its analysis, EPA did consider all existing sources in complex terrain with
emission limits based on the Valley and COMPLEX I screening models.  For
these sources current emission limits were compared with those that would
be derived from RTDM, as the commenter desired.  However, many sources in
complex terrain have emission limits set on some basis other than the cur-
rently approved models.  EPA also considered these sources and compared
their emission limits based on alternative modeling techniques with those
that would be based on RTDM.  Since EPA does not plan to impose retroactively
the revised modeling guideline to change the emission limits for these latter
sources, the comparison with RTDM is appropriate and the EPA analysis is
valid.   It would be wholly inappropriate to base a comparison  on emission
limits derived from Valley or COMPLEX I where these models were not actually
used.  Contrary to the commenter's claim, the analysis by EPA, placed in the
Docket, showed that the magnitude of the potential increases in national
emissions associated with the use of RTDM will  not be appreciable.
     Comment Summary (Miscellaneous)
     The model developer recommended that RTDM (Version 3.2) supercede the
previous Version 3.1 which contained two programming errors.
     One commenter urged EPA to make RTDM, as well as all  other EPA recommended
models, publicly available through the National Technical  Information Service
(NTIS).
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     EPA Response
     To correct the programming errors identified by the model developer, EPA
agrees to substitute Version 3.2 of RTDM for Version 3.1 in this rulemaking.
EPA has tested Version 3.2 of RTDM that was submitted by this developer and
has found the changes (to the earlier Version 3.1) to be correct, necessary
and with little impact on maximum estimated concentrations.
     EPA agrees with the commenter views to make readily available to the
public all EPA recommended models.  EPA has notified the RTDM model devel-
oper of EPA's intent to release RTDM through NTIS for public distribution
in a manner similar to other models recommended for regulatory applications.
(See Docket Items VI-I-1, VI-D-1).

Conclusion
     EPA reaffirms its proposal to modify the guideline to list RTDM as a
third level  screening model  for estimating air quality impact from stationary
point sources in rural complex terrain.  Users who may wish not to commit
the additional resources necessary to use RTDM as a third-level  screening
model are not required to do so; the existing initial  or a second-level
screening technique remains  available for use.  Since it has been demon-
strated that RTDM with full  on-site data can underpredict concentrations
substantially, EPA does not  recommend RTDM as a refined model  at this time;
however, it remains an available option for users, subject to case-by-case
approval.
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III.  Rough Terrain Diffusion Model (RTDM) - Data Input
      Comment Summary (Use of Remote Sensing Devices)
      Commenters stated that specifying stack top wind measurements pre-
cludes the use of SODAR [which can not provide reliable measurements at
lower heights, e.g., 50m or less], but can provide reliable wind measure-
ments at heights typical of plume transport.
      EPA Response
      EPA does not intend to preclude the use of remote sensing devices
(e.g., SODAR) to directly measure wind speed and direction at plume transport
height, provided that the necessary data quality assurance and recovery rate
requirements are met.  Section 5.2.1.4 of the guideline^- is being revised to
explicitly state that SODAR may be used to measure winds as indicated here.
      Comment Summary (On-site Data)
      Some commenters stated that EPA should require little, if any, on-site
data because RTDM is only a screening model.  Some suggested that EPA should
allow the use of NWS data exclusively because using these data, RTDM is still
more accurate than COMPLEX I.
      EPA Response
      EPA does not agree with the commenter's statement that RTOM should not
require any on-site data because it is a screening model.  The Guideline on
Air Quality Models (Revised), on page 5-4 that was subject to prior public
comment, states that the input of on-site (site-specific) data for the pre-
sent second-level complex terrain screening models is preferred.   It has al-
ways been EPA's intention that on-site data be used in these models, e.g.,
COMPLEX I.  Allowing the use of off-site data with the third-level screening
technique, RTDM, would be inconsistent with this guidance.  Since EPA did not
seek comments on the use of off-site data for RTDM, the Agency does not consider
this matter an issue in the present rulemaking.
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      Comment Summary (Wind Input)

      One commenter suggested that 10m winds may be measured on-site, but
no additional on-site data (such as stability and temperature)  should be
required.  Another commenter stated that it is not necessary to limit the
use of RTDM (as a screen) to situations in which only upper level  [100m]
stack top on-site data are available and EPA should not '•equine these data.
While use of stack top winds may be preferable, and while it may be appro-
priate for EPA to ask RTDM users to gather such data, other wind data [as
low as the 10m level] can be used if necessary without having a significant
adverse effect on the model's performance.  Specifically, RTDM has been
tested with both surface level  (10m) on-site data, and even NWS data, and
it still provides conservative predictions that are closer to observed
concentrations than the predictions provided by COMPLEX I.  They further
added that, as a minimum, the use of on-site surface level data should be
allowed on a 2-year interim basis until upper level on-site wind data are
available in order to apply RTDM either as a screening or as a refined model.
Other commenters, however, supported EPA's position to require stack top
wind data.


      EPA Response

      EPA has examined all the arguments presented by the commenters and

continues to recommend that for input to RTDM winds should be based on fixed

measurements at stack top height.  For stacks greater than 100m, the measure-

ment height may be limited to 100m in height relative to stack base.  This

recommendation is broadened to include wind data representative of plume

transport height where such data are derived from measurements taken with

remote sensing devices such as SODAR.  EPA's rationale is that the best data

from the scientific point of view should be input to RTDM.  This rationale

is augmented further in the response to comments below.

     EPA's recommendation to use measurements representative of wind flow at

stack top is consistent with the prevailing scientific opinion that use of

stack top winds 1s superior in complex terrain, as the commenter acknowl-

edges, and that in complex terrain these winds can not be estimated accurately
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from surface level measurements.  The use of stack top winds is also consist-
ent with present modeling guidance given in Section 9.3.3.2 of the guideline'-
which was subject to an earlier rulemaking.
     Although the sensitivity analysis to determine the performance of the
RTDM model when used with different wind measurement levels as presented by
one of the commenters is very interesting, a serious limitation exists.  As
pointed out earlier in Section II, the limited height of terrain at the Widows
Creek facility precluded comparisons (between model predictions and observed
concentrations) during conditions when the plume centerline actually impinges
on high terrain; a condition that must be considered when determining the de-
sign concentration.  Based on the limited analysis presented by the commentersi
EPA cannot conclude that more conservative estimates are always obtained when
lower level winds (than at stack top height) are used as input to RTDM.
     EPA's rationale for its recommendations is that the scientific integrity
of this model is enhanced with the input of these winds.  EPA has made known
its position on wind data since July 1985 and thus there has been ample time
to plan for, if not complete much of, the data collection process.  (See
Docket Item IV-E-3).  For these reasons, the need for an interim period,
during which the best scientific data are exempt from use in RTDM, is not
technically justified.
     Nevertheless, the Agency does not wish arbitrarily to preclude any source
from using RTDM for lack of necessary data input.  Thus, the Agency encourages
source owners to allow for time necessary to (1) gather input data needed for
new models, (2) execute the model to determine the emission limit; and (3) sub'
m1t the documentation for rulemaking action.  Since EPA 1s Interested in the
most scientifically credible analysis, the Agency will  work with the source
to develop reasonable schedules for collecting and using these data in RTDM.

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       Comment  Summary  (Miscellaneous)
       Several  commenters  also  requested clarification between the data
 input  requirements  stated in the proposed text and the "10 meter (default)"
 statement  for  anemometer  height in the proposed table.

       EPA  Response
       The  commenters1  suggestions to clarify the data requirements in the
 text and table have been  implemented.  In addition, the variable ITIPD has
 been set to 1  (i.e., is used), as recommended by the model developer, to
 correct an error in the original EPA proposal (see Docket Item IV-I-21).

 Conclusion
     EPA reaffirms its recommendation that, for input to RTDM as a third-
level screening model, winds should be measured at stack top height.   For
stacks greater than 100m, the measurement height may be limited to 100m
in height relative to stack base.  Appropriate allowance for the use  of
measurements from remote sensing devices is also provided.  EPA's rationale
is that the best data from the scientific point of view (i.e.,  winds  repre-
sentative of conditions at stack top height) should be input to this  model
to improve confidence in the predicted concentrations.
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IV.  Industrial Source Complex (ISC) Model
     Comment Summary (Do Not Support EPA's  Proposal)
     For a variety of reasons, several  commenters did not support the
modification to the building downwash algorithm in the ISC model  as
exactly proposed by EPA.  Some claimed the  EPA proposal  to select the
worst of two estimates (from the API version and the original  ISC model)
was inconsistent with the API approach.  Some claimed that this proposed
approach has no physical basis and is based on model-to-model  comparisons.
When ISC predicts higher values than the API version, it is because ISC
assumes downwash under stable conditions and low wind speeds,  an  unlikely
event based on field data and literature review.  In addition, the version
of the ISC model proposed by EPA contained  some features that  were not
included in the version of ISC proposed by  API (i.e., stack tip downwash,
buoyancy-induced dispersion, final plume rise and different wind  profile
exponents).

     EPA Response
     The refinements in the treatment of building wake effects in the ISC model
as proposed by API are:  (1) reduced plume  rise due to initial plume dilution;
(2) enhanced plume spread as a linear function of the effective plume height;
and (3) specification of building dimensions as a function of  wind direction.
EPA agreed that all three refinements would improve the realism of the ISC
model.   Most of the controversy in this rulemaking is related  to  the best
method to implement the second refinement as explained next.
     In the present ISC model, the effect of building wake on  plume spread
occurs abruptly for effective stack heights less than Good Engineering Practice
(GEP) formula height.  That is, for any plume height from a stack with greater
than GEP formula height, the building wake  is assumed to have  no  effect on
plume spread, but for a plume height from a stack with less than  formula  height
the full wake effect is assumed.  Wind tunnel studies6 have suggested as  a
refinement that it 1s Important to compute  plume enhancement (the vertical  and
                                       17

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crosswind spreading of the plume due to building wakes)  as a continuous
function of stack height.  Based on this information,  API  proposed  a  linear
"decay" function.  Although there is uncertainty about the correct  shape of
this "decay" factor, EPA felt that the API approach  was  reasonable  and
proposed it.
     After further analysis of the data provided by  API,  EPA found  that  most
of these data were collected at sources with small stack  height  to  building
height ratios (Hs/Hg) of approximately 1,5.   A change  in  the shape  of the
linear decay factor could have a modest effect on concentrations for  these
sources, but a substantial  effect on sources with HS/HR  >  1.5.   Since it was
uncertain how accurately the API linear treatment works  for these latter
cases, EPA originally proposed to select the highest of  two estimates (from
the API version and the original ISC model)  in order to  avoid arbitrarily
selecting lower concentrations.  EPA's concern about the  potential  under-
prediction of the proposed API version stems from the  apparent systematic
tendency for the present ISC model to underestimate  downwash concentrations.7
Thus, for large sources, which usually have  HS/HB >  1.5,  the misapplication
of the API results would result in a further, more serious, underestimation
of potential impact during downwash conditions.   The intent of EPA's  original
proposal can be accomplished by limiting the use of  the API modifications
to sources with HS/HB <. 1.5 while requiring  sources  with  HS/HB > 1.5  to  use
the ISC model in UNAMAP Version 6, as described  in more  detail later  in  this
section.
     EPA's analysis has also Indicated that  API  downwash  modifications perform
1n a similar manner to ISC for sources with  HS/HB <.  1.5 during stable, low
wind speed conditions contrary to the commenter's assertion.  This  analysis
1s shown in Docket Item VI-E-3.
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     The API modifications were adopted on a different version of the ISC
model than that originally proposed by API because of timing.  API explored
the possibility of making these refinements during the Third Conference on
Air Quality Modeling in January 19852.  However, documentation of these
refinements was not submitted to EPA until early 1986.  By that time, the
ISC model was already in the process of being changed, from UNAMAP Version
5 to Version 6, also a result of public comment at the third modeling con-
ference.  Thus, EPA could only propose the API downwash algorithm in con-
junction with the new UNAMAP Version 6 of ISC.  One commenter has subsequently
incorporated the API modifications into the ISC model in UNAMAP Version 6
and identified this approach as ISC-6MOD.  This approach is discussed in
detail  at the end of this section.

     Comment Summary (Support EPA's Proposal  But Require More Tests)
     Several commenters stated that the API data do not provide EPA with
sufficient basis to approve the inclusion of the API modifications as
proposed by EPA.  The API tests are limited and are not applicable to
elevated receptors, a wide range of potential  critical meteorological
conditions, and stack height (Hs)  to building height (Hjj) ratios greater
than 1.3.  Moreover, the use of standard deviation of wind direction
fluctuations (sigma-A) to estimate lateral dispersion (sigma-y) was shown
to improve the performance of the  API  version of the ISC model  and should
have been proposed by EPA.  One commenter stated a concern for the applica-
tion of the API modifications in the urban mode of the ISC model  (where the
McElroy-Pooler (M-P) dispersion coefficients  are employed) until  a rigorous
evaluation indicates this to be appropriate.

     EPA Response
     EPA has already limited the application  of the ISC model to receptors
on terrain below stack height and  it is unnecessary to further limit the
API downwash modification to elevated receptors as the commenter suggests.
                                     19

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Building downwash usually occurs close to the point of release and it is
unlikely that any significant differences in terrain height exist within
such short distances from the point of release.
     EPA agrees with the commenter that the performance of the API modifications
to ISC under all meteorological conditions has not been addressed by API.
However, the meteorological conditions are adequately accounted for by the
API test data for the application being proposed here.
     EPA agrees with the commenter that the API modifications to the ISC
model appear to be limited to certain stack height to building height ratios.
EPA's review of the data shows this ratio extends up to about 1.5.  Where
the HS/HB ratio is greater than 1.5, EPA believes that the data presented
to date do not support the API modification or, in turn, any changes to the
current procedure in the ISC model in UNAMAP Version 6 for these ratios.
     EPA does not recommend the use of sigma-A to estimate sigma-y for a
couple of reasons.  First, the relationship between sigma-A and sigma-y is
site-specific and no generic guidance is available for applicability to
other locations.  Second, the use of sigma-A to estimate sigma-y implies
that another variable is needed to determine vertical  dispersion or sigma-z.
This so called "split sigma" approach is not recommended by EPA.2
     EPA disagrees with the commenter's suggestion to limit the application
of the API modifications of the ISC model to the rural version of that
model.   The API modifications are an attempt to provide more realistic con-
centration estimates during building downwash conditions.   The downwash
phenomenon is a function of building geometry with respect to the wind.  The
commenter presented no data and EPA has no reason to believe that the down-
wash phenomenon occurs differently in rural  than in urban  environments.
                                      20

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In addition, for the far-wake region concentrations converge to values that
would occur in the absence of the building.  Therefore, it is technically
sound to assume that the downwash algorithm proposed by API can be used in
rural as well  as urban settings.  The adequacy of the M-P dispersion
coefficients themselves was addressed previously by EPA2 and is therefore
not an issue in this rulemaking.
     If EPA were to accept the commenter's conjecture that using the API
modifications is inappropriate in urban settings, sources located in urban
areas and with HS/HB < 1.5 would be required to use the present ISC model.
This creates a problem because the better API downwash technique, acknowledged
by both EPA and the model  developer, could not be applied to these sources.
The commenter did not present for EPA's consideration an alternative approach
for these urban sources.  Thus,  EPA rejects the commenters conjecture and has
decided to accept the application of the API modifications for both rural  and
urban settings 1n the ISC model.
     Comment Summary (Alternative Approach: ISC-6MOD)
     The model  developer submitted an alternative approach which incorporates
in principle the ideas contained in the API proposal  to modify the downwash
algorithm but minimizes the differences with the ISC  UNAMAP Version 6 by
incorporating many of the new features of the ISC model except for stack tip
downwash and buoyancy-induced dispersion.  The commenter stated that the two
features not Included are implicitly accounted for in the API scheme to treat
downwash.  The commenter referred to this proposed version as ISC-6MOD which
is most similar in concept to the model originally proposed by API and does
not result 1n significantly different maximum concentrations.
     EPA Response
     EPA believes that the data and rationale presented by the commenter
support the ISC-6MOD approach, which 1s based on the  ISC model  in UNAMAP
Version 6 but does not Include stack tip downwash and buoyancy-Induced
dispersion.  However, data presented 1n support of applying ISC-6MOD show
                                      21

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that use of these modifications is limited to Hs/Hg less than 1.5, especially
in terms of the higher observed concentrations which are of regulatory con-
cern.  Where the. Hs/HB ratio is greater than 1.5, EPA believes that the data
presented to date do not support the ISC-6MOD approach; the basic downwash
approach in ISC UNAMAP Version 6 should continue to be used.
Conclusion

     EPA agrees with the alternative approach presented by the model
developer and believes that it represents the best scientific method  avail-
able at this time.  EPA will revise its modeling guidance and modify  the
ISC model  in UNAMAP Version 6 to include the ISC-6MOD downwash algorithm in
the regulatory default option switch (ISW(28)=1) for sources with HS/HB £
1.5.  However, for sources with Hs/Hg > 1.5, there is no scientific basis to
change the ISC model.  Since the basic building downwash algorithm proposed
by API and the performance improvements remain essentially intact with
ISC-6MOD,  and since the existing ISC model will continue to be used when
these modifications are inapplicable, EPA believes that the alternative
approach effectively accomplishes the same goal as the original  proposal
and does not constitute a significant change.  Thus, a re-proposal  of the
modified downwash algorithm OSC-6MOD is not necessary.
                                     22

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V.  Offshore and Coastal Dispersion (OCD) Model
    Comment Summary
    Commenters were generally favorable on the proposal to adopt the OCD
model as a refined model in the guideline.  However, one stated that the
OCD model should remain in Appendix B and not be designated as an EPA
preferred model until the following technical issues are resolved:
    - the OCD model appears to be continually undergoing substantial
revisions and it is uncertain whether current model evaluation summaries
are applicable for the version of OCD currently in use.
    - detailed model evaluations of OCD using tracer data demonstrate
significant underpredictions of peak measured concentrations.
    EPA Response
    The OCD model was proposed as a preferred or Appendix A model because
it is a unique approach needed to fill a void in the existing regulatory
program.  The version of the OCD model recommended by EPA is designated by
the Department of Interior, Minerals Management Service (MMS) as Version
3.0 (Rev 85329).  EPA has asked and received confirmation from the MMS that
the recommended version of this model  was indeed used in the evaluation
studies.  (Please see Docket Item VI-D-2.)  From the list of corrections
shown by the commenter (Docket Item V-D-17, attachment E-l), it appears
that these changes were needed to eliminate minor coding inconsistencies
in the program.  If this model is substantially revised in the future, EPA
Intends to ask the MMS to re-do the evaluation summaries and use additional
data bases.
     The OCD model  as recommended by EPA was evaluated by the MMS using
three data bases (Docket Item V-D-9).   A review of the model  evaluation
results shows no consistent tendency for underpredictions for the ten
highest ranked concentrations.  From a regulatory point of view,  these are
among the most important statistics since model  estimates should demonstrate
                                     23

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compliance with the national standards, which are not to be exceeded more
than once per year.  Naturally, EPA has some concern about the ability of
the OCD to predict the highest concentration.  However, here also, the
underprediction of about 16-30% for two of the data bases are in contrast
with the overprediction of about 85% in the third data base.  EPA examined
the example referred to by the commenter, and it appears that the commenter
is referring to examples where a hybrid OCD model, not proposed, is used.
This should not be confused with the version of OCD addressed in this rule-
making.  Even so, the underprediction cited does not appear to be significant
(i.e., 10-20 percent) and is within the error margin associated with other
Gaussian models.

    Comment Summary (Miscellaneous)
    One commenter raised several other objections to the use of the OCD Model;
    - over water dispersion characterized by OCD is much greater than that
characterized by MPTER.  This results in an inconsistency in the EPA modeling
guideline.   Dispersion over water has been demonstrated in numerous studies
to be less than dispersion over land.
    - the OCD model can accept monthly climatological  values of certain
parameters in lieu of measured hourly values.  It is inappropriate for
such important and widely varying parameters to be specified as a monthly
average.
    - the EPA model summary implies that the OCD model  may be combined with
another model  and used for assessing air quality impact on complex terrain.
    Another commenter questioned if the experiments to validate OCD were
influenced by high altitude transport of onshore emissions.

    EPA Response
    The characterization of dispersion over water Is an Integral  part of
this model  and cannot be evaluated separately.   EPA does not require that
                                     24

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all models remain completely consistent when these models are designed for
different applications.  The OCD model is not recommended by EPA for over
land applications and should not be compared with the MPTER model.
    The studies (referenced earlier) show very little difference between
OCD's preferred and default methods for parameterizing offshore stability
and determining the hierarchy of meteorological  data.  Generally, EPA
prefers the use of available site-specific data rather than default values
wherever possible.  The MMS agrees that hourly data should be used and a
preference for such data has been included in the modeling guidance.
    Combining OCO with any other complex terrain model, such as COMPLEX I,
cannot be approved on a generic basis.  All  hybrid models should be reviewed
on a case-by-case basis.  EPA will  modify the model summary in Appendix A
of the guideline to eliminate any possible confusion on this issue.
    The three OCD model validation studies (referenced on page 23), relied
on tracer gas measurements and, therefore, are not influenced by high altitude
transport of onshore emissions.
    Conclusion
    EPA has concluded to adopt OCD as a preferred model to be listed in
Appendix A of the guideline because:
    1.  The performance of the OCD model  is  judged by EPA to be acceptable.
There is no other competing model  to which the performance of OCD can be
compared and relative accuracy quantified.
    2.  OCD 1s a unique OP pioneering approach to specific analysis problems.
    3.  OCD has been used for regulatory application 1n the past and its
selection results 1n a minimum disruption of regulatory programs.
    4.  OCD is widely released through NTIS.
                                     25

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    5.  The use of OCD has resulted in public familiarity with this model.
    6.  This model has met the solicitation requirements outlined in
45 FR 20157^ including the practicality of the model, based on technical  merit,
for use in ongoing regulatory programs.
                                     26

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VI.  AVACTA II Model



     There was no comment on the proposal to include this model as an



alternative model in Appendix B of the Guideline on Air Quality Models



(Revised).  Models listed in that category may be considered for use on



a case-by-case basis as described on page 3-8 of the modeling guideline.



Thus, EPA will adopt this model as proposed.
                                     27

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VII.  References

1.  Environmental Protection Agency, 1986.  Guideline on Air Quality Models
    (Revised).  EPA Publication No. EPA 450/2-78-027R.  U.  S. Environmental
    Protection Agency, Research Triangle Park, NC (NTIS No.  PB 86-245248).

2.  Environmental Protection Agency, 1986.  Summary of Comments and Responses
    on the December 1984 Proposed Revisions to the Guideline on Air Quality
    Models.  U. S. Environmental Protection Agency, Research Triangle Park,
    NC.  [Docket Item IV-G-26]

3.  Lavery, R. F., B. R. Greene, B. A. Egan, and F. A. Schiermeier, 1983.
    The EPA Complex Terrain Model Development Program.  Preprints,  6th
    Symposium on Turbulence and Diffusion, March 15-22, 1983.  Boston,
    Massachusetts.   American Meteorological Society, Boston.

4.  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  Interna-
    tional  Technical Meeting on Air Pollution Modeling and  Its Applications,
    Copenhagen, Denmark.

5.  White,  F. D., Ed., and J. K. 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).

6.  Huber,  A. H., and W. H. Snyder, 1982.   Wind Tunnel Investigation of the
    Effects of a Rectangular-Shaped Building on Dispersion  of Effluents from
    Short Adjacent  Stacks.  Atmos.  Environ, 176:2837-2448.

7.  Environmental  Protection Agency, 1981.  An Evaluation Study for the
    Industrial  Source Complex Dispersion Model.  EPA Publication No.
    EPA 450/4-81-002.  U.  S. Environmental Protection Agency, Research
    Triangle Park,  NC.  (NTIS No. PB 81-176539).
                                     28

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Appendix A

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 32180       Federal Register / Vol. 61. No. 174 / Tuesday. September 8. 1886 f Proposed Rules
 ENVIRONMENTAL PROTECTION
 AGENCY

 40 CFR Parts 51 and 52

 [AH-FRL-3030-4, Dock* No. A-40-46]

 Requirement* for Preparation,
 Adoption, and Submlttal of
 Imptcnwntation Plan*

 *O8NCY: Environmental Protection
 Agency {EPA}.
 ACTON: Supplemental notice »f
 Proposed rulemaking. _

 SUMMARY: EPA is issuing a supplement
 to the notice of proposed rulemaking
 wat was published an December 7, 1984
 [48 FR 48018]. Today's notice proposes
 to include (1) addition of a specific
 version of the Rough Terrain Dispersion
 Model (RTDM) as a screening model, (2)
 modification of the downwash algorithm
 In the Industrial Source Complex (ISC)
 model, (3) addition of the Offshore and
 Coastal Dispersion (OCD) model to
 EPA's list of preferred models, and (4)
 addition of the AVACTA II model as an
 alternative model in the "Guideline on
 Air Quality Models. Revised." EPA 450/
 2--78-027R. The revised guideline lists
 the air quality models required to
 estimate air quality impact for sources
 of air pollutants which appear at 40 CFR
 51<24 and 5&21. The purpose of the
 Proposed changes is to augment the
 guidance in response to a substantial
 Dumber of public comments urging the
 Agency to do  so. EPA is soliciting public
 comments on  these four proposed
 •Ganges only.
 °*Tta: The period for comment on these
 Proposed changes doses  October 9,
 1886.
           Written comments should
{* submitted to: Central Docket Section
W.E-131). U.S. Environmental Protection
Agency, 401 M Street, SW., Washington,
°C 20460, Attention: Docket A-80-48.
  Copies of reports referenced herein, aa
W«U as all public comments an
maintained at Docket A-40-46. The
Docket is available for public inspection
*ad copying between 8:00 ajn. and 4.-00
Pja- Monday through Friday, at the
*?dr*«« above. A reasonable fee may be
^fgad for copying. A copy of the
Proposed revised pages to the guideline
*?y be obtained from the Docket or the
          ow.
                            TACT:
L0t«ph A. Tikvart Chief, Source
***Ptor Analysis Branch, Office of Air
^ty Planning and Standards, US.
{^ironmental Protection Agency,
fifuarch Triangle Park. North Carolina
if7!!; telephone (019) 541-5561 or Jawad
% Tomna, telephone (010) 541-5681.
 SUmiMCMTAMV

 Background
   In March I960, EPA issued a Notice
 soliciting air quality models developed
 outside the Agency for potential
 inclusion in the planned revisions to the
 Guideline on Air Quality Models [45 FR
 20157]. EPA received nearly 30 air
 quality models from private model
 developers. These were reviewed for
 technical feasibility and for utility to
 potential users, hi addition to a review
 by EPA for technical merit
 documentation, validation, and coding, a
 submitted model is open to public
 review and comment
   On December 7.1084 [49 FR 48018],
 EPA proposed amendments to its
 regulations concerning air quality
 models and announced that it would
 hold a public hearing on these proposed
 amendments. On December 20,1S84 (49
 FR 49484], EPA announced the Third
 Conference on Air Quality Modeling to
 provide a forum for public review. A
 transcript of all oral comments received
 at the conference, as well as a record of
 all written  comments, is maintained in
 Docket A-80-48. EPA is in the final
 stages of the rulemaking process on the
 revisions to the Guideline on Air Quality
 Models and will announce these
 revisions in a separate Federal Register
 notice.
  During the public comment period.
 EPA received requests to consider
 several additional new modeling
 techniques. However, the developers did
 not submit  those models to EPA until
 much later. Due to insufficient time for
 public review, these models could not be
 included hi the revised guideline. In this
 separate regulatory proposal, EPA is
 seeking public comment on four
 additional models as described below.
 These four  additions, when
 promulgated, will require modifications
 to the "Guideline on Air Quality Models,
 Revised." A copy of those pages
 proposed for revision is also available in
 Docket A-80-48, Item IV-J-2 for public
 review and comment
 Proposed Action
A. Rough Terrain Diffution Mods!
  Th* "Guideline on Air Quality
 Models, Revised" describes two level*
 of sophistication of models: Screening
 and refined. Screening models provide a
 conservative estimate of the air quality
 infpact of a  source. The purpose of
 screening models is to eliminate from
 further consideration those sources that
 clearly will  not causa or contribute to
 ambient concentrations in excess of
 either the National Ambient Air Quality
Standards (NAAQS) or the allowable
 prevention of significant deterioration
 (PSD) concentration increments. Refined
 models consist of those analytical
 techniques that provide more detailed
 treatment of physical and chemical
 atmospheric processes, require more
 detailed and precise input data,' and
 provide more specialized concentration
 estimates. As a result, they provide a
 more accurate estimate of source impact
 and the effectiveness of control
 strategies.
   Due to a lack of scientifically sound
 and proven techniques, the guideline
 does not recommend any refined air
 quality model for determining pollutant
 concentrations from sources in
 "complex terrain" areas (where the
 height of the terrain exceeds the height
 of the source being modeled]. Such a
 model would apply  in situations where
 the impaction of effluent plumes on
 terrain at elevations equal to or greater
 than plume centerline during stable
 atmospheric conditions are believed to
 cause air quality problems. In the
• absence of an approved case-specific,
 refined, complex terrain model, the
 guideline specifies screening models in
 two categories, depending on the level
 of sophistication and the amount of
 Input data required. The Valley
 Screening Technique is recommended
 for first level screening with an assumed
 worst case; COMPLEX I and the
 SHORTZ/LONGZ models are
 recommended with hourly measured
 meteorological  data^as second level
 screening techniques for rural and urban
 applications, respectively.
   Because there is perceived to be an
 immediate need, EPA received
 numerous public comments suggesting
 that it place a high priority on
 accelerating the development of a
 refined complex terrain model based on
 current research and/or recommend
 such a model based  on review of
 candidate models. Many commenters,
 notably from the utility industry,
 proposed the Rough Terrain Diffusion
 Model (RTDM)  as a  preferred, refined
 model that can fill this need. One of the
 technical improvements in RTDM is the
 ability to determine  the critical
 streamline, La., whether a plume will
 likely flow over, around or impact on a
 terrain obstacle. Further discussion on
 this model is contained in Docket Items
 IV-D-22 and 27: IV-H-21; IV-K-8 and
 11: and IV-B-1.
  EPA recognizes the efforts of many
 groups to develop a refined model for
 complex terrain applications and. EPA
 has been conducting, over the last five
 years, the Complex Terrain Model
Development program as documented in
 the Fourth Milestone Report [EPA/800/

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             Federal  Register  /  Vol.  51.  No. 174 / Tuesday. September 9. 1986 / Proposed Rules
                                                                     32181
3-64/110). While thi* program ii a
tignificant Hep toward the solution of a
complicated problem, completion of the
research project is not expected before
late 1986. In addition. EPA has also been
evaluating the performance of eight
currently available complex terrain
models that were submitted as a result
of 45 PR 20137. The first available data
base developed under this program.
Cinder Cone Butie. and also the
Westvaco-Luke Milt data base were
used to compare model predictions with
observed air quality data. The
performance of these models was
evaluated using an extensive set of
statistical measures recommended by
the American Meteorological Society. Of
the eight models tested. RTDM showed
the best overall performance for both
data sets. For more detail see
"Evaluation of Complex Terrain Air
Quality Simulation Models." EPA-450/
  RTDM requires an extensive set of
meteorological data input such as
horizontal and vertical turbulence
measurements and measured vertical
temperature profiles (delta-T). A survey
by the Utility Air Regulatory Croup
(UARG) has shown that this type of data
is not presently collected at moat power
plant facilities in complex terrain areas
(Docket Item FV-E-3| and model inputs
would therefore be restricted to more
routine meteorological measurements.
At the January 1965 Conference on Air
Quality Modeling. EPA expressed
concern about how well RTDM would
perform without  the use of the more
sophisticated on-site meteorological
data. Also. EPA asked for more
information on how well RTDM would
perform relative  to COMPLEX I for
distances beyond two kilometers from
the source. To respond to EPA's
concern* about the use of RTDM with
more routine data. UARG further
evaluated RTDM model performance
using the Cinder Cone Butte and
Westveco-Luke Mill data bases. Three
raeteoroiofical input seta wen used
First, for the full on-site caae,
meteorological Inputs Included on-cite
turbulence, wind profile and
 temperature profile measurement*.
Second, for the default case, only on-site
 temperature, wind speed, and wind
 direction measurements were used as
 model Inputs. All other parameters were
 baaed on default values specified in the
 model Third, for delta-T/defaull ease.
 on-site temperature profiles were used.
 in addition to other model Inputs being
 the same as case two above. The results
 indicated that RTDM only with default
 input eats (caae 2 above) did not
 underpredict the highest concentration*.
The other two (full on-site and deita-T/
default) did underpredict high
concentrations for some comparisons
with observed data. For more detail
refer to Docket Item IV-K-e.
  In addition, UARG also evaluated
RTDM model performance using 2 years
of data from the Tennessee Valley
Authority's Widows Creek power plant.
located in northeastern Alabama where
the number of monitoring sites is
sufficient. A description of this
evaluation is contained in Docket Item
IV-K-6. The conclusion drawn from this
study is that for the primary averaging
times, there were instances of
underpredictions of "•"'nOT
concentrations while for the default data
input set the model overpredicted. The
delta-T/defauit caae was not tested.
  Independent of these model
evaluation studies, a considerable
amount of high quality, research grade
data were being collected under the
EPA's continuing Complex Terrain
Model Development program at the
Tracy Power Plant east of Reno.
Nevada.  This area is surrounded by
complex  terrain in many directions. For
21 hours  of data that had previously
undergone full data quality control
checks, UARG further tested RTDM. The
analysis  showed that RTDM with full
on-site data, substantially
underpredicted the concentntiona. but
RTDM with default data almost exactly
predicted maximum concentration*. For
more detail see Docket Item IV-K-11.
  These  evaluations indicate that.
although RTDM may be technically
superior to other model*.
 EPA's COMPLEX I screening model
 when all the necessary on-«te data are
 available, there is a potential for
 underprediction*. In the default mode.
 RTDM la not aa sophisticated but
 provide* a margin of safety necessary to
 ensure the protection of ambient air
 quality standard*. In thi* mode. RTDM
 can mote property be eharacterixed aa a
 screening model If on-eite temperature,
 stability, wind speed and direction data
 are input to Una modal RTDM may be
 classified aa a third lev*l screen— ame
 sophisticated than the  present second
 lev*! screes, COMPLEX L yet not aa
 sophisticated a* the model developers
 hadaeeumed.
   EPA la therefore seeking public
 comment oa it* proposal to farther
 modify the revised foiddtaM to Uat
 «TDM « a third level  screen for
 estimating air quality impact from
 stationary point aoorce* in rani
 complex terrain. EPA believe* that thi*
 proposal he* several good aapects. First
 atoce It ha* been demonatratad that
 RTDM with Ml on-aite data can
underpredict concentrations
substantially. EPA cannot recommend
RTDM as a refined model at this time-
EPA believes that it is more prudent to
await results from its Complex Terrain
Model Development program before
recommending a refined model. Second.
many users may not wish to commit the
additional resources necessary to use
RTDM as a third level screen, and EPA
believes they should not presently be
required to do so: less sophisticated
screening techniques (i.e.. more
conservative) remain available. Finally.
the RTDM model with full on-site data H
an available option for users, subject to
ease-by-case approval.
B. Modifications to the Industrial
Source Complex Model (ISC)

  EPA received comments from the
American Petroleum Institute (API)
requesting the approval of a modified
version of the building downwash
algorithm in the Industrial Source
Complex (ISC) model. A current
shortcoming of ISC is that *e effect of
building wakes on plume dispersion
occurs abruptly for effective stack
heights less than Good Engineering
Practice (CEP). That ia. for any plume
height greater than either 2.5 building
height* or the building height plus 1-5
time* the lesser of the building height or
width, the building wake is assumed to
have no effect on dispersion. For a
plume height slightly less than CEP the
full wake effect is assumed This leads
to an unrealistic physical discontinuity
which ia not duplicated either in
physical simulation (e.g.. wind tunnel] or
by obaervation. For meteorological
condition* under which downwash doe*
not occur, the ISC model would be
unchanged The effect of the proposed
changes to ISC ia to replace the present
 "full downwaah/no downwash" model
 with one that predicts progressively-
 increasing downwash with decreases to
 stack heights at and below GEP. The
 proposed modification* to ISC include:
 (1) The enhancement of the dispersion
 coefficients through the introduction of •
 linearly decreasing decay factor a* a
 function of plume height (at two building
 height* downwind) above building
 height instead of the current step      .
 function behavior at a •pedfic height: Pf
 final phnnt rise reduced by initial plu0«
 dilution instead of the current approacn
 where final plume height is unaffected
 by building downwash: (3) different
        i building widths and heights for
 every tan degree wind sector (4)
 optional input of hourly stack
 temperature, velocity and emission
 rates. For more detailed discussion* ot

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 32182
Federal Register / Vd.  51, No.  174 / Tuesday, September 9, 1986 / Proposed Rules
 these changes, see Docket Items IV-D-
 28 and IV-1-23.
   The modifications to ISC were
 evaluated by API with two sets ef field
 data. The first set consists of tracer
 experiments at two natural gas
 compressor stations and the second
 consists of one year of air quality data '•
 collected at a «OOMW power plant
 Model evaluation results indicated that
 the short-term version of the existing
 (unmodified) ISC model was
 underpredicting maximum ground-level
 concentrations, under moderate to high
 wind speeds and neutral stability
 conditions, by a factor of 2-4. The
 proposed modifications improve the
 physics of the model (i.e. do better than
 the ISC model at matching the
 meteorological conditions of the highest
 observed concentrations), although the
 results indicate a slight overproduction.
  EPA proposes therefore to revise the
 downwash algorithm for the ISC model
 «the guideline by using the API
 Codifications for applications to stacks
 •horter than the Good Engineering
 Practice (GEP) stack height EPA
 recommends mis change for the
 following reasons. First EPA's  own
*odel evaluation program [An
 evaluation Study for the Industrial
 £>urce Complex Dispersion Model,
 epA-450/4-81-002] has indicated an
 *Pparent systematic tendency to
 "aderestimate the concentrations
 Ptoduced near the source by buoyant
•Jack emissions subject to building
**ke effects. APTs Aiding* support
;*ese conclusions and have provided
^aatructive help to develop realistic
••gorithnu to accurately predict ground
<«vel concentrations. Second, although
**»y other caonMBtan stated  that the
|*p- model's current downwash
Ugorithm overpredicts ground level
P^centrations, this condusipn ha* not
°**n supported by a comparison of
      measured versus predicted
£Offshan and Coattal Qitpenion

 ,EPA received comments from the
       ' Management Service (MMS)
  requesting the inclusion of the Offshore
  and Coastal Dispersion (OCD) model in
  the revised guideline as a recommended
  model for application to sources located
  over water [Docket Item FV-D-8]. This
  model has been approved for use by the
  MMS in 50 FR12248. In subsequent
  communications between EPA and
  MMS, MMS has agreed that the
  applies tion of this model should be
  limited to estimating air quality impact
  from offshore sources on onshore flat
 •terrain areas. This model is not
  recommended by EPA for use in air
  quality impact asaesements for onshore
 sources.
   Hie OCD model was evaluated by the
 model developers in order to determine
 whether its performance was better than
 the original MMS model (CRSTER with
 stability classes A and B collapsed into
 C). Further discussion of this model is
 contained in Docket Hems IV-D-9 and
 rv-i-22. Aerometric data from three
 separate offshore and coastal diffusion
 experiments wen used in this
 evaluation. Two versions of the OCD
 model wen tested. One required
 measurements of parameters
 (turbulence intensities) that an not
 made on a routine basis: the other
 version was run without the turbulence
 intensity data. The results indicated that
 both versions of the OCD model
 performed better than the original MMS
 model Even without turbulence
 intensity data, the OCD model is a good.
 screening model for assnsiring air quality
 impact from offshore sources under very
 stable atmospheric conditions. When
 these conditions an present the highest
 onshore coocaotrationa an expected
 from these offshore sources.
   EPA is proposing to list the OCD
 model as a preferred nodal in the
 revised guideline, for estimating air
. quality impact from offshore sources on
 onshore flat terrain areas. EPA's
 recommendation of this action is based
 on fan finiitnof that **"* materials
 submitted in support of this model meet
 the six requinmeats outlined by EPA in
 Ha notice solidtinf sir quality models
 developed outside the Agency in 46 FR
 20157.
                                                               D.AVACTA 11 Model

                                                                 EPA received a comment from the
                                                               model developer AeroVironment. Inc.
                                                               requesting the inclusion of the AVACTA
                                                               II model as an alternative model in
                                                               Appendix B of the revised guideline
                                                               [Docket Item IV-K-13J. Models listed in
                                                               Appendix B must meet the six criteria
                                                               outlined in 45 FR 20157 and may be
                                                               considered for use on a case-by-case
                                                               basis subject to a demonstration.
                                                                 EPA has determined that the material
                                                               submitted in support of the model meets
                                                               the six criteria and is proposing to list
                                                               this model as an alternative model in the
                                                               revised guideline.

                                                               Classification

                                                                 The revisions being proposed herein
                                                               to the previous proposal will not change
                                                               the conclusions regarding Executive
                                                               Order 12291. Regulatory Flexibility Act
                                                               Economic Impact Assessment or
                                                               Paperwork Reduction Act which were
                                                               previously stated. Consequently this
                                                               action is not considered major under
                                                               E.0. 12291.

                                                               List of Subjects

                                                               40CFRPart51

                                                                Administrative practice and
                                                              -procedure. Air pollution control
                                                               Intergovernmental relations. Reporting
                                                               and recordkeeping requirements. Ozone,
                                                               Sulfur oxides. Nitrogen dioxide. Lead.
                                                               Particulata matter, Hydrocarbons.
                                                              40CFRPart52

                                                                Air pollution central Ozone, Sulfur
                                                              oxides. Nitrogen dioxide. Lead.
                                                                Authority: Sees. 185(e) and 320. aeon Air,
                                                              Act 42 U.&C. 747SU). 7B20.

                                                                Dattd: August ft. 19B6.
                                                              DoaR.Oay.
                                                              AuutantAAniniftratorforAirmd
                                                              Radiation.
                                                              JPR Doc W-194B7 Filed 9-4-8* 849 Ul]

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37418      Federal  Register  /  Vol. 51. No. 204  /  Wednesday.  October 22. 1966 / Proposed Rules
ENVIRONMENTAL PROTECTION
AGENCY

40 CFR Parts 51 and 52
[AH-FHL-3097-3, Docket No. A-80-46]

Requirements for Preparation,
Adoption, and Sufamlttal of
Implementation Plans

AGENCY: Environmental Protection
Agency (EPA).
ACTION: Proposed rule: extension of
comment pehod.
              notice extends the time
period in which to file comments in
response to the Supplemental Notice of
Proposed RuJemaking in Central Docket
No. A-80-46 (9/9/86. 51 fit 32180]
concerning the proposed tndmton of
four air quality models into the
"Guideline on Air Quality Models
(Revised)," EPA 450/2-78-027R. On
September 29. Hunton and Williams on
behalf of the Utility Air Regulatory
Group requested that thfroominent
period be extended n evder to provide
more time to evaluate and teat the
proposed ISC modifications. On October
1. the Natural Reaoafcea Defense
Council requested that the comment
period be extended in order to provide
more time to exaaxiaa end review the
documents submitted to the Docket
conceraiiig the ISC and RTQM aodela.
Other pntetttial enmmmian hawe also
expressed «a ifiietsat ia additioB«l Uae
to comment. As a result, as noted below,
the public comment pehod has been
extended to December 9,1966.
DATE: Comments may now be Hied on or
before December 9.1986.
ADDRESS: Written comments should
continue to be submitted to: Central
Docket Section (LE-131). U.S.
Environmental Protection Agency. 401 M
Street SW., Washington. DC 20406,
Attention: Docket A-80-46.
FOB FURTHER INFORMATION CONTACT:
Joseph ATikvart, Chief. Source
Receptor Analysis Branch. Office of Air
Quality Planning and Standards. UJ5.
Environmental Protection Agency.
Research Triangle Park, NC 27711:
telephone (919) 541-5561 or Jawad S.
Touma. telephone (919) 541-5681.
SUPPLEMENTARY INFORMATION: The
following item was included in the
Docket but reference to it was
inadvertently omitted from the original
proposal On page 32180. column 3. at
the ead of the 2nd full paragraph add:
Docket Item IV-4-21. User's Guide to the
Rough Terrain Diffusion Model (RTDM),
(Rev. 3.W). September 1985.
  Dated: October 10.1986.
Don K. Clay.
Acting Assistant Administrator far Air cad
Radiation.
(FR Doc. 86-23634 Filed 10-21-80; 8:45 am]
BOUNO CODE (MMO-M

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Appendix B

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Docket
Number
V-D-1
V-D-2
V-D-3
V-D-4
V-D-5
V-D-6
V-D-7
V-D-8
V-0-9
V-D-10

V-0-11
V-D-12
V-D-13
V-D-14

V-D-15
V-D-16
V-D-17
V-D-18
V-D-19
V-D-20
V-D-21
V-D-22
V-D-23
               List of Commenters Appearing in Docket A-80-46
Commenter
Hunton & Williams
Tennessee Valley Authority
US EPA (OAQPS)
Pennsylvania Power & Light Co.
Hammermill Paper Co
Natural Resources Defense Council
Conoco, Inc.
Aluminum Co. of America
Westvaco
State of Maryland, Office of
   Environmental Programs
Middle South Services, Inc.
County of Santa Barbara, CA
Illinois Power Co.
U S Department of Interior,
Minerals Managment Service
County of Santa Barbara, CA
TRC Environmental Consultants, Inc.
County of Santa Barbara, CA
General Public Utilities Corp.
Tennessee Valley Authority
Pennsylvania Dept. of Env. Resources
Potomac Electric Power Co.
Natural Resources Defense Council
Proctor & Gamble Co.
Date of
Document
9-29-86
10-06-86
9-29-86
9-26-86
9-29-86
10-01-86
10-01-86
10-08-86
10-06-86
10-06-86

10-07-86
10-03-86
10-03-86
10-21-86

10-15-86
12-01-86
12-04-86
12-02-86
12-08-86
12-04-86
12-08-86
12-09-86
12-09-86

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Docket                                                              Date of
Number                   Commenter                                  Document

V-D-24                   Environmental Research & Technology        12-08-86
V-D-25                   Hunton & Williams                          12-09-86
V-D-26                   Boston Edison                              12-05-86
V-D-27                   American Petroleum Institute               12-09-86
V-D-28                   Middle South Services, Inc.                12-08-86
Late Arrivals:
V-H-1                    US Department of Agriculture,             12-17-86
                         Forest Service
V-H-2                    Hunton & Williams                          01-08-87
V-H-3                    Hunton & Williams                          02-02-87

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