Update on Monitoring, Modeling & Data Issues

1. Update on Monitoring, Modeling & Data Issues Region 4 Air Pollution Control Agencies Fall 2012 Meeting Raleigh, NC October 23, 2102 Richard A. “Chet” Wayland, Director Air Quality Assessment Division

2. Monitoring • Ambient Monitoring Deployment Schedule(Final or Proposed ) • All deployment deadlines by January 1 unless otherwise noted

3. Near-road NO2 Monitoring Proposed Deadlines for Near-road NO2 Monitoring 1st Monitor Jan 2014; 2nd Monitor Jan 2015 January 1, 2014 January 1, 2017

5. Modeling 10th Conference on Air Quality Modeling • Presentations posted immediately after conference: • http://www.epa.gov/ttn/scram/10thmodconfpres.htm • Full transcription posted on June 21, 2012: • http://www.epa.gov/ttn/scram/10thmodconf.htm(Follow Links) • Summary of Comments document including an overview of next steps and action items posted on October 5, 2012: • http://www.epa.gov/ttn/scram/10thmodconf/10thMC_Summary_of_Comments-Revised_10-05-2012.pdf • Response to Comments document projected for delivery at the end of the calendar year 2012. U.S. Environmental Protection Agency

6. 10th Conference on Air Quality Modeling • Formal plan for updates to Appendix W: • Goal to have a draft plan available in early 2013. • Discussion at A&WMA specialty conference and the 2013 RSL Modelers’ Workshop in spring 2013 (Information on these meetings on next slide). • Revised draft plan based on engagement and feedback available soon thereafter. • Rulemaking proposal for language amendments and updates to Appendix W released for public comment and response in connection with the 11th Conference on Air Quality Modeling (late 2014 / early 2015). U.S. Environmental Protection Agency

7. Upcoming Conferences / Workshops • 2013 A&WMA Specialty Conference: • “Guideline on Air Quality Models: The Path Forward” • March 19-21, 2013, Sheraton Raleigh Hotel, Raleigh, NC. • http://boilermact.awma.org/wp-content/uploads/2012/09/AQ_Models_CFA.pdf • 2013 Regional, State, and Local Modelers’ Workshop: • April 22-25, 2013, EPA’s Region 6 office in Dallas, TX. • Open (regulatory, industrial, consultant / contractor, environmental, public) participation day on Tuesday, April 23. • Workshop information will be posted on EPA’s SCRAM website in December 2012 or early January 2013. U.S. Environmental Protection Agency

8. AERMOD Modeling System Updates • Updates based on comments received through the 10th Modeling Conference along with other previously identified needs and ongoing feedback from the regulated modeling community. • Near-term (updated release in early to mid November): • Addition of a minimum wind speed threshold option and a few bug fixes to AERMET. • Interim addressing of "low wind speed" issue based on review of 10th Modeling Conference comments and published literature. • “Beta option" with EPA evaluations demonstrating appropriateness for use in PSD permitting U.S. Environmental Protection Agency

9. AERMOD Modeling System Updates • Near-term – Continued: • Considering updates incorporating EPA's Office of Research & Development (ORD) development of enhanced line-source characterization and algorithm. • ORD delivered drafts to the Air Quality Modeling Group on 9/19/12. • Longer-term: • Reviewing issues with building characterization and downwash algorithms, seeking ORD support for wind tunnel and related research. • Consider other necessary updates based on 10th Modeling Conference comments. U.S. Environmental Protection Agency

10. CALPUFF Modeling System Updates • EPA’s regulatory CALPUFF version 5.8 Modeling System updated to include newer version of the post processing program, CALPOST, on August 27, 2012: • CALPOST version 6.221 (level 080724) includes the "Method 8" IMPROVE equation revision per the Federal Land Managers' Air Quality Related Values Work Group (FLAG) revised October 2010 Phase 1 Report. • http://www.epa.gov/ttn/scram/dispersion_prefrec.htm#calpuff • Updates to the regulatory CALPUFF version 5.8 to address known bug fixes • Met with Federal Land Managers and working to modify and test code updates for provision to TRC by the end of 2012. U.S. Environmental Protection Agency

11. SO2 NAAQS Activities • Reviewing 09/2012 beta release of EPRI funded variable emissions tool, EMVAP, and related programs for consideration as part of future state attainment demonstrations in determining enforceable limits: • Planning discussions with EPRI immediately following the CMAS conference in October 2012. • http://sourceforge.net/projects/epri-dispersion/ • Updating SO2 SIP modeling guidance for attainment demonstrations (late 2012 / early 2013) for use by areas to be designated nonattainment. U.S. Environmental Protection Agency

12. SO2 NAAQS Activities • Review and comments on evaluations of AERMOD modeling of current SO2 sources, ongoing with updated reports by states and/or EPA presentations in future. • EPA review of recently reported AERMOD evaluations by IDEM have uncovered issues with representativeness of meteorological inputs and input errors that once addressed significantly improves model performance for 1-hour SO2 concentrations with model to monitored ratios of 1.15 to 1.3. • EPA will continue to pursue opportunities to evaluate AERMOD modeling system to ensure appropriate use for SO2 implementation by state and local agencies. U.S. Environmental Protection Agency

13. NO2 NAAQS Activities • Released NO2 In-Stack Ratio (ISR) database on EPA’s SCRAM website on August 30, 2012: • Completed through small workgroup of EPA, state, and local agency modelers. • http://www.epa.gov/ttn/scram/no2_isr_database.htm • Continue working with API and their contractors on ARM2 as a modified NO2 Tier 2 method: • Reviewing documentation and evaluations, awaiting updates with specifics on how to formally implement within AERMOD. • Upon full receipt, EPA will independently verify evaluations and, as appropriate, write a guidance memorandum on how ARM2 may be used for permitting applications. U.S. Environmental Protection Agency

14. NO2 NAAQS Activities • Engaging with stakeholders on evaluations of NO2 Tier 3 approaches of OLM and PVMRM. • Continue to advocate for new field studies to allow more full model performance evaluation so these Tier 3 approaches could be characterized as refined methods as part of the planned regulatory update to Appendix W. • As discussed at 10th Modeling Conference, EPA will need support from the community to fund, design and conduct such field studies so looking for partners for collaboration and/or willing to consult on external efforts. U.S. Environmental Protection Agency

15. PM2.5 NAAQS Activities • As part of proposed PM2.5 NAAQS, completed technical memorandum demonstrating basis for surrogacy policy to address PSD requirements of potential secondary visibility index standards. • Completing draft PM2.5 Permit Modeling Guidance for public release (mid/late-October): • Comments will be accepted on the draft guidance document throughout the remainder of 2012. • Final PM2.5 Permit Modeling Guidance (early 2013) • Planning discussions on SCICHEM and CMAQ-APT with EPRI and contractors (Sage Management & Environ) during CMAS conference in October 2012. U.S. Environmental Protection Agency

16. Data 2012 Ozone Data: Region 4 States follow the nation-wide trend

17. 2012 generally produced more exceedances but not necessarily higher concentrations on peak days

19. Analysis of Ozone and Meteorology Atlanta, Charlotte, Chattanooga, Louisville, and Memphis June – July, 2012 Preliminary Analysis – Please Do Not Quote or Cite

20. Background • From June 26 to July 1, 2012, high ozone was measured across the southeast • During this time period, the region also experienced a record heat wave • Analysis of meteorological data indicates that the following conditions were present during this period: • High temperature (several all-time high temperatures were recorded) • Low humidity • Low cloud cover (therefore high solar intensity) • These conditions are all conducive to ozone formation

29. Annual Monitoring Network Plan Reviews

30. EPA’s Network Plan Approval / Disapproval Process • States are required to submit Network Plans to EPA by July 1 • Prior to July 1: • EPA develops/updates tools that the agencies can use to evaluate their network to determine if it is meeting the minimum requirements. • EPA encourages questions throughout the drafting phase. • When provided drafts, EPA tries (if time allows) to review and provide comments on them. • After July 1: • Once the final Network Plan is received EPA meets with the states via phone or in person regarding questions EPA has about the plans. • Approval letters are drafted by state contacts and are reviewed by section chief, branch chief and signed by the Division Director.

31. EPA’s Network Plan Approval / Disapproval Process (cont.) • Approval authority for Network Plans was delegated this year from the RA to the APTMD Director. • Letters with many requested changes generally require more analysis and time. • Some changes (e.g., shut downs) may require more analysis and time. • EPA has 120 days to approve Network Plans. • No formal appeal process is outlined in the regulations; however, EPA is willing to discuss at any time any issue and review any additional information that a state would like it to.

32. EPA Network Plan Reviews: Take Away Messages • EPA will discuss adverse responses with you and/or your staff. • Monitors and sites are evaluated on a case by case basis. • Statistical test found in 40 CFR Part 58.14(c)(1) is applied to every SLAMS monitor, every year, using the previous 5 years of design values.

33. EPA Network Plan Reviews: Take Away Messages (cont.) • Proposing to discontinue the highest monitor in an area is rarely approved, even if it is a single pollutant site. • If EPA finds the discontinuance of a monitor will not compromise data collection needed for implementation of a NAAQS, and if the other requirements in Appendix D continue to be met, then EPA is more likely to agree with closing a monitor (or site).

34. EPA Network Plan Reviews: Take Away Messages (cont.) • Any monitor listed as SLAMS requires EPA approval for any change associated with that monitor. • Regardless of whether the monitor is in a MSA/CBSA or whether there are more than the federal minimally required monitors in a MSA/CBSA

35. EPA Network Plan Reviews: Take Away Messages (cont.) • Budget constraints are not the best reason to cite for closing a monitor or site. • If siting criteria and/or site access is an issue, we will be happy to complete a site evaluation with you. • If a SLAMS monitor is not eligible for removal under any of the criteria listed in 40 CFR Part 58.14(c)(1) through (c)(5), and logistical problems beyond the state’s control make it impossible to continue operation, then the monitor may be moved to a nearby location with the same scale of representation.