Model Clearinghouse Status and Updates

Transcription

1 Model Clearinghouse Status and Updates 2011 R/S/L Modelers Workshop Atlanta, GA George M. Bridgers OAQPS-AQAD-Air Quality Modeling Group 1

2 Model Clearinghouse There s a new sheriff in town OAQPS recognized the significant need for improved coordination with the Regional Offices on the myriad of ongoing NSR/PSD permit modeling issues A dedicated Model Clearinghouse director could focus attention to the needs of the Regional Offices as well as keep OAQPS informed on developing permit modeling issues in a timely fashion reducing the surprises Previously, the Model Clearinghouse had served a central permit modeling role for the Agency Significant desire to reestablish / revitalize the Model Clearinghouse 2

3 George Bridgers Model Clearinghouse Model Clearinghouse Director effective January 3, 2011 Memo introducing the new MC Director was sent out to the Regional Offices (ADD, APM, RO Modeling Contacts) and OAQPS management on April 27,2011 Spent over 12 years working with the NC Division of Air Quality is a variety of roles from ambient monitoring, SIP AQ and met modeling including a very involved role for NC in the VISTAS / SEMAP regional modeling, SIP documentation and submittal, nonattainment t boundary recommendation packages, public meetings and hearings, AQ forecasting and outreach principle developer of NC s AQ forecasting program, architect and sys admin for NCDAQ s Linux Cluster 3

4 What is it? Model Clearinghouse A process and mechanism by which an EPA Regional Office can obtain EPA Headquarters concurrence on implementation ti issues related to air quality modeling. Statutory authority? Appendix W to 40 CFR51, Section 3.3(b): As appropriate, p Regional Office may request assistance from the Model Clearinghouse after an initial evaluation and decision has been reached concerning the application of a model, analytical technique or data base in a particular regulatory action. 4

5 Model Clearinghouse Goals Provides national consistency in regulatory decisions Timely interpretation of guidance (as issues arise) Minimizes bad precedents: Get in early on issues Memoranda provide essential support to regions, states and locals Guidance development through consensus building 5

6 Model Clearinghouse Operation Technical issues Response provided by OAQPS/AQMG and other technical experts with review by policy staff Policy issues (if submitted to MC) Referred to New Source Review Group Response provided by OAQPS/Air Quality Policy Division with technical inputs as appropriate As appropriate, Model Clearinghouse responses may be reviewed by OGC 6

7 Formal Clearinghouse Process State contacts Region Region writes memo to clearinghouse: Statement of Issue Desired approach Justification Clearinghouse facilitates solutions and writes formal response Clearinghouse summarizes & archives decisions: Searchable database (MCHISRS) via web access (SCRAM) Present summary at annual Regional/State/Local workshop Write annual report 7

8 Formal Clearinghouse Process (Continued) OAQPS develops guidance as appropriate: Policy memo, EPA Report, Rule Making 8

9 Importance of Process Importance of Model Clearinghouse process has been stressed in the recent past, especially with promulgation of CALPUFF and AERMOD Emphasis on formal process of Regional Office presenting issue to Model Clearinghouse, perhaps initiated at State level, with full background information and RO position Informal contacts with OAQPS staff do not constitute consulting with the Model Clearinghouse Importance of Modeling Protocols to get review and input early in the process (EPA & FLMs) 9

10 Importance of Process Respecting the roles of various parties/stakeholders Applicant Reviewing authority (RO or State) OAQPS as needed, with both technical (AQMG) and policy (AQPD) perspectives Public Importance of consistency is stressed several places in Appendix W, including the very first sentence: Industry and control agencies have long expressed a need for consistency in the application of air quality models for regulatory purposes. 10

11 Importance of Process Clarify distinction between regulatory modeling applications, which fall under purview of Appendix W, and non-regulatory applications, such as risk assessments The Guideline recommends air quality modeling techniques that should be applied to State Implementation Plan (SIP) revisions for existing sources and to new source reviews (NSR), including prevention of significant deterioration (PSD). Applicable only to criteria air pollutants, it is intended for use by EPA Regional Offices in judging the adequacy of modeling analyses performed by EPA, State and local agencies and by industry. 11

12 Model Clearinghouse Information Storage and Retrieval System (MCISRS) Ample discussion and feedback on MCISRS at the 2010 R/S/L Modelers Workshop On-going effort to update MCISRS to include original (or as near original as possible) signed copies of the formal Model Clearinghouse actions, requests and responses. Kudos to Annamaria Coulter (Region 2) for providing a wealth of archival information 239 entries updated since last year 2/3 rds of these entries are considered formal 12

13 Model Clearinghouse Information Storage and Retrieval System (MCISRS) Work will continue this summer on updating the records 1443 total records (formal & informal) 750 records still need original form of documentation Sorting and contacting ti specific Regional Offices with respect to all outstanding formal Model Clearinghouse actions MCISRS Updates Case Sensitive search capability should be added on or about June 9,

14 Model Clearinghouse Activities Region 10 AERMOD-COARE Application Application of AERMOD in specific parts of the Artic Ocean (Beaufort and Chukchi Seas) to account for influences of overwater transport on plume dispersion from offshore operations (Shell Oil Company) Coupled Ocean-Atmospheric Response Experiment (COARE) bulk flux algorithm replaced AERMET Regional Office was seeking concurrence on their approval of AERMOD-COARE as an alternative model (Section322a a Appendix W to 40 CFR51) 14

15 Model Clearinghouse Activities Region 10 AERMOD-COARE Application (Continued) Regional 10 delivered and well developed Model Clearinghouse request package that included a significant amount of coordination with the permit applicant The materials provided by the applicant and their contractors adequately addressed the five elements associated with Condition 3 as listed in Section e of Appendix W We concurred with Region 10 on the use of AERMOD-COARE in the Beaufort and Chukchi Seas on May 6, 2011 This is not a generic approval of AERMOD-COARE but can serve as a good basis for additional application with the appropriate level of coordination and documentation with ROs 15

16 Model Clearinghouse Activities Region 7 Alcoa Davenport Work / EBDs Ongoing coordination with Region 7 and Alcoa concerning the application of fluid modeling / wind tunnel testing to inform Equivalent Building Dimensions (EBDs) for use in permit modeling The Davenport Works facility is an extremely long (sizeble length to width ratio) and low (basically 1 story) building and typical AERMOD modeling was demonstrating fence line concerns Attempt to use wind tunnel test to develop EBDs Concerns with roughness blocks representing the facility building included with EBD testing in addition to up/downwind surface roughness elements 16

17 Model Clearinghouse Activities Region 7 Alcoa Davenport Work / EBDs (Continued) Alternative approaches being explored and modeled based on the unique nature of the low and elongated building Model Clearinghouse will issue an statement in the formal response to Region 7 that will effectively suspend previous Modeling Clearinghouse approval of the use of fluid modeling / wind tunnel tests to develop / inform EBDs Previous approvals were with respect to developing EBDs for ISC modeling exercises With the promulgation of AERMOD, additional evaluation must be performed Need for coordination with the Regional Offices and MC / AQMG 17

18 Model Clearinghouse Activities Region 4 Chevron / EBDs Lattice type building that present challenges with AERMOD modeling As with Region 7, we are coordinating but also informing on the suspension of the previous approval of wind tunnel tests to develop EBDs Region 8 ND PSD Program AQPD and AQMG are working on a series of responses to specific issues that the Agency has with ND s PSD Program / SIP 18

19 Model Clearinghouse Activities Region 5 Excelsior / Mesaba Energy Project Multiple issues addressed by the FLMs with respect to their Class 1 area modeling protocol Modeling Clearinghouse is being engaged to respond / concur with the FLMs on the issue of the puff splitting option in CALPUFF Applicant has proposed to use the puff splitting option for sourcereceptor distances of significantly less than 200km Historically, puff splitting has only been used for distances of greater than 200km Applicant did not provide technical justification or rational for the deviation 19

20 Discussion & Questions 20

21 Model Clearinghouse Director of Model Clearinghouse George Bridgers OAQPS/AQAD/AQMG (919)