January 15, 2014 

MEMORANDUM

SUBJECT: Corrections to UNC Tables of Modeled Visibility Impact 

FROM: Scott Bohning 

 Air Division, AIR-7 

 EPA Region 9 

TO: Arizona Regional Haze FIP Docket EPA-R09-OAR-2013-0588 

This memorandum documents corrections I made in October and December, 2012 to 

spreadsheets created by our contractor, the University of North Carolina, to help us prepare our 

Arizona Regional Haze FIP. These spreadsheets contain tables of CALPUFF modeling results, 

emissions, control costs, and calculation of visibility cost-effectiveness in dollars per deciview. 

The tables were included in reports submitted by UNC to EPA. The problems I found were not 

in the modeling results or in the estimates of emissions and costs themselves, but rather in how 

they were combined in the spreadsheets. 

Note that we did not directly rely on these UNC report tables, and so our FIP proposal is not 

affected by the erroneous values in some of the tables. 

The spreadsheets with mistakes are those for TEP Sundt and the CalPortland Cement Plant: 

• irv_az_unit4_dollarperdv_analysis_final.xls 

• irv_az_units1-3_dollarperdv_analysis_final.xls 

• cpc_az_unit1-4_dollarperdv_analysis_final.xls 

The corrected versions are: 

• irv_az_unit4_dollarperdv_analysis_final_fixed.xls 

• irv_az_units1-3_dollarperdv_analysis_final_fixed.xls 

• cpc_az_unit1-4_dollarperdv_analysis_final_fixed.xls 

The corrections affect the following UNC reports: 

• Technical Analysis for Arizona Regional Haze FIPs: Task 7: Five-Factor BART Analysis 

for Chemical Lime Company Nelson, TEP Sundt (Irvington), and Catalyst Paper 

(Snowflake) Plants, EP-D-07-102 WA5-12 Task 7, Institute for the Environment, 

University of North Carolina at Chapel Hill, October 9, 2012

• Technical Analysis for Arizona Regional Haze FIPs: Task 9: Five-Factor RP Analyses 

for TEP Springerville, APS Cholla, TEP Sundt, CalPortland Cement and Phoenix 

Cement Plants, EP-D-07-102 WA5-12 Task 9, Institute for the Environment, University 

of North Carolina at Chapel Hill, October 3, 2012 
Corrections for Sundt unit 4

Spreadsheet: irv_az_unit4_dollarperdv_analysis_final_fixed.xls

Report affected: none 

Some results spreadsheet visibility results do not match those in the actual CALPOST model 

output files. UNC’s POSTCALPOST processor results matched OK for the very few that I 

checked, so problem seems to be that spreadsheet was not updated with latest model results. 

Affects controls 2, 3, 6, 7, 10, 11. 

In addition, the spreadsheet used leftover constants instead of calculating benefits for: 

 "vis6.annav" benefits for ctrl11 2001 and ctrl7 2002 

 "vis8.20best" benefits for ctrl 9 2001 

These do not affect results in the UNC Task 6 report, which did not use individual years, rather 

just the averages and the merged multiyear results (22nd high over 2001-2003). 

Corrections for Sundt units 1-3

Spreadsheet: irv_az_units1-3_dollarperdv_analysis_final_fixed.xls 

Report affected: Task 9 

ULNB on units 1-3 was modeled along with 1) unit 4 having SCR+DSI, and 2) with unit having 

just DSI. However the benefit of just the ULNB can't be estimated with the "base case" that was 

used. (The "base" has just LNB on unit 4, so the control cases add controls to both 1-3 and 4, 

whereas we really need a comparison that adds controls only to 1-3.) To fix this, I used Task 7 

estimates of unit 4 SCR+DSI, and of unit 4 DSI to provide "base cases" corresponding to the two 

ULNB control runs. This affects all estimates of visibility impact, benefit, and $/dv cost 

effectiveness for Sundt 1-3. (In addition, some of the descriptions of unit 4 controls in the 

spreadsheet did not match those actually used in CALPUFF.) 

Corrections that ideally would be made to Task 9 report, for Sundt 1-3

Tables in "WA5-12 Task 9 Deliverable (Springerville-Cholla-Irvington-CalPortland-PhoenixRPAnalysis Report)_final.pdf" and their replacement from "irv_az_units1-

3_dollarperdv_analysis_final_xied.xls" 

Table 22(a) & 23(a) (p.20, pdf.26), Impairment & Benefits, Method 6(a) 

 → "area impacts-vis6annav" tab, "Table 1(a)", left & right halves 

Table 22(b) & 23(b) (p.21, pdf.27), Impairment & Benefits, Method 8(b) 

 → "area impacts-vis8b20" tab, "Table 1(b)", left & right halves 

Table 24(a) (p.21, pdf.27) Cost Effectiveness 

 → "area impacts-vis6annav" tab, "Table 5(a)" 

Table 24(b) (p.21, pdf.27) Cost Effectiveness 

 → "area impacts-vis8b20" tab, "Table 5(b)" 
Table 25(a) (p.22, pdf.28) Summary of Control Effectiveness 

 → "scenarios-vis6annav" tab, lower pair of tables 

Table 25(b) (p.22, pdf.28) Summary of Control Effectiveness 

 → "scenarios-vis8b20" tab, lower pair of tables 

Corrections for CalPortland Cement

Spreadsheet: cpc_az_unit1-4_dollarperdv_analysis_final_fixed.xls 

Report affected: Task 9 

Some of the runs involved controls just on kilns 1-3, and some just on kiln 4. The descriptions in 

the UNC report and spreadsheet are correct, however the numbering of the various CALPUFF 

runs had these two reversed. I fixed the visibility impacts and benefits just by switching various 

rows and columns; however, the $/dv cost effectiveness numbers are new because a given $ cost 

is now associated with a different dv. This affects all estimates of visibility impact, benefit, and 

$/dv cost effectiveness for CalPortland Cement. 

Corrections that ideally would be made to Task 9 report, for CalPortland Cement

Tables in "WA5-12 Task 9 Deliverable (Springerville-Cholla-Irvington-CalPortland-PhoenixRPAnalysis Report)_final.pdf" and their replacement from "cpc_az_unit1-

4_dollarperdv_analysis_final_fixed.xls" 

Table 31(a) & 32(a) (p.27, pdf.33), Impairment & Benefits, Method 6(a) 

 → "area impacts-vis6annav" tab, "Table 1(a)", left & right halves 

Table 31(b) & 32(b) (p.27, pdf.33), Impairment & Benefits, Method 8(b) 

 → "area impacts-vis8b20" tab, "Table 1(b)", left & right halves 

Table 33(a) (p.28, pdf.34) Cost Effectiveness 

 → "area impacts-vis6annav" tab, "Table 5(a)" 

Table 33(b) (p.28, pdf.34) Cost Effectiveness 

 → "area impacts-vis8b20" tab, "Table 5(b)" 

Table 34(a) (p.28, pdf.34) Summary of Control Effectiveness 

 → "scenarios-vis6annav" tab, lower pair of tables 

Table 34(b) (p.29, pdf.35) Summary of Control Effectiveness 

 → "scenarios-vis8b20" tab, lower pair of tables