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## SO 2 

## Air Dispersion Modeling Report for White Bluff Steam

Electric Station

August 2015

ERM Project No. 0268066

www.erm.com

## SO 2 

## Air Dispersion Modeling Report for White Bluff Steam

Electric Station

August, 2015

ERM Project No. 0268066

_____________________________________ Peter T. Belmonte

Partner

- in

- Charge

_____________________________________ Richard P. Hamel
Project Manager

Environmental Resources Management
One Beacon Street, 5 th Floor

Boston, MA 02108

T: 617

- 646

- 7800

F: 617

- 267

- 6447ii

TABLE OF CONTENTS

INTRODUCTION 1

- 1 1.0

PROJECT OVERVIEW 1

- 1 1.1

OVERVIEW OF METHODOL OGY 1

- 2 1.2

FACILITY DESCRIPTION AND REGULATORY SETTI NG 2

- 1 2.0

FACILITY LOCATION 2

- 1 2.1

SO 2 ATTAINMENT STATUS 2

- 1 2.2

SOURCE PARAME TERS AND EMISSION RA TES 2

- 4 2.3

AIR DISPERSION MODEL ING ANALYSIS 3

- 1 3.0

MODEL SELECTION AND APPLICATION 3

- 1 3.1

THE 1

- HOUR SO 2 NAAQS 3

- 1 3.2

METEOROLOGICAL DATA 3

- 1 3.3

RECEPTOR GRID 3

- 3 3.4

GOOD ENGINEERING PRA CTICE STACK HEIGHT A NALYSIS 3

- 4 3.5

AMBIENT SO 2 BACKGROUND DATA FOR CUMULATIVE MODELING 3

- 4 3.6

MODELING RESULTS 4

- 1 4.0

CONCLUSIONS 4

- 1 4.1

REFERENCES 5

- 1 5.0iii LIST OF TABLES

Table 2

- 1 White Bluff Station Point Sources

– Stack Parameters 2

- 5

Table 3

- 1 Characteristics of the Adams Field

– Little Rock Meteorological Data 3

- 2

Table 3

- 2 Seasonal Diurnal SO2 Concentrations at Little Rock Monitor (μg/m3) 3

- 5

Table 4

- 1 1

- hour SO 2 Modeling Results for White Bluff Station 4

- 1

LIST OF FIGURES

Figure 1

- 1 White Bluff Station Surroundings and Land Use 1

- 4

Figure 2

- 1 White Bluff Station Site Pl an 2

- 2

Figure 2

- 2 White Bluff Station Local Topography 2

- 3

Figure 3

- 1 Relative Location of Facility, Airport, and Ambient Monitor 3

- 6

Figure 3

- 2 Three

- year Wind Rose (2012

- 2014): Little Rock

– Adams Field 3

- 7

Figure 3

- 3 Near

- Field Model Receptors 3

- 8

Figure 3

- 4 Far

- Field Model Receptors 3

- 9

Figure 4

- 1 White Bluff Station 1

- hour SO 2 Impact Contours 4

- 2

LIST OF APPENDICES

APPENDIX A ELECTRONIC MODELING ARCHIVEERM 1

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INTRODUCTION 1.0

ERM Consulting & Engineering, Inc. (ERM), has prepared this report documenting that

maximum model

- predicted SO 2 impacts from Entergy Arkansas Inc.’s (Entergy) White Bluff Steam Electric Station (White Bluff) are in attainment with the 1

- hour Sulfur Dioxide (SO 2 ) National Ambient Air Quality Standa rd (NAAQS) and will fulfill the requirements of the EPA’s 1

- Hour SO 2 Data Requirements Rule (DRR) . This analysis shows that the ambient air quality in the vicinity of White Bluff, currently undesignated

for the 1

- hour SO 2 NAAQS, is within the standard an d should be identified as

“attainment” in the next cycle of designations.

This modeling report describes the modeling methodology that was used to evaluate potential impacts of SO 2 emissions from White Bluff on ambient air quality. Copies of the modeling fi les are provided in Appendix A, the Electronic Modeling Archive.

Project Overview 1.1

Unlike previous NAAQS attainment demonstrations, EPA has proposed to make 1

- hour

SO 2 NAAQS attainment determinations using ambient air monitoring data and/or air dispersion modeling. In situations where air modeling is used to make this determination, the approach described in EPA’s proposed “Modeling Technical Assistance Document” (TAD) 1 , which sets forth a significantly different technical approach compared to conventional regulatory modeling prescribed by 40 CFR Part 51, Appendix W (EPA’s Guideline on Air Quality Models ) could be used. This approach

would also meet the requirements of the DRR

.

EPA distinguishes the approaches described in the SO 2 Modeling TAD to “reflect a view that designations are intended to address current actual air quality (i.e., modeling

simulates a monitor ), and thus are unlike attainment plan modeling, which must provide assurances that attainment will occur.” EPA’s proposed approach would utilize several distinctive technical approaches, including but not limited to the following:

 Simulating actual emissions and exhaust conditions (e.g., temperature and flo wrate) on an hourly basis reflecting actual operations for a specified historical time period;

 Representing actual stack heights, irrespective of the GEP regulations;

 Limiting modeled ambient air receptors to locations where monitoring could actually tak e place by excluding waterways, roadways, railways, restricted access property, and other locations that would conventionally be considered “ambient air” for regulatory and permitting purposes; and

1 http://epa.gov/oaqps001/sulfurdioxide/pdfs/SO2ModelingTAD.pdfERM 1

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 Simulating a three

- year period of meteorological and background monitoring data, concurrent with the actual operating conditions and emissions, to meet EPA’s objective that “modeling simulates monitoring” in this context.

ERM performed a modeling analysi s evaluating the impacts on ambient air quality

from SO 2 emissions at White Bluff. As discussed in this report, ERM’s approach to the modeling analysis used those refinements directly addressed in the proposed rule, i.e. the use of actual hourly emissions, actual stack heights, and seasonal diurnal ambient background concentrations.

As shown in this modeling report, SO 2 impacts from White Bluff emission sources,

when combined with ambient air concentrations taken from a nearby representative monitor, are below the 1

- hour SO 2 NAAQS.

This first section of this report describes the model ing methodology that was followed. Section 2 provides a description of the facility and the emissions included in the modeling. Model selection and the methodology used in the modeling are described in Section 3. The modeling results are presented in Secti on 4. References are provided in

Section 5.

Overview of Methodology 1.2

ERM’s assessments were conducted in a manner consistent with United States Environmental Protection Agency (EPA) air quality regulations and modeling guidelines that are generally adopted by Arkansas Department of Environmental Quality (ADEQ), including the following:

 Guideline on Air Quality Models

– 40 CFR Part 51, Appendix W, Revised November 9,

2005.

 AERMOD Implementation Guide , Revised March 19, 2009;

 “SO 2 NAAQS Designations Modeling Technical Assistance Document (Draft),”
December 2013;

 “SO 2 NAAQS Designations Monitoring Technical Assistance Document (Draft),”
December 2013;

 “Data Requirements Rule for the 2010 1

- Hour Sulfur Dioxide (SO 2 ) Primary Nationa l Ambient Air Quality Standard (NAAQS),” Pre

- publication final rule, ( submitted to the Federal Register on August 10, 2015, FRL

- 9928

- 18

- OAR ); and

 “Guidance for 1

- hour SO 2 Nonattainment Area SIP Submissions,” April 23, 2014.

The steps that were undertake n by ERM to conduct the air dispersion modeling analyses are summarized below:ERM 1

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 Compiled information on the parameters and characteristics for all sources of SO 2 emissions at White Bluff including the main EGU’s, the auxiliary boiler, the emergency diesel g enerator, and the fire pump engine;

 Developed a comprehensive receptor grid to capture the maximum off

- site impacts

from White Bluff sources using AERMAP (v.11103)

.

 Obtained ambient background concentration data for SO 2 from nearby monitors to represent sources not explicitl y included in the modeling runs ;

 Developed 3 years (2012

- 2014 ) of meteorological data using surface observations from Adams Field in Little Rock, AR with upper air data from North Little Rock Airport using the most recent version (v.15181 ) of AERMET, the meteorological data processor for AERMOD, and its two preprocessors: AERSURFACE (v.13016) and AERMINUTE (v. 14337 ).

 Conducted an air dispersion modeling analysis using the most recent version of EPA’s regulatory d ispersion model, AERMOD (v.15181 ) and 3 years (2012

- 2014) of actual emissions data from White Bluff Sources, consistent with the methodology

described in the SO 2 Data Requirements Rule and SO 2 Modeling TAD.

 Summarized the results and compared them with the 1

- hour SO 2 NAAQS to

determine a recommended attainment designation for the vicinity of White Bluff.ERM 1

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Figure 1

- 1 White Bluff Station Surroundings and Land UseERM 2

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FACILITY DESCRIPTION AND REGULATORY SETTI NG 2.0

Facility Location 2.1

The White Bluff Steam Electric Station is located in the town of Redfield, Arkansas, along the western b anks of the Arkansas River. The station is located about 3 miles southeast of downtown Redfield. The site is accessed by Arkansas State Route 46. The station is approximately 24 miles south

- southeast of Little Rock, Arkansas and 16 miles

northwest of Pine Bluff, Arkansas. Approximate site coordinates are 34.424 o North
Latitude, 92.139 o West Longitude. The Universal Transverse Mercator (“UTM”) coordinates of the facility are 579,107 Easting and 3,809,459 Northing (using North

American Datum of 1983

- NAD83) in UTM Zone 15. The base elevation of the facility is 310’ (94.488m) above sea level. A full scale site plan of White Bluff is shown in Figure 2.1, and Figure 2.2 shows the site location marked on a United States Geological Survey (“USGS”) 7.5

- minute topog raphic map.

SO 2 Attainment Status 2.2

In July 2013, EPA issued a rule designating 29 counties or partial counties as non

attainment for 1

- hour SO 2 . However, the vast majority of the country was not designated by EPA at that time due to the lack of monitors, or poor siting of existing monitors, for the purpose of capturing source based maximum ambient SO 2 concentrations. None of the counties surrounding White Bluff, including Jefferson , the county in which White Bluff is located, have been designated as attain ment or non

attainment for the 1

- hour SO 2 NAAQS.ERM 2

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Figure 2

- 1 White Bluff Station Site PlanERM 2

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Figure 2

- 2 White Bluff Station Local TopographyERM 2

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Source Parameters and Emission Rates 2.3

Fo r this 1

- hour SO 2 NAAQS modeling demonstration, all sources of SO 2 at the facility were included in the modeling. Per the 1

- hour SO 2 Data Requirements Rule and SO 2 Modeling TAD, the most recent 3 years of actual emissions data were used where available, and the actual stack heights of all sources were used in the modeling. The following provides a description of all White Bluff SO 2 emission sources represented in

th e model runs . Table 2

- 1 summarizes the characteristics of the emissions sources that were included in the modeling. The actual emissions data used in the modeling are

described below:

 Units No. 1 and No. 2 (Source ID: SN01 and SN02)

. There are two boilers in operation at the White Bluff Station, Unit 1 and Unit 2. Units 1 and 2 are vented
to a common, dual

- flue stack. For the se main units, three years (2012

- 2014 ) of actual hourly emissions, stack temperature, and exhaust flow rate data were input into the m odel. Th is emissions data w as provided by Entergy from prior

submittals to the EPA’s Clean Air Markets Database , while temperature and exhaust flow rates were provided by Entergy from the facility CEM system . As per the 1

- hour SO 2 Data Requirements Rule, t he actual 1000 ft. height of the main stack was represented in each case. The two Units at the facility were modeled as separate sources, each emitting from their own flue. This is a conservative representation because it neglects potentially enhanced buoy ancy from a combined plume from both flues.

 Auxiliary Boiler (Source ID: SN05). The auxiliary boiler was also modeled using actual hourly emissions data. For this source, however, exhaust temperature and velocity were not available, so for all hours the exit temperature and velocity were set to the values located in the ADEQ source registration tables for the auxiliary boiler.

 Emergency Diesel Generator (Source ID: SN21) and Emergency Fire Pump Engine (Source ID: SN22). The two emergency engines at the facility both have horizontal exhaust releases. This is represented in the modeling by setting the exit velocity of each source to 0.001 m/s to simulate the lack of vertical

momentum out of the stack. Emissions data were only available on a month by

month total emission basis for each engine. To convert that data into an emission rate for modeling, for each engine the total annual emissions for each year was determined and the highest annual total selected. That total was then divided by 52 to represent tha t the engines are tested once per week during the year. The resulting emission rate was then used as the lb/hr emission rate in the modeling. Based on information provided by Entergy employees , the emergency generator

is typically tested weekly on Wednesda ys, while the fire pump is typically tested on Friday evenings. To simulate this standard practice, the emergency generatorERM 2

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was set in the modeling using the HRDOW7 emission factor (i.e., variable by hour of day and 7 days per week) to emit during an 8 hou r period on Wednesdays from 8 AM to 4 PM, and the fire pump was set to operate on Friday’s from 4 PM until Midnight. While this significantly overestimates the total emissions of the emergency engines, because the form of the 1

- hour SO 2 standard only considers the hour with the highest concentration each day, at least 7 of these hours are “dropped” and thus only one hour worth of emission is potentially included in the maximum daily impacts.

Data supporting the actual emissions used fo r the 5 sources included in the modeling are provided in the spreadsheets WB_Hourly Actual Emissions 2012

- 2014 .xlsx and WB Em G en Hours and Emissions 2012

- 2014 .xlsx included in Appendix A: The Electronic Modeling Archive.

Table 2

- 1 White Bluff Station Point Sources

– Stack Parameters

Description Model

Source Stack Height Exit Temperature Exit Velocity Stack

Diameter
(ft) (m) (F) (K) (ft/sec) (m/s) (ft.) (m)

Unit 1 Boiler 1 SN01 1000 304.80

--- --- --- --- 25.7 7.83

Unit 2 Boiler 1 SN02 1000 304.80

--- --- --- --- 25.7 7.83

Auxiliary Boiler SN05 15 4.57 475 519.25 65.0 19.81 3.0 0.91

Emergency Diesel Engine SN21 24 7.32 963 790.54

---- 0.001 2 0.8 0.25

Emergency Fire Pump SN22 14 4.27 1058 843.15

---- 0.001 2 0.5 0.15

1. For the 2 main boilers, exit temperature and exit velocity varied on an hourly basis based on actual emissions

data.

2. Emergency Diesel Engine and Emergency Fire Pump stacks are horizontal, so modeled exit velocity was 0.001 m/s for both.ERM 3

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AIR DISPERSION MODEL ING ANALYSIS 3.0

ERM conducted the modeling analysis for White Bluff to quantify ambient impacts of

SO 2 relative to the 1

- hour NAAQS following the proposed approach described in the

SO 2 Modeling TAD.

Model Selection and Application 3.1

The latest version of USEPA’s AERMOD model (v.15181 ) was used for predicting ambient impacts for 1

- hour SO 2 . Regulatory default options were used in the analysis. Model predicted impacts were combined with an ambient background concentration and compared to the 1

- hour SO 2 NAAQS to determine the recommended attainment status of the area in the vicinity of the facility.

The 1

- hour SO 2 NAAQS 3.2

This study focuses on the maximum model

- predicted 1

- hour SO 2 impacts of White Bluff and compares them to the 1

- hour SO 2 NAAQS. The new standard came into effect in August, 2010. The form of the standard is the 99 th percentile of the 3

- year average 1

- hour daily maximum concentration, and the standard was set to 75 ppb (196.5  g/m 3 ).

Meteorological Data 3.3

Guidance for regulatory air quality modeling recommends the use of one year of on

- site meteorological data or five years of representative off

- site meteorological data. The SO 2 Modeling TAD however, specifies that 3 years of meteorological data concurrent to the actual emissions data being input into the model be used. Since on

- site data are not

available for the White Bluff site, meteorological data available from the National Weather Service (NWS) were used in this analysis.

Three years (2012

- 2014 ) of surface observations from the NWS tower at Adams Field Airport in Little Rock, AR (WBAN No. 13963) and concurrent up per air data from North Little Rock Municipal Airport in North Little Rock, AR (WBAN No. 03952) were processed with the most recent version of AERMET (v.1 5181 ) the meteorological preprocessor for AERMOD, along with the two pre

- processors to AERMET:

AERSURF ACE (v.13016) and AERMINUTE (v. 14337 ). AERMET was applied to create the two meteorological data files required for input to AERMOD.

AERMET requires specification of site characteristics including surface roughness (z

o ), albedo (r), and Bowen ratio (B

o ). These parameters were developed according to the guidance provided by EPA in the AERMOD Implementation Guide (AIG) (EPA, 2008a) using AERSURFACE. The area within 1 km of the meteorological tower at Adams Field was broken into 12 sectors of 30 degrees each to analyze the surface characteristics in each 30 degree arc around the tower. AERMET uses the surface characteristics in theERM 3

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sector from which the wind approaches the tower as part of the meteorological data processing for each hour.

In AERSURFACE, the various land cover categories are linked to a set of seasonal surface characteristics. As such, AERSURFACE requires specification of the seasonal category for each month of the year. The following five seasonal categories are offered by AERSURFACE:

1. Midsummer with lush vegetation;

2. Autumn with unharvested cropland;

3. Late autumn after frost and harvest, or winter with no snow;

4. Winter with continuous snow on ground; and

5. Transitional spring with partial green coverage or short annuals.

The AERSURFACE run was performed using the seasonal temporal resolution option. The default seasonal distribution was used: December, January, and February were categorized as winter with no snow, March, April, and May as spring, June, July, and August as summer, and Septem ber, October, and November as fall. The precipitation was assumed to be average over the 3

- year period.

Additionally, 1

- minute ASOS wind data, collected at the Adams Field meteorological tower, were processed using the AERMINUTE pre

- processor for AERMET. The data

characteristics of Adams Field are shown in Table 3

- 1. Figure 3

- 1 shows the relative location of Adams Field and White Bluff Station, and Figure 3

- 2 shows the 3

- year wind

rose for Adams Field.

Table 3

- 1 Characteristics of the Adams Field

– Little Rock Meteorological Data

Distance from White Bluff Station 21.7 miles

Average Wind Speed 3.42 m/s

Percent Calm Hours 1.10 %

Data Completeness 99.95 %

All files associated with the meteorological data processing are included in Appendix A: The Electronic Modeling Archive.ERM 3

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Receptor Grid 3.4

A comprehensive Cartesian receptor grid extending out to approximately 20 kilometers (km) from White Bluff was used in the AERMOD modeling analysis to assess maximum ground

- level 1

- hour SO 2 concentrations. The Modeling TAD states that the receptor grid must be sufficient to determine ambient air quality in the vicinity of the source being studied. The 20

- kilometer receptor grid is more than sufficient to resolve the

maximum 1

- hour SO 2 impacts in the area around White Bluff , and it clearly illustrates decreasing SO 2 concentration gradients in relation to the plant.

The Cartesian receptor grid consisted o f the following receptor spacing:

 50

- meter spacing along the facility fence line;

 100

- meter spacing extending from the fence line to 5 kilometers;

 500

- meter spacing extending from 5 to 10 kilometers; and

 1,000

- meter spacing extending from 10 to 20 kilomet ers.

The above receptor data was used without modification in the modeling. Per the 1

- hour

SO 2 Modeling TAD, a number of receptors located over the Arkansas River and the nearby Pine Bluff Arsenal could be excluded from the modeling domain because

ambient monitors could not reasonably be placed at these locations, but these receptors were retained in this analysis as a measure of conservatism.

Terrain elevations from National Elevation Data (“NED”) from USGS were processed using the most recent version of AERMAP (v.11103) to develop the receptor terrain elevations required by AERMOD. NED data files contain profiles of terrain elevations, which in conjunction with receptor locations are used to generate receptor height scales. The height scale is the terr ain elevation in the vicinity of a receptor that has the greatest influence on dispersion at that location and is used for model computations in complex

terrain areas. The near

- field (within 5 kilometers) and far

- field (full grid) receptor grids

are shown in Figures 3

- 3 and 3

- 4, respectively.ERM 3

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Good Engineering Practice Stack Height Analysis 3.5

As described in the SO 2 Modeling TAD, when modeling actual emissions from a facility

in order to evaluate the attainment status of an area with regard to the 1

- hour SO 2 NAAQS, the full height of all stacks is allowed in the modeling regardless of their GEP Formula Heights. Therefore, no GEP stack height analysis is necessary for this study.

E ach source was modeled with its actual stack height in the an alysis

, and downwash effects were considered through the use of EPA’s buildi ng profile input program (BPIP)

.

Ambient SO 2 Background Data for Cumulative Modeling 3.6

It was assumed, after initial modeling, that impacts from White Bluff sources would

exceed th e 1

- hour SO 2 Significant Impact Level (SIL) of 7.9  g/m 3 . As a result, ambient background data from the closest , most representative SO 2 monitor to White Bluff was downloaded from the ADEQ ambient monitoring website to represent other sources of

SO 2 in the area . A review of the data showed that the most representative monitor for use in the modeling is located in Little Rock (Monitor ID# 05

- 119

- 0007).

EPA guidance allows simulation of background values that vary by season and hour of day that could simulate a lower value than the 99th percentile. The modeling was performed with a set of seasonal diurnal values developed using the methodology
described in the USEPA March 1st, 2011 Clarification Memorandum for 1

- hour NO 2 Modeling. Though this memora ndum primarily addresses NO 2 modeling, page 20 describes the process for developing seasonal diurnal background values for SO 2 as well.

The location of the selected ambient monitor relative to White Bluff is shown in Figure

3

- 1. The seasonal diurnal values used are show n in Table 3

- 2

.ERM 3

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Table 3

- 2 Seasonal Diurnal SO2 Concentrations at Little Rock Monitor ( μg/m3)

Hour 1 Winter Spring Summer Fall

1 6.89 5.67 4.80 5.50

2 7.85 5.32 4.28 6.19

3 7.33 6.19 4.45 6.02

4 6.89 5.76 4.19 4.71

5 8.55 4.97 4.19 5.15

6 9.60 4.80 5.41 5.85

7 9.60 6.28 5.50 6.63

8 8.99 5.24 6.11 6.54

9 7.50 6.46 7.68 7.85

10 8.38 8.20 7.42 9.07

11 9.16 8.46 9.95 8.20

12 10.73 15.09 10.38 9.34

13 9.69 11.08 10.91 11.17

14 10.56 9.34 9.86 9.51

15 10.03 8.20 13.18 9.95

16 9.42 7.94 9.34 10.47

17 7.15 9.86 11.08 9.16

18 7.50 7.42 9.69 7.24

19 9.25 6.37 9.86 6.98

20 12.30 6.54 8.73 5.93

21 9.07 6.02 6.19 6.28

22 6.11 8.99 5.76 5.67

23 6.46 7.07 5.67 5.85

24 7.24 6.81 5.41 6.11

1. Hours in AERMOD are defined as hour

- ending. i.e., Hour 1 is the period from midnight through 1 AM, etc.ERM 3

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Figure 3

- 1 Relative Location of Facility, Airport, and Ambient MonitorERM 3

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Figure 3

- 2 Three

- year Wind Rose (2012

- 2014 ): Little Rock

– Adams FieldERM 3

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Figure 3

- 3 Near

- Field Model ReceptorsERM 3

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Figure 3

- 4 Far

- Field Model ReceptorsERM 4

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MODELING RESULTS 4.0

The modeling results are shown in Table 4

- 1 below. The modeled design value represents the modeled 3

- year average of the 99th percentile, maximum daily 1

- hour average impact for White Bluff, which is then added to the ambient background

concentrat ion and the total impact compared to the NAAQS to demonstrate attainment.

Contours of the predicted impacts, as well as the location of the maximum p redicted impact of 162.4  g/m 3 , are shown in Figure 4

- 1 . The table shows that model predicted impacts from White Bluff , when modeled using the most recent three years of actual

emissions data and added to a representative ambient background concentration , are below the level of the 1

- hour SO 2 NAAQS.

Table 4

- 1 1

- hour SO 2 Modeling Results for White Bluff Station

Source White

Bluff
Only White Bluff

and
Background 1

- hr. SO 2

NAAQS Below

NAAQS?

White Bluff Station 153.7 162.4 196.5 Yes

Conclusions 4.1

The air dispersion modeling performed as described in this report shows that the SO 2 emissions from White Bluff Station result in maximum predicted impacts below the

1

- hour SO 2 National Ambient Air Quality Standard. T herefore

, an attainment designation for Jefferson County is recommended.ERM 4

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Figure 4

- 1 White Bluff Station 1

- hour SO 2 Impact ContoursERM 5

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REFERENCES 5.0

U.S. Environmental Protection Agency. (USEPA 2005) Guideline on Air Quality Models (GAQM, 40CFR Appendix W), November, 2005

U.S. Environmental Protection Agency. (USEPA 2009) AERMOD Implementation
Guide, AERMOD Implementation Workgroup. March 19, 2009.

U.S. Environmental Protection Agency. (USEPA 2011) USEPA memo entitled “Additional Clarification Regarding Application of Appendix W Modeling Guidance

for the 1

- hour NO 2 National Ambient Air Quality Standard”, US EPA, Office of Air Quality Planning and Standards, Raleigh, NC. March 1, 2011.

U.S. Environmental Protection Agency. (USEPA 2014) “SO 2 NAAQS Designations Modeling Technical Assistance Document (Draft),” December 2013;

U.S. Environmental Protection Agen cy. (USEPA 2014) “SO 2 NAAQS Designations Monitoring Technical Assistance Document (Draft),” December 2013;

U.S. Environmental Protection Agency. (USEPA 2014) “Data Requirements Rule for the

1

- Hour Sulfur Dioxide (SO 2 ) Primary National Ambient Air Qualit y Standard (NAAQS),” Final rule submitted August 10, 2015 ; and

U.S. Environmental Protection Agency. (USEPA 2014) “Guidance for 1

- hour SO 2 Nonattainment Area SIP Submissions,” April 23, 2014.

## Appendix A

Electronic Modeling Archive