UNITED STATES OF AMERICA

ENVIRONMENTAL PROTECTION AGENCY 

 

 

 

 

EIGHTH CONFERENCE ON AIR QUALITY MODELING 

_________________________________________ 

EPA Auditorium 

109 TW Alexander Drive 

Research Triangle Park, NC 

September 23, 2005 

V O L U M E 2 OF 2 

_______________________ 

P A G E S 1 - _251 

__________________ ___ 

 

 The above entitled meeting was called to order by Tyler J. Fox 

PRESIDING OFFICER: 

TYLER J. FOX 

Group Leader 

Air Quality Modeling Group (C439-01) 

Office of Air Quality Planning and Standards 

EPA 

Research Triangle Park, NC 27711 
 Vol. 2, p. 2 

 A P P E A R A N C E S 

 _____________________ 

 

 Presiding: Tyler Fox, Leader, Air Quality Modeling 

 Group 

 

 Warren Peters, Model Clearing House 

 Director, EPA 

 

 ________________________________________ 

 

 

 
 Vol. 2, p. 3 

 T A B L E O F C O N T E N T S 

 _________________________________ 

 

 

 

 Topic Presenter Page No. 

 _____ _________ ________ 

 

 Opening Remarks Tyler Fox 6 

 

 Updating Regulatory Desmond Bailey 13 

 Dispersion Models 

 

 Updating regulatory Roger Brode 18 

 Dispersion Models 

 

 Questions Audience 39 

 

 Review, Current and Warren Peters 48 

 Available Model 

 Evaluations 

 

 Ideas/Selection and John Irwin 64 

 Approval 

 

 Comments/New Approach Robert Paine 75 

 on Modeling 

 

 European Assessment David Carruthers 81 

 

 Industrial Viewpoints Ken Steinberg 87 

 

 Comments Warren Peters 91 

 

 Comments John Irwin 92 

 

 Panel Comments 95 

 

 Model Acceptance Tyler Fox 114 

 

 Panel/Selection and John Irwin 117 

 Approval 

 

 Panel/New Models Robert Paine l24 

 

 
 Vol. 2, p. 4 

 T A B L E O F C O N T E N T S 

 _________________________________ 

 (Continued) 

 ___________ 

 

 Topic Presenter Page No. 

 _____ _________ ________ 

 

 Panel/Foreign David Carruthers 129 

 Development 

 

 Panel/Model Ken Steinberg 136 

 Comparison 

 

 Panel/State Ken McBee 140 

 Perspective 

 

 Panel/State Chris Arrington 145 

 Perspective 

 

 Audience Questions/Comments 148 

 

 AWMA/AB3 Gale Hoffnagle 173 

 

 AWMA/AB3 Ron Petersen 174 

 

 AWMA/CFD Alan Huber 176 

 

 AWMA/Modeling Ron Petersen 181 

 

 AWMA/AB3 Russell Lee 186 

 

 AWMA/AB3 Mark Bennett 196 

 

 FAA/EDMS Development Ted Thrasher 209 

 

 UARG Cindy Langworthy 224 

 

 API Ken Steinberg 232 

 

 AWMA/AB3 Robert Paine 242 

 

 EPA Keyword Index 252 

 ________________________________________ 

 
 Vol. 2, p. 5 

 The following EIGHTH CONFERENCEE ON AIR 

 QUALITY MODELING, was continued at the United States 

 Environmental Protection Agency, Building C, Auditorium 

 C-111, Research Triangle Park, North Carolina, and was 

 reported by Manie P. Currin, Court Reporter and Notary Public 

 in and for the State of North Carolina, on Friday, September 

 23, 2005, commencing at 8:00 a.m. 

 The following proceedings were had, to wit: 

 ________________________________________ 

 

 

 

 

 
 1 Opening Remarks/Tyler Fox Vol. 2, p. 6 

 2 TYLER FOX: Why don't we go ahead and get started now. 

 

 3 Good morning to everybody; hope you all have 

 4 your coffee and everything in hand. Again, we will 

 5 try and work through things so that we can get a 

 6 break in in the morning. 

 7 I know there is a lot to go through, and then 

 8 there will be public comments this afternoon. 

 9 I wanted to go through a summary, real quick, 

10 and hopefully get us on track. Wanted to start 

11 with just a statement about where we are going and 

12 what we are trying to do and just kind of a 

13 philosophy here which is, you can plan all you 

14 want, and if you don't do anything, it's really 

15 meaningless. 

16 And you can do all you want, but if you are 

17 not planning, and you don't know where you're 

18 going, that's just not very smart. But if you 

19 actually plan and do things to implement your plan, 

20 you're going to get someplace. 

21 Now, it may not be exactly where you thought 

22 you were going to go, and it may not be exactly 

23 where everybody agreed to go, but as long as you're 

24 doing it together, it's got to be a better place 

25 than where you came from. 
 1 Opening Remarks/Tyler Fox Vol. 2, p. 7 

 2 And what we are trying to do here, and I think 

 3 as you saw through the vision statement that we've 

 4 got here for this area of our group, is to try and 

 5 define where we need to go and what our what our 

 6 core purpose is. 

 7 We, could continue to do the things that we've 

 8 been doing for the past three decades, in the way 

 9 that we did them for the last three decades. And 

10 quite frankly, I just don't think that that is 

11 going to be a viable or sustainable thing, given 

12 the changes that we're seeing both internally and 

13 externally; internally in the terms of the models 

14 that we are dealing with that you heard yesterday, 

15 AERMOD is no ISC. 

16 AERMOD and CALPUFF open up a whole new area of 

17 science; modeling science and the like, that really 

18 change and make more complex the world that we live 

19 in, and appropriately so. And that puts an extra 

20 burden on us in terms of the complexities to make 

21 sure the outside world understands and appreciates 

22 those complexities in the decisions that they make. 

23 The other thing is, externally, you know, the 

24 time of -- of making requests and getting hundreds 

25 of thousands or millions of dollars to -- for model 
 1 Opening Remarks/Tyler Fox Vol. 2, p. 8 

 2 development and other types of things just isn't 

 3 going to be a reality. We are going to have to 

 4 make do and work with smaller budgets, have do 

 5 things more ourselves and more in a collaborative 

 6 approach, taking advantage of the comparative 

 7 advantage that we all have and expertise in other 

 8 areas. 

 9 So, just wanted to highlight that, and, again, 

10 our first two elements there in terms of fostering 

11 a collaborative environment across EPA and other 

12 stakeholders and partners. The second element of 

13 the use of gridded met data, you saw that 

14 yesterday. 

15 The first two sessions, AERMOD implementation 

16 and CALPUFF implementation. 

17 You heard the background of the complexities 

18 of the model, and then all the way through, I 

19 thought nicely flowing, to the implementation 

20 issues and the challenges that we all face with 

21 this new model, and the existing model that we 

22 have, CALPUFF, and the current challenges and 

23 future challenges that we have with it; 

24 implementing it, learning through applications and 

25 bringing that information to the public, for us all 
 1 Opening Remarks/Tyler Fox Vol. 2, p. 9 

 2 to understand and recognize and then do something 

 3 about it. Do something with that information to 

 4 move us forward. 

 5 And then you had the panel discussion 

 6 yesterday afternoon, focusing on the use of gridded 

 7 met data, something that we need to consider. We 

 8 need to be careful and thoughtful in our 

 9 consideration in moving ahead obviously, but it's 

10 an avenue that we need to pursue to open up both 

11 readily accessible and maybe better information for 

12 our models and being able to allow our models to 

13 utilize some of the scientific skills that we're -- 

14 that we're bringing into -- into these systems. 

15 And today, this morning, we will hear some 

16 more about CALPUFF and the updating of it, in terms 

17 of moving from the EPA approved version to the -- 

18 to the beta version, and Mark Evangelista and 

19 company will go through that. 

20 But I did want to walk through the third and 

21 fourth elements, because that's going to be the 

22 focus of the two panels this morning, which is, 

23 focusing on continually developing the way in which 

24 we evaluate our models, and pushing our models in 

25 ways that maybe they haven't been pushed before, 
 1 Opening Remarks/Tyler Fox Vol. 2, p. 10 

 2 and then prioritizing the direction that we need to 

 3 take our models in terms of the research and the 

 4 improvements in them. 

 5 And then fourth, thinking about alternative 

 6 approaches or different ways of going through model 

 7 acceptance, and having it be more timely, have it 

 8 respect the evolution of models, in a more timely 

 9 and more immediate way, and always, is there 

10 championing the best use of the science in each and 

11 every application. 

12 And I wanted to finish with some 

13 acknowledgements. This was only a -- you know -- 

14 two-day conference, but it takes a lot of effort, 

15 and I wanted as to recognize a number of folks who 

16 made it possible. 

17 First, Warren Peters, our Model Clearing House 

18 Director, really stepped in and did a great job to 

19 make this happen. 

20 He coordinated everything, got the logistics 

21 done, the layout, everything. It wouldn't have been 

22 possible without Warren's efforts, and I really 

23 appreciate Warren and his and effort. 

24 Also, you met a number of folks that work 

25 here, both in our NOAA branch; Mark Evangelista, is 
 1 Opening Remarks/Tyler Fox Vol. 2, p. 11 

 2 the branch chief. Desmond Bailey and Dennis 

 3 Atkinson are in our NOAA branch, doing a wonderful 

 4 job on the meteorological side, and within our 

 5 division. 

 6 And then you also saw folks within my group, 

 7 the Air modeling -- Quality Modeling Group; 

 8 including Karen Wesson, the -- Pete Eckhoff, and 

 9 actually that's -- that's really it in terms of our 

10 dispersion modeling. 

11 We are organizing ourselves across our -- 

12 across teams, and the folks that you saw make up 

13 our dispersion modeling team with Warren as -- as 

14 the lead. 

15 And those are the folks that you always should 

16 feel comfortable contacting if you have any 

17 questions including myself -- our clarification on 

18 things. 

19 They are all able to and capable of answering 

20 these questions, and if we need to pursue other 

21 folks to get you the answers that you need then 

22 certainly we'll do so. 

23 Also I wanted to -- to thank the regional 

24 modelers that are here, a number of whom 

25 participated actively yesterday. And I really am 
 1 Updating Dispersion Models/D. Bailey Vol. 2, p. 12 

 2 thankful that they're here with us, and to be 

 3 honest, we couldn't have a successful program. 

 4 They are key and critical in doing the things 

 5 that we do here, and they're often not the ones 

 6 that -- that get a lot of -- a lot of 

 7 appreciation. 

 8 But I did want to acknowledge Al Cimorelli, 

 9 Bret Anderson, Brian Hennessy, Stan Krivo, 

10 Rick Gilliam, Herman Wong, Kevin Golden. Am I missing 

11 somebody --? 

12 Eric Schneider, Mick Daye. Is there anybody else 

13 that I missed. We got a really nice turnout from 

14 the regional modelers, and, again, I appreciate 

15 their coming and attending this function with us. 

16 So, with that, let's go ahead and get started 

17 on the EPA's new approach to updating models, the 

18 case of CALPUFF and we'll have a presentation 

19 there, and then we'll move into panel discussions 

20 through the rest of the morning, and then as I 

21 said, we'll have the public comments this 

22 afternoon. 

23 Thank you. 

24 DESMOND BAILEY: Good morning. I'm glad to 

 

25 see that most of you survived the -- Oh! Brian's 
 1 Updating Dispersion Models/D. Bailey Vol. 2, p. 13 

 2 last night. 

 3 (Chuckles from audience.) 

 4 (Auditorium lights are adjusted.) 

 5 DESMOND BAILEY: Well, what I intend to talk 

 6 about is a -- it's not a new approach, but an 

 7 improved approach for updating our dispersion 

 8 models. 

 9 And what I will discuss, or talk about, is the 

10 sort of a generic aspects of the approach, and then 

11 I'll follow up with Roger Brode with -- will 

12 discuss the application of the approach to the 

13 CALPUFF model. 

14 It's basically a -- what we put together is a 

15 standard operating procedure. Its -- parts of it 

16 are a work-in-progress. 

17 It's to be implemented when we make changes to 

18 a regulatory dispersion model, either CALPUFF or 

19 AERMOD. And it will be completed -- it's intended 

20 to be completed prior to the release of the updated 

21 model. 

22 They -- it has three essential elements. We 

23 need -- it needs to identify differences in model 

24 estimates that are used in regulatory decision 

25 making. 
 1 Updating Dispersion Models/D. Bailey Vol. 2, p. 14 

 2 WARREN PETERS: Desmond, excuse me, could I 

 3 have you step up with the microphone? 

 4 DESMOND BAILEY: Be more than happy to. 

 5 WARREN PETERS: Thank you. 

 6 DESMOND BAILEY: It's designed to identify 

 7 differences between the beta and the updated model 

 8 of -- the current model and the beta, the updated 

 9 model in estimates that are used in regulatory 

10 decision making. 

11 And then the protocol, or the procedures, are 

12 -- the next step would be to resolve these 

13 differences, either -- in some way. 

14 When we update a model in some cases we expect 

15 differences. Sometimes we will find differences we 

16 didn't expect, and we need to examine them and 

17 determine -- or decide if they're okay, or do we 

18 need to go back and look for a bug or reevaluate, 

19 and then the final thing is to document. 

20 The -- I will say that this is not intended to 

21 replace the model clearing house facility degrees 

22 of freedom in a CALPUFF modeling analysis and its 

23 future in AERMOD analysis. There are going to be 

24 issues that can only be addressed through a lot of 

25 clearing house approach. This will not replace 
 1 Updating Dispersion Models/D. Bailey Vol. 2, p. 15 

 2 that. 

 3 We have tried to capture some of the degrees 

 4 of freedom in the CALPUFF through a selection of 

 5 scenarios. We certainly invite participation from 

 6 the public to, you know, comment on what scenarios 

 7 we have chosen, and if there are scenarios that 

 8 need to be added, we would certainly welcome that 

 9 input. 

10 We -- the whole process will be transparent. 

11 We intend to post the results on SCRAM, and provide 

12 the tool and the necessary files for running the 

13 tool in some fashion to -- to your people. 

14 The heart of the tool, or the heart of the 

15 procedure, if you will, is a -- what we call an 

16 analysis tool. It manages the extraction or the -- 

17 I'm sorry -- the execution of the old and new model 

18 components and in a case like CALPUFF -- there are 

19 multiple components. In the case of the CALPUFF, 

20 we're only looking at two components of a -- 

21 we're looking at the -- at CALMET and CALPUFF. 

22 We haven't -- although we use CALPOST to 

23 generate the results, and we have not really 

24 exercised the -- all the components of the CALPOST. 

25 And there are preprocessors to CALMET. They 
 1 Updating Dispersion Models/D. Bailey Vol. 2, p. 16 

 2 are not included in this -- at this point, although 

 3 they will be in the future. 

 4 The tool takes care of file management. It 

 5 extracts results from a model output files; 

 6 identifies differences in the model estimates and 

 7 then creates summary reports. 

 8 As I say, with the -- all the degrees of 

 9 freedom in a -- in a modeling system like CALPUFF, 

10 this is the type of tool that's necessary. 

11 It's more than necessary now. In the past we 

12 did get by with doing an analysis from your desk 

13 top, and -- but that's beyond -- beyond our 

14 capabilities. We need some -- need a tool, 

15 something like this. 

16 I think I mentioned what the, you know, what 

17 the -- how do we resolve differences or resolving 

18 differences or the results expected which several 

19 model components are involved in the difference if 

20 we do find a difference; is it one, or is it a 

21 combination or two or more? 

22 Is the difference compiler related? Is the 

23 difference significant? 

24 And the bottom line, is it okay -- are we 

25 comfortable releasing the model to the regulatory 
 1 Updating Dispersion Models/D. Bailey Vol. 2, p. 17 

 2 applications. 

 3 (Projecting new slide.) 

 4 The options for approval, or update, are a 

 5 blessing. You can take your pick in the case of 

 6 CALPUFF. 

 7 I think -- I think the -- probably, we will 

 8 approve CALPUFF in some form or another with 

 9 qualifications. I think this is what we would aim 

10 for, and Roger will present some results from the 

11 analysis, and we'll be looking at those results in 

12 the next several weeks, in a making a -- going 

13 through the options for approval. 

14 As I said, the process is intended to be 

15 transparent. Results and the tool and the 

16 scenarios will all be made publicly -- they will 

17 all be available. 

18 And this one, I guess is out of order, but 

19 this is one of Roger's -- 

20 FROM THE AUDIENCE: I think that's an older version of the 

21 presentation. 

22 DESMOND BAILEY: Is that an older version of the 

23 presentation? 

24 FROM THE AUDIENCE: It's an old version of the presentation. 

25 DESMOND BAILEY: Okay. Can we get a -- let's see -- I guess 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 18 

 2 we can, maybe --. 

 3 FROM THE AUDIENCE: So far, I think the only change was the 

 4 "objectives" was all caps. That was my first clue. 

 5 We've got to run the analysis through on it and -- 

 6 (Comments and laughter from audience.) 

 7 ROGER BRODE: Hey, Desmond, don't go too far in case I need 

 

 8 to direct any questions your way. 

 9 Overview of CALPUFF. (Correct computer slide 

10 is located.) 

11 ROGER BRODE: Is there a pointer here, too? 

12 WARREN PETERS: Yes, it's right there. 

13 ROGER BRODE: As Desmond said, the -- this is the tentative 

14 starting point. Right now, there are ten scenarios 

15 included in the test data set. There's actually an 

16 eleventh optional that covers chemistry, but the 

17 chemistry deposition components of CALPUFF aren't 

18 really technically part of the regulatory 

19 application of the model. 

20 (Projecting slide.) 

21 So the focus of the first ten scenarios is 

22 just on estimating concentrations. The ten 

23 scenarios cover a range of source types, modeling 

24 domains and meteorology, types of meteorological 

25 data. 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 19 

 2 Right now, we are focused on preparing a base 

 3 version of the model which is to defined as the 

 4 April, 2003 version that was officially promulgated 

 5 a few years ago. And we are comparing that to a 

 6 Beta version of the model, which is now the July, 

 7 2004 version, and the analysis tool is set up as a 

 8 two stage process. 

 9 The primary analysis is what we call it, is to 

10 compare the base version of CALMET and CALPUFF 

11 together with the Beta version of CALMET and 

12 CALPUFF, and that's just a straight comparison, and 

13 then identify if there are any differences between 

14 the base and beta versions of the modeling system. 

15 If differences are found, then a secondary 

16 analysis can be performed on the affected 

17 scenarios. 

18 And the secondary analysis is, again, designed 

19 to attribute whether the differences in this case 

20 are due to changes in CALMET or CALPUFF. 

21 Okay, and it does mention right now the 

22 processors to CALMET are not part of the analysis 

23 tool or part of the data set. It's just focused on 

24 the main components of CALMET and CALPUFF. 

25 And this graph here tries to illustrate that 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 20 

 2 overall process, so you have the base version of 

 3 CALPUFF, and the base version of CALMET run, and so 

 4 that's one model run. The Beta version of CALPUFF 

 5 and the Beta version of CALMET are run. That's the 

 6 primary analysis is to compare those two. 

 7 If there are differences found there, then the 

 8 secondary analysis can be performed which runs the 

 9 Beta version of CALPUFF against the Beta version of 

10 CALMET. 

11 And since we've already actually run both of 

12 those, we actually don't have to rerun -- we just 

13 have to do one set of runs, and if those are -- 

14 those results are compared to the two previous sets 

15 of results and depending on, if you get differences 

16 one way or the other, you can attribute it to the 

17 CALMET or CALPUFF or in some cases, both. 

18 We don't need to do that comparison. There is 

19 no additional information to the system. 

20 And these scenarios, of course, are made up of 

21 range of sources, again a long range of modeling 

22 domains that cover, you know, CALMET, can cover a 

23 wide gamut of modeling scenarios from --. 

24 So, the complex flow, local scale impacts 

25 assessment to, of course, the long-range transport 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 21 

 2 assessment. 

 3 Range of terrain scenarios are included and 

 4 meteorological data, we have both. 

 5 NWS driven scenarios as well as incorporating 

 6 MM5 data. And then we, also, since we are still in 

 7 a transition from a PG based dispersion, ISC-like 

 8 dispersion to AERMOD-like dispersion, we also 

 9 include different options for dispersion in the 

10 scenarios. 

11 (Projecting slide.) 

12 And there is a lot of information on this 

13 slide. I thought about splitting it up, but here's 

14 a brief description about the ten (10) scenarios 

15 that are included. 

16 The first five scenarios actually include 

17 real met data, either the National Weather Service 

18 data, or MM5, or both. 

19 And the bottom five are all sort of set up as 

20 idealized scenarios to idealize met data, idealize 

21 domain and very -- they are much smaller domain, 

22 and the idea there is to provide some additional 

23 information for diagnostic purposes, if we need to 

24 focus in on impacts for a certain source type, for 

25 example, then that can provide some useful 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 22 

 2 diagnostic information. 

 3 We start with the large scale in the scenario 

 4 one, and that's the large domain -- I'll show you 

 5 some slides to give you an idea of what the domains 

 6 look like. 

 7 (Projecting slide.) 

 8 In the Pacific Northwest, and that's based on 

 9 just NWS data only, surface and upper air data. 

10 (Projecting slide.) 

11 Scenario two is the exact same domain, but 

12 driven by MM5 in the No Obs mode. So, --. 

13 (Projecting slide.) 

14 Scenario three is sort of medium scale, sort 

15 of subset of that first domain focused more in the 

16 coastal area of Oregon, and this one we used NWS 

17 data with MM5, so a mixture. 

18 (Projecting slide.) 

19 Then we have another medium scale domain near 

20 the Shenandoah National Park, sort of, you know, 

21 some of these were set up intentionally to simulate 

22 what an actual scenario might look like or an 

23 actual CALPUFF application might look like. 

24 (Projecting slide.) 

25 And then, again, the -- then there was one 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 23 

 2 small scale complex flow situation in the Deep 

 3 Valley and the Columbia River Gorge. And then 

 4 finding that utilized data sets we had two that 

 5 included an idealized scale, first run was 

 6 similarity dispersion and second run was PG-based 

 7 dispersion. 

 8 (Projecting slide.) 

 9 And then eight and nine are these same 

10 scenarios, but without the hill, again, comparing 

11 similarity-based dispersion and PG-based 

12 dispersion. 

13 Now, all of these nine, actually, we ran 

14 CALMET, so even for the idealized scenarios, we 

15 sort of generated the met data to run through 

16 CALMET to get the wind field, so these are, as we 

17 mentioned, wind fields. 

18 (Projecting slide.) 

19 Scenario ten (10) is the only scenario that 

20 didn't include CALMET, and that -- we fed it 

21 CTDM-type surface and profile data to simulate 

22 vertical wind shear, and, again, using the 

23 idealized hill in the scenarios six and seven. 

24 Now, as far as the sources go, we identified 

25 the four core sources that are included in all the 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 24 

 2 scenarios, and that includes the ground level area 

 3 source, the elongated source, a ten-meter volume 

 4 source, a thirty (30) meter non-buoyant point 

 5 source, and then a sixty-five (65) meter buoyant 

 6 point source. 

 7 So each of these scenarios includes at least 

 8 those four sources. 

 9 Now, for scenarios one, two and five, again, 

10 one and two are the larger-scale domains, and those 

11 two domains are about a thousand kilometers on the 

12 side, so five hundred (500) kilometers from the 

13 center point. 

14 We actually included two sets of those core 

15 sources at different parts of the domain. 

16 And then scenario three, we had the four core 

17 sources, plus, we put in a taller point stack near 

18 the coast just to see what would happen. 

19 Scenario four, again, we have the four core 

20 sources, plus, we had a the buoyant source. So we 

21 tried to cover range of source types and introduce 

22 different elements in different settings. 

23 Scenarios six and seven, we also added some 

24 PRIME downwash sources, a thirty-five (35) meter 

25 buoyant stack, a thirty-five (35) meter cap stack, 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 25 

 2 and then a fifty (50) meter buoyant stack. I think 

 3 those were all with the -- so a typical thirty-four 

 4 (34) meter building that's been used in EPA 

 5 consequence analyses. 

 6 (Projecting graph.) 

 7 This is a graphic showing scenario one, which 

 8 is, again, is a large scale domain in the Pacific 

 9 Northwest. I think you can sort of pick out some 

10 of the features there; those red squares, if you 

11 can see and define the locations of the sources, so 

12 there were four sources located down near Salem, 

13 Oregon, and another set over here in Jordan Valley 

14 kind of on the east- -- eastern edge of Oregon. 

15 And then the locations of the NWS surface and 

16 upper air station is also depicted there. I think 

17 this is showing surface roughness with the terrain 

18 contours based upon the CALMET terrain. 

19 This was -- the grid spacing for this was 

20 twelve kilometers (12km), and it just so happened 

21 the MM5 data we used also had a twelve kilometer 

22 (12km) grid spacing. 

23 (Projecting slide.) 

24 It's the same domain, just showing the land 

25 use data; again, those two red squares represent 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 26 

 2 the locations of the groups of sources. 

 3 (Projecting slide.) 

 4 These are some plots that came along with the 

 5 MM5 data, showing the domain. It was a much larger 

 6 domain, and we took a subset out of the MM5 domain 

 7 to drive scenario two, which was MM5 in the No Obs 

 8 mode, and it shows the land use type, terrain 

 9 heights for that region. 

10 (Projecting slide.) Scenario four; I don't 

11 have a depiction for scenario three right now to 

12 show you, but, again, it's a subset up in this 

13 region of scenario one, with, I believe, with a 

14 four-kilometer (4km) grid spacing. 

15 (Going back to previous map.) 

16 So we started with twelve kilometer (12km) MM5 

17 data in that case and went to four kilometer (4km) 

18 CALMET grid spacing for scenario three. 

19 (Projecting slide.) This is scenario four, 

20 and then just another different element here, in 

21 that we had several Class 1 areas in the region; 

22 there's Shenandoah National Park and a couple of 

23 other [regional] class scenarios. 

24 So, in terms of receptors, all the other 

25 scenarios we just used it -- used the sampling grid 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 27 

 2 part of CALPUFF for receptors. 

 3 (Projecting slide.) 

 4 Here we introduced discrete receptors, 

 5 probably in the different Class 1 areas, and then 

 6 we also put in a smaller, tighter resolution 

 7 sampling grid next to -- close to one of the 

 8 sources. 

 9 So the core sources are down here, sort of 

10 with prevailing winds blowing it toward the 

11 National Park, and then the buoyant area source was 

12 located at a -- on the west side of Shenandoah 

13 Valley, trying to simulate a forest fire in that 

14 region, again, somewhat downwind of the sampling 

15 grid. 

16 (Projecting slide.) 

17 This is a sort of near-field complex flow 

18 scenario in the Columbia River Gorge; pretty deep 

19 gorge, and again here we have two sets of the core 

20 sources, one located down in river valley; that 

21 location. And another set is located up on the 

22 ridge over here. 

23 (Projecting another slide.) 

24 And I think it was roughly about a hundred by 

25 a hundred (100x100) domain; not exactly, a hundred 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 28 

 2 by eighty (100x80), actually, I think. And we 

 3 actually based this on some inputs that Joe Scire 

 4 at Earth Tech provided, so we appreciate his input. 

 5 And MFG provided us -- Incorporated, provided us us 

 6 with the MM5 data for scenario two and three. 

 7 The idealized scenarios, once again, scenario 

 8 six, includes an idealized Gaussian shaped hill, 

 9 three hundred meters in height, located at the 

10 center of a ten (10) by ten (10) kilometer domain, 

11 with a grid spacing of two hundred and fifty (250) 

12 meters. 

13 Sources were located at the left edge of the 

14 domain, upwind of the hill, and simulated steady 

15 state meteorology was set up to idealize. 

16 (Projecting slide.) 

17 We had six hours of stable conditions in a 

18 steady state, trying to simulate a steady state 

19 condition; six hours of near neutral and six hours 

20 of convective. And for scenario six, again, the 

21 dispersion was based on the similarity theory. 

22 And this (projecting next slide) doesn't show 

23 the actual domain, but it does show you the general 

24 shape of the Gaussian hill, by Gaussian a little 

25 bit wider in one dimension than the other. 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 29 

 2 (Projecting slide.) 

 3 The other idealized scenarios based on the 

 4 same basic setup. Scenario seven is, again, the 

 5 same as scenario six, except with PG-based 

 6 dispersion. 

 7 (Projecting slide.) 

 8 Scenario eight (8) is the same as six (6) 

 9 except without the hill. So scenario eight uses 

10 similarity dispersion. 

11 (Projecting slide.) 

12 Nine is the same as eight except using 

13 PG-based dispersion. 

14 (Projecting slide.) 

15 Now, ten (10), again, is sort of the only one 

16 that doesn't use CALMET. We fed the data through 

17 the CTDM surface and profile option, and we tried 

18 to introduce simulated shear, vertical wind shear, 

19 both wind speed and wind direction. 

20 And in this case, we had two sets of simulated 

21 steady state meteorology, six hours of stable 

22 conditions, six hours of near neutral. And here we 

23 just looked at dispersion based on similarity 

24 theory. 

25 (Projecting slide.) 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 30 

 2 So here is some depictions of concentration 

 3 contours for some of the different sources for 

 4 scenario six (6), just to give you an idea. 

 5 So here is a ten-kilometer (10) by 

 6 ten-kilometer (10) domain. Unfortunately, I 

 7 couldn't get the terrain contoured in here, but on 

 8 the some of the slides you'll see pretty clearly 

 9 where the terrain is located. 

10 And the source is located at the western edge 

11 with the wind flow from left to right, sort of 

12 blowing at the hill. 

13 (Projecting slide.) 

14 This is a ten-meter (10m) volume source. You 

15 see part of the plume does -- too. 

16 See some impact of the hill there, part of the 

17 plume going around the hill. This is for the 

18 stable conditions. 

19 And that's the thirty-meter (30m) non-buoyant 

20 source for stable. The terrain influence becomes a 

21 little more noticeable there. 

22 Sixty-five (65) meters, looks like the plume 

23 mostly goes over the hill, but you can certainly 

24 see some of the enhanced impacts at the center of 

25 the domain where the hill is located. 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 31 

 2 (Projecting slide.) 

 3 And then for -- this is one of those downwash 

 4 sources, for the kind of cap stack with MM fact set 

 5 to zero, so that it behaved pretty much like a 

 6 volume source, except with some downwash. 

 7 And that's the same source without the cap 

 8 showing again the enhanced impact where the hill is 

 9 upwind of the -- on the upwind side of the hill. 

10 (Projecting slide). 

11 This is the fifty-meter (50m) downwash source, 

12 again for stable conditions. 

13 (Projecting slide.) 

14 Now, in the scenario ten (10), again, we have 

15 the same hill located in the surface domain, but we 

16 put our sources -- moved out sources down near the 

17 southwest edge of the domain, because the wind 

18 shear from the winds near the surface are coming 

19 out of the west and up at about two hundred (200) 

20 meters are coming out of the southwest. I think we 

21 built for sixty degrees (60o) of shear up to a 

22 level -- two hundred (200) meter level. 

23 So this is the ten-meter (10m) volume source, 

24 so it's pretty much going to east to west, but you 

25 start -- as the plume grows, you start to to see 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 32 

 2 some of the influence of the vertical wind shear 

 3 for the downwind. 

 4 (Projecting slide.) 

 5 This is the ten-year volume source under 

 6 neutral conditions, so, again, the plume is much 

 7 deeper, and it's experiencing -- showing more 

 8 effects of the wind shear. Previous slides, I 

 9 guess, were stable. 

10 (Projeting slide.) 

11 This is the thirty-meter (30m) nonbuoyant 

12 source in stable conditions, and there is a little 

13 bit of leftward shift to the plume impact, but not 

14 much. But if you go to neutral conditions, -- 

15 (Projecting slide.) 

16 -- you see a definite impact of that shear's plume 

17 picks up to higher levels. 

18 (Projecting slide.) 

19 This is the sixty-five (65) meter buoyant 

20 source, so you can see the hill pretty clearly, as 

21 it's impacting the hill pretty directly under 

22 stable conditions. Under neutral conditions, a 

23 little bit of an impact from the hill, but not a 

24 lot, just a broader footprint. 

25 So, some of these -- 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 33 

 2 (Projecting slide.) 

 3 -- these results are still pretty fresh in terms of 

 4 the analysis. The base version to the newer Beta 

 5 version, dated July, 2004, and just a brief summary 

 6 of those results so far, mostly minor differences 

 7 were found, but these differences occurred in all 

 8 scenarios except scenario ten (10). 

 9 In other words, scenario ten (10) is the only 

10 scenario that didn't base its meteorology on CALMET 

11 to some extent. And scenario ten (10) had no 

12 differences between base and Beta. 

13 We did run a secondary analysis to these, and 

14 all differences that we saw were attributable to 

15 changes into CALMET. So that simplifies the post 

16 analysis a little bit. These narrows the focus. 

17 The maximum difference that we saw in terms of 

18 ranked high values was about five percent (5%), and 

19 that occurred before the volume source in scenario 

20 four and stuck out a little bit because most of the 

21 differences that we saw were less than about point 

22 three percent (.3%). 

23 And finally there was no consistent trend in 

24 terms of the bias of the results; some were higher, 

25 some were lower, based on the Beta versus base. 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 34 

 2 But just to say a little bit more about the 

 3 analysis tool itself, it summarizes the results at 

 4 different levels. So the first level is just a 

 5 simple binary comparison; are there differences or 

 6 not, and the output file actually just says, yes or 

 7 no, for each source, you basically get a yes or no, 

 8 there're differences or there're not. Doesn't 

 9 quantify those differences and then the next level 

10 of comparison, it just gives you the overall 

11 maximum and minimum percent difference anywhere in 

12 the domain for that source. 

13 And then the next step is to give the maximum 

14 overall minimum or the maximum difference 

15 normalized by the highest value for that averaging 

16 time. 

17 And then we actually go in and we selected 

18 several range values. We looked at the first, 

19 second, fourth and eighth highest for each 

20 averaging period. We look at the one-hour, 

21 three-hour, eight-hour, twenty-four-hour and period 

22 end -- period averages, and so a lot of focus is 

23 probably going to be on those range values since 

24 they are of the most interest for a regulatory 

25 application of the model. 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 35 

 2 I think the five point two percent (5.2%) 

 3 difference for volume source occurred for the 

 4 eighth highest value. But most of the other range 

 5 values, showed no differences or very small 

 6 differences again. 

 7 And then there is another level that basically 

 8 can give you a distribution of the percent -- you 

 9 know -- the percentage difference in different 

10 bins, so within plus or minus point one percent 

11 (.1%), plus or minus point five percent (.5%), and 

12 so on. 

13 And then finally we also generated plot files 

14 of differences, and so if you want to in and look 

15 at in much more detail and try to diagnose the 

16 problem, in fact we have a -- show you here very 

17 quickly here, what we did for scenario two. That 

18 was, again, just MM5 data driving it in the No Obs 

19 mode, and I don't know whether you can see this, 

20 but this is the large modeling domain, and it's 

21 about a thousand kilometers on the side. 

22 The volume -- this was looking at the volume 

23 source near Salem which is located right there. 

24 You can see the contours there, just to put -- put 

25 that in perspective, and then this is a plot -- a 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 36 

 2 fraction of biases over the whole domain for that 

 3 volume source. 

 4 And you can see most of it is occurring right 

 5 up here in the northwest corner, so -- and looking 

 6 at just that quadrant, you can see a little more 

 7 detail. That -- the differences are focused along 

 8 the coast. This is where the coastline kind of 

 9 comes into play within that domain. And so all the 

10 action is right along the coast. 

11 And that kind of points to the changes that 

12 was made in CALMET, going from the base version, 

13 actually, to the July 2003 Beta version which 

14 corrected a problem with mixing heights over 

15 waters, so we think that is probably the source of 

16 these differences. 

17 Again, these are very small concentrations, if 

18 you, oops, go -- anyway your source is way down 

19 here. You're talking about large differences in 

20 very small values, so in terms of the regulatory 

21 impact it's not significant. In this case, it's 

22 sort of clean in that we have a clearly 

23 identifiable cause of those differences. 

24 As Desmond said, there is some additional 

25 analysis is going to be done over the next several 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 37 

 2 weeks to try to understand the full range of the 

 3 results that we've seen so far, and make a decision 

 4 about it. 

 5 And just to sort of summarize some of the 

 6 issues that we encountered, and maybe some lessons 

 7 learned in the process, first because we wanted to 

 8 encompass a full range of typical applications of 

 9 the CALPUFF modeling system, we had wanted to 

10 include the scenario with the Lambert Conformal 

11 option, and one issue we dealt with is that the 

12 base versions of the modeling system have an issue 

13 dealing with Lambert Conformal. There was a little 

14 bug in there. 

15 So we made the decision early on to go ahead 

16 and fix just that one bug in the base version, so 

17 that we could include that scenario, and we 

18 appreciate your experienced help with getting the 

19 average log, because we wanted to also eliminate 

20 any differences due to compiler differences, so Joe 

21 provided us with the executables that we needed for 

22 that. 

23 There is not -- I mean, there's some guidance 

24 on using Lambert Conformal option, but as far as 

25 how you define you reference latitudes, there is 
 1 Updating Dispersion Models/Roger Brode Vol. 2, p. 38 

 2 not a lot of information that we can see readily 

 3 available in the CALPUFF documentation. 

 4 Let's see -- I guess one of the big issues I'm 

 5 sure anybody who has run the CALPUFF modeling 

 6 system has dealt with is, there is no source 

 7 grouping available. So in this case, we really 

 8 wanted to be able to present results on a source by 

 9 source basis, so it would be easier to diagnose and 

10 understand what's happening, and so each source was 

11 set up as a separate run. 

12 There are, you know, some fixed arrays on this 

13 and, again ran into a little problem because the 

14 prognostic data limits in CALMET didn't match the 

15 low mets for the grid arrays. 

16 And so our MM5 data, since it was already 

17 twelve kilometer spacing, we needed to up the array 

18 limits on the prognostic data arrays for CALMET, 

19 also ran into a limit in TERREL for a number of DEM 

20 files needed for scenarios one and two, and those 

21 were the large-scale domains. 

22 You know, there's no slug option for PRIME 

23 sources; probably wouldn't want to run it, because 

24 it would take that much longer to run but --. 

25 And then there are a few unsupported NWS met 
 1 Questions/Audience Vol. 2, p. 39 

 2 data formats, some of the MM5 data was, I think, 

 3 from 2001 or 2002, so we wanted to use National 

 4 Weather Service data for the same time period, and 

 5 that meant we wanted to use the ISHWO data that was 

 6 the easiest format to work with, and that's not 

 7 directly supported, so we had to do some data 

 8 manipulations to get it into the, I think, Sam- -- 

 9 a SAMSON format so we could run it through CALMET. 

10 So I think that sums it up. If there are any 

11 questions, I'll be glad to ask for Desmond's help 

12 in answering them. 

13 (No response.) 

14 I think that Desmond did mention that the data 

15 set and analysis tool are going to be provided. 

16 There will some issues to deal with the size of it. 

17 I think the full data set with all the outputs 

18 comes on a smart disc. 

19 FROM THE AUDIENCE: Do you have any thought as to how you 

 

20 would add scenarios, if they were required, say, 

21 for example, what I'm thinking is that in this 

22 case, as you pointed out, there is known bug in 

23 mixing height over water. So if you had not had a 

24 scenario that included water, you wouldn't see 

25 that, and we can't, of course, anticipate any bugs 
 1 Questions/Audience Vol. 2, p. 40 

 2 that might be discovered in the future. 

 3 So if there is a situation in the future where 

 4 there is -- that's driving the change from a 

 5 current version to a new version and that's not 

 6 somehow included in your current scenarios, have 

 7 you given any thought to how you would add the 

 8 scenario to address that situation? 

 9 DESMOND BAILEY: You know I'd -- we would certainly -- I 

10 mean, we could add scenarios. We would have to -- 

11 I mean it would be, you know, the the template is 

12 there, so it would be an easy -- it wouldn't be 

13 easy, but it would be certainly doable and we would 

14 welcome it. 

15 I think the -- that's the type of input that 

16 -- of additional scenarios that we would want to 

17 include. 

18 ROGER BRODE: I think, as we mentioned earlier, we don't -- 

19 we're not including the preprocessors for CALMET in 

20 the data sets at this time. That's a future 

21 expansion, but this is sort of the first step. 

22 But I think all we would need, or all Desmond 

23 would need, would be the CALMET and CALPUFF inputs, 

24 also CALPOST preferably, but -- and I don't think 

25 it would be that hard just to set it up and 
 1 Questions/Audience Vol. 2, p. 41 

 2 incorporate those into data sets. 

 3 Right now, again, just to give -- put some 

 4 perspective, I think on a typical desk top 

 5 computer, doing a primary analysis, running both 

 6 base and beta is probably about a two-day effort. 

 7 We tried to keep the run time somewhat manageable 

 8 so you don't have to sit back and wait a month for 

 9 the results to come out, and probably part of the 

10 way to -- that we dealt with that was to limit the 

11 data periods that we ran to about a month, I think, 

12 for each scenario. 

13 So that's another -- future extension might be 

14 to include some longer averaging periods in there, 

15 longer data periods. 

16 Most of that run time is in scenarios one and 

17 two -- one and five, one being the large-scale NWS; 

18 five being the small-sale complex flow. 

19 It's interesting to note the difference in 

20 right time between scenarios one and two was quite 

21 remarkable, and I think scenario one takes 

22 probably, what, ten (10) hours to run and scenario 

23 two may be six to ten (10) minutes to run, 

24 something like that. 

25 DESMOND BAILEY: With the tool being available, you know, 
 1 Questions/Audience Vol. 2, p. 42 

 2 anyone with the -- with the experience in running 

 3 CALPUFF and CALMET -- or CALPUFF could actually run 

 4 the tool, and we certainly encourage that. 

 5 ROGER BRODE: We tried to set it up in a way that's very easy 

 6 to run. Basically all you have to do is run one 

 7 batch file, and it'll go through and run all those 

 8 scenarios, base the beta; run the analysis tools, 

 9 generate all the results. 

10 That's the easy part. Understanding the 

11 results is what's going to take some time. 

12 MARK GARRISON: I'm Mark Garrison, with ERM. 

13 I have a quick question, and it's an easy one. 

14 The No Obs runs that you did, was that sort of the 

15 -- was that the pure No Obs, or did you select one 

16 of the used surface data and MM5 data for the long 

17 range? 

18 ROGER BRODE: That was No Obs, MM5 only. Scenario three is 

19 where we mer- -- sort of merged NWS with MM5 data 

20 in that sort of medium-scale domain. 

21 So we did have one with all NWS, one with all 

22 MM5 and then one with mixed. 

23 MARK GARRISON: NWS surface and MM5 data? 

24 ROGER BRODE: NWS surface and upper air and MM5 data. I 

25 think we used the MM5 data to initialize the wind 
 1 Questions/Audience Vol. 2, p. 43 

 2 field in that case. 

 3 ROBERT PAINE: Robert Paine with ENSR. 

 4 I have a question of EPA about whether this is 

 5 a new type of analysis that's going to be applied 

 6 to every model change of every model, because I 

 7 think there has been dozens of model changes over 

 8 the last decades, and I don't think such a detailed 

 9 analysis has been done typically, and is it 

10 expensive, is it time consuming, is it resource 

11 sapping? 

12 What is the plan in the future? 

13 DESMOND BAILEY: Now that the tool has been developed, you 

14 know, it's not resource -- and I mean, as Roger 

15 said, you can run all ten scenarios over a weekend, 

16 but, you know, I anticipate we wouldn't -- we 

17 wouldn't run it, you know, every month; perhaps 

18 once a year. 

19 I don't, you know, we'd have to -- these are 

20 decisions we'd have to make internally as to, you 

21 know, when is it appropriate to reevaluate the -- 

22 the changes. 

23 MARK GARRISON: I was wondering if you had one of these for 

24 AERMOD and one of these for myriad of other model 

25 panaceas? 
 1 Questions/Audience Vol. 2, p. 44 

 2 Do you have to set one up for every one of 

 3 these models, and every time you change it, you 

 4 have to run through this again? 

 5 DESMOND BAILEY: I would anticipate we'd have the tool for -- 

 6 analysis tool for CALPUFF and one for AERMOD. I 

 7 wouldn't -- we wouldn't, I don't think there is 

 8 any plans that -- to go beyond that at the 

 9 moment. 

10 RICHARD SCHULZE: Dick Schulze Trinity Consultants. 

11 Have you given any thought to using the same 

12 kind of analysis for, say, a model like SCIPUFF 

13 which is in many ways similar or different than 

14 CALPUFF? 

15 DESMOND BAILEY: I have not. It's -- my -- but there is, you 

16 know, something to consider. 

17 AL CIMORELLI: This is All Cimorelli. I have a question 

18 about the technique. Has anybody given thought to 

19 when you run through this to go back and look at 

20 the performance tests that actually justify the 

21 model in the first place? 

22 It would seem to me -- I mean, this is 

23 obviously very important information, but the 

24 question is, is it better or worse, and --. 

25 DESMOND BAILEY: Yes, I think that the premise is that the 
 1 Questions/Audience Vol. 2, p. 45 

 2 current -- I mean that's one of the -- its premise 

 3 is that the current version is okay, and that's -- 

 4 you know, something we need to -- to think about. 

 5 ROGER BRODE: I'll just mention that in the beginning the 

 6 process, there was some discussion that we include 

 7 some of the model evaluation data sets. 

 8 I think it was decided for now to focus on 

 9 this type of scenario, but --. 

10 AL CIMORELLI: I think -- just my own thought is, if you have 

11 more significant changes to come along, that where 

12 you would anticipate maybe the performance of the 

13 model has changed, then that might be something to 

14 consider adding at that time. 

15 But also to answer Bob's question a little 

16 bit, I don't think we've had quite as formal a 

17 process for models like AERMOD arise here in the 

18 past except when we went from ISC-1 to ISC-2, there 

19 was a pretty thorough comparison made, and those 

20 results were published, but there definitely some 

21 internal testing that is done, some 

22 characterization of the results more qualitatively, 

23 but I think it's good to go to more transparent 

24 process, as Desmond said. 

25 WARREN PETERS: This is Warren Peters. Roger, correct me if 
 1 Questions/Audience Vol. 2, p. 46 

 2 I'm wrong, but I believe every time we have 

 3 modified AERMOD over the last five years, we have 

 4 run through the entire consequence analysis, and we 

 5 have gone back and looked at the model evaluation 

 6 results is the best we could do every time. 

 7 Is that correct? 

 8 ROGER BRODE: That's correct. 

 9 WARREN PETERS: Okay. That concludes the first part this 

10 morning on the updating of models in CALPUFF, and 

11 as we've seen from our questions and answers, we 

12 have even brought in the concept of doing the 

13 same sim- -- similar kinds for the AERMOD 

14 updating. 

15 There is one other thing I thought I'd just 

16 mention as an aside, and we certainly welcome 

17 comments on this. 

18 Right now the current process is that, I 

19 believe I saw it with CALPUFF as well, that the 

20 version model of our models is pretty much based on 

21 approximately the date that when we released the 

22 version, but what we are finding is because 

23 sometimes we made significant changes to the model, 

24 sometimes we made minor bug corrections, almost 

25 insignificant corrections, that the version number 
 1 Questions/Audience Vol. 2, p. 47 

 2 gives you no clue as to what you're looking at with 

 3 this version of AERMOD, for instance, and we are 

 4 considering the idea of going more to the idea of 

 5 what we haven't sought -- what we haven't sought, 

 6 where we have a version number with maybe three 

 7 digits or three numbers to it. 

 8 Now, when you make a major change to the 

 9 model, you'd have a change in the first digit, so 

10 to speak, you know, like eight point two point 

11 three (8.2.3). 

12 Now, if you have a major change, you go up to 

13 nine point 0 (9.0). If you have perhaps a science 

14 change or a significant change but not earth 

15 shattering, you know, you change the second digit, 

16 you know, eight point two (8.2) goes up to eight 

17 point three (8.3), and if you are making bug 

18 corrections, you go from eight point two point one 

19 (8.2.1) to eight point two point two (8.2.2). 

20 So when you look at the version number, you 

21 have a clue as to whether the version you have on 

22 your computer is approximately equal to what's up 

23 on the web site; the current version. 

24 We're thinking about that, and if you have 

25 some ideas, then we welcome that change in the way 
 1 Current & Available Model Evals/Peters Vol. 2, p. 48 

 2 we label our models. Let us know and we will 

 3 consider that, but I think there was some merit in 

 4 looking at that different approach. 

 5 Okay. On the next part of the meeting this 

 

 6 morning, we would like to go back and -- and start 

 7 thinking about review of the current and available 

 8 model evaluation methods. 

 9 We are going to have a panel discussion here 

10 in this second part, but at the first part, we 

11 wanted to mention that this session actually is to 

12 provide an overview of the current model evaluation 

13 methods, and we want to discuss the additional 

14 approaches and methods that are available in 

15 conducting model components evaluations. 

16 Their review and a reevaluation of how to 

17 conduct model components evaluations is warranted, 

18 now that AERMOD and CALPUFF have been accepted for 

19 regulatory use. 

20 That's the theme for our session this morning 

21 at this point. 

22 The first presentation, I'm going to give, and 

23 it's going to be just a brief overview of the model 

24 evaluation procedures as we now have them in our 

25 Appendix W and in -- detailed in some of the 
 1 Current & Available Model Evals/Peters Vol. 2, p. 49 

 2 references in the protocols. 

 3 (Projecting slide.) 

 4 Again, as I mentioned, this will be an 

 5 overview for looking at the procedures for 

 6 evaluating new air dispersion models within the 

 7 Appendix W. 

 8 This comes from Appendix W, which is really an 

 9 appendix to 40 CFR, Part 51 in the Guidelines. 

10 It's called "Guideline on Air Quality Models", and 

11 it addresses, of course, bringing in new air 

12 quality models and how to evaluate them into the 

13 regulatory fold, so to speak. 

14 The parts that we are going be discussing this 

15 morning are coming from Section three point one 

16 point one (3.1.1) of Appendix W, and under 

17 subsection B here, it says, when a model is found 

18 to perform better than the listed model, it is 

19 recommended as a preferred model. 

20 Which makes sense. 

21 It goes on to say here, if no model performs 

22 better than the current preferred model, then other 

23 factors are considered: past use, public 

24 familiarity, resource requirements and 

25 availability. 
 1 Current & Available Model Evals/Peters Vol. 2, p. 50 

 2 And always, as the guidelines specifically 

 3 states, EPA is soliciting the new refined models 

 4 which are based on sounder scientific principles 

 5 and more reliably estimate concentrations as a 

 6 continuous effort on our part, and that's 

 7 solicitation. 

 8 Under Subsection C, a new model must be, and 

 9 here we have a list now; it must be computerized, 

10 it must have a user's guide. And this user's guide 

11 should have more than just information about how to 

12 just turn on the model, it has to include some -- 

13 some of the mathematics of the model, so you will 

14 have an understanding of the science and the number 

15 of algorithms behind the model, the minimum data 

16 requirements to drive the model, and the basic 

17 operational characteristics. 

18 Each model should have a complete set of test 

19 data, so that when you download the executed books, 

20 you can run it on your PC and make sure that it's 

21 working the way it's supposed to. 

22 It needs to be useful to the typical users. 

23 Going on, that same subsection, it must be 

24 available at a reasonable cost. It must not be 

25 proprietary. It must be subjected to a performance 
 1 Current & Available Model Evals/Peters Vol. 2, p. 51 

 2 evaluation, and we will talk about that some more, 

 3 and be subjected to a scientific peer review. 

 4 (Projecting slide.) 

 5 Okay. 

 6 Let me go back here (looking for correct 

 7 slide). 

 8 And under alternative models, the new model 

 9 for procedures are a -- must produce equivalent 

10 concentrations. 

11 A performance evaluation indicates that the 

12 new model performs better, or the preferred model 

13 is less appropriate. 

14 And then under alternative models; the EPA 

15 protocol provides a statistical technique for 

16 evaluating performance for peak concentrations, and 

17 it references the ASTM method to provide a general 

18 philosophy for developing a statistical 

19 evaluation. 

20 So all of that is referenced in the guideline. 

21 Now, I want to just briefly go over some of the 

22 details of the protocol. 

23 This part of this presentation is multi-based 

24 on the generic language that's found in Appendix W, 

25 but it also goes back and references the documents 
 1 Current & Available Model Evals/Peters Vol. 2, p. 52 

 2 and others that are mentioned in the Appendix W, as 

 3 well. 

 4 So, it's a summary of several documents plus 

 5 the language in the Appendix W. 

 6 As I've mentioned here in this first slide 

 7 here, these slides are pretty much based on the EPA 

 8 document, entitled the "Protocol for Determining 

 9 the Best Performing Model", which came out in 

10 December of 1992, and it's directly referencing 

11 Appendix W. 

12 That also is heavily based on the Cox/Tikvart 

13 method that was a paper generated, I believe, in 

14 1990. There is a screen test in this protocol, and 

15 it's one of the first steps and is based on a 

16 fractional bias, and we'll see this as we go 

17 through the protocols. And fractional bias is 

18 defined here. 

19 Notice that there is a -- an equation, let me 

20 highlight it here. 

21 This equation, right here, defines the method 

22 by which we can look at and compare the observed 

23 versus the predicted values. I guess you can't see 

24 my footnote here, but the PR stands for the 

25 predicted concentration, the OB is observed, and by 
 1 Current & Available Model Evals/Peters Vol. 2, p. 53 

 2 taking the difference and then dividing by the 

 3 summation of the two values and multiplying by two, 

 4 you have a metric that can describe the comparision 

 5 between the two values. 

 6 I notice in this case, we do the mathematics 

 7 at that if the predicted model is a factor or two 

 8 higher than the observed values, the fractional 

 9 bias comes out to be about point six seven (.67), 

10 and that the maximum value of the fractional bias 

11 can't be higher than two, no matter how much the 

12 prediction model is higher than the observed 

13 values, fractional bias cannot be higher than a 

14 factor of two. 

15 So it's a nice handy metric where it does not 

16 have a very large range of values; it's something 

17 you deal with on a standard graph in a linear 

18 fashion. 

19 And the screen method is based on the highest 

20 twenty-five values of the observed data, and it's 

21 looked at basically taking all of the observed data 

22 around the study area and just doing a -- basically 

23 a quantile-quantile quad comparison by ranking 

24 every high concentration, no matter where it 

25 occurs, and putting it on this list from high to 
 1 Current & Available Model Evals/Peters Vol. 2, p. 54 

 2 low. 

 3 We looked at the highest twenty-five (25) 

 4 values and then proceeded to do a fractional bias 

 5 analysis for each of the high values. 

 6 And that, again, it's a ranking of the 

 7 predicted ranges, it's a ranking of the observed 

 8 values, and then it's not paired to time and space. 

 9 It's just compared based on the quantile-quantile 

10 plots. 

11 If the absolute value of a fractional bias 

12 exceeds point six seven (.67), which means that the 

13 model is predicted by a factor or two higher over 

14 the twenty-five (25) highest values, the model may 

15 be excluded. 

16 There is a more advanced statistical test in 

17 there, and it has two components to it. There is a 

18 regulatory component and a science component. 

19 On the regulatory component, again cites is 

20 what we've seen in the screening analysis, the 

21 precise time, the location and the meteorological 

22 conditions are not of concern. It's the magnitude 

23 of the highest concentrations that is of primary 

24 concern. And that's what we are after typically 

25 for a regulatory application. 
 1 Current & Available Model Evals/Peters Vol. 2, p. 55 

 2 The sta- -- test -- like he said, the test 

 3 statistic that we have in this model is called the 

 4 robust highest concentration or RHC. And 

 5 basically what it is is, it's a smooth estimate of 

 6 the highest concentrations, and believe -- it's 

 7 recommended in the protocol that it be approximate 

 8 type of -- type of emission down here, the highest 

 9 twenty-five (25) concentrations that you would have 

10 seen in the test study. 

11 And robust highest concentration, when we say 

12 it's smooth, it's based on a tail exponential fit 

13 to the upper end of the distribution. 

14 So it's a mathematically smooth function based 

15 on an algorithmic function, actually. 

16 This analysis is conducted for the regulatory 

17 averaging times, normally like three in twenty-four 

18 (24) hours, those averaging times of concern for 

19 the standards that we're looking at. 

20 And, again, it uses as a performance measure, 

21 the fractional bias, and notice in this case now, 

22 it's the fractional bias of the robust highest 

23 concentrations. 

24 So we've got two levels in here now. I just 

25 want to make sure we understand this, because 
 1 Current & Available Model Evals/Peters Vol. 2, p. 56 

 2 there's more metrics that are coming; it builds on 

 3 each other, but we have a robust highest 

 4 concentration which describes a generic 

 5 concentration, and now we have the fractional bias 

 6 which is a way to directly compare the predicted 

 7 versus the observed. 

 8 On the science component, here's where the 

 9 location and the meteorological conditions are of 

10 concern. It's the magnitude of the highest 

11 concentrations under each of the conditions that 

12 we're looking at. 

13 Again, under the science component, we're 

14 still looking at the robust highest concentrations. 

15 It still has, when we say the RHC, or the robust 

16 highest concentrations, it's still using the same 

17 equation, it's a smooth tail exponential fit to the 

18 upper end of the distribution. 

19 It also uses the fractional bias as the metric 

20 for testing, but in this case, now, notice the 

21 difference; it's conducted for the one-hour 

22 concentrations, not the averaging times of concern 

23 for the regulatory needs. 

24 The protocol recommends conducting this 

25 analysis in a six-way split, so to speak, with two 
 1 Current & Available Model Evals/Peters Vol. 2, p. 57 

 2 wind speed groups and three stability categories, 

 3 but that could change. It's just not a hard -- 

 4 it's not a hard recommendation yet; it suggests 

 5 these things. 

 6 So basically when we're doing the scientific 

 7 complete, you can see it's more complicated, more 

 8 involved, and again, looking at location and 

 9 meteorological conditions, we're trying to compare 

10 more one for one the exact actual observations and 

11 predictions. 

12 But now in the end, we're going to -- in this 

13 model protocol we're going to combine both 

14 components into one metric, and it's called the 

15 composite performance metric or CPM. 

16 Now I want you to study this equation just for 

17 a second to understand what's going on here, but 

18 basically I want you to first focus in on the 

19 fractions in here in helping to understand the 

20 weighting factor. 

21 This is a suggested concentration -- or 

22 suggested equation in the model protocol, and in 

23 this case we have a one third times the absolute 

24 fractional bias, and this is the science component, 

25 if you will. If you notice, it's summed over the 
 1 Current & Available Model Evals/Peters Vol. 2, p. 58 

 2 i and j, over each of the hours over the different 

 3 conditions for wind speed and stability, and then 

 4 it's a two-thirds fraction for the science 

 5 component -- I'm sorry, for the regulatory 

 6 component here, two-thirds times, and this is the 

 7 absolute fractional bias for the three-hour in this 

 8 case, and the absolute fractional bias for the 

 9 twenty-four-hour as they're sewn together and then 

10 divided by two, but it's essentially the average of 

11 the absolute fractional bias on the regulatory 

12 component. 

13 So there is a double weighting, if you will, 

14 on the regulatory component of one-third (1/3), or 

15 half the weighting for the science. And, again, 

16 that's a composite performance metric. 

17 And, also, as I mentioned earlier, that 

18 average is taking over all the different scenarios 

19 and conditions there when you're doing the 

20 scientific evaluation. 

21 And then doing the model to model comparison 

22 which is, of course, the last step -- we have one 

23 more metric; the model comparison measure, or MCM, 

24 and in this case it's, as you can see on the screen 

25 here, it's just a subtraction of the two 
 1 Current & Available Model Evals/Peters Vol. 2, p. 59 

 2 performance -- the composite performance measures 

 3 from model A to model B. So it's a relatively 

 4 simple equation there. 

 5 Now the yardstick which is the term used in 

 6 the protocol is the ratio of the composite 

 7 difference to the standard error. And how do we 

 8 calculate the standard error? Well, it's actually 

 9 a blocked, bootstrap method that is suggested in 

10 the protocol, and it will go through and generate 

11 the estimate of the standard error. 

12 And the blocking is done by day and by season, 

13 and there is a detailed explanation on how that's 

14 done. And the bottom line here is that the ratios, 

15 when they are larger than one point seven (1.7), 

16 they indicate a significant difference in the two 

17 models at about the ninety percent (90%) confidence 

18 level. 

19 So I realize that was a little complicated, 

20 but I think you basically have captured the idea, 

21 so that -- in the model-to-model comparison, is 

22 just a subtraction of the composite performance 

23 metric, and this, again, is just a single model 

24 result here, and notice again emphasizing that it's 

25 a weighting of the science and the regulatory 
 1 Current & Available Model Evals/Peters Vol. 2, p. 60 

 2 component. 

 3 (Projecting slide.) 

 4 Then we have a fractional bias in here when we 

 5 are comparing observed versus predicted 

 6 concentrations, and, of course, as I mentioned 

 7 earlier in one of the other presents, we have the 

 8 robust highest concentration which is a pseudo 

 9 concentration based on the high twenty-five (25) 

10 concentrations. 

11 So that should give us an overview of the 

12 protocols and the methods that we have right now in 

13 Appendix W and some of the suggestions and some of 

14 the guidance. 

15 So if I could call up -- Al, did you have a 

16 question? 

17 AL CIMORELLI: Yeah. 

18 WARREN PETERS: You will need to turn that microphone on. 

19 AL CIMORELLI: Al Cimorelli. I'd just like to make a 

20 comment, a clarifying comment. When you talked 

21 about this, Warren, there is really two things I 

22 think in here; one is the set of statistics that 

23 are there and how we look at new models, maybe 

24 approve new models and so on and so forth which 

25 really there wasn't a whole lot of discussion about 
 1 Current & Available Model Evals/Peters Vol. 2, p. 61 

 2 that. 

 3 Most of what you've discussed here, if I'm not 

 4 mistaken, has to do with alternative models, and 

 5 the alternative models really is a sort of case 

 6 specific definition of a model that's appropriate 

 7 for a situation compared to the preferred model. 

 8 So you have a situation in application where 

 9 there's a preferred model, the Agency says that if 

10 you use that model, no problem, just use it, we'll 

11 accept the results. But if you believe that there 

12 is another model more appropriate for that 

13 circumstance, then these are the type of statistics 

14 that you have to go through with a protocol -- an 

15 up-front protocol that the regulatory authority and 

16 the applicant will negotiate to come up with 

17 utilizing these statistics to come up with a score 

18 that the best model then wins and can be used for 

19 that particular application. 

20 I just wanted to make sure that we 

21 differentiated that from, I think, a discussion we 

22 will later about how to bring a new model like 

23 AERMOD or CALPUFF or some other model into the 

24 fray. 

25 WARREN PETERS: You are correct, Mr. Cimorelli. Some of this 
 1 Current & Available Model Evals/Peters Vol. 2, p. 62 

 2 language is pulled out, and the guidance is 

 3 provided for the approval of alternative models. 

 4 But, also, it would make sense, and although 

 5 it's not directly stated in Appendix W, that it 

 6 also would apply to, as we attempt to develop new, 

 7 preferred models as well, you still would have to 

 8 go through a similar procedure, I think by 

 9 implication, that many of these tools and 

10 approaches would have to be used. 

11 But specifically, speaking, at this current 

12 time, Appendix W is for the alternative models that 

13 the later portions of the protocol is actually 

14 applied to. 

15 ROBERT PAINE: Robert Paine, ENSR. 

16 Some of your earlier slides -- some of the 

17 language from the Appendix W looked -- looked 

18 unfamiliar. Is that new language? 

19 WARREN PETERS: The ASTM language was new. That came out of 

20 2003. 

21 ROBERT PAINE: Maybe -- my follow-up question is, when is the 

22 new Appendix W going to be unveiled to us all, and 

23 it's unfortunate it wasn't unveiled to us before 

24 this meeting, because we could have lots to say 

25 about it, but we don't of it in front of us? 
 1 Panel Discussion Vol. 2, p. 63 

 2 WARREN PETERS: I'm not sure what you mean by new Appendix W. 

 3 ROBERT PAINE: (Interposing) Well, AERMOD -- AERMOD's 

 4 promulgation will require a change to Appendix W 

 5 and then, also, there's implementation 

 6 documentation that I suspect is -- has been 

 7 reviewed by -- within EPA. But we, the user 

 8 community, have not seen any of that. 

 9 When will we see that? 

10 WARREN PETERS: Well, when it's promulgated. I guess there 

11 will be, obviously, some changes to Appendix W 

12 because of the -- by virtue of AERMOD being the new 

13 preferred model. 

14 So that, I mean there is some language in 

15 there, but as I recall, and I haven't looked at the 

16 package in quite a while, but there aren't 

17 significant, big-time changes to Appendix W. It's 

18 mostly to incorporate the new model, you know, 

19 AERMOD. 

20 And, of course, all the Appendix W changes 

21 that were thought of were in the proposal package, 

22 so there were earlier versions that the public did 

23 see and review. 

24 Okay, may I call up to the front now, the 

 

25 panel, please, and that would be John Irwin, Bob 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 64 

 2 Paine, -- 

 3 (Panel members come to table at front of 

 4 conference room.) 

 5 WARREN PETERS: -- Ken Steinberg. 

 6 I believe this morning to help go through this 

 7 panel discussion, we have basically asked our panel 

 8 members to think about the concept of looking at 

 9 the current EPA procedures and giving us any new 

10 ideas or concepts that they might like to present. 

11 We'd like to have both a panel discussion on 

12 any other new ideas that they present, both from 

13 the panel members as well as from the audience. 

14 And -- I believe we could probably start off 

15 this morning by listening to Mr. John Irwin. 

16 I believe, John, you have some slides that you 

17 wanted to present and some ideas, so we're 

18 actually going to begin with you. 

19 I believe I have your presentation here. 

20 (Locating screen presentation.) 

21 WARREN PETERS: And, John, if you want, I'll just run the 

22 slides for you from here. 

23 JOHN IRWIN: That's fine. Is the microphone on? 

 

24 Good, well, as the slide says, these are some 

25 ideas I have on how we might update the procedures 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 65 

 2 that we currently are using for evaluating models; 

 3 sort of -- I'm not going to get real specific here. 

 4 I'm thinking sort of in a broad vision way here, 

 5 just to lay out some ideas of maybe to meet the 

 6 goal of being more collaborative and to work with 

 7 other Federal agencies and to work with other 

 8 private industries, what might we do to alter the 

 9 way the process has been working? 

10 So let's take a look at where we are. You 

11 can't read it, so I will mention what is there, 

12 which has already been reviewed. 

13 The first group of words says that the EPA 

14 created the Cox/Tikvart methodology of robust 

15 highest concentrations in the use of the fractional 

16 bias, and came up with a methodology for evaluating 

17 performance of the model to predict a very high 

18 concentration. 

19 More recently AERMIC used this procedure and 

20 various other evaluation techniques that I won't go 

21 through, but they were comparing frequency 

22 distributions and scatter plots and all kinds of 

23 things that you can go back and review. 

24 But they used a variety of technique to try 

25 and illustrate the performance of AERMIC versus the 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 66 

 2 performance of ISC, in demonstrating to the public 

 3 the performance of the new model and how it 

 4 compared with ISC. 

 5 The EPA method actually, this third bullet, is 

 6 in error. The EPA methodology does provide a way 

 7 of ranking and also comparing relative skill and 

 8 seeing if the skill is significant or not. I was 

 9 working from dim memory when I put the slide 

10 together, so (chuckles from audience) -- but going 

11 back and looking at it, yes, it does provide a way 

12 of seeing whether or not the difference in 

13 performance is significant or not. 

14 And one of the things I -- I'll come back to 

15 is that the technique, when it was devised, was 

16 looking at the world in a particular way. Since 

17 1992, we have learned things. 

18 And we are learning more and more that there 

19 is a stochastic element to dispersion theory that 

20 really isn't recognized in any of the current 

21 models. It's there in the observations, and when 

22 we were thinking back in 1992, when I use the word 

23 "we", I'm also including John Irwin in this. When 

24 I was thinking back in 1992, I didn't even think 

25 about whether the stochastic processes that caused 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 67 

 2 fluctuations in the observed concentrations, I 

 3 didn't think it was significant, I didn't think it 

 4 was anything to be of great concern about in the 

 5 evaluation of the models. 

 6 Since then, I've learned a great deal, and so 

 7 have others, and we are starting to worry that the 

 8 current evaluation methodologies need to be 

 9 upgraded to directly confront this issue, because 

10 otherwise, we're going to get a false picture of 

11 model performance. So I'll come back to this point 

12 a little bit later, but part of the idea I have of 

13 opening up the process and changing the way we 

14 develop the evaluation methods, is to try and get 

15 other minds and other people involved in the 

16 process so that we can not only upgrade our 

17 evaluation methods but almost continually update 

18 our evaluation methods as we learn new things in 

19 the sciences. 

20 So in the next slide, I say, what might be 

21 changed? 

22 Well, we could open the process up, and there 

23 are existing agencies to do this. They are called 

24 voluntary standards development organizations. 

25 One of them in particular is ASTM 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 68 

 2 International; used to be called American Society 

 3 for Testing and Materials. Recently they changed 

 4 their name to ASTM International. 

 5 The -- these agencies, or these voluntary 

 6 standards groups, they have been in existence for 

 7 hundreds of years. They've been used to -- to 

 8 build railroads, you know, so that railroads can go 

 9 across the country and have the same width between 

10 the rails. They are there to help public and 

11 private entities tackle the technical questions 

12 that come up in doing business, and the key to them 

13 is they try to bring all parties to the table and 

14 give them an equal voice, not to set policy, that's 

15 not their purpose. 

16 Their purpose is to solve the technical 

17 questions in a collaborative way. 

18 So I'm suggesting that maybe this would be 

19 something to consider, is to create a subcommittee 

20 within ASTM whose perfect -- whose only purpose 

21 really is to develop evaluation methodologies that 

22 can be used to test the performance of air quality 

23 models. 

24 So that sort of moves the discussion outside 

25 of EPA into a voluntary standards organization 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 69 

 2 where anybody can participate by paying their dues, 

 3 which I think are seventy-five dollar ($75) a year 

 4 now. 

 5 The -- a test method could be devised, could 

 6 be written up as an ASTM standard. One of the 

 7 benefits of this is you have a standing committee 

 8 of experts who meet probably face to face as much 

 9 as twice a year, maybe more often. They're 

10 corresponding by e-mail and developing standards 

11 and arguing over whether this is working, or that's 

12 not working, they're testing the ideas. 

13 All of this is sort of a communal conversation 

14 that's going on, and over the years, I can tell 

15 you, I have been in ASTM now for probably over 

16 twenty (20) years, over the years you develop a 

17 sense of how another person is thinking, and you 

18 also develop an awareness of how you got where you 

19 are. 

20 So, you build into this process an awareness 

21 and appreciation for the technical abilities of 

22 others and also for an awareness of how you've 

23 gotten where you are, so that you don't fall into 

24 the same holes that you fell into before. 

25 And, also, it actually spurs on to narrow 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 70 

 2 ideas. People see is that there is a benefit 

 3 perhaps for them to participate in the process. It 

 4 actually facilitates their business. They know in 

 5 advance what the new evaluation methodologies are 

 6 going to be. They build their products to address 

 7 those new capabilities. 

 8 They see that there might be a way of 

 9 attracting customers if they make it easier for 

10 people to use those methodologies that are being 

11 developed. In this sense someone had test data 

12 sets, they can post them on their web site, and 

13 that would attract people to their web site, but 

14 they could make the test data sets and the 

15 methodologies that implement the met- -- you know 

16 -- the test methods, they could make all that 

17 freely available off their web site, and they 

18 attract some advertisement to themselves, and also 

19 they provide a public service. 

20 But there are some common worries which I have 

21 on the next slide. 

22 One of them is, you'll hear people say, oh, 

23 no, no, no, we can't go with ASTM. You just know 

24 what they're going to do. They're going to develop 

25 all these test methods, and then EPA is going to be 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 71 

 2 forced to use these test methods. Not really. 

 3 EPA is going to promulgate in a regulatory 

 4 action the test methods that they accept and want 

 5 to be used. They are going to define which test 

 6 methods are going to be used. 

 7 ASTM doesn't define anything for EPA. ASTM 

 8 develops standards. EPA can pick and choose which 

 9 methodologies they wish to implement and which ones 

10 they wish to have used. 

11 Now, you can make an argument in a public 

12 forum, that, gee, you should have picked this 

13 standard versus that standard, but EPA doesn't lose 

14 control. They still have the control to define 

15 what they want to use. 

16 Another one about losing control is that 

17 they'll say, well, you've got all these people 

18 working, how's EPA going to maintain some control, 

19 well, they have to participate. 

20 But the reason why we are creating this 

21 standing committee is to get others involved to 

22 help. If you want to have EPA do everything, then 

23 that means EPA has to pay for everything. EPA has 

24 to create this little thing, and you hear people 

25 say, I wonder what they're doing, I wonder what 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 72 

 2 they're thinking. And I've heard this, you know, 

 3 everything is built for the inside and then at the 

 4 very last moment, "Bingo, oh, hi, look, I've 

 5 created this new creature for you all to use. 

 6 And then you start arguing over it. The 

 7 process that I'm suggesting is very open, and 

 8 that's the whole reason that ASTM exists is that 

 9 everybody can look into this glass fish bowl where 

10 the debate is occurring, and then can even 

11 participate in the debate. 

12 You don't even have to be a member, by the 

13 way, to walk into an ASTM committee and 

14 participate. The only thing that you lose is you 

15 can't vote, but you can walk, and you can make your 

16 case and you can make your arguments and you can 

17 walk out, whether we listen to you or not. If you 

18 are a member, we have to listen to you, (laughter) 

19 because if you cast a negative vote, we have to 

20 formally address it. 

21 But, it's a very open process. 

22 So, what can we do now? I think we need to 

23 get the message out that a large segment of what 

24 we've observed is stochastic noise in the 

25 observations. And that stochastic noise I 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 73 

 2 guarantee you is not being simulated by our 

 3 models. 

 4 Our models tell you what your going to see 

 5 with the boundary conditions specified on average, 

 6 and there are large deviations that we're now 

 7 coming to understand that exist between what's 

 8 simulated and what's observed on an hour-by-hour 

 9 basis. 

10 We need to get that message out, because it 

11 has a great impact on how you develop evaluation 

12 methods. 

13 There is a test method or a test standard in 

14 ASTM. It's called D-6589. It's mentioned in the 

15 guideline. It doesn't specify a specific 

16 methodology to be used. It specifies a philosophy, 

17 and the philosophy outlines the problem as we 

18 currently see it, namely, that there's a large 

19 segment of observed concentrations that involve 

20 stochastic noise. Then it shouldn't scare anyone, 

21 because we have known about turbulence since the 

22 time we ever started talking about air pollution. 

23 We're just starting to learn that this 

24 turbulence has organized swirls in it. They are 

25 called eddies, and the organized swirls cause the 
 1 Ideas/Selection & Approval/John Irwin Vol. 2, p. 74 

 2 concentrations to have large fluctuations when the 

 3 wind blows past a monitor. And those large 

 4 fluctuations could give you, if you're trying to 

 5 test your model to perform against it, unless your 

 6 model also forecasts that noise, you can get a 

 7 false impression of what your model is doing. 

 8 So this ASTM methodology was up for its 

 9 five-year review. It was originally passed in 

10 2000, and this year the committee reviewed the 

11 standard, made some minor editorial changes to it, 

12 and voted on it, and I think it's close to being 

13 published in its newly revised form. 

14 The Cox/Tikvart methodology that was mentioned 

15 earlier we could easily do a ASTM standard, and if 

16 somebody wanted to participate in that, we could do 

17 it. And there is a lot of other standards, if you 

18 go around to the Department of Energy, a lot of 

19 people have a lot of ideas on how models might be 

20 evaluated. 

21 It would be very nice to have a whole 

22 collection of tools on how to evaluate model 

23 performance to choose from, and then from this 

24 collection of tools, EPA could specify the ones 

25 that they want to have used and the databases that 
 1 Comments/New Approach-Modeling/R. Paine Vol. 2, p. 75 

 2 they would wish people to use. 

 3 I think it would create a way of gathering 

 4 information, updating information and being ready 

 5 to change and mold the ideas as we learn things in 

 6 the future. 

 7 And I'll stop there, even though I have some 

 8 other slides, I'll just stop right there. 

 9 WARREN PETERS: All right. Thank you, John. 

10 That will start to stimulate our thinking 

11 about the different ways we can do business in 

12 evaluating models and the tools we use. 

13 Bob Paine, I know you will have seen some of 

14 John's presentations within the last couple of 

15 days, and you've also looked at some of the 

16 questions. 

17 Did you have something to say? Do you have a 

 

18 question for us? 

19 ROBERT PAINE: (Interposing) I have a presentation called 

20 the Paine eval, and also, John, I think the -- the 

21 AERMOD evaluation databases have been put up on 

22 SCRAM. 

23 I think one of your comments was, they ought 

24 to be. I think they have been. 

25 JOHN IRWIN: Good. 
 1 Comments/New Approach-Modeling/R. Paine Vol. 2, p. 76 

 2 ROBERT PAINE: Why don't we go to the next slide. 

 3 WARREN PETERS: Let me get full screen. (Screen is 

 4 adjusted.) 

 5 ROBERT PAINE: Oh, yeah, sure. 

 6 One thing I wanted to say was, I don't know if 

 7 the ASTM standard has been put on the SCRAM web 

 8 site yet, so the 6589 item. 

 9 WARREN PETERS: I don't believe that it has, Bob. 

10 ROBERT PAINE: I think you can purchase it from ASTM, but I 

11 don't know that we should have to pay for that. 

12 JOHN IRWIN: ASTM lives by the revenue that they gain by the 

13 selling of the standards. 

14 The standard costs thirty-five dollars ($35). 

15 This isn't going do break anyone's pocket. 

16 ROBERT PAINE: Okay. 

17 JOHN ERWIN: It is copyrighted material. It cannot be 

18 reproduced and given away freely. That's part of 

19 the rules of the game. 

20 (Laughter.) 

21 ROBERT PAINE: Okay. Why don't we -- why don't we go onto 

22 the next slide? 

23 (Projecting slide.) 

24 I think, Warren, you talked about the 

25 Cox/Tikvart approach, but my understanding since 
 1 Comments/New Approach-Modeling/R. Paine Vol. 2, p. 77 

 2 I've gotten some free things from John in the past, 

 3 this guide does apply to the tracer field studies 

 4 having intensive surface networks of receptors, and 

 5 it does provide a best fit of -- to the arc -- 

 6 each arc of observed concentrations rather than 

 7 picking the peak value, or it does both, I guess. 

 8 It conducts resampling of the predicted and 

 9 observed concentrations, and give confidence 

10 intervals to the results. And all of this is very 

11 laudable and good science. 

12 All right, go on to the next slide. 

13 (Projecting slide.) 

14 But I would also like to bring up the fact 

15 that we have the -- another class of non-tracer 

16 databases which I think also ought to be considered 

17 by EPA as equally valuable. These are long-term, 

18 for example, one-year data sets that are spatially 

19 sparse but temporally rich, if you will, not 

20 addressed by the ASTM guideline, but addressed by 

21 the Cox/Tikvart approach. 

22 So I guess the new standard presumably does 

23 not exclude the Cox/Tikvart approach but augments 

24 them. 

25 And what I was wondering if John would -- 
 1 Comments/New Approach-Modeling/R. Paine Vol. 2, p. 78 

 2 would say that the Cox/Tikvart, of course, needs to 

 3 be sort of harmonized with the ASTM, or is it okay 

 4 as it is? 

 5 Maybe there has to be some melding of the two, 

 6 and I would get on with that later as to how -- how 

 7 to evaluate two types of databases; that is tracer 

 8 and -- and long-term databases and come up with a 

 9 standard statistic at the end that combines them 

10 all. 

11 Next slide. 

12 (Projecting slide. ) 

13 Well, the advantage of the long-term databases 

14 are for one thing, I think there is quite a few of 

15 them, and they are probably less costly than the 

16 extremely high cost of short-term studies. 

17 EPA has conducted studies in the past of these 

18 databases over the past two or three decades, in 

19 fact, in various classes such as rural, urban and 

20 complex terrain model evaluations, and the model 

21 evaluation methodology software has been developed 

22 that was as Warren described. 

23 Next slide. 

24 (Projecting slide.) 

25 Other advantages of such databases are that 
 1 Comments/New Approach-Modeling/R. Paine Vol. 2, p. 79 

 2 while the regulatory standards in the U.S. are -- 

 3 are, I think, best addressed in some ways by 

 4 long-term studies, especially long-term averages, 

 5 especially annual averages, which are important for 

 6 risk assessment, they could only be assessed by 

 7 long-term databases. 

 8 Also, the large range of meteorological 

 9 conditions expected at a site might be totally 

10 missed by a short-term tracer study, and you can 

11 only really realize this range with a long-term 

12 database. 

13 And the statistics that rely on pairing of 

14 space with unpairing times will work quite well 

15 with such databases. 

16 And our next slide, Warren. 

17 (Projecting slide.) 

18 Obviously, there is disadvantages because for 

19 any given time period, you don't know where the 

20 plume centerline is unless you get lucky, and they 

21 don't -- these databases do not work well for 

22 statistics that rely on events paired in time, but 

23 not necessarily paired in space. 

24 They don't lend themselves well to intensive 

25 analyses of short-term events. 
 1 Comments/New Approach-Modeling/R. Paine Vol. 2, p. 80 

 2 So it's evident that both types of evaluation 

 3 databases, that is, tracer databases that are short 

 4 short term, but spatially rich and the long-term 

 5 spatially sparse databases do have their useful 

 6 features that compliment each other. 

 7 (Projecting slide.) 

 8 And I think the next slide is the last one. I 

 9 recommend that EPA should certainly incorporate 

10 this guide in their approved techniques for 

11 short-term tracer databases, and they should also 

12 continue to use the Cox/Tikvart approach for 

13 evaluating long-term databases, and maybe there can 

14 be common statistical measures for overall model 

15 performance assessments. 

16 WARREN PETERS: Okay, thank you, Bob. 

17 And, Bob, did you have any further comments on 

18 some of John Irwin's presentation this morning in 

19 addition to the can program you have here. 

20 ROBERT PAINE: No. I did send you, Warren, some -- there is 

21 probably available on a web site some discussion of 

22 the D-6589, so people can -- can look at that 

23 without paying ASTM. I know ASTM can use the 

24 money, but there are publicly available to do a 

25 Google search on D-6589 (laughter). 
 1 European Assessment/David Carruthers Vol. 2, p. 81 

 2 You can find some stuff that's free 

 3 (laughter). 

 4 WARREN PETERS: Okay, thank you. 

 5 Now, obviously John Irwin was picked for this 

 6 panel because of his extensive experience in model 

 7 evaluation and looking at the different models that 

 8 EPA has been using for years. 

 9 But Bob Paine has been directly involved in 

10 evaluating both the PRIME, ISC-PRIME and in the 

11 AERMOD, so that he's written a number of reports 

12 and was the main author, really, on the evaluation 

13 for AERMOD, so he has extensive experience, really, 

14 in dealing with these protocols and procedures on 

15 these two models. 

16 Doctor Carruthers is championing the model 

17 from England, ADMS, and he's been talking and 

18 negotiating with EPA over the last several years, 

19 and I know he's gone through the model evaluation 

20 period for ADMS and has compared it to AERMOD and 

21 other models. He has experience in this area, too, 

22 and Doctor Carruthers, you have some comments that 

23 I realize you wanted to make, and I believe you 

24 have a presentation. 

25 DAVID CARRUTHERS: I just have one -- one slide, but I 

 
 1 European Assessment/David Carruthers Vol. 2, p. 82 

 2 thought I would perhaps start by saying a few words 

 3 about myself, since I'm sort of from -- from over 

 4 the sea. 

 5 I'm -- so I'm actually from Thames 

 6 Environmental Research Consultants, and we are 

 7 based in Cambridge, obviously. And I hope I can 

 8 give some of you from Europe both in this panel 

 9 session and -- and in the next panel session. 

10 I'm -- I have been involved in the ADMS, air 

11 dispersion modeling system, since 1988, so I have a 

12 lot of experience both in the development aspects 

13 of -- of the model and -- and obviously the 

14 evaluation and direction. 

15 And I should just say now that ADMS is one of 

16 the models based on the back scaling. So 

17 it's a direct sort of -- it's -- it's -- has many 

18 similarities, in its fundamental aspects, to 

19 AERMOD. 

20 And I've also been involved in a series of 

21 workshops which have been held across Europe, and 

22 they were perhaps, they were called, perhaps mis23 -- inappropriately, but harmonization of 

24 short-range atmospheric dispersion models in 

25 Europe. 
 1 European Assessment/David Carruthers Vol. 2, p. 83 

 2 Now, they've undergone a lot of discussion, 

 3 but I think harmonization is not one of the 

 4 outcomes. 

 5 (Laughter.) 

 6 But they have -- they have discussed in great 

 7 detail mobilization procedures, and I should say 

 8 that before I came this week, I did talk to Helge 

 9 Olesen who is head -- head of the sort of the 

10 committee in charge of these workshops. And so 

11 what I say will also reflect some of his comments, 

12 because he was involved in developing the IML 

13 Danish model, which I believe was the first ever 

14 Rentree model developed using scaling. 

15 To come on to the current session, I haven't 

16 got that much to say on this, but I think there are 

17 a few -- there are a few pertinent comments I 

18 should make. 

19 And first of all, though we're talking about 

20 model evaluation methodologies, I think it's 

21 important to say that the scientific assessment of 

22 models is -- is very important, and I think we 

23 shouldn't always get completely lost in discussion 

24 of various protocols about statistical evaluations. 

25 So, actually understanding how models deal with 
 1 European Assessment/David Carruthers Vol. 2, p. 84 

 2 certain problems within the overall problem is -- 

 3 is -- is crucial and should not -- should not be 

 4 ignored. 

 5 Also, it's very important, I think this has 

 6 come from a lot of the discussions in Europe, it's 

 7 very important to consider the quality of the data 

 8 which is being used, and it's also important to 

 9 explore the data that's being used. I know one of 

10 the techniques that's being used in the -- in the 

11 model tool kits in Europe is the things that look 

12 very carefully at the Gaussian data, and only for 

13 instance do evaluation or validation on data which 

14 is deemed to be above a certain quality. 

15 So all of a sudden, we've been through this 

16 exercise of looking at various validation 

17 procedures, looking to see a complete data set, 

18 then taking quality data by the certain quality 

19 standard, and then perhaps being more stringent in 

20 taking the highest standard of data, and, of 

21 course, you can get very different impressions of a 

22 model performance. 

23 So I think that is -- that is important to 

24 consider. 

25 And we've already mentioned the various 
 1 European Assessment/David Carruthers Vol. 2, p. 85 

 2 validation procedures which have been used for the 

 3 USEPA models there, and John's mentioned the ASTM 

 4 methodology. 

 5 I can never concur with Bob Paine that the 

 6 ASTM methodology should be brought forward, but 

 7 it's certainly important to maintain the ability to 

 8 look at these long-term measurements, and certainly 

 9 they are very, very important in overall 

10 assessments of models. 

11 I've written down below the model validation 

12 kit. This is something that really a -- a piece of 

13 software that's being put together using some -- 

14 some software from the States and from Europe, 

15 using the boot package and that's not published at 

16 the web site of -- of this , which has 

17 both the -- both the boot package and the model 

18 validation kit based on otherwise maximum, which 

19 has been used both in Europe and the past, I 

20 believe, by John's ASTM methodology. 

21 And then something which perhaps is a little 

22 bit dear to my heart, which I -- perhaps got to me 

23 as we've been trying perhaps to see now how ADMS 

24 performs relative to the various states that it's 

25 been used to look at AERMOD and -- in the USA here. 
 1 European Assessment/David Carruthers Vol. 2, p. 86 

 2 And we found it quite difficult, certainly in 

 3 the past, and the situation may have changed, but 

 4 we found it quite difficult to actually reproduce 

 5 exactly in terms of input with ADMS exactly what 

 6 has been used to test -- to test the -- to test 

 7 AERMOD, so I would make it a plea that when 

 8 statistical evaluation or evaluation models is 

 9 done, that the input files are made available so 

10 that -- so that other potential -- other -- other 

11 important developers can actually see exactly how 

12 models have been used in different circumstances, 

13 because we've been discussing, I think yesterday, 

14 very much how there are now many, many different 

15 opportunities to change the inputs in these newer 

16 models, so it becomes more and more important that 

17 we see those files. 

18 And I believe the last point is it's still, 

19 despite the last large amount of validation that's 

20 being done, there are still some areas where I 

21 think field data sets are lacking some detailed 

22 data sets, and they include some building downwash 

23 applications and complex terrain. 

24 Thank you. 

25 WARREN PETERS: Thank you. 
 1 Industrial Viewpoints/Ken Steinberg Vol. 2, p. 87 

 2 And next we'd like to hear from Ken Steinberg, 

 3 who's representing API. 

 4 We'll see from an industrial standpoint, we 

 5 have models, we evaluate them. Ken, you're on the 

 6 receiving end of our work, and I believe you have 

 7 done some evaluation work, as I remember, -- 

 8 KEN STEINBERG: (Interposing) Yeah. 

 9 WARREN PETERS: -- with certain situations at refineries and 

10 so forth, and did some model evaluation. There was 

11 a paper presented. 

12 But, Ken, you have some comments. 

13 KEN STEINBERG: Yes. I'd first like to give a little bit of 

 

14 a background, and maybe even before I mention my 

15 relevant background, perhaps gets me being able to 

16 to be on this committee, I would like to say that 

17 you have heard all the salient points that I could 

18 make already by these three gentlemen. 

19 David kind of stole most of my thunder when he 

20 talked about the data sets, because I think that 

21 was not mentioned up until that point, and so I'd 

22 like to give a little perspective based on the last 

23 twenty-five years or so that I have been involved 

24 in industry activities regarding models and model 

25 development. 
 1 Industrial Viewpoints/Ken Steinberg Vol. 2, p. 88 

 2 Prior to representing API, I worked for Exxon 

 3 Mobil for the model development group, in the 

 4 engineering area, and had quite a bit of experience 

 5 running regulatory models for permit applications. 

 6 Also through the API activities, began to 

 7 evaluate models because the goal that industry has 

 8 essentially, and the message that I'm really here 

 9 to present is that industry is interested in using 

10 models that are based on sound science. 

11 And what the API committee has done and has 

12 worked with OAQPS for many, many of those years has 

13 been striving towards assuring that sound science 

14 is applied. 

15 I'd like to provide a little perspective to 

16 some of the discussions here. 

17 There has been a lot of mention of the 

18 evaluation methods, and I, whether they be for 

19 field experiments where you have dense arrays or 

20 field experiments where sparse arrays and -- are 

21 carried out over a longer -- longer time 

22 periods. 

23 And I think where we are today, using the EPA 

24 methods for evaluating models or some of the 

25 methods that API has used, using a slightly 
 1 Industrial Viewpoints/Ken Steinberg Vol. 2, p. 89 

 2 different statistics, but essentially we are 

 3 looking at variance and bias in models and looking 

 4 at the significance of the model differences that 

 5 are being compared is significantly an improved 

 6 position than where we were twenty (20) years ago, 

 7 or fifteen (15) years ago. 

 8 I think we need to look back at some of those 

 9 methods and perhaps fine tune them and tweak them, 

10 but we also have to look back and, say, have they 

11 served us well? Where have they not served us 

12 well? And where they have not served us well, to 

13 put our energy and emphasis. 

14 My own sense is that they have served us quite 

15 well, and so that while I think I've heard eighty 

16 percent (80%) of the discussion so far on those 

17 methods, maybe more, I don't think that's really 

18 where the problems lie in the future. 

19 I think the problems lie in -- in the data 

20 sets. I think the data sets are, many of them go 

21 back twenty (20) -- twenty (20) years and longer, 

22 and some of the models that we are now promulgating 

23 have very sophisticated latest science approaches 

24 where measurements were never taken back in some of 

25 the early days. And we're trying to use our 
 1 Industrial Viewpoints/Ken Steinberg Vol. 2, p. 90 

 2 evaluation methods with data sets where we have 

 3 fundamental problems, how do we -- how do we set up 

 4 the model and basically dumb down the model to 

 5 match the data that we are attempting to drive it 

 6 with? 

 7 So my perspective, I suppose is, and I found 

 8 this in the industry work that we were doing as 

 9 well over the last five or six years, that the need 

10 was really to focus on and carry out field 

11 experiments, and the industry did carry out a 

12 number of field experiments, a number of laboratory 

13 experiments, wind tunnel experiments and so forth 

14 with trace gas releases and so forth, looking at 

15 area and volume sources, looking at downwash and 

16 things of that sort. 

17 But, again, I would emphasize that that's 

18 where the critical need, and that's where I think 

19 much of the money needs to be spent and time needs 

20 to be spent. While I wouldn't want to suggest at 

21 the cost of some of the other points that have 

22 already been made, they need to be carried on as 

23 well. 

24 But I personally think that eighty percent 

25 (80%) of the problem is in our data. 
 1 Comments/Warren Peters Vol. 2, p. 91 

 2 WARREN PETERS: Thank you, Ken. 

 

 3 I'm not sure the panel touched on it, but one 

 4 of the concerns that I have is that when we look at 

 5 the evaluation databases, for instance, what we've 

 6 gone through with AERMOD, now we ran seventeen 

 7 databases, as we have -- you may recall from our 

 8 summary yesterday morning that the large number of 

 9 databases, but still in reality, we haven't 

10 probably covered the majority of source types to 

11 which AERMOD is going to be applied. 

12 So, if that does raise up an antenna in terms 

13 of the process of the way to go through this, I 

14 think it makes it very, very important for us to do 

15 the the scientific component. I know John Irwin 

16 and I have argued about this in times past, but I 

17 think I'm starting to see his -- his ideas and 

18 agreeing with it, that the science component really 

19 helps us to understand that not only does AERMOD 

20 produce good regulatory concentrations, but it also 

21 produces good concentrations in other less 

22 meteorological settings. 

23 That is, they're insignificant for the tall 

24 stacks with the types of sources that we have in 

25 the evaluation database, but they may be very 
 1 Comments/John Irwin Vol. 2, p. 92 

 2 important for other source types, the smaller 

 3 stacks in different conditions. 

 4 So by going through and evaluating a model for 

 5 the different components under different 

 6 conditions, which aren't necessarily of regulatory 

 7 interest, still gives us a lot of insight in how 

 8 the model is performing over all the spectrum of 

 9 atmospheric conditions, because if we were to draw 

10 a bin diagram up here, a big circle of all the 

11 source scenarios that are possible in the world in 

12 which we need the model, the model evaluation: 

13 database is only going to cover a small portion of 

14 that bin diagram. 

15 So we have to build confidence in our models 

16 to extrapolate the model and prior to these sources 

17 were -- where AERMOD and other models have never 

18 been tested before. So it seems to me it's very 

19 important to have a science component as well as a 

20 regulatory component in the testing. 

21 So that's a comment from me. Okay, any other 

22 thoughts from the panel about this idea? Databases 

23 or the lack of databases; John? 

24 JOHN IRWIN: Back to John Irwin's world here. 

 

25 Just to mention a few things that slipped 
 1 Comments/John Irwin Vol. 2, p. 93 

 2 through the cracks. 

 3 I want to make it clear, if you ever do 

 4 acquire D-6589, when you read it, you will find 

 5 that the first probably ninety percent (90%) of the 

 6 pages is talking about the philosophy of how you 

 7 conduct a model evaluation. 

 8 In the appendix, there is an example that we 

 9 created to illustrate the thought process and how 

10 the -- how we envision modern evaluation methods to 

11 be developed, you know, just, just as an example, 

12 it was not to exclude other evaluation techniques 

13 that this example was provided. The example was 

14 provided to illustrate if you do consider 

15 stochastic processes, these are some of the things 

16 you have to deal with in thinking about it and in 

17 dealing with them. 

18 And the example is not a standard. It's not a 

19 standard evaluation procedure. It's just there as 

20 I described it as an example. 

21 In order for it to become a test method, it 

22 would have to be extracted out from the annex and 

23 written up as a test method and demonstrated that 

24 -- so that you could call upon it and say, I want 

25 you to use that method. It would have to be pulled 
 1 Comments/John Irwin Vol. 2, p. 94 

 2 out of the annex and actually written that way. 

 3 So the real meat of D-6589 is not the test 

 4 example; the real meat of D-6589 is trying to 

 5 describe to you the problem as we perceive it in 

 6 developing statistical evaluation methods for air 

 7 quality models. 

 8 In developing that example, we have worked 

 9 with a lot of people over the years, including 

10 David. He's run his model for us so that we 

11 could have model runs for three different data 

12 sets, so that we could compare a variety of 

13 models and -- and see how the test method worked, 

14 and it has evolved over time, as we've learned new 

15 things. 

16 We have learned that the methodology had to be 

17 altered, ever so slightly. 

18 The latest model runs are all available 

19 including all model inputs all meteorology, all 

20 emissions and all of the actual observations from 

21 three different tracer data sets. 

22 So an FT -- anonymous FTP site that EPA/ORD 

23 maintains, and that information could be made 

24 available on our SCRAM web site for people to see. 

25 Data quality is important. One of the things 
 1 Comments/John Irwin Vol. 2, p. 95 

 2 that's suggested in D-6589 is that you sort data 

 3 into groups before you test the model. The idea is 

 4 that you would only sort good quality data into 

 5 groups. 

 6 You wouldn't just blindly sort anything that 

 7 you had your hands on into a group and then start 

 8 working with it. 

 9 And I agree fully with the idea that working 

10 with the old tracer data sets is a challenge with 

11 the new modern models, because they're asking for 

12 inputs that aren't available in the old tracer data 

13 sets. 

14 That is a problem. It's going to be 

15 continuing a problem, because collecting and 

16 archiving data sets is expensive. 

17 WARREN PETERS: Any other comments from the panel on either 

18 John's ideas or the the -- my suggestion I raised 

19 about a limited databases? 

20 Ken. 

21 KEN STEINBERG: Well, I would -- I would just suggest that 

22 this -- this is an area I'm thinking in terms of 

23 the application of some of the models, regulatory 

24 models for residual risks, and I will mention some 

25 of this later on this afternoon. 
 1 Comments/John Irwin Vol. 2, p. 96 

 2 But the testing of the models that you have 

 3 inferred have been exhausted, but area and volume 

 4 source testing is one very key area that's going to 

 5 get a lot of usage in residual risks, whereas, 

 6 there -- there's just performance anomalies that 

 7 are out there, and we need to look at them and 

 8 really find out what is truth and then try and make 

 9 sure that the models that we are using are 

10 providing that, because there is a huge amount of 

11 regulatory consequences and costs to society that 

12 could be avoided if -- if we can make sure that we 

13 are applying the proper models, and that's going to 

14 be, I think, helped substantially, if we have 

15 appropriate field data studies. 

16 WARREN PETERS: Are there any questions or comments from the 

17 audience? 

18 AL CIMORELLI: This is Al Cimorelli. 

19 John, I want to address this to John. 

20 First, let me say that I -- I mean I think 

21 it's a great idea to go to an outside organization 

22 like that and to bring in as many experts as you 

23 can, have these -- have these test methods 

24 developed in a transparent way that people can 

25 utilize. 
 1 Comments/John Irwin Vol. 2, p. 97 

 2 I also have to admit that I got myself a copy 

 3 of the test methods, so I mean, if I gave you 

 4 fifteen (15) bucks, you think I feel less guilty or 

 5 something? Maybe, give me the address to send the 

 6 money to. (Laughter from the audience.) I can 

 7 make a little contribution. Maybe we can get 

 8 matching funds from the conference somewhere. 

 9 Anyway, the question I have for you is this; I 

10 completely agree with the concept that our models, 

11 I mean, the atmosphere is clearly stochastic. 

12 If you set up -- if you could set up an 

13 experiment where all the inputs were identical and 

14 you ran it over and over and over again, you'd keep 

15 getting different answers that can -- they convert 

16 it to an ensemble and our models do, in fact, 

17 predict those ensembles. Because if you run the 

18 model over and over and over and over again, you 

19 get the same answer with the same inputs. 

20 And I think that, in fact, these -- this type 

21 of test method, I think, recognizes that and that's 

22 extremely important, and it's important to 

23 understand that. 

24 However, there is in some ways a disconnect. 

25 If we go and we develop a model and we compare it 
 1 Comments/John Irwin Vol. 2, p. 98 

 2 against the ensemble average, if we can get the 

 3 data to do that adequately, and I'm not convinced 

 4 that we can do that without extensive data, we 

 5 then have a question that we're trying to have 

 6 these ans- -- models answered, and that question 

 7 is, what, what is the extreme value of that 

 8 ensemble. 

 9 So there is a bit of a disconnect between the 

10 two of those things. So it seems to me that either 

11 you build the model that somehow has an inherent 

12 conservative approach to it in some ways, and you 

13 compare it against this design concentration, or 

14 what-have-you, which is really the question that's 

15 being answered, and you say, yeah, yeah, looks like 

16 it's doing that pretty well, so now you can go out 

17 and say, I run the model, I have some confidence 

18 that it's getting this design value, or you build 

19 the model that goes after the ensemble, and now you 

20 go apply it and you know, you know damn right well, 

21 that where you are is underestimating the design 

22 concentration. 

23 And so the question, I guess is, if you were 

24 going to take this logically to its next conclusion 

25 is is you get this model that's designed for [an] 
 1 Comments/John Irwin Vol. 2, p. 99 

 2 ensemble on the average, now you need some 

 3 probability function that you can then apply for 

 4 some particular application, so now you can 

 5 estimate what the -- what the high, second high, or 

 6 the extreme value is? 

 7 And so the question then becomes, how you go 

 8 about estimating what that probability function is, 

 9 and that's going to obviously change from location 

10 to location. 

11 Has there been thought given to that, and I'll 

12 just finish by saying that when a test method comes 

13 out, I think it might be real important for ASTM or 

14 anyone to try to identify the questions that these 

15 methods are trying to answer. 

16 And then somebody can look at the relevance of 

17 whether that test method is important to the answer 

18 to the question they are trying to answer. 

19 JOHN IRWIN: Part of my thinking -- this is John Irwin. Part 

20 of my thinking in raising the issue that the world 

21 is stochastic, and we're using right now 

22 deterministic models that estimate the ensemble 

23 mean, is to, if I make this very obvious and if 

24 EPA makes it very public that this is the real 

25 situation, what this does is it sets up pressure 
 1 Comments/John Irwin Vol. 2, p. 100 

 2 to develop models that account for that 

 3 difference. 

 4 And they do -- there already is in existence a 

 5 model that worries about predicting not only the 

 6 ensemble mean but the concentration fluctuations 

 7 about the mean and it's called SCIPUFF. And it 

 8 does worry about the fact that the world has a 

 9 stochastic component, and it would be very easy for 

10 us to build other models of like philosophy. 

11 Now what would you do to evaluate that model? 

12 Well, now you evaluate the model for a group of 

13 data that has similar boundary conditions. You 

14 ask, how well does the model predict the average 

15 profile in this group of data, and how well does it 

16 estimate the scatter about the average profile? 

17 So now you test your model on two things; the 

18 ability to pull out the average pattern and the 

19 ability to simulate the scatter. 

20 Then how would you use the model? 

21 Well, if you want the model to be used to look 

22 at second high concentrations, you would run the 

23 model in a stochastic form. You would have it 

24 estimate the second high concentration and give you 

25 an average second high concentration. 
 1 Comments/John Irwin Vol. 2, p. 101 

 2 So -- and what this does if we think about 

 3 this, I mean if you really think about how the 

 4 world works and what we are doing, we are setting 

 5 up a process of thought that says, the world is 

 6 more complicated than the models right now are 

 7 currently estimating. 

 8 So that sets up a research agenda for the 

 9 future, for model development. More sophisticated 

10 thinking in our model development is going to 

11 require more -- more thought in how the models are 

12 applied and used and developed. It's also going to 

13 require more thought on how we evaluate the models, 

14 but at least it's a forward look. 

15 If we stay where we are, well, we are going to 

16 be using the same meteorology that we used thirty 

17 (30) years ago, and the models aren't going to 

18 advance, and we are not going to get past this 

19 hurdle that what we are now simulating with our 

20 models, is not what is going on out there in 

21 reality, and we are using tools that are really not 

22 designed for the purposes for which they're being 

23 used. They really -- I mean they were designed 

24 originally in a concept that we thought when we 

25 were, you know, when I was young and naive, I 
 1 Comments/John Irwin Vol. 2, p. 102 

 2 thought that ISC was predicting the second high 

 3 concentration. Now I see it doesn't have the 

 4 physics to do that. If it does it, it's doing it 

 5 in error. You know, it's flat wrong. If it comes 

 6 up with a second high concentration, there is 

 7 something wrong in the model. 

 8 I didn't know that when I started with EPA 

 9 back in 1975. Now I know that. 

10 Now, what do I do, stick my head in the sand 

11 like an ostrich and ignore the fact, or do I make 

12 it obvious and say to everybody, I've learned 

13 something in thirty years of working in this field, 

14 and I'd like to see us move past the thought 

15 process of ISC and -- and AERMOD, even. I'd like 

16 us to move it into a stochastic process world, 

17 where we actually are trying to simulate the 

18 processes as they occur in the atmosphere. 

19 I'll stop there. 

20 I'll get off my soap box! 

21 WARREN PETERS: Thank you, John. 

22 Any further comments or questions from the 

23 audience? 

24 Dick. 

25 RICHARD SCHULZE: You know, we in this room, this is Dick 
 1 Comments/John Irwin Vol. 2, p. 103 

 2 Schulze, Trinity, are a very small portion of the 

 3 model development evaluation efforts that are going 

 4 on in this nation. 

 5 EPA has one particular view, but at the same 

 6 time the Army is doing a great deal of work, the 

 7 Air Force, the Department of Energy, at Lawrence 

 8 Livermore Anderson and some of the other 

 9 laboratories, the Department of Homeland Security, 

10 all of these governmental entities are spending far 

11 more money than EPA in the area of model 

12 development. 

13 And I'm wondering what benefit might be 

14 derived from just a governmental get-together of 

15 all these governmental agencies, because we are all 

16 dealing with some of the same issues that we're 

17 dealing with in this room. And we are dealing -- 

18 you know -- with a small portion of what's going on 

19 throughout this nation. 

20 I think we can benefit by developing links 

21 with these other groups, and -- and learning from 

22 them, and having them learn from us. 

23 WARREN PETERS: Thank you, Dick. 

24 John. 

25 JOHN VIMONT: Well, one other question I had for the panel 
 1 Comments/John Irwin Vol. 2, p. 104 

 2 was, most of the techniques that are talked about 

 3 here are basically looking at matching things, 

 4 for the most part, irrespective of the time they 

 5 occur or where they occur. 

 6 Some applications, particularly application of 

 7 CALPUFF or Class 1 areas demands that these 

 8 concentrations occur at a specific place at least 

 9 and preferably at a specific time. 

10 What are your thoughts on demanding the models 

11 actually not only predict the right -- the high 

12 concentration, but also the right concentration in 

13 the right place at the right time? 

14 TYLER FOX: Question, John. 

15 WARREN PETERS: For the startup -- that was John Vimont of 

16 the National Park Service. Okay? 

17 JOHN VIMONT: Thank you. 

18 JOHN IRWIN: This is John Irwin, representing John Irwin. 

19 (Chuckles.) 

20 Well, I'm going to test you a little bit, 

21 John. 

22 If I gave you a pair of dice, and I asked you, 

23 is this a fair pair of dice? How would you find 

24 out? Would you roll it once, see that it came up 

25 with an outcome of two, and say, Hmm, it's a fair 
 1 Comments/John Irwin Vol. 2, p. 105 

 2 pair of dice. No, you wouldn't do that. You would 

 3 run it maybe a hundred (100) times, wouldn't you, 

 4 or maybe a thousand times, you'd throw the pair of 

 5 dice, and you would look at the distribution of 

 6 outcomes, and you would check it against the 

 7 binomial distribution to make sure that two, three, 

 8 four, five, six, seven and all the other outcomes 

 9 came out reasonably close to the theoretical 

10 prediction of what a pair of dice should give you. 

11 And if it comes out reasonably close, you 

12 would say, this is a fair pair of dice and it's 

13 doing the job of acting like a fair pair of dice. 

14 Now you also realize that it's, at least in my 

15 opinion, impossible to predict the series of 

16 outcomes that you are going to get. 

17 So we know exactly what the distribution is to 

18 be, but we have absolutely no ability to predict 

19 the series of outcomes. 

20 Now, if you do learn how to do that, would you 

21 please take me to Las Vegas? (Laughter.) So, your 

22 question; you want a model to predict what's seen 

23 in exactly the location of where you see it, and 

24 exactly where it occurs in time. Actually that's 

25 philosophically impossible, absolutely impossible. 
 1 Comments/John Irwin Vol. 2, p. 106 

 2 The only thing air quality dispersion models 

 3 can predict is the distribution of outcomes to be 

 4 seen at a location over time, and if you have a 

 5 fully stochastic model, it will give you a full 

 6 description of the probability distribution of 

 7 outcomes to be seen over time at a particular 

 8 location. 

 9 That's the only thing it can predict. It 

10 can't predict exactly what's seen in each 

11 realization. That philosophically can't happen. 

12 JOHN VIMONT: I don't disagree. However, the metrics that 

13 I've seen proposed don't really deal with the 

14 distribution at the place and time. They just deal 

15 with the distribution anywhere, which doesn't seem 

16 very satisfactory to me. 

17 JOHN IRWIN: I agree. That's why we need new methods. 

18 WARREN PETERS: Well, actually that's not quite true, John, 

19 you remember in that review I gave on the 

20 scientific component of the protocol, there 

21 actually was a bearing. 

22 JOHN VIMONT: There was, which I was surprised to see, 

23 however, some -- 

24 WARREN PETERS: Averaged out. 

25 JOHN VIMONT: Right. There were some models that were really 
 1 Comments/John Irwin Vol. 2, p. 107 

 2 asked to at least get things close in space, and 

 3 again, the regulatory requirements sometimes for 

 4 like Class I is, where you're looking only at that 

 5 area; you're predicting the increment in a Class 1 

 6 area. You are supposed to have it in the Class 1 

 7 area, and the model evaluation is saying, I've got 

 8 to max somewhere else, isn't necessarily relevant 

 9 to that question. 

10 So, I guess one thing I would suggest is that 

11 as you develop these techniques, that the -- and 

12 then the model may be used for other things as 

13 well. So, you have to consider both things. 

14 But consider the regulatory application or, as 

15 Al was talking about, the form of the standard, you 

16 know, in, you know, in connec- -- setting up your 

17 evaluation procedures. 

18 WARREN PETERS: We want to probably take a few-minute break. 

19 I realize this is -- part of the program is 

20 probably not your cup of tea here, for most members 

21 of the audience. 

22 This is really technical on -- and -- in 

23 nature, and also there is a tremendous number of 

24 details, as you can see from the general side he 

25 presented this morning, the equations get really 
 1 Comments/John Irwin Vol. 2, p. 108 

 2 heavy fairly quickly, but I do believe there is a 

 3 bottom line here for modelers that are using, you 

 4 know, CALPUFF or AERMOD or whatever, it's still 

 5 useful for you to spend a few minutes taking out 

 6 the model evaluation reports, going through them 

 7 and trying to get at least a glimpse of the 

 8 modeling forms you've seen and notice that they're 

 9 not tested in all regimes, and get a feel for it, 

10 what regimes were they tested in where they 

11 performed well, and get a basic sense of where we 

12 know the model does a good job, and how it's been 

13 tested. 

14 And you don't have to spend a lot of time on 

15 the reports; you don't have to be an expert to just 

16 to get a feel for, and some confidence in, the 

17 model. 

18 Or, lack of confidence, perhaps, in certain 

19 areas where you realize that the model has not been 

20 tested. 

21 So it's some really important information in 

22 those model evaluation reports. Again, probably 

23 one of the lessons we can learn this morning is, go 

24 back and read those reports and get that sense. 

25 TYLER FOX: Before we take our break, and this will be really 
 1 Comments/John Irwin Vol. 2, p. 109 

 2 brief, and I just want to kind of reflect on what I 

 3 heard just -- and to the extent I'm not digesting 

 4 things correctly here, get some feedback from the 

 5 panel. 

 6 But there is three main things that I kind of 

 7 summarized here is; the need for a process that is 

 8 both open and capable of the appropriate betting 

 9 that considers, you know, a number of different 

10 factors that are both scientific and regulatory, 

11 and keeps in mind what the overall purpose and goal 

12 of these models are. 

13 But, again, having a process and making sure 

14 that we engage properly and get -- to get the right 

15 people involved. 

16 Secondly, accessibility and transparency, and 

17 that applies, not just to the models, but to 

18 evaluation tools and to the data that are used in 

19 those evaluations. 

20 And then, lastly, which I -- I couldn't agree 

21 more with, is, getting the right data. 

22 And one of my questions is, how is -- how do 

23 we promote a process to get the investments made in 

24 those field studies that are so critical for us to 

25 push things forward? 
 1 Comments/John Irwin Vol. 2, p. 110 

 2 Because, as you said, without that, we are 

 3 really walking blind, without really -- you know -- 

 4 and we're just going to continue to bump around, 

 5 because we've got to have those data to know if 

 6 we're getting the right things out of our models, 

 7 especially as complex and especially as many knobs 

 8 and twitches as we have in these models now, it's 

 9 very important for us to -- to really start taking 

10 that into consideration and bring the monitoring 

11 and other types of field study efforts. 

12 And I think getting other Federal agencies 

13 involved, again, through the -- through the vision 

14 statements, trying to get a collaborative approach, 

15 not just within EPA, but involving all the Federal 

16 agencies. 

17 So to the extent anybody has any ideas to -- 

18 to propose over the next thirty (30) days and put 

19 in the docket, or if anybody wants to briefly touch 

20 on that now, I will just -- 

21 KEN STEINBERG: Let me -- This is Ken Steinberg with API. 

22 Over the last ten (10) years or so, maybe a 

23 little longer, I was involved with -- with a field 

24 model that didn't deal with the AERMOD type models 

25 per se. 
 1 Comments/John Irwin Vol. 2, p. 111 

 2 It tended to deal with accidental release 

 3 models, which we'll -- what is relevant is that 

 4 these studies were joint studies. The first one 

 5 which was called Tidbox, which was a field study in 

 6 Nevada where EPA/ORD participated along with 

 7 industry through an organization called Petroleum 

 8 Environmental Research Forum, where anyone, and I 

 9 know EPA is a participant on that group, can 

10 propose a project, and this particular joint effort 

11 was -- was, I don't know, two or three million 

12 dollars in size. 

13 And it would not be difficult to propose the 

14 projects and find out who the sponsors are who 

15 would be interested, and it would be a real fine 

16 opportunity, and there is precedent for having that 

17 sort of linkage, to -- to actually put major field 

18 studies together. 

19 And I know API, for example, has investigated 

20 a number of activities that looked at doing 

21 photochemical modeling studies, and there are 

22 various industry organizations, I know some in 

23 California that have jointly sponsored major field 

24 studies. 

25 So -- so those studies have been done in the 
 1 Comments/John Irwin Vol. 2, p. 112 

 2 past, and there are mechanisms out there to do 

 3 it. 

 4 It takes really leadership and -- and speaking 

 5 from industry's standpoint, it -- it often is 

 6 difficult to go to industry management and say I'd 

 7 like to have you invest in X number of dollars over 

 8 the next five years to develop a field study, or 

 9 ten (10) years, but it really enhances it when it's 

10 related to the business, and secondly, it's related 

11 to participation with the regulatory authority in 

12 -- in a cooperative sense in a technical vein. 

13 This has nothing to do with policy. 

14 This is purely to either try to get the data 

15 or to get the data and to help improve the models 

16 and technically evaluate them. 

17 There is plenty of precedent where that type 

18 of study has been done, and it's going to require 

19 someone and probably someone from industry, and API 

20 could help serve as a focal point to get to the 

21 right people and to the government to make that 

22 happen. 

23 And I would hope that within Government, there 

24 would be a liaison to the various other 

25 organizations that are doing test work. 
 1 Comments/John Irwin Vol. 2, p. 113 

 2 As -- as Dick Schulze mentioned, there is a 

 3 vast amount of work that's being done. 

 4 WARREN PETERS: Thank you. 

 5 One other comment in the back. 

 6 LOUIS MILITANA: Louis Militana, with AAQS. 

 7 EPA, when they assess penalties to people who 

 8 are not in compliance have the program called the 

 9 supplemental environmental performance, I guess, or 

10 SEPs, and they are always struggling to try to come 

11 up with ideas of how to, instead of just having the 

12 company pay money but fund projects, environmental 

13 projects. 

14 I mean there is a very good avenue to raise 

15 that as a collection method of collecting -- you 

16 know -- various dollars across the environmental -- 

17 the penalties, and in thinking of funding a 

18 modeling validation study. 

19 So it's -- you know -- there is a process now, 

20 I think, within EPA's house itself to try to 

21 capture some of those dollars. 

22 WARREN PETERS: Thank you. 

23 TYLER FOX: Well, we will take a, I believe, a ten-minute 

24 break. Again, I really appreciate your active 

25 engagement in this discussion and look forward to 
 1 Model Acceptance/Tyler Fox Vol. 2, p. 114 

 2 the next session. Thank you. 

 3 ________________________________ 

 4 (BREAK, 10:26 - 10:46 A.M.) 

 5 ________________________________ 

 6 (Announcements.) 

 7 (Comments off record.) 

 8 TYLER FOX: Our last session for this in the morning deals 

 

 9 an issue of -- and issue of -- of model 

10 acceptance. 

11 Just as a -- as a setup here, you've heard 

12 from me, and you've heard many other people talk 

13 about things that will be changing in the future. 

14 Our models will be changing, evolving, the 

15 science of them, the process by which we evaluate 

16 these as we discussed just recent- -- just now, 

17 needs to keep pace, the databases supporting that. 

18 Also in the context of collaboration across 

19 EPA, across Federal Government, trying to promote 

20 that type of collaboration and that more community 

21 approach to -- to model development that is really 

22 something that we should consider when you see the 

23 loss of technical expertise, especially as it 

24 relates to my group, and I know OAQPS in general, 

25 the leadership and the expertise that was there, 
 1 Model Acceptance/Tyler Fox Vol. 2, p. 115 

 2 the leadership in that expertise that was there 

 3 over the past two decades or so is -- is 

 4 leaving. 

 5 And we need to be able to internally have a 

 6 process to sustain that and have that transfer into 

 7 the institutions so that we don't lose it once 

 8 individuals walk out the door. And we need to 

 9 recognize that we are not going to always be able 

10 to backfill for these folks, and even if we could, 

11 could we get the expertise at a similar level 

12 that's walking out. 

13 So to maintain that level of expertise is 

14 going to be a challenge. To maintain the 

15 leadership and the ability to develop models and go 

16 through this process, given the budgets that we're 

17 going to be facing is going to be another 

18 challenge. 

19 It's -- it's not something that, you know, me 

20 pitching to my management and getting some money 

21 and the amount of money that we might able to get 

22 is going to be able to solve the issues. 

23 So what we'd like to do in this session is 

24 just throw out the question of -- of model 

25 acceptance and have the panel talk about and 
 1 Model Acceptance/Tyler Fox Vol. 2, p. 116 

 2 reflect upon the current process, and ideas about a 

 3 future process that would, again, be more timely, 

 4 be more re- -- you know, maybe more continual in 

 5 its -- in its evolution in -- with respect to the 

 6 model science as it changes and the evaluations as 

 7 they are able to be performed, and get us to a 

 8 place where we are harmonized and in a way -- in a 

 9 way that obviously doesn't put me in -- in a 

10 position where I'm yet again telling you that 

11 AERMOD's coming, AERMOD's coming, AERMOD's 

12 coming. 

13 People are using AERMOD, people need to be 

14 using AERMOD, people probably should have been 

15 using AERMOD for a long time, and I don't feel 

16 comfortable being put in a position where our 

17 regulatory process is inhibiting or not promoting 

18 the use of the right science. 

19 And that -- that is kind of at the heart of 

20 the question that we'd like the panel members to 

21 try and address. 

22 We've got the same members that we had, 

23 excuse me, earlier this morning, and then from 

24 Virginia and West Virginia, we have Ken McBee and 

25 Chris Arrington to add that perspective here as 
 1 Model Acceptance/Tyler Fox Vol. 2, p. 117 

 2 well. 

 3 So, John, we'll kick it off with you again, 

 4 and I believe you have a presentation, so I'll go 

 5 ahead and -- 

 6 (Adjusting auditorium lights.) 

 7 TYLER FOX: So we'll begin with John Irwin, and we'll walk 

 8 through from there. 

 9 JOHN IRWIN: Well, I like the quote that you started off with 

10 earlier, Tyler. This is John Irwin for the sixth 

11 time, that vision without action goes nowhere. 

12 Action without vision is a nightmare. What we need 

13 is both vision and action. 

14 What I'm going to outline for you is a bit 

15 visionary. I don't think we can get there. I know 

16 that we can't do it right now. But I set it as a 

17 goal, something to work towards, and that's the, I 

18 guess, the way I will portray it. 

19 (Projecting slide.) 

20 On the next slide I sort of outline very 

21 quickly where we are. 

22 In principle, all candidate models must pass a 

23 minimum level of documentation in its formulation, 

24 user's guides, peer review and availability. 

25 EPA developed the Cox/Tikvart methodology. 
 1 Model Acceptance/Tyler Fox Vol. 2, p. 118 

 2 Other people, Joe Chang and Steve Hanna, created a 

 3 boot program that implements the bootstrap 

 4 resampling procedure. 

 5 Russ Lee and I, many years ago, once tried to 

 6 create a Fortran code to do this. I don't think it 

 7 ever got formally completed ready -- to be ready 

 8 for public dissemination. 

 9 One of the problems with Government agencies, 

10 you get things started, and you find out you don't 

11 have any money. 

12 EPA has defined model evaluation techniques 

13 which has a means for ranking skill, and even 

14 testing for the significance of the differences, 

15 unlike what that bullet says up there. 

16 And I'd like you to understand that this 

17 system, developed largely by Government workers and 

18 Government money, took years to put into place, and 

19 to change it is no simple task. It takes a lot of 

20 work to come up with new ideas and new procedures 

21 and implement them and test them. 

22 It's just tough. 

23 And I appreciate what Tyler Fox is saying, 

24 that if we could just somehow expand the number of 

25 people working in this project, get more hands to 
 1 Model Acceptance/Tyler Fox Vol. 2, p. 119 

 2 the task, maybe we could accomplish more. 

 3 (Projecting slide.) 

 4 So in the next slide, I say "what might be 

 5 changed?" 

 6 Well, I said in my first presentation, we need 

 7 to get the message out that models are predicting 

 8 one thing and we're observing another, and I won't 

 9 go back through that. 

10 We need a collection of test procedures that 

11 tells you the relative skill in competitive models 

12 for the same application. 

13 And in that test of ranking of skill, we need 

14 to see whether the differences, even if one model 

15 is ranked somewhat different than another, is it 

16 really significantly different given the data sets 

17 that you are using and the uncertainty that are in 

18 the analysis. 

19 But envision what happens if we had a whole 

20 collection of evaluation (cough) methods. We 

21 don't have them right now, we don't have a whole 

22 collection of documented databases and 

23 documented data sets that everyone in using and a 

24 whole collection of evaluation methods that we're 

25 comfortable with. 
 1 Model Acceptance/Tyler Fox Vol. 2, p. 120 

 2 But what if we did have that? 

 3 What if there was a standing committee in ASTM 

 4 that's developing evaluation methods and kicking 

 5 out methods, and people are developing data sets 

 6 and we're starting to publicly distribute these 

 7 data sets, and everybody's getting sort of familiar 

 8 with them. 

 9 What if we were there? What could we do? 

10 Well, next slide. 

11 (Projecting slide.) 

12 I gave you something to debate about. Don't 

13 worry, you don't have to do this right away, you've 

14 got at least three to five years, or maybe longer, 

15 before we get here. 

16 All right? I'm just setting out something 

17 that we could shoot for. 

18 What would happen if EPA changed the model 

19 guideline to say: the minimum acceptable 

20 documentation for an acceptable model is..., and 

21 they listed user's guides, science formulations, 

22 sensitivity reports, and maybe even define the 

23 content, the scope, and content of those documents 

24 and what was supposed to be in them. 

25 And then they said, by the way, your model has 
 1 Model Acceptance/Tyler Fox Vol. 2, p. 121 

 2 to be peer reviewed, and I want that peer review 

 3 conducted in this fashion, and I want it documented 

 4 in the following fashion, and I want all of that 

 5 written up and available for public review. 

 6 And last, but not least, you will have to 

 7 demonstrate to EPA that your model has completed 

 8 both of those first two parts, and then you're 

 9 going to test your model using ASTM test methods A, 

10 B, and C with data sets one through twelve (12), 

11 and you must demonstrate that your model does at 

12 least as well as, or maybe even better than, some 

13 level of skill; maybe it's defined by the model 

14 that's currently approved by EPA, or maybe it's 

15 just a number for each data set and each test 

16 method. 

17 Now, what this is called is called a 

18 performance standard, and it doesn't say a 

19 particular model. It just says a particular skill 

20 that has to be achieved in order to be accepted. 

21 If we had this kind of thing, then the models 

22 that would be approved for use would not have to go 

23 through regulatory review. This kind of process 

24 would be sort of a certification process that could 

25 happen when it is available at that time that the 
 1 Model Acceptance/Tyler Fox Vol. 2, p. 122 

 2 model has its paperwork submitted, EPA goes through 

 3 a review, certifies that it's there and perhaps 

 4 goes up on their web site and lists this model and 

 5 says certification was completed. Here's all the 

 6 documents that were submitted, and in our opinion 

 7 this model is ready for regulatory use in these 

 8 particular venues. 

 9 Pretty quick, if you think about it, at least 

10 quicker than where we are right now, more flexible 

11 than where we are right now. 

12 There are pitfalls, there are problems, I 

13 know, you know, I'm not saying I have all of this 

14 thought out, but I'm just setting for you some 

15 vision of where we might able to go. 

16 It's a worthy goal. Whether or not we ever 

17 get there, but I think it's a worthy idea to get 

18 towards. 

19 Now, next slide. 

20 (Slide is projected.) 

21 Common worries. 

22 You've heard some of these before. EPA will 

23 be forced to accept a bad model. 

24 And I ask you how is that going to happen? If 

25 EPA lays out the criteria and your model, or the 

 ___ 
 1 Model Acceptance/Tyler Fox Vol. 2, p. 123 

 2 model that is approved does at least as well in all 

 3 of these different tests as the approved model, can 

 4 you say that this is a bad model, and should not be 

 5 approved. 

 6 EPA will lose control. Well, not really, EPA 

 7 is going to define what's necessary, what's needed, 

 8 and EPA is going to be the gatekeeper. I don't 

 9 think EPA will lose control on this process. 

10 The one part that probably is most problematic 

11 is the third bullet. 

12 Right now, the way we use the models, we don't 

13 know what to do if you have two models that give 

14 two different answers for the emission control 

15 limit. EPA just has not come up with a way of 

16 handling that. 

17 I have my cryptic response. It doesn't really 

18 solve the problem, but my cryptic response is this; 

19 if you are going to be a leader, sometimes you are 

20 going to run into situations that are nasty, and 

21 part of being a leader, part of EPA -- if EPA wants 

22 to provide the leadership role, part of being the 

23 leadership role is to find a solution to this 

24 problem. 

25 We don't have to have the solution now. We 
 1 Panel/New Models/Robert Paine Vol. 2, p. 124 

 2 don't even have this procedure now. We don't have 

 3 the evaluation tools now, but I think that this is 

 4 the least of the worries, personally. I think the 

 5 solution can be found, and I have every confidence 

 6 that it can be found. So I'll stop right there and 

 7 let you people worry about my vision. 

 8 WARREN PETERS: Thank you, John. 

 9 Now we have John Paine. 

10 ROBERT PAINE: I have a presentation labeled "Paine, New 

 

11 Models". It's the lowest on the right. 

12 Can we have the next slide? 

13 WARREN PETERS: Sure. 

14 ROBERT PAINE: And I, as -- following up with what John said, 

15 and I was able to see some fast notes. This 

16 situation that's being considered is that for the 

17 same regulatory application, reasonably could be 

18 several different recommended dispersion models may 

19 give different answers, all of them which are 

20 presumably, possibly valid. 

21 And this could lead to, unless we sort this 

22 out, extensive arguments over the best model where 

23 industry probably attempts to find the lowest 

24 predicting model and opponents advocate the highest 

25 predicting model, and that leads to probably all 
 1 Panel/New Models/Robert Paine Vol. 2, p. 125 

 2 sorts of legal fights in the permit appeals, and 

 3 who is right, and how is EPA going to manage this 

 4 confusion, is sort of what we have to solve before 

 5 we can go there. 

 6 Next slide. 

 7 (Projecting slide.) 

 8 I think that it's possible to do. One thing 

 9 that would make it better is that we need to have a 

10 third party peer review. I don't know if there 

11 would be a standing type of peer review committee. 

12 I think it would have to be different for different 

13 types of models. We currently have seventeen (17) 

14 databases for AERMOD, and we need other databases 

15 for other types of sources. But I think that there 

16 should be an extensive set of evaluation databases 

17 set aside, and we used to worry about whether a 

18 database was independent, or developmental, whether 

19 once you touched it it was solid, and you couldn't 

20 use it again. 

21 But I think if you have enough such databases 

22 it shouldn't matter and, therefore, a large set 

23 will reduce comments off this -- this type of 

24 issue, because a good model must perform well 

25 across a large variety of data sets. 
 1 Panel/New Models/Robert Paine Vol. 2, p. 126 

 2 Next slide. 

 3 (Slide is projected. ) 

 4 I hope that we can make it so that we don't 

 5 have to wait fourteen (14) years to have a model 

 6 like AERMOD be -- be approved. 

 7 A lot of performance should be certainly 

 8 geared to avoiding model under predictions and 

 9 making note of the areas where model performance 

10 excels and where -- is it adequate? Not all models 

11 are going to be right for all applications. There 

12 will be strengths and the weaknesses, as we know, 

13 for all sorts of models. 

14 And, therefore, recommendations for its use 

15 can be qualified based on the model formulation, 

16 the inherent limitations and -- and the evaluation 

17 performance. 

18 So, next slide. 

19 (Projecting slide.) 

20 So, you measure that each model use would have 

21 to have a modeling protocol, and selected case as 

22 to why the selected model is the best for the given 

23 application, and EPA may need to have a panel of 

24 experts to make judgment calls. 

25 It could be the role of the EPA model clearing 
 1 Panel/New Models/Robert Paine Vol. 2, p. 127 

 2 house. I imagine that EPA regions may want to 

 3 retain their traditional roles, as well, to make 

 4 their regional decisions. 

 5 Next slide. 

 6 (Projecting slide. ) 

 7 So what might be minimal requirements for 

 8 models to be approved for use? 

 9 It's probably been mentioned before, among 

10 those are peer review and evaluation tests. Model 

11 documentation is available. 

12 Now in the case of a proprietary, or a model 

13 where the Code is -- is not disclosed to the 

14 public, perhaps this is possible but it -- a -- the 

15 panel would probably have to verify that the Code 

16 accurately portrays what the model is -- is 

17 advertised to do in its formulation which -- and I 

18 think the model formulation would have to be 

19 documented. 

20 In any -- any case for any model, that's 

21 right, and in certain analyses, I think it's 

22 necessary to determine the limitations of whether 

23 if you don't know the value of certain model inputs 

24 is that will lead to a radically different output 

25 that -- that would make it unacceptable in terms of 
 1 Panel/New Models/Robert Paine Vol. 2, p. 128 

 2 its uncertainty. 

 3 Next slide. 

 4 (Projecting slide.) 

 5 To maintain the use of the model, I think EPA 

 6 should periodically review the adequacy of the 

 7 models previously accepted for use so that they 

 8 don't become obsolete. 

 9 Models should be available to the public 

10 entities at a reasonable cost, and if a model is 

11 changed after its initial acceptance, especially if 

12 it's changed by a private entity, I think that 

13 change should be publicly available and documented 

14 to be acceptable for its regulatory review and use. 

15 Next slide. 

16 (Projecting slide.) 

17 So EPA's role in this vision that John laid 

18 out would be that I think the proposed approach has 

19 its merits, but it's ambitious and untested, but it 

20 has its promise. 

21 Decisions on model selection could certainly 

22 be controversial, especially in areas where many 

23 models are proposed to be potentially applicable. 

24 Now, here's a big question. 

25 EPA has many demands on its resources and 
 1 Panel/Foreign Development/D. Carruthers Vol. 2, p. 129 

 2 with recent budgetary strains, can EPA really 

 3 develop the resources needed to administer such a 

 4 program? 

 5 And as models get added to the list, you know, 

 6 the regions are having enough trouble learning 

 7 AERMOD. Suppose they had to learn other models. 

 8 Can the regions and states keep up with the 

 9 ever increasingly long list of approved dispersion 

10 models? 

11 So that's a challenge. I think that ends my 

12 presentation. 

13 TYLER FOX: Thank you, Bob. 

14 And next is Doctor Carruthers. 

15 DAVID CARRUTHERS: I have a presentation there as well, which 

 

16 is -- it's on the left there. 

17 (Projecting slide.) 

18 Okay. Thank you very much. 

19 Again, I'm going to go through the questions 

20 which were formulated from the point of view again 

21 of development and outside the USA. 

22 But I hope I can give you some interesting 

23 reflections. 

24 And now this first slide which I'll spend an 

25 extended amount of time on, it just, I think growth 
 1 Panel/Foreign Development/D. Carruthers Vol. 2, p. 130 

 2 in this, the key criteria for acceptance of the 

 3 model. 

 4 And now from our own perspective as developers 

 5 of another model and the two issues which concerns, 

 6 I believe, are concerning this audience or this 

 7 panel here today, first of all that there is only a 

 8 single preferred model; and secondly right at the 

 9 bottom that they think the model should be 

10 proprietary. 

11 Now, I would say more about models not being 

12 proprietary except I'm not sure why that is, in 

13 fact, the case. It seems to me that needs some 

14 explanation. 

15 So we'll go on to talk about the preferred 

16 model status in the one model, and what 

17 that sort of, I think implies -- if I can have the 

18 next slide, please. 

19 (Projecting slide. ) 

20 -- and should just say, perhaps, referring to 

21 Bob Paine's last point, there are, in fact, a 

22 number of models which are being accepted for use 

23 in the UK, so that we already have a rather sort of 

24 more flexible system. 

25 We don't -- we don't actually stipulate that 
 1 Panel/Foreign Development/D. Carruthers Vol. 2, p. 131 

 2 one model should be used. And I do, you know, I 

 3 sort of still stick with the argument, that 

 4 chemicals -- we have agency chemicals that 

 5 -- and some difficult things, but I think the 

 6 advantages outweigh those difficult things. 

 7 But, again, to go through and some, I think, 

 8 disadvantages mainly of the -- of the current 

 9 approach which are listed here. 

10 First of all, there is a potential for 

11 contradiction. I mean, this didn't really come up 

12 with AERMOD, perhaps because not all the models out 

13 there that were looked at in eval- -- in the 

14 evaluation, but there is potential that a 

15 proprietary model could be, for instance, shown to 

16 be better than them, a nonproprietary model, what 

17 do you do in that circumstance? 

18 And I think sort of looking back in history a 

19 little bit, I think the -- the supplier of the 

20 third model was first, or perhaps when there were a 

21 lot -- a lot fewer models around, so perhaps it was 

22 easier to -- to stick with one model, and mention 

23 -- the reason I mention the incident, is it's now 

24 much freer movement of information, so I think it's 

25 very easy for most people to become familiar with 
 1 Panel/Foreign Development/D. Carruthers Vol. 2, p. 132 

 2 new systems as long as they are documented properly 

 3 and that there's reasonable software. 

 4 And the next slide is very much the 

 5 perspective from the UK, -- 

 6 (Projecting slide.) 

 7 -- and -- which is that as soon as you give a 

 8 -- the US EPA gives a model the stamp, and this is 

 9 certainly the case for ISC, it becomes the sort of 

10 model which is accepted and used 

11 throughout the world. 

12 Now, that has some good aspects possibly when 

13 that model does deal with the applications in the 

14 best way. But the problem is because of this sort 

15 of stamp, (cough) almost, it gets used in many 

16 situations, I believe, where it's not necessarily 

17 the best model, and even it's used for applications 

18 where it is not appropriate. 

19 And -- and just to sort of take it a bit 

20 further, we have found, for instance, there was -- 

21 there was huge reluctance to use an ADMS at first 

22 rather (cough) than ISC, just because ISC had a US 

23 EPA stamp. 

24 And I think you will accept that ADMS are 

25 using -- are finding that they are much better 
 1 Panel/Foreign Development/D. Carruthers Vol. 2, p. 133 

 2 models than ISC. 

 3 And then the last two points, I think, from 

 4 our perspective that this sort of always using one 

 5 model can tend to stifle development and scientific 

 6 research, and that's perhaps, you know, as much a 

 7 comment about UK as US, but there is sort of always 

 8 the comment in UK, well, ADMS is coming, why 

 9 should we do anything else? 

10 And that's --- I mean, perhaps that's not so 

11 relevant to this discussion here, but I think you 

12 will find it interesting -- interesting 

13 nonetheless. 

14 May we have the next slide, please? 

15 (Projecting slide.) 

16 And so I think I'm really perhaps saying, in a 

17 way, very much what has already been said in terms 

18 of an alternative system, perhaps, and for the 

19 reasons I've just mentioned, I mean, an alternative 

20 system where potential for more than one model to 

21 be used in a particular application, would seem a 

22 more progressive system, which is, I think, going 

23 to help scientific development. 

24 And I think it's already been said how we 

25 should go about this, but the idea of some panel 
 1 Panel/Foreign Development/D. Carruthers Vol. 2, p. 134 

 2 basically using the community to review inclusion 

 3 based various acceptance criteria which will 

 4 already be for the public to see, seems to lie 

 5 forward. 

 6 And the particular question was raised; what 

 7 about the fact that, you know, that different 

 8 models give different results. Well, I think you 

 9 have already crossed that bridge -- crossed that 

10 line, because AERMOD, and we've already discussed 

11 this, that AERMOD and CALPUFF are really quite 

12 complex models, which can give quite different 

13 outputs depending on what input you give them, 

14 and I think, you know, the impression I certainly 

15 got yesterday was that you weren't going to be 

16 that prescriptive about how you defined an input. 

17 It will be the guidelines rather than 

18 prescription. 

19 It's inevitable that different application for 

20 a different use of the model for a particular 

21 application by different parties will give -- will 

22 give different predictions of concentration. 

23 So I think that's going to happen, and you're 

24 going to have to deal with that situation. 

25 And then, as has already been said, of course, 
 1 Panel/Foreign Development/D. Carruthers Vol. 2, p. 135 

 2 these are differences that are purely illustrative 

 3 of the uncertainty that exists in this whole area, 

 4 and that's been quite a lot said; it's just another 

 5 manifestation of that. 

 6 And could I have the next slide, please? 

 7 (Projecting slide.) 

 8 And then this is the -- quite a brief slide. 

 9 There was that question about what criteria 

10 the model developer should sort of fit, I wasn't 

11 quite sure what was said specifically, and we've 

12 got that message, so I won't say any more about 

13 that. 

14 And then the basis for determining acceptable 

15 model, well, I think so sort of threshold criteria, 

16 plus resident criteria does seem to lie forward as 

17 -- as this gentleman was saying. 

18 And I just wanted to stress again, I think in 

19 all these evaluations, it's important to have full 

20 disclosure of all relevant information, and that's 

21 really -- really comes back to what I said 

22 earlier. 

23 I think a statistical evaluation is, of 

24 course, is very important, but other aspects of it 

25 should not be ignored. 
 1 Panel/Model Comparison/Ken Steinberg Vol. 2, p. 136 

 2 And that's all I want to say. 

 3 Thank you. 

 4 TYLER FOX: Thank you. 

 5 Next is Ken Steinberg. 

 6 KEN STEINBERG: Well, the perspective, again, I guess I can 

 

 7 bring, is perspective from a -- from a user point of view. 

 8 While I was working with Exxon/Mobil, the 

 9 organization I was part of at Exxon, the research 

10 and engineering company, provided service 

11 worldwide, so as a result we were exposed, many 

12 times, to the -- to the problem of a air pollution 

13 concern, -- 

14 TYLER FOX: Ken, can you get closer to the mic? 

15 KEN STEINBERG: -- to an air pollution concern, where the 

16 regulatory agency put the burden on the company to 

17 select the model. 

18 In other cases, the regulatory agency had 

19 their own ideas about a model, and sometimes it 

20 might be a U.S. model, and sometimes it might be a 

21 model from Europe or somewhere else. 

22 It became quite interesting, because we would 

23 get an experience base with the various models, and 

24 as a result we would have various comparisons, that 

25 would give us a mixed feeling about whether we were 
 1 Panel/Model Comparison/Ken Steinberg Vol. 2, p. 137 

 2 using, in a particular regulatory format, the best 

 3 model. 

 4 Quite often, it became a rather 

 5 expedient-driven issue from the standpoint of the 

 6 company to resolve whatever the problem was. So 

 7 even if, and I'm thinking of a specific example in 

 8 Canada, where we were initially asked to use ISC 

 9 where there was some complex terrain, and there was 

10 a potential of a noncompliance in trying to explain 

11 some high concentrations, and, of course, ISC was 

12 attributing very high concentrations to our sources 

13 which nobody really believed. 

14 We then applied ADMS, and we found that the 

15 concentrations that were predicted were far closer 

16 to the observed concentrations, which perhaps may 

17 be fortuitous and for the wrong reasons, but we 

18 kind of got warm and fuzzy about that, because the 

19 wind fields that were being used in the model 

20 seemed to be more characteristic of what you would 

21 expect in a complex terrain situation. 

22 And then finally we ended up using AERMOD just 

23 because the regulator heard that EPA was moving in 

24 that direction, the concentrations changed off of 

25 unreasonably high values, but didn't really improve 
 1 Panel/Model Comparison/Ken Steinberg Vol. 2, p. 138 

 2 our ability to predict the circumstances very well, 

 3 but it satisfied the regulatory issue, and from 

 4 the company's standpoint, the answer was 

 5 essentially the same whether we used ADMS or 

 6 AERMOD, and so the customer was happy, and we were 

 7 done. But I -- I kind of started getting into this 

 8 area of, well, how good is ADMS and how does it 

 9 compare to AERMOD? 

10 And so Steve Hanna did a study for API that 

11 compared ISC, AERMOD, and ADMS. And I won't go 

12 through all the boring statistics, but basically 

13 the -- a very similar procedure that was used that 

14 was described that EPA's protocol for evaluating 

15 models came away with a conclusion where we looked 

16 at five different data sets, some area source, the 

17 volume source, which are kind of unique, and other 

18 tall stack, Kincaid and some others, that are 

19 popular who -- use. 

20 And lo and behold, ADMS outperformed all of 

21 the other models, the majority of the time, while 

22 AERMOD was significantly improved over ISC, there 

23 was certainly a preference in performance that 

24 appeared to move into ADMS. So my -- my question 

25 at the time was, why can't I use that model. 
 1 Panel/Model Comparison/Ken Steinberg Vol. 2, p. 139 

 2 If I can use it in Europe and I can use it in 

 3 the far east and South America, why can't I use it 

 4 in the United States? 

 5 So we brought it up and discussed it with some 

 6 people at OAQPS, and David followed up, and it 

 7 seems from my perspective to have boiled down to, 

 8 not a matter of any of the issues other than this 

 9 proprietary concern. 

10 And from my perspective, I don't understand 

11 it. I -- I know that in common usage is Windows, 

12 and I'm sure there is a lot of proprietary 

13 technology in Windows, but we all accept it, we 

14 use it, and we are quite pleased with its 

15 performance. 

16 We have measures of what we put into it and 

17 what comes out it to test whether it's functioning, 

18 and that there isn't a, you know, the Wizard of Oz 

19 behind the curtain doing something funny, and 

20 spurious (chuckles from audience), so we're quite 

21 pleased with it. 

22 And so from my perspective, as a user, if I 

23 have an application where I can demonstrate that -- 

24 and have demonstrated that AERMOD or ADMS is 

25 appropriate, I should be able to use it without 
 1 Panel/State Perspective/Ken McBee Vol. 2, p. 140 

 2 going through a particularly onerous process, 

 3 because in the world out there where we are 

 4 struggling to make profits and, you know, delay in 

 5 time can be extremely expensive to a -- to a 

 6 particular project at a refinery or permitting, or 

 7 not permitting a project. 

 8 And in some cases the margins for projects 

 9 going forward are very close, and so I -- my -- my 

10 perspective is that I would like to see qualified 

11 models being made available, and the idea of a 

12 single model that can only be used until -- because 

13 we believe it tells the truth, I think is foolish, 

14 and I kind of agree with some of the other comments 

15 that have been made, I won't repeat them but that's 

16 my perspective. 

17 TYLER FOX: Thank you. 

18 Ken McBee. 

19 KEN McBEE: Good morning. Ken -- my name is Ken McBee, 

20 Virginia Department of Environmental Quality. 

21 I must say that when we started this process 

22 earlier this summer, we started the cause about 

23 futures in modeling, and I must say that my first 

24 thoughts was, "if the ain't broke...", what are we 

25 doing here, why should we fix something that we -- 
 1 Panel/State Perspective/Ken McBee Vol. 2, p. 141 

 2 we don't need to, but I'd like to think that I am 

 3 more open about that sort of thing. 

 4 And we do welcome -- we welcome science being 

 5 changed and improvements to science. But we always 

 6 have to look on the state side of the things, as -- 

 7 when you're talking about regulatory, we have to go 

 8 by an EPA-approved model that is set up in our 

 9 regulations that we need to follow, and we use the 

10 results as they come out of those models and move 

11 forward with them. 

12 I will say, though, that with AERMOD, even 

13 though there has been a lot of harangue over time, 

14 in anticipation of it being promulgated, we in 

15 Virginia started sometime ago, I don't know, five 

16 or six years ago, getting trained. Thankfully we 

17 had -- or fortunately we had Al Cimorelli, at 

18 Region III, who was on the AERMIC committee, and he 

19 started training folks in that region or series of 

20 states. 

21 And we had -- we had several training courses, 

22 and we early on in Virginia decided we're going -- 

23 we're going to go with AERMOD, and we've been going 

24 with it for the last five years. 

25 We have recommended use, of course, we've 
 1 Panel/State Perspective/Ken McBee Vol. 2, p. 142 

 2 learned -- we've learned about parameters over 

 3 time, and I'm also on the Committee where we're 

 4 working on the -- to come up with some guidance on 

 5 -- on how we should do AERMOD. 

 6 But we've stepped forward and went ahead and 

 7 went with AERMOD, and I -- I request -- I recommend 

 8 that people use it for the different PSD projects 

 9 we've had and some other projects. 

10 And it worked out fine. 

11 All I've got -- the only thing I have to do in 

12 the State of Virginia is write a letter to -- well, 

13 it comes from our area director to the regional 

14 administrator at EPA which really goes to Debbie 

15 Lowman then, our regional modeler who will just -- 

16 I make the request to use AERMOD in a particular 

17 case, and they approve it. 

18 And we both realize that the science is the 

19 best thing that we should be going with right now, 

20 and that what we have is the best model, and we 

21 just -- we go that direction and, of course, we 

22 still have people who use ISC and ISC-PRIME, and we 

23 can't really prevent that, but I do recommend the 

24 use of AERMOD. 

25 But when we first started talking about the 
 1 Panel/State Perspective/Ken McBee Vol. 2, p. 143 

 2 possibility of other models of -- it was brought up 

 3 a while ago the training situations just what we -- 

 4 how -- how different AERMOD was from ISC was such a 

 5 -- you know -- it looks like ISC, but that's about 

 6 as far as it goes. 

 7 From there on you need to learn new terms like 

 8 boundary layers and all, you know, the surface 

 9 characteristics and get all that straight on how 

10 you get the parameters right for the model. 

11 And if we have another model that's just as 

12 good as AERMOD, we'll have to learn that model, 

13 we'll have to be trained on that model, learn its 

14 idiosyncrasies, and I think it puts a lot on the 

15 states to have to know how to work all those 

16 models, and to be able to use them from a 

17 regulatory approach. 

18 And we have a lot -- we have a lot of 

19 priorities set upon us in the states to be 

20 efficient in permitting -- in the permitting 

21 process, and I don't think we could be very 

22 efficient if we have to look at a lot of different 

23 models and decide one over the other. 

24 So, I guess we, you know, overall we still 

25 preferred model first, though we are, like I said, 
 1 Panel/State Perspective/Ken McBee Vol. 2, p. 144 

 2 we like to see new science and we'll work with EPA 

 3 in that process. 

 4 I know over time, there's been a lot of -- a 

 5 lot of states out there actually haven't even 

 6 started AERMOD, and they are waiting for the 

 7 promulgation which, I think, is not thinking out of 

 8 the box or looking toward the future. We need to 

 9 move ahead with what we've got. 

10 I think from the State of Virginia, we would 

11 wel- -- we would welcome to look at other models, 

12 but we also, you know, put the caveat on there that 

13 we need -- we'll need a lot of time to get -- you 

14 know, the learning curve on each model is quite 

15 different, and with the AERMOD that really comes 

16 out in -- I mean it took -- we've had several 

17 training sessions, and then we still are learning 

18 how to use it and how to set the parameters up 

19 correctly, and there is a lot of discussion still 

20 going on along those lines. 

21 So -- that's about all I have to say about 

22 that. 

23 TYLER FOX: Thank you, Ken. 

24 Chris Arrington from West Virginia. 

25 CHRIS ARRINGTON: Hello! As you stated, I'm Chris Arrington 
 1 Panel/State Perspective/Chris Arrington Vol. 2, p. 145 

 2 from the West Virginia Division of Environmental 

 3 Protection. Like Ken, my perspective comes from 

 4 the state regulatory focus. 

 5 We don't do much model development. We're 

 6 much more down in the trenches, get your hands 

 7 dirty, you know, you use these models to actually 

 8 get these permits out, day in and day out. 

 9 And as Ken said, when you're doing it from 

10 that point of view, you don't have some of the 

11 luxuries as you do from looking at more of a 

12 scientific viewpoint. 

13 That said, West Virginia does believe in 

14 adopting the new technology, new models and new 

15 approaches. We're one of the early adoptees of 

16 both CALPUFF and AERMOD -- 

17 WARREN PETERS: (Interposing) Ken, excuse me, would you move 

18 that microphone a little closer? 

19 CHRIS ARRINGTON: Sorry, Warren. I didn't want to blow 

20 everybody out. 

21 We were one of the early adoptees of both 

22 AERMOD and CALPUFF, and that's been quite 

23 beneficial for our state in addressing some of the 

24 problems that we've had, especially in complex 

25 terrain and complex flow situations. 
 1 Panel/State Perspective/Chris Arrington Vol. 2, p. 146 

 2 The old tools just didn't do the job, to be 

 3 honest, on some of our projects. So we were kind 

 4 of forced into adopting the new technology, but 

 5 we've found it's beneficial. It does take a lot of 

 6 work to keep up and change over to the new models, 

 7 but we are for that. 

 8 However, I would say that we want to urge 

 9 caution, when we start looking enlarged new models, 

10 both the training requirements, Ken said can be 

11 tough, in getting people trained and familiar with 

12 the use. 

13 Sorry, I lost my train of thought there. One 

14 of those days! But then overall, we are for that. 

15 I think the current process and procedures right 

16 now are somewhat cumbersome, has stifled probably 

17 some good development in the introduction of new 

18 models and techniques. So some of the ideas that 

19 John Irwin has sounds quite interesting to us, and 

20 we think maybe some of those procedures should be 

21 followed, working out some of the ideas and see how 

22 it goes. 

23 We do think that the preferred model approach, 

24 or having a preferred model, is a good idea. That 

25 way you do have one model that you feel comfortable 
 1 Panel/State Perspective/Chris Arrington Vol. 2, p. 147 

 2 with that has been widely reviewed and used, and 

 3 you know what it's going to do. 

 4 So having a preferred model is good, but 

 5 having options that are out there is also good to 

 6 address specific problems or specific situations. 

 7 Let's see, I guess the last comment I would 

 8 really have the -- because Ken has covered most of 

 9 these issues pretty well, but the last comment I 

10 would have is the concern over there being multiple 

11 approved models for multiple situations. 

12 If you live in flatland state where you're 

13 using ISC all the time, you know, that's never been 

14 an issue. If you used ISC, you used ISC. 

15 Well, in the complex terrain world that we've 

16 commonly had to address, there are more than one 

17 model, and we do have to go out there and figure 

18 out which model is the best model to use, and we 

19 typically, you know, have industries coming and 

20 choose between the models and propose to us which 

21 one they want to use. 

22 I mean, you're looking at right now; there's 

23 CALPUFF, AERMOD, ISC3, CT screen, you know, IGM 

24 used to be used frequently in our state. RTEM, 

25 complex one Complex I. So I don't think it's a big issue. I 
 1 Audience Questions/Comments Vol. 2, p. 148 

 2 think we can through having different models, but 

 3 you need people who are familiar with those models 

 4 and know how to apply them, and know which is the 

 5 best model to use in that case. 

 6 I don't think it's so much of an issue. 

 7 So, I guess my final words would be to urge 

 8 the adoptions of the new approaches to the adoption 

 9 of models themselves. 

10 There is lots of good science technology out 

11 there. We'd like to see it used. Let's, you know, 

12 find a balance. Let's not open it up so easily 

13 that all of a sudden you have fifteen, sixteen 

14 models out there that every time you do a project 

15 you're seeing an entirely new model and an entirely 

16 new procedure to be used. That's it. 

17 TYLER FOX: Thank you, Chris. 

18 All right, at this time, I want to thank all 

19 the panelists for their discussion and open it up 

20 to the audience for question and answer period. 

21 Where is that mic? 

22 GALE HOFFNAGLE: I guess I have two comments; one -- one is 

23 your processing job, John, -- this is Gale 

24 Hoffnagle from TRC. 

25 The process that you outlined does not allow, 
 1 Audience Questions/Comments Vol. 2, p. 149 

 2 or did not allow, what I would call public input. 

 3 You had peer review input, but not public input to 

 4 that process. 

 5 What we have now and with the adoption of 

 6 CALPUFF or AERMOD, is a public input process. 

 7 So, I would think that would have to be 

 8 included some -- someplace in this process. 

 9 Okay. 

10 The second comment is just from the point of 

11 view of multiple models and multiple ideas, the EPA 

12 regulatory world has another place in which models 

13 are used, and that is in the risk management 

14 planning program. 

15 And, of course, the office of solid waste, 

16 chemical emergency preparedness and prevention 

17 office, its response generally to "I want to use 

18 this model", or another model, or some other model 

19 or some other model, was, use your best judgment. 

20 So it left it up to the risk management 

21 planner, shall we say, what model to use. 

22 Now, that's -- that may be going way too far 

23 from the way we have been on this side, but it is a 

24 completely different way of looking at the model 

25 problem, which is having the applicant pick which 
 1 Audience Questions/Comments Vol. 2, p. 150 

 2 models to use, and using their best judgment, in 

 3 which case chemical emergency, preparedness and 

 4 prevention office has to understand all the models 

 5 and what they are -- what their good points and bad 

 6 points are. 

 7 But that covers the question of which is the 

 8 right model for this particular application. Right 

 9 now we have one model that has to cover all 

10 applications. 

11 And as -- as Ken Steinberg has pointed out, 

12 the models we have just aren't really well compared 

13 to area sources, volume sources, line sources, et 

14 cetera, et cetera, et cetera. 

15 So it's clear that even AERMOD and CALPUFF 

16 aren't well designed necessarily when compared 

17 against sets of sources that we have to model every 

18 day. 

19 So best judgment, in my opinion, and on -- are 

20 on a case-by-case basis is still an extremely 

21 important way that we are to do modeling. 

22 TYLER FOX: Any other comments, questions? 

23 John Irwin. 

24 Al Cimorelli. 

25 AL CIMORELLI: I have a few. 
 1 Audience Questions/Comments Vol. 2, p. 151 

 2 (Chuckles from audience.) 

 3 Just a couple. 

 4 I guess -- I guess the first one has to do 

 5 with this business of different answers having -- 

 6 not having preferred models, but having sort of 

 7 John Irwin's world. 

 8 I think it is a -- I think it is a great idea, 

 9 but I -- I have to get the right adjective for 

10 this. I think -- I think it might work in the 

11 twenty-third century, (laughter), or even in the 

12 twenty-fourth century, or sometime down the road. 

13 I think one of the major problems associated with 

14 it is the fact that I think we can all agree that 

15 you can have a variety of models that pass these 

16 cri- -- these performance standards, and then you 

17 end up with a lot of different answers for the same 

18 particular application. 

19 And I think that's actually a pretty good 

20 estimate of what the uncertainty might be about the 

21 predictions. It could be. 

22 You know, if you have a lot of models or a lot 

23 of different ways of looking at the same problems, 

24 and so on. 

25 So now you're dealing with the question of 
 1 Audience Questions/Comments Vol. 2, p. 152 

 2 uncertainty. Once you don't have a best estimate, 

 3 now you have to get the decision makers to deal 

 4 with not having a best estimate. I think that 

 5 would be terrific, because I don't think decisions 

 6 are made by science, and I don't think they should 

 7 be made by science. I think science informs 

 8 decisions and should only inform decisions. 

 9 What that that means is is that within the 

10 uncertainty bounds of your decision, if the 

11 application at one end costs you a million, and at 

12 the other end costs you a billion, then you have to 

13 figure out what are the criteria are we going to 

14 use? 

15 And so you're talking about an entirely 

16 different paradigm. 

17 There was -- I was at a, and I think you may 

18 even have been -- some people may have been there. 

19 We -- we had a conference on uncertainty years and 

20 years ago. It was called the Early House 

21 Conference, and a whole host of people came to this 

22 conference, and we tried to talk, and we talked and 

23 we talked about what kind of -- how to deal with 

24 uncertainty. 

25 Of course, decision makers at the end of this 
 1 Audience Questions/Comments Vol. 2, p. 153 

 2 said, I just want a best estimate. But there was 

 3 -- but there was -- there was a fellow by, and I 

 4 can't remember his first name, his last name is 

 5 Ayers, and he was the head of the Sierra Club, I 

 6 think -- 

 7 FROM THE AUDIENCE: Richard Ayers. 

 8 AL CIMORELLI: -- Richard Ayers, right, at the time, and he 

 9 said something that stuck with me a long time. 

10 And he says, look, good company policy is 

11 really, getting to agree to agree. You're not only 

12 always going to get the right answers, but you've 

13 got to at least agree to agree. 

14 And I think that to some extent that's really 

15 where we are. Until we can change that paradigm, I 

16 honestly don't see how we're going to implement a 

17 regulatory program like this. 

18 I might give you a propar- -- you know -- a 

19 risk proprietary program. I think that's a little 

20 different, because you may have a new -- you know 

21 -- a new oil refinery coming into the Gulf Coast, 

22 and it's one local agency who's reviewing it, when 

23 you have an oil company with billions of dollars 

24 interest behind it, and you've got -- it's going to 

25 be a very difficult situation. 
 1 Audience Questions/Comments Vol. 2, p. 154 

 2 So, that's, I guess, my point with regards to 

 3 that. 

 4 Secondly, if you have a lot of new models 

 5 coming in, it's not enough to simply say that this 

 6 model passes the standard. As we've learned with 

 7 lots of models, equally, if not more important, is, 

 8 is this thing being applied right? 

 9 Can you apply this thing correctly? 

10 The only way to answer that question is going 

11 to be for the reviewing authority to understand 

12 how that model really works and in what 

13 circumstances, and so in order for them to say, 

14 yeah, you got the right data, no, you don't have 

15 the right data. 

16 You know, I -- I look at a lot of the work 

17 that's been done by -- by David Carruthers, and -- 

18 you know -- ADMS is a great model, and I think 

19 that, you know, there're applications where I'm 

20 sure it does far better than AERMOD, and there 

21 are -- there're circumstances where AERMOD does 

22 far better than -- than ADMS as well, and other 

23 models. 

24 Of course, that's the situation. The question 

25 is, how do we handle this system? 
 1 Audience Questions/Comments Vol. 2, p. 155 

 2 My opinion is, is you've got to have a 

 3 baseline preferred model for a system where you 

 4 have lots of different kinds of people with lots of 

 5 different experience running the thing. 

 6 But maybe where we can go to is a situation 

 7 when we look at how to approve alternative models. 

 8 We should not be in a situation where in any 

 9 given specific case, somebody's forced to use 

10 AERMOD when there is -- when there is a 

11 preponderance of evidence which would indicate that 

12 XYZ model is better for that application. In that 

13 area I think we've got plenty of latitude, and 

14 that's something that we actually should look at. 

15 My -- and I would add to all of this that 

16 model development, when people start building model 

17 models, and you allow them to just pass a standard, 

18 unless you've got an enormously comprehensive 

19 database, you're going to have people building 

20 their models to the database. You know they're 

21 going to do that, and you know we are in an 

22 advocacy situation. 

23 People aren't building models for no reason. 

24 They are building models to get permits through in 

25 this world, and so they're going to look at the 
 1 Audience Questions/Comments Vol. 2, p. 156 

 2 database, and they're going to say, what do I need 

 3 to do to tweak this model to get it to the pass 

 4 this thing to get me a lower number so I don't have 

 5 to put as much control on it. 

 6 I think that's just a fact of reality. And 

 7 the only way to prevent that is to have an 

 8 extraordinarily complex set of databases, and we 

 9 have already heard, there is no data out there. I 

10 mean, we don't have that kind of data. 

11 I mean, if we had the data for the -- for the 

12 area sources and the volume sources and so on, we 

13 would have looked at it. 

14 We don't have it. If we get it, then we 

15 should use it. So, I think we need to have a 

16 preferred model system. We need to have a way of 

17 getting a better model through the system. 

18 I mean, AERMOD is -- you know -- there's no 

19 reason why AERMOD has to be the preferred model, if 

20 there is another model that should take over its 

21 place, that model should be brought through. 

22 Final comment I'll make is about proprietary; 

23 the proprietariness of models. 

24 I really do appreciate the concept of -- of 

25 needing a proprietary model, but I guess in the 
 1 Audience Questions/Comments Vol. 2, p. 157 

 2 public sector, if I were in the public, and I -- 

 3 and I -- and I didn't like the results of a model, 

 4 I might want as to see what's going on inside that 

 5 model. 

 6 That's different than Windows. That is 

 7 different than Windows. You're -- we're making 

 8 decisions about how much control to put on a plant 

 9 and about people's health, and I think that it is 

10 our responsibility, as public officials, to provide 

11 to the -- to people, and we have to provide to 

12 people all of what went into our decision making 

13 especially a model. 

14 If you can get past that, the next question is 

15 who's going to make the changes? What if you have 

16 to make a change? You have to go to that whoever 

17 owns that model; we don't -- we can't touch the 

18 Code, nobody else can touch the Code; only that 

19 person can make the change. 

20 What happens if that private firm goes out of 

21 business? Now, where are we? Do we all of a 

22 sudden then pick up the Code? So, I guess I'll -- 

23 I will stop there and let other people talk. 

24 JESSE Thé: This is Jesse Thé, with Lakes Environmental. 

25 I'm proposing something that may satisfy 
 1 Audience Questions/Comments Vol. 2, p. 158 

 2 everybody. It's like -- I understand it's very 

 3 hard to move from model-to-model to model and then 

 4 have this continuous stream of learning what the 

 5 models do. 

 6 And I proposing something that would not be 

 7 twenty-third century. It would be twenty-first 

 8 century. 

 9 I find it very opportune that we have the 

10 internet; I find it very opportune that we use the 

11 same model, but it's very hard to even get the 

12 preferred models and modify them to work better. 

13 I'll give you an example: I don't see -- this is 

14 my personal view -- any need to go in and create a 

15 better plume model. 

16 We are almost at the edge of all that plume 

17 models can do. There is not much we can do because 

18 it's a limitation, it's a straight line model. We 

19 can't do much with it. 

20 So the next model then would be something like 

21 a puff model, which is also intermediate before we 

22 have enough processing power to use the rigid 

23 tracer models. 

24 We can have then would be, in this process 

25 that John was talking about, we could have a 
 1 Audience Questions/Comments Vol. 2, p. 159 

 2 process where the public would have input to 

 3 improve these models, and this model that the state 

 4 regulators wouldn't have to relearn for the public 

 5 would be bringing modifications. 

 6 And there are examples, for example, it's the 

 7 case of CALPUFF. We modified CALPUFF to put to the 

 8 public, to run parallel mode, for CALMET and for 

 9 CALPUFF itself. 

10 We submitted these changes to Earth Tech, and 

11 this was two years ago. Nobody even mentioned a 

12 lot of us need to run CALMET in a single computer 

13 for months on end, and there are projects that we 

14 cannot even run, because it can't go parallel. 

15 And when we go to CALPUFF, we have the same 

16 situation. 

17 This example is not to comment and complain 

18 about the specific case; it's to describe that we 

19 don't have processes in place to transform, for 

20 example, CALPUFF model which is a preferred model 

21 into something that would run on the second for 

22 older models, for minutes; it must run under hour, 

23 and we don't have a lot of processors in place 

24 where the public can bring input. 

25 We are in a open source time where we could 
 1 Audience Questions/Comments Vol. 2, p. 160 

 2 use these mechanisms, and people like us and like a 

 3 lot of people here, could provide input and have it 

 4 done through a process that would be faster and 

 5 more responsive. 

 6 And we wouldn't have to have anybody 

 7 retraining CALPUFF. Let's say it's -- we come up 

 8 with a conclusion that the bare model would be, 

 9 theoretical would be, a [tracer? LaGrangian? stochastic? ] 

particle model 

10 which would be like a definite step that we would 

11 need to take. 

12 We have Hysplit IV, which everybody could 

13 contribute, put everything in place and once you 

14 learn that one, it would work for a very, very wide 

15 area of applications. 

16 Again this is not providing you the definite 

17 answer for all the problems, but it would satisfy 

18 everybody's needs here that we see improving the 

19 models, and it's going slow. So instead of going 

20 to the idea which John described very well, we go 

21 to an intermediate stage where we would have some 

22 preferred -- and somebody could with EPA provide 

23 the guidance, saying we will be coordinated with 

24 the holders of the approval, and we would like to 

25 have a [LaGrangian?] particle model, it will -- we'll be 
 1 Audience Questions/Comments Vol. 2, p. 161 

 2 using that and here are the guidance, let's 

 3 everybody work towards that. 

 4 How can we improve a puff model, and forget 

 5 about the plume. Plumes are ideal for permitting 

 6 for series of applications, and if we spend too 

 7 much time on that, it's -- it's not leading towards 

 8 a more general precise model. So that's my two 

 9 cents on this. 

10 RUSSELL LEE: I'm Russ Lee with R. F. Lee Consulting. 

11 I just wanted to address a comment on this 

12 proprietary issue. 

13 There are several things and not just one 

14 hidden under the word "proprietary". The idea at 

15 the beginning, as I understand it, was that the 

16 Code of these programs with -- EPA would want to 

17 have the Code of any programs that it used in its 

18 regulatory process to be open to public view. And, 

19 generally, people don't like their proprietary 

20 programs open to public view. 

21 However, there is no reason they cannot do 

22 this and still retain copyright protection to the 

23 program, and to allow whatever is permitted under 

24 the copyright laws to allow its sufficient 

25 visibility and sufficient use by EPA and by -- by 
 1 Audience Questions/Comments Vol. 2, p. 162 

 2 model users as a part of the conditions. 

 3 Now, I'm certainly no expert at copyright law, 

 4 but I think at some point it would behoove us to 

 5 talk to -- to -- someone needs to talk to a 

 6 copyright attorney, lay out the whole issue, lay 

 7 out the problems. 

 8 After all we can pick up a book and that's 

 9 copyright; they've got all kinds of -- you know -- 

10 protection there, but every word is available and 

11 open to the public. 

12 I don't know that we need to ask people to 

13 give up their copyright rights to the Code, and I 

14 don't think that everybody is going to be unhappy 

15 about if they retained the copyright of letting the 

16 Code have public view in the context of the 

17 modeling -- EPA modeling the way it's commonly 

18 done. 

19 So I think we -- we've inadvertently taken 

20 this proprietariness of the Code as a package and 

21 assumed is that it would have to be all given up, 

22 when all people would need to do would be to give 

23 up a part of it. 

24 KEN STEINBERG: Can I say something about this proprietary 

25 issue? 
 1 Audience Questions/Comments Vol. 2, p. 163 

 2 It's quite common -- 

 3 WARREN PETERS: Can you identify yourself? 

 4 KEN STEINBERG: Ken Steinberg, representing API. 

 5 It's quite common in industry for technology 

 6 be made available to competitors, and it's always 

 7 made available -- the vast majority of process 

 8 technology, for example, is what I'm speaking of, 

 9 in a proprietary format. 

10 That allows the competitor to use the 

11 technology, and for a royalty to be provided to the 

12 developer of the royalty. Okay? 

13 It also is quite common for anyone who wants 

14 to evaluate that technology, as a potential someone 

15 who wants to license it, to ret- -- to retain 

16 confidentiality agreements to -- to look at the 

17 technology in -- in its detail. 

18 All they have to do is to make sure that they 

19 sign that they will essentially, for a period of 

20 time, never use it, divulge it. 

21 And so there are ways of dealing with 

22 proprietary technology that are done routinely, and 

23 I don't quite understand, I guess, EPA's need to 

24 have all Code in the public domain. 

25 The vast majority of model users never look at 
 1 Audience Questions/Comments Vol. 2, p. 164 

 2 the Code, never. They look at the inputs and the 

 3 outputs to see whether to see whether the inputs 

 4 and the outputs make sense. 

 5 If there is ever a question about inputs and 

 6 outputs making sense that requires an investigation 

 7 into the Code -- a -- even a proprietary code, that 

 8 can be carried by EPA, as long as there is a 

 9 confidentiality agreement, and if that information 

10 were to ever be taken to Court, I'm sure the Courts 

11 have access to information that's proprietary if 

12 there is a concern about something being done less 

13 than on the up and up. 

14 So I don't quite understand why a proprietary 

15 code isn't acceptable in -- in this modeling 

16 regime. I really, really don't. 

17 If a consultant is very interested to know, a 

18 competitor of someone who develops a proprietary 

19 code, and they want to find out what's going on, 

20 they can sign a confidentiality agreement and get 

21 access to it for their particular purpose. 

22 It's done all the time! And it seems to work 

 ___ 

23 quite efficiently and effectively. 

24 So that's my comment on that. 

25 But while I have the phone, I won't get to 
 1 Audience Questions/Comments Vol. 2, p. 165 

 2 actually -- or the phone, the microphone, 

 3 (laughter), I have two other -- two other points on 

 4 this alternate model point that was mentioned. 

 5 I just want to emphasize, I think alternate 

 6 models is a fine approach; just lower the 

 7 threshold, make it easier. It may well be that you 

 8 can pre-certify alternate models for certain 

 9 applications, so that an applicant can easily 

10 select that model. 

11 Unfortunately it may create additional burden 

12 on the States, and others, who have to get up to 

13 speed on how it's used, but if they are essentially 

14 looking at a permit for a refinery that's maybe a 

15 hundred million dollars ($100,000,000) or -- just 

16 for the permitting, I suspect that there will be 

17 resources available to allow that education 

18 process. That -- that I don't anticipate being an 

19 impediment to using the model. 

20 The -- the -- the other point that I -- I 

21 don't want this record to stand without having a 

22 rebuttal. 

23 Contrary to what may have been intended, 

24 people have to realize that at least responsible 

25 industry is no happier with concentrations that are 
 1 Audience Questions/Comments Vol. 2, p. 166 

 2 low than they are with concentrations that are too 

 3 high. And I'll tell you why. 

 4 Concentrations that are too low will avoid 

 5 putting control technology, albeit it expensive, 

 6 into a process, but monitoring that is carried out 

 7 after the project starts, will conclusively tell 

 8 the tale if there are exceedances, that control 

 9 equipment will be then retrofitted, and I assure 

10 you that the retrofit costs will be ten to twenty 

11 times the initial cost of installing that control 

12 equipment, and there is no refiner in this country 

13 that wants to retrofit control technology at these 

14 ridiculous costs. 

15 So they do not want models that under predict. 

16 They do not want answers just to get a piece of 

17 paper. That's foolishness! So that was my other 

18 point. 

19 YOUSHENG ZENG: This is Yousheng Zeng with Providence 

20 Engineering. 

21 I have two comments; one is -- relates to John 

22 Irwin's approach. I'm comparing this modeling 

23 acceptance with some other EPA approach. 

24 Specifically, EPA developed very impressive 

25 model of data quality objective model dealing with 
 1 Audience Questions/Comments Vol. 2, p. 167 

 2 ambient monitoring in that it establishes the -- 

 3 basically the model recognized, there is a lot of 

 4 uncertainty in dealing with atmospheric 

 5 conditions. 

 6 So nothing is absolutely certain, even if you 

 7 have actual monitor there, there is a lot of 

 8 variation. So that model take into consideration 

 9 of that uncertainty and develop a gray zone. So 

10 acceptance is not, you know, clear-cut, one value. 

11 It's a range of value. And I think we are -- here 

12 we have a model, we -- everybody understand that a 

13 model does not predict exact value, but then in a 

14 regulatory process, everybody treat -- or 

15 regulatory agency that that as a -- as if that's 

16 the true value, and they give permit or not give a 

17 permit. 

18 I think that approaches fundamentally -- there 

19 is a fundamental problem approach with that 

20 approach. 

21 And the concept of developing a gray zone, 

22 that will have certain -- actually that gray is 

23 designed to cover up those uncertainty, and also 

24 evaluate what will be the consequence if a wrong 

25 decision is made. 
 1 Audience Questions/Comments Vol. 2, p. 168 

 2 I think that model is -- that concept -- I'm 

 3 not saying that model can be directly used for the 

 4 modeling type of situation, but that concept, I 

 5 think, is very important. 

 6 And if we can use something similar -- develop 

 7 a tool similar to that, and then that -- what John 

 8 proposed that performance-based criteria can be 

 9 more systematically implemented. Hopefully that 

10 will be not like a twenty-third century or 

11 something like that. 

12 I think that model -- EPA -- I mean it's 

13 within the same agency, so I think a different 

14 branch of EPA is doing different things. I think 

15 that will be really good to look into that 

16 approach. 

17 Similarly -- I mean, modeling is similar to 

18 monitoring; one is measuring, one is predicting it 

19 -- and on the monitoring side, the people already 

20 recognize the uncertainty on the modeling side -- 

21 everybody on the standards knows there's 

22 uncertainty, but everybody treats them as there is 

23 only one value. That's -- really should not be the 

24 case. 

25 Second, is a minor comment about a previous 
 1 Audience Questions/Comments Vol. 2, p. 169 

 2 comment about that performance-based process will 

 3 now go -- the lack of public participation will be 

 4 a problem. 

 5 I think that can be resolved because you can 

 6 public -- you can comment on the procedures, just 

 7 kind of similar to Title Five (V) permitting 

 8 process, you can comment on the general permit, and 

 9 then once you fit that model, then it's okay. 

10 So the permitting public is integrated 

11 into the earlier stage, but not necessarily in the 

12 specific cases. 

13 Those are my two comments. 

14 LOUIS MILITANA: Lu Militana with AAQS. 

15 We've talked and heard a lot about the 

16 uncertainty of models and how the regulatory 

17 community uses the maximum or high -- second 

18 highest values to demonstrate compliance with the 

19 NAAQS. 

20 I think we need to realize these uncertainties 

21 in how the NAAQSs are established. Those are not 

22 absolute values. Everybody knows about risk 

23 assessment. They know how those values are -- are 

24 established. 

25 We need to continue -- we've seen some 
 1 Audience Questions/Comments Vol. 2, p. 170 

 2 improvements on how to define compliance with those 

 3 standards in terms of PM-10, as opposed to the 

 4 high, second highest values for SO2. I think we 

 5 need to -- EPA needs to push in the further 

 6 redevelopment and revisiting every time they go to 

 7 -- to review of the National Air Quality standards 

 8 in the criteria documents to redefine how those -- 

 9 how the NAAQSs are complied with so they can better 

10 match the uncertainty of the models with the 

11 uncertainty of the NAAQS standards. 

12 NAGESH: Hello, everyone. I'm Nagesh, representing 

13 [Maricopa Association of] Governments. I am interested in this 

14 regular modeling or this special modeling, though I 

15 have experience with CMAC (cough), and 

16 handling smoke. 

17 And we are very much concerned about the 

18 evaluation and the model and permitting. I have a 

19 . 

20 Is there a need kind of rule in AERMOD or ISC 

21 that gives like a specific scenario if you are 

22 processing, it give that, how the model 

23 is calculating the data, starting from how we mix 

24 the emission input, how we take the chemical input, 

25 how we take the chemistry input, and do this 
 1 Audience Questions/Comments Vol. 2, p. 171 

 2 step-by-step analysis, and use the , 

 3 so that one can say that whether the model is under 

 4 predicting or over predicting. 

 5 If not, why is over predicting so we can be 

 6 able to enlighten like the model whether 

 7 it's meteorological concept going on or the 

 8 chemistry aspect, or actually the . 

 9 So do we have any kind of developmental aspect 

10 of the evaluation tool that is going to present in 

11 the near future of the -- please how it presents? 

12 So, I guess that's it. Thank you. 

13 TYLER FOX: Tyler Fox, EPA. At present I'm not aware, Roger 

14 or somebody can correct me, a more diagnostic 

15 specific-type evaluation tools with respect to 

16 AERMOD. 

17 I -- I know that there are evaluations done to 

18 incrementally look at things to try to identify 

19 those -- those things, but --. 

20 WARREN PETERS: This is Warren Peters. We do have some 

21 debug tools in there that provide interim results. 

22 You can go back and check to see -- you know -- if 

23 you're getting some of the basic parameters correct 

24 here, or not, if they are a little bit on the crude 

25 side in terms of what you have in mind. 
 1 Audience Questions/Comments Vol. 2, p. 172 

 2 But there are tools in AERMOD to help you get 

 3 down that path. 

 4 TYLER FOX: It's the noon hour, and so we should go ahead and 

 5 break for lunch. I did want to really thank and 

 6 express our appreciation to all the panelists for 

 7 their willingness to, not just offer their thoughts 

 8 in response to comments, but really engage in an 

 9 active discussion on a topic that obviously we are 

10 all interested in and isn't going to be resolved 

11 this afternoon or tomorrow, but if we can continue 

12 this dialogue in the areas and the venues that we 

13 can, I would really appreciate getting all the 

14 input we can from all of you as we move forward, 

15 because I think that we have identified a number of 

16 areas where we don't and should not put our head in 

17 the sand as John said, and we need to be aware and 

18 have our eyes wide open on these things, because 

19 these models are only becoming more complex, and 

20 even in the existing regime, the -- the ability to 

21 work within the preferred models, there are a 

22 number of options that we're going to have to 

23 really address these concerns one way or the 

24 other. 

25 So, thank you, to everybody and have a great 
 1 AWMA/AB3/Gale Hoffnagle Vol. 2, p. 173 

 2 one. 

 3 (Applause.) 

 4 _______________________________ 

 5 (LUNCH 12:03 - 1:07 P.M.) 

 6 _______________________________ 

 7 (Announcements.) 

 8 WARREN PETERS: Okay. I believe we are ready to go. We have 

 9 at this point five presenters scheduled for this 

10 afternoon, and the first set will be from the AWMA, 

11 and I'd like to introduce Gale Hoffnagle who will 

12 be the session chairman for this part of the panel. 

13 There will be several presentations. 

14 GALE HOFFNAGLE: Thank you, Warren. 

15 I'm Gale Hoffnagle, and representing here the 

16 Air and Waste Management Association. 

17 In the domain of the Air and Waste Management 

18 Association, we are known as AB3 in the meteorology 

19 committee. 

20 The meteorology committee used to be called 

21 meteorological aspects of air pollution control. 

22 There are a hundred seventeen (117) members of the 

23 meteorology committee, more than are here at the 

24 present, and we have to get their views included in 

25 the slides that we are presenting, and we hope the 
 1 AWMA/AB3/Ron Petersen Vol. 2, p. 174 

 2 the comments will be of use to EPA. 

 3 We'd like to thank EPA for this opportunity to 

 4 make a presentation of our thoughts, and we will be 

 5 making written comments by the written comment 

 6 deadline. 

 7 There are three presentations. The first is 

 8 nonstandard modeling approach is to be given by Ron 

 9 Petersen, AERMOD to be given by Russ Lee and 

10 CALPUFF to be given by Mark Bennett. 

11 And we will be giving those presentations 

12 later -- the comments later. 

13 RON PETERSEN: I'm Ron Petersen from CPP, as Gale said, 

 

14 providing comments for Air and Waste AB3 Committee, 

15 and Alan Huber will also be -- we're kind of a tag 

16 team presentation here. He will be talking about 

17 the CFD issues. 

18 The comment area is refined models to be 

19 considered for complex near-field situations, and 

20 the two models we're going to specifically talk 

21 about here are computational fluid dynamics 

22 modeling and wind-tunnel modeling. 

23 Advantages and the limitations of these two 

24 (2) models, CFD/wind-tunnel modeling; these models 

25 really supplement routine models such as AERMOD for 
 1 AWMA/AB3/Ron Petersen Vol. 2, p. 175 

 2 very complex situations where we have interactions 

 3 between structures and complex features that can 

 4 really disrupt the flow. 

 5 They can also been used for some unusual 

 6 source characteristics like, let's say, merge 

 7 stacks, cap stacks, horizontal stacks, some very 

 8 unusual source configurations. 

 9 They are highly site-specific. However, they 

10 cannot be used for all meteorological conditions. 

11 They have some limitations under which conditions 

12 they work best, so they are -- they really cannot 

13 be applied in long-term simulations. 

14 They can been used, however, to parameterize 

15 routine models to make them work better in all 

16 conditions. 

17 Why use them in air quality studies? 

18 Of course, first, we talked about already that 

19 they can simulate flows that are very complex. 

20 Current routinely applied air quality models 

21 do not include the physical dimensions of the 

22 building. You may think they do, but they 

23 simplify it down to just a single building 

24 shape, so not treating individual building 

25 shapes. They're just looking at a simple building 
 1 AWMA/CFD/Alan Huber Vol. 2, p. 176 

 2 configuration. 

 3 The simulations can be used to understand 

 4 details of a specific case study. And they can be 

 5 used to support the development and use of better 

 6 simplified algorithms for a simple general 

 7 application. 

 8 Now I want to turn it over to Alan to talk 

 9 about the specifics of CFD. 

10 ALAN HUBER: Yes, I am here today, I'm not, when I say CFD, 

 

11 I'm not talking about a particular code. I'm 

12 talking about the full computational construct, and 

13 that's -- you know, has to do with being 

14 computational and the fluid dynamics of things that 

15 flow. 

16 And CFD software solves the fundamental 

17 physics equations, and it characterizes the 

18 physical models, and the building of a software to 

19 closely match the true geometry. 

20 So this is a generic approach in this modern 

21 -- modern times, we have much more computational 

22 power, and the software has evolved that, of 

23 course, for some classes of problems, we can get 

24 very valid solutions if applying CFD. 

25 What are some of the constructs of CFD 
 1 AWMA/CFD/Alan Huber Vol. 2, p. 177 

 2 software? It -- you take your domain and divide it 

 3 into discrete volumes or elements, and the key 

 4 feature is that these elements resolve the flow 

 5 sufficiently. 

 6 So, you can look at recirculation, and the 

 7 fine details of every building's abilities 

 8 accurately. 

 9 The equations of mass, momentum, energy, 

10 scalars, such as pollutants, are solved 

11 numerically. And you can -- in the CFD code you 

12 can simulate physical processes such as heating, 

13 particle motion/deposition and chemistry. 

14 CFD code can either be applied in a steady 

15 state mode or with more computational power you 

16 have time varying solutions. 

17 Many practical problems can be assumed steady 

18 state following a sort of hour by hour setup that 

19 we commonly use for regulatory models. 

20 What are some of the issues of making CFD 

21 codes applicable routinely? 

22 Well, you need the computational resources. 

23 Today, it's very common that -- that an industrial 

24 complex could be practically run on most 

25 workstations. 
 1 AWMA/CFD/Alan Huber Vol. 2, p. 178 

 2 Well, if you want to simulate a complex full 

 3 urban area, probably only the largest systems could 

 4 be used for that kind of situation. 

 5 CFD code involves many lines of the 

 6 interacting code, so I, you know, can appreciate 

 7 before a particular code would be entered into a 

 8 regular application would have to undergo some full 

 9 range of applications to test the reliability of 

10 the Code. 

11 And that's not trivial, but certainly doable. 

12 CFD code, while solving the fundamental 

13 physics equations at some level requires a 

14 turbulence model. 

15 So there is some uncertainty to -- even with 

16 -- given the CFD code. Hopefully, what happens is 

17 that the turbulence is closed at a much higher 

18 order, and depending on your resolution on mesh, 

19 the uncertainty is on smaller scales and less 

20 significant to your -- the significance of your 

21 solution. 

22 But in the CFD model has boundary conditions, 

23 requiring some approximations. That -- that's the 

24 same with all the regulatory models. We were 

25 talking earlier today about on -- on -- on -- 
 1 AWMA/CFD/Alan Huber Vol. 2, p. 179 

 2 there's chaos in the atmosphere, but, you know, 

 3 even with the perfect model, even if you had the 

 4 perfect regulatory model, there's uncertainty in 

 5 the input parameters of boundary conditions. 

 6 There's no uniform boundary. So those models have 

 7 that extra uncertainty that leads to -- to 

 8 variability; likewise, some carryover in the CFD 

 9 application. 

10 Before our CFD could be probably routinely 

11 applied, it should be used some best practice 

12 methods, you know, if it's -- CFD codes have many 

13 options. 

14 So, it's probably important that at -- 

15 particular types of applications undergo the 

16 validations -- same validation tests that was 

17 recommended here, so -- in the case of -- for when 

18 there's building influences, for instance. 

19 And the Code should be used -- have user 

20 friendly interfaces. Air quality monitors should 

21 be able to run the routine applications. 

22 Just quickly go through a couple of examples 

23 of CFD simulations. 

24 Today, there's buildings -- the whole issue 

25 here is the CFD. You can enter a specific building 
 1 AWMA/CFD/Alan Huber Vol. 2, p. 180 

 2 geometry. For most urban areas, there already is 

 3 building geometry. For industrial sites, there are 

 4 plenty of commercial vendors that can quickly 

 5 develop a building geometry for any particular 

 6 site. 

 7 (Projecting graph.) 

 8 Here's a case where the CFD, what you see here 

 9 is -- is a line source with two levels of surface 

10 heating compared to an urban line source. 

11 So, recognize that the CFD should be able to 

12 run under comparable conditions to non-building 

13 influences that you might have in your other 

14 regulatory models to show that level of 

15 comparability before you move ahead with 

16 demonstrating building effects. 

17 Then in the case of building effects, we all 

18 know in your urban street canyons, there is some 

19 complex flows, which are really there and it's -- 

20 which regulatory models don't really account for. 

21 So this provides a mechanism for having more 

22 reliable solutions in urban environments. 

23 And here's a case where concentration is, in a 

24 street canyon, very variable. And it doesn't 

25 follow any type of plume or any type of solution 
 1 AWMA/Modeling/Ron Petersen Vol. 2, p. 181 

 2 would come out of air modeling. 

 3 And then in complex urban environments, with 

 4 multiple buildings, we see how the flow pattern 

 5 near the surface is very strongly influenced by 

 6 every individual building. 

 7 That's going to dramatically affect how a 

 8 emission pollutant can transport through this 

 9 environment. And it really is not possible in our 

10 threatening present regulatory model. 

11 Okay. 

12 RON PETERSEN: Thank you, Alan. 

 

13 Wind-tunnel modeling, just background on that. 

14 It's -- actually the CFD is sometimes called the 

15 virtual wind tunnel, but its basic equations are 

16 solved in the wind tunnel by simulating the flow 

17 and then measuring what's going on. 

18 It's kind of like an analog computer. You get 

19 infinitesimal resolution and infinite memory, 

20 really, in the wind-tunnel simulation. 

21 And the math model should really be able to 

22 simulate what's going on in the wind tunnel. It's 

23 a steady state condition, so it's a good source for 

24 model testing and validation. 

25 Some other little background: the wind and 
 1 AWMA/Modeling/Ron Petersen Vol. 2, p. 182 

 2 turbulence profiles are consistent with the 

 3 underlying surface roughness, and dis- -- 

 4 dispersion in the wind tunnel matches boundary 

 5 layer theory much like what's in the AERMOD right 

 6 now. 

 7 The measured concentrations are steady-state 

 8 averages, pretty much the same as the Gaussian 

 9 plume model, and there's no time scaling really is 

10 needed. 

11 The best simulations, however, are for neutral 

12 stability, so you really can't extend it much 

13 beyond the neutral case, and that's where we need 

14 to get the field data for -- (cough) to take it to 

15 other conditions. 

16 Just in the background right now, there really 

17 is already a guideline for wind-tunnel modeling. 

18 It was put out in eighty-one ('81), and I should 

19 mention that ASCE has a standard on how to use 

20 wind-tunnel modeling right now for specifying wind 

21 loads on structures, so the ASCE group uses that to 

22 define structural wind loads for most of the 

23 buildings you see around the country. 

24 Now, just a few applications to consider and 

25 some are existing, that -- where wind tunnels are 
 1 AWMA/Modeling/Ron Petersen Vol. 2, p. 183 

 2 already used in the regulatory environment. 

 3 Good engineering practice stack heights, of 

 4 course, for complex structures, cooling towers, 

 5 cylindrical structures, lattice structures, complex 

 6 terrain, is used there when the need arises. 

 7 Another application is what's called 

 8 equivalent building dimensions, where you can do a 

 9 study to put in -- replace the BPIP file with 

10 wind tunnel determined dimensions for unusual 

11 sites, like here, a hyperbolic cooling tower, for 

12 example, you'd like to find out what retainer 

13 building to put in to -- to get the right 

14 concentration distribution downwind of that type of 

15 a structure. 

16 So that's already something that's being done, 

17 but it's not really talked about much in the 

18 current guidance or regulations. 

19 Terrain wakes right now really are not 

20 considered in AERMOD, and they may be really 

21 affecting some sources. So it's really not even 

22 accounted for. 

23 Maybe the wind tunnel, there is a place where 

24 the wind tunnel number could be used directly, if 

25 you want to assess what's going on due to a nearby 
 1 AWMA/Modeling/Ron Petersen Vol. 2, p. 184 

 2 upwind terrain feature. 

 3 Or, here's a case where you have flow in urban 

 4 areas where you have short stacks next to a tall 

 5 building, plume impact on the building; that's 

 6 really not treated well, by the current models. 

 7 Here's another case where maybe the wind 

 8 tunnel should be used directly, or the other more 

 9 extreme case, a tall upwind building, pulling the 

10 source upwind in a building cavity, another 

11 situation that's not really handled by existing 

12 models. 

13 So these are some cases where maybe the wind 

14 tunnel should be used to provide direct estimates, 

15 or even in an urban street canyon environment where 

16 the models really sort of -- site specific numbers 

17 are not therein. 

18 So, to really kind of wrap it up here, some of 

19 the implementation issues, the wind tunnel and CFD 

20 models can perform better than any of the present 

21 models for certain complex situations. 

22 The models cannot be applied for every hour of 

23 the year, however. 

24 So the question is; how can a -- how could you 

25 replace some of the hourly predictions with these 
 1 AWMA/Modeling/Ron Petersen Vol. 2, p. 185 

 2 models into an existing code to get longer term 

 3 averages? That would be an implementation issue. 

 4 For a specific CFD code, the compiled version 

 5 can be frozen and options/parameters fixed so you 

 6 can repeat -- get repeatable results. 

 7 That is an issue, getting repeatable answers 

 8 from CFD. 

 9 The performance of CFD codes can be 

10 established. They still need to be evaluated 

11 through some comparisons with databases, wind 

12 tunnel fields, so there is still some model 

13 validation, at least, going on there. 

14 But guidance for regulatory application, of 

15 both CFD and wind tunnel models is needed. An 

16 oversight of these applications is also needed. 

17 Perhaps it could be done through a working group of 

18 CFD and wind tunnel users with final oversight by 

19 EPA. 

20 Kind of some of the recommendations and ending 

21 points here for us would be to recommend EPA 

22 determine where areas where CFD and wind tunnel 

23 modeling may be used to complement existing approved 

24 models. 

25 Also include language allowing the use of 
 1 AWMA/AB3/Russell Lee Vol. 2, p. 186 

 2 these methods in these areas, some kind of -- 

 3 let people know that this is something they could 

 4 do. 

 5 And, also, have some kind of methodology. For 

 6 example, we do right now have an EPA fluid model 

 7 and guideline for wind tunnels, but it probably 

 8 would need to be updated. It's 1981, so it seems 

 9 like it should be brought up-to-date. 

10 We right now do need a CFD modeling guideline. 

11 There is no guideline at all for that. So that 

12 would be something to work on, and then provide a 

13 mechanism for peer review, evaluation and 

14 documentation when you use these models. 

15 So that ends my comments and turn it back to 

16 Gale here. 

17 GALE HOFFNAGLE: All right. 

18 RUSSELL LEE: Good afternoon. I'm Russ Lee, of R.F. Lee 

 

19 Consulting. Primarily I am here representing the 

20 Air and Waste Management Association, AB3 

21 Committee, to offer our comments on AERMOD. 

22 Granted that I am in the consulting business 

23 myself and also was on the Committee that developed 

24 AERMOD, I have my AWMA hat on today, and am serving 

25 as a reporter from the AB3 Committee to provide 
 1 AWMA/AB3/Russell Lee Vol. 2, p. 187 

 2 AERMOD -- comments on the AERMOD. 

 3 First, the general comments from the AB3 

 4 Committee of AERMOD are favorable. 

 5 The model evaluation which most of you have 

 6 gone over is -- is rather impressive, particularly 

 7 compared to some of the older models. 

 8 And -- but there are some implementation, 

 9 documentation and guidance issues that need to be 

10 dealt with sooner or later, and some of them should 

11 be dealt with fairly soon. 

12 The existence of these issues, please, the 

13 existence of these issues should not be used as a 

14 basis to delay promulgation. They are not of that 

15 severity in any way, shape or form. But they are 

16 concerns that we have that -- that need to be 

17 addressed as AERMOD comes into use. 

18 One general comment that's -- I wasn't quite 

19 sure what category to put this in, but many -- in 

20 many parts of the country, particularly in the 

21 mount- -- in mountainous regions of the west, there 

22 is a real need to be using the ten-meter (10m) DEM 

23 files. 

24 These are the ones where the -- points are -- 

25 elevation samples are made ten meters (10m) apart, 
 1 AWMA/AB3/Russell Lee Vol. 2, p. 188 

 2 most of the files that are available are so-called 

 3 thirty-meter (30m) files and AERMAP reads those. 

 4 At the present, AERMAP does not read the ten-meter 

 5 (10m) files. 

 6 We were told, I believe yesterday, that they 

 7 were in the process -- that EPA was in the process 

 8 of upgrading AERMAP to accept these, and we 

 9 considered taking this comment out, but we have 

10 left it in, and there is a number of other comments 

11 that we have done the same thing for, because even 

12 though EPA realizes and agrees with us that it 

13 needs to be done, and we are in the process of 

14 doing it, we want it to be a matter of public 

15 record that this is wanted, that this is needed. 

16 And there is several statements I may make 

17 along through here that fall in that same 

18 category. 

19 Many of us, and I used to work at EPA, very 

20 often, we -- some of our technical people thought 

21 it was very obvious that something should be done. 

22 We couldn't get money to do it. 

23 Public comments come in; the same thing comes 

24 in from the public. Suddenly, the money appears. 

25 So recognizing that, if you are doing something -- 
 1 AWMA/AB3/Russell Lee Vol. 2, p. 189 

 2 if EPA's doing something we like, we will say it 

 3 anyway so that EPA management knows that this is 

 4 something we want, and this is something we like. 

 5 Implementation issues provide the intended 

 6 schedule for promulgation of AERMOD. (Chuckles 

 7 from audience.) This is -- you know what we're 

 8 talking about here. It's not out yet. It was any 

 9 month now, then any day now, and now it's any hour 

10 now. 

11 I think it's very close, but nobody seems to 

12 be able to predict it even so. 

13 Even EPA doesn't know the answer to that, but 

14 it certainly is helpful to the users of the models 

15 to know what's coming when. 

16 Explicit clarification of grandfathering of 

17 ISCST3. 

18 How long will EPA allow the support of ISCST3? 

19 Are there any situations where ISC can continue to 

20 be used after EPA, after AERMOD becomes an EPA 

21 model of choice, short of demonstrating its -- that 

22 it is a better model which is not likely to happen 

23 in very many cases. This is a question that comes 

24 up, and it should be addressed. The -- the, if not 

25 in the Federal Register, notice at least in the 
 1 AWMA/AB3/Russell Lee Vol. 2, p. 190 

 2 guidance, it should be very, very clear exactly 

 3 where, you know, when, if ISC completely 

 4 disappears, or if there is so situations under 

 5 which it does not disappear and can be used, this 

 6 is not something you much -- you think about much 

 7 until you are on the side of running models, and 

 8 you find a state wants to use an outdated model, 

 9 can they do that? 

10 That's one example. 

11 Point of contact or questions about the model 

12 can be answered quickly and accurately. That 

13 presumably is going to happen when we -- when the 

14 model is released -- is promulgated, but we want to 

15 make sure it happens. 

16 We want to make sure that there is enough 

17 funding so that the person responsible for 

18 responding can have perhaps the time of an 

19 additional person if it's needed; that -- that 

20 enough training is done within EPA so these 

21 questions can be answered reasonably promptly. 

22 Providing adequate funding for a timely 

23 maintenance and corresponding documentation of the 

24 AERMOD code. 

25 There is concern at AWMA, and there may be 
 1 AWMA/AB3/Russell Lee Vol. 2, p. 191 

 2 concern in other areas as well, and I think it 

 3 sounds like there is a point of contact for the 

 4 maintenance and a mechanism starting to be 

 5 developed, but we want to be sure that there is -- 

 6 that there is a maintenance plan and that the model 

 7 is maintained and as changes are made, that 

 8 documentation is -- comes along with it, and that 

 9 EPA provides the personnel and funding needed to 

10 carry this out. 

11 Guidance issues. 

12 (Projecting slide.) 

13 Providing sufficient guidance to assure that 

14 reasonable consistency in the applications of 

15 AERMOD, and this is to make sure that people don't 

16 start using it in a completely inappropriate way. 

17 A little -- I need little more guidance than 

18 we have, and this is going -- this is going to he 

19 evolve, but we need to make it a matter of record 

20 that -- that we need it, and that -- so that the 

21 guidance doesn't come out to we can never get 

22 upgraded. 

23 Use of the Bulk-Richardson scheme for using 

24 on-site data in remote areas without cloud cover 

25 data. 
 1 AWMA/AB3/Russell Lee Vol. 2, p. 192 

 2 One of the nice things about AERMOD is you can 

 3 input on-site data directly, and -- but you never 

 4 have the complete sets that you need. What's 

 5 missing is cloud cover. 

 6 But the use of Bulk-Richardson scheme allows 

 7 the use of on-site data without having to have an 

 8 observer out there observe the cloud cover. 

 9 However, there is a need for guidance on what 

10 is appropriate and what is inappropriate use of the 

11 scheme. 

12 PVMRM method is new. There needs to be -- its 

13 use needs to be standardized, and we -- we need 

14 guidance on it as well. 

15 The land use parameters. 

16 People -- this is new. So people are a little 

17 confused, particularly if they have -- if they are 

18 model users but not, even some of those of us who 

19 are technically astute, and especially those who 

20 are not, the use of the land -- guidance on land 

21 use parameters is critical. 

22 One is multiple land use sectors; is that 

23 okay, when is it okay, when it is not okay, what 

24 restrictions on that guidance on defining seasons 

25 because we have this table in the AERMET manual 
 1 AWMA/AB3/Russell Lee Vol. 2, p. 193 

 2 that defi- -- that says for certain seasons and 

 3 certain types of land use, here are the parameters 

 4 that you put in, surface roughness and, 

 5 Monin-Obukov and I mean I've already -- the 

 6 Bowen ratio, and the albedo. 

 7 There is a description in the MPRM manual that 

 8 is fairly explicit and does explain this a little 

 9 bit more than anything that appears in the AERMET 

10 manual, and that is, for example, winter values are 

11 values when the ground is covered with snow. 

12 People need to know this and how to apply it, 

13 and how to make sure things -- and make sure that 

14 it is being used properly. 

15 Complete and release AERSCREEN. We've been 

16 told that this is just about there and that it is 

17 going to happen, but we want EPA to know that it is 

18 important to the user community, to the AWMA group 

19 within the user community. 

20 There is another issue of exactly, it -- is 

21 AERSCREEN going to be used in exactly the same way 

22 as SCREEN was relative to the ISC, or is it going 

23 to be used slightly different? 

24 Are there some differences in the way it can 

25 be applied? 
 1 AWMA/AB3/Russell Lee Vol. 2, p. 194 

 2 Is it going to be designated as a screening 

 3 model in Appendix W? If it is, that partially 

 4 defines the role of AERSCREEN. 

 5 So even though there's somebody in the midst 

 6 of putting all of this together, you may think, 

 7 well, the role of AERSCREEN is obvious to the user 

 8 who is not in the middle of it; who is kind of on 

 9 the outside, it may not necessarily be obvious, so, 

10 the guidance needs to be perhaps carefully crafted 

11 so that all of the -- so that users will have no 

12 question about that. 

13 There are a few documentation issues within 

14 AERMET, and -- or the AERMET documentation 

15 regarding land use sectors and -- I've already 

16 pretty much covered this, but we have also at first 

17 glance, many -- some several people have looked at 

18 the documentation and said, okay, we'll set these 

19 up when they're downwind. 

20 So since that question comes up, on first 

21 glance, it's -- perhaps a few more words in the 

22 documentation at some point, or in the guidance at 

23 some point, would be helpful. 

24 With AERMET'S ability to use on-site data, 

25 there is in AERMET just a whole list of codes of 
 1 AWMA/AB3/Russell Lee Vol. 2, p. 195 

 2 many types of on-site data that can be input. 

 3 What is not stated is that many of these input 

 4 variables are not connected to anything. They are 

 5 place holders. The user needs to know which 

 6 variables are actually -- can actually be input to 

 7 AERMET and which variables only look like they are 

 8 being input and are -- and are really going 

 9 nowhere. 

10 For example, you can input according to the 

11 documentation, heat flux; you call it HFLX. You 

12 input a file with E flux -- with heat flux in it 

13 and you look and you can get no differences in the 

14 results. Why? Well, it doesn't use them. It 

15 doesn't use heat flux, it doesn't do anything with 

16 it. It's a place holder. The user needs to know 

17 this. 

18 Well, granted that's going to be a moving 

19 target, because presumably some of these things 

20 will be added in as we go, but it needs to be 

21 stated somewhere that they are place holders and 

22 which ones are live, so to speak, and which ones 

23 are not. 

24 To just summarize, and this is very -- this 

25 whole presentation is a summary really. Far more 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 196 

 2 details will appear in the written version later, 

 3 but we encourage the prompt release of AERMOD. We 

 4 have been waiting for it. We think it is a good 

 5 thing, and it needs to be -- it needs to be 

 6 promulgated. 

 7 At the same time, there is work needed and 

 8 funding needed to do it in many cases, in the areas 

 9 of its implementation, guidance and documentation. 

10 Thank you. 

11 GALE HOFFNAGLE: Mark. 

12 MARK BENNETT: This is Mark Bennett from CH2M Hill, and I, 

 

13 like these two speakers, I am here to present 

14 comments from Air and Waste Management Association, 

15 AB3 Committee. And my comments here are on the 

16 implementation of CALPUFF. 

17 Okay. 

18 First and foremost we want to reaffirm our 

19 support of CALPUFF. We think it is a good model. 

20 It's beneficial to the modeling community and to 

21 the regulatory community to have this model. 

22 However, we do have some specific concerns, 

23 and because we want to be positive here, we have 

24 recommendations to go along with those concerns, 

25 and we also, when we were putting together these 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 197 

 2 comments, we looked at CALPUFF as possibly serving 

 3 as a template for models for the future, as we're 

 4 here today there may be alternative approaches, so 

 5 we tried to think that as well. 

 6 And just sort of to give you an overview, too, 

 7 of the general theme you will see running through 

 8 these comments is that we'd like to see EPA take a 

 9 more active oversight in CALPUFF than we have seen 

10 in the last few recent years since it's been 

11 promulgated. 

12 Okay, so general concerns, that document -- 

13 the model itself, as it gets updated and 

14 documentation to go along with those updates, there 

15 seems to be what is perceived as a rather severe 

16 lag in time of getting those out to the users. 

17 Next, and we heard yesterday quite a bit of 

18 discussion about the use of meteorological data 

19 with CALPUFF and other models. We are concerned 

20 about consistency, availability and the quality of 

21 a -- specifically mesoscale data sets to go along 

22 with CALPUFF, with the CALPUFF modeling system. 

23 One thing we didn't hear mentioned yesterday, 

24 but is of concern to a number of our users is there 

25 seems to be a lack in the methodology for 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 198 

 2 evaluating the wind fields that come out of 

 3 CALMET. 

 4 This is something we've heard concern 

 5 expressed about at previous meetings, but nothing 

 6 has been done so far that is available to the 

 7 general user, and another big concern that came 

 8 from nearly everybody we spoke to on this is, there 

 9 seems to be quite a bit of inconsistency in 

10 guidance from local and Federal agencies in using 

11 CALPUFF, and I think we heard quite a bit about 

12 that yesterday, as well. 

13 Now on to some specific concerns. The 

14 official regulatory version that you can go and 

15 download has known errors in it, -- oh, let me back 

16 up for one moment here. 

17 Just as Russ said, we've heard yesterday and 

18 today, some comments coming from EPA which we are 

19 in agreement with, but we just wanted to include in 

20 our comments reaffirmation that those are things 

21 that we are concerned about that we want and are 

22 needed. 

23 So some of these, like this one, we heard 

24 about earlier today, but I'm going to repeat just 

25 so it's part of the public record. 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 199 

 2 So, again the official version has known 

 3 errors; the beta version which fixes those errors 

 4 is not the official version. So obviously that 

 5 leads to difficulty in modeling -- in the real 

 6 world when we are out there trying to model for 

 7 permits. 

 8 So, obvious recommendations are, we want EPA 

 9 to ensure that there is timely maintenance of the 

10 CALPUFF code, and a comment similar to what you saw 

11 Russ give for AERMOD, we also want EPA to provide 

12 adequate funding for a specific point of contact 

13 for CALPUFF that can give quickly and accurately 

14 answered questions. 

15 Another obvious one here. 

16 The users guide is out of date and incomplete. 

17 Looking back at the record, for the seventh 

18 modeling conference, this committee made similar 

19 comments at that time, June 2000, and we are still 

20 in the same situation. 

21 So another straightforward recommendation, 

22 something that really is needed for CALPUFF to be 

23 considered a regulatory model, is that EPA to 

24 ensure that there is an up-to-date and complete 

25 user's guide corresponding to the official 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 200 

 2 version. 

 3 Al right, meteorological data. 

 4 Again, we heard quite about this yesterday, 

 5 and we are going to echo some of the same concerns 

 6 we heard yesterday. Again, a specific example of 

 7 this inconsistency in terms of what's acceptable to 

 8 different regulators. We have heard of Obs versus 

 9 No Obs, various MM5 data sets that are available; 

10 that's RUC, ETA, we've heard about RAMS also 

11 yesterday. 

12 Another thing we heard yesterday was that the 

13 thirty-six (36) kilometer MM5 data sets which are 

14 the most readily available, may not be sufficient. 

15 Therefore, we might need twelve kilometer 

16 (12km) data sets, four kilometer data sets. We 

17 don't know, but we do have a concern that those 

18 data sets, given that right now we have to model 

19 three years of meteorology, are not generally 

20 available in addition to what's acceptable that's 

21 available, there is a question of adequacy that we 

22 heard expressed yesterday about a number of these 

23 data sets; which data sets are adequate, properly 

24 evaluated. 

25 And, then, of course, we are all expecting 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 201 

 2 there to be an increase from the requirement of 

 3 three years of meteorological data to five years. 

 4 So, again, this exacerbates these concerns about, 

 5 do we have five years of data -- meteorological 

 6 data sets that are acceptable? 

 7 The recommendations that we have is that EPA 

 8 should provide oversight for consistency and 

 9 adequacy of these data sets, the ones that we are 

10 being required to use five years for example, and 

11 EPA should collect and distribute these at cost. 

12 Okay, another concern we have is both, I think 

13 if you read between the lines a little bit 

14 yesterday, you heard concerns about when is it 

15 appropriate and not appropriate to use AERMOD. 

16 We talked about checkerboard land use, for 

17 example. We talked about there was some comment 

18 about redefining what near-field constitutes. 

19 So, as most of the people in this room know, 

20 in addition to long-range transport, when CALPUFF 

21 was approved, it was also approved on a 

22 case-by-case basis for complex wind fields. 

23 So we anticipate the increased use of CALPUFF 

24 for complex wind fields, but again, as has already 

25 been expressed in this room over the last couple 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 202 

 2 of days, this case has not been thoroughly 

 3 evaluated. 

 4 So our recommendations are, and again, I'll 

 5 stop again here for a minute to pause and clarify, 

 6 we -- we have also heard a number of times that EPA 

 7 may not have as much budget as they would like and 

 8 as we would like to address some of these issues, 

 9 and we have to work together collaboratively. We 

10 are all in agreement with that, and so we want to 

11 provide some recommendations on methods that we -- 

12 that have been used in the past and may be used in 

13 this case to get the most bang for your buck so to 

14 speak. 

15 So a number of years ago when EPA was 

16 evaluating the screening procedure for CALPUFF, 

17 there was an explicit solicitation for input, from 

18 the modeling community on people who were looking 

19 at cases where they did both the refined and 

20 screening model, and they might also look at 

21 reducing the arc of the rings, and the user 

22 community responded to that, provided some papers on 

23 that and that was used -- EPA used that. 

24 So, again, this is an idea we're suggesting 

25 here for complex wind fields and for a number of 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 203 

 2 other ones you will see, where if EPA feels it is 

 3 appropriate, they might actively solicit input from 

 4 the modeling community on these topics so there 

 5 could be more data from which to draw conclusions 

 6 and start creating policy memos or maybe just 

 7 technical memos. 

 8 And that's why we go on to our last bullet 

 9 here which you will see a couple of times is that 

10 we would strongly like to see the model clearing 

11 house reactivated. 

12 Again, we believe we have heard over the last 

13 couple of days that that's going to happen, and we 

14 want to urge strongly that we want to see that 

15 happen. The last time we checked the last 

16 information in there was from was 1997, I believe, 

17 so we might even have some catching up to do. 

18 AERMOD-like dispersion; a concern. A number 

19 of us had felt that this was now the preferred 

20 mode, but recently we've heard that maybe it is not 

21 the preferred mode. 

22 I -- we reference here an e-mail I received 

23 from John Irwin back in 2001 where he said he was 

24 recommending that as a preferred mode. 

25 So, again, inconsistent or not clear 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 204 

 2 guidance, inconsistency on acceptability is 

 3 definitely a concern as we are -- have to use this 

 4 AERMOD-like dispersion on a number of permitting 

 5 projects. 

 6 Some regulators have experience; others have 

 7 not. 

 8 So, that's a concern. 

 9 So the recommendation here is, that we'd like 

10 to receive some clear guidance that maybe would end 

11 up in the model clearing house, on what is the 

12 status of using or not using the AERMOD-like 

13 dispersion of CALPUFF. 

14 EPA should, again, possibly solicit input from 

15 people using this, and catalogue these and make 

16 these available, and then any memos appropriately 

17 should be put in the modeling clearing house. 

18 Okay, visibility analysis. 

19 Arguably, this is one of the most critical 

20 issues when you're using CALPUFF in a PSD 

21 permitting process. 

22 In the past, we believe we have heard EPA 

23 defer to the Federal Land Managers on this issue. 

24 I think we heard some comment to that effect today, 

25 but I thought I heard comments contrary to that 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 205 

 2 yesterday. 

 3 There is no clear guidance available. It's 

 4 one of the most contentious issues. We heard again 

 5 yesterday a number of these aqueous phase, 

 6 chemistry, so on and so forth, and it -- it is 

 7 arguably one of the largest sources of user 

 8 frustration in using CALPUFF, one of the largest 

 9 concerns in CALPUFF implementation. 

10 So, the committee would like to recommend that 

11 EPA take over the guidance for CALPUFF including 

12 its use for visibility modeling. 

13 We'd like to see an upgrade to the aqueous 

14 phase chemistry. We'd like to see clear regulatory 

15 guidance on these various issues associated with 

16 visibility analysis, and again the same comment 

17 about cataloging the -- these cases, making them 

18 available to the public and, if appropriate, 

19 soliciting input from the modeling community. 

20 So as Russ said, this -- this whole 

21 presentation is somewhat a summary, and we'll be 

22 providing details in our written comments. 

23 But to just summarize here and then give you a 

24 list of some high priority items: EPA should 

25 clearly and definitely take over regulatory 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 206 

 2 guidance for CALPUFF. 

 3 EPA should ensure support and timely model 

 4 maintenance, especially in light of the fact that 

 5 it is setting somewhat of a precedent for a future 

 6 nontraditional modeling approval. 

 7 We'd like to see EPA actively collect and make 

 8 available these meteorological data sets, and then 

 9 also case studies in the areas of concern. 

10 And, again, EPA should reactivate and actively 

11 maintain the model clearing house. 

12 This is just -- this is not in any particular 

13 order, but this is a list of high priority items of 

14 whether it's your highest priority probably has to 

15 do with what your most recent experience in 

16 modeling with CALPUFF is, but we would -- all 

17 members of the Committee agreed that these are high 

18 priority items and that the -- the highest for some 

19 of us. 

20 So the official version should be free from 

21 known errors and should have associated user 

22 guidance. That -- that's just the basic 

23 requirement for having a regulatory model. 

24 The visibility issues that I explained in 

25 detail on the previous slide. I won't go into that 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 207 

 2 again. 

 3 The availability, acceptability and adequacy 

 4 of this mesoscale meteorological data sets that we 

 5 are required to use three, or now possibly five 

 6 years, of data. 

 7 Again, a methodology to evaluate the CALMET 

 8 wind fields, the complex wind field cases, and 

 9 AERMOD-like dispersion. 

10 I thank you for your time. 

11 GALE HOFFNAGLE: Okay. That concludes our remarks. 

12 I would say we have two invitations for you. 

13 The first invitation is that sometime in the next 

14 week, before September the 30th, you may file your 

15 abstracts for the annual meeting at which the AB3 

16 committee will have four or five sessions. 

17 The annual meeting is currently scheduled and 

18 remains currently scheduled for New Orleans in 

19 June. Okay. 

20 So, it's still scheduled for New Orleans in 

21 June, and one way to help New Orleans is to go have 

22 your convention there. So we're still planning to 

23 do that. 

24 The other opportunity is closer, and dearer, 

25 perhaps to us, and that is in April 24th to 28th, 
 1 AWMA/AB3/Mark Bennett Vol. 2, p. 208 

 2 2006, next spring, in Denver, we will have our 

 3 third conference on regulatory applications of air 

 4 quality models. We are having it in Denver 

 5 specifically to get the input of the Park Service 

 6 and Forest Service and the Wildlife Service. 

 7 However, I would like, as I did yesterday, to 

 8 invite OAQPS, and the modeling section, to use the 

 9 venue in any way you feel might be appropriate for 

10 public discussions of model issues. 

11 And so we would continue to like to make that 

12 invitation. 

13 The first two days, on the 24th and the 25th 

14 will be -- obviously will be classroom 

15 presentations by Bob Paine of AERMOD, and Joe 

16 Scire of CALPUFF, and Lloyd Schulman has offered 

17 to give his course again on ISC-PRIME. 

18 So if you are looking for, or if you state 

19 people are looking for, a place to come learn 

20 something about the models, this would be a good 

21 opportunity to do so. And then on Wednesday, 

22 Thursday, Friday we will have our sessions with 

23 abstracts and with panel discussions about various 

24 issues related to models. 

25 The abstracts are due in the first week of 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 209 

 2 December, so we have a couple of months now to 

 3 figure out what abstracts to present for giving 

 4 papers at that conference, and we all hope to see 

 5 you in Denver. 

 6 Thank you. 

 7 WARREN PETERS: Thank you, Gale. 

 8 Warren Peters. 

 9 We appreciate all that time and effort on 

10 those comments, and we appreciate you being on time 

11 for our conference today. (Chuckles.) 

12 Next we have on the schedule, a presentation 

13 from Ted Thrasher who works for CSSI. He will be 

14 representing FAA. 

15 Ted. 

16 TED THRASHER: (Projecting slide.) That's what I am going to 

 

17 talk about. The EDMS development. EDMS is the Emissions and 

18 Dispersion Modeling System. 

19 Just as an introduction for those of you who 

20 aren't familiar with EDMS, it is the required model 

21 for any FAA projects. So if you are going to add a 

22 runway or make some kind of airport change, that's 

23 going to change the capacity or the operations of 

24 the airport, then you are required to use EDMS for 

25 your modeling. 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 210 

 2 It covers aviation sources, what you'd expect 

 3 at an airport, things like aircraft, auxiliary 

 4 power units, ground support equipment. 

 5 But then a lot of the other sources that you'd 

 6 also find at the airport that aren't directly 

 7 aviation related, so cars in parking lots and the 

 8 parking garages, the access roadways, any power 

 9 plants that are specific to the airport that are 

10 close by, fuel tanks, that kind of thing. 

11 This has some history, you can see that the 

12 roots of EDMS go back about twenty years; back when 

13 it was the Complex Source Microcomputer Model, and 

14 it's been updated over the years. 

15 And starting in 1991, is when it really became 

16 known as EDMS. And then with the 1997 release of 

17 EDMS three point 0 (3.0), it entered the Windows 

18 era and came with a graphical user interface. 

19 At the modeling conference in 2000, we talked 

20 about how we were getting ready to release EDMS 

21 four point 0 (4.0), and that it would be the first 

22 application of AERMOD within EDMS. 

23 And before, with the EDMS three series, we 

24 were using a combination of PAL2 and CALINE3. 

25 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 211 

 2 And now, 2005, we have just recently released 

 3 EDMS four point three (4.3), and we've got major 

 4 release of five point 0 (5. 0), if it works, and 

 5 I'm going to talk about both of those. 

 6 Terms of what you get out of EDMS for the -- 

 7 at the most basic level, intermissions inventory 

 8 can be generated for your airport. The data 

 9 sources that are used to allow that to happen are 

10 the ICAO exhaust emissions division data bank for 

11 jet aircraft engines. 

12 We also have some additional aircraft engine 

13 data that was supplied directly from the 

14 manufacturers, and then we interface with MOBILE to 

15 get the on-the-road vehicle emissions NONROAD for 

16 the NONROAD vehicle emissions; things like ground 

17 support equipment. 

18 And then AP forty-two (AP-42) also has quite a 

19 bit of emissions data in it. 

20 That all comes supplied as a set of systems 

21 tables that are used by EMS. Then in addition, 

22 what the user has to input are things like your 

23 fleet mix of aircraft, the specific aircraft engine 

24 combinations, the number of operations that you 

25 have, how long the aircraft has been taxiing or in 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 212 

 2 queue, and then on the automobile vehicle side, 

 3 points like the traffic levels, the parking lot 

 4 throughputs, speeds on the roadways, all those 

 5 things that would be required for running MOBILE. 

 6 And then finally the stationary source 

 7 operations. And in this case I'm talking 

 8 stationery sources, and we make a distinction in 

 9 EDMS that also discusses training fires -- training 

10 fires at the airport. 

11 Then as we transition into a dispersion 

12 analysis, you have to enter in all your airport 

13 layout information. These are your gates, your 

14 taxiways, the actual physical dimensions of the 

15 queues, and the dimensions of the runways. 

16 And then we provide an interface to AERMOD, 

17 AERMET and AERMAP. 

18 In terms of the recent developments, and for 

19 recent I'm talking about EDMS versions, four point 

20 two (4.2) and four point three (4.3), the last two 

21 releases. 

22 We expanded our pollutants that we report on 

23 by adding some built-in conversion factors to break 

24 out between HCs, VOCs, NMHCs, and then also a 

25 distinction between PM10 and PM two point five 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 213 

 2 (2.5). 

 3 A database repair function was added. This 

 4 was in the case that a lot of the dispersion runs 

 5 can take a very long period of time, and if you 

 6 have a power outage part way through, then you have 

 7 some kind of data base corruption, this provides a 

 8 means to recover from that, so you can keep moving 

 9 forward, and you don't lose everything and have to 

10 start over again. 

11 For the aircraft times in mode, we've done 

12 some analysis work with that. We are -- have 

13 transitioned to a performance-based calculations 

14 that just rely -- relying on the ICAO default 

15 kinds of mode for aircraft. 

16 And we've provided some enhancements for the 

17 ground support equipment models, realizing that 

18 people tend to be very interested in quantifying 

19 the impacts of transitioning to away from diesel 

20 equipment and maybe to CNG, LPG or electric 

21 equipment, and the change in that fleet mix and 

22 what the impact is going to be at the airport. 

23 We also provide a direct interface now to 

24 MOBILE5a, 5b, six point two (6.2), and the reason 

25 we did that was that depending on what version 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 214 

 2 MOBILE was used in the SIP, that would dictate what 

 3 we were going to use for EDMS, so we just provided 

 4 interface to all three of those. 

 5 We expanded our parking facility modeling to 

 6 include parking garages now. Before it could only 

 7 model parking lots, and people were having to do 

 8 some tricks with overlaying parking lots on top of 

 9 each other to create a model parking garage. 

10 That's all automated now. 

11 We've also enhanced our roadway and taxiway 

12 modeling. The stationary source modeling has been 

13 completely overhauled so that it is now basically, 

14 if you look at the air quality handbook and you 

15 look at all the parameters that are specified 

16 there, it is going to be duplicated exactly within 

17 EDMS. 

18 So, there's no ambiguity, there is no question 

19 as to what data elements are required. 

20 And we've made some changes to the dispersion 

21 model that we're going to touch on. 

22 I've already talked about the expanded 

23 pollutant report, and there's just a screen shot of 

24 an emissions inventory out of EDMS4.3, and it shows 

25 all those additional pollutants. 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 215 

 2 In addition to those pollutants you can now 

 3 choose the output units that you are interested in. 

 4 Previously, you were limited to only reporting your 

 5 emissions inventory in tons, and we realize that 

 6 some people that were modeling very small numbers 

 7 of operations that was really too coarse a detail. 

 8 And we've also added the ability to output in 

 9 metric as well as the English units. 

10 The database repair they discuss, just -- the 

11 main reason that it happens is because the header 

12 was getting corrupted, so that's how we targeted 

13 that. 

14 The aircraft times and mode, we are using the 

15 SAE eighteen forty-five (1845) performance 

16 methodology, and those of you that have done noise 

17 modeling will recognize that's about the same 

18 methodology that's used by INM, the Integrated 

19 Noise Model. 

20 And here's just some history that covers the 

21 transition from getting away from the ICAO times 

22 and mode for FAA projects to the current time 

23 period. 

24 EDMS four point three (4.3), by the way, 

25 allows you to switch back and forth, so if you have 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 216 

 2 a requirement to use those ICAO times and mode, 

 3 you can do so. 

 4 The GSE modeling enhancements, in addition to 

 5 what I mentioned earlier, with the different field 

 6 types, you can also look at the deterioration 

 7 factors, and that's thanks to the draft mode, 2004 

 8 edition. 

 9 And we, also, just from a user flexibility 

10 standpoint, added a function that will allow the 

11 users to easily rema- -- revert back to their 

12 default GSE assignments. Users that complained in 

13 the past that they did all this customizing for 

14 their airport, and then there is no easy way to 

15 roll back. 

16 Here's just a screen shot showing you that, 

17 yes, you can switch between the different versions 

18 of MOBILE. 

19 In terms of the way that we are handling the 

20 parking facilities, we are using vertically 

21 stacked AERMOD area sources to model the parking 

22 garages. 

23 The improvements that will be made to the 

24 roadways and taxiways, the first one was that in 

25 the older versions of EDMS, they were hard coded at 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 217 

 2 twenty meters wide, but realizing that not all the 

 3 airport access roads are the same width, they have 

 4 the same number of lanes, we allowed the user to 

 5 edit back to anything they wanted. And so, the 

 6 user can override the default setting or the twenty 

 7 meters that remains as the default. 

 8 This is a list of all the different types of 

 9 stationery sources that are covered. I'm not going 

10 to talk about these in detail other than you can 

11 see it's fairly comprehensive, and the user can 

12 specify which AERMOD source type to use to best 

13 represent their source. So we provide the base 

14 emission data, the user can edit any of the control 

15 parameters that you can see and then can also 

16 specify how it should be represented in AERMOD to 

17 best meet their needs. 

18 EDMS four point three (4.3) includes AERMOD 

19 zero two two two two (02222), and that also 

20 includes the PRIME and building downwash models, 

21 and we have created a new AERMOD wizard that's the 

22 air base. That's one of the screens there 

23 (projecting three different graphs). It is a 

24 four-step process that we walk users through. 

25 We also added an interface to the buildings 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 218 

 2 component of the AERMOD. You can see how -- what 

 3 our interface looks like. 

 4 On the AERMET side, we've updated our AERMET 

 5 wizard, and now it includes the database of met 

 6 stations so that you can actually just scan the 

 7 headers of your met file that you are providing and 

 8 give a best guess as, okay, this looks like it's 

 9 for this location, also looks like it's this time 

10 period, prevents a lot of user errors that way. 

11 We also do a lot of air checking along the 

12 way, so that you don't get all the way to the last 

13 step, and then run AERMET only to find out that it 

14 failed. 

15 And new in EDMS four point two (4.2), we added 

16 a user interface to AERMAP. Previously, users had 

17 to run that on their own. 

18 The big addition for EDMS four point three 

19 (4.3) is the addition of aircraft particulate 

20 matter, and those of you who have done aviation 

21 modeling realize that the ICAO engine emissions data 

22 bank doesn't include aircraft PMs. 

23 What it does include is smoke number, and 

24 using the equation that's shown there at the 

25 bottom, we have come up with a conservative 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 219 

 2 estimate of aircraft PM emissions based on that 

 3 smoke number value. 

 4 There are some caveats that only applies to 

 5 commercial jet engines, and it is really only 

 6 intended as just an interim way of -- of meeting 

 7 the PM compliance requirements. 

 8 While we are still working out those 

 9 compliances and the accuracy of PM measurement 

10 techniques. EDMS5 will be our next major release, 

11 and that's planned for next year. 

12 Some of the big things that we're changing, 

13 the first one is for supporting the application for 

14 airport emission reduction credit applications. 

15 And as you know, you have to run a range of years 

16 and a range of scenarios and then show the 

17 difference year by year for each one of those 

18 scenarios. 

19 In the previous versions of EDMS, such as 

20 EDMS4, you could only do a single year and a single 

21 scenario in that study. So, if you wanted to do a 

22 AERC application, you had to run EDMS over and over 

23 and over again and generate all those input files, 

24 it's very time consuming. 

25 Now, we offer kind of one-stop shopping for 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 220 

 2 that. You can store all your years, all your 

 3 scenarios all in one place and generate the report 

 4 for your emission reduction credit application 

 5 right at the end. 

 6 We are improving the way that we're doing the 

 7 flight profile generation. Before it was just a 

 8 static look-up table. Now we're going just 

 9 straight to the basic equations, and it's 

10 completely dynamic, and combining that with Boeing 

11 fuel flow method two, we can take the met data, 

12 figure out really what the engine thrust is going 

13 to be, and get a good feel for what the emissions 

14 are going to be out of that engine as opposed to 

15 just using static values. 

16 We are also improving the way that we look at 

17 Aircraft taxiing, and by defining the taxi path so 

18 users won't have to explicitly define little 

19 itty-bitty segments of taxiways. You can just do 

20 your airport layout, say I need to go from gate A 

21 via taxiways Bravo, Charlie and Delta; EDMS is 

22 going to figure out which parts of those taxiways 

23 the aircraft is going to use, and also it will 

24 figure out where the aircraft are going to get 

25 backed up in a queue automatically, so that reduces 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 221 

 2 a lot of the user input requirements. 

 3 And the way we are representing them in AERMOD 

 4 is enhanced also. We're using a lot more points, 

 5 we're defining curves in the roadways as opposed to 

 6 having roadways all at ninety (90) degree segments. 

 7 And all the segments are connected together. 

 8 We are also adding the ability to have a 

 9 one-way roadway. Previously all roadways were 

10 assumed to be bidirectional. 

11 And just so, you don't think we're doing all 

12 this in the vac- -- in a vacuum, we do have an EDMS 

13 design review group, and there are currently twelve 

14 (12) members. That's part of the EDMS DRG; 

15 representative from Government, FAA, and EPA, and 

16 Warren Peters is a member of our EDMS DRG. 

17 We have representatives from academia and also 

18 from industry. 

19 Their purpose is to recommend model 

20 enhancements, provide technical guidance for how to 

21 apply the model, review changes that we are making 

22 to the model, and we hold meetings, as required, 

23 whenever -- whenever there is a significant release 

24 coming up or if there's a major issue to discuss. 

25 But as Warren knows, there is a lot of 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 222 

 2 communication on the side, outside of just the 

 3 meeting. 

 4 Related to the EDMS5 development is this 

 5 larger vision that the FAA has which is the 

 6 aviation environmental design tool, also known as 

 7 AEDT, and its main function is to allow users to 

 8 assess the interdependencies between 

 9 aviation-related noise and emission. And they 

10 are starting out by incorporating today's tools 

11 which are EDMS, and SAE, which is a global 

12 emissions model, and then on the noise side, INM [ed. Integrated 

Noise Model] 

13 and MAGENTA. 

14 This is a five-year project that we're looking 

15 at, and it will be a phased approach, harmonizing 

16 data, and harmonizing the models. 

17 In summary, we've had a lot of enhancement 

18 that recently that improve the accuracy and user 

19 flexibility for EDMS. 

20 FAA is spending their monies researching for 

21 ways to better understand and characterize aviation 

22 emissions and improving their own EDMS modeling 

23 capability. 

24 We are going to, in the near future, have 

25 improved fidelity in our airport modeling 
 1 FAA/EDMS Development/Ted Thrasher Vol. 2, p. 223 

 2 capability, much increased user flexibility, and in 

 3 general, the EDMS is going to be a much stronger 

 4 tool. 

 5 Thanks for your time. 

 6 WARREN PETERS: For your information, Ted, and other members 

 7 of the audience, if you are running AERMOD in large 

 8 batch mode, lots of sources and lots of receptors, 

 9 we have a restart function within AERMOD. It's not 

10 well advertised, but we have been utilizing it on 

11 some of the toxic studies we've done in 

12 Philadelphia. 

13 I've never shared Ted's pain before in these 

14 large runs, but lately we have been doing AERMOD on 

15 a large scale, and I feel more for the EDMS needs. 

16 So there is a restart function in there. 

17 Also, I talked with Jesse Thé. Is Jesse still 

18 here? 

19 RUSSELL LEE: No, he had to leave early. 

20 WARREN PETERS: He had to leave. 

21 He has mentioned that he has AERMOD running in 

22 parallel. We have been working very hard at a 

23 frustrating level to get AERMOD to run in parallel 

24 with open MP. 

25 It has not worked well at all. He's actually 
 1 UARG/Cindy Langworthy Vol. 2, p. 224 

 2 go done to MPI which is a different way of doing 

 3 business in the parallel world, and apparently he's 

 4 been successful in doing it. 

 5 So, Jesse and I will hook up, and we'll talk 

 6 some more about it, but if it works as good as the 

 7 sales pitch, forgive me, Jesse, I'll get that back 

 8 out, and it will be announced in the web pages, so 

 9 we can have parallel opportunities. 

10 And as you know, today you can buy a 

11 relatively cheap PC and can run two, four, six, 

12 eight off-run processors on the mother board for 

13 only several thousand dollars. So this may be a 

14 very nice advantage to the way we do business in 

15 the future. 

16 That's an aside. I'm cutting into somebody's 

17 time. 

18 Next on the program here is Lucinda Langworthy. 

19 She's from Hunton and Williams, but representing 

20 the Utility Air Regulatory Group [ed.(UARG)]. 

21 LUCINDA LANGWORTHY: Thank you, Warren. I am Cindy 

 

22 Langworthy, and I am an attorney, not a modeler, so 

23 I'm not going to address the strengths and 

24 weaknesses of individual models. 

25 What I do want to talk about today, however, 
 1 UARG/Cindy Langworthy Vol. 2, p. 225 

 2 is the process for determining the requirements for 

 3 regulatory modeling and for informing the 

 4 regulated community of those requirements. 

 5 You probably all know this, but the individual 

 6 electric utilities, that are the members of UARG 

 7 frequently find that air quality modeling 

 8 determines how they will be permitted to operate 

 9 their plants. 

10 Recently, we've been using CALPUFF quite a 

11 bit, and in fact a model, or a suite of models that 

12 we really haven't talked about here a lot is the 

13 regional models that probably are something that 

14 needs to be folded into the general modeling 

15 concerns. 

16 But anyway, so, the UARG members are very 

17 interested in which models and modeling techniques 

18 are available, and how decisions are being made 

19 concerning which modeling approaches they will be 

20 required to use. 

21 And recently, they've been finding that it's 

22 very difficult to get this information. One 

23 example of this is the inaccessibility of the model 

24 clearing house which is, as the SCRAM web site 

25 notes, is intended to record information about 
 1 UARG/Cindy Langworthy Vol. 2, p. 226 

 2 referrals and discussions from EPA regional offices 

 3 involving the interpretation of modeling guidance 

 4 for a specific regulatory applications. And I have 

 5 actually had people tell me to look -- from EPA -- 

 6 to tell me to look there. 

 7 But, the model clearing house web site is only 

 8 useful if it is operating, and for sometime now it 

 9 has been impossible for the public, at least, to 

10 access the web site. The web site indicates work 

11 is in progress. Results are security issues. This 

12 work has apparently been "in progress" for 

13 sometime. 

14 (Chuckles.) 

15 Is there any schedule for making this valuable 

16 information once again available to the public, and 

17 I gather you heard that from AWMA. I don't know 

18 whether there is anything on the schedule. 

19 Another area of some frustration has been 

20 EPA's response when someone applying the model for 

21 a regulatory purpose has identified a problem with 

22 general applicability with that model and brought 

23 it to the Agency's attention. And even when a 

24 solution to the problem has been proposed, it does 

25 not appear that EPA has acted to correct the 
 1 UARG/Cindy Langworthy Vol. 2, p. 227 

 2 problem or even to advise the public of its 

 3 existence. 

 4 For example, these examples actually concern 

 5 the AERMOD model, and its associated data 

 6 processors, AERMAP and AERMET. 

 7 With regard to AERMAP, one member of UARG 

 8 advised EPA of two problems with the AERMAP model. 

 9 First they found that AERMAP did not apply a 

10 necessary scaling factor to the digital elevation 

11 terrain model files where the elevations were 

12 expressed in meters, although the model worked 

13 properly if the elevation was given in feet. 

14 In addition, some of the DEM files express 

15 elevation relative to a local offset, but AERMAP 

16 failed to adjust for the local offset. 

17 Neither of these problems resulted in an error 

18 message from AERMOD, yet each of them could affect 

19 the modeling results. And although the concerns 

20 were brought to EPA's attention almost eighteen 

21 months ago and code provisions needed to correct 

22 the problem were provided to EPA, it does not 

23 appear that corrections have been made. 

24 Another representative of another UARG member 

25 pointed out that when three integers were used in 
 1 UARG/Cindy Langworthy Vol. 2, p. 228 

 2 the liquid precipitation field of the HUSWO data, 

 3 AERMIC produced an error message, although HUSWO 

 4 allows three integers in the field. 

 5 The individual indicated to EPA that the model 

 6 would run, however, when the maximum hourly 

 7 precipitation value was no greater than ninety-nine 

 8 (99). In other words, two integers. Although EPA 

 9 acknowledged the issue in response, we've yet to 

10 see anything indicating that the Agency has done 

11 anything to correct it. 

12 And these are just examples that raise 

13 questions about how responsive EPA is being to 

14 issues raised by the public. And they, also, by 

15 the way, cause a little concern about whether EPA 

16 is validating the preprocessor components of its 

17 models as carefully as it is examining the 

18 dispersion model itself. 

19 The preprocessors are also key to model 

20 performance and should be rigorously tested before 

21 they are approved for general regulatory use. 

22 If EPA decides to change how the models are 

23 evaluated, as the Federal Register notes in 

24 announcing this conference suggested they might, 

25 UARG urges EPA to pay attention to how 
 1 UARG/Cindy Langworthy Vol. 2, p. 229 

 2 preprocessors are validated, and, of course, the 

 3 same care needs to be applied to postprocessors. 

 4 I don't have an example, but clearly one of 

 5 the post procedures is very important to UARG 

 6 members as the visibility component with CALPUFF. 

 7 And finally, I want to just express some 

 8 consternation about how this conference was planned 

 9 and has been conducted. Although we were aware 

10 that EPA might hold a modeling conference this 

11 fall, we did not have specific information about it 

12 until notice was published through the Federal 

 _______ 

13 Register on August 22nd. 

 ________ 

14 And that's the minimum amount of time 

15 necessary legally to announce a conference, but it 

16 doesn't give much time to prepare, and it didn't at 

17 that time provide any agenda or anything. 

18 And the Federal Register notice provided only 

 ________________ 

19 general information that EPA was considering to -- 

20 changes to some of the model practices; it did not 

21 specify about how these practices might change. 

22 And while UARG agrees that some aspects of the 

23 model practice highlighted in the Federal Register 

24 notice could, and perhaps should, be revised, the 

25 information in the Federal Register does not 
 1 UARG/Cindy Langworthy Vol. 2, p. 230 

 2 suggest what changes are under consideration. 

 3 Nor was more information available from the 

 4 SCRAM web site, that may have have changed now, 

 5 but it wasn't there yesterday, or from the EPA 

 6 docket. 

 7 So, you all really could not prepare very 

 8 substantive comments at this point on the changes 

 9 that were being selected -- suggested. And one 

10 example, if the Federal Register notice indicated 

 _______ ________ 

11 that EPA would present information on a, quote, new 

12 approach for updating or for revising models, and 

13 on alternative approaches for approved models, 

14 that's been discussed today. 

15 UARG has, in the past, suggested that EPA 

16 revise its approach to designating models that are 

17 acceptable to facilitate the use of the best models 

18 that are reasonably -- in an expeditious manner. 

19 And the example of AERMOD might be an example 

20 of why, perhaps, that needs to be done. 

21 But we had no information available to us, to 

22 allow us to evaluate what might be contemplated. 

23 So, the lack of specific information on the topics 

24 to be considered at this conference, as well as the 

25 siting of the conference down here, whereas in the 
 1 UARG/Cindy Langworthy Vol. 2, p. 231 

 2 past, it's been held in DC, which is a little more 

 3 central and high profile than this, and I must say 

 4 the scheduling of all the public speakers at the 

 5 after lunch on Friday when all the EPA invited 

 6 speakers had already completed their presentations, 

 7 did raise some questions as to whether EPA is truly 

 8 interested in hearing from others like the 

 9 regulatory community. 

10 But if the Agency is interested in hearing 

11 from the public, and we think it should be, then it 

12 needs to communicate that by making information 

13 more readily available in a timely manner and when 

14 it receives suggestions from the public, it should 

15 share its response to those suggestions. 

16 So what does UARG want? 

17 UARG wants reasonable notice about what 

18 modeling techniques EPA will require and how those 

19 techniques will be selected as well as reasonable 

20 responsiveness to suggestions from the regulatory 

21 community for improving model performance. 

22 Are there things that have been presented here 

23 that UARG members favor? There probably are, but 

24 since we have just learned of the EPA's proposals 

25 for the issues that EPA is considering, we will 
 1 API/Ken Steinberg Vol. 2, p. 232 

 2 have to respond to them more fully in writing after 

 3 a reasonable period for a meaningful consideration. 

 4 Thank you very much. 

 5 WARREN PETERS: Thank you, Cindy, I think. 

 6 (Chuckles.) 

 7 Next on our program this afternoon, we have a 

 8 fifteen minutes scheduled for Ken Steinberg, from 

 9 API. 

10 Ken, I believe you have some slides. 

11 KEN STEINBERG: Yes. 

 

12 Okay. My name is Ken Steinberg. I'm 

13 appearing here on behalf of API. 

14 I wanted to set the stage by saying that API 

15 has a strong interest in the revisions to the 

16 guidelines on air quality models. 

17 We have that belief because the models used 

18 frequently by companies, oil companies and natural 

19 gas companies, and been used in a host of 

20 regulatory applications, including some that are 

21 somewhat different insofar as what the guideline 

22 was originally intended. 

23 It was an area for residual risk. 

24 And our goal is that we are looking for 

25 scientifically sound models, so that they -- they 
 1 API/Ken Steinberg Vol. 2, p. 233 

 2 can be used for regulatory purposes. 

 3 I'm going to summarize some of the API 

 4 concerns regarding performance with AERMOD, and 

 5 this is based on reviewing two EPA reports that are 

 6 shown here; AERMOD: latest features and evaluation 

 7 results, June, 2003, and the comparison of 

 8 regulatory design concentrations, AERMOD versus 

 9 ISCST3, and some other models that were also 

10 published in June of 2003. 

11 The summary of our concerns are on this slide; 

12 the analysis that we were -- that I am going to 

13 share with you that -- that's been done by API 

14 focused on annual results, and was limited to those 

15 sources that dealt with area and volume. 

16 And in particular we found that the 

17 urban/rural performance of AERMOD is not consistent 

18 with that of ISC, and that AERMOD appears to 

19 appreciably over-predict majority of concentrations 

20 throughout modeling domain that would be of 

21 interest in residual risk modeling. 

22 And I'll show you some more about that. 

23 First, for the rural/urban performance issue, 

24 we examined the flat and simple terrain simulations 

25 that were done in the -- in the report, that dealt 
 1 API/Ken Steinberg Vol. 2, p. 234 

 2 with the regulatory concentrations. 

 3 It dealt with two meteorological data sets; 

 4 Pittsburgh, 1964, and Oklahoma City, 1984. Various 

 5 source configurations were included, including the 

 6 area and volume source, and a standard and 

 7 consistent receptor array was used. 

 8 A simple analysis that we did does not show 

 9 that the AERMOD treatment of enhanced dispersion 

10 occurs for urban areas that were traditionally 

11 observed in ISC. 

12 (Projecting slide.) 

13 And this is a table that was taken, or data 

14 taken, out of Appendix B of that report for area 

15 sources. And I don't want to point anybody with 

16 this (indicating laser pointer), but what I'm 

17 really talking about is as you can see in this 

18 column under ISC for rural, and this is the rural 

19 area source, flat terrain for Oklahoma City, and 

20 this is for Pittsburgh, and then this is, of 

21 course, the urban -- these are the annual 

22 concentrations that were reported, and what we can 

23 see here is an average of those values. 

24 Similarly, a substantially lower values for 

25 urban setting and the average there. 
 1 API/Ken Steinberg Vol. 2, p. 235 

 2 If we look at the comparison between the ISC 

 3 for the averages, we can see that there is an 

 4 appreciable lower concentrations as you move from a 

 5 rural to an urban area for the same source for the 

 6 same area source. 

 7 When we go to AERMOD, we can see that there 

 8 is, again, the same layout on the table where we 

 9 have concentrations where the two meteorological 

10 regimes and an average and similarly for the urban 

11 areas, and when we look at those averages, we see a 

12 substantially lower concentration than we -- 

13 substantially different or lower difference in 

14 concentration, so there seems to be quite a bit 

15 less dispersion going on from the rural setting to 

16 the urban setting. 

17 A few other items that I'd like to point out 

18 that are interesting from the behavior of the -- 

19 between the ISC and AERMOD is that when we look at 

20 within a rural area, there is a fair bit of 

21 enhanced dispersion going on in AERMOD, as we 

22 compare it to the concentrations that were shown 

23 for ISC. 

24 But when we go into an urban area, we see 

25 almost like a reverse behavior where the 
 1 API/Ken Steinberg Vol. 2, p. 236 

 2 concentrations are actually higher for AERMOD than 

 3 they were for ISC in urban areas, which -- which 

 4 looks a little odd, and similarly when we go across 

 5 to here. 

 6 (Projecting slide.) 

 7 This next slide just kind of summarizes those 

 8 points, where we are seeing in the first point a 

 9 significant increase in dispersion, from rural to 

10 urban, between ISC and AERMOD, and just in this 

11 ratio which is the ISC to the AERMOD 

12 concentrations, the factor of dilution is about two 

13 point three (2.3), to two point four (2.4). 

14 In AERMOD we see a minimal increase where the 

15 dilution is about a ratio of one point one (1.1), 

16 and then, of course, in the -- excuse me -- and 

17 recognize it. 

18 In AERMOD we're seeing an increase in -- in 

19 the dispersion, and for urban settings, we -- we 

20 see a decrease in the dispersion, which again, 

21 we're -- we're asking, is -- is all of this 

22 behavior reasonable? 

23 It's certainly somewhat different from what we 

24 are accustomed to. 

25 (Projecting slide.) 
 1 API/Ken Steinberg Vol. 2, p. 237 

 2 This next slide shows data taken for volume 

 3 sources out of the same report and is basically set 

 4 up the same way, and I'll try to just kind of 

 5 highlight again the ratio that we are seeing 

 6 between concentrations for rural and for urban. 

 7 Between the two models we're seeing some enhanced 

 8 dispersion going on in the urban setting for ISC. 

 9 But for AERMOD, we're -- we're not seeing 

10 that. In fact we are seeing somewhat -- just a 

11 very small amount of change in concentration. 

12 (Projecting slide.) 

13 And this next setting puts it in pretty much 

14 the same terms as the -- for the area sources, 

15 where we're seeing some increase in dispersion from 

16 the rural to urban, but the ratio there for volume 

17 sources is on the order of one point four (1.4), 

18 where contrasting it was around two point four 

19 (2.4) for area sources. 

20 In AERMOD the minimum increase in dispersion 

21 for volume sources have -- show again it's a ratio 

22 of about one point one. 

23 And then for rural settings, and this was 

24 looking across the concentrations between ISC and 

25 AERMOD, there is actually a decrease in dispersion 
 1 API/Ken Steinberg Vol. 2, p. 238 

 2 from ISC to -- to AERMOD; that is, we're -- we're 

 3 seeing an opposite behavior, and for urban 

 4 settings, we are seeing a slightly decrease. 

 5 So for volume sources, though this behavior is 

 6 somewhat smaller, it's again clear that volume 

 7 sources, their behavior is supported by data or 

 8 just an unintentional product of the modifications 

 9 to AERMOD. 

10 (Projecting slide.) 

11 In moving to the next point in API comments, 

12 and this is the over-prediction of the majority of 

13 the concentrations throughout the modeling 

14 domain. 

15 Again, the -- the key concern here is as this 

16 model might be applied to residual risk 

17 assessments, and in residual risk assessments, the 

18 model predictions throughout the entire 

19 concentration of the domain, not just the highest 

20 or second highest are of great interest. 

21 Now this figure is again taken out of EPA 

22 report, and focusing on what is the red signals 

23 here, we are seeing relatively good at bringing 

24 that up through the higher end of the regime, but 

25 as we get to the lower range, it starts becoming 
 1 API/Ken Steinberg Vol. 2, p. 239 

 2 biased quite substantially to over-predict, and our 

 3 concern is that this over-prediction will be 

 4 magnified in residual risk assessments. 

 5 And this is for the American Gas Association 

 6 data. It's a small research firm in -- with some 

 7 gas engine compressors where the exhaust -- the 

 8 exhaust, I think, was spiked with some 

 9 sulfur hexafluoride. 

10 (Projecting slide.) 

11 And this is just kind of a series of 

12 highlights of what we are concerned about; the 

13 AERMOD predictions and concentrations are poor 

14 throughout most of the concentration domain. 

15 AERMOD significantly over-predicts the lowest 

16 range of observed concentrations, and it suggests 

17 these over-predictions for the annual averages that 

18 are used in risk assessment. 

19 And this is another case that was in the 

20 evaluation report for the Alaska North Slope. And 

21 again in the similar way, although not as dramatic 

22 as in the first, we are again seeing that there is 

23 tending to be a bias for its over-prediction in the 

24 lower range of the concentrations, although this is 

25 much better than in the first comparison. 
 1 API/Ken Steinberg Vol. 2, p. 240 

 2 But still it would indicate that there is a 

 3 trend toward over-prediction, perhaps by as much as 

 4 fifty percent (50%). 

 5 And again this behavior of over-prediction is 

 6 likely to cause risk assessment results to be 

 7 biased. 

 8 So in conclusion -- the conclusions from this 

 9 and a few recommendations. 

10 The API analysis results, again for annual and 

11 for area and volume sources, appear to show that 

12 urban/rural performance of AERMOD is not consistent 

13 with that of ISC. It's not apparent whether this 

14 behavior, in some cases dramatic, is supported by 

15 data. 

16 It appears that AERMOD appreciably 

17 over-predicts the majority of the concentrations 

18 throughout the modeling regime for some of the data 

19 sets. 

20 We think that EPA should examine the area of 

21 volume source performance. 

22 Previous evaluations show good agreement, for 

23 concentrations at the highest end of the 

24 distribution, but show poorer agreement over the 

25 remainder of the concentration domain. 
 1 API/Ken Steinberg Vol. 2, p. 241 

 2 This performance could cause annual 

 3 concentrations using risk assessment to be 

 4 over predicted. 

 5 EPA should investigate both urban performance 

 6 and the distribution of predictions before 

 7 requiring use of AERMOD for area and volume 

 8 sources. 

 9 And API believes that the concern regarding 

10 model performance here suggests, at a minimum, the 

11 grandfathering period of ISC should be extended to 

12 allow these concerns to be technically addressed. 

13 That's really the extent of my comments, or 

14 API's comments. 

15 WARREN PETERS: Thank you, Ken. 

16 The last presentation on the program this 

17 afternoon is from Robert Paine of ENSR. 

18 ROBERT PAINE: What about Steve -- 

19 WARREN PETERS: Steve couldn't get his presentation together. 

20 It wouldn't work. He's going to send that to us 

21 separate. 

22 Can you give me your comments here, Bob? 

23 ROBERT PAINE: Okay, I'll do that. 

24 WARREN PETERS: Thank you. 

25 
 1 AWMA/AB3/Robert Paine Vol. 2, p. 242 

 2 

 3 ROBERT PAINE: I'm Robert Paine, ENSR. 

 

 4 And by the way, just to address one of Ken's 

 5 issues with the QQ plots, one of my initial 

 6 thoughts on the lower end of the concentrations is 

 7 that the observations are a little uncertain there. 

 8 You're down to the -- to the threshold of detection 

 9 limits on your monitors, and therefore, we're not 

10 sure if we trust the observations of that part of 

11 the distribution. 

12 So that -- and -- and another issue is, how 

13 much do those concentrations contribute to the 

14 annual average. It would be interesting to know if 

15 that's twenty percent (20%), fifty percent (50%) or 

16 whatever. 

17 So those two issues may be -- if you look at 

18 it some more, the model may be doing better, 

19 because we are not sure about the observations 

20 validity, and we also may not be concerned about a 

21 huge part of the annual average integrated amount 

22 from those type -- from that part of the 

23 distribution. 

24 Anyway, let me go -- let me do -- I have a few 

25 things to talk about. One is regional models that 
 1 AWMA/AB3/Robert Paine Vol. 2, p. 243 

 2 Cindy Langworthy touched on. 

 3 Let's see (searching for computer/screen 

 4 control). Okay, thanks. 

 5 Basically comments on a Lagrangian and 

 6 Eulerian long-range transport and regional models. 

 7 First of all, the guideline doesn't really 

 8 address, that is Appendix W, does not address how 

 9 to model with regional or Eulerian models. 

10 I want to talk about the best uses for 

11 Lagrangian versus Eulerian models, and where does 

12 EPA go from here, if it goes anywhere? 

13 Is there a need for regional models? 

14 Obviously, sort of like there is an elephant in the 

15 room, and the elephant is that the two most 

16 problematic issues for nonattainment of criteria 

17 pollutants are ozone and PM two point five (2.5). 

18 They involve multiple precursors and complex 

19 chemistry and transport almost makes this whole 

20 conference a minor point, because everyone is 

21 worrying about ozone and PM2.5. 

22 And the current models mentioned in 40CFR PART 

23 51, Appendix W, do not address these models really 

24 adequately at all. 

25 Obviously the pollutants are important due to 
 1 AWMA/AB3/Robert Paine Vol. 2, p. 244 

 2 widespread and large nonattainment areas and the 

 3 scale of the emission changes are going to be 

 4 required to address these as massive. Also, 

 5 there's just been a proposed procedure for 

 6 implementation of the PM-2.5 standard. It does 

 7 mention on upcoming future increments PM -- the 

 8 increments for PM-2.5, so how's that going to be 

 9 matched? 

10 Well, that's part of the Lagrangian Models, 

11 such as CALPUFF and SCIPUFF. Compute the change of 

12 concentration following a puff or a parcel as it's 

13 affected by the wind. And they're more suitable 

14 for individual sources. 

15 They could be run for hundreds of sources, but 

16 for a typical PSE, project single source, they are 

17 the most suitable for long-range transport. 

18 Their chemistry treatment is somewhat limited. 

19 Ozone can't be modeled, because of complex 

20 interactions. 

21 PM two point five (2.35) can be modeled to 

22 some extent. 

23 Eulerian models are a different breed in that 

24 you have various grid cells and the total 

25 concentrations is obtained relative to this fixed 
 1 AWMA/AB3/Robert Paine Vol. 2, p. 245 

 2 grid of cells, and the pollutant concentrations in 

 3 -- and meteorological variables are defined in each 

 4 grid point. 

 5 When you try to model an individual source of 

 6 these models, though, you -- you get an 

 7 instantaneous pseudo-dilution of the point source 

 8 into the grid cell that it happens to be in. 

 9 So it is not suitable for near-field impacts 

10 at all. 

11 Obviously, as you get to large grid cells, 

12 you're covering large areas, this -- this problem 

13 becomes even more acute, and you have to go down 

14 to very small grid cells if you are going to stay 

15 with the Eulerian approach to model single 

16 sources. 

17 And these approaches are most suitable when 

18 you have complex emissions, nonlinear chemical 

19 conversions involved for large distances, which are 

20 certainly involved with ozone and regional PM two 

21 point five (2.5) rather than near-field point 

22 specific PM two point five (2.5) issues. 

23 There is not -- I don't know if there is any 

24 approved pathway for how to prescribe whether a 

25 particular regional Eulerian model is approved for 
 1 AWMA/AB3/Robert Paine Vol. 2, p. 246 

 2 use. We seem to be focusing on CAMx and CMAQ in 

 3 general practice throughout the United States. 

 4 There have been evaluation studies, I don't 

 5 know if there is a system for determining 

 6 acceptable criteria for approving these models, but 

 7 it would be nice to have that. 

 8 They are very complex and intensive models, 

 9 and only a few groups will be running them in 

10 practice. I think they're uncertainty in 

11 sensitivity to uncertainties of input in and -- and 

12 various model options need review. 

13 And as with other main models, their accuracy 

14 is good in some areas, poor in others. I remember 

15 a presentation by Ralph Morrison, how good are the 

16 models, and he shows a nice graph. 

17 And then the next slide is, how poor are the 

18 models? The same model run; just another day. 

19 They were just terrible so -- you know -- and they 

20 have good days and they have bad days like most of 

21 us. 

22 (Chuckles.) 

23 Continuous work on a consistent evaluation 

24 approaches is really recommended, some of the 

25 short-range models, especially if we get the PM two 
 1 AWMA/AB3/Robert Paine Vol. 2, p. 247 

 2 point five (2.5), PSE increments. 

 3 What is a source to do if it has to do a 

 4 cumulative analysis? You can't -- I don't know if 

 5 you could run CALPUFF, or you certainly can't run 

 6 AERMOD to get secondary particulate formation. 

 7 I hope EPA is thinking about this. 

 8 That's the end of that presentation. I have a 

 9 couple of other. 

10 Yesterday, I brought up the issue of this NOAA 

11 ready model. I just wanted to follow that up with 

12 a couple of follow-up things here. 

13 (Projecting slide.) 

14 I found where you can find it. 

15 There, at the top of the slide -- it will 

16 probably be provided in the notes here. It's www 

17 dot arl dot noaa dot gov slash ready slash hysplit 

18 four dot html 

19 (www.arl.noaa.gov/ready/hysplit.4/html) [ed. current active link: 

http://www.arl.noaa.gov/ready.php]. 

20 This is the opening page. You have to have a 

21 user agreement to run this, but I was able to get 

22 it, but I don't know my password or even in the 

23 office, so I wasn't able to work it yesterday, but 

24 the next thing is, you can run a multiple of 

25 HYSPLIT, which I guess is some long-range transport 
 1 AWMA/AB3/Robert Paine Vol. 2, p. 248 

 2 model, and there is an area on the web site that 

 3 describes it. 

 4 You can run it anytime you want with either 

 5 archive data or with real time forecast data, 

 6 registration being required, that even if there is 

 7 a volcanic eruption, I guess you can run it, too. 

 8 But the nice thing about it is it's ready. It's 

 9 ready for use any time. I don't know if the 

10 computers or like foolproof in terms of crashing, 

11 but the nice thing about it is it's a NOAA product, 

12 and you can actually put in a -- a point on the 

13 earth and put in an emission characteristic, and it 

14 will produce a prediction for you. 

15 And I'm going to show you an example of what 

16 it looks like in my last presentation. 

17 We had to do this for a case in which there 

18 was a purging of a natural gas line, and we had to 

19 warn people if there was going to be a real stink 

20 about it, if you will, literally. 

21 (Chuckles.) 

22 So we use it as a forecast tool, and we 

23 basically -- the model comes out with a movie and 

24 even projects -- you give it a latitude and 

25 longitude, and it will automatically put down 
 1 AWMA/AB3/Robert Paine Vol. 2, p. 249 

 2 background map and ranges of distances and run the 

 3 model and within like a minute or two give you this 

 4 graphic. 

 5 Why can't we do this with CALPUFF and AERMOD, 

 6 is my question. Maybe one NOAA outfit should talk 

 7 to another NOAA outfit and try to link these models 

 8 together, because these -- these models are linked 

 9 continuously to the latest ETA and, I guess, what 

10 is it called now -- 

11 FROM THE AUDIENCE: WRF -- 

12 ROBERT PAINE: Well, no, there is another name for the ETA 

13 model, but the latest NOAA products, NOAA forecast 

14 products, are linked to this system, and you can 

15 run a dispersion model any time you want for any 

16 place, maybe on the face of the earth, or at least 

17 in the United States and get a prediction. 

18 And we were able to tell with this which way 

19 was the wind blowing in case something happened. 

20 It would be nice to have EPA talk to, you 

21 know, the NOAA people at EPA talk to the NOAA 

22 people at -- you know -- Rowland Draxler, and his 

23 associates to see if there could be some links with 

24 some of the EPA advance models. 

25 And that's all I have to say. 
 1 AWMA/AB3/Robert Paine Vol. 2, p. 250 

 2 WARREN PETERS: I believe that concludes our workshop. Are 

 3 there any other comments at this second? 

 4 We do have a little bit more time. It's a 

 5 quarter of three. 

 6 Any other last second comments? 

 7 (No response.) 

 8 WARREN PETERS: All right, I want to thank everyone for all 

 9 their time and effort on this. Obviously this 

10 takes a lot of time and thought. 

11 We've asked for that cooperation from you, and 

12 this coming year, I realize is a bit of piece of 

13 work. And many of you have come from great 

14 distances, so I believe this has been a successful 

15 interchange of ideas, and we do thank you for your 

16 time and effort in being here. 

17 Thank you. 

18 _____________________________________________________________ 

19 (WHEREUPON, THE CONFERENCE WAS CONCLUDED AT 3:50 P.M.) 

20 _____________________________________________________________ 

21 

22 

23 

24 

25 
 Vol. 2, p. 251 

 C E R T I F I C A T E 

 _____________________ 

 

 I, Manie P. Currin, Court Reporter and Notary 

 Public in and for the State of North Carolina, duly 

 commissioned, qualified and authorized to take and 

 certify hearings, do hereby certify that on Friday, 

 September 23, 2006, I stenographically reported the 

 foregoing conference hearing at the time and place 

 aforesaid, and that same was reduced to typewritten form 

 under my direct supervision; that the transcript 

 contained herein, pages 1-251 inclusive, is a true and 

 correct transcription of said proceedings to the best of 

 my ability and understanding; that I am not related to 

 any of the parties to this action; that I am not of 

 counsel; and that I am not interested in the event of 

 this cause. 

 IN WITNESS WHEREOF, I have hereunto set my hand 

 and affixed my official Notarial seal, this the 25th day 

 of March, 2006. 

 _______________________________ 

 NOTARY PUBLIC 

 

 My Commission expires: 7-16-06 

 

 

 

 

 

 

 Manie P. Currin and Associates 

 Court Reporters 

 203 East Industry Drive - Suite C 

 Oxford, North Carolina 27565 

 Telephone: (919) 693-6954 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 252 

 2 KEYWORD INDEX 

 _____________ 

 3 

 4 1. AERMAP 21. concentration 

 5 2. AERMET 22. concentrations 

 6 3. AERMOD 23. data 

 7 4. AERSCREEN 24. database 

 8 5. air 25. databases 

 9 6. albedo 26. default 

10 7. algorithm 27. DEM 

11 8. algorithms 28. dispersion 

12 9. appendix 29. domain 

13 10. atmosphere 30. downwash 

14 11. boundary 31. downwind 

15 12. Bowen 32. EPA 

16 13. calm 33. ETA 

17 14. CALMET 34. Federal 

18 15. CALPUFF 35. file 

19 16. cell 36. files 

20 17. cells 37. forecast 

21 18. Class I 38. forecasts 

22 19. clearing house 39. gridded 

23 20. complex 40. group 

24 

25 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 253 

 2 KEYWORD INDEX 

 _____________ 

 3 

 4 41. groups 61. modeler 

 5 42. guidance 62. modelers 

 6 43. guide 63. modeling 

 7 44. guideline 64. Monin-Obukov 

 8 45. guidelines 65. monitor 

 9 46. implement 66. monitors 

10 47. implementation 67. near-field 

11 48. implementing 68. No Obs 

12 49. ISC 69. NOAA 

13 50. ISC-PRIME 70. NWS 

14 51. layer 71. OAQPS 

15 52. layers 72. observations 

16 53. mesoscale 73. observed 

17 54. met 74. Obukov 

18 55. meteorological 75. ozone 

19 56. mixing 76. parameter 

20 57. MM5 77. parameters 

21 58. model 78. particle 

22 59. Model Clearing House 79. plume 

23 60. model evaluation 80. PRIME 

24 

25 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 254 

 2 KEYWORD INDEX 

 _____________ 

 3 

 4 81. processors 101. SCRAM 

 5 82. profile 102. screening 

 6 83. promulgated 103. sensitivity 

 7 84. promulgation 104. service 

 8 85. protocol 105. site 

 9 86. protocols 106. slope 

10 87. PSD 107. source 

11 88. puff 108. speed 

12 89. ratio 109. stack 

13 90. ratios 110. stacks 

14 91. receptor 111. statistical 

15 92. regime 112. steady state 

16 93. regimes 113. surface 

17 94. regulatory 114. terrain 

18 95. RUC 115. toxic 

19 96. rule 116. tracer 

20 97. run 117. turbulence 

21 98. rural 118. urban 

22 99. scale 119. variability 

23 100. scaling 120. weather 

24 

25 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 255 

 2 KEYWORD INDEX 

 _____________ 

 3 

 4 121. wind 141. 

 5 122. wind speed 142. 

 6 123. winds 143. 

 7 

 8 

 9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 256 

 2 

 3 Page Ref No. Keyword = "AERMAP" 

 4 ____ _______ __________________ 

 5 

 6 188 3 thirty-meter (30m) files and AERMAP reads those. 

 7 188 4 At the present, AERMAP does not read the ten-meter 

 8 188 8 of upgrading AERMAP to accept these, and we 

 9 212 17 AERMET and AERMAP. 

10 218 16 a user interface to AERMAP. Previously, users had 

11 227 6 processors, AERMAP and AERMET. 

12 227 7 With regard to AERMAP, one member of UARG 

13 227 8 advised EPA of two problems with the AERMAP model. 

14 227 9 First they found that AERMAP did not apply a 

15 227 15 elevation relative to a local offset, but AERMAP 

16 

17 Page Ref No. Keyword = "AERMET" 

18 ____ _______ __________________ 

19 

20 192 25 because we have this table in the AERMET manual 

21 193 9 bit more than anything that appears in the AERMET 

22 194 14 AERMET, and -- or the AERMET documentation 

23 194 24 With AERMET'S ability to use on-site data, 

24 194 25 there is in AERMET just a whole list of codes of 

25 195 7 AERMET and which variables only look like they are 

26 212 17 AERMET and AERMAP. 

27 218 4 On the AERMET side, we've updated our AERMET 

28 218 13 step, and then run AERMET only to find out that it 

29 227 6 processors, AERMAP and AERMET. 

30 

31 Page Ref No. Keyword = "AERMOD" 

32 ____ _______ __________________ 

33 

34 7 15 AERMOD is no ISC. 

35 7 16 AERMOD and CALPUFF open up a whole new area of 

36 8 15 The first two sessions, AERMOD implementation 

37 13 19 AERMOD. And it will be completed -- it's intended 

38 14 23 future in AERMOD analysis. There are going to be 

39 21 8 dispersion to AERMOD-like dispersion, we also 

40 43 24 AERMOD and one of these for myriad of other model 

41 44 6 analysis tool for CALPUFF and one for AERMOD. I 

42 45 17 process for models like AERMOD arise here in the 

43 46 3 modified AERMOD over the last five years, we have 

44 46 13 same sim- -- similar kinds for the AERMOD 

45 47 3 this version of AERMOD, for instance, and we are 

46 48 18 now that AERMOD and CALPUFF have been accepted for 

47 61 23 AERMOD or CALPUFF or some other model into the 

48 63 3 ROBERT PAINE: (Interposing) Well, AERMOD -- AERMOD's 

49 63 12 because of the -- by virtue of AERMOD being the new 

50 63 19 AERMOD. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 257 

 2 

 3 Page Ref No. Keyword = "aermod" 

 4 ____ _______ __________________ 

 5 

 6 75 21 AERMOD evaluation databases have been put up on 

 7 81 11 AERMOD, so that he's written a number of reports 

 8 81 13 for AERMOD, so he has extensive experience, really, 

 9 81 20 period for ADMS and has compared it to AERMOD and 

10 82 19 AERMOD. 

11 85 25 been used to look at AERMOD and -- in the USA here. 

12 86 7 AERMOD, so I would make it a plea that when 

13 91 6 gone through with AERMOD, now we ran seventeen 

14 91 11 which AERMOD is going to be applied. 

15 91 19 helps us to understand that not only does AERMOD 

16 92 17 were -- where AERMOD and other models have never 

17 102 15 process of ISC and -- and AERMOD, even. I'd like 

18 108 4 know, CALPUFF or AERMOD or whatever, it's still 

19 110 24 model that didn't deal with the AERMOD type models 

20 116 11 AERMOD's coming, AERMOD's coming, AERMOD's 

21 116 13 People are using AERMOD, people need to be 

22 116 14 using AERMOD, people probably should have been 

23 116 15 using AERMOD for a long time, and I don't feel 

24 125 14 databases for AERMOD, and we need other databases 

25 126 6 like AERMOD be -- be approved. 

26 129 7 AERMOD. Suppose they had to learn other models. 

27 131 12 with AERMOD, perhaps because not all the models out 

28 134 10 line, because AERMOD, and we've already discussed 

29 134 11 this, that AERMOD and CALPUFF are really quite 

30 137 22 And then finally we ended up using AERMOD just 

31 138 6 AERMOD, and so the customer was happy, and we were 

32 138 9 compare to AERMOD? 

33 138 11 compared ISC, AERMOD, and ADMS. And I won't go 

34 138 22 AERMOD was significantly improved over ISC, there 

35 139 24 and have demonstrated that AERMOD or ADMS is 

36 141 12 I will say, though, that with AERMOD, even 

37 141 23 we're going to go with AERMOD, and we've been going 

38 142 5 -- on how we should do AERMOD. 

39 142 7 went with AERMOD, and I -- I request -- I recommend 

40 142 16 I make the request to use AERMOD in a particular 

41 142 24 use of AERMOD. 

42 143 4 how -- how different AERMOD was from ISC was such a 

43 143 12 good as AERMOD, we'll have to learn that model, 

44 144 6 started AERMOD, and they are waiting for the 

45 144 15 different, and with the AERMOD that really comes 

46 145 16 both CALPUFF and AERMOD -- 

47 145 22 AERMOD and CALPUFF, and that's been quite 

48 147 23 CALPUFF, AERMOD, ISC3, CT screen, you know, IGM 

49 149 6 CALPUFF or AERMOD, is a public input process. 

50 150 15 So it's clear that even AERMOD and CALPUFF 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 258 

 2 

 3 Page Ref No. Keyword = "aermod" 

 4 ____ _______ __________________ 

 5 

 6 154 20 sure it does far better than AERMOD, and there 

 7 154 21 are -- there're circumstances where AERMOD does 

 8 155 10 AERMOD when there is -- when there is a 

 9 156 18 I mean, AERMOD is -- you know -- there's no 

10 156 19 reason why AERMOD has to be the preferred model, if 

11 170 20 Is there a need kind of rule in AERMOD or ISC 

12 171 16 AERMOD. 

13 172 2 But there are tools in AERMOD to help you get 

14 174 9 Petersen, AERMOD to be given by Russ Lee and 

15 174 25 really supplement routine models such as AERMOD for 

16 182 5 layer theory much like what's in the AERMOD right 

17 183 20 considered in AERMOD, and they may be really 

18 186 21 Committee, to offer our comments on AERMOD. 

19 186 24 AERMOD, I have my AWMA hat on today, and am serving 

20 187 2 AERMOD -- comments on the AERMOD. 

21 187 4 Committee of AERMOD are favorable. 

22 187 17 addressed as AERMOD comes into use. 

23 189 6 schedule for promulgation of AERMOD. (Chuckles 

24 189 20 be used after EPA, after AERMOD becomes an EPA 

25 190 24 AERMOD code. 

26 191 15 AERMOD, and this is to make sure that people don't 

27 192 2 One of the nice things about AERMOD is you can 

28 196 3 but we encourage the prompt release of AERMOD. We 

29 199 11 Russ give for AERMOD, we also want EPA to provide 

30 201 15 appropriate and not appropriate to use AERMOD. 

31 203 18 AERMOD-like dispersion; a concern. A number 

32 204 4 AERMOD-like dispersion on a number of permitting 

33 204 12 status of using or not using the AERMOD-like 

34 207 9 AERMOD-like dispersion. 

35 208 15 presentations by Bob Paine of AERMOD, and Joe 

36 210 22 application of AERMOD within EDMS. 

37 212 16 And then we provide an interface to AERMOD, 

38 216 21 stacked AERMOD area sources to model the parking 

39 217 12 specify which AERMOD source type to use to best 

40 217 16 specify how it should be represented in AERMOD to 

41 217 18 EDMS four point three (4.3) includes AERMOD 

42 217 21 and we have created a new AERMOD wizard that's the 

43 218 2 component of the AERMOD. You can see how -- what 

44 221 3 And the way we are representing them in AERMOD 

45 223 7 of the audience, if you are running AERMOD in large 

46 223 9 we have a restart function within AERMOD. It's not 

47 223 14 large runs, but lately we have been doing AERMOD on 

48 223 21 He has mentioned that he has AERMOD running in 

49 223 23 frustrating level to get AERMOD to run in parallel 

50 227 5 the AERMOD model, and its associated data 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 259 

 2 

 3 Page Ref No. Keyword = "aermod" 

 4 ____ _______ __________________ 

 5 

 6 227 18 message from AERMOD, yet each of them could affect 

 7 230 19 And the example of AERMOD might be an example 

 8 233 4 concerns regarding performance with AERMOD, and 

 9 233 6 shown here; AERMOD: latest features and evaluation 

10 233 8 regulatory design concentrations, AERMOD versus 

11 233 17 urban/rural performance of AERMOD is not consistent 

12 233 18 with that of ISC, and that AERMOD appears to 

13 234 9 that the AERMOD treatment of enhanced dispersion 

14 235 7 When we go to AERMOD, we can see that there 

15 235 19 between the ISC and AERMOD is that when we look at 

16 235 21 enhanced dispersion going on in AERMOD, as we 

17 236 2 concentrations are actually higher for AERMOD than 

18 236 10 urban, between ISC and AERMOD, and just in this 

19 236 11 ratio which is the ISC to the AERMOD 

20 236 14 In AERMOD we see a minimal increase where the 

21 236 18 In AERMOD we're seeing an increase in -- in 

22 237 9 But for AERMOD, we're -- we're not seeing 

23 237 20 In AERMOD the minimum increase in dispersion 

24 237 25 AERMOD, there is actually a decrease in dispersion 

25 238 2 from ISC to -- to AERMOD; that is, we're -- we're 

26 238 9 to AERMOD. 

27 239 13 AERMOD predictions and concentrations are poor 

28 239 15 AERMOD significantly over-predicts the lowest 

29 240 12 urban/rural performance of AERMOD is not consistent 

30 240 16 It appears that AERMOD appreciably 

31 241 7 requiring use of AERMOD for area and volume 

32 247 6 AERMOD to get secondary particulate formation. 

33 249 5 Why can't we do this with CALPUFF and AERMOD, 

34 

35 Page Ref No. Keyword = "AERSCREEN" 

36 ____ _______ _____________________ 

37 

38 193 15 Complete and release AERSCREEN. We've been 

39 193 21 AERSCREEN going to be used in exactly the same way 

40 194 4 defines the role of AERSCREEN. 

41 194 7 well, the role of AERSCREEN is obvious to the user 

42 

43 Page Ref No. Keyword = "air" 

44 ____ _______ _______________ 

45 

46 11 7 the Air modeling -- Quality Modeling Group; 

47 22 9 just NWS data only, surface and upper air data. 

48 25 16 upper air station is also depicted there. I think 

49 42 24 ROGER BRODE: NWS surface and upper air and MM5 data. I 

50 49 6 evaluating new air dispersion models within the 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 260 

 2 

 3 Page Ref No. Keyword = "air" 

 4 ____ _______ _______________ 

 5 

 6 49 10 It's called "Guideline on Air Quality Models", and 

 7 49 11 it addresses, of course, bringing in new air 

 8 68 22 can be used to test the performance of air quality 

 9 73 22 time we ever started talking about air pollution. 

10 82 10 I'm -- I have been involved in the ADMS, air 

11 94 6 developing statistical evaluation methods for air 

12 103 7 Air Force, the Department of Energy, at Lawrence 

13 106 2 The only thing air quality dispersion models 

14 136 12 times, to the -- to the problem of a air pollution 

15 136 15 KEN STEINBERG: -- to an air pollution concern, where the 

16 170 7 -- to review of the National Air Quality standards 

17 173 16 Air and Waste Management Association. 

18 173 17 In the domain of the Air and Waste Management 

19 173 21 meteorological aspects of air pollution control. 

20 174 14 providing comments for Air and Waste AB3 Committee, 

21 175 17 Why use them in air quality studies? 

22 175 20 Current routinely applied air quality models 

23 179 20 friendly interfaces. Air quality monitors should 

24 181 2 would come out of air modeling. 

25 186 20 Air and Waste Management Association, AB3 

26 196 14 comments from Air and Waste Management Association, 

27 208 3 third conference on regulatory applications of air 

28 209 22 runway or make some kind of airport change, that's 

29 209 24 the airport, then you are required to use EDMS for 

30 210 3 at an airport, things like aircraft, auxiliary 

31 210 6 also find at the airport that aren't directly 

32 210 9 plants that are specific to the airport that are 

33 211 8 can be generated for your airport. The data 

34 211 11 jet aircraft engines. 

35 211 12 We also have some additional aircraft engine 

36 211 23 fleet mix of aircraft, the specific aircraft engine 

37 211 25 have, how long the aircraft has been taxiing or in 

38 212 10 fires at the airport. 

39 212 12 analysis, you have to enter in all your airport 

40 213 11 For the aircraft times in mode, we've done 

41 213 15 kinds of mode for aircraft. 

42 213 22 what the impact is going to be at the airport. 

43 214 14 if you look at the air quality handbook and you 

44 215 14 The aircraft times and mode, we are using the 

45 216 14 their airport, and then there is no easy way to 

46 217 3 airport access roads are the same width, they have 

47 217 22 air base. That's one of the screens there 

48 218 11 We also do a lot of air checking along the 

49 218 19 (4.3) is the addition of aircraft particulate 

50 218 22 bank doesn't include aircraft PMs. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 261 

 2 

 3 Page Ref No. Keyword = "air" 

 4 ____ _______ _______________ 

 5 

 6 219 2 estimate of aircraft PM emissions based on that 

 7 219 14 airport emission reduction credit applications. 

 8 220 17 Aircraft taxiing, and by defining the taxi path so 

 9 220 20 your airport layout, say I need to go from gate A 

10 220 23 the aircraft is going to use, and also it will 

11 220 24 figure out where the aircraft are going to get 

12 222 25 improved fidelity in our airport modeling 

13 224 20 the Utility Air Regulatory Group [ed.(UARG)]. 

14 225 7 frequently find that air quality modeling 

15 232 16 guidelines on air quality models. 

16 

17 Page Ref No. Keyword = "albedo" 

18 ____ _______ __________________ 

19 

20 193 6 Bowen ratio, and the albedo. 

21 

22 Page Ref No. Keyword = "algorithm" 

23 ____ _______ _____________________ 

24 

25 55 15 on an algorithmic function, actually. 

26 

27 Page Ref No. Keyword = "algorithms" 

28 ____ _______ ______________________ 

29 

30 50 15 of algorithms behind the model, the minimum data 

31 176 6 simplified algorithms for a simple general 

32 

33 Page Ref No. Keyword = "appendix" 

34 ____ _______ ____________________ 

35 

36 48 25 Appendix W and in -- detailed in some of the 

37 49 7 Appendix W. 

38 49 8 This comes from Appendix W, which is really an 

39 49 9 appendix to 40 CFR, Part 51 in the Guidelines. 

40 49 16 point one (3.1.1) of Appendix W, and under 

41 51 24 on the generic language that's found in Appendix W, 

42 52 2 and others that are mentioned in the Appendix W, as 

43 52 5 the language in the Appendix W. 

44 52 11 Appendix W. 

45 60 13 Appendix W and some of the suggestions and some of 

46 62 5 it's not directly stated in Appendix W, that it 

47 62 12 time, Appendix W is for the alternative models that 

48 62 17 language from the Appendix W looked -- looked 

49 62 22 new Appendix W going to be unveiled to us all, and 

50 63 2 WARREN PETERS: I'm not sure what you mean by new Appendix W. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 262 

 2 

 3 Page Ref No. Keyword = "appendix" 

 4 ____ _______ ____________________ 

 5 

 6 63 4 promulgation will require a change to Appendix W 

 7 63 11 will be, obviously, some changes to Appendix W 

 8 63 17 significant, big-time changes to Appendix W. It's 

 9 63 20 And, of course, all the Appendix W changes 

10 93 8 In the appendix, there is an example that we 

11 194 3 model in Appendix W? If it is, that partially 

12 234 14 taken, out of Appendix B of that report for area 

13 243 8 address, that is Appendix W, does not address how 

14 243 23 51, Appendix W, do not address these models really 

15 

16 Page Ref No. Keyword = "atmosphere" 

17 ____ _______ ______________________ 

18 

19 97 11 I mean, the atmosphere is clearly stochastic. 

20 102 18 processes as they occur in the atmosphere. 

21 179 2 there's chaos in the atmosphere, but, you know, 

22 

23 Page Ref No. Keyword = "boundary" 

24 ____ _______ ____________________ 

25 

26 73 5 with the boundary conditions specified on average, 

27 100 13 data that has similar boundary conditions. You 

28 143 8 boundary layers and all, you know, the surface 

29 178 22 But in the CFD model has boundary conditions, 

30 179 5 the input parameters of boundary conditions. 

31 179 6 There's no uniform boundary. So those models have 

32 182 4 dispersion in the wind tunnel matches boundary 

33 

34 Page Ref No. Keyword = "Bowen" 

35 ____ _______ _________________ 

36 

37 193 6 Bowen ratio, and the albedo. 

38 

39 Page Ref No. Keyword = "calm" 

40 ____ _______ ________________ 

41 

42 15 21 we're looking at the -- at CALMET and CALPUFF. 

43 15 25 And there are preprocessors to CALMET. They 

44 19 10 compare the base version of CALMET and CALPUFF 

45 19 11 together with the Beta version of CALMET and 

46 19 20 are due to changes in CALMET or CALPUFF. 

47 19 22 processors to CALMET are not part of the analysis 

48 19 24 the main components of CALMET and CALPUFF. 

49 20 3 CALPUFF, and the base version of CALMET run, and so 

50 20 5 and the Beta version of CALMET are run. That's the 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 263 

 2 

 3 Page Ref No. Keyword = "calm" 

 4 ____ _______ ________________ 

 5 

 6 20 10 CALMET. 

 7 20 17 CALMET or CALPUFF or in some cases, both. 

 8 20 22 domains that cover, you know, CALMET, can cover a 

 9 23 14 CALMET, so even for the idealized scenarios, we 

10 23 16 CALMET to get the wind field, so these are, as we 

11 23 20 didn't include CALMET, and that -- we fed it 

12 25 18 contours based upon the CALMET terrain. 

13 26 18 CALMET grid spacing for scenario three. 

14 29 16 that doesn't use CALMET. We fed the data through 

15 33 10 scenario that didn't base its meteorology on CALMET 

16 33 15 changes into CALMET. So that simplifies the post 

17 36 12 was made in CALMET, going from the base version, 

18 38 14 prognostic data limits in CALMET didn't match the 

19 38 18 limits on the prognostic data arrays for CALMET, 

20 39 9 a SAMSON format so we could run it through CALMET. 

21 40 19 we're not including the preprocessors for CALMET in 

22 40 23 would need, would be the CALMET and CALPUFF inputs, 

23 42 3 CALPUFF and CALMET -- or CALPUFF could actually run 

24 159 8 public, to run parallel mode, for CALMET and for 

25 159 12 lot of us need to run CALMET in a single computer 

26 198 3 CALMET. 

27 207 7 Again, a methodology to evaluate the CALMET 

28 

29 Page Ref No. Keyword = "CALMET" 

30 ____ _______ __________________ 

31 

32 15 21 we're looking at the -- at CALMET and CALPUFF. 

33 15 25 And there are preprocessors to CALMET. They 

34 19 10 compare the base version of CALMET and CALPUFF 

35 19 11 together with the Beta version of CALMET and 

36 19 20 are due to changes in CALMET or CALPUFF. 

37 19 22 processors to CALMET are not part of the analysis 

38 19 24 the main components of CALMET and CALPUFF. 

39 20 3 CALPUFF, and the base version of CALMET run, and so 

40 20 5 and the Beta version of CALMET are run. That's the 

41 20 10 CALMET. 

42 20 17 CALMET or CALPUFF or in some cases, both. 

43 20 22 domains that cover, you know, CALMET, can cover a 

44 23 14 CALMET, so even for the idealized scenarios, we 

45 23 16 CALMET to get the wind field, so these are, as we 

46 23 20 didn't include CALMET, and that -- we fed it 

47 25 18 contours based upon the CALMET terrain. 

48 26 18 CALMET grid spacing for scenario three. 

49 29 16 that doesn't use CALMET. We fed the data through 

50 33 10 scenario that didn't base its meteorology on CALMET 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 264 

 2 

 3 Page Ref No. Keyword = "calmet" 

 4 ____ _______ __________________ 

 5 

 6 33 15 changes into CALMET. So that simplifies the post 

 7 36 12 was made in CALMET, going from the base version, 

 8 38 14 prognostic data limits in CALMET didn't match the 

 9 38 18 limits on the prognostic data arrays for CALMET, 

10 39 9 a SAMSON format so we could run it through CALMET. 

11 40 19 we're not including the preprocessors for CALMET in 

12 40 23 would need, would be the CALMET and CALPUFF inputs, 

13 42 3 CALPUFF and CALMET -- or CALPUFF could actually run 

14 159 8 public, to run parallel mode, for CALMET and for 

15 159 12 lot of us need to run CALMET in a single computer 

16 198 3 CALMET. 

17 207 7 Again, a methodology to evaluate the CALMET 

18 

19 Page Ref No. Keyword = "CALPUFF" 

20 ____ _______ ___________________ 

21 

22 7 16 AERMOD and CALPUFF open up a whole new area of 

23 8 16 and CALPUFF implementation. 

24 8 22 have, CALPUFF, and the current challenges and 

25 9 16 more about CALPUFF and the updating of it, in terms 

26 12 18 case of CALPUFF and we'll have a presentation 

27 13 13 CALPUFF model. 

28 13 18 a regulatory dispersion model, either CALPUFF or 

29 14 22 of freedom in a CALPUFF modeling analysis and its 

30 15 4 of freedom in the CALPUFF through a selection of 

31 15 18 components and in a case like CALPUFF -- there are 

32 15 19 multiple components. In the case of the CALPUFF, 

33 15 21 we're looking at the -- at CALMET and CALPUFF. 

34 16 9 freedom in a -- in a modeling system like CALPUFF, 

35 17 6 CALPUFF. 

36 17 8 approve CALPUFF in some form or another with 

37 18 9 Overview of CALPUFF. (Correct computer slide 

38 18 17 chemistry deposition components of CALPUFF aren't 

39 19 10 compare the base version of CALMET and CALPUFF 

40 19 12 CALPUFF, and that's just a straight comparison, and 

41 19 20 are due to changes in CALMET or CALPUFF. 

42 19 24 the main components of CALMET and CALPUFF. 

43 20 3 CALPUFF, and the base version of CALMET run, and so 

44 20 4 that's one model run. The Beta version of CALPUFF 

45 20 9 Beta version of CALPUFF against the Beta version of 

46 20 17 CALMET or CALPUFF or in some cases, both. 

47 22 23 actual CALPUFF application might look like. 

48 27 2 part of CALPUFF for receptors. 

49 37 9 the CALPUFF modeling system, we had wanted to 

50 38 3 available in the CALPUFF documentation. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 265 

 2 

 3 Page Ref No. Keyword = "calpuff" 

 4 ____ _______ ___________________ 

 5 

 6 38 5 sure anybody who has run the CALPUFF modeling 

 7 40 23 would need, would be the CALMET and CALPUFF inputs, 

 8 42 3 CALPUFF and CALMET -- or CALPUFF could actually run 

 9 44 6 analysis tool for CALPUFF and one for AERMOD. I 

10 44 14 CALPUFF? 

11 46 10 morning on the updating of models in CALPUFF, and 

12 46 19 believe I saw it with CALPUFF as well, that the 

13 48 18 now that AERMOD and CALPUFF have been accepted for 

14 61 23 AERMOD or CALPUFF or some other model into the 

15 104 7 CALPUFF or Class 1 areas demands that these 

16 108 4 know, CALPUFF or AERMOD or whatever, it's still 

17 134 11 this, that AERMOD and CALPUFF are really quite 

18 145 16 both CALPUFF and AERMOD -- 

19 145 22 AERMOD and CALPUFF, and that's been quite 

20 147 23 CALPUFF, AERMOD, ISC3, CT screen, you know, IGM 

21 149 6 CALPUFF or AERMOD, is a public input process. 

22 150 15 So it's clear that even AERMOD and CALPUFF 

23 159 7 case of CALPUFF. We modified CALPUFF to put to the 

24 159 9 CALPUFF itself. 

25 159 15 And when we go to CALPUFF, we have the same 

26 159 20 example, CALPUFF model which is a preferred model 

27 160 7 retraining CALPUFF. Let's say it's -- we come up 

28 174 10 CALPUFF to be given by Mark Bennett. 

29 196 16 implementation of CALPUFF. 

30 196 19 support of CALPUFF. We think it is a good model. 

31 197 2 comments, we looked at CALPUFF as possibly serving 

32 197 9 more active oversight in CALPUFF than we have seen 

33 197 19 with CALPUFF and other models. We are concerned 

34 197 22 with CALPUFF, with the CALPUFF modeling system. 

35 198 11 CALPUFF, and I think we heard quite a bit about 

36 199 10 CALPUFF code, and a comment similar to what you saw 

37 199 13 for CALPUFF that can give quickly and accurately 

38 199 22 something that really is needed for CALPUFF to be 

39 201 20 in addition to long-range transport, when CALPUFF 

40 201 23 So we anticipate the increased use of CALPUFF 

41 202 16 evaluating the screening procedure for CALPUFF, 

42 204 13 dispersion of CALPUFF. 

43 204 20 issues when you're using CALPUFF in a PSD 

44 205 8 frustration in using CALPUFF, one of the largest 

45 205 9 concerns in CALPUFF implementation. 

46 205 11 EPA take over the guidance for CALPUFF including 

47 206 2 guidance for CALPUFF. 

48 206 16 modeling with CALPUFF is, but we would -- all 

49 208 16 Scire of CALPUFF, and Lloyd Schulman has offered 

50 225 10 Recently, we've been using CALPUFF quite a 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 266 

 2 

 3 Page Ref No. Keyword = "calpuff" 

 4 ____ _______ ___________________ 

 5 

 6 229 6 members as the visibility component with CALPUFF. 

 7 244 11 such as CALPUFF and SCIPUFF. Compute the change of 

 8 247 5 you could run CALPUFF, or you certainly can't run 

 9 249 5 Why can't we do this with CALPUFF and AERMOD, 

10 

11 Page Ref No. Keyword = "cell" 

12 ____ _______ ________________ 

13 

14 245 8 into the grid cell that it happens to be in. 

15 

16 Page Ref No. Keyword = "cells" 

17 ____ _______ _________________ 

18 

19 244 24 you have various grid cells and the total 

20 245 2 grid of cells, and the pollutant concentrations in 

21 245 11 Obviously, as you get to large grid cells, 

22 245 14 to very small grid cells if you are going to stay 

23 

24 Page Ref No. Keyword = "Class I" 

25 ____ _______ ___________________ 

26 

27 107 4 like Class I is, where you're looking only at that 

28 

29 Page Ref No. Keyword = "clearing house" 

30 ____ _______ __________________________ 

31 

32 10 17 First, Warren Peters, our Model Clearing House 

33 14 21 replace the model clearing house facility degrees 

34 14 25 clearing house approach. This will not replace 

35 204 11 up in the model clearing house, on what is the 

36 204 17 should be put in the modeling clearing house. 

37 206 11 maintain the model clearing house. 

38 225 24 clearing house which is, as the SCRAM web site 

39 226 7 But, the model clearing house web site is only 

40 

41 Page Ref No. Keyword = "complex" 

42 ____ _______ ___________________ 

43 

44 7 18 change and make more complex the world that we live 

45 7 20 burden on us in terms of the complexities to make 

46 7 22 those complexities in the decisions that they make. 

47 8 17 You heard the background of the complexities 

48 20 24 So, the complex flow, local scale impacts 

49 23 2 small scale complex flow situation in the Deep 

50 27 17 This is a sort of near-field complex flow 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 267 

 2 

 3 Page Ref No. Keyword = "complex" 

 4 ____ _______ ___________________ 

 5 

 6 41 18 five being the small-sale complex flow. 

 7 78 20 complex terrain model evaluations, and the model 

 8 86 23 applications and complex terrain. 

 9 110 7 especially as complex and especially as many knobs 

10 134 12 complex models, which can give quite different 

11 137 9 where there was some complex terrain, and there was 

12 137 21 expect in a complex terrain situation. 

13 145 24 problems that we've had, especially in complex 

14 145 25 terrain and complex flow situations. 

15 147 15 Well, in the complex terrain world that we've 

16 147 25 complex one Complex I. So I don't think it's a big issue. I 

17 156 8 extraordinarily complex set of databases, and we 

18 172 19 these models are only becoming more complex, and 

19 174 19 considered for complex near-field situations, and 

20 175 2 very complex situations where we have interactions 

21 175 3 between structures and complex features that can 

22 175 19 they can simulate flows that are very complex. 

23 177 24 complex could be practically run on most 

24 178 2 Well, if you want to simulate a complex full 

25 180 19 complex flows, which are really there and it's -- 

26 181 3 And then in complex urban environments, with 

27 183 4 course, for complex structures, cooling towers, 

28 183 5 cylindrical structures, lattice structures, complex 

29 184 21 models for certain complex situations. 

30 201 22 case-by-case basis for complex wind fields. 

31 201 24 for complex wind fields, but again, as has already 

32 202 25 here for complex wind fields and for a number of 

33 207 8 wind fields, the complex wind field cases, and 

34 210 13 it was the Complex Source Microcomputer Model, and 

35 243 18 They involve multiple precursors and complex 

36 244 19 Ozone can't be modeled, because of complex 

37 245 18 you have complex emissions, nonlinear chemical 

38 246 8 They are very complex and intensive models, 

39 

40 Page Ref No. Keyword = "concentration" 

41 ____ _______ _________________________ 

42 

43 30 2 So here is some depictions of concentration 

44 52 25 predicted concentration, the OB is observed, and by 

45 53 24 every high concentration, no matter where it 

46 55 4 robust highest concentration or RHC. And 

47 55 11 And robust highest concentration, when we say 

48 56 4 concentration which describes a generic 

49 56 5 concentration, and now we have the fractional bias 

50 57 21 This is a suggested concentration -- or 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 268 

 2 

 3 Page Ref No. Keyword = "concentration" 

 4 ____ _______ _________________________ 

 5 

 6 60 8 robust highest concentration which is a pseudo 

 7 60 9 concentration based on the high twenty-five (25) 

 8 65 18 concentration. 

 9 98 13 compare it against this design concentration, or 

10 98 22 concentration. 

11 100 6 ensemble mean but the concentration fluctuations 

12 100 24 estimate the second high concentration and give you 

13 100 25 an average second high concentration. 

14 102 3 concentration. Now I see it doesn't have the 

15 102 6 up with a second high concentration, there is 

16 104 12 concentration, but also the right concentration in 

17 134 22 give different predictions of concentration. 

18 180 23 And here's a case where concentration is, in a 

19 183 14 concentration distribution downwind of that type of 

20 235 12 substantially lower concentration than we -- 

21 235 14 concentration, so there seems to be quite a bit 

22 237 11 very small amount of change in concentration. 

23 238 19 concentration of the domain, not just the highest 

24 239 14 throughout most of the concentration domain. 

25 240 25 remainder of the concentration domain. 

26 244 12 concentration following a puff or a parcel as it's 

27 

28 Page Ref No. Keyword = "concentrations" 

29 ____ _______ __________________________ 

30 

31 18 22 just on estimating concentrations. The ten 

32 36 17 Again, these are very small concentrations, if 

33 50 5 and more reliably estimate concentrations as a 

34 51 10 concentrations. 

35 51 16 evaluating performance for peak concentrations, and 

36 54 23 of the highest concentrations that is of primary 

37 55 6 the highest concentrations, and believe -- it's 

38 55 9 twenty-five (25) concentrations that you would have 

39 55 23 concentrations. 

40 56 11 concentrations under each of the conditions that 

41 56 14 still looking at the robust highest concentrations. 

42 56 16 highest concentrations, it's still using the same 

43 56 22 concentrations, not the averaging times of concern 

44 60 6 concentrations, and, of course, as I mentioned 

45 60 10 concentrations. 

46 65 15 highest concentrations in the use of the fractional 

47 67 2 fluctuations in the observed concentrations, I 

48 73 19 segment of observed concentrations that involve 

49 74 2 concentrations to have large fluctuations when the 

50 77 6 each arc of observed concentrations rather than 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 269 

 2 

 3 Page Ref No. Keyword = "concentrations" 

 4 ____ _______ __________________________ 

 5 

 6 77 9 observed concentrations, and give confidence 

 7 91 20 produce good regulatory concentrations, but it also 

 8 91 21 produces good concentrations in other less 

 9 100 22 at second high concentrations, you would run the 

10 104 8 concentrations occur at a specific place at least 

11 137 11 some high concentrations, and, of course, ISC was 

12 137 12 attributing very high concentrations to our sources 

13 137 15 concentrations that were predicted were far closer 

14 137 16 to the observed concentrations, which perhaps may 

15 137 24 that direction, the concentrations changed off of 

16 165 25 industry is no happier with concentrations that are 

17 166 2 low than they are with concentrations that are too 

18 166 4 Concentrations that are too low will avoid 

19 182 7 The measured concentrations are steady-state 

20 233 8 regulatory design concentrations, AERMOD versus 

21 233 19 appreciably over-predict majority of concentrations 

22 234 2 with the regulatory concentrations. 

23 234 22 concentrations that were reported, and what we can 

24 235 4 appreciable lower concentrations as you move from a 

25 235 9 have concentrations where the two meteorological 

26 235 22 compare it to the concentrations that were shown 

27 236 2 concentrations are actually higher for AERMOD than 

28 236 12 concentrations, the factor of dilution is about two 

29 237 6 between concentrations for rural and for urban. 

30 237 24 looking across the concentrations between ISC and 

31 238 13 the concentrations throughout the modeling 

32 239 13 AERMOD predictions and concentrations are poor 

33 239 16 range of observed concentrations, and it suggests 

34 239 24 lower range of the concentrations, although this is 

35 240 17 over-predicts the majority of the concentrations 

36 240 23 concentrations at the highest end of the 

37 241 3 concentrations using risk assessment to be 

38 242 6 thoughts on the lower end of the concentrations is 

39 242 13 much do those concentrations contribute to the 

40 244 25 concentrations is obtained relative to this fixed 

41 245 2 grid of cells, and the pollutant concentrations in 

42 

43 Page Ref No. Keyword = "data" 

44 ____ _______ ________________ 

45 

46 8 13 the use of gridded met data, you saw that 

47 9 7 met data, something that we need to consider. We 

48 18 15 included in the test data set. There's actually an 

49 18 25 data. 

50 19 23 tool or part of the data set. It's just focused on 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 270 

 2 

 3 Page Ref No. Keyword = "data" 

 4 ____ _______ ________________ 

 5 

 6 21 4 meteorological data, we have both. 

 7 21 6 MM5 data. And then we, also, since we are still in 

 8 21 17 real met data, either the National Weather Service 

 9 21 18 data, or MM5, or both. 

10 21 20 idealized scenarios to idealize met data, idealize 

11 22 9 just NWS data only, surface and upper air data. 

12 22 17 data with MM5, so a mixture. 

13 23 4 finding that utilized data sets we had two that 

14 23 15 sort of generated the met data to run through 

15 23 21 CTDM-type surface and profile data to simulate 

16 25 21 the MM5 data we used also had a twelve kilometer 

17 25 25 use data; again, those two red squares represent 

18 26 5 MM5 data, showing the domain. It was a much larger 

19 26 17 data in that case and went to four kilometer (4km) 

20 28 6 with the MM5 data for scenario two and three. 

21 29 16 that doesn't use CALMET. We fed the data through 

22 35 18 was, again, just MM5 data driving it in the No Obs 

23 38 14 prognostic data limits in CALMET didn't match the 

24 38 16 And so our MM5 data, since it was already 

25 38 18 limits on the prognostic data arrays for CALMET, 

26 39 2 data formats, some of the MM5 data was, I think, 

27 39 4 Weather Service data for the same time period, and 

28 39 5 that meant we wanted to use the ISHWO data that was 

29 39 7 directly supported, so we had to do some data 

30 39 14 I think that Desmond did mention that the data 

31 39 17 I think the full data set with all the outputs 

32 40 20 the data sets at this time. That's a future 

33 41 2 incorporate those into data sets. 

34 41 11 data periods that we ran to about a month, I think, 

35 41 15 longer data periods. 

36 42 16 of the used surface data and MM5 data for the long 

37 42 19 where we mer- -- sort of merged NWS with MM5 data 

38 42 23 MARK GARRISON: NWS surface and MM5 data? 

39 42 24 ROGER BRODE: NWS surface and upper air and MM5 data. I 

40 42 25 think we used the MM5 data to initialize the wind 

41 45 7 some of the model evaluation data sets. 

42 50 15 of algorithms behind the model, the minimum data 

43 50 19 data, so that when you download the executed books, 

44 53 20 twenty-five values of the observed data, and it's 

45 53 21 looked at basically taking all of the observed data 

46 70 11 developed. In this sense someone had test data 

47 70 14 they could make the test data sets and the 

48 74 25 that they want to have used and the databases that 

49 75 21 AERMOD evaluation databases have been put up on 

50 77 16 databases which I think also ought to be considered 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 271 

 2 

 3 Page Ref No. Keyword = "data" 

 4 ____ _______ ________________ 

 5 

 6 77 18 for example, one-year data sets that are spatially 

 7 78 7 to evaluate two types of databases; that is tracer 

 8 78 8 and -- and long-term databases and come up with a 

 9 78 13 Well, the advantage of the long-term databases 

10 78 18 databases over the past two or three decades, in 

11 78 25 Other advantages of such databases are that 

12 79 7 long-term databases. 

13 79 12 database. 

14 79 15 with such databases. 

15 79 21 don't -- these databases do not work well for 

16 80 3 databases, that is, tracer databases that are short 

17 80 5 spatially sparse databases do have their useful 

18 80 11 short-term tracer databases, and they should also 

19 80 13 evaluating long-term databases, and maybe there can 

20 84 7 very important to consider the quality of the data 

21 84 9 explore the data that's being used. I know one of 

22 84 12 very carefully at the Gaussian data, and only for 

23 84 13 instance do evaluation or validation on data which 

24 84 17 procedures, looking to see a complete data set, 

25 84 18 then taking quality data by the certain quality 

26 84 20 taking the highest standard of data, and, of 

27 86 21 think field data sets are lacking some detailed 

28 86 22 data sets, and they include some building downwash 

29 87 20 talked about the data sets, because I think that 

30 89 19 I think the problems lie in -- in the data 

31 89 20 sets. I think the data sets are, many of them go 

32 90 2 evaluation methods with data sets where we have 

33 90 5 match the data that we are attempting to drive it 

34 90 25 (80%) of the problem is in our data. 

35 91 5 the evaluation databases, for instance, what we've 

36 91 7 databases, as we have -- you may recall from our 

37 91 9 databases, but still in reality, we haven't 

38 91 25 the evaluation database, but they may be very 

39 92 13 database is only going to cover a small portion of 

40 92 22 thoughts from the panel about this idea? Databases 

41 92 23 or the lack of databases; John? 

42 94 11 could have model runs for three different data 

43 94 21 three different tracer data sets. 

44 94 25 Data quality is important. One of the things 

45 95 2 that's suggested in D-6589 is that you sort data 

46 95 4 that you would only sort good quality data into 

47 95 10 with the old tracer data sets is a challenge with 

48 95 12 inputs that aren't available in the old tracer data 

49 95 16 archiving data sets is expensive. 

50 95 19 about a limited databases? 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 272 

 2 

 3 Page Ref No. Keyword = "data" 

 4 ____ _______ ________________ 

 5 

 6 96 15 appropriate field data studies. 

 7 98 3 data to do that adequately, and I'm not convinced 

 8 98 4 that we can do that without extensive data, we 

 9 100 13 data that has similar boundary conditions. You 

10 100 15 profile in this group of data, and how well does it 

11 109 18 evaluation tools and to the data that are used in 

12 109 21 more with, is, getting the right data. 

13 110 5 because we've got to have those data to know if 

14 112 14 This is purely to either try to get the data 

15 112 15 or to get the data and to help improve the models 

16 114 17 needs to keep pace, the databases supporting that. 

17 119 16 really significantly different given the data sets 

18 119 22 collection of documented databases and 

19 119 23 documented data sets that everyone in using and a 

20 120 5 out methods, and people are developing data sets 

21 120 7 data sets, and everybody's getting sort of familiar 

22 121 10 B, and C with data sets one through twelve (12), 

23 121 15 just a number for each data set and each test 

24 125 14 databases for AERMOD, and we need other databases 

25 125 16 should be an extensive set of evaluation databases 

26 125 18 database was independent, or developmental, whether 

27 125 21 But I think if you have enough such databases 

28 125 25 across a large variety of data sets. 

29 138 16 at five different data sets, some area source, the 

30 154 14 yeah, you got the right data, no, you don't have 

31 154 15 the right data. 

32 155 19 database, you're going to have people building 

33 155 20 their models to the database. You know they're 

34 156 2 database, and they're going to say, what do I need 

35 156 8 extraordinarily complex set of databases, and we 

36 156 9 have already heard, there is no data out there. I 

37 156 10 mean, we don't have that kind of data. 

38 156 11 I mean, if we had the data for the -- for the 

39 166 25 model of data quality objective model dealing with 

40 170 23 is calculating the data, starting from how we mix 

41 182 14 to get the field data for -- (cough) to take it to 

42 185 11 through some comparisons with databases, wind 

43 191 24 on-site data in remote areas without cloud cover 

44 191 25 data. 

45 192 3 input on-site data directly, and -- but you never 

46 192 7 the use of on-site data without having to have an 

47 194 24 With AERMET'S ability to use on-site data, 

48 195 2 many types of on-site data that can be input. 

49 197 18 discussion about the use of meteorological data 

50 197 21 a -- specifically mesoscale data sets to go along 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 273 

 2 

 3 Page Ref No. Keyword = "data" 

 4 ____ _______ ________________ 

 5 

 6 200 3 Al right, meteorological data. 

 7 200 9 No Obs, various MM5 data sets that are available; 

 8 200 13 thirty-six (36) kilometer MM5 data sets which are 

 9 200 16 (12km) data sets, four kilometer data sets. We 

10 200 18 data sets, given that right now we have to model 

11 200 23 data sets; which data sets are adequate, properly 

12 201 3 three years of meteorological data to five years. 

13 201 5 do we have five years of data -- meteorological 

14 201 6 data sets that are acceptable? 

15 201 9 adequacy of these data sets, the ones that we are 

16 203 5 could be more data from which to draw conclusions 

17 206 8 available these meteorological data sets, and then 

18 207 4 of this mesoscale meteorological data sets that we 

19 207 6 years, of data. 

20 211 8 can be generated for your airport. The data 

21 211 10 the ICAO exhaust emissions division data bank for 

22 211 13 data that was supplied directly from the 

23 211 19 bit of emissions data in it. 

24 213 3 A database repair function was added. This 

25 213 7 some kind of data base corruption, this provides a 

26 214 19 as to what data elements are required. 

27 215 10 The database repair they discuss, just -- the 

28 217 14 emission data, the user can edit any of the control 

29 218 5 wizard, and now it includes the database of met 

30 218 21 modeling realize that the ICAO engine emissions data 

31 220 11 fuel flow method two, we can take the met data, 

32 222 16 data, and harmonizing the models. 

33 227 5 the AERMOD model, and its associated data 

34 228 2 the liquid precipitation field of the HUSWO data, 

35 234 3 It dealt with two meteorological data sets; 

36 234 13 And this is a table that was taken, or data 

37 237 2 This next slide shows data taken for volume 

38 238 7 sources, their behavior is supported by data or 

39 239 6 data. It's a small research firm in -- with some 

40 240 15 data. 

41 240 18 throughout the modeling regime for some of the data 

42 248 5 archive data or with real time forecast data, 

43 

44 Page Ref No. Keyword = "database" 

45 ____ _______ ____________________ 

46 

47 79 12 database. 

48 91 25 the evaluation database, but they may be very 

49 92 13 database is only going to cover a small portion of 

50 125 18 database was independent, or developmental, whether 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 274 

 2 

 3 Page Ref No. Keyword = "database" 

 4 ____ _______ ____________________ 

 5 

 6 155 19 database, you're going to have people building 

 7 155 20 their models to the database. You know they're 

 8 156 2 database, and they're going to say, what do I need 

 9 213 3 A database repair function was added. This 

10 215 10 The database repair they discuss, just -- the 

11 218 5 wizard, and now it includes the database of met 

12 

13 Page Ref No. Keyword = "databases" 

14 ____ _______ _____________________ 

15 

16 74 25 that they want to have used and the databases that 

17 75 21 AERMOD evaluation databases have been put up on 

18 77 16 databases which I think also ought to be considered 

19 78 7 to evaluate two types of databases; that is tracer 

20 78 8 and -- and long-term databases and come up with a 

21 78 13 Well, the advantage of the long-term databases 

22 78 18 databases over the past two or three decades, in 

23 78 25 Other advantages of such databases are that 

24 79 7 long-term databases. 

25 79 15 with such databases. 

26 79 21 don't -- these databases do not work well for 

27 80 3 databases, that is, tracer databases that are short 

28 80 5 spatially sparse databases do have their useful 

29 80 11 short-term tracer databases, and they should also 

30 80 13 evaluating long-term databases, and maybe there can 

31 91 5 the evaluation databases, for instance, what we've 

32 91 7 databases, as we have -- you may recall from our 

33 91 9 databases, but still in reality, we haven't 

34 92 22 thoughts from the panel about this idea? Databases 

35 92 23 or the lack of databases; John? 

36 95 19 about a limited databases? 

37 114 17 needs to keep pace, the databases supporting that. 

38 119 22 collection of documented databases and 

39 125 14 databases for AERMOD, and we need other databases 

40 125 16 should be an extensive set of evaluation databases 

41 125 21 But I think if you have enough such databases 

42 156 8 extraordinarily complex set of databases, and we 

43 185 11 through some comparisons with databases, wind 

44 

45 Page Ref No. Keyword = "default" 

46 ____ _______ ___________________ 

47 

48 213 14 that just rely -- relying on the ICAO default 

49 216 12 default GSE assignments. Users that complained in 

50 217 6 user can override the default setting or the twenty 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 275 

 2 

 3 Page Ref No. Keyword = "default" 

 4 ____ _______ ___________________ 

 5 

 6 217 7 meters that remains as the default. 

 7 

 8 Page Ref No. Keyword = "DEM" 

 9 ____ _______ _______________ 

10 

11 38 19 also ran into a limit in TERREL for a number of DEM 

12 66 2 performance of ISC, in demonstrating to the public 

13 93 23 written up as a test method and demonstrated that 

14 104 7 CALPUFF or Class 1 areas demands that these 

15 104 10 What are your thoughts on demanding the models 

16 121 7 demonstrate to EPA that your model has completed 

17 121 11 and you must demonstrate that your model does at 

18 128 25 EPA has many demands on its resources and 

19 139 23 have an application where I can demonstrate that -- 

20 139 24 and have demonstrated that AERMOD or ADMS is 

21 169 18 highest values to demonstrate compliance with the 

22 180 16 demonstrating building effects. 

23 187 22 is a real need to be using the ten-meter (10m) DEM 

24 189 21 model of choice, short of demonstrating its -- that 

25 227 14 In addition, some of the DEM files express 

26 

27 Page Ref No. Keyword = "dispersion" 

28 ____ _______ ______________________ 

29 

30 11 10 dispersion modeling. 

31 11 13 our dispersion modeling team with Warren as -- as 

32 13 7 improved approach for updating our dispersion 

33 13 18 a regulatory dispersion model, either CALPUFF or 

34 21 7 a transition from a PG based dispersion, ISC-like 

35 21 8 dispersion to AERMOD-like dispersion, we also 

36 21 9 include different options for dispersion in the 

37 23 6 similarity dispersion and second run was PG-based 

38 23 7 dispersion. 

39 23 11 similarity-based dispersion and PG-based 

40 23 12 dispersion. 

41 28 21 dispersion was based on the similarity theory. 

42 29 6 dispersion. 

43 29 10 similarity dispersion. 

44 29 13 PG-based dispersion. 

45 29 23 just looked at dispersion based on similarity 

46 49 6 evaluating new air dispersion models within the 

47 66 19 is a stochastic element to dispersion theory that 

48 82 11 dispersion modeling system, since 1988, so I have a 

49 82 24 short-range atmospheric dispersion models in 

50 106 2 The only thing air quality dispersion models 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 276 

 2 

 3 Page Ref No. Keyword = "dispersion" 

 4 ____ _______ ______________________ 

 5 

 6 124 18 several different recommended dispersion models may 

 7 129 9 ever increasingly long list of approved dispersion 

 8 182 4 dispersion in the wind tunnel matches boundary 

 9 203 18 AERMOD-like dispersion; a concern. A number 

10 204 4 AERMOD-like dispersion on a number of permitting 

11 204 13 dispersion of CALPUFF. 

12 207 9 AERMOD-like dispersion. 

13 209 18 Dispersion Modeling System. 

14 212 11 Then as we transition into a dispersion 

15 213 4 was in the case that a lot of the dispersion runs 

16 214 20 And we've made some changes to the dispersion 

17 228 18 dispersion model itself. 

18 234 9 that the AERMOD treatment of enhanced dispersion 

19 235 15 less dispersion going on from the rural setting to 

20 235 21 enhanced dispersion going on in AERMOD, as we 

21 236 9 significant increase in dispersion, from rural to 

22 236 19 the dispersion, and for urban settings, we -- we 

23 236 20 see a decrease in the dispersion, which again, 

24 237 8 dispersion going on in the urban setting for ISC. 

25 237 15 where we're seeing some increase in dispersion from 

26 237 20 In AERMOD the minimum increase in dispersion 

27 237 25 AERMOD, there is actually a decrease in dispersion 

28 249 15 run a dispersion model any time you want for any 

29 

30 Page Ref No. Keyword = "domain" 

31 ____ _______ __________________ 

32 

33 21 21 domain and very -- they are much smaller domain, 

34 22 4 one, and that's the large domain -- I'll show you 

35 22 11 Scenario two is the exact same domain, but 

36 22 15 of subset of that first domain focused more in the 

37 22 19 Then we have another medium scale domain near 

38 24 15 sources at different parts of the domain. 

39 25 8 is, again, is a large scale domain in the Pacific 

40 25 24 It's the same domain, just showing the land 

41 26 5 MM5 data, showing the domain. It was a much larger 

42 26 6 domain, and we took a subset out of the MM5 domain 

43 27 25 a hundred (100x100) domain; not exactly, a hundred 

44 28 10 center of a ten (10) by ten (10) kilometer domain, 

45 28 14 domain, upwind of the hill, and simulated steady 

46 28 23 the actual domain, but it does show you the general 

47 30 6 ten-kilometer (10) domain. Unfortunately, I 

48 30 25 the domain where the hill is located. 

49 31 15 the same hill located in the surface domain, but we 

50 31 17 southwest edge of the domain, because the wind 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 277 

 2 

 3 Page Ref No. Keyword = "domain" 

 4 ____ _______ __________________ 

 5 

 6 34 12 the domain for that source. 

 7 35 20 but this is the large modeling domain, and it's 

 8 36 2 fraction of biases over the whole domain for that 

 9 36 9 comes into play within that domain. And so all the 

10 42 20 in that sort of medium-scale domain. 

11 163 24 have all Code in the public domain. 

12 173 17 In the domain of the Air and Waste Management 

13 177 2 software? It -- you take your domain and divide it 

14 233 20 throughout modeling domain that would be of 

15 238 14 domain. 

16 238 19 concentration of the domain, not just the highest 

17 239 14 throughout most of the concentration domain. 

18 240 25 remainder of the concentration domain. 

19 

20 Page Ref No. Keyword = "downwash" 

21 ____ _______ ____________________ 

22 

23 24 24 PRIME downwash sources, a thirty-five (35) meter 

24 31 3 And then for -- this is one of those downwash 

25 31 6 volume source, except with some downwash. 

26 31 11 This is the fifty-meter (50m) downwash source, 

27 86 22 data sets, and they include some building downwash 

28 90 15 area and volume sources, looking at downwash and 

29 217 20 includes the PRIME and building downwash models, 

30 

31 Page Ref No. Keyword = "downwind" 

32 ____ _______ ____________________ 

33 

34 27 14 region, again, somewhat downwind of the sampling 

35 32 3 for the downwind. 

36 183 14 concentration distribution downwind of that type of 

37 194 19 up when they're downwind. 

38 

39 Page Ref No. Keyword = "EPA" 

40 ____ _______ _______________ 

41 

42 8 11 a collaborative environment across EPA and other 

43 9 17 of moving from the EPA approved version to the -- 

44 12 17 on the EPA's new approach to updating models, the 

45 25 4 (34) meter building that's been used in EPA 

46 43 4 I have a question of EPA about whether this is 

47 50 3 states, EPA is soliciting the new refined models 

48 51 14 And then under alternative models; the EPA 

49 52 7 here, these slides are pretty much based on the EPA 

50 63 7 reviewed by -- within EPA. But we, the user 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 278 

 2 

 3 Page Ref No. Keyword = "epa" 

 4 ____ _______ _______________ 

 5 

 6 64 9 the current EPA procedures and giving us any new 

 7 65 13 The first group of words says that the EPA 

 8 66 5 The EPA method actually, this third bullet, is 

 9 66 6 in error. The EPA methodology does provide a way 

10 68 25 of EPA into a voluntary standards organization 

11 70 25 all these test methods, and then EPA is going to be 

12 71 3 EPA is going to promulgate in a regulatory 

13 71 7 ASTM doesn't define anything for EPA. ASTM 

14 71 8 develops standards. EPA can pick and choose which 

15 71 13 standard versus that standard, but EPA doesn't lose 

16 71 18 working, how's EPA going to maintain some control, 

17 71 22 help. If you want to have EPA do everything, then 

18 71 23 that means EPA has to pay for everything. EPA has 

19 74 24 collection of tools, EPA could specify the ones 

20 77 17 by EPA as equally valuable. These are long-term, 

21 78 17 EPA has conducted studies in the past of these 

22 80 9 recommend that EPA should certainly incorporate 

23 81 8 EPA has been using for years. 

24 81 18 negotiating with EPA over the last several years, 

25 88 23 And I think where we are today, using the EPA 

26 94 22 So an FT -- anonymous FTP site that EPA/ORD 

27 99 24 EPA makes it very public that this is the real 

28 102 8 I didn't know that when I started with EPA 

29 103 5 EPA has one particular view, but at the same 

30 103 11 more money than EPA in the area of model 

31 110 15 not just within EPA, but involving all the Federal 

32 111 6 Nevada where EPA/ORD participated along with 

33 111 9 know EPA is a participant on that group, can 

34 113 7 EPA, when they assess penalties to people who 

35 113 20 I think, within EPA's house itself to try to 

36 114 19 EPA, across Federal Government, trying to promote 

37 117 25 EPA developed the Cox/Tikvart methodology. 

38 118 12 EPA has defined model evaluation techniques 

39 120 18 What would happen if EPA changed the model 

40 121 7 demonstrate to EPA that your model has completed 

41 121 14 that's currently approved by EPA, or maybe it's 

42 122 2 model has its paperwork submitted, EPA goes through 

43 122 22 You've heard some of these before. EPA will 

44 122 25 EPA lays out the criteria and your model, or the 

45 123 6 EPA will lose control. Well, not really, EPA 

46 123 8 and EPA is going to be the gatekeeper. I don't 

47 123 9 think EPA will lose control on this process. 

48 123 15 limit. EPA just has not come up with a way of 

49 123 21 part of being a leader, part of EPA -- if EPA wants 

50 125 3 who is right, and how is EPA going to manage this 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 279 

 2 

 3 Page Ref No. Keyword = "epa" 

 4 ____ _______ _______________ 

 5 

 6 126 23 application, and EPA may need to have a panel of 

 7 126 25 It could be the role of the EPA model clearing 

 8 127 2 house. I imagine that EPA regions may want to 

 9 128 5 To maintain the use of the model, I think EPA 

10 128 17 So EPA's role in this vision that John laid 

11 128 25 EPA has many demands on its resources and 

12 129 2 with recent budgetary strains, can EPA really 

13 132 8 -- the US EPA gives a model the stamp, and this is 

14 132 23 EPA stamp. 

15 137 23 because the regulator heard that EPA was moving in 

16 138 14 was described that EPA's protocol for evaluating 

17 141 8 by an EPA-approved model that is set up in our 

18 142 14 administrator at EPA which really goes to Debbie 

19 144 2 we like to see new science and we'll work with EPA 

20 149 11 view of multiple models and multiple ideas, the EPA 

21 160 22 preferred -- and somebody could with EPA provide 

22 161 16 Code of these programs with -- EPA would want to 

23 161 25 visibility and sufficient use by EPA and by -- by 

24 162 17 modeling -- EPA modeling the way it's commonly 

25 163 23 I don't quite understand, I guess, EPA's need to 

26 164 8 can be carried by EPA, as long as there is a 

27 166 23 acceptance with some other EPA approach. 

28 166 24 Specifically, EPA developed very impressive 

29 168 12 I think that model -- EPA -- I mean it's 

30 168 14 branch of EPA is doing different things. I think 

31 170 5 need to -- EPA needs to push in the further 

32 171 13 TYLER FOX: Tyler Fox, EPA. At present I'm not aware, Roger 

33 174 2 the comments will be of use to EPA. 

34 174 3 We'd like to thank EPA for this opportunity to 

35 185 19 EPA. 

36 185 21 points here for us would be to recommend EPA 

37 186 6 example, we do right now have an EPA fluid model 

38 188 7 were in the process -- that EPA was in the process 

39 188 12 though EPA realizes and agrees with us that it 

40 188 19 Many of us, and I used to work at EPA, very 

41 189 2 if EPA's doing something we like, we will say it 

42 189 3 anyway so that EPA management knows that this is 

43 189 13 Even EPA doesn't know the answer to that, but 

44 189 18 How long will EPA allow the support of ISCST3? 

45 189 20 be used after EPA, after AERMOD becomes an EPA 

46 190 20 enough training is done within EPA so these 

47 191 9 EPA provides the personnel and funding needed to 

48 193 17 going to happen, but we want EPA to know that it is 

49 197 8 these comments is that we'd like to see EPA take a 

50 198 18 today, some comments coming from EPA which we are 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 280 

 2 

 3 Page Ref No. Keyword = "epa" 

 4 ____ _______ _______________ 

 5 

 6 199 8 So, obvious recommendations are, we want EPA 

 7 199 11 Russ give for AERMOD, we also want EPA to provide 

 8 199 23 considered a regulatory model, is that EPA to 

 9 201 7 The recommendations that we have is that EPA 

10 201 11 EPA should collect and distribute these at cost. 

11 202 6 we -- we have also heard a number of times that EPA 

12 202 15 So a number of years ago when EPA was 

13 202 23 that and that was used -- EPA used that. 

14 203 2 other ones you will see, where if EPA feels it is 

15 204 14 EPA should, again, possibly solicit input from 

16 204 22 In the past, we believe we have heard EPA 

17 205 11 EPA take over the guidance for CALPUFF including 

18 205 24 list of some high priority items: EPA should 

19 206 3 EPA should ensure support and timely model 

20 206 7 We'd like to see EPA actively collect and make 

21 206 10 And, again, EPA should reactivate and actively 

22 221 15 representative from Government, FAA, and EPA, and 

23 226 2 referrals and discussions from EPA regional offices 

24 226 5 actually had people tell me to look -- from EPA -- 

25 226 20 EPA's response when someone applying the model for 

26 226 25 not appear that EPA has acted to correct the 

27 227 8 advised EPA of two problems with the AERMAP model. 

28 227 20 were brought to EPA's attention almost eighteen 

29 227 22 the problem were provided to EPA, it does not 

30 228 5 The individual indicated to EPA that the model 

31 228 8 (99). In other words, two integers. Although EPA 

32 228 13 questions about how responsive EPA is being to 

33 228 15 the way, cause a little concern about whether EPA 

34 228 22 If EPA decides to change how the models are 

35 228 25 UARG urges EPA to pay attention to how 

36 229 10 that EPA might hold a modeling conference this 

37 229 19 general information that EPA was considering to -- 

38 230 5 but it wasn't there yesterday, or from the EPA 

39 230 11 that EPA would present information on a, quote, new 

40 230 15 UARG has, in the past, suggested that EPA 

41 231 5 after lunch on Friday when all the EPA invited 

42 231 7 did raise some questions as to whether EPA is truly 

43 231 18 modeling techniques EPA will require and how those 

44 231 24 since we have just learned of the EPA's proposals 

45 231 25 for the issues that EPA is considering, we will 

46 233 5 this is based on reviewing two EPA reports that are 

47 238 21 Now this figure is again taken out of EPA 

48 240 20 We think that EPA should examine the area of 

49 241 5 EPA should investigate both urban performance 

50 243 12 EPA go from here, if it goes anywhere? 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 281 

 2 

 3 Page Ref No. Keyword = "epa" 

 4 ____ _______ _______________ 

 5 

 6 247 7 I hope EPA is thinking about this. 

 7 249 20 It would be nice to have EPA talk to, you 

 8 249 21 know, the NOAA people at EPA talk to the NOAA 

 9 249 24 some of the EPA advance models. 

10 

11 Page Ref No. Keyword = "ETA" 

12 ____ _______ _______________ 

13 

14 200 10 that's RUC, ETA, we've heard about RAMS also 

15 249 9 continuously to the latest ETA and, I guess, what 

16 249 12 ROBERT PAINE: Well, no, there is another name for the ETA 

17 

18 Page Ref No. Keyword = "Federal" 

19 ____ _______ ___________________ 

20 

21 65 7 other Federal agencies and to work with other 

22 110 12 And I think getting other Federal agencies 

23 110 15 not just within EPA, but involving all the Federal 

24 114 19 EPA, across Federal Government, trying to promote 

25 189 25 in the Federal Register, notice at least in the 

26 198 10 guidance from local and Federal agencies in using 

27 204 23 defer to the Federal Land Managers on this issue. 

28 228 23 evaluated, as the Federal Register notes in 

29 229 12 until notice was published through the Federal 

30 229 18 And the Federal Register notice provided only 

31 229 23 model practice highlighted in the Federal Register 

32 229 25 information in the Federal Register does not 

33 230 10 example, if the Federal Register notice indicated 

34 

35 Page Ref No. Keyword = "file" 

36 ____ _______ ________________ 

37 

38 16 4 The tool takes care of file management. It 

39 34 6 not, and the output file actually just says, yes or 

40 42 7 batch file, and it'll go through and run all those 

41 183 9 study to put in -- replace the BPIP file with 

42 195 12 input a file with E flux -- with heat flux in it 

43 207 14 week, before September the 30th, you may file your 

44 218 7 headers of your met file that you are providing and 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 282 

 2 

 3 Page Ref No. Keyword = "files" 

 4 ____ _______ _________________ 

 5 

 6 15 12 the tool and the necessary files for running the 

 7 16 5 extracts results from a model output files; 

 8 35 13 And then finally we also generated plot files 

 9 38 20 files needed for scenarios one and two, and those 

10 86 9 done, that the input files are made available so 

11 86 17 we see those files. 

12 187 23 files. 

13 188 2 most of the files that are available are so-called 

14 188 3 thirty-meter (30m) files and AERMAP reads those. 

15 188 5 (10m) files. 

16 219 23 and over again and generate all those input files, 

17 227 11 terrain model files where the elevations were 

18 227 14 In addition, some of the DEM files express 

19 

20 Page Ref No. Keyword = "forecast" 

21 ____ _______ ____________________ 

22 

23 248 5 archive data or with real time forecast data, 

24 248 22 So we use it as a forecast tool, and we 

25 249 13 model, but the latest NOAA products, NOAA forecast 

26 

27 Page Ref No. Keyword = "forecasts" 

28 ____ _______ _____________________ 

29 

30 74 6 model also forecasts that noise, you can get a 

31 

32 Page Ref No. Keyword = "gridded" 

33 ____ _______ ___________________ 

34 

35 8 13 the use of gridded met data, you saw that 

36 9 6 yesterday afternoon, focusing on the use of gridded 

37 

38 Page Ref No. Keyword = "group" 

39 ____ _______ _________________ 

40 

41 7 4 got here for this area of our group, is to try and 

42 11 6 And then you also saw folks within my group, 

43 11 7 the Air modeling -- Quality Modeling Group; 

44 38 7 grouping available. So in this case, we really 

45 65 13 The first group of words says that the EPA 

46 88 3 Mobil for the model development group, in the 

47 95 7 you had your hands on into a group and then start 

48 100 12 Well, now you evaluate the model for a group of 

49 100 15 profile in this group of data, and how well does it 

50 111 9 know EPA is a participant on that group, can 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 283 

 2 

 3 Page Ref No. Keyword = "group" 

 4 ____ _______ _________________ 

 5 

 6 114 24 relates to my group, and I know OAQPS in general, 

 7 182 21 loads on structures, so the ASCE group uses that to 

 8 185 17 Perhaps it could be done through a working group of 

 9 193 18 important to the user community, to the AWMA group 

10 221 13 design review group, and there are currently twelve 

11 224 20 the Utility Air Regulatory Group [ed.(UARG)]. 

12 

13 Page Ref No. Keyword = "groups" 

14 ____ _______ __________________ 

15 

16 26 2 the locations of the groups of sources. 

17 57 2 wind speed groups and three stability categories, 

18 68 6 standards groups, they have been in existence for 

19 95 3 into groups before you test the model. The idea is 

20 95 5 groups. 

21 103 21 with these other groups, and -- and learning from 

22 246 9 and only a few groups will be running them in 

23 

24 Page Ref No. Keyword = "guidance" 

25 ____ _______ ____________________ 

26 

27 37 23 There is not -- I mean, there's some guidance 

28 60 14 the guidance. 

29 62 2 language is pulled out, and the guidance is 

30 142 4 working on the -- to come up with some guidance on 

31 160 23 the guidance, saying we will be coordinated with 

32 161 2 using that and here are the guidance, let's 

33 183 18 current guidance or regulations. 

34 185 14 But guidance for regulatory application, of 

35 187 9 documentation and guidance issues that need to be 

36 190 2 guidance, it should be very, very clear exactly 

37 191 11 Guidance issues. 

38 191 13 Providing sufficient guidance to assure that 

39 191 17 A little -- I need little more guidance than 

40 191 21 guidance doesn't come out to we can never get 

41 192 9 However, there is a need for guidance on what 

42 192 14 guidance on it as well. 

43 192 20 are not, the use of the land -- guidance on land 

44 192 24 restrictions on that guidance on defining seasons 

45 194 10 the guidance needs to be perhaps carefully crafted 

46 194 22 documentation at some point, or in the guidance at 

47 196 9 of its implementation, guidance and documentation. 

48 198 10 guidance from local and Federal agencies in using 

49 204 2 guidance, inconsistency on acceptability is 

50 204 10 to receive some clear guidance that maybe would end 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 284 

 2 

 3 Page Ref No. Keyword = "guidance" 

 4 ____ _______ ____________________ 

 5 

 6 205 3 There is no clear guidance available. It's 

 7 205 11 EPA take over the guidance for CALPUFF including 

 8 205 15 guidance on these various issues associated with 

 9 206 2 guidance for CALPUFF. 

10 206 22 guidance. That -- that's just the basic 

11 221 20 enhancements, provide technical guidance for how to 

12 226 3 involving the interpretation of modeling guidance 

13 

14 Page Ref No. Keyword = "guide" 

15 ____ _______ _________________ 

16 

17 49 9 appendix to 40 CFR, Part 51 in the Guidelines. 

18 50 2 And always, as the guidelines specifically 

19 50 10 it must have a user's guide. And this user's guide 

20 51 20 So all of that is referenced in the guideline. 

21 73 15 guideline. It doesn't specify a specific 

22 77 3 this guide does apply to the tracer field studies 

23 77 20 addressed by the ASTM guideline, but addressed by 

24 80 10 this guide in their approved techniques for 

25 120 19 guideline to say: the minimum acceptable 

26 134 17 It will be the guidelines rather than 

27 182 17 is already a guideline for wind-tunnel modeling. 

28 186 7 and guideline for wind tunnels, but it probably 

29 186 10 We right now do need a CFD modeling guideline. 

30 186 11 There is no guideline at all for that. So that 

31 199 16 The users guide is out of date and incomplete. 

32 199 25 user's guide corresponding to the official 

33 232 16 guidelines on air quality models. 

34 232 21 somewhat different insofar as what the guideline 

35 243 7 First of all, the guideline doesn't really 

36 

37 Page Ref No. Keyword = "guideline" 

38 ____ _______ _____________________ 

39 

40 51 20 So all of that is referenced in the guideline. 

41 73 15 guideline. It doesn't specify a specific 

42 77 20 addressed by the ASTM guideline, but addressed by 

43 120 19 guideline to say: the minimum acceptable 

44 182 17 is already a guideline for wind-tunnel modeling. 

45 186 7 and guideline for wind tunnels, but it probably 

46 186 10 We right now do need a CFD modeling guideline. 

47 186 11 There is no guideline at all for that. So that 

48 232 21 somewhat different insofar as what the guideline 

49 243 7 First of all, the guideline doesn't really 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 285 

 2 

 3 Page Ref No. Keyword = "guidelines" 

 4 ____ _______ ______________________ 

 5 

 6 49 9 appendix to 40 CFR, Part 51 in the Guidelines. 

 7 50 2 And always, as the guidelines specifically 

 8 134 17 It will be the guidelines rather than 

 9 232 16 guidelines on air quality models. 

10 

11 Page Ref No. Keyword = "implement" 

12 ____ _______ _____________________ 

13 

14 6 19 actually plan and do things to implement your plan, 

15 8 15 The first two sessions, AERMOD implementation 

16 8 16 and CALPUFF implementation. 

17 8 19 thought nicely flowing, to the implementation 

18 8 24 implementing it, learning through applications and 

19 13 17 It's to be implemented when we make changes to 

20 63 5 and then, also, there's implementation 

21 70 15 methodologies that implement the met- -- you know 

22 71 9 methodologies they wish to implement and which ones 

23 118 21 and implement them and test them. 

24 153 16 honestly don't see how we're going to implement a 

25 168 9 more systematically implemented. Hopefully that 

26 184 19 the implementation issues, the wind tunnel and CFD 

27 185 3 averages? That would be an implementation issue. 

28 187 8 And -- but there are some implementation, 

29 189 5 Implementation issues provide the intended 

30 196 9 of its implementation, guidance and documentation. 

31 196 16 implementation of CALPUFF. 

32 205 9 concerns in CALPUFF implementation. 

33 244 6 implementation of the PM-2.5 standard. It does 

34 

35 Page Ref No. Keyword = "implementation" 

36 ____ _______ __________________________ 

37 

38 8 15 The first two sessions, AERMOD implementation 

39 8 16 and CALPUFF implementation. 

40 8 19 thought nicely flowing, to the implementation 

41 63 5 and then, also, there's implementation 

42 184 19 the implementation issues, the wind tunnel and CFD 

43 185 3 averages? That would be an implementation issue. 

44 187 8 And -- but there are some implementation, 

45 189 5 Implementation issues provide the intended 

46 196 9 of its implementation, guidance and documentation. 

47 196 16 implementation of CALPUFF. 

48 205 9 concerns in CALPUFF implementation. 

49 244 6 implementation of the PM-2.5 standard. It does 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 286 

 2 

 3 Page Ref No. Keyword = "implementing" 

 4 ____ _______ ________________________ 

 5 

 6 8 24 implementing it, learning through applications and 

 7 

 8 Page Ref No. Keyword = "ISC" 

 9 ____ _______ _______________ 

10 

11 7 15 AERMOD is no ISC. 

12 21 7 a transition from a PG based dispersion, ISC-like 

13 45 18 past except when we went from ISC-1 to ISC-2, there 

14 66 2 performance of ISC, in demonstrating to the public 

15 66 4 compared with ISC. 

16 81 10 evaluating both the PRIME, ISC-PRIME and in the 

17 102 2 thought that ISC was predicting the second high 

18 102 15 process of ISC and -- and AERMOD, even. I'd like 

19 132 9 certainly the case for ISC, it becomes the sort of 

20 132 22 rather (cough) than ISC, just because ISC had a US 

21 133 2 models than ISC. 

22 137 8 Canada, where we were initially asked to use ISC 

23 137 11 some high concentrations, and, of course, ISC was 

24 138 11 compared ISC, AERMOD, and ADMS. And I won't go 

25 138 22 AERMOD was significantly improved over ISC, there 

26 142 22 still have people who use ISC and ISC-PRIME, and we 

27 143 4 how -- how different AERMOD was from ISC was such a 

28 143 5 -- you know -- it looks like ISC, but that's about 

29 147 13 using ISC all the time, you know, that's never been 

30 147 14 an issue. If you used ISC, you used ISC. 

31 147 23 CALPUFF, AERMOD, ISC3, CT screen, you know, IGM 

32 170 20 Is there a need kind of rule in AERMOD or ISC 

33 189 19 Are there any situations where ISC can continue to 

34 190 3 where, you know, when, if ISC completely 

35 193 22 as SCREEN was relative to the ISC, or is it going 

36 208 17 to give his course again on ISC-PRIME. 

37 233 18 with that of ISC, and that AERMOD appears to 

38 234 11 observed in ISC. 

39 234 18 column under ISC for rural, and this is the rural 

40 235 2 If we look at the comparison between the ISC 

41 235 19 between the ISC and AERMOD is that when we look at 

42 235 23 for ISC. 

43 236 3 they were for ISC in urban areas, which -- which 

44 236 10 urban, between ISC and AERMOD, and just in this 

45 236 11 ratio which is the ISC to the AERMOD 

46 237 8 dispersion going on in the urban setting for ISC. 

47 237 24 looking across the concentrations between ISC and 

48 238 2 from ISC to -- to AERMOD; that is, we're -- we're 

49 240 13 with that of ISC. It's not apparent whether this 

50 241 11 grandfathering period of ISC should be extended to 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 287 

 2 

 3 Page Ref No. Keyword = "ISC-PRIME" 

 4 ____ _______ _____________________ 

 5 

 6 81 10 evaluating both the PRIME, ISC-PRIME and in the 

 7 142 22 still have people who use ISC and ISC-PRIME, and we 

 8 208 17 to give his course again on ISC-PRIME. 

 9 

10 Page Ref No. Keyword = "layer" 

11 ____ _______ _________________ 

12 

13 182 5 layer theory much like what's in the AERMOD right 

14 

15 Page Ref No. Keyword = "layers" 

16 ____ _______ __________________ 

17 

18 143 8 boundary layers and all, you know, the surface 

19 

20 Page Ref No. Keyword = "mesoscale" 

21 ____ _______ _____________________ 

22 

23 197 21 a -- specifically mesoscale data sets to go along 

24 207 4 of this mesoscale meteorological data sets that we 

25 

26 Page Ref No. Keyword = "met" 

27 ____ _______ _______________ 

28 

29 8 13 the use of gridded met data, you saw that 

30 9 7 met data, something that we need to consider. We 

31 10 24 Also, you met a number of folks that work 

32 11 4 job on the meteorological side, and within our 

33 18 24 domains and meteorology, types of meteorological 

34 21 4 meteorological data, we have both. 

35 21 17 real met data, either the National Weather Service 

36 21 20 idealized scenarios to idealize met data, idealize 

37 23 15 sort of generated the met data to run through 

38 24 4 source, a thirty (30) meter non-buoyant point 

39 24 5 source, and then a sixty-five (65) meter buoyant 

40 24 24 PRIME downwash sources, a thirty-five (35) meter 

41 24 25 buoyant stack, a thirty-five (35) meter cap stack, 

42 25 2 and then a fifty (50) meter buoyant stack. I think 

43 25 4 (34) meter building that's been used in EPA 

44 28 9 three hundred meters in height, located at the 

45 28 12 meters. 

46 28 15 state meteorology was set up to idealize. 

47 29 21 steady state meteorology, six hours of stable 

48 30 22 Sixty-five (65) meters, looks like the plume 

49 31 20 meters are coming out of the southwest. I think we 

50 31 22 level -- two hundred (200) meter level. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 288 

 2 

 3 Page Ref No. Keyword = "met" 

 4 ____ _______ _______________ 

 5 

 6 32 19 This is the sixty-five (65) meter buoyant 

 7 33 10 scenario that didn't base its meteorology on CALMET 

 8 38 25 And then there are a few unsupported NWS met 

 9 48 8 model evaluation methods. 

10 48 13 methods, and we want to discuss the additional 

11 48 14 approaches and methods that are available in 

12 51 17 it references the ASTM method to provide a general 

13 52 13 method that was a paper generated, I believe, in 

14 52 21 This equation, right here, defines the method 

15 53 4 you have a metric that can describe the comparision 

16 53 15 So it's a nice handy metric where it does not 

17 53 19 And the screen method is based on the highest 

18 54 21 precise time, the location and the meteorological 

19 56 2 there's more metrics that are coming; it builds on 

20 56 9 location and the meteorological conditions are of 

21 56 19 It also uses the fractional bias as the metric 

22 57 9 meteorological conditions, we're trying to compare 

23 57 14 components into one metric, and it's called the 

24 57 15 composite performance metric or CPM. 

25 58 16 that's a composite performance metric. 

26 58 23 more metric; the model comparison measure, or MCM, 

27 59 9 a blocked, bootstrap method that is suggested in 

28 59 23 metric, and this, again, is just a single model 

29 60 12 protocols and the methods that we have right now in 

30 65 14 created the Cox/Tikvart methodology of robust 

31 65 16 bias, and came up with a methodology for evaluating 

32 66 5 The EPA method actually, this third bullet, is 

33 66 6 in error. The EPA methodology does provide a way 

34 67 8 current evaluation methodologies need to be 

35 67 14 develop the evaluation methods, is to try and get 

36 67 17 evaluation methods but almost continually update 

37 67 18 our evaluation methods as we learn new things in 

38 68 21 really is to develop evaluation methodologies that 

39 69 5 The -- a test method could be devised, could 

40 70 5 advance what the new evaluation methodologies are 

41 70 10 people to use those methodologies that are being 

42 70 15 methodologies that implement the met- -- you know 

43 70 16 -- the test methods, they could make all that 

44 70 25 all these test methods, and then EPA is going to be 

45 71 2 forced to use these test methods. Not really. 

46 71 4 action the test methods that they accept and want 

47 71 6 methods are going to be used. 

48 71 9 methodologies they wish to implement and which ones 

49 73 12 methods. 

50 73 13 There is a test method or a test standard in 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 289 

 2 

 3 Page Ref No. Keyword = "met" 

 4 ____ _______ _______________ 

 5 

 6 73 16 methodology to be used. It specifies a philosophy, 

 7 74 8 So this ASTM methodology was up for its 

 8 74 14 The Cox/Tikvart methodology that was mentioned 

 9 78 21 evaluation methodology software has been developed 

10 79 8 Also, the large range of meteorological 

11 83 20 model evaluation methodologies, I think it's 

12 85 4 methodology. 

13 85 6 ASTM methodology should be brought forward, but 

14 85 20 believe, by John's ASTM methodology. 

15 88 18 evaluation methods, and I, whether they be for 

16 88 24 methods for evaluating models or some of the 

17 88 25 methods that API has used, using a slightly 

18 89 9 methods and perhaps fine tune them and tweak them, 

19 89 17 methods, maybe more, I don't think that's really 

20 90 2 evaluation methods with data sets where we have 

21 91 22 meteorological settings. 

22 93 10 the -- how we envision modern evaluation methods to 

23 93 21 In order for it to become a test method, it 

24 93 23 written up as a test method and demonstrated that 

25 93 25 you to use that method. It would have to be pulled 

26 94 6 developing statistical evaluation methods for air 

27 94 13 models and -- and see how the test method worked, 

28 94 16 We have learned that the methodology had to be 

29 94 19 including all model inputs all meteorology, all 

30 96 23 can, have these -- have these test methods 

31 97 3 of the test methods, so I mean, if I gave you 

32 97 21 of test method, I think, recognizes that and that's 

33 99 12 just finish by saying that when a test method comes 

34 99 15 methods are trying to answer. 

35 99 17 whether that test method is important to the answer 

36 101 16 be using the same meteorology that we used thirty 

37 106 12 JOHN VIMONT: I don't disagree. However, the metrics that 

38 106 17 JOHN IRWIN: I agree. That's why we need new methods. 

39 113 15 that as a collection method of collecting -- you 

40 117 25 EPA developed the Cox/Tikvart methodology. 

41 119 20 collection of evaluation (cough) methods. We 

42 119 24 whole collection of evaluation methods that we're 

43 120 4 that's developing evaluation methods and kicking 

44 120 5 out methods, and people are developing data sets 

45 121 9 going to test your model using ASTM test methods A, 

46 121 16 method. 

47 171 7 it's meteorological concept going on or the 

48 173 18 Association, we are known as AB3 in the meteorology 

49 173 20 The meteorology committee used to be called 

50 173 21 meteorological aspects of air pollution control. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 290 

 2 

 3 Page Ref No. Keyword = "met" 

 4 ____ _______ _______________ 

 5 

 6 173 23 meteorology committee, more than are here at the 

 7 175 10 cannot be used for all meteorological conditions. 

 8 179 12 methods, you know, if it's -- CFD codes have many 

 9 186 2 these methods in these areas, some kind of -- 

10 186 5 And, also, have some kind of methodology. For 

11 187 25 elevation samples are made ten meters (10m) apart, 

12 192 12 PVMRM method is new. There needs to be -- its 

13 197 18 discussion about the use of meteorological data 

14 197 25 seems to be a lack in the methodology for 

15 200 3 Al right, meteorological data. 

16 200 19 three years of meteorology, are not generally 

17 201 3 three years of meteorological data to five years. 

18 201 5 do we have five years of data -- meteorological 

19 202 11 provide some recommendations on methods that we -- 

20 206 8 available these meteorological data sets, and then 

21 207 4 of this mesoscale meteorological data sets that we 

22 207 7 Again, a methodology to evaluate the CALMET 

23 215 9 metric as well as the English units. 

24 215 16 methodology, and those of you that have done noise 

25 215 18 methodology that's used by INM, the Integrated 

26 217 2 twenty meters wide, but realizing that not all the 

27 217 7 meters that remains as the default. 

28 218 5 wizard, and now it includes the database of met 

29 218 7 headers of your met file that you are providing and 

30 220 11 fuel flow method two, we can take the met data, 

31 227 12 expressed in meters, although the model worked 

32 234 3 It dealt with two meteorological data sets; 

33 235 9 have concentrations where the two meteorological 

34 245 3 -- and meteorological variables are defined in each 

35 

36 Page Ref No. Keyword = "meteorological" 

37 ____ _______ __________________________ 

38 

39 11 4 job on the meteorological side, and within our 

40 18 24 domains and meteorology, types of meteorological 

41 21 4 meteorological data, we have both. 

42 54 21 precise time, the location and the meteorological 

43 56 9 location and the meteorological conditions are of 

44 57 9 meteorological conditions, we're trying to compare 

45 79 8 Also, the large range of meteorological 

46 91 22 meteorological settings. 

47 171 7 it's meteorological concept going on or the 

48 173 21 meteorological aspects of air pollution control. 

49 175 10 cannot be used for all meteorological conditions. 

50 197 18 discussion about the use of meteorological data 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 291 

 2 

 3 Page Ref No. Keyword = "meteorological" 

 4 ____ _______ __________________________ 

 5 

 6 200 3 Al right, meteorological data. 

 7 201 3 three years of meteorological data to five years. 

 8 201 5 do we have five years of data -- meteorological 

 9 206 8 available these meteorological data sets, and then 

10 207 4 of this mesoscale meteorological data sets that we 

11 234 3 It dealt with two meteorological data sets; 

12 235 9 have concentrations where the two meteorological 

13 245 3 -- and meteorological variables are defined in each 

14 

15 Page Ref No. Keyword = "mixing" 

16 ____ _______ __________________ 

17 

18 36 14 corrected a problem with mixing heights over 

19 39 23 mixing height over water. So if you had not had a 

20 

21 Page Ref No. Keyword = "MM5" 

22 ____ _______ _______________ 

23 

24 21 6 MM5 data. And then we, also, since we are still in 

25 21 18 data, or MM5, or both. 

26 22 12 driven by MM5 in the No Obs mode. So, --. 

27 22 17 data with MM5, so a mixture. 

28 25 21 the MM5 data we used also had a twelve kilometer 

29 26 5 MM5 data, showing the domain. It was a much larger 

30 26 6 domain, and we took a subset out of the MM5 domain 

31 26 7 to drive scenario two, which was MM5 in the No Obs 

32 26 16 So we started with twelve kilometer (12km) MM5 

33 28 6 with the MM5 data for scenario two and three. 

34 35 18 was, again, just MM5 data driving it in the No Obs 

35 38 16 And so our MM5 data, since it was already 

36 39 2 data formats, some of the MM5 data was, I think, 

37 42 16 of the used surface data and MM5 data for the long 

38 42 18 ROGER BRODE: That was No Obs, MM5 only. Scenario three is 

39 42 19 where we mer- -- sort of merged NWS with MM5 data 

40 42 22 MM5 and then one with mixed. 

41 42 23 MARK GARRISON: NWS surface and MM5 data? 

42 42 24 ROGER BRODE: NWS surface and upper air and MM5 data. I 

43 42 25 think we used the MM5 data to initialize the wind 

44 200 9 No Obs, various MM5 data sets that are available; 

45 200 13 thirty-six (36) kilometer MM5 data sets which are 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 292 

 2 

 3 Page Ref No. Keyword = "model" 

 4 ____ _______ _________________ 

 5 

 6 7 17 science; modeling science and the like, that really 

 7 7 25 of thousands or millions of dollars to -- for model 

 8 8 18 of the model, and then all the way through, I 

 9 8 21 this new model, and the existing model that we 

10 10 6 approaches or different ways of going through model 

11 10 17 First, Warren Peters, our Model Clearing House 

12 11 7 the Air modeling -- Quality Modeling Group; 

13 11 10 dispersion modeling. 

14 11 13 our dispersion modeling team with Warren as -- as 

15 11 24 modelers that are here, a number of whom 

16 12 14 the regional modelers, and, again, I appreciate 

17 13 13 CALPUFF model. 

18 13 18 a regulatory dispersion model, either CALPUFF or 

19 13 21 model. 

20 13 23 need -- it needs to identify differences in model 

21 14 7 differences between the beta and the updated model 

22 14 8 of -- the current model and the beta, the updated 

23 14 9 model in estimates that are used in regulatory 

24 14 14 When we update a model in some cases we expect 

25 14 21 replace the model clearing house facility degrees 

26 14 22 of freedom in a CALPUFF modeling analysis and its 

27 15 17 I'm sorry -- the execution of the old and new model 

28 16 5 extracts results from a model output files; 

29 16 6 identifies differences in the model estimates and 

30 16 9 freedom in a -- in a modeling system like CALPUFF, 

31 16 19 model components are involved in the difference if 

32 16 25 comfortable releasing the model to the regulatory 

33 18 19 application of the model. 

34 18 23 scenarios cover a range of source types, modeling 

35 19 3 version of the model which is to defined as the 

36 19 6 Beta version of the model, which is now the July, 

37 19 14 the base and beta versions of the modeling system. 

38 20 4 that's one model run. The Beta version of CALPUFF 

39 20 21 range of sources, again a long range of modeling 

40 20 23 wide gamut of modeling scenarios from --. 

41 34 25 application of the model. 

42 35 20 but this is the large modeling domain, and it's 

43 37 9 the CALPUFF modeling system, we had wanted to 

44 37 12 base versions of the modeling system have an issue 

45 38 5 sure anybody who has run the CALPUFF modeling 

46 43 6 to every model change of every model, because I 

47 43 7 think there has been dozens of model changes over 

48 43 24 AERMOD and one of these for myriad of other model 

49 44 12 kind of analysis for, say, a model like SCIPUFF 

50 44 21 model in the first place? 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 293 

 2 

 3 Page Ref No. Keyword = "model" 

 4 ____ _______ _________________ 

 5 

 6 45 7 some of the model evaluation data sets. 

 7 45 13 model has changed, then that might be something to 

 8 46 5 have gone back and looked at the model evaluation 

 9 46 23 sometimes we made significant changes to the model, 

10 47 9 model, you'd have a change in the first digit, so 

11 48 8 model evaluation methods. 

12 48 12 provide an overview of the current model evaluation 

13 48 15 conducting model components evaluations. 

14 48 17 conduct model components evaluations is warranted, 

15 48 23 it's going to be just a brief overview of the model 

16 49 17 subsection B here, it says, when a model is found 

17 49 18 to perform better than the listed model, it is 

18 49 19 recommended as a preferred model. 

19 49 21 It goes on to say here, if no model performs 

20 49 22 better than the current preferred model, then other 

21 50 8 Under Subsection C, a new model must be, and 

22 50 12 just turn on the model, it has to include some -- 

23 50 13 some of the mathematics of the model, so you will 

24 50 15 of algorithms behind the model, the minimum data 

25 50 16 requirements to drive the model, and the basic 

26 50 18 Each model should have a complete set of test 

27 51 12 new model performs better, or the preferred model 

28 52 9 the Best Performing Model", which came out in 

29 53 7 at that if the predicted model is a factor or two 

30 53 12 prediction model is higher than the observed 

31 54 13 model is predicted by a factor or two higher over 

32 54 14 the twenty-five (25) highest values, the model may 

33 55 3 statistic that we have in this model is called the 

34 57 13 model protocol we're going to combine both 

35 57 22 suggested equation in the model protocol, and in 

36 58 21 And then doing the model to model comparison 

37 58 23 more metric; the model comparison measure, or MCM, 

38 59 3 from model A to model B. So it's a relatively 

39 59 21 so that -- in the model-to-model comparison, is 

40 59 23 metric, and this, again, is just a single model 

41 61 6 specific definition of a model that's appropriate 

42 61 7 for a situation compared to the preferred model. 

43 61 9 there's a preferred model, the Agency says that if 

44 61 10 you use that model, no problem, just use it, we'll 

45 61 12 is another model more appropriate for that 

46 61 18 that the best model then wins and can be used for 

47 61 22 will later about how to bring a new model like 

48 61 23 AERMOD or CALPUFF or some other model into the 

49 63 13 preferred model. 

50 63 18 mostly to incorporate the new model, you know, 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 294 

 2 

 3 Page Ref No. Keyword = "model" 

 4 ____ _______ _________________ 

 5 

 6 65 17 performance of the model to predict a very high 

 7 66 3 the performance of the new model and how it 

 8 67 11 model performance. So I'll come back to this point 

 9 74 5 test your model to perform against it, unless your 

10 74 6 model also forecasts that noise, you can get a 

11 74 7 false impression of what your model is doing. 

12 74 22 collection of tools on how to evaluate model 

13 78 20 complex terrain model evaluations, and the model 

14 80 14 be common statistical measures for overall model 

15 81 6 panel because of his extensive experience in model 

16 81 16 Doctor Carruthers is championing the model 

17 81 19 and I know he's gone through the model evaluation 

18 82 11 dispersion modeling system, since 1988, so I have a 

19 82 13 of -- of the model and -- and obviously the 

20 83 13 Danish model, which I believe was the first ever 

21 83 14 Rentree model developed using scaling. 

22 83 20 model evaluation methodologies, I think it's 

23 84 11 model tool kits in Europe is the things that look 

24 84 22 model performance. 

25 85 11 I've written down below the model validation 

26 85 17 both the -- both the boot package and the model 

27 87 10 so forth, and did some model evaluation. There was 

28 88 3 Mobil for the model development group, in the 

29 89 4 at the significance of the model differences that 

30 90 4 the model and basically dumb down the model to 

31 92 4 So by going through and evaluating a model for 

32 92 8 the model is performing over all the spectrum of 

33 92 12 which we need the model, the model evaluation: 

34 92 16 to extrapolate the model and prior to these sources 

35 93 7 conduct a model evaluation. 

36 94 10 David. He's run his model for us so that we 

37 94 11 could have model runs for three different data 

38 94 18 The latest model runs are all available 

39 94 19 including all model inputs all meteorology, all 

40 95 3 into groups before you test the model. The idea is 

41 97 18 model over and over and over and over again, you 

42 97 25 If we go and we develop a model and we compare it 

43 98 11 you build the model that somehow has an inherent 

44 98 17 and say, I run the model, I have some confidence 

45 98 19 the model that goes after the ensemble, and now you 

46 98 25 is is you get this model that's designed for [an] 

47 100 5 model that worries about predicting not only the 

48 100 11 Now what would you do to evaluate that model? 

49 100 12 Well, now you evaluate the model for a group of 

50 100 14 ask, how well does the model predict the average 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 295 

 2 

 3 Page Ref No. Keyword = "model" 

 4 ____ _______ _________________ 

 5 

 6 100 17 So now you test your model on two things; the 

 7 100 20 Then how would you use the model? 

 8 100 21 Well, if you want the model to be used to look 

 9 100 23 model in a stochastic form. You would have it 

10 101 9 future, for model development. More sophisticated 

11 101 10 thinking in our model development is going to 

12 102 7 something wrong in the model. 

13 103 3 model development evaluation efforts that are going 

14 103 11 more money than EPA in the area of model 

15 105 22 question; you want a model to predict what's seen 

16 106 5 fully stochastic model, it will give you a full 

17 107 7 area, and the model evaluation is saying, I've got 

18 107 12 then the model may be used for other things as 

19 108 3 bottom line here for modelers that are using, you 

20 108 6 the model evaluation reports, going through them 

21 108 8 modeling forms you've seen and notice that they're 

22 108 12 know the model does a good job, and how it's been 

23 108 17 model. 

24 108 19 areas where you realize that the model has not been 

25 108 22 those model evaluation reports. Again, probably 

26 111 21 photochemical modeling studies, and there are 

27 113 18 modeling validation study. 

28 114 9 an issue of -- and issue of -- of model 

29 114 21 approach to -- to model development that is really 

30 115 24 just throw out the question of -- of model 

31 116 6 model science as it changes and the evaluations as 

32 118 12 EPA has defined model evaluation techniques 

33 119 14 to see whether the differences, even if one model 

34 120 18 What would happen if EPA changed the model 

35 120 20 documentation for an acceptable model is..., and 

36 120 25 And then they said, by the way, your model has 

37 121 7 demonstrate to EPA that your model has completed 

38 121 9 going to test your model using ASTM test methods A, 

39 121 11 and you must demonstrate that your model does at 

40 121 13 level of skill; maybe it's defined by the model 

41 121 19 particular model. It just says a particular skill 

42 122 2 model has its paperwork submitted, EPA goes through 

43 122 4 goes up on their web site and lists this model and 

44 122 7 this model is ready for regulatory use in these 

45 122 23 be forced to accept a bad model. 

46 122 25 EPA lays out the criteria and your model, or the 

47 123 2 model that is approved does at least as well in all 

48 123 3 of these different tests as the approved model, can 

49 123 4 you say that this is a bad model, and should not be 

50 124 22 out, extensive arguments over the best model where 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 296 

 2 

 3 Page Ref No. Keyword = "model" 

 4 ____ _______ _________________ 

 5 

 6 124 24 predicting model and opponents advocate the highest 

 7 124 25 predicting model, and that leads to probably all 

 8 125 24 issue, because a good model must perform well 

 9 126 5 have to wait fourteen (14) years to have a model 

10 126 8 geared to avoiding model under predictions and 

11 126 9 making note of the areas where model performance 

12 126 15 can be qualified based on the model formulation, 

13 126 20 So, you measure that each model use would have 

14 126 21 to have a modeling protocol, and selected case as 

15 126 22 to why the selected model is the best for the given 

16 126 25 It could be the role of the EPA model clearing 

17 127 10 those are peer review and evaluation tests. Model 

18 127 12 Now in the case of a proprietary, or a model 

19 127 16 accurately portrays what the model is -- is 

20 127 18 think the model formulation would have to be 

21 127 20 In any -- any case for any model, that's 

22 127 23 if you don't know the value of certain model inputs 

23 128 5 To maintain the use of the model, I think EPA 

24 128 10 entities at a reasonable cost, and if a model is 

25 128 21 Decisions on model selection could certainly 

26 130 3 model. 

27 130 5 of another model and the two issues which concerns, 

28 130 8 single preferred model; and secondly right at the 

29 130 9 bottom that they think the model should be 

30 130 16 model status in the one model, and what 

31 131 2 one model should be used. And I do, you know, I 

32 131 15 proprietary model could be, for instance, shown to 

33 131 16 be better than them, a nonproprietary model, what 

34 131 20 third model was first, or perhaps when there were a 

35 131 22 easier to -- to stick with one model, and mention 

36 132 8 -- the US EPA gives a model the stamp, and this is 

37 132 10 model which is accepted and used 

38 132 13 that model does deal with the applications in the 

39 132 17 the best model, and even it's used for applications 

40 133 5 model can tend to stifle development and scientific 

41 133 20 system where potential for more than one model to 

42 134 20 a different use of the model for a particular 

43 135 10 the model developer should sort of fit, I wasn't 

44 135 15 model, well, I think so sort of threshold criteria, 

45 136 17 select the model. 

46 136 19 their own ideas about a model, and sometimes it 

47 136 20 might be a U.S. model, and sometimes it might be a 

48 136 21 model from Europe or somewhere else. 

49 137 3 model. 

50 137 19 wind fields that were being used in the model 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 297 

 2 

 3 Page Ref No. Keyword = "model" 

 4 ____ _______ _________________ 

 5 

 6 138 25 at the time was, why can't I use that model. 

 7 140 12 single model that can only be used until -- because 

 8 140 23 futures in modeling, and I must say that my first 

 9 141 8 by an EPA-approved model that is set up in our 

10 142 15 Lowman then, our regional modeler who will just -- 

11 142 20 and that what we have is the best model, and we 

12 143 10 you get the parameters right for the model. 

13 143 11 And if we have another model that's just as 

14 143 12 good as AERMOD, we'll have to learn that model, 

15 143 13 we'll have to be trained on that model, learn its 

16 143 25 preferred model first, though we are, like I said, 

17 144 14 know, the learning curve on each model is quite 

18 145 5 We don't do much model development. We're 

19 146 23 We do think that the preferred model approach, 

20 146 24 or having a preferred model, is a good idea. That 

21 146 25 way you do have one model that you feel comfortable 

22 147 4 So having a preferred model is good, but 

23 147 17 model, and we do have to go out there and figure 

24 147 18 out which model is the best model to use, and we 

25 148 5 best model to use in that case. 

26 148 15 you're seeing an entirely new model and an entirely 

27 149 18 this model", or another model, or some other model 

28 149 19 or some other model, was, use your best judgment. 

29 149 21 planner, shall we say, what model to use. 

30 149 24 completely different way of looking at the model 

31 150 8 right model for this particular application. Right 

32 150 9 now we have one model that has to cover all 

33 150 17 against sets of sources that we have to model every 

34 150 21 important way that we are to do modeling. 

35 154 6 model passes the standard. As we've learned with 

36 154 12 how that model really works and in what 

37 154 18 you know -- ADMS is a great model, and I think 

38 155 3 baseline preferred model for a system where you 

39 155 12 XYZ model is better for that application. In that 

40 155 16 model development, when people start building model 

41 156 3 to do to tweak this model to get it to the pass 

42 156 16 preferred model system. We need to have a way of 

43 156 17 getting a better model through the system. 

44 156 19 reason why AERMOD has to be the preferred model, if 

45 156 20 there is another model that should take over its 

46 156 21 place, that model should be brought through. 

47 156 25 needing a proprietary model, but I guess in the 

48 157 3 and I -- and I didn't like the results of a model, 

49 157 5 model. 

50 157 13 especially a model. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 298 

 2 

 3 Page Ref No. Keyword = "model" 

 4 ____ _______ _________________ 

 5 

 6 157 17 owns that model; we don't -- we can't touch the 

 7 158 3 hard to move from model-to-model to model and then 

 8 158 11 same model, but it's very hard to even get the 

 9 158 15 better plume model. 

10 158 18 it's a limitation, it's a straight line model. We 

11 158 20 So the next model then would be something like 

12 158 21 a puff model, which is also intermediate before we 

13 159 20 example, CALPUFF model which is a preferred model 

14 160 8 with a conclusion that the bare model would be, 

15 160 9 theoretical would be, a [tracer? LaGrangian? stochastic? ] 

particle model 

16 160 25 have a [LaGrangian?] particle model, it will -- we'll be 

17 161 4 How can we improve a puff model, and forget 

18 161 8 a more general precise model. So that's my two 

19 162 2 model users as a part of the conditions. 

20 162 17 modeling -- EPA modeling the way it's commonly 

21 163 25 The vast majority of model users never look at 

22 164 15 code isn't acceptable in -- in this modeling 

23 165 4 this alternate model point that was mentioned. 

24 165 10 select that model. 

25 165 19 impediment to using the model. 

26 166 22 Irwin's approach. I'm comparing this modeling 

27 166 25 model of data quality objective model dealing with 

28 167 3 basically the model recognized, there is a lot of 

29 167 8 variation. So that model take into consideration 

30 167 12 we have a model, we -- everybody understand that a 

31 167 13 model does not predict exact value, but then in a 

32 168 2 I think that model is -- that concept -- I'm 

33 168 3 not saying that model can be directly used for the 

34 168 4 modeling type of situation, but that concept, I 

35 168 12 I think that model -- EPA -- I mean it's 

36 168 17 Similarly -- I mean, modeling is similar to 

37 168 20 recognize the uncertainty on the modeling side -- 

38 169 9 then once you fit that model, then it's okay. 

39 170 14 regular modeling or this special modeling, though I 

40 170 18 evaluation and the model and permitting. I have a 

41 170 22 processing, it give that, how the model 

42 171 3 so that one can say that whether the model is under 

43 171 6 able to enlighten like the model whether 

44 174 8 nonstandard modeling approach is to be given by Ron 

45 174 22 modeling and wind-tunnel modeling. 

46 178 14 turbulence model. 

47 178 22 But in the CFD model has boundary conditions, 

48 179 3 even with the perfect model, even if you had the 

49 179 4 perfect regulatory model, there's uncertainty in 

50 181 2 would come out of air modeling. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 299 

 2 

 3 Page Ref No. Keyword = "model" 

 4 ____ _______ _________________ 

 5 

 6 181 10 threatening present regulatory model. 

 7 181 13 Wind-tunnel modeling, just background on that. 

 8 181 21 And the math model should really be able to 

 9 181 24 model testing and validation. 

10 182 9 plume model, and there's no time scaling really is 

11 182 17 is already a guideline for wind-tunnel modeling. 

12 182 20 wind-tunnel modeling right now for specifying wind 

13 185 12 tunnel fields, so there is still some model 

14 185 23 modeling may be used to complement existing approved 

15 186 6 example, we do right now have an EPA fluid model 

16 186 10 We right now do need a CFD modeling guideline. 

17 187 5 The model evaluation which most of you have 

18 189 21 model of choice, short of demonstrating its -- that 

19 189 22 it is a better model which is not likely to happen 

20 190 8 you find a state wants to use an outdated model, 

21 190 11 Point of contact or questions about the model 

22 190 14 model is released -- is promulgated, but we want to 

23 191 6 that there is a maintenance plan and that the model 

24 192 18 model users but not, even some of those of us who 

25 194 3 model in Appendix W? If it is, that partially 

26 196 19 support of CALPUFF. We think it is a good model. 

27 196 20 It's beneficial to the modeling community and to 

28 196 21 the regulatory community to have this model. 

29 197 13 the model itself, as it gets updated and 

30 197 22 with CALPUFF, with the CALPUFF modeling system. 

31 199 5 leads to difficulty in modeling -- in the real 

32 199 6 world when we are out there trying to model for 

33 199 18 modeling conference, this committee made similar 

34 199 23 considered a regulatory model, is that EPA to 

35 200 18 data sets, given that right now we have to model 

36 202 18 the modeling community on people who were looking 

37 202 20 screening model, and they might also look at 

38 203 4 the modeling community on these topics so there 

39 203 10 we would strongly like to see the model clearing 

40 204 11 up in the model clearing house, on what is the 

41 204 17 should be put in the modeling clearing house. 

42 205 12 its use for visibility modeling. 

43 205 19 soliciting input from the modeling community. 

44 206 3 EPA should ensure support and timely model 

45 206 6 nontraditional modeling approval. 

46 206 11 maintain the model clearing house. 

47 206 16 modeling with CALPUFF is, but we would -- all 

48 206 23 requirement for having a regulatory model. 

49 208 8 invite OAQPS, and the modeling section, to use the 

50 208 10 public discussions of model issues. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 300 

 2 

 3 Page Ref No. Keyword = "model" 

 4 ____ _______ _________________ 

 5 

 6 209 18 Dispersion Modeling System. 

 7 209 20 aren't familiar with EDMS, it is the required model 

 8 209 25 your modeling. 

 9 210 13 it was the Complex Source Microcomputer Model, and 

10 210 19 At the modeling conference in 2000, we talked 

11 214 5 We expanded our parking facility modeling to 

12 214 7 model parking lots, and people were having to do 

13 214 9 each other to create a model parking garage. 

14 214 12 modeling. The stationary source modeling has been 

15 214 21 model that we're going to touch on. 

16 215 6 some people that were modeling very small numbers 

17 215 17 modeling will recognize that's about the same 

18 215 19 Noise Model. 

19 216 4 The GSE modeling enhancements, in addition to 

20 216 21 stacked AERMOD area sources to model the parking 

21 218 21 modeling realize that the ICAO engine emissions data 

22 221 19 Their purpose is to recommend model 

23 221 21 apply the model, review changes that we are making 

24 221 22 to the model, and we hold meetings, as required, 

25 222 12 emissions model, and then on the noise side, INM [ed. Integrated 

Noise Model] 

26 222 22 emissions and improving their own EDMS modeling 

27 222 25 improved fidelity in our airport modeling 

28 224 22 Langworthy, and I am an attorney, not a modeler, so 

29 225 3 regulatory modeling and for informing the 

30 225 7 frequently find that air quality modeling 

31 225 14 needs to be folded into the general modeling 

32 225 19 concerning which modeling approaches they will be 

33 225 23 example of this is the inaccessibility of the model 

34 226 3 involving the interpretation of modeling guidance 

35 226 7 But, the model clearing house web site is only 

36 226 20 EPA's response when someone applying the model for 

37 226 22 general applicability with that model and brought 

38 227 5 the AERMOD model, and its associated data 

39 227 8 advised EPA of two problems with the AERMAP model. 

40 227 11 terrain model files where the elevations were 

41 227 12 expressed in meters, although the model worked 

42 227 19 the modeling results. And although the concerns 

43 228 5 The individual indicated to EPA that the model 

44 228 18 dispersion model itself. 

45 228 19 The preprocessors are also key to model 

46 229 10 that EPA might hold a modeling conference this 

47 229 20 changes to some of the model practices; it did not 

48 229 23 model practice highlighted in the Federal Register 

49 231 18 modeling techniques EPA will require and how those 

50 231 21 community for improving model performance. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 301 

 2 

 3 Page Ref No. Keyword = "model" 

 4 ____ _______ _________________ 

 5 

 6 233 20 throughout modeling domain that would be of 

 7 233 21 interest in residual risk modeling. 

 8 238 13 the concentrations throughout the modeling 

 9 238 16 model might be applied to residual risk 

10 238 18 model predictions throughout the entire 

11 240 18 throughout the modeling regime for some of the data 

12 241 10 model performance here suggests, at a minimum, the 

13 242 18 it some more, the model may be doing better, 

14 244 19 Ozone can't be modeled, because of complex 

15 244 21 PM two point five (2.35) can be modeled to 

16 245 5 When you try to model an individual source of 

17 245 15 with the Eulerian approach to model single 

18 245 25 particular regional Eulerian model is approved for 

19 246 12 various model options need review. 

20 247 11 ready model. I just wanted to follow that up with 

21 248 2 model, and there is an area on the web site that 

22 248 23 basically -- the model comes out with a movie and 

23 249 3 model and within like a minute or two give you this 

24 249 13 model, but the latest NOAA products, NOAA forecast 

25 249 15 run a dispersion model any time you want for any 

26 

27 Page Ref No. Keyword = "Model Clearing House" 

28 ____ _______ ________________________________ 

29 

30 10 17 First, Warren Peters, our Model Clearing House 

31 14 21 replace the model clearing house facility degrees 

32 204 11 up in the model clearing house, on what is the 

33 206 11 maintain the model clearing house. 

34 226 7 But, the model clearing house web site is only 

35 

36 Page Ref No. Keyword = "model evaluation" 

37 ____ _______ ____________________________ 

38 

39 45 7 some of the model evaluation data sets. 

40 46 5 have gone back and looked at the model evaluation 

41 48 8 model evaluation methods. 

42 48 12 provide an overview of the current model evaluation 

43 81 19 and I know he's gone through the model evaluation 

44 83 20 model evaluation methodologies, I think it's 

45 87 10 so forth, and did some model evaluation. There was 

46 92 12 which we need the model, the model evaluation: 

47 93 7 conduct a model evaluation. 

48 107 7 area, and the model evaluation is saying, I've got 

49 108 6 the model evaluation reports, going through them 

50 108 22 those model evaluation reports. Again, probably 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 302 

 2 

 3 Page Ref No. Keyword = "model evaluation" 

 4 ____ _______ ____________________________ 

 5 

 6 118 12 EPA has defined model evaluation techniques 

 7 187 5 The model evaluation which most of you have 

 8 

 9 Page Ref No. Keyword = "modeler" 

10 ____ _______ ___________________ 

11 

12 142 15 Lowman then, our regional modeler who will just -- 

13 224 22 Langworthy, and I am an attorney, not a modeler, so 

14 

15 Page Ref No. Keyword = "modelers" 

16 ____ _______ ____________________ 

17 

18 11 24 modelers that are here, a number of whom 

19 12 14 the regional modelers, and, again, I appreciate 

20 108 3 bottom line here for modelers that are using, you 

21 

22 Page Ref No. Keyword = "modeling" 

23 ____ _______ ____________________ 

24 

25 7 17 science; modeling science and the like, that really 

26 11 7 the Air modeling -- Quality Modeling Group; 

27 11 10 dispersion modeling. 

28 11 13 our dispersion modeling team with Warren as -- as 

29 14 22 of freedom in a CALPUFF modeling analysis and its 

30 16 9 freedom in a -- in a modeling system like CALPUFF, 

31 18 23 scenarios cover a range of source types, modeling 

32 19 14 the base and beta versions of the modeling system. 

33 20 21 range of sources, again a long range of modeling 

34 20 23 wide gamut of modeling scenarios from --. 

35 35 20 but this is the large modeling domain, and it's 

36 37 9 the CALPUFF modeling system, we had wanted to 

37 37 12 base versions of the modeling system have an issue 

38 38 5 sure anybody who has run the CALPUFF modeling 

39 82 11 dispersion modeling system, since 1988, so I have a 

40 108 8 modeling forms you've seen and notice that they're 

41 111 21 photochemical modeling studies, and there are 

42 113 18 modeling validation study. 

43 126 21 to have a modeling protocol, and selected case as 

44 140 23 futures in modeling, and I must say that my first 

45 150 21 important way that we are to do modeling. 

46 162 17 modeling -- EPA modeling the way it's commonly 

47 164 15 code isn't acceptable in -- in this modeling 

48 166 22 Irwin's approach. I'm comparing this modeling 

49 168 4 modeling type of situation, but that concept, I 

50 168 17 Similarly -- I mean, modeling is similar to 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 303 

 2 

 3 Page Ref No. Keyword = "modeling" 

 4 ____ _______ ____________________ 

 5 

 6 168 20 recognize the uncertainty on the modeling side -- 

 7 170 14 regular modeling or this special modeling, though I 

 8 174 8 nonstandard modeling approach is to be given by Ron 

 9 174 22 modeling and wind-tunnel modeling. 

10 174 24 (2) models, CFD/wind-tunnel modeling; these models 

11 181 2 would come out of air modeling. 

12 181 13 Wind-tunnel modeling, just background on that. 

13 182 17 is already a guideline for wind-tunnel modeling. 

14 182 20 wind-tunnel modeling right now for specifying wind 

15 185 23 modeling may be used to complement existing approved 

16 186 10 We right now do need a CFD modeling guideline. 

17 196 20 It's beneficial to the modeling community and to 

18 197 22 with CALPUFF, with the CALPUFF modeling system. 

19 199 5 leads to difficulty in modeling -- in the real 

20 199 18 modeling conference, this committee made similar 

21 202 18 the modeling community on people who were looking 

22 203 4 the modeling community on these topics so there 

23 204 17 should be put in the modeling clearing house. 

24 205 12 its use for visibility modeling. 

25 205 19 soliciting input from the modeling community. 

26 206 6 nontraditional modeling approval. 

27 206 16 modeling with CALPUFF is, but we would -- all 

28 208 8 invite OAQPS, and the modeling section, to use the 

29 209 18 Dispersion Modeling System. 

30 209 25 your modeling. 

31 210 19 At the modeling conference in 2000, we talked 

32 214 5 We expanded our parking facility modeling to 

33 214 12 modeling. The stationary source modeling has been 

34 215 6 some people that were modeling very small numbers 

35 215 17 modeling will recognize that's about the same 

36 216 4 The GSE modeling enhancements, in addition to 

37 218 21 modeling realize that the ICAO engine emissions data 

38 222 22 emissions and improving their own EDMS modeling 

39 222 25 improved fidelity in our airport modeling 

40 225 3 regulatory modeling and for informing the 

41 225 7 frequently find that air quality modeling 

42 225 14 needs to be folded into the general modeling 

43 225 17 interested in which models and modeling techniques 

44 225 19 concerning which modeling approaches they will be 

45 226 3 involving the interpretation of modeling guidance 

46 227 19 the modeling results. And although the concerns 

47 229 10 that EPA might hold a modeling conference this 

48 231 18 modeling techniques EPA will require and how those 

49 233 20 throughout modeling domain that would be of 

50 233 21 interest in residual risk modeling. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 304 

 2 

 3 Page Ref No. Keyword = "modeling" 

 4 ____ _______ ____________________ 

 5 

 6 238 13 the concentrations throughout the modeling 

 7 240 18 throughout the modeling regime for some of the data 

 8 

 9 Page Ref No. Keyword = "Monin-Obukov" 

10 ____ _______ ________________________ 

11 

12 193 5 Monin-Obukov and I mean I've already -- the 

13 

14 Page Ref No. Keyword = "monitor" 

15 ____ _______ ___________________ 

16 

17 74 3 wind blows past a monitor. And those large 

18 110 10 that into consideration and bring the monitoring 

19 166 6 into a process, but monitoring that is carried out 

20 167 2 ambient monitoring in that it establishes the -- 

21 167 7 have actual monitor there, there is a lot of 

22 168 18 monitoring; one is measuring, one is predicting it 

23 168 19 -- and on the monitoring side, the people already 

24 

25 Page Ref No. Keyword = "monitors" 

26 ____ _______ ____________________ 

27 

28 179 20 friendly interfaces. Air quality monitors should 

29 242 9 limits on your monitors, and therefore, we're not 

30 

31 Page Ref No. Keyword = "near-field" 

32 ____ _______ ______________________ 

33 

34 27 17 This is a sort of near-field complex flow 

35 174 19 considered for complex near-field situations, and 

36 201 18 about redefining what near-field constitutes. 

37 245 9 So it is not suitable for near-field impacts 

38 245 21 point five (2.5) rather than near-field point 

39 

40 Page Ref No. Keyword = "No Obs" 

41 ____ _______ __________________ 

42 

43 22 12 driven by MM5 in the No Obs mode. So, --. 

44 26 7 to drive scenario two, which was MM5 in the No Obs 

45 35 18 was, again, just MM5 data driving it in the No Obs 

46 42 14 The No Obs runs that you did, was that sort of the 

47 42 15 -- was that the pure No Obs, or did you select one 

48 42 18 ROGER BRODE: That was No Obs, MM5 only. Scenario three is 

49 200 9 No Obs, various MM5 data sets that are available; 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 305 

 2 

 3 Page Ref No. Keyword = "NOAA" 

 4 ____ _______ ________________ 

 5 

 6 10 25 here, both in our NOAA branch; Mark Evangelista, is 

 7 11 3 Atkinson are in our NOAA branch, doing a wonderful 

 8 247 10 Yesterday, I brought up the issue of this NOAA 

 9 247 17 dot arl dot noaa dot gov slash ready slash hysplit 

10 248 11 but the nice thing about it is it's a NOAA product, 

11 249 6 is my question. Maybe one NOAA outfit should talk 

12 249 7 to another NOAA outfit and try to link these models 

13 249 13 model, but the latest NOAA products, NOAA forecast 

14 249 21 know, the NOAA people at EPA talk to the NOAA 

15 

16 Page Ref No. Keyword = "NWS" 

17 ____ _______ _______________ 

18 

19 21 5 NWS driven scenarios as well as incorporating 

20 22 9 just NWS data only, surface and upper air data. 

21 22 16 coastal area of Oregon, and this one we used NWS 

22 25 15 And then the locations of the NWS surface and 

23 38 25 And then there are a few unsupported NWS met 

24 41 17 two -- one and five, one being the large-scale NWS; 

25 42 19 where we mer- -- sort of merged NWS with MM5 data 

26 42 21 So we did have one with all NWS, one with all 

27 42 23 MARK GARRISON: NWS surface and MM5 data? 

28 42 24 ROGER BRODE: NWS surface and upper air and MM5 data. I 

29 

30 Page Ref No. Keyword = "OAQPS" 

31 ____ _______ _________________ 

32 

33 88 12 worked with OAQPS for many, many of those years has 

34 114 24 relates to my group, and I know OAQPS in general, 

35 139 6 people at OAQPS, and David followed up, and it 

36 208 8 invite OAQPS, and the modeling section, to use the 

37 

38 Page Ref No. Keyword = "observations" 

39 ____ _______ ________________________ 

40 

41 57 10 more one for one the exact actual observations and 

42 66 21 models. It's there in the observations, and when 

43 72 25 observations. And that stochastic noise I 

44 94 20 emissions and all of the actual observations from 

45 242 7 that the observations are a little uncertain there. 

46 242 10 sure if we trust the observations of that part of 

47 242 19 because we are not sure about the observations 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 306 

 2 

 3 Page Ref No. Keyword = "observed" 

 4 ____ _______ ____________________ 

 5 

 6 52 22 by which we can look at and compare the observed 

 7 52 25 predicted concentration, the OB is observed, and by 

 8 53 8 higher than the observed values, the fractional 

 9 53 12 prediction model is higher than the observed 

10 53 20 twenty-five values of the observed data, and it's 

11 53 21 looked at basically taking all of the observed data 

12 54 7 predicted ranges, it's a ranking of the observed 

13 56 7 versus the observed. 

14 60 5 are comparing observed versus predicted 

15 67 2 fluctuations in the observed concentrations, I 

16 72 24 we've observed is stochastic noise in the 

17 73 8 simulated and what's observed on an hour-by-hour 

18 73 19 segment of observed concentrations that involve 

19 77 6 each arc of observed concentrations rather than 

20 77 9 observed concentrations, and give confidence 

21 137 16 to the observed concentrations, which perhaps may 

22 234 11 observed in ISC. 

23 239 16 range of observed concentrations, and it suggests 

24 

25 Page Ref No. Keyword = "Obukov" 

26 ____ _______ __________________ 

27 

28 Keyword not found in text 

29 

30 Page Ref No. Keyword = "ozone" 

31 ____ _______ _________________ 

32 

33 243 17 pollutants are ozone and PM two point five (2.5). 

34 243 21 worrying about ozone and PM2.5. 

35 244 19 Ozone can't be modeled, because of complex 

36 245 20 certainly involved with ozone and regional PM two 

37 

38 Page Ref No. Keyword = "parameter" 

39 ____ _______ _____________________ 

40 

41 175 14 They can been used, however, to parameterize 

42 

43 Page Ref No. Keyword = "parameters" 

44 ____ _______ ______________________ 

45 

46 142 2 learned -- we've learned about parameters over 

47 143 10 you get the parameters right for the model. 

48 144 18 how to use it and how to set the parameters up 

49 171 23 you're getting some of the basic parameters correct 

50 179 5 the input parameters of boundary conditions. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 307 

 2 

 3 Page Ref No. Keyword = "parameters" 

 4 ____ _______ ______________________ 

 5 

 6 192 15 The land use parameters. 

 7 192 21 use parameters is critical. 

 8 193 3 certain types of land use, here are the parameters 

 9 214 15 look at all the parameters that are specified 

10 217 15 parameters that you can see and then can also 

11 

12 Page Ref No. Keyword = "particle" 

13 ____ _______ ____________________ 

14 

15 160 9 theoretical would be, a [tracer? LaGrangian? stochastic? ] 

particle model 

16 160 25 have a [LaGrangian?] particle model, it will -- we'll be 

17 177 13 particle motion/deposition and chemistry. 

18 

19 Page Ref No. Keyword = "plume" 

20 ____ _______ _________________ 

21 

22 30 15 see part of the plume does -- too. 

23 30 17 plume going around the hill. This is for the 

24 30 22 Sixty-five (65) meters, looks like the plume 

25 31 25 start -- as the plume grows, you start to to see 

26 32 6 neutral conditions, so, again, the plume is much 

27 32 13 bit of leftward shift to the plume impact, but not 

28 32 16 -- you see a definite impact of that shear's plume 

29 79 20 plume centerline is unless you get lucky, and they 

30 158 15 better plume model. 

31 158 16 We are almost at the edge of all that plume 

32 180 25 follow any type of plume or any type of solution 

33 182 9 plume model, and there's no time scaling really is 

34 184 5 building, plume impact on the building; that's 

35 

36 Page Ref No. Keyword = "PRIME" 

37 ____ _______ _________________ 

38 

39 24 24 PRIME downwash sources, a thirty-five (35) meter 

40 38 22 You know, there's no slug option for PRIME 

41 81 10 evaluating both the PRIME, ISC-PRIME and in the 

42 217 20 includes the PRIME and building downwash models, 

43 

44 Page Ref No. Keyword = "processors" 

45 ____ _______ ______________________ 

46 

47 19 22 processors to CALMET are not part of the analysis 

48 159 23 and we don't have a lot of processors in place 

49 224 12 eight off-run processors on the mother board for 

50 227 6 processors, AERMAP and AERMET. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 308 

 2 

 3 Page Ref No. Keyword = "profile" 

 4 ____ _______ ___________________ 

 5 

 6 23 21 CTDM-type surface and profile data to simulate 

 7 29 17 the CTDM surface and profile option, and we tried 

 8 100 15 profile in this group of data, and how well does it 

 9 100 16 estimate the scatter about the average profile? 

10 220 7 flight profile generation. Before it was just a 

11 231 3 central and high profile than this, and I must say 

12 

13 Page Ref No. Keyword = "promulgated" 

14 ____ _______ _______________________ 

15 

16 19 4 April, 2003 version that was officially promulgated 

17 63 10 WARREN PETERS: Well, when it's promulgated. I guess there 

18 141 14 in anticipation of it being promulgated, we in 

19 190 14 model is released -- is promulgated, but we want to 

20 196 6 promulgated. 

21 197 11 promulgated. 

22 

23 Page Ref No. Keyword = "promulgation" 

24 ____ _______ ________________________ 

25 

26 63 4 promulgation will require a change to Appendix W 

27 144 7 promulgation which, I think, is not thinking out of 

28 187 14 basis to delay promulgation. They are not of that 

29 189 6 schedule for promulgation of AERMOD. (Chuckles 

30 

31 Page Ref No. Keyword = "protocol" 

32 ____ _______ ____________________ 

33 

34 14 11 And then the protocol, or the procedures, are 

35 51 15 protocol provides a statistical technique for 

36 51 22 details of the protocol. 

37 52 14 1990. There is a screen test in this protocol, and 

38 55 7 recommended in the protocol that it be approximate 

39 56 24 The protocol recommends conducting this 

40 57 13 model protocol we're going to combine both 

41 57 22 suggested equation in the model protocol, and in 

42 59 6 the protocol is the ratio of the composite 

43 59 10 the protocol, and it will go through and generate 

44 61 14 that you have to go through with a protocol -- an 

45 61 15 up-front protocol that the regulatory authority and 

46 62 13 the later portions of the protocol is actually 

47 106 20 scientific component of the protocol, there 

48 126 21 to have a modeling protocol, and selected case as 

49 138 14 was described that EPA's protocol for evaluating 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 309 

 2 

 3 Page Ref No. Keyword = "protocols" 

 4 ____ _______ _____________________ 

 5 

 6 49 2 references in the protocols. 

 7 52 17 through the protocols. And fractional bias is 

 8 60 12 protocols and the methods that we have right now in 

 9 81 14 in dealing with these protocols and procedures on 

10 83 24 of various protocols about statistical evaluations. 

11 

12 Page Ref No. Keyword = "PSD" 

13 ____ _______ _______________ 

14 

15 142 8 that people use it for the different PSD projects 

16 204 20 issues when you're using CALPUFF in a PSD 

17 

18 Page Ref No. Keyword = "puff" 

19 ____ _______ ________________ 

20 

21 158 21 a puff model, which is also intermediate before we 

22 161 4 How can we improve a puff model, and forget 

23 244 12 concentration following a puff or a parcel as it's 

24 

25 Page Ref No. Keyword = "ratio" 

26 ____ _______ _________________ 

27 

28 59 6 the protocol is the ratio of the composite 

29 193 6 Bowen ratio, and the albedo. 

30 236 11 ratio which is the ISC to the AERMOD 

31 236 15 dilution is about a ratio of one point one (1.1), 

32 237 5 highlight again the ratio that we are seeing 

33 237 16 the rural to urban, but the ratio there for volume 

34 237 21 for volume sources have -- show again it's a ratio 

35 

36 Page Ref No. Keyword = "ratios" 

37 ____ _______ __________________ 

38 

39 59 14 done. And the bottom line here is that the ratios, 

40 

41 Page Ref No. Keyword = "receptor" 

42 ____ _______ ____________________ 

43 

44 234 7 consistent receptor array was used. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 310 

 2 

 3 Page Ref No. Keyword = "regime" 

 4 ____ _______ __________________ 

 5 

 6 164 16 regime. I really, really don't. 

 7 172 20 even in the existing regime, the -- the ability to 

 8 238 24 that up through the higher end of the regime, but 

 9 240 18 throughout the modeling regime for some of the data 

10 

11 Page Ref No. Keyword = "regimes" 

12 ____ _______ ___________________ 

13 

14 108 9 not tested in all regimes, and get a feel for it, 

15 108 10 what regimes were they tested in where they 

16 235 10 regimes and an average and similarly for the urban 

17 

18 Page Ref No. Keyword = "regulatory" 

19 ____ _______ ______________________ 

20 

21 13 18 a regulatory dispersion model, either CALPUFF or 

22 13 24 estimates that are used in regulatory decision 

23 14 9 model in estimates that are used in regulatory 

24 16 25 comfortable releasing the model to the regulatory 

25 18 18 really technically part of the regulatory 

26 34 24 they are of the most interest for a regulatory 

27 36 20 very small values, so in terms of the regulatory 

28 48 19 regulatory use. 

29 49 13 regulatory fold, so to speak. 

30 54 18 regulatory component and a science component. 

31 54 19 On the regulatory component, again cites is 

32 54 25 for a regulatory application. 

33 55 16 This analysis is conducted for the regulatory 

34 56 23 for the regulatory needs. 

35 58 5 component -- I'm sorry, for the regulatory 

36 58 11 the absolute fractional bias on the regulatory 

37 58 14 on the regulatory component of one-third (1/3), or 

38 59 25 a weighting of the science and the regulatory 

39 61 15 up-front protocol that the regulatory authority and 

40 71 3 EPA is going to promulgate in a regulatory 

41 79 2 while the regulatory standards in the U.S. are -- 

42 88 5 running regulatory models for permit applications. 

43 91 20 produce good regulatory concentrations, but it also 

44 92 6 conditions, which aren't necessarily of regulatory 

45 92 20 regulatory component in the testing. 

46 95 23 the application of some of the models, regulatory 

47 96 11 regulatory consequences and costs to society that 

48 107 3 again, the regulatory requirements sometimes for 

49 107 14 But consider the regulatory application or, as 

50 109 10 factors that are both scientific and regulatory, 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 311 

 2 

 3 Page Ref No. Keyword = "regulatory" 

 4 ____ _______ ______________________ 

 5 

 6 112 11 to participation with the regulatory authority in 

 7 116 17 regulatory process is inhibiting or not promoting 

 8 121 23 through regulatory review. This kind of process 

 9 122 7 this model is ready for regulatory use in these 

10 124 17 same regulatory application, reasonably could be 

11 128 14 to be acceptable for its regulatory review and use. 

12 136 16 regulatory agency put the burden on the company to 

13 136 18 In other cases, the regulatory agency had 

14 137 2 using, in a particular regulatory format, the best 

15 138 3 but it satisfied the regulatory issue, and from 

16 141 7 when you're talking about regulatory, we have to go 

17 143 17 regulatory approach. 

18 145 4 the state regulatory focus. 

19 149 12 regulatory world has another place in which models 

20 153 17 regulatory program like this. 

21 161 18 regulatory process to be open to public view. And, 

22 167 14 regulatory process, everybody treat -- or 

23 167 15 regulatory agency that that as a -- as if that's 

24 169 16 uncertainty of models and how the regulatory 

25 177 19 we commonly use for regulatory models. 

26 178 24 same with all the regulatory models. We were 

27 179 4 perfect regulatory model, there's uncertainty in 

28 180 14 regulatory models to show that level of 

29 180 20 which regulatory models don't really account for. 

30 181 10 threatening present regulatory model. 

31 183 2 already used in the regulatory environment. 

32 185 14 But guidance for regulatory application, of 

33 196 21 the regulatory community to have this model. 

34 198 14 official regulatory version that you can go and 

35 199 23 considered a regulatory model, is that EPA to 

36 205 14 phase chemistry. We'd like to see clear regulatory 

37 205 25 clearly and definitely take over regulatory 

38 206 23 requirement for having a regulatory model. 

39 208 3 third conference on regulatory applications of air 

40 224 20 the Utility Air Regulatory Group [ed.(UARG)]. 

41 225 3 regulatory modeling and for informing the 

42 226 4 for a specific regulatory applications. And I have 

43 226 21 a regulatory purpose has identified a problem with 

44 228 21 they are approved for general regulatory use. 

45 231 9 regulatory community. 

46 231 20 responsiveness to suggestions from the regulatory 

47 232 20 regulatory applications, including some that are 

48 233 2 can be used for regulatory purposes. 

49 233 8 regulatory design concentrations, AERMOD versus 

50 234 2 with the regulatory concentrations. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 312 

 2 

 3 Page Ref No. Keyword = "RUC" 

 4 ____ _______ _______________ 

 5 

 6 200 10 that's RUC, ETA, we've heard about RAMS also 

 7 

 8 Page Ref No. Keyword = "rule" 

 9 ____ _______ ________________ 

10 

11 170 20 Is there a need kind of rule in AERMOD or ISC 

12 

13 Page Ref No. Keyword = "run" 

14 ____ _______ _______________ 

15 

16 15 12 the tool and the necessary files for running the 

17 18 5 We've got to run the analysis through on it and -- 

18 20 3 CALPUFF, and the base version of CALMET run, and so 

19 20 4 that's one model run. The Beta version of CALPUFF 

20 20 5 and the Beta version of CALMET are run. That's the 

21 20 11 And since we've already actually run both of 

22 23 5 included an idealized scale, first run was 

23 23 6 similarity dispersion and second run was PG-based 

24 23 15 sort of generated the met data to run through 

25 33 13 We did run a secondary analysis to these, and 

26 38 5 sure anybody who has run the CALPUFF modeling 

27 38 11 set up as a separate run. 

28 38 23 sources; probably wouldn't want to run it, because 

29 38 24 it would take that much longer to run but --. 

30 39 9 a SAMSON format so we could run it through CALMET. 

31 41 5 computer, doing a primary analysis, running both 

32 41 7 We tried to keep the run time somewhat manageable 

33 41 16 Most of that run time is in scenarios one and 

34 41 22 probably, what, ten (10) hours to run and scenario 

35 41 23 two may be six to ten (10) minutes to run, 

36 42 2 anyone with the -- with the experience in running 

37 42 3 CALPUFF and CALMET -- or CALPUFF could actually run 

38 42 6 to run. Basically all you have to do is run one 

39 42 7 batch file, and it'll go through and run all those 

40 42 8 scenarios, base the beta; run the analysis tools, 

41 43 15 said, you can run all ten scenarios over a weekend, 

42 43 17 wouldn't run it, you know, every month; perhaps 

43 44 4 have to run through this again? 

44 44 19 when you run through this to go back and look at 

45 46 4 run through the entire consequence analysis, and we 

46 50 20 you can run it on your PC and make sure that it's 

47 64 21 WARREN PETERS: And, John, if you want, I'll just run the 

48 88 5 running regulatory models for permit applications. 

49 94 10 David. He's run his model for us so that we 

50 97 17 predict those ensembles. Because if you run the 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 313 

 2 

 3 Page Ref No. Keyword = "run" 

 4 ____ _______ _______________ 

 5 

 6 98 17 and say, I run the model, I have some confidence 

 7 100 22 at second high concentrations, you would run the 

 8 105 3 run it maybe a hundred (100) times, wouldn't you, 

 9 123 20 going to run into situations that are nasty, and 

10 155 5 different experience running the thing. 

11 159 8 public, to run parallel mode, for CALMET and for 

12 159 12 lot of us need to run CALMET in a single computer 

13 159 14 cannot even run, because it can't go parallel. 

14 159 21 into something that would run on the second for 

15 159 22 older models, for minutes; it must run under hour, 

16 177 24 complex could be practically run on most 

17 179 21 be able to run the routine applications. 

18 180 12 run under comparable conditions to non-building 

19 190 7 until you are on the side of running models, and 

20 197 7 of the general theme you will see running through 

21 209 22 runway or make some kind of airport change, that's 

22 212 5 things that would be required for running MOBILE. 

23 212 15 queues, and the dimensions of the runways. 

24 218 13 step, and then run AERMET only to find out that it 

25 218 17 to run that on their own. 

26 219 15 And as you know, you have to run a range of years 

27 219 22 AERC application, you had to run EDMS over and over 

28 223 7 of the audience, if you are running AERMOD in large 

29 223 21 He has mentioned that he has AERMOD running in 

30 223 23 frustrating level to get AERMOD to run in parallel 

31 224 11 relatively cheap PC and can run two, four, six, 

32 228 6 would run, however, when the maximum hourly 

33 244 15 They could be run for hundreds of sources, but 

34 246 9 and only a few groups will be running them in 

35 246 18 models? The same model run; just another day. 

36 247 5 you could run CALPUFF, or you certainly can't run 

37 247 21 user agreement to run this, but I was able to get 

38 247 24 the next thing is, you can run a multiple of 

39 248 4 You can run it anytime you want with either 

40 248 7 a volcanic eruption, I guess you can run it, too. 

41 249 2 background map and ranges of distances and run the 

42 249 15 run a dispersion model any time you want for any 

43 

44 Page Ref No. Keyword = "rural" 

45 ____ _______ _________________ 

46 

47 78 19 fact, in various classes such as rural, urban and 

48 233 23 First, for the rural/urban performance issue, 

49 234 18 column under ISC for rural, and this is the rural 

50 235 5 rural to an urban area for the same source for the 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 314 

 2 

 3 Page Ref No. Keyword = "rural" 

 4 ____ _______ _________________ 

 5 

 6 235 15 less dispersion going on from the rural setting to 

 7 235 20 within a rural area, there is a fair bit of 

 8 236 9 significant increase in dispersion, from rural to 

 9 237 6 between concentrations for rural and for urban. 

10 237 16 the rural to urban, but the ratio there for volume 

11 237 23 And then for rural settings, and this was 

12 

13 Page Ref No. Keyword = "scale" 

14 ____ _______ _________________ 

15 

16 20 24 So, the complex flow, local scale impacts 

17 22 3 We start with the large scale in the scenario 

18 22 14 Scenario three is sort of medium scale, sort 

19 22 19 Then we have another medium scale domain near 

20 23 2 small scale complex flow situation in the Deep 

21 23 5 included an idealized scale, first run was 

22 25 8 is, again, is a large scale domain in the Pacific 

23 223 15 a large scale, and I feel more for the EDMS needs. 

24 244 3 scale of the emission changes are going to be 

25 

26 Page Ref No. Keyword = "scaling" 

27 ____ _______ ___________________ 

28 

29 82 16 the models based on the back scaling. So 

30 83 14 Rentree model developed using scaling. 

31 182 9 plume model, and there's no time scaling really is 

32 227 10 necessary scaling factor to the digital elevation 

33 

34 Page Ref No. Keyword = "SCRAM" 

35 ____ _______ _________________ 

36 

37 15 11 We intend to post the results on SCRAM, and provide 

38 75 22 SCRAM. 

39 76 7 the ASTM standard has been put on the SCRAM web 

40 94 24 available on our SCRAM web site for people to see. 

41 225 24 clearing house which is, as the SCRAM web site 

42 230 4 SCRAM web site, that may have have changed now, 

43 

44 Page Ref No. Keyword = "screening" 

45 ____ _______ _____________________ 

46 

47 54 20 what we've seen in the screening analysis, the 

48 194 2 Is it going to be designated as a screening 

49 202 16 evaluating the screening procedure for CALPUFF, 

50 202 20 screening model, and they might also look at 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 315 

 2 

 3 Page Ref No. Keyword = "sensitivity" 

 4 ____ _______ _______________________ 

 5 

 6 120 22 sensitivity reports, and maybe even define the 

 7 246 11 sensitivity to uncertainties of input in and -- and 

 8 

 9 Page Ref No. Keyword = "service" 

10 ____ _______ ___________________ 

11 

12 21 17 real met data, either the National Weather Service 

13 39 4 Weather Service data for the same time period, and 

14 70 19 they provide a public service. 

15 104 16 the National Park Service. Okay? 

16 136 10 and engineering company, provided service 

17 208 5 specifically to get the input of the Park Service 

18 208 6 and Forest Service and the Wildlife Service. 

19 

20 Page Ref No. Keyword = "site" 

21 ____ _______ ________________ 

22 

23 47 23 on the web site; the current version. 

24 70 12 sets, they can post them on their web site, and 

25 70 13 that would attract people to their web site, but 

26 70 17 freely available off their web site, and they 

27 76 8 site yet, so the 6589 item. 

28 79 9 conditions expected at a site might be totally 

29 80 21 probably available on a web site some discussion of 

30 85 16 the web site of -- of this , which has 

31 94 22 So an FT -- anonymous FTP site that EPA/ORD 

32 94 24 available on our SCRAM web site for people to see. 

33 122 4 goes up on their web site and lists this model and 

34 175 9 They are highly site-specific. However, they 

35 180 6 site. 

36 184 16 the models really sort of -- site specific numbers 

37 225 24 clearing house which is, as the SCRAM web site 

38 226 7 But, the model clearing house web site is only 

39 226 10 access the web site. The web site indicates work 

40 230 4 SCRAM web site, that may have have changed now, 

41 248 2 model, and there is an area on the web site that 

42 

43 Page Ref No. Keyword = "slope" 

44 ____ _______ _________________ 

45 

46 239 20 evaluation report for the Alaska North Slope. And 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 316 

 2 

 3 Page Ref No. Keyword = "source" 

 4 ____ _______ __________________ 

 5 

 6 18 23 scenarios cover a range of source types, modeling 

 7 21 24 focus in on impacts for a certain source type, for 

 8 24 3 source, the elongated source, a ten-meter volume 

 9 24 4 source, a thirty (30) meter non-buoyant point 

10 24 5 source, and then a sixty-five (65) meter buoyant 

11 24 6 point source. 

12 24 21 tried to cover range of source types and introduce 

13 27 11 National Park, and then the buoyant area source was 

14 30 10 And the source is located at the western edge 

15 30 14 This is a ten-meter (10m) volume source. You 

16 30 20 source for stable. The terrain influence becomes a 

17 31 6 volume source, except with some downwash. 

18 31 7 And that's the same source without the cap 

19 31 11 This is the fifty-meter (50m) downwash source, 

20 31 23 So this is the ten-meter (10m) volume source, 

21 32 5 This is the ten-year volume source under 

22 32 12 source in stable conditions, and there is a little 

23 32 20 source, so you can see the hill pretty clearly, as 

24 33 19 that occurred before the volume source in scenario 

25 34 7 no, for each source, you basically get a yes or no, 

26 34 12 the domain for that source. 

27 35 3 difference for volume source occurred for the 

28 35 23 source near Salem which is located right there. 

29 36 3 volume source. 

30 36 15 waters, so we think that is probably the source of 

31 36 18 you, oops, go -- anyway your source is way down 

32 38 6 system has dealt with is, there is no source 

33 38 8 wanted to be able to present results on a source by 

34 38 9 source basis, so it would be easier to diagnose and 

35 38 10 understand what's happening, and so each source was 

36 91 10 probably covered the majority of source types to 

37 92 2 important for other source types, the smaller 

38 92 11 source scenarios that are possible in the world in 

39 96 4 source testing is one very key area that's going to 

40 138 16 at five different data sets, some area source, the 

41 138 17 volume source, which are kind of unique, and other 

42 159 25 We are in a open source time where we could 

43 175 6 source characteristics like, let's say, merge 

44 175 8 unusual source configurations. 

45 180 9 is -- is a line source with two levels of surface 

46 180 10 heating compared to an urban line source. 

47 181 23 a steady state condition, so it's a good source for 

48 184 10 source upwind in a building cavity, another 

49 210 13 it was the Complex Source Microcomputer Model, and 

50 212 6 And then finally the stationary source 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 317 

 2 

 3 Page Ref No. Keyword = "source" 

 4 ____ _______ __________________ 

 5 

 6 214 12 modeling. The stationary source modeling has been 

 7 217 12 specify which AERMOD source type to use to best 

 8 217 13 represent their source. So we provide the base 

 9 234 5 source configurations were included, including the 

10 234 6 area and volume source, and a standard and 

11 234 19 area source, flat terrain for Oklahoma City, and 

12 235 5 rural to an urban area for the same source for the 

13 235 6 same area source. 

14 240 21 volume source performance. 

15 244 16 for a typical PSE, project single source, they are 

16 245 5 When you try to model an individual source of 

17 245 7 instantaneous pseudo-dilution of the point source 

18 247 3 What is a source to do if it has to do a 

19 

20 Page Ref No. Keyword = "speed" 

21 ____ _______ _________________ 

22 

23 29 19 both wind speed and wind direction. 

24 57 2 wind speed groups and three stability categories, 

25 58 3 conditions for wind speed and stability, and then 

26 165 13 speed on how it's used, but if they are essentially 

27 

28 Page Ref No. Keyword = "stack" 

29 ____ _______ _________________ 

30 

31 24 17 sources, plus, we put in a taller point stack near 

32 24 25 buoyant stack, a thirty-five (35) meter cap stack, 

33 25 2 and then a fifty (50) meter buoyant stack. I think 

34 31 4 sources, for the kind of cap stack with MM fact set 

35 138 18 tall stack, Kincaid and some others, that are 

36 183 3 Good engineering practice stack heights, of 

37 216 21 stacked AERMOD area sources to model the parking 

38 

39 Page Ref No. Keyword = "stacks" 

40 ____ _______ __________________ 

41 

42 91 24 stacks with the types of sources that we have in 

43 92 3 stacks in different conditions. 

44 175 7 stacks, cap stacks, horizontal stacks, some very 

45 184 4 areas where you have short stacks next to a tall 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 318 

 2 

 3 Page Ref No. Keyword = "statistical" 

 4 ____ _______ _______________________ 

 5 

 6 51 15 protocol provides a statistical technique for 

 7 51 18 philosophy for developing a statistical 

 8 54 16 There is a more advanced statistical test in 

 9 80 14 be common statistical measures for overall model 

10 83 24 of various protocols about statistical evaluations. 

11 86 8 statistical evaluation or evaluation models is 

12 94 6 developing statistical evaluation methods for air 

13 135 23 I think a statistical evaluation is, of 

14 

15 Page Ref No. Keyword = "steady state" 

16 ____ _______ ________________________ 

17 

18 28 18 steady state, trying to simulate a steady state 

19 29 21 steady state meteorology, six hours of stable 

20 181 23 a steady state condition, so it's a good source for 

21 

22 Page Ref No. Keyword = "surface" 

23 ____ _______ ___________________ 

24 

25 22 9 just NWS data only, surface and upper air data. 

26 23 21 CTDM-type surface and profile data to simulate 

27 25 15 And then the locations of the NWS surface and 

28 25 17 this is showing surface roughness with the terrain 

29 29 17 the CTDM surface and profile option, and we tried 

30 31 15 the same hill located in the surface domain, but we 

31 31 18 shear from the winds near the surface are coming 

32 42 16 of the used surface data and MM5 data for the long 

33 42 23 MARK GARRISON: NWS surface and MM5 data? 

34 42 24 ROGER BRODE: NWS surface and upper air and MM5 data. I 

35 77 4 having intensive surface networks of receptors, and 

36 143 8 boundary layers and all, you know, the surface 

37 180 9 is -- is a line source with two levels of surface 

38 181 5 near the surface is very strongly influenced by 

39 182 3 underlying surface roughness, and dis- -- 

40 193 4 that you put in, surface roughness and, 

41 

42 Page Ref No. Keyword = "terrain" 

43 ____ _______ ___________________ 

44 

45 21 3 Range of terrain scenarios are included and 

46 25 17 this is showing surface roughness with the terrain 

47 25 18 contours based upon the CALMET terrain. 

48 26 8 mode, and it shows the land use type, terrain 

49 30 7 couldn't get the terrain contoured in here, but on 

50 30 9 where the terrain is located. 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 319 

 2 

 3 Page Ref No. Keyword = "terrain" 

 4 ____ _______ ___________________ 

 5 

 6 30 20 source for stable. The terrain influence becomes a 

 7 78 20 complex terrain model evaluations, and the model 

 8 86 23 applications and complex terrain. 

 9 137 9 where there was some complex terrain, and there was 

10 137 21 expect in a complex terrain situation. 

11 145 25 terrain and complex flow situations. 

12 147 15 Well, in the complex terrain world that we've 

13 183 6 terrain, is used there when the need arises. 

14 183 19 Terrain wakes right now really are not 

15 184 2 upwind terrain feature. 

16 227 11 terrain model files where the elevations were 

17 233 24 we examined the flat and simple terrain simulations 

18 234 19 area source, flat terrain for Oklahoma City, and 

19 

20 Page Ref No. Keyword = "toxic" 

21 ____ _______ _________________ 

22 

23 223 11 some of the toxic studies we've done in 

24 

25 Page Ref No. Keyword = "tracer" 

26 ____ _______ __________________ 

27 

28 77 3 this guide does apply to the tracer field studies 

29 78 7 to evaluate two types of databases; that is tracer 

30 79 10 missed by a short-term tracer study, and you can 

31 80 3 databases, that is, tracer databases that are short 

32 80 11 short-term tracer databases, and they should also 

33 94 21 three different tracer data sets. 

34 95 10 with the old tracer data sets is a challenge with 

35 95 12 inputs that aren't available in the old tracer data 

36 158 23 tracer models. 

37 

38 Page Ref No. Keyword = "turbulence" 

39 ____ _______ ______________________ 

40 

41 73 21 because we have known about turbulence since the 

42 73 24 turbulence has organized swirls in it. They are 

43 178 14 turbulence model. 

44 178 17 that the turbulence is closed at a much higher 

45 182 2 turbulence profiles are consistent with the 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 320 

 2 

 3 Page Ref No. Keyword = "urban" 

 4 ____ _______ _________________ 

 5 

 6 78 19 fact, in various classes such as rural, urban and 

 7 178 3 urban area, probably only the largest systems could 

 8 180 2 geometry. For most urban areas, there already is 

 9 180 10 heating compared to an urban line source. 

10 180 18 know in your urban street canyons, there is some 

11 180 22 reliable solutions in urban environments. 

12 181 3 And then in complex urban environments, with 

13 184 3 Or, here's a case where you have flow in urban 

14 184 15 or even in an urban street canyon environment where 

15 233 17 urban/rural performance of AERMOD is not consistent 

16 234 10 occurs for urban areas that were traditionally 

17 234 21 course, the urban -- these are the annual 

18 234 25 urban setting and the average there. 

19 235 5 rural to an urban area for the same source for the 

20 235 10 regimes and an average and similarly for the urban 

21 235 16 the urban setting. 

22 235 24 But when we go into an urban area, we see 

23 236 3 they were for ISC in urban areas, which -- which 

24 236 10 urban, between ISC and AERMOD, and just in this 

25 236 19 the dispersion, and for urban settings, we -- we 

26 237 6 between concentrations for rural and for urban. 

27 237 8 dispersion going on in the urban setting for ISC. 

28 237 16 the rural to urban, but the ratio there for volume 

29 238 3 seeing an opposite behavior, and for urban 

30 240 12 urban/rural performance of AERMOD is not consistent 

31 241 5 EPA should investigate both urban performance 

32 

33 Page Ref No. Keyword = "variability" 

34 ____ _______ _______________________ 

35 

36 179 8 variability; likewise, some carryover in the CFD 

37 

38 Page Ref No. Keyword = "weather" 

39 ____ _______ ___________________ 

40 

41 21 17 real met data, either the National Weather Service 

42 39 4 Weather Service data for the same time period, and 

43 

44 Page Ref No. Keyword = "wind" 

45 ____ _______ ________________ 

46 

47 23 16 CALMET to get the wind field, so these are, as we 

48 23 17 mentioned, wind fields. 

49 23 22 vertical wind shear, and, again, using the 

50 29 18 to introduce simulated shear, vertical wind shear, 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 321 

 2 

 3 Page Ref No. Keyword = "wind" 

 4 ____ _______ ________________ 

 5 

 6 29 19 both wind speed and wind direction. 

 7 30 11 with the wind flow from left to right, sort of 

 8 31 17 southwest edge of the domain, because the wind 

 9 32 2 some of the influence of the vertical wind shear 

10 32 8 effects of the wind shear. Previous slides, I 

11 42 25 think we used the MM5 data to initialize the wind 

12 57 2 wind speed groups and three stability categories, 

13 58 3 conditions for wind speed and stability, and then 

14 74 3 wind blows past a monitor. And those large 

15 90 13 experiments, wind tunnel experiments and so forth 

16 137 19 wind fields that were being used in the model 

17 139 11 it. I -- I know that in common usage is Windows, 

18 139 13 technology in Windows, but we all accept it, we 

19 157 6 That's different than Windows. That is 

20 157 7 different than Windows. You're -- we're making 

21 174 22 modeling and wind-tunnel modeling. 

22 181 13 Wind-tunnel modeling, just background on that. 

23 181 15 virtual wind tunnel, but its basic equations are 

24 181 16 solved in the wind tunnel by simulating the flow 

25 181 20 really, in the wind-tunnel simulation. 

26 181 22 simulate what's going on in the wind tunnel. It's 

27 181 25 Some other little background: the wind and 

28 182 4 dispersion in the wind tunnel matches boundary 

29 182 17 is already a guideline for wind-tunnel modeling. 

30 182 20 wind-tunnel modeling right now for specifying wind 

31 182 22 define structural wind loads for most of the 

32 182 25 some are existing, that -- where wind tunnels are 

33 183 10 wind tunnel determined dimensions for unusual 

34 183 23 Maybe the wind tunnel, there is a place where 

35 183 24 the wind tunnel number could be used directly, if 

36 184 7 Here's another case where maybe the wind 

37 184 13 So these are some cases where maybe the wind 

38 184 19 the implementation issues, the wind tunnel and CFD 

39 185 11 through some comparisons with databases, wind 

40 185 15 both CFD and wind tunnel models is needed. An 

41 185 18 CFD and wind tunnel users with final oversight by 

42 185 22 determine where areas where CFD and wind tunnel 

43 186 7 and guideline for wind tunnels, but it probably 

44 198 2 evaluating the wind fields that come out of 

45 201 22 case-by-case basis for complex wind fields. 

46 201 24 for complex wind fields, but again, as has already 

47 202 25 here for complex wind fields and for a number of 

48 207 8 wind fields, the complex wind field cases, and 

49 210 17 EDMS three point 0 (3.0), it entered the Windows 

50 244 13 affected by the wind. And they're more suitable 
 1 Eighth Modeling Conference Keyword Index Vol. 2, p. 322 

 2 

 3 Page Ref No. Keyword = "wind" 

 4 ____ _______ ________________ 

 5 

 6 249 19 was the wind blowing in case something happened. 

 7 

 8 Page Ref No. Keyword = "wind speed" 

 9 ____ _______ ______________________ 

10 

11 29 19 both wind speed and wind direction. 

12 57 2 wind speed groups and three stability categories, 

13 58 3 conditions for wind speed and stability, and then 

14 

15 Page Ref No. Keyword = "winds" 

16 ____ _______ _________________ 

17 

18 27 10 with prevailing winds blowing it toward the 

19 31 18 shear from the winds near the surface are coming 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50