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 27711Vol. 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 l24Vol. 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 model1 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 all1 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, is1 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 am1 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's1 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 replace1 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. They1 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 regulatory1 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 guess1 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 that1 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 transport1 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 useful1 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 one1 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 the1 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 represent1 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 grid1 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 hundred1 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 see1 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 narrow s 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 -- a1 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 several1 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 is1 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 met1 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 bugs1 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 and1 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 wind1 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 the1 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 if1 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 number1 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 way1 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 the1 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 performance1 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 documents1 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 by1 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 to1 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, because1 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 two1 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 the1 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 two1 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 regulatory1 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 about1 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 this1 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, Bob1 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 procedures1 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 the1 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 caused1 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 ASTM1 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 organization1 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 narrow1 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 be1 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 what1 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 I1 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 the1 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 that1 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 since1 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 that1 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 I1 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 with1 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 various1 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 slightly1 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 our1 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 very1 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 slipped1 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 pulled1 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 things1 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 it1 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 pressure1 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, I1 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 Dick1 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 panel1 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 fair1 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 really1 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 really1 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 really1 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 the1 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 to1 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 and1 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 as1 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 to1 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 has1 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 the1 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. We1 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 all1 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 clearing1 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 of1 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 and1 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 growth1 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 that1 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 with1 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 better1 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 panel1 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 were1 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 improve1 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 without1 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've1 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 the1 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 Arrington1 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 comfortable1 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. RT E M,

25 complex one Complex I. So I don't think it's a big issue. I1 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 which1 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 of1 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 this1 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 the1 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 the1 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 satisfy1 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 a1 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 could1 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 be1 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 -- by1 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 at1 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 to1 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 are1 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 with1 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 previous1 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 some1 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 this1 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 great1 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 the1 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 for1 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 building1 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 CFD1 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 building1 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 solution1 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 and1 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 are1 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 nearby1 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 these1 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 of1 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 provide1 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 the1 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 be1 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 manual1 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 of1 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 more1 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 these1 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 for1 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 official1 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 expecting1 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 couple1 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 of1 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 clear1 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 that1 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 regulatory1 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 that1 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 of1 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.

251 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 in1 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 five1 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 version1 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 have1 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 at1 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 buildings1 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 conservative1 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 for1 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 reduces1 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 of1 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 modeling1 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 actually1 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 about1 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 the1 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 in1 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 how1 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 not1 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 the1 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 will1 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 -- they1 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 dealt1 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 the1 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 dispersion1 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 becoming1 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.

251 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 that1 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 to1 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 fixed1 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 for1 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 two1 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 transport1 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 down1 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

25Vol. 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) 693-69541 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

251 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

251 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

251 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

251 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 CALPUFF1 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 data1 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 the1 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 the1 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 CALMET1 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 a1 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 flow1 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 -- or1 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 than1 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 on1 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 considered1 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 along1 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, whether1 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 twenty1 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 models1 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 wind1 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 user1 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 this1 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 are1 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 and1 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, can1 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 end1 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 really1 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 does1 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 to1 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 in1 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 data1 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 are1 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 average1 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 where1 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 model1 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, probably1 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 to1 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 observations1 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 evaluating1 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 the1 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 the1 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 at1 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. And1 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 source1 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 tall1 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 the1 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 suitable1 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

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