1 Not Final Agency Action 

### High Level Summary of Meeting with Industry June 1, 2012

Introduction
This summary describes ideas and thoughts ex pressed by industry st akeholders (IS) at the June 1 meeting with Environmental Prot ection Agency (EPA) staff regarding implementation of the 2010 primary 1-hour sulfur dioxide (SO 2 ) National Ambient Air Quality Standard (NAAQS). While the discu ssion covered many topics, monitoring and modeling received the most attention, with the following general messages:
There was strong support for a hybrid approach which allows states flexibility to use monitoring or modeling to determine whether areas are meeting or not meeting the standard. Furthermore, a threshold should be established to prioritize the sources of interest. A phased mon itoring approach is recommended to characterize air quality in areas initially designated as unclassifiable.
Only monitoring data should be used for nonattainment designations and characterizing air quality in unclassifiable areas. Models overpredict, while monitors show real data.
This summary below is organized into three broad topics consistent with the White Paper: monitoring, modeling, and implementation. In addition, key subtopics addressed are thresholds (monitoring/modeling), actual e missions (modeling), hybrid approach, guidance/rulemaking, and timing (implementation). A list of in-person participants is attached; a few additional IS representatives participated by the phone.

Limitations
Please note is a high level summary, reflecting concepts EPA heard during the meeting. It is not intended to be a full transcript or include all topics discussed. As EPA moves forward with implementation of the 2010 SO 2 NAAQS, the Agency will be informed both by concepts contained in this summary as well as concepts not described in this summary. Like all of the SO 2 implementation-related material s produced by EPA to date (e.g., the March 2011 and September 2011 guidance memoranda; the April 12, 2012 letters to state agencies and tribal r epresentatives; and the May 2012 White Paper) this summary does not constitute final or binding agency action. These materials are part of an overall work in progress toward developi ng practicable approaches to implementing the SO 2 NAAQS that assure expeditious protecti on of public health. Ultimately, this stakeholder outreach process may lead to revised guidance or additional rulemaking.2 Not Final Agency Action Monitoring
Many IS stated support for monitoring over mod eling in general because they believe that models over predict while monitors show real data.
Many IS stated that the next step is for EPA to issue guidance describing monitoring criteria for SO 2 . They recommend the guidance be flexible (so states can use common sense), clarify the number of monito rs required, and consider population and meteorology. A few IS indicated there is also a need for monitors dedicated to tracking trends and to identify background concentrations.
Costs of monitoring are a key concern of the IS . One IS stated the monitoring costs were $50,000 per site but that operation and maintenance is not that expensive. Some IS stated that, compared to costs of controls, monitoring costs are dollars well spent. A few IS noted that with network optimization and proper screening it may not be as hard as initially thought to deploy a sufficient network.
Who pays for monitors is also a key issue discussed. While some IS said they would be willing to discuss paying for new monitors, there was not a strong commitment to actually be willing to pay. They stated se veral points on this topic: EPA and other funding sources need to be explored; one option to consider is cost sharing; industry already gives the government tax dollars wh ich the government should use to meet priority public health concerns; industry alread y pays for monitoring in many cases; and industry budgets also have been cut in many cases.
Many IS provided suggestions that could help optimize the SO 2 monitoring network:

Relocating some monitors s hould be a first priority.

Recognize future controls.

Discontinue monitors showing lower levels.

Mine data already in hand.

Look at all the retired monitor data.

Use a screening model to identify sources that do not need monitors.

Shift the allocation of m onitors from ozone to SO 2 . Some IS felt that with proper placement, a few monitors, or even a single monitor could adequately characterize the air quality around a source. They noted that modeling can be useful in placing a monitor, but should not be the exclusive means of determining siting.
Many IS stated there is a need for a sunsetprovision for monitors, the network should change as sources change, and st ates should be given flexibility on implementation. Some IS stated that the limiting cost factor is operation and maintenance over many years. Some IS suggested the removal proce ss could be supported by use of continuous emissions monitoring system (CEMS) data, historic data, and other pollutant monitors as surrogates (e.g., correlate PM and SO 2 data).3 Not Final Agency Action A few IS asked whether EPA is open to us ing data from industry-operated monitors. They noted that many sources already have industry-operated monitors. When these are considered, the burden of going to a monitori ng-only approach might not be as great as initially thought.

Thresholds
IS made several suggestions and points regardi ng the concept of focusing implementation on sources exceeding a particular threshold:

Focus on sources over 5,000 tons per year, since it is harder for smaller facilities to afford monitoring;

Establish thresholds by sector or source category;

The higher the threshold, the more likel y funding will be able to be found for monitoring;

Consider using a population-we ighted index as a factor in developing a thresholdbased approach.
Many IS supported the threshold concept but expressed concern about implementing the thresholds using today’s source locations and emissions profiles, when that will bechanging a lot over the next few years due to factors such as complying with the CrossState Air Pollution Rule and the Mercury and Air Toxics Standards, and expected source retirements. They stated that industry is making these regulatory decisions now even though compliance dates are far in the fu ture. They suggested states should have flexibility in this monitoring decision to site monitors based on future emissions in order to avoid the unnecessary deployment of monitors in places where there will not be a problem in the future.
Modeling
Many IS stated that models are not a substitute for monitors. They stated it would be inequitable to spend hundreds of millions of dollars for controls based on modeling. Several IS provided claims to support their position, including the following:

Current models are not representative of actual air quality, whether actual or allowable emissions are used.

The SO 2 1-hour standard is different than any other past standard in that there is now no room for conservatism.

One attendee stated that in an analysis where actual hourly emissions data and onsite meteorological data were used, the results from AERMOD modeling were 3 times the monitored ambient air quality data from the same time frame.

With higher concentrations, the differe nce between modeling and monitoring results gets larger.

Models are conservative in low wind speed and downwash cases.

Models are imperfect while monitors are the truth.4 Not Final Agency Action Some IS recognized that modeling may be useful in certain situations: where states and sources provide technical analyses showing the modeling is accurate; where modeling with conservative parameters, such as potential to emit, shows attainment; and to help site monitors. Some IS indicated that they would be willing to help states with modeling.

Some IS stated that model refinements are needed before the AERMOD model should be used, especially with respect to low wind speeds. They stated that revisions to Appendix W are needed and the next version of AERM OD needs to go through public review to address any unintended consequences of the revisions, especially downwash.
Some IS stated that any modeling approach must recognize that there are complex multisource areas where a monitor is a more accurate and cost-effective approach.
Some IS stated that industry ideas for mode l improvement have not been acted on by EPA. They stated that EPA’s m odel clearinghouse is too slow . Some IS stated they want more interaction with EPA and more exped itious action. They noted that Electric Power Research Institute model improvement activities are underway and improvements will be posted within one week of the June 1 meeting regarding a distance applicability study for steady state models and an emissions variability processor.

Some IS stated that AERMOD does not fit a ll cases and that EPA should allow use of alternative models, as is the case in SIP development. They also indicated that a less arduous process is needed for CALPUFF and other models.
Some IS stated EPA modeling guidance is needed to clarify issues related to the appropriate distance for low wind speed cases, meteorological data, background concentrations, and start-up emi ssions. Other IS stated that if on-site meteorological data are not available, then the results would not be realistic. Some IS stated that modeling should not include all other sources. A few I S stated the modeling should focus on base load units, not cycling units. They indicated concern that Canadian sources could cause problems.

Some IS stated that EPA should consider that the probability is low that the highest emissions would occur at the same time as worst-case meteorology, and that a person would be exposed to these concentrations at the location of maximum concentration. Some IS also stated concern over modeled imp acts on an island or over water, since it is likely no one would be exposed at that location.
Noting concerns about the unrepresentativene ss of certain meteorological data (such as airport meteorological data), some IS felt that any modeling approach would need to include provisions for on-site meteorological data collection before modeling could be done. Other IS noted that the cost and timin g for meteorological data collection to support modeling may be similar to that of simply using a monitoring-only approach.5 Not Final Agency Action Actual Emissions
Some IS stated that to represent current air quality, models should use actual emissions and actual stack heights. They asserted that the Clean Air Act (CAA) does not prohibit use of actual stack heights for modeling current air quality and, thus, good engineering practice stack heights should not be used.
Some IS stated that modeling for planning purposes (Prevention of Significant Deterioration and State Implementation Plans) is not the same as modeling for designations. They stated that including intermittent and small sources could strain the modeling process; e.g., auxiliary boilers with short stacks or low capacity units (< 10%). Some IS also noted that the likelihood of a unit operating at its permit limit for 8,760 hours per year is very low. Some IS sugg ested that emissions variability should be considered in the modeling, at least for electricity generating units with CEMS data. A few IS also noted concern regarding start -up emissions and felt EPA should consider ways to simplify treatment of these sources.
Implementation
Many IS stated that designations should be made based on monitoring, not modeling.
Most of the IS who commented stated they do not agree with the section 110(a)(1) concept described in the White Paper (i.e. requiring near-term modeling and controls as necessary for sources in unclassifiable areas) because it would require SIP action in areas where a violation had not been identified usin g monitoring. Some object in principle to addressing unmonitored areas (or even areas with clean monitors nearby) with the same processes as nonattainment areas would use, even if more time were provided.
Some IS stated that areas that get designated as unclassifiable for SO 2 should be treated in a similar manner as unclassifiable areas for other NAAQS pollutan ts. Some IS stated that areas located far from sources s hould be designated attainment. A few IS recommended that future action be left to st ate discretion and stated this approach is consistent with the CAA. Other IS suggested the process could include comparing similar source sizes across the country.
Where a problem is observed, some IS suggested the state would, at that time, start a process to resolve it and fe lt it could be done without a nonattainment designation. One IS described a past case where an attainment area for particulate matter later recorded high readings, the state and others initiate d a process and study, and emissions were reduced such that the problem was resolved within 18 months without a nonattainment designation.
A few IS commented that, if a state has a mechanism such as title V, it could work as an option for addressing violations, though m odeling alone should not be the basis for identifying the violation. Other IS stated that a title V permit renewal process is not the6 Not Final Agency Action appropriate place to determine whether an area meets or does not meet the standard, nor to create new emission reduction requirements for sources in unclassifiable areas.
Hybrid
Some IS believe that states need the flexibility which would be allowed in the hybrid approach. They suggest states should d ecide between monitoring and modeling.
Rulemaking or Guidance
The IS stated that rulemaking with a comment period is necessary for defining requirements to address sources in unclassifiable areas; guidance alone would be inadequate.
Timing
Many of the IS stated that EPA should notrush to adopt and implement additional requirements for addressing unclassifiable areas. They noted that SIPs are an iterative process which takes time. For unclassifiabl e areas, some IS suggested EPA should consider for the SO 2 program action similar to the NO 2 program, which provides sufficient time for a phased monitoring deployment approach.
Virtually all of the IS stated that only monito ring data should be used for nonattainment designations. They further stated that time is needed to deploy additional monitors. Several recommended EPA establish a phased schedule for monitoring in unclassifiable areas where the Agency thinks more monitoring is needed.7 Not Final Agency Action ATTENDEES FOR SO 2 NAAQS IMPLEMENTATION STAKEHOLDER MEETING June 1 - Industry Representatives

Baker Jeff Total Chemical & Refinery Bond Alex National Mining Caiazza Roger Environmental Energy Alliance of NY Collins Renee Luminant Power Coughlin Patrick Duke Energy Cromwell T. Ted NRECA Deason Doug Downstream and Chemical SH&E Dupuis Lenny Dominon Ellis Howard EnviroPlan Consulting Feldman Howard API Fleischmann Laura Winston & Strawn Garrison Mark Environmental Resources ERM Gesser Ryan Georgia Pacific Gossett Stephen Eastman Chemical Greco Robert We Energies Guerra Sergio Wenck Assoc. Hanning Joseph U.S. Steel Hill Jonathan Trinity Consultants Hirsch Robert Portland Cement Association Ipanag Sylvia Guam Power Authority Kacenjar Allen ArcelorMittal,USA Kaufmann Robert Koch Companies Public Sector Knipping Eladio Electric Power Research Insitiute Kuryla Matt Baker Botts L.L.P. Langworthy Lucinda Hunton & Williams Lebeis Michael DTE Energy Lee Max Koogler & Associates Lettrich Jeff ALCOA Ling Michael Environmental Protection Agency Long David American Electric Power Lucas Kyle Black & Vech Manousos Pete First Energy Corp. Consultant Mastro Donna EPA Region 3 McCall Colin All4 Inc. Morrison Angela Note: Assisting Dr. Lee Pagano Peter American Iron and Steel Institute Page Steve Environmental Protection Agency

Paine Robert AECOM/American Petroleum Institute/American Iron and Steel Institute Pelan Michael Lafarge North America, Inc. Pinkerton John National Council for Air and Stream Improvement, Inc.8 Not Final Agency Action Raasch Clay We Energies/Trinity Consultant Sabangan Lorina Guam Power Authority Scarpinuto Bill Dominion Schewe George Trinity Consultants Shimshock John GenOn Energy Smith Ross PotashCorp/PCS Phosphate Co. Inc. Smith Steve Houston Regional Monitoring Smithson Stephen Stephens Keith Powersouth energy Cooperative Summerhays John EPA Region 5 Walter Justin Southern Company Warner Brian Wolverine Power Cooperative/NRECA Wayland Chet Environmen tal Protection Agency Willoughby Patrice Oxbow Carbon Winston Cynthia Progress Energy Wittliff Dan GDS/Consultant for East TX Electric Coop Zavoda Rich ArcelorMittal,USA