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Modeling VS Modeling

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SO2 1 -Hour NAAQS. Modeling VS Modeling. Rule Chronology. Proposed December 9, 2009 Adopted June 22, 2010 States Designation Recommendation due: June 3, 2011 EPA Final Designation set for June 3, 2012. Proposed Rule Preamble.

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Presentation Transcript
rule chronology
Rule Chronology
  • Proposed December 9, 2009
  • Adopted June 22, 2010
  • States Designation Recommendation due: June 3, 2011
  • EPA Final Designation set for June 3, 2012
proposed rule preamble
Proposed Rule Preamble
  • Devoted 9 pages in Section III of Preamble to Monitoring Requirements
  • Section III specifically states: “Ambient SO2 monitoring data are used to determine whether an area is in violation of the SO2 NAAQS”
  • Preamble does not mention Modeling
preamble solicited comments
Preamble Solicited Comments
  • Preamble in proposed rule has many areas where EPA specifically solicited comments, e.g.
    • Requirement for state and local agencies to report both hourly and 5-minute averages
    • Levels as high as 150 ppb
  • EPA did not seek comment on Modeling trumping Monitoring
  • No hint, EPA was considering a Policy that Modeling would be preferential to Monitoring
final rule
Final Rule
  • 50.17 a) sets standard at 75 ppb
  • 50.17 b) the 1-hour standard is met at an ambient air quality monitoring sitewhen the 3-year average of the annual (99th percentile) of the daily maximum 1-hour average concentrations is less than or equal to 75 ppb, as determined in accordance with Appendix T
  • Appendix T identifies data handling for monitoring data
  • No mention of Modeling
state s concerns
State’s Concerns
  • Guidance stipulating that modeling trumps monitoring is unprecedented and sets a new direction
  • Guidance has not been vetted through public review
  • Guidance selects AERMOD as model of choice
    • Concerns that AERMOD is overly conservative
    • Other Models e.g. Calpuff may be better suited
  • Guidance Requires Maximum Emission Rates
    • Most Sources operate well below maximum rates
    • Ignores CEM data that is available
  • Guidance Ignores Ambient Monitoring unless it shows violation
designation schedule
Designation Schedule
  • State’s must submit Designation Recommendations NLT June 3, 2011
  • EPA Notifies States by February 3, 2012 concerning any intended modifications to State’s Recommendation
  • Comment Period ends March 20, 2012
  • State’s Respond by April 3, 2012
    • Insufficient time to conduct modeling
  • EPA Promulgates Designation NLT June 3, 2012
chronology
Chronology
  • June 22, 2010 Rule Promulgated
  • August 2010 ND and others Petitioned EPA to Reconsider
  • January 18, 2011 EPA denies Petition
  • March 30, 2011 Court issued order consolidating Petitions for Review
  • April 28, 2011 Filing Deadline – Statement of Issues
  • May 12, 2011 Briefing Schedule Deadline
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