1 / 8

Modeling VS Modeling

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.

damon
Download Presentation

Modeling VS Modeling

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript


  1. SO2 1-Hour NAAQS Modeling VS Modeling

  2. 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

  3. 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

  4. 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

  5. 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

  6. 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

  7. 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

  8. 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

More Related