EPA Region 10 Cumulative Effects Analysis Methodology Development Rob Wilson and Herman Wong WESTAR Fall Technical Conference September 16, 2003

Objective Develop procedures and data sets for WA, OR, & ID Consistent application with State &FLM buy-in Cumulative Class I Increment analysis Cumulative air quality related value (AQRV) (visibility and deposition) analysis Available on Internet (No Class II Increment or NAAQS for now)

Dispersion Model CALPUFF System For point sources For mobile and area sources? Limited chemistry Practicality for large runs?

Meteorology 12-km MM5 data from Univ. of Washington Three years of data Limited study to evaluate CALMET options for MM5

Terrain with 12-km spacing

Emissions Request to States for point sources –Baseline –Actual –Allowable –SO 2 >40TPY, NO x >40TPY, PM>15 TPY Mobile source assessment –MOBILE 6 applied to Puget Sound region, 1988 & 2003 –VMT up 34% –Tail-pipe NOx emissions down 22% –Fugitive PM scales with VMT –Will need to be included in PSD increment analyses

Process State concerns: –Predicted widespread increment violations or AQRV impacts may lead to construction ban –Policy development should precede technical development –Lack of resources to help development or to implement Joint Technical Advisory Committee with States and FLMs Joint policy development group (progress?)

Initial Problems & Issues Changes/errors in CALMET/CALPUFF How to calculate PSD Increment –Model only increases and decreases –Model baseline and current –Short-term increment

Initial Problems & Issues (continued) Emission inventories –No minor sources yet –Idaho EI still in development –Washington not fully evaluated yet (only point sources >100 TPY)

Oregon EI Issues Stack parameters –Provided total emissions for the source; not by emissions unit –One stack for all units at a source, max plume rise –Missing for many sources; will assign NEI defaults by SIC code –Not suitable for Class II increment or NAAQS analysis –PSD program not linked to EI improvement –ODEQ does not seem to have the will or the resources to get stack data for modeling TSP/PM 10 inconsistency –For baseline, PM 10 = % of TSP –For current actuals, PM 10 based on emission factors

EI Suggestions Should account for minor sources, too (will have to for 2002 EI) Minimum modeling data –By emission unit at stationary source –UTM or lat/long, datum, and elevation –Operating schedule –Baseline, permit allowable, and current actual emissions –Stack data (height, temp, exit diameter/velocity) –Nearby building dimensions

Project Schedule System installed in March 2003 Currently evaluating met and preparing EIs Testing with single source December 2003? Preliminary system with complete EI by January 2004? Tested system available to others by April 2004? Policy development schedule???

Things to Try Later Employ CMAQ –For mobile and area sources –Background for CALPUFF –Emissions outside of WA, OR, and ID Nesting to 4 km in CALMET/CALPUFF Employ 4-km MM5 data

Some Recommendations Further evaluation of options in generating meteorological data with MM5 & CALMET State and Tribal EIs should be built for modeling PSD/NSR/Title 5 programs should improve state EI Need to be getting nearby building data Policy development for Cumulative Effects Analysis should be pursued more aggressively