FLM ISSUES AROUND THE COUNTRY EPA REGION 4 AIR QUALITY MODELERS WORKSHOP

2 Disclaimer The following presentation represents the current views and ideas of the federal land management agencies’ staff and does not necessarily represent the official position of the Department of the Interior, the Department of Agriculture, or the agencies or bureaus of these departments. Editorial comments are those of the presenter and do not necessarily reflect the views or opinions of anyone else.

3 FLM COMPLETION OF BART REVIEWS FLMs have seen the final analyses of state SIP and federal FIP BART analyses. NPS has provided additional BART modeling analyses with optional control scenarios to EPA Regions 5, 7, 8, 9. Craig 3 units, Colorado G. Gentleman, 4 units, Kansas Colstrip 4 units, Montana Coyote 1 unit, Wyoming Laramie River 3 units, Wyoming Intermountain Power 2 units, Utah Four Corners 5 units, New Mexico Navajo 2 units, Arizona Taconite facilities, MN,MI

SCREENING OUT OF A CLASS I AIR QUALITY RELATED ANALYSIS PER CLASS I AREA EMISSIONS / DISTANCE TO EACH CLASS I AREA(S) EMISSIONS = MAXIMUM 24 HOUR EMISSION LIMITS FOR: SO 2 + SO 4 + NO X + PMC + PMF + SOA + EC X 8760 / 2000 = TPY DISTANCE TO EACH CLASS I AREA IN KILOMETERS IS Q/D ≤ 10 PER CLASS I AREA ?

5 REGION 4 QUESTIONS Q: The emissions for the visibility analysis are the maximum allowable 24-hour emissions from all modified facilities less the actual hourly rate averaged over the past two years (annual emissions over the past two years divided by the hours of operation over these two years.). This is noted to be different from net short- term project emission used in other PSD Class I and II compliance assessments (Page 24). **This the procedure does not appear to be used for the visibility assessment in the PSD permit applications.** True for major modifications, the netting that the FLMs apply is to address the effects of the 24-hour permitted emission rate for that specific emission(s) increases due to just the modification emission increase. Using a 30 day average emission rate as input to the visibility modeling analyses does not restrict the facility from emitting pollution at a higher rate for shorter time periods (e.g., 24- hour average). A 30 day average emission rate smooths out days with high emissions, and therefore, would underestimate the predicted 24-hour visibility impacts.

6 Question #2 Q: The emission rates to use for deposition are not explicitly provided. Are these based on the total facility emissions including the project, the only net project increased emissions, or some other method like that given above for visibility? The discussion of DATs (Page 66), the emissions are associated with proposed new or modified facilities. Emissions for the AQRV deposition analysis for a new source are the permitted annual emissions. For a major modification just the increase in emissions are modeled for the deposition Kg/HA/YR both sulfur and nitrogen : Eastern US Kg/HA/YR both sulfur and nitrogen : Western US

7 Question #3 Q: The initial Q/D screening assessment discussion (Page 18) just address the "source". It does not explicitly address modification projects. Therefore, the proper Q value used in the screening appear to be total facility, including proposed project, annual emissions which are determined by annualized maximum 24-hour total facility emissions. Note that most of the Q/D analyses in PSD analyses have just used the net project increased emissions. What are the correct emissions to use for the Q/D assessment? Note that Q/D (emissions TPY/distance KM)is applied to screen- in or screen-out sources for visibility/haze analysis only, not applied for deposition or increment issues. Q/D only applies for sources/modifications >50 km. For modifications Q is only the emission increase in visibility or deposition impairing emissions.

8 Question #4 Q: Provide, the appropriate CALPUFF settings for proper AQRV assessments CALPUFF Test options specified to see if they conform to regulatory values? (MREG) Default: 1 ! MREG = 1 ! 0 = NO checks are made 1 = Technical options must conform to USEPA Long Range Transport (LRT) guidance METFM 1 or 2 AVET 60. (min) PGTIME 60. (min) MGAUSS 1 MCTADJ 3 MTRANS 1 MTIP 1 MCHEM 1 or 3 (if modeling SOx, NOx) MWET 1 MDRY 1 MDISP 2 or 3 MPDF 0 if MDISP=3 1 if MDISP=2 MROUGH 0 MPARTL 1 SYTDEP 550. (m) MHFTSZ 0

9 Question #4 Q: Provide, the appropriate POSTUTIL settings for proper VISIBILITY AQRV assessments Recompute the HNO3/NO3 partition for concentrations? (MNITRATE) Default: 0 ! MNITRATE = 1 ! 0 = no 1 = yes, for all sources combined 2 = yes, for a source group 3 = yes, ALM application in one step Input File Default File Name CALPUFF.DAT ! MODDAT =COLSTRIP-1234-SO2NOXBART-2006.CON ! !END! Data File MODEL.DAT ! UTLDAT =PU-MN-COLSTRIP-1234-SO2NOXBART2006.CON ! The following NSPECINP species will be processed: ! ASPECI = SO2 ! !END! ! ASPECI = SO4 ! !END! ! ASPECI = NOX ! !END! ! ASPECI = HNO3 ! !END! ! ASPECI = NO3 ! !END! ! ASPECI = PMF ! !END! ! ASPECI = PMC ! !END! ! ASPECI = EC ! !END! ! ASPECI = SOA ! !END!

10 Question #4 Q: Provide, the appropriate POSTUTIL settings for proper DEPOSITION AQRV assessments Recompute the HNO3/NO3 partition for concentrations? (MNITRATE) Default: 0 ! MNITRATE = 0 ! 0 = no 1 = yes, for all sources combined 2 = yes, for a source group 3 = yes, ALM application in one step Input File Default File Name Number of CALPUFF data files (NFILES) Default: 1 ! NFILES = 2 ! Input File Default File Name CALPUFF.DAT ! MODDAT =DW-MI-ANNUAL-01.DRY ! !END! 2 (none) ! MODDAT =DW-MI-ANNUAL-01.WET ! !END! Subgroup (2a) Subgroup (2b) The following NSPECOUT species will be written: ! ASPECO = N ! !END! ! ASPECO = S ! !END!

11 IMPROVE Algorithms FLAG 2000 – b ext = 3f(RH)[sulfates] +3f(RH)[nitrates] +4[organics] +10[elemental carbon] +1[fine soil] +0.6[coarse matter] + 10 New (changes in blue) – b ext = 2.2f S (RH)[small sulfates] + 4.8f L (RH)[large sulfates]+2.4f S (RH)[small nitrates] + 5.1f L (RH)[large nitrates] +2.8[small organics] + 6.1[large organics] +10[elemental carbon] +1[fine soil] +1.7f SS (RH)[sea salt] +0.6[coarse matter] +Rayleigh scattering (site specific) +0.33[NO 2 (ppb)]

CALPOST v6.221 Method 8 Mode 5 INPUT GROUP: 2 -- Visibility Parameters (ASPEC = VISIB) Test visibility options specified to see if they conform to FLAG 2008 configuration? (MVISCHECK) -- Default: 1 ! MVISCHECK = 1 ! 0 = NO checks are made 1 = Technical options must conform to FLAG 2008 visibility guidance ASPEC = VISIB LVNO2 = T NO2CALC = 1 RNO2NOX = 1.0 MVISBK = 8 M8_MODE = 5 Some of the data entered for use with the FLAG 2008 configuration are specific to the Class I area being evaluated. These values can be checked within the CALPOST user interface when the name of the Class I area is provided. Name of Class I Area (used for QA purposes only) (AREANAME) -- Default: User ! AREANAME =Great Smoky MTS NP !

CALPOST v6.221 Method 8 Mode 5 Additional inputs used for MVISBK = 8: Extinction coefficients for hygroscopic species (modeled and background) may be computed using hourly RH values and hourly modeled concentrations, or using monthly RH values inferred from the RHFAC adjustment factors and either hourly or daily modeled concentrations, or using monthly RHFSML, RHFLRG, and RHFSEA adjustment factors and either hourly or daily modeled concentrations. (M8_MODE) -- Default: 5 ! M8_MODE= 5 ! FLAG (2008) 1 = Use hourly RH values from VISB.DAT file with hourly modeled and monthly background concentrations. 2 = Use monthly RH from monthly RHFAC and EPA (2003) f(RH) tabulation with hourly modeled and monthly background concentrations. (VISB.DAT file is NOT needed). 3 = Use monthly RH from monthly RHFAC with EPA (2003) f(RH) tabulation with daily modeled and monthly background concentrations. (VISB.DAT file is NOT needed). 4 = Use monthly RHFSML, RHFLRG, and RHFSEA with hourly modeled and monthly background concentrations. (VISB.DAT file is NOT needed). 5 = Use monthly RHFSML, RHFLRG, and RHFSEA with daily modeled and monthly background concentrations. (VISB.DAT file is NOT needed).

14 ENERGY DEVELOPMENT OIL & GAS FLMs – Bureau of Land Management has seen large increases in oil and gas development of leases on BLM lands. BLM lease lands are often in close proximity to NPS, US Forest Service Lands, and Fish & Wildlife Service lands. BLM often balked at performing adequate air quality impact analyses including and evaluating against FLM FLAG thresholds of visibility and acid deposition impacts. EPA and BLM also did not agree on many of the same issues. Therefore in June 2011 an interagency MOU was signed

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Technical Implications & Applications of MOU / (Air Modeling) for Federal Oil & Gas NEPA Decisions Bureau of Land Management U.S. Forest Service Environmental Protection Agency National Park Service Fish & Wildlife Service 16

Clean Air Act Overview Provides Additional protection for Class I areas  Preserve AQ and Air Quality Related Values (AQRVs)  AQRVs include resources sensitive to air pollution (e.g., soil, water, visibility, plants, animals)  Regional Haze Programs and national visibility goals for Class I areas National Visibility Goal: “remedy any existing and prevent any future manmade visibility impairment in mandatory Class I areas” 17

Air Quality & Oil and Gas Development Why are We Concerned? 18

Why was the MOU Necessary? AQRV Protection Pre-MOUPost-MOU BLM and other FLM Agencies used 2 different sets of thresholds and methodologies to evaluate potential impacts to AQRVs. NEPA documents featured the Lead Agency’s approach. BLM and the other FLM Agencies may use 2 different sets of thresholds and methodologies to evaluate potential impacts to AQRVs. The Lead Agency’s NEPA documents will discuss affected Agencies’ thresholds and methodologies and their views on: -The nature of impacts to AQRVs on their lands; and -Potential mitigation. 19

Why was the MOU Necessary? Dispute Resolution (Sec. VII) Pre-MOUPost-MOU Disputes between Federal Agencies were often not resolved and stretched into years of conflict. A dispute resolution process offers specific steps and a timetable to avoid delays. The Agency seeking resolution will initiate the process with a written statement to “Level One” contacts for all involved Agencies. If not resolved, disputes will be elevated to “Level Two” and then “Level Three” contacts at the Assistant Secretary/Assistant Administrator/Under Secretary level in Washington, DC. 20

What Type of Model Do I Use? Model Characteristics Matrix in appendix to MOU describes models to be used when modeling is triggered For distances less than 50-km: – AERMOD for NAAQS and increment – VISCREEN/PLUVUE for visibility For distances greater than 50-km (usually for smaller projects): – CALPUFF for NAAQS, increment, and AQRV For all distances where complex atmospheric chemistry (Ozone and fine particles) are of concern: – CAMx/CMAQ for NAAQS and AQRV 21

22 OTHER FUTURE FLM ISSUES FLMs and EPA thru IWAQM are considering the MMIF met processor using WRF as a replacement for CALMET FLMs are considering creating 12 km nationwide grids for use in LRT modeling (similar to the VISTAS domains). EPA investigating MMIF for use with AERMOD. FLMs & EPA are forming a group to evaluate deposition for AQRV acid deposition at < 50 km to relieve the burden of running CALPUFF for near field deposition. Long Term a replacement for CALPUFF with better chemistry and dispersion. Provide comments to October permit memorandum regarding notification to the FLMs of major source permits > 100 km. FLMs request notification of major source permits up to 300 km distance from their Class I areas. Explore the use of AERMOD for acid deposition AQRV analysis for distances < 50km. For increment analysis > 50km FLMs/EPA may investigate running CALPUFF in the no chemistry or deposition mode.

23 NPS SPECIAL MONITORING EFFORTS NPS is expanding its NH3 monitoring program NPS is expanding its Hg monitoring network. NPS measures trends of impacts to NPS resources in Region 4 and nearby NPS units. Nationwide the potential NPS Class I units could be nonattainment of the O3 NAAQS. If 75ppb ~ 6 nonattainmant If 70 ppb ~15 nonattainment If 65 ppb ~19 nonattainment If 60 ppb~23 nonattainment

Ammonia (NH3) Monitoring The NADP Ammonia Monitoring Network (AMoN) has expanded from 20 original pilot sites to 58 sites since 2010, 10 of which are funded by NPS. NADP AMoN

Ammonia (NH3) Monitoring Samples are collected biweekly with a Radiello passive sampler. A site costs ~$2.5K/yr to operate. Potential expansion in 2013 by EPA to all CASTNet sites. AMoN Site at Loch Vale in Rocky Mountain National Park.

2011 Ambient NH3 Concentrations

Monitoring Mercury Wet Deposition Mercury Deposition Network (MDN) 16 of 108 MDN sites are in national parks NPS MDN site

Fish Songbirds E X P E R I E N C E Y O U R A M E R I C A Grand Teton NP (WY) Mount Rainier NP (WA) Yosemite NP (CA) Monitoring Hg in NPS Biota: 2012 Dragonfly Larvae

NPS Hg Studies: WACAP & more E X P E R I E N C E Y O U R A M E R I C A

Conditions and Trends In & Near Region 4 Trend analyses are completed using 10 years (2000–2009) of data from on-site or nearby monitors. Five-year (2005–2009) estimates of air quality conditions are used to evaluate conditions. NPS ARD has established thresholds conditions for visibility as good ( 8 dv); ozone as good (≤ 60 ppb), moderate (61–75 ppb), and significant concern (≥ 76 ppb); and atmospheric deposition of nitrogen and sulfur as good ( 3 kg/ha/yr).