FINAL
August 24, 2004
FIFRA SCIENTIFIC ADVISORY PANEL (SAP)
OPEN MEETING
AUGUST 26-27, 2004
FIFRA SAP WEB SITE https://www.epa.gov/scipoly/sap/
OPP Docket Telephone: (703) 305-5805
Docket Number: OPP-2004-0241
THURSDAY, AUGUST 26, 2004
Holiday Inn - National Airport
2650 Jefferson Davis Highway
Arlington , VA 22202
Telephone: (703) 684-7200
Fumigant Bystander Exposure Model Review: The Fumigant Exposure Modeling System (FEMS) Using Metam Sodium as a Case Study
FIFRA SCIENTIFIC ADVISORY PANEL (SAP)
OPEN MEETING
AUGUST 26-27, 2004
FIFRA SAP WEB SITE https://www.epa.gov/scipoly/sap/
OPP Docket Telephone: (703) 305-5805
Docket Number: OPP-2004-0241
FRIDAY, AUGUST 27, 2004
Holiday Inn - National Airport
2650 Jefferson Davis Highway
Arlington , VA 22202
Telephone: (703) 684-7200
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8:30 AM Introduction and Identification of Panel Members – Steven Heeringa, Ph.D. (FIFRA SAP Session Chair)
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8:35 AM Administrative procedures by Designated Federal Official - Mr. Paul Lewis
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8:40 AM Follow-up from Previous Day’s Discussion – Mr. Jeffrey Dawson (Office of Pesticide Programs, EPA)
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9:00 AM Panel Discussion (continued)
Question 3: The determination of appropriate flux/emission rates is critical to the proper use of the FEMS model as these values define the source of fumigants in the air that can lead to exposures. There are different methods of determining flux/emission rates from empirical data including direct measurements and what is referred to as the “indirect” or “back-calculation” method. Direct measurement of flux is not that common in the available data because of the difficulties and expense associated with generating these types of data. The “indirect” method is most commonly used and involves fitting monitoring data with ISC to determine flux/emission rates. Upon its review of how flux rates can be calculated, the Agency has identified a number of questions it would like the panel to consider. The emission fitting procedures used in FEMS are based on least squares analyses of log-transformed, dispersion modeling and field monitoring data. What, if any refinements are needed for this process? Is it appropriate to log transform these types of data for back-calculation purposes and to use a least-squares regression analysis which implicitly assumes that the fitted line passes through the origin? How appropriate is it to use a flux/emission factor from a single monitoring study (or small number of studies) and apply it to different situations such as for the same crop in a different region of the country? Does the panel believe that FEMS could adequately consider multiple, linked application events as well as single source scenarios? Does FEMS appropriately address situations where data are missing (i.e., is the data filling procedure appropriate)? Should there be a threshold r2 value below which a regression of measured versus modeled air concentrations should not be used in flux rate determinations? What are possible alternative approaches?
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10:00 AM BREAK
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10:15 AM Panel Discussion (continued)
Question 4: The integration of actual time-base meteorological data into ISCST3 is one of the key components that separates the FEMS methodology from that being employed by the Agency in its current assessment. The Agency has identified several potential sources of these data including the National Weather Service, Federal Aviation Administration, California Irrigation Management Information System (CIMIS), and the Florida Automated Weather Network (FAWN). The Agency is also aware that there are several approaches that can be used to process meteorological data and acknowledges that FEMS used PCRAMMET which is a standard Agency tool for this purpose. Upon its review of what meteorological data are available and how it can be processed for use in an assessment such as this, the Agency has identified a number of questions it would like the panel to consider. The test case example in FEMS is based on the National Weather Service ASOS meteorological monitoring station in Fresno, California. What are the SAP’s thoughts on the use of National Weather Service / Federal Aviation Administration meteorological data sets in comparison with either CIMIS or FAWN for this type of application? What criteria should be used to identify meteorological regions for analysis and how should specific monitoring data be selected from within each region? Anemometer sampling height has been identified as a concern by the Agency in preparation for this meeting. For example, some data are collected at 2 meters while others are collected at a height of 10 meters. What are the potential impacts of using either type of data in an analysis of this nature? FEMS uses “assumed distributions” to account for uncertainty in the meteorological data based on Hanna, 1998 [as referenced in the FEMS background paper]. Is this an appropriate technique? Does FEMS treat stability class inputs appropriately, especially the quantitative manipulations of these data that have been completed? Is the concurrent use of emissions and meteorological conditions in FEMS useful in identifying concurrent upper-end conditions that could lead to peak exposures for bounding exposure events?
Question 5: The Agency model, ISCST3 is the basis for the FEMS approach. This model has been peer reviewed and is commonly used for regulatory purposes by the Agency. FEMS also uses other Agency systems such as PCRAMMET and TOXST. Are there specific recommendations that the panel can make with regard to any parameter that should be altered to optimize the manner that they are used in FEMS? ISCST3 can treat “calm” (i.e., periods where the windspeed in essentially 0) in one of two ways including the concentration is set to (0) and an approach that uses the last non-calm wind direction/concentration. FEMS uses the first approach. Does the panel concur? In Section 2.2 Specific Technical Considerations With Regard To The Design Of FEMS of the background document, there is a section entitled Computing Endpoint Distances. Please comment on the procedures included in this section? The FEMS analysis is based on a single field being treated once per year. On this basis, ISCST3 files include 200 full years of hour-by-hour sequential data. Application start times are randomly selected to match the user-supplied application frequency. For example, if a model user entered 10,000 simulations, there will be approximately 10,000 randomly selected start times with batch modeling treatment of 4 days duration for each application. In addition, FEMS allows for more than one application per year to be modeled. Does the panel view this as an appropriate process? If not can it make suggest recommendations or modifications that may improve this process? Can the panel comment on the source geometry used in FEMS and the implications of this choice?
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12:00 PM LUNCH
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1:00 PM Panel Discussion (continued)
Critical Element 3: Results
Question 6: Soil fumigants can be used in different regions of country under different conditions and they can be applied with a variety of equipment. Does the SAP believe that the methodologies in FEMS can be applied generically in order to assess a wide variety of fumigant uses? What considerations with regard to data needs and model inputs should be considered for such an effort?
Question 7: Does FEMS adequately identify and quantify airborne concentrations of soil fumigants that have migrated from treated fields to sensitive receptors? The Agency is particularly concerned about air concentrations in the upper ends of the distribution. Are these results presented in a clear and concise manner that would allow for appropriate characterization of exposures that could occur at such levels?
Question 8: A sensitivity analysis has been conducted and is described in the FEMS background document. What types, if any, of additional contribution/sensitivity analyses are recommended by the panel to be the most useful in making scientifically sound, regulatory decisions? What should be routinely reported as part of a FEMS assessment with respect to inputs and outputs? Are there certain tables and graphs that should be reported? What types of further evaluation steps does the panel recommend for FEMS?
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5 :00 PM ADJOURNMENT
Please be advised that agenda times are approximate. For further information, please contact the Designated Federal Official for this meeting, Mr. Paul Lewis, via telephone: (202) 564-8450; fax: (202) 564-8382; or email: lewis.paul@epa.gov |
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