This is a preliminary document prepared by a subgroup of members of the Base Programs Analyses and Policies Work Group as part of the Federal Advisory Committee Act (FACE) Subcommittee process. It is not an EPA document. Interested people should forward their comments to a member of the Base Programs Analyses and Policies Work Group.

Boundaries of Areas of Violation

Date:	January 27, 1997

Contact:	John Crouch, Hearth Products Association, Telephone 916/974-1188,

Fax 916/974-8380

Introduction

Section 107 of the Clean Air Act (CAA) requires the EPA to designate as nonattainment "any area that does not meet (or that contributes to ambient air quality in a nearby area that does not meet) the national primary or secondary ambient air quality standard for the pollutant." Designated nonattainment areas are subject to CAA section 172 general nonattainment provisions, which include making reasonable further progress (RFP), developing an emission inventory, providing for contingency measures if RFP is not achieved, and other requirements. Additionally, in accordance with CAA section 173, major new or modified sources in nonattainment areas must comply with the lowest achievable emission rate (LAER) and must offset any emission increases by obtaining emission reductions from sources located in the nonattainment area.

The EPA is considering a PM2.5 annual standard based on the 3-year average of the annual arithmetic mean PM2.5 concentrations, spatially averaged across an area, and an 8-hour ozone standard based on a 3-year average of ozone concentrations at the highest monitor. (See National Ambient Air Quality Standards for Particulate Matter: Proposed Decision, November, 1996; National Ambient Air Quality Standards for Ozone: Proposed Decision, November, 1996; and Proposed Requirements for Designation of Reference and Equivalent Methods for PM2.5 and Ambient Air Quality Surveillance for Particulate Matter, November, 1996.)

Nonattainment areas have traditionally attempted to identify both the area in which a violation is occurring and the area which is causing or influencing the violation. In order to address broader transport issues which are relevant to ozone, fine particles (PM-fine), and regional haze, the July 25, 1996 Designation Issues for New NAAQS issue paper recommends that the nonattainment designation process be separated into two parts -- identifying the "Area of Violation" (AOV) and determining the "Area of Influence" (AOI). This proposed designation approach would combine the ability to address broader transport issues with the ability to continue to implement local controls as necessary. (The Designation Issues for New NAAQS paper provides additional discussion of problems associated with the traditional nonattainment designation process.)

"AOV" is defined as that region which exceeds the ambient air quality standard and thus provides the information on where the population is being exposed to unhealthy air. "AOI" is a specified area containing the set of anthropogenic and nonanthropogenic sources potentially contributing to downwind AOVs. (In the case of localized air quality problems, the AOI and AOV could coincide.)

The process for determining AOIs is discussed in the November 12, 1996 Update on the AOV/AOI Concepts paper and will be examined in greater detail in a forthcoming paper. Furthermore, legal issues regarding the regulatory requirements triggered by a nonattainment designation, such as RFP, sanctions, and control strategies, will be addressed in other issue papers. This paper focuses on the AOV boundaries portion of the proposed process.

As recommended in the Designation Issues for New NAAQS paper, boundaries of AOVs would be based on monitored data or, where available, on a combination of both monitored and modeled data and refined by analytical methods, including modeling, reviewing source and emissions data, and using statistical tools. The paper also indicates that co-AOVs could be delineated where overlapping PM-fine and ozone AOVs occur.

AOV boundaries could be established based on monitoring data, emissions, meteorology, modeling results, political boundaries, or statistical techniques. The attached Current Status of Tools/Guidance for Ozone, PM, & Haze document (August 22, 1996) summarizes tools and data which could be utilized in delineating AOVs. (The Current Status of Tools/Guidance document focuses on the overall implementation process, and thus some of the tools may not be useful for the AOV boundary process.) The Conceptual Model (June 14, 1996) also discusses the currently available tools and data.

This paper develops options for the specifics of establishing AOV boundaries.

Issues and Options

Issue:	What is the purpose behind defining AOV boundaries? 1. Count and track where violations occur? 2. Notify people exposed? 3. Setup boundaries to be used for regulatory requirements?

Issue: Given a potential PMfine /PM10 annual standard based on a spatial average, how should PMfine AOV boundaries be determined?

Issue: Given a potential ozone /PMfine 24-hour /PM10 24-hour standard based on measurements at a single monitor, how should ozone AOV boundaries be determined?

Issue: How should PMfine and Ozone co-AOV boundaries be determined?

Attachment

August 22, 1996

Current Status of Tools/Guidance for Ozone, PM, & Haze

The following information is being presented to the National and Regional Strategies Workgroup (NRSWG) members per membership request of a status update on current tools/guidance available or under development for Ozone, PM, & Regional Haze NAAQS programs. The following list of information does not provide information on the availability of the tools/information but rather identifies what tools/information is needed to support the Ozone, PM, & Regional Haze implementation programs. A timeline describing the projected availability of the tools/information may be available for future FACE meetings.

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Plan for emission inventory support to state/local agencies on new ozone and PM SIP applications

Emission Inventory & Factors Group: David Mobley, Group Leader

NRSWG team contact:	Tom Pace

CAVEAT

These are emission inventory and emission factor development steps that will be necessary but are not necessarily planned, funded, or underway.

Development of emission inventory guidance to produce a modeling quality emission inventory for ozone and fine PM.

Pollutant coverage: SO2, NOX, VOC, CO, NH3, PM-2.5, PM-10.

Geographic Extent:	National (lower 48 states) should include annual and daily emission such that different "seasons" can be accommodated.

Available at promulgation

Targeted Emissions Factor Development

Using existing NET to identify source categories, by pollutant, with high uncertainty and high emissions. Develop new/revise EF's for these source categories. Target is to improve EF's for the top 50 percent of emissions. Highest uncertainty currently in PM-2.5 and NH3.

Ongoing: Most significant source categories available 6/30/00

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Tools for implementing any revisions to the ozone and PM ambient air quality networks required as part of the NAAQS review

Monitoring & Quality Assurance Group: John Silvasi, Group Leader

NRSWG team contact:	John Silvasi/Neil Frank

Ozone

1.	If necessary, updated Red Book documentation containing appropriate quality assurance/quality control requirements. OAQPS/ORD document. Should be available 3Q97.

2.	Updated guidance on modifying ozone seasons, as needed. OAPQS document.

Should be available 3Q97.

3.	Updated guidance on siting monitors to measure photochemical oxidants to include consideration for an 8-hour primary, and any secondary ozone NAAQS that may be adopted. OAQPS document. Should also be available 3Q97.

4.	Updated the PAMS guidance document as necessary. Should be available 3Q97.

Note: The ozone NAAQS review would not require any FRM methodology changes, as in the case of a revised PM NAAQS.

PM

The "tools" under development are in terms of guidance and training. The first two categories are being developed by Desert Research Institute (DRI), the third by Washington University.

1)	Guidelines

a) PM Network Design and Siting (draft due Nov 96)

b) Use of PM continuous instrumentation for episode monitoring and PSI reporting(draft due Nov 96)

c) Use of non-reference PM measurements for control strategy development (draft due Nov 97)

2)	Training

a) workshop on implementing new PM monitoring requirements (to include all aspects of PM sampling, analysis, network design, etc.) (draft workshop materials due spring 1997, for execution in late 1997)

3)	Aerosol Data Base Organization - Internet and world wide web based information system to integrate ad hoc PM data bases, including IMPROVE and special study data.(projected date: mid 1997)

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Plan for modeling support to state/local agencies on new Ozone and PM SIP applications

Air Quality Modeling Group:	Joe Tikvart, Group Leader

NRSWG team contact:	Ned Meyer

Assumptions: All models and guidance should be available for public review and comment at the time of the FACE Phase II proposal (i.e., 6/30/98). Support activities and data bases should be available at, and leading up to, the time of promulgation (i.e., 6/30/99). Nonattainment SIP's (Section 172) are due 6/30/02.

Models-3 Applications for Ozone and Particulate Matter

Systems specification and resource requirements*

Computer code*

Preprocessors/Postprocessors*

Users Guides*

Access/Links to system**

Software loaded on State Systems (as requested)**

Training**

Maintenance/technical support of final system**

General Guidance & Supporting Data Base Activities for Ozone & PM SIPs

Guidance on attainment tests*

Guidance on regulatory applications*

Guidance on interpreting model performance*

Peer reviews of models, guidance, and data bases*

Observational model tools & guidance*

Use of PAMS data to support modeling*

Data bases (test data bases at proposal*; complete data bases at promulgation**)

Emissions

Meteorological

Air Quality Data

Fast solvers (models of models for SIP analyses)***

Supplementary Modeling Tools for PM/Visibility

Receptor Models*

Primary PM models for local impacts*

Users Guides*

Guidance on addressing local PM impacts*

Visibility modeling tools*

Guidance on visibility analyses*

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* Needed at proposal

** Needed between proposal and promulgation with continuing support as needed

***Needed within one year after promulgation, but well before SIP analyses are due