This is a preliminary summary. It has been placed on the bulletin board for comments and corrections by the Base Programs Analyses and Policies Work Group members. When their review is complete and this summary is in final form, this warning will be removed.

April 4, 1996

Summary

March 20, 1996 Base Programs Analyses and Policies Work Group	Meeting Alexandria, Virginia

I.	OVERVIEW

The work group met on March 20, 1996 in Alexandria, Virginia. Four presentations followed opening remarks and introductions targeted to member' responses to the work group questionaire. Members then discussed the interim implementation transition policy.

II.	PARTICIPANTS

Work group:

Joe Paisie-Chair, Jerry Golden-Chair, David Baron, Vincent Brisini, Glen Cass, John Crouch, Gregory Dana, Richard Dworek, Steve Gerritson, George Lauer (for Greg Schaefer), Dennis Lawler, Arthur Lee, Chung Liu (for Mel Zeldin), Arthur Marin (for Jim Ralston), Brock Nicholson, Bob Palzer, Steve Pezda, Richard Phelps, Jim Salvaggio, Conrad Schneider, Eric Skelton, Jean Vernet, and Herb Williams.

EPA members and staff:

Sharon Reinders-Team Lead, Howard Hoffman, Mark Kataoka, Ned Meyer, Bruce Polkowsky, Callie Videtich

Others:

Chuck Mueller, David Chock, Tanya Peacock, Dennis Drake, and Cindy Langworthy. Beth Friedman, EC/R, Incorporated (EPA Contractor Support)

Work group members not in attendance:

Jeff Gabriel, Rich Halvey, and Don Pickrell

III.	ACTION ITEMS

1) The next conference call will be on April 3, 1996 from 11:00 a.m. to 12:30 p.m. eastern. The call-in number is 202/260-7280, access code 3818#. Issue Papers 1(a) and 1(b) will be discussed.

2) The EPA will distribute copies of the Glen Cass presentation to work group members.

IV.	MEETING SUMMARY

Information Update

Robert Kappelmann, representing the Jacksonville Electric Authority, has been added to the work group to maintain the balance of interests among members because Jerry Golden determined that he would be unable to fully represent the utilities' interests while serving as co-chair.

All of the (phase I) issue papers have been claimed for development except for issue 1.d, "To what extent should the boundaries of the NAAQS nonattainment areas and regional haze planning areas coincide?" Issues 1.a and 1.b will be discussed at the April 3 teleconference.

Communication Issues

1)	The EPA is establishing locations for the FACA work groups' use on the EPA Technology Transfer Network (TTN) bulletin board. Members were asked to consider whether they want access to other groups bulletin board locations and whether to allow access to the Base Programs location.

2)	EPA will set up more lines for future conference calls so more people in different locations can listen in. People at the same location should still use a single line.

3)	A state representative requested the agenda be structured to allow more time for discussion of individual issues.

4)	One member stressed the need for adequate time to review issue papers before they are discussed at a conference call.

Presentation 1. Atmospheric Process and Diffusion Ozone Modeling for Current and Potential New Ozone NAAQS

Ned Meyer, EPA, gave a presentation summarizing a report showing broad modeling and monitoring findings pertaining to implementation of the ozone NAAQS. (Copies of this report were distributed at the meeting.) The report suggests regional transport is likely to be an important component of problems that may occur in meeting new NAAQS for ozone and fine particulates, as well as in meeting goals established for regional visibility. He summarized the following broad trends in ozone as follows:

1)	Ozone levels have been approaching or exceeding the level of the standard (0.12 ppm) in the eastern United States since the 1980's.

2)	The role of biogenics has been increasingly appreciated since the 1980's.

3)	Ozone transport has been observed in large portions of California.

4)	The OTAG survey concludes regional ozone transport is very important in the east.

He noted that there are 5 key implementation hypotheses to an ozone program.

1)	Urban VOC control effectiveness at reducing ozone is present in and immediately downwind of urban areas.

2)	Regional VOC control may be effective in reducing ozone on an urban scale, but is less effective regionally.

3)	Regional NOx control may be effective in reducing regional ozone.

4)	Urban NOx control may increase peak ozone locally, but reduce ozone further downwind regionally.

5)	Urban VOC control and regional NOx control may be the most effective combination of strategies.

He presented results of a review of 1991 to 1993 monitored ozone data relative to alternative under consideration for a potential new primary ozone NAAQS. The first slide was an assessment of how many counties contain one or more monitors at which the potential NAAQS would not be met. One conclusion is that a NAAQS reflecting a level of ozone in the 0.08 ppm range would likely make the problem of meeting the ozone NAAQS more widespread than is currently the case. The second table compared the estimated number of nonattainment areas likely under two potential NAAQS scenarios. Again, the conclusion is that the number of areas not meeting the NAAQS would increase with a change in the NAAQS.

The next table showed a comparison of design values for various locations in "severe/extreme" areas and "marginal" areas. The comparison shows that there is a smaller difference in design values between severe/extreme areas and marginal areas under an 8-hour NAAQS than under the current 1-hour NAAQS. He noted that these findings have implications for any policy that attempts to distinguish control requirements on the basis of classifications of severity of measured air quality levels. Instead, additional or other air quality indicators may be needed to implement an 8-hour NAAQS. A question was asked whether EPA has looked at the data from the perspective of the exposed population. Mr. Meyer said this has not been done, but that it would be possible to do so.

He then presented the results of applying the Regional Oxidant Model (ROM) to a 3-month period using 1987 meteorological conditions. The study simulated the effects of mandatory Clean Air Act requirements, population growth to 2007, and additional NOx control measures rising from the Memorandum of Understanding (MOU) and low emitting vehicles in the Northeast Transport Region. Data were presented showing a substantial reduction of emissions as a result of this set of controls. The ROM model was then used to evaluate the effects on nonattainment using an 8-hour, 5 exceedances of 0.08 ppm. The results show that, in general, many more areas would be considered as not meeting this NAAQS in 2007. However, the ROM model has a tendency to overpredict daily exceedances. He noted that results should not be taken literally, but used to illustrate trends. In general, both modeling and monitoring data suggest large geographic areas may have difficulty attaining a revised NAAQS. (Copies of these slides will be mailed to work group members under separate cover.)

Presentation 2. Particulate Matter Transport and Regional Haze

Glen Cass, Caltech, gave a presentation on the effects of particulate matter transport and regional haze. (Copies of his slides will be mailed to work group members under separate cover.) He started the presentation by noting that fine particulates have the same wavelengths as visible radiation, which is why they are of concern in any regional haze program. He described a study using data collected with ambient fine particle samplers. These samplers are equipped with multiple filters to allow the collection of the range of fine particle types, and they provide samples that are nearly complete material balances.

Ten components compose virtually all of the mass of fine PM all over the world. Only the proportions of these compounds differ. The major components of fine PM are organic carbon, elemental carbon (e.g., diesel engines), nitrate ion, sulfate, ammonium ion, crustal and trace elements (e.g., road dust), and other (7.2% in the California samples). The organic carbon fraction can be further resolved (alkanes, N-alkanic acids, etc.), and used to determine which organic compounds are gas conversion products and which are emitted directly by sources. Using the composition data, one can develop estimates of the origins of the PM.

It is also possible to measure PM emissions at the source. A major difficulty in this approach is that organic vapors will form particulates as the plume cools in the atmosphere. However, the organic vapors are still in the gas phase at stack temperatures. To overcome this difficulty, the samplers used a dilution source sampling train to simulate the cooling and dilution process. Samples were also collected from sources such as natural gas home appliances, brake dust, tire dust, and cigarette smoke) comprising approximately 80 percent of the organic aerosol contribution to the atmosphere. The resulting data were used to develop PM10 and PM2.5 emission inventories. According to the inventories, particle sizes vary the most for fugitive dust sources, which are largely composed of PM10. In contrast, the distribution of PM10 versus PM2.5 for mobile sources is largely identical. In general, the larger particles are mostly crustal in origin, while the smaller particles are largely organic and elemental carbon.

A complete inventory would contain gaseous PM precursors, i.e., SO2, NOx, and VOC.

There are two ways to relate emissions to air quality. The first is to construct models for transport and atmospheric chemistry reactions leading to a mechanistic, elaborate material balance. The second way is to use chemical tracer models, and work backwards from an atmospheric sample to precursors. A transport approach includes an emissions model containing aerosol size distributions, aerosol size chemical compositions, and speciated gas phase emissions. Other models include a transport reaction model containing gas phase chemistry and secondary aerosol formation and a light scattering and adsorption model. Caltech has compared the predictions of their transport model to emissions data, size distribution data, and light scattering data. In all cases, the model was a reasonable predictor. Another technique is to digitize a photograph, and then use the model to predict how that photograph would appear under certain PM conditions.

In a molecular tracer approach, the key is to select unique chemical tracers that are representative of individual sources and that are stable chemically from the source to the receptor. Once the markers are identified in an individual sample, it is possible to back calculate what sources contributed to emissions. Using this approach, in 1982, it appeared that the largest contributors of PM were primary sources such as diesel engines, road dust, and gasoline vehicles. In the 1990's, most PM is secondary in origin. At this point there was a discussion of differences between the Caltech inventory and California's inventory. Mr. Cass noted no adjustments were made for the motor vehicle component and that Caltech's overall emission estimate is much smaller than the State's. He added, for secondary sources, Caltech used the State's SO2 and NOx inventories. VOC was scaled up to account for additional motor vehicle emissions. In response to a question, Mr. Cass said the model could be reprogrammed to look at control strategies.

One member asked if Mr. Cass had any information on the fraction of secondarily formed aerosols in the East. Mr. Cass referred to the NAS report. (Relevant portions of this report will be mailed to work group members under separate cover.) In that report, approximately half of the fine particles are sulfate aerosols, most of which are secondarily formed. However, the eastern U.S. is deficient in fine particulate data and in urban aerosol data. Any program should look at chemical composition data in addition to mass data.

In response to another question, Mr. Cass said there were surprisingly similar measurements between the 1982 and 1990's data sets. He speculated that the increased prevalence of controls was offset by population growth.

One member observed that the 1982 data set is mostly primary in origin. In 1987, secondary organics are also relatively small. However, on a "bad high chemical day", secondary aerosols could be very high. Mr. Cass agreed the annual basis differs from a specific day.

Finally, one member asked which strategy, the transport model or tracer method, is better. Mr. Cass suggested the transport model could only be applied in California at the present time, because only California has the data to support the model. In other areas of the country, a good strategy would be to use the tracer approach initially, and then upgrade inputs so that the transport approach could be used eventually.

Presentation 3. Visibility Programmatic Elements

Bruce Polkowsky, EPA, summarized visibility program requirements of the Clean Air Act (Act). According to section 169A(a)(2)(3), the Administrator is required complete, within 18 months of promulgation, a study and report to Congress on available methods for preventing future and remedying existing impairment in class I Federal areas. Within 24 months of enactment, the Administrator shall promulgate regulations ensuring reasonable progress. Upon promulgation of section 169A regulations, the states are required to revise within 12 months their state implementation plans (SIPs) to contain emission limits, schedules of compliance, and other measures necessary to carry out the Federal regulations.

The Act requires the imposition of best available retrofit technology (BART) on major sources that began operating between 1966 and 1977. The SIP's must also include a long-term strategy for making reasonable further progress. Both BART and reasonable further progress must take into account costs of compliance, energy and non-air quality impacts, and the remaining useful life of the source. In addition, BART must be developed considering existing pollution controls, and the degree of improvement in visibility.

Key elements to consider when developing a regional haze program include regional planning areas, including coordination with ozone and PM areas; the definition of reasonable progress, e.g., specifying the amount of improvement of a specific criteria over a given amount of time and/or the reduction of dirty days while protecting clean days; monitoring programs; elements of a reasonable progress demonstration; the role of BART; technical tools such as regional air quality models and transfer coefficients, emissions inventories and tracking, integrated assessment models, and future growth projections; and the consequences of a failure to demonstrate progress.

One member asked how good are the planning tools and models. Mr. Polkowsky said, while the models are not perfect, they can make a good first step. Program designers should consider the effects of other air programs (e.g., Title IV) in their planning. The final program should be designed such that the requirements match the ability of the tools.

Another member asked what the rule would look like. Mr. Polkowsky said Grand Canyon Visibility Transport Commission modeled 8 States plus Mexico. Visibility concerns alone might not be strong enough to require additional regional planning, even though the problem can only be truly addressed on a regional basis. A fine PM standard due to health effects may drive the EPA toward increased regional planning.

One member noted TVA had reduced sulfate emissions 50 percent over the last ten years, and yet, visibility in the Smokies has worsened over that time. Mr. Polkowsky said other factors such as regional budgets and the timeframe of the reductions must be considered.

One member said other projections show the full implementation of Title IV will only result in 2 to 3 miles of improvement. In contrast, Mr. Polkowsky thought the improvement should be considered substantial.

Presentation 4. Clean Air Act Tools for Interstate Transport

Substituting for Kevin McLean, Howard Hoffman, OGC, summarized the ozone transport tools in the Clean Air Act. Some of the tools are focused on the states. For example, section 110(a)(2)(D) says the SIP must include provisions prohibiting sources or other emissions activity from contributing significantly to nonattainment in, or interfere with maintenance by, any other State with respect to any primary or secondary NAAQS. Further, the section prohibits interference with measures required to be included in the applicable implementation plan for any other State to prevent significant deterioration of air quality or to protect visibility

Two issues are raised by this language. The first issue is the definition of "contributing significantly," and the second is how to ensure these SIP provisions are consistent with other provisions of the Act. An ozone example of the difficulty of the latter is seen in a severe area upwind of a marginal area, which marginal area is required to come into compliance earlier than the severe area. Should the severe area install controls so the marginal area comes into attainment by the statutory deadline (1993), or should the severe area have until its attainment date (2003) to take measures to ensure the marginal area's attainment?

The EPA has not developed any numerical definition of what constitutes a significant contribution. Such a definition may not be possible. For example, several upwind areas could contribute to a downwind area, and the downwind area itself may contribute to its own nonattainment or visibility status. In such a case, determining who is contributing significantly may not be possible.

The EPA's responsibility is to issue a SIP call under section 110 if the State is not meeting its obligations to control its sources. In the case of transport issues, EPA could issue a SIP call to the upwind State. If the SIP call does not produce satisfactory results, EPA would issue a Federal Implementation Plan (FIP).

The second major tool in the Act is found in section 126(b), which says "Any State or political subdivision may petition the Administrator for a finding that any major source or group of stationary sources emits or would emit any air pollutant in violation of the prohibition of section 110(a)(2)(D)(ii). Within 60 days after receipt of any petition under this subsection and after public hearing, the Administrator shall make such a finding or deny the petition." This provision is focused on the source, and it is limited to area and major stationary sources. If EPA makes a finding under this provision, it can revoke the source's permit or refuse to grant a permit to construct unless the source uses/installs EPA-mandated controls. Once again, the test is "contributing significantly." The EPA has received several petitions, but has never made a finding against a source.

The third major ozone transport tool relates to interstate transport commissions. Sections 176A and 184 of the Act provide for the establishment of interstate transport commissions in general, and specifically establish the Northeast Transport Region. Each state within the transport region is required to implement enhanced vehicle inspection and maintenance programs and VOC RACT controls. The Transport Commission can also recommend other controls. The test in this case is whether the standards are necessary for the other States to attain the NAAQS. The EPA must review and approve the Commission's recommendations. If the EPA finds that the recommendations are inadequate, EPA will issue a SIP call.

One member noted the first two remedies have never been used, and the only remedy seems to be in the courts. Mr. Hoffman said there is a political process to develop consensus, but if this process fails, resolution in the courts is likely. Joe Paisie noted his experience in Chicago, where several section 126 petitions were filed. All of the petitions were denied, and EPA was sued and subsequently upheld. In each case, EPA had supported the upwind source.

One member asked if EPA had plans to establish rules in the SIP requirements regarding regional haze to address uncertainties such as the definition of "contributes significantly" in order to require the States to be more precise. Joe Paisie said this is the purpose of the FACA process, and it will be considered by the regional haze work group. Howard Hoffman added that EPA probably would not establish a specific numerical definition. Instead, EPA would like to develop a consensus on what constitutes a reasonable control strategy.

One member asked if Congress made any changes in the 1990 Act's amendments to address the power of sections 110 and 126. Howard Hoffman said the provisions were expanded in 1990. The pre-1990 standard of the upwind area's responsibility relied on an "interference" standard. With the amendments, this test was sharpened to a "contributes significantly" standard. Also, sources that could be targets were expanded from a "group of sources" to "any emission activity." Section 126 was expanded from targeting major sources alone to all stationary sources.

One member asked how Tribal lands fit into the transport tools. Another member noted EPA is in the process of proposing provisions to treat the tribes as States. However, this rule is complicated by considerations of Indian law, Supreme Court law, etc., and it is very controversial.

Sharon Reinders said another transport tool is found in section 107 of the Act, which provides for the establishment of nonattainment areas if they are found to contribute to the ambient air quality in nearby areas that do not meet the NAAQS. Howard Hoffman said that historically this provision is viewed narrowly. That is, if an area contributes to the nonattainment status of an area a couple of hundred miles away, it would probably not be considered to be nonattainment.

One member asked about transboundary limitations. Howard Hoffman said the Act provides for study provisions for transnational pollution problems as well as relief provisions. For example, El Paso, Texas, has been relieved of requirements to demonstrate attainment because of transported pollution from Mexico. One member asked if Canada and Mexico can act against the U.S. Mr. Hoffman replied action is not possible under the Act, but it would be under NAFTA.

Interim Implementation Transition Policy

Jerry Golden said the Steering Committee will be discussing the interim implementation transition policy. He asked the base programs work group if there was consensus on the basic principles that he could carry forward. He summarized the principles as follows:

1)	The policy should emphasize "no backsliding";

2)	During the transition period, a cost/benefit analysis should be applied to new programs;

3)	New programs should be evaluated with respect to exposure levels; and

4)	The policy should provide flexibility for options that are put in place. There should be no absolute mandate to keep every program in place.

A general discussion of the definition of "backsliding" followed. One member said the policy should continue programs to achieve public health and welfare. Another member gave an example of how the appearance of backsliding could occur. In the shift to a PM2.5 standard, mass reductions could be lower under the PM2.5 scenario than under the PM10 scenario. The source could be meeting the final PM2.5 goal, but perceived as backsliding with respect to the PM10 standard. Another member noted the PM10 program could be mistakenly focused on fugitive dust, which would be less of an emphasis in a PM2.5 program.

Glen Cass noted there is no discussion of the eventual goal of the transition policy, which makes it hard to design the transition policy. Jerry Golden asked how much this uncertainty affects current efforts such as data collection and model building. One member noted the above principles should be viewed as insurance. If the group is comfortable that the policy is headed in the right direction, there will be room to be creative in designing the next steps.

One member said he wants to ensure the program is not focused on the wrong pollutant. Another member said EPA is not planning to drop the PM10 standard, and the major difference in the ozone standard is the averaging time (8 hours vs. 1 hour).

One member said, from a regulatory agency perspective, the "no backsliding" concept is insufficient. If the control program is in the SIP, they want to be able to use that program until there is a new SIP. It does not make sense to stop progress every time there is a new standard. Jerry Golden said new initiatives should be held to a cost effectiveness (or cost/benefit or exposure/risk) test to make sure they are appropriate in light of the revision. For example, an area that is nonattainment under a 1-hour ozone standard might be in attainment under an 8-hour standard. In this case, additional programs under the 1-hour standard might not make sense. The key is defining the starting point and using the right models.

One member noted the use of the term "transition" may be confusing. He said EPA should hold its position until the requirements of a new standard are understood. Where there are elements in an existing program that do not make sense under the new standard, the burden should be on states to make a finding that SIP adjustments are justified.