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To: Mark Scruggs-STSWG issue lead.

David Sanders-for STSWG

cc: Donna Lamb

From Steve Ziman

I have reviewed the paper, and have comments on it. I have tried to follow

the headings in the paper with respect to my comments.

Comments on Integrated Implementation Issue Paper dated Sept. 19, 1996.

Overall, this draft is much better written than prior drafts. It has taken

material from the overview of the conceptual model by Scheffe and

incorporated it into the text. A major issue that is still not sufficiently

discussed is that there can be different levels of integration, from data

collection to modeling to planning. Depending on how integration is defined,

the concept may or may not be supportable in all situations. Also, without

having available data on much of the nation with respect to particulate

levels, composition and timing of peak concentrations, assumptions are made

about options that may not hold when data and data analysis become

available.

Specific Comments:

I. Introduction:

General Issue Statement: Until data is available to use for data analysis

and modeling, it is not clear that there are common transport mechanisms, or

that the transport is really regional. The review of Robin Dennis RADM

modeling by Vuchovich indicates that high sulfate levels may occur in summer,

but in a different meteorological regime than ozone. Questions have been

raised from OTAG modeling about the extent of regional transport and impacts

for ozone and its precursors. Moreover, until and unless there is a firm

understanding of what is contributing to fine particulate composition for a

specific area, it is not clear that there are a commonality of controls with

respect to ozone. For example, most alkanes less than C-8 do not form

organic aerosols. Yet these are the majority of hydrocarbon fugitive

emissions that are being controlled for ozone. Thus, per the general comment

above, there is need to specify what we mean by integration.

Why Does Integration Make Sense: In the 4th paragraph, the draft urges that

the process start by trying to maximize integration and back off only when

the analyses show it is not possible. This approach makes an assumption that

we should be going in one direction. It is not clear that this approach is a

good use of resources, as it can push for development of a program that upon

review is not necessarily supportable for all or some areas. Again, it is

very necessary to get enough data and do enough data analysis in order to

design a workable program on an area by area basis. A better approach might

well be to opt in to integration, rather than opt out.

With respect to integration of compliance programs (5th paragraph), we still

need to know enough about both ozone formation and fine particulate formation

to understand if there are really common precursors, and that reduction of

these common precursors will be beneficial for both standards. If that is

so, then (for specific area) a common compliance strategy does make sense.

II. Data and Tools Needed to Perform an Integrated Analysis:

The statement in the 1st paragraph noting that data and tools are important

but not a prerequisite for an integrated approach does not appear to be

supported from a technical sense. Based on numerous programs of data

collection, analysis and modeling, one can not make sound decisions with lack

of supportable information. The problems associated with ozone and fine

particulate formation should not be ignored in order to move ahead in a

policy decision process.

II. 1. Monitoring: While it is certainly desirable to try to have an

integrated monitoring network that addresses both compliance and scientific

needs, it is not clear that the same network design will suffice for ozone

and fine particle, or regional haze. Design of an effective network, which

includes precursor and criteria pollutant monitoring as well as

meteorological monitoring has to be based on analysis of existing data as

well as a feedback mechanism to improve the network with availability of new

data. The design could be very different for each pollutant. Again,

integration should be attempted only where there is justification for

efficient use of resources.

II. 2. Modeling: As noted in the comments on the regional haze issue paper,

the state of science is not yet at the place in which there are available

models (and the air quality, emissions inventory and meteorological

data)which have, through thorough evaluation, shown that they are capable of

providing reasonable results. And for situations in which peak ozone, fine

PM and regional haze do not occur concurrently, different data bases will be

needed to use for modeling.

II. 3. Expanded Emissions Inventories: While this states what is desired,

there is need to acknowledge that in order to develop the emissions

inventories to a level of accuracy needed for modeling will require

significant additional work beyond what we now have. This improvement will

not only require large expenditures (in some cases equal to the cost of

collection of air quality data for modeling), but better methodologies than

presently available. For some sources, such as those associated with non

point source emissions-ie. fugitive dust, it may not be worth the resources

to develop an inventory for use in source modeling. However, there will be

need for new, innovative methods for source profiling. Overall, the

inventory task will continue to be the one that presents the most problems.

Options: Overall, the options are too general, and do not recognize some of

the issues described above. There is need for an option that allows for as

much flexibility in addressing the issues and the ability to integrate

approaches to the degree supported by science. Though not a major part of

this paper, it is not clear that the proposed standards and goals are

feasible in terms of ability to achieve. To continue to assume that the

standards can be achieved will lead to policy decisions that may not be

rational.

Option 2 is a one size fits all approach. In some areas, it is very clear

that this approach is inappropriate. And, as noted previously, the

assumptions that underlie the desire for full integration do not hold

throughout the US. Option 4 is the only one that even acknowledges some of

the above issues, and it should be reworded to recognize some of the pressing

technical problems.

Expanded Monitoring Network for PM-fine Ozone and RH, Including Speciation:

PM-fine: Point 5 is questionable in that it assumes that epidemiological

studies will be the basis of determining PM health effects. Also, there may

be an assumption that the present design of epidemiological studies can

provide the needed data. The entire issue of the design and value of

epidemiological studies is a very contentious issue. Given this, a rewrite

of point 5 might be: Where, as applicable, design networks which can also

provide relevant ambient air quality data information on PM and its

precursors, and associated meteorology to support data needs of health

effects researchers

Ozone: It is not clear what point 1 means. One can design and implement a

monitoring network for tracking both ozone and its precursors. The issue in

design of the network, aside from instrument selection, is how long does one

have to monitor to detect signal from noise; and to detect a trend?

Depending on the network design, results could take over 5 years (based on

some analyses of this issue that have been published in the literature).

Expanded capability to do integrated modeling:

It is not clear what point 1 means. I have no suggestions in that I just

don t understand the point. With respect to point 3, while it is clear that

there is definite need to evaluate the aerosol module of any model, there is

still a need to make sure that the chemistry is working etc. That is, the

ozone model better be good, since it provides the gaseous species

concentrations that are then used as input to the aerosol module.

As a very major omission, there is no discussion about need for data

analysis. This is very important in that it provides an independent

assessment of our understanding of ozone and PM formation, and also a basis

to test model results against. No program should only depend on modeling for

information!!!!

III. Assessment of Potential Integrated Controls.

Most of this is policy. However, until there is sufficient data available,

assumptions about existing source controls being beneficial for addressing

fine particles and visibility is questionable for some of the organic

aerosols for reasons stated previously. Also, since regional haze is so

dependent on the size of the particle, with sub micron particles being most

important, controls for ozone and PM may be sufficient to show progress for

those two pollutants, but not to make significant difference for visibility

improvement.

With respect to the options, options 2 and 3 probably are not reasonable in

light of need to develop sufficient information on multimedia pollutant

effects to a degree that a reasonable calculation of benefits could be made.

There is also another option that should be considered from a technical

perspective. That would be one in which the benefits and adverse effects of

the ozone and PM criteria pollutants are determined, and provide input to

discuss (as appropriate) derived benefits for regional haze. This recognizes

that the first two are criteria health based standards, and regional haze

improvement is a goal.

Cost of Controls: From a technical view point, costs can be better

understood on a $ per improvement basis. The improvement can be air quality,

population exposure, or some other metric. Use of $ per ton does not provide

as much information by which to rank different controls.

If there are questions about these comments, please call, e-mail or fax:

510-242-1530-phone

510-242-5947-fax

sdzi@chevron.com

Steve Ziman

11/5/96