From:	Ziman, Steve - <SDZI@chevron.com>

To:	RTP3.RTMU540(sanders-dave),RTPMAINHUB.INTERNET("mo...

Date:	9/27/96 5:02pm

Subject:	comments on reg.haze paper

FROM: Ziman, Steve -SDZI

DATE: 09/27/96 13:55

TO: OPEN ADDRESSING SERVI-OPENADDR

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SUBJECT: comments on reg.haze paper

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FORWARDED FROM: Ziman, Steve -SDZI

FROM: Ziman, Steve -SDZI

DATE: 09/27/96 12:45

TO: OPEN ADDRESSING SERVI-OPENADDR

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SUBJECT: comments on reg.haze paper

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Tom:

I have looked at your list of technical areas. I think you have identified a significant amount of information needs that are presently not available now, but must be available in order to even make cogent policy statements. As I have previously indicated, the conceptual frame work laid out here essentially makes a number of assumptions that may not be consistent with the data. Because the devil is in the details, many of the options may not be appropriate as more understanding is provided. I would suggest that it may be useful to rephrase the needs as you have put them into a slightly different order, one that reflects the timing of the needs:

1. Data Collection

a: Major improvements in inventories specifically for with respect to primary or secondary precursors for PM 2.5. These inventories are now in a state of flux, and very questionable. In particular, for mobile sources, the mobile source inventory (Mobile 5 or California s EMFAC ) do not address this sufficiently, and do not fully address even the VOC component for ozone.

Stationary sources are similar. As noted, there are no ammonia inventories in existence except for Los Angeles. This is a very important issue, especially if there are questions of what is the limiting agent in aerosol formation, and also in the competition among the sulfate versus nitrate.

With respect to primary emissions, especially the fugitive dust categories, the cost of even attempting to develop a source oriented inventory (versus a receptor approach) is not realistic.

b. Though regional haze can occur throughout the year, it is probably a episodic type of thing in that it is meteorologically driven. Thus, it is important that any visibility measurements and ambient measurements be done daily rather than every 6 days if we are to be able to understand what is occurring. This is true both for data analysis and any attempt at modeling.

This is extremely important in order to understand the spatial scope of any regional haze problem. And it must be done at many different areas in order to understand if integration or any of the choices in the options part of the paper are national or regional or sub regional in scope , as well as part of an integrated approach

c. Data Analysis: In order to even understand some of the basis issues, there is need to carry out data analysis to provide model independent answers. Only with a well thought out data analysis program do we know what is raised in b. above

d. Modeling: In order to have a reasonable mechanism to relate precursor reduction to fine particle reduction, and hence scattering and adsorption, source oriented modeling will probably be the only acceptable mechanism. And in order to deal with regional issues, a lagrangian approach will not be suitable for reactive species as the plumes are not additive. This would seem to dictate a eularian approach. As has been previously be stressed, to date there has been no real work aimed at designing a collection program for a data set suitable for evaluation of the particle forming module of these types of models. Obviously, that extends to the visibility portion as well.

Without this information, it is not clear to me that one can make any recommendations on goals, timing , targets or control or cap approaches. To do so is to not understand the ramification of each of the options in terms of the type, amount, and cost of emissions reductions relative to any goal.

Though noted in the historical section of this issue paper, there was an EPA report on the improvement in Class I area associated with other CAA mandated requirements, there is no discussion of that report and its findings, or whether the

report was well done or flawed. This information is needed as well.

Going from a technical comment to a policy one, it is difficult to understand how

any options can be selected until or unless we know if the goals and objective of the regional haze program are going to supersede any efforts needed to attain the two criteria standards that are part of the FACA. If, as suggested by an SAI study done during the GCYTC study, only very

small improvement in visibility will be achieved if Los Angeles were to meet all applicable Titles I-III requirements, than different factions of the FACA will have very different and strong opinions on the options. Similarly, if the regional haze issue is national in scope, many communities that now do not

have to make reductions will have to consider what needs to be done. This could also affect any decisions on the options.

The bottom line is that it is difficult to make any decisions on options when lacking knowledge of what those options mean

Steve Ziman

cc: D. Sanders-please send to Tom by e-mail as at this point I don't have his. I'll fax to him, but it helps to have in electronic format