Draft Summary of the Federal Advisory Committee Act (FACA)

Science and Technical Support Work Group Meeting

Mutual Building, Tom Helms' Office

February 11, 1997

Durham, North Carolina

The Science and Technical Support Work Group (STSWG) of the FACA Subcommittee met on Tuesday, February 11, 1997 in Durham, North Carolina. A list of the participants and a summary of the meeting follows.

Work Group Participants

Name	Affiliation

Harvey Jeffries, Co-Chair	University of North Carolina-Chapel Hill

Diana Andrews	Kentucky DEP

John Cabaniss	AIAM

David Chock	Ford Motor Company

Cyril Durrenberger	TNRCC

Tom Moore	Arizona

Leon Outlaw (for Jay Hudson)	Santee Cooper

Steve Porter (for S.T. Rao)	N.Y. Department of Environmental Conservation

Jay Turner	DOT

Work Group Members Not Participating

Tom Helms, Co-Chair	U.S. EPA

Glenn Cass	Cal Tech

Kirit Chaudhari	Virginia DEQ

John Core	WESTAR

Ellis Cowling	SOS

Bruce Hill	Appalachian Mountain Club

David Kelly	Navajo EPA

Dave McNeil	Utah DEQ

Rich Poirot	Vermont

Jay Rosenthal	Navy

Mark Scruggs	DOI

Manop Vanichchagorn	Louisiana DEQ

Dan Weiss	Cinergy Corporation

Jeffrey West	GPU Services Corp.

Steve Ziman	Chevron Corporation

Non-Work Group Participants

Bob Wayland, SAIC; Christine Hawk, U.S. EPA/OMS; Ellen Baldridge and Tom Braverman, U.S. EPA/AQMG; Robin Dunkins and Charlene Spells, U.S. EPA/IPSG; Bill Kuykendal, U.S. EPA/EIFG; Nancy Mayer, U.S. EPA/ISEG; JoAnn Allman, David Sanders, and John Silvasi, U.S. EPA/OPSG.

Summary of the Meeting

Conceptual Model Discussion

Harvey Jeffries opened the meeting with a discussion of the status of the Conceptual Model. Mr. Jeffries indicated that he was having second thoughts regarding the current status of Chapter 5. He stated that he believed that S.T. Rao's comments were right on target, and that David Chock agreed with this position. Mr. Jeffries suggested that we adopt David Chock's suggestion to drop Chapter 5 from the current version of the document, until after our workshop on source attribution. Mr. Jeffries then asked Steve Porter if this approach would acceptable to the S.T. Rao group?

Steve Porter responded "yes", that this would address their concerns.

Tom Moore also agreed with this approach.

John Silvasi questioned if we should include a note in the current document to indicate that we are waiting on the outcome of the Source Attribution Work Shop to finalize our conclusions on this material?

Harvey Jeffries agreed that this would be appropriate.

David Sanders indicated that he would be interested in reversing sections 3.a and 3.b in the current document.

Harvey Jeffries said that this would be a reasonable assumption, based on the diagram I have provided for the cover/Executive Summary.

Diana Andrews questioned if it would be possible to correct Chapter 4 before we release the document to the Subcommittee?

David Sanders suggested that he would work with the contractor to make the necessary changes.

Tom Moore volunteered to provide some material on PM monitoring to the contractor for inclusion in the final version of the document.

RAMP/AOI Summary from 1/30 - 1/31/97 Meeting

Harvey Jeffries now moved to a discussion of the joint face-to-face meetings held on January 30/31, 1997 between the STSWG, National and Regional Strategies Work Group (NRSWG) and the Base Program Analysis and Policies (BPAP) Work Group. Harvey Jeffries indicated that the group met on the second day of the meeting with the individual Work Groups and discussed the individual Issue Papers in great detail. In his opinion, STSWG was able to make significant contributions to both the BPAP and NRSWG discussions. The outcome of these discussions was the following definition for a Regional Air Management Partnership (RAMP):

Five Step Process in establishing a RAMP

-	identified ASAP; the process is a combination of technical and political concepts

-	early procedures to identify preliminary AOIs

-	identification of preliminary AOIs

-	preparation of a Regional Implementation Plan (RIP)

-	SIP/TIP Preparation

Additionally, Mr. Jeffries discussed the Source Attribution Modeling Conference, which is basically an attempt to address transport-related issues. OAQPS has a need to do this, and Ned Meyer is taking the lead on this. There are a number of techniques emerging from different companies, which are currently being discussed in a number of different venues (i.e. OTAG). ORD also has a need to investigate these different tools, and perform some degree of evaluation of these different tools. Thus, STSWG has an opportunity to participate in this effort.

Harvey Jeffries also indicated that Dan Weiss and others have asked for presentation time at the February 19, 1997 face-to-face Work Group meeting. However, following the discussions last week in Durham, Tom Helms and I have decided that the Work Group's interests would be best served by spending this time next Wednesday to iron-out the basics for the Source Attribution Workshop, rather than hearing additional tools presented to the Work Group. Mr. Jeffries indicated that he had the opportunity to review some preliminary information from Ned Meyer and Ken Schere. Currently, this information appears to be more formal than Mr. Jeffries had originally thought. Therefore, Harvey Jeffries asked each Work Group member to come to the meeting with at least a strawman of what he/she would like to see accomplished at this workshop.

John Cabaniss responded that it occurred to him from the presentations and the discussions, that if you really did a scientific approach to the AOI issue, and looked at each AOV and tried to determine the constraints on the individual AOIs, it would lead to better definition of the RAMPs. Particularly in the east, where there is a lot of overlap, this procedure could be difficult to implement. The question becomes whether you start large and then go smaller; or vice versa - e.g. start small and then build-up.

Harvey Jeffries responded that this is why we are trying to have the workshop, to address these very issues. There are new techniques available to do some of these things, and we simply need to get them out into the open and discuss them critically.

John Cabaniss added that the scientific approach to RAMP is the significant difference between ozone and particulates, irrespective of the haze issue.

Mr. Jeffries responded that it is clear that the RAMP is supposed to be inclusive for all three of these. Basically, this is what Don Theiler wrote: "The formation of RAMPs will be undertaken by combining political and technical considerations for regions having like air quality situations."

Tom Moore responded that the other Work Groups have no interest in learning anything about this. Their current approach is basically, we have heard your complaints, and we are going to make the science fit the policy. We are going to make these decisions on a policy-based perspective.

John Cabaniss voiced agreement with Tom Moore, saying that the bottom line is that the Work Groups are going to end-up with whatever methodology is politically expedient.

Harvey Jeffries stated that he had no intention of the STSWG working with EPA to draw maps for RAMPs and AOIs. He reminded the group that we are charged to provide information on the tools and allow EPA to actually "make the lines."

John Silvasi reminded the Work Group that the Agency is facing some pretty stringent deadlines. Mr. Silvasi indicated that EPA needs some answers, and we needs them relatively quickly. On the other hand, EPA is not asking you to work for nothing. EPA acknowledges that the individual Work Group members have contributed a great deal of information, time and dollars to this entire FACA process, and the Agency definitely appreciates your efforts.

Harvey Jeffries stated that after thinking on the subject, that he was not that up-tight on Don Theiler's definition of a RAMP.

Ellen Baldridge asked if she could clarify STSWG's role in this process. Ms. Baldridge stated EPA simply want STSWG to evaluate the tools, not actually draw the lines. It would be helpful to know what the appropriate tools are, and how we use them to draw the lines.

Harvey Jeffries responded to Ms. Baldridge saying that his problems are in part with the composition of the STSWG. Secondly, STSWG is not really in the game of picking and choosing among the tools that are out there. We are not positioned to pick one model over another. This is the reason for the Source Attribution Workshop in April. Thus, Mr. Jeffries indicated that he was interested in spending time next Wednesday afternoon to define the workshop and put together the necessary people at the table for the workshop. He said that STSWG members are simply not informed well enough to make absolute recommendations to EPA on the use/non-use of the specific tools which are out there. The tools simply have not been around long enough to make these determinations.

John Silvasi questioned if the purpose of the workshop was for AOI determination, or RAMP determination?

Harvey Jeffries replied saying that the RAMP is close enough to the AOI that you cannot actually separate the two.

Leon Outlaw asked Mr. Jeffries exactly what is the differentiation between the RAMP and the AOI?

Harvey Jeffries answered saying, a RAMP is simply an attempt to have a AQCR larger than an individual state, to implement the planning process. To the extent that a state can solve its problems internally, it does not have to play in a RAMP. A RAMP is only involved when there are contributions between different states. The actual AOI analysis may be different than the actual RAMP - it doesn't have to be, but it most likely will be. In his opinion, the RAMP determination is not that big of a deal - you only have to get them close. However, the identification of a AOI is a big deal, and does require some detailed technical analyses.

Tom Moore voiced his agreement with Harvey Jeffries, stating that he agreed that the modeling, how to use the results, and data analysis is the key to defining the AOI. However, developing control strategies is the key to finishing the AOI issue. Mr. Moore indicated that all states and tribes who want to participate in a RAMP must do some basic, underlying things in order to participate. The modeling should be held-off until such time that all participants are on a level playing field.

Harvey Jeffries asked Tom Moore if he could develop a strawman for next week's meeting?

Tom Moore responded that he would be glad to tackle this issue.

Ellen Baldridge asked if we have a RAMP that identifies the states that are going to work together, and you have nonattainment areas, how do you work this legally?

Harvey Jeffries responded that Don Theiler's paper makes it very clear; you cannot associate and AOI with a nonattainment area.

Ms. Baldridge asked if you are using the CAA, how do you do it?

Diana Andrews suggested the group would someone from Office of General Counsel (OGC) to discuss this with us.

David Sanders reminded the Work Group members that we had strayed too far from the agenda and asked that we re-focus the discussion. Mr. Sanders suggested that we move on to discussing Ned Meyer's workshop.

Source Attribution Workshop

Ned Meyer begin this discussion by stating that Harvey Jeffries's suggestion to have the workshop sooner is problematic, because it will take time to get all the participants lined-up, and then get all the paid reviewers together. Thus, Mr. Meyer indicated that AQMG is looking at the later part of April, and the early part of May. He stated that he did not think that this is too late for the purpose of having this workshop.

Harvey Jeffries asked Ned Meyer to recall their conversation on the afternoon of Friday, January 31, 1997. Mr. Jeffries stated that in that conversation, he conveyed the thought the field is too premature to hold such a formal review of this information and doing so will mandate that you lose some of the key presenters at this workshop. Mr. Jeffries indicated that the scientific community is simply not that far along at this stage in the ball game. He suggested that if the process was not so formal/rigid up-front, that you could get a great deal more information.

Ned Meyer indicated that he was perfectly willing to listen to your suggestions next week at the face-to-face meeting.

Harvey Jeffries indicated that success for next week's meeting would be to hold a discussion to identify the types of information that we need to gather; not specifically reviewing the individual tools. He said that we would need a long period during which to lay out all of these ideas. Mr. Jeffries reminded Ned Meyer that he was on the agenda for next Wednesday afternoon, and that STSWG was planning to have a fairly focused discussion on how we address the issues discussed in Don Theiler's paper. He asked Mr. Meyer if this was on target?

Ned Meyer stated that EPA was going to have another go around internally tomorrow, and he could better answer that question then.

Tom Moore questioned if we could see this strawman proposal for the Workshop prior to next week's meeting?

David Sanders replied that he would get this information to everyone.

Ned Meyer asked Mr. Sanders to wait until after the internal tomorrow to distribute anything, because the agenda may change based on these internal discussions tomorrow.

David Sanders concurred, and asked Ned Meyer to provide him with updated materials after the close of the internal meeting.

Tom Moore also encouraged all the Work Group participants to arrive next Wednesday with their own strawman proposals, and bring an open mind, and be willing to put our heads together and work toward consensus.

Harvey Jeffries stated that we needed to make certain that the particulate matter (PM) people from the Grand Canyon Visibility Transport Commission (GCVTC) get equal credit in this meeting next week.

Tom Moore replied that he would not let this slip through the cracks.

Issue Papers

Matrix Discussion

No discussion at this time.

Modeling Requirements, Emission Inventories and Statements

John Silvasi indicated that an Issue Paper on this subject probably needs to wait until this process is completed?

Harvey Jeffries quested what was the actual purpose of this paper?

John Silvasi responded that it was intended to identify requirements for issues relating to modeling, inventories, etc.

Tom Moore suggested that what he was seeing from this paper was a menu of approved models and a list of inventories which need to worked- up. He continued stating that he viewed the AOI problem as a lot bigger than any list that we can work up. The process is a convergent, convoluted process.

David Sanders asked if this menu would deal with the quality of the models and inventories needed to get to the end line?

Diana Andrews cautioned the group to be careful in defining loops, because of the dates and deadlines involved.

Harvey Jeffries reminded Ms. Andrews that this simply could not be avoided. Mr. Jeffries used the OTAG process as an example, stating that OTAG has come to the realization that the process is not an end-all endeavor. He indicated that Tom Moore is describing the reality of the situation, and ultimately it is going to be this way. The process is simply cyclical in nature, and this cannot be avoided. He concluded by saying that he did not necessarily like the title or the box that it is in.

Tom Moore offered to continue working on it in some future form; but, that he simply was not in the linear mode on this issue.

John Silvasi stated that eventually the EPA staff will be drafting a background document, that will outline the issues.

Harvey Jeffries suggested that the group needs to look at the Demerjian and Roth document again, prior to drafting anything.

Ned Meyer responded that he was quite familiar with this document. Mr. Meyer indicated that is was his understanding that they were simply looking for introductory paragraphs on what was needed; not necessarily the end-all solution to each of these problems.

Tom Moore reminded the Work Group members that the STSWG scientific inputs need to be structured to a sufficient level of detail and accuracy such that they can contribute to the policy decision.

Cyril Durrenberger said that as an user of this stuff, I would suggest a cyclical process with sufficient feedback loops for consensus building.

Control Technology

Charlene Spells presented the Control Technology issues, and asked the following questions:

What magnitude of controls are actually available?

At what cost is the maximum amount of control available? (This will vary from pollutant to pollutant, e.g. at $12B we can remove 80% of the NOx).

Ms. Spells indicated that the purpose of this paper was to get together a matrix of currently available control technologies, which could contribute to the removal of multiple pollutants. We have pulled together some PM technologies, and have borrowed from the OTAG process some ozone controls. We are trying to identify co-control benefits for multiple pollutants.

Cyril Durrenberger offered that TNRCC has used this methodology for some time.

Harvey Jeffries asked if Mr. Durrenberger could bring an example of this next week?

Mr. Durrenberger indicated that he would be happy to do so.

John Silvasi said that he would bring the matrix which Charlene Spells has developed. He also offered that his matrix was originally developed by Tom Pace.

Charlene Spells stated that based on previous conversations, there was not much interest in this paper. Is this still a correct assessment?

Harvey Jeffries asked what were the burning science questions here - is there something that needs explaining?

Charlene Spells responded that there are not really any science issues to solve.

Harvey Jeffries stated that he did not really see anything for STSWG to contribute to this paper.

Charlene Spells indicated that this approach is okay; however, she just needed to hear this from STSWG, such that she can take it back to BPAP.

Harvey Jeffries said that based on the Ziman approach, we need to examine the maximum available controls, and at what cost. After all, in Ziman's scenario, he designed a control strategy and then attempted to implement this approach.

Cyril Durrenberger stated that we need to design a metric to look at this issue. It is really an operations research type of issue, and I think we really need to resolve this scientifically.

Harvey Jeffries asked if it is technically feasible to say that we can get rid of NOx? If we cannot, then if we can only remove 60% of it, then it is probably not feasible to beat-up on NOx - we need to focus our efforts elsewhere.

John Silvasi added that he simply did not know the answer to these questions. However, our Emissions Standards Division is probably a good starting point for these types of discussions.

Harvey Jeffries suggest that we some experts from ESD come and talk with us. Mr. Jeffries also asked how trading might affect the Control Technology issue. He stated that STSWG needed to get a handle on this issue, because the STSWG is simply not "smart" on this issue.

Ned Meyer replied that the Regulatory Impact Analysis ( RIA ) is probably doing a good deal on this issue.

Harvey Jeffries stated that he had asked Tom Helms about this, and suggested that we probably need the RIA group to give us a briefing on their progress.

Ned Meyer offered that there will be a session at the next FACA meeting on Thursday evening to discuss the RIA.

John Silvasi reminded the group that Charlene Spells is working on a catalog of where you get synergistic effects - i.e you control ozone precursors, and low and behold you improve PM- fines.

As a means of summary, John Silvasi reminded the group that the public comment period for the standard had been extended to March 12, 1997, and is for both ozone and PM. As a result, promulgation of the standard has been pushed to July 19, 1997. Harvey Jeffries also said that the Phase I Executive Summary Document is going to all subcommittee members. Mr. Jeffries indicated that he had a copy and that it was an impressive document. He suggested that the other Work Group members get a copy, and review the material prior to next week's meeting.