Draft Summary of the Federal Advisory Committee Act (FACA)

Science and Technical Support Work Group Meeting

Mutual Building, Room 836

November 5, 1996

Durham, North Carolina

The Science and Technical Support Work Group (STSWG) of the FACA Subcommittee met on Tuesday, November 5, 1996 between 1:30 pm and 3:00 pm EDT in Room 836 of the Mutual Building, Durham, North Carolina. A list of the participants and a summary of the meeting follows.

Work Group Participants

Name	Affiliation

Tom Helms, Co-Chair	U.S. EPA

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

Diana Andrews	Kentucky DEP

David Chock	Ford Motor Company

Kirit Chaudhari	Virginia DEQ

Ellis Cowling	SOS

Bruce Hill	Appalachian Mountain Club

Tom Moore	Arizona

S.T. Rao	New York ARB

Jeffrey West	GPU Services Corp.

Steve Ziman	Chevron Corporation

Work Group Members Not Participating

John Cabaniss	AIAM

Glenn Cass	Cal Tech

John Core	WESTAR

Jay Hudson	Santee Cooper

David Kelly	Navajo EPA

Dave McNeill	Utah DEQ

Rich Poirot	Vermont

Jay Rosenthal	Navy

Mark Scruggs	DOI

Jay Turner	DOT

Manop Vanichchagorn	Louisiana DEQ

Dan Weiss	Cinergy Corporation

Non-Work Group Participants

Bob Wayland, SAIC; Mike Teague, UARG; Pradeep Saxena, EPRI; Ken Schere, U.S. EPA/AREAL; Bill Kuykendal and Ned Meyer, U.S. EPA/EMAD; Scott Mathias, U.S. EPA/ISEG; JoAnn Allman, Denise Gerth, Bill Johnson, Annie Nikbakht, and David Sanders, U.S. EPA/OPSG.

Summary of Meeting

Harvey Jeffries gave a recap of the Issue Papers that were discussed at the FACA Subcommittee meeting held in Dallas, Texas.

David Sanders noted that during today's call the STSWG would focus on the Phase II Issue Papers that would be discussed at the FACA Subcommittee meeting in Denver, Colorado.

Issue Papers to be Discussed in Denver

The following four issue papers were to be discussed during the FACA Subcommittee meeting in Denver:

Integrated Implementation	STSWG lead - Mark Scruggs

Attainment Dates	STSWG lead - John Cabaniss

New Source Review	STSWG lead - Dave McNeill

AOI/AOV	STSWG lead - S.T. Rao and Tom Moore.

Tentative Schedule for Denver Meeting

The following tentative schedule for the STSWG meeting in Denver was given:

The meeting will start at noon on Monday, November 18, 1996. The meeting will adjourn at 2:30 pm for a late lunch break.

There may be a joint meeting between work group co-chairs from 2-4 pm.

The STSWG meeting will reconvene at 3:30 pm and will run until 7:00 pm. Special presentation will be made during this session (e.g., Steve Ziman's concerns on the API paper and resources and tools Issue Paper for fine particulate matter (PM-fines) of Tom Moore).

The FACA Subcommittee meeting will start at 9:00 pm on Tuesday, November 19, 1996 and will run until 5:00 pm. The meeting will resume on Wednesday, November 20, 1996 at 8:00 am and will adjourn at 2:00 pm.

Harvey Jeffries stated that the FACA Subcommittee will work through the Issue Papers, similar to what was done in Dallas. He added that it should be a very busy meeting.

Diana Andrews asked if the FACA Subcommittee ever came to closure on the Issue Papers.

Harvey Jeffries replied that a lot of people are beginning to complain that significant closure is not being reached. He said the Subcommittee will do better next time. The form of the ozone standard will be announced by this time and we could discuss this.

David Sanders clarified that the ozone NAAQS will be announced officially on November 29, 1996.

Steve Ziman said that he heard rumors from within EPA that the decision has already been made. He asked if perhaps, one of the EPA staff could leak this information to the STSWG.

S.T. Rao asked what happened to the other Issue Papers not referenced above?

Harvey Jeffries said that the work group needs to concentrate on these four issues first and be prepared to provide conclusions at the Denver meeting. He added that the other papers could be dealt with at a later date.

Diana Andrews stated that she had not been able to get up with Richard Dworek because he has been ill, but that she would keep trying.

Ellis Cowling commented that CASAC has made some different recommendations that he thought should be discussed at the Denver meeting. He added that there is a possibility that the EPA Staff Paper's recommendation and CASAC's recommendation on the secondary standard could be a viable alternative.

Harvey Jeffries asked Mr. Cowling to hold this type of discussion until after the STSWG finishes the four issue papers.

Jeff West asked to have a copy of the agenda e-mailed to him.

David Sanders responded that he would be glad to do this. He noted two other things. First he said that on November 18th, besides the joint meeting of the co-chairs, between 4-6 pm there would be a joint meeting of the Base Programs and Policies (BPAP) Work Group and the National and Regional Strategies Work Group (NRSWG). They would like some representatives from STSWG, but not the entire work group. Second, between 5-7 pm, there will be a meeting of the Coordination Committee which will take up Harvey Jeffries' and Tom Helm's time.

Steve Ziman said that he needed a revised agenda by COB today for the 18th.

Harvey Jeffries said that he would send Tom Helms to the Coordination Committee meeting. He added that he thought the STSWG could meet during this time to resolve some issues.

New Source Review

Regarding New Source Review, Harvey Jeffries said that he did not know where Dave McNeill was on this, but he did not think that there had been much science involvement with it.

AOI/AOV Issue Paper

Regarding AOI/AOV, Harvey Jeffries said that he did not want the STSWG to get bogged down in what tools we are going to use to determine AOI/AOV. He stated that remarks were made during the Dallas Subcommittee meeting that everyone has not embraced the AOI/AOV concept. He said that this issue paper still needs to come before the Subcommittee adding that it is still a very broad, conceptual approach. Mr. Jeffries said that he wanted the Work Group to look at whether there are any scientific issues involved.

Tom Moore suggested that perhaps the science issue is how not to draw the boundaries.

Harvey Jeffries responded yes. He added that we need to be able to characterize pollutants and the periods of AOI and AOV.

Steve Ziman said that you cannot remove this concept from the integrated implementation paper, because the assumptions that are made are questionable. He added that we may want to discuss integrated implementation first and then discuss the AOI/AOV issue paper.

Harvey Jeffries responded that he thought Mr. Ziman was exactly correct. He said that it is still very unclear and that there is no bright line distinction for drawing AOI lines.

Diana Andrews asked if the work group was still dealing with the Don Theiler paper.

Harvey Jeffries replied yes.

Kirit Chaudhri said that he needed to talk with Steve Ziman about this paper.

Steve Ziman said that he would call Kirit Chaudhri either today or tomorrow.

Integrated Implementation Issue Paper

Tom Moore said that this paper was started by Donna Lamb. He added that it is very broad and general in scope.

Harvey Jeffries said that Donna Lamb began to raise some issues that were problematic. One of these problematic issues is the order you might pursue in resolving these issues under the integrated implementation (e.g. does it make sense to do one thing before another issue). Some of the information indicates that spending money on PM to remedy health effects could be more beneficial than spending the same dollars on the ozone issue. Or, for example, the issue of permitting ozone to increase in a NOx control strategy region, because that in the long run the effects on PM could be beneficial.

Steve Ziman noted that we simply don't have the data to deal with these issues.

Harvey Jeffries said that you have to understand the relative costs of PM attainment and ozone attainment, prior to developing your integrated global approach to implementation. He asked if the members followed this discussion.

Jeff West asked if what you're saying is that the attainment of the standard is not the most important issue here.

Harvey Jeffries responded, "exactly." He added the attainment of a standard for an individual pollutant may not be the best methodology for improving a regions overall air quality and health benefits. He asked what is the appropriate rate of progress for these issues?

Jeff West said that it really gets back to the availability of tools to do the appropriate analyses.

Tom Moore stated that he is writing a straw man proposal on what should be in our tools document.

David Sanders said that he thought the STSWG should have another conference call next Tuesday in preparation for Denver. He suggested that the STSWG should appoint people to generate bulletized lists for the next conference call which summarize the individual issues.

Harvey Jeffries asked Tom Moore if he is developing a document for circulation within the other work groups.

Tom Moore responded that it should be a timeline with rationale for when to do what.

Steve Ziman added that you might get some input from Ken Schere because the NARSTO process has attempted to discuss this.

David Sanders noted that there are at least three timelines coming from the BPAP Work Group. He said that it would be interesting to compare/contrast them. He said he would be happy to be the centerpoint for the distribution of these time lines.

Harvey Jeffries thought we needed to provide John Cabaniss some information on what it takes to be an AOI and/or an AOV.

Steve Ziman said we need to do this for all the issues (e.g. ozone, pm and regional haze), not simply ozone. The timelines will be markedly different for the different issues.

Harvey Jeffries suggested there is another piece to this. Rich Scheffe did some initial work, dealing with model studies. He noted there are a lot of people who have assumed because some things have been done in the past with specific models, that the answers exist. Thus, we need to address the fact that these things have been done, and explain to them why they are not scientifically acceptable tools.

Tom Moore said that is the purpose of the timeline - to show these people that more things need to be done. He added we're not going to simply replace the PM10 standard with a PM2.5 standard. It is most likely that we will get a proposal that has both standards for attainment. He said this may not be a big problem east of the 100th meridian but out here in the west it is making big noise.

Steve Ziman noted that in central California, the field study will not begin until mid- 1999.

Harvey Jeffries stated that our discussion might be maximized by focusing on these tools issues. He wondered if the Work Group could spend less than an hour on dealing with these four issue papers and spend the remaining time dealing with other issues (e.g. Steve's concerns, etc.). He suggested that perhaps an integrated approach would be better than working on the issue papers one by one.

David Sanders said that it looks like the Denver meeting agenda may be changing.

Harvey Jeffries asked where the lunch break is on the agenda.

David Sanders responded 2:30 pm but for the east coast people it will be more like dinner.

Steve Ziman suggested a working lunch.

Harvey Jeffries said this was a better approach. He said that from 2:00 pm - 3:00 pm the Work Group could talk about data analysis and tools. From 4:00 pm - 6:00 pm the Work Group can go back and discuss any closure on these four Issue Papers.

Jeff West asked if the purpose of the meeting was to develop an outline for data and tools?

Harvey Jeffries responded that the purpose of the meeting is two-fold: 1) to state clear science issues with individual Issue Papers and 2) to convey our overarching issues with the Issue Papers.

Jeff West said that it seems like the Work Group needs to pose questions, then provide answers.

Harvey Jeffries proposed the following schedule:

12:00 pm - 1:00 pm	Issue paper discussions (15 minutes per paper)

1:00 pm - 2:00 pm	Tools questions, timelines, data, models, etc.

2:00 pm - 3:00 pm	Issue of areas flipping in/out of attainment.

Steve Ziman responded that we're trying to make sure that the people who are writing the implementation policy have a clear understanding of the science issues involved, because of variability you will have to over control in order to meet the standard. With ozone, for example, you're essentially aiming at a standard that is extremely close to the background concentrations.

Harvey Jeffries noted that the rate of progress is also important here for areas flipping in and out of attainment.

S.T. Rao said this is a double-edged sword. The current requirements require you to address these issues.

Steve Ziman responded what are you gaining by this. He added that we are discussing implementation and not the development of the standard. We must consider cost.

Harvey Jeffries responded this a policy question.

Steve Ziman replied "yes, you're correct. But we owe them the scientific explanations associated with these type of policy decisions."

S.T. Rao said this is what State implementation plans (SIPs) are all about. We are talking about meeting and maintaining a standard.

Harvey Jeffries said that a place could in the long-term be meeting the standard but on a short-term basis it could be flipping in and out of attainment.

Steve Ziman commented that S.T. Rao was missing the whole point here. He added we are not bound by anything that is currently in the Clean Air Act.

S.T. Rao responded that you cannot have it both ways. If you are constructing credible plans, you must assure compliance with the standards.

Steve Ziman noted this is what we are trying to get away from.

S.T. Rao replied "you cannot separate one from the other."

Harvey Jeffries asked why are we having this tools "discussion"!

Bruce Hill asked Harvey Jeffries to identify the document that is being discussed.

David Sanders responded it is the paper by David Chock and he would get Bruce Hill information about it. He added that this data was reviewed by Warren Freas, Barry Gilbert and David Chock, and they all reached the same conclusions. He said it's the issue of the 100-year flood vs. the 10-year flood - it is because of the variability in meteorology.

S.T. Rao commented he fundamentally disagreed with this line of discussion.

Harvey Jeffries stated we are changing from an exceedance-based standard to a concentration-based standard.

S.T. Rao said you are still dealing with the exceedance of some level or threshold. Essentially, you're questioning whether a standard is a goal or finite limit.

Steve Ziman responded that this is not what you're doing.

Bruce Hill asked why is this not attainable?

S.T. Rao responded because of meteorological variability.

Steve Ziman said that he would have people present studies which show conclusively, that these standards are not attainable. What we are saying is that in the foreseeable future, we cannot see the technical tools to attain the standards.

David Sanders interrupted this discussion and re-focused the discussion on the issues to be addressed in Denver. He expressed the need to summarize the conclusions on these Issue Papers.

Harvey Jeffries asked everyone to read the Issue Papers prior to Friday and submit comments/suggestions to David Sanders.

David Sanders noted that the Issue Papers would be placed on the TTN just prior to the Denver meeting. The current deadline is next Tuesday, November 12, 1996. The Issue Papers are currently on the TTN and he did not foresee them changing significantly prior to the next FACA meeting. He noted after November 12th, you can pull down the revised versions and determine what changes have been made.

Diana Andrews asked where the interim transition principles paper was located? Is it on the TTN? She stated that she has a draft PM transition principles paper dated September 26, 1996, but she did not have all the pages.

David Sanders said that paper should be under the BPAP Work Group area.

Harvey Jeffries said (to David Sanders) you need to contact Mark Scruggs, Dave McNeill and John Cabaniss and tell them we want short, 15-minute presentations of their papers at the Denver meeting.

Tom Moore recapped what David Sanders was going to do:

(1)	New draft agenda by COB today;

(2)	Contact Mark Scruggs, Dave McNeill, John Cabaniss and define their roll on the Denver agenda;

(3)	Send comments to David by Friday on these Issue Papers; prepare short, concise summaries of the STSWG comments on these papers; and,

(4)	David will e-mail these back out on Friday/Monday, prior to our call next Tuesday.

Bruce Hill asked Harvey if we are still pulling together the available PM-fines data?

David Sanders responded yes, that he has the same charge from Sally Shaver. He suggested that perhaps, they should compile Mr. Hill's information, with Mark Scruggs' IMPROVE data, along with Neil Frank's data and anything else that is available.

Tom Moore commented that we should wait until EPA has a reference method proposed.

Harvey Jeffries agreed, adding we need to recognize what is out there and what is available. He said John Seitz was trying to determine/distinguish which places are bound to not meet the new standard versus those areas which may/may not meet the standard. We simply need to obtain what is out there and available, such that we can move forward now.

Steve Ziman noted everyone west of the 100th meridian is probably going to have great concern over this standard.

Harvey Jeffries commented Glen Cass raised these issues to the subcommittee.

Tom Moore stated that predicting attainment/nonattainment is not the difficulty of using existing data. The true issue here is being able to design effective control strategies, using these existing data. He noted EPA has designed a sampler which is not likely to collect certain particle types.

Steve Ziman said that he did not think that you can use any of this data for any cogent analyses.

Bruce Hill thought Neil Frank should make a presentation at our next meeting on the Federal reference method.

Tom Moore suggested we need to discuss the monitoring network and what the collected data will be used for.

Harvey Jeffries added the stickler is once there is a standard, you must designate within 3 years. EPA feels compelled to determine that they have a problem, rather than dealing with how to solve the problem. Thus, it is more appropriate to classify the whole country as having a problem than it is to determine how to deal with the problem.

David Sanders introduced JoAnn Allman. She said that regarding EPA travel reimbursements, you must call 919-541-1815 and confirm travel with her. She must make the travel arrangements even if you attended the Dallas Meeting. She added if you have outstanding vouchers, he must receive these invoices prior to Thursday or Friday of this week.

Ned Meyer expressed concern with the problem of source attribution. Mr. Meyer said that EMAD may plan something in the February time frame to deal with source attribution. Things that may be reviewed include: Process Analysis of Harvey Jeffries; Envrion's UAM-X; SAI's UAM-V modeling; Sandy Sillman's work, etc. EMAD would like to direct some of their resources to look at this problem. We are also looking for more corroborating evidence to support our positions. He asked who we should invite to this February meeting.

Pradeep Saxena suggested adding Glen Cass and John Seinfeld's work also.

The meeting was adjourned.