Plan of Action

Air Quality Services, Inc

FROM: AQS Management Team

TO: AQS Project Team - Weaser Plant Ozone Analysis

PLAN OF ACTION

All members of the team need to read the modeling approach discussion paper to gain some familiarity with the modeling approach that will be applied. Ideally, all team members should run the model with the default values to see what information it provides. The chief modeler on the team should review the OZIP documentation to gain a better understanding of the data needs. In particular, the chief modeler must become very familiar with the form to be filled out prior to OZIP implementation. The chief modeler must know what default values are, and when they should and should not be used.

After everyone on the team has reviewed the modeling approach discussion paper, the chief modeler should convene a meeting of the team members to establish assignments and deadlines. Even though each team member has specific duties, the workload does not divide evenly. Success depends upon the team pitching in to help in other areas (particularly helping the modeler) as time is available.

The environmental chemist should examine the two chemical mechanism packages - Regional Acid Deposition Model (RADM) and Carbon-Bond 4, to determine which may most accurately reflect the chemistry of southern Colorado. The chemist also has a choice regarding reactivities. For background information on this topic, the chemist should read the gas-phase reaction mechanisms paper. The chemist should consider looking at the sensitivity of the model as a function of the chemical mechanism. In other words, do you or do you not get any different results with the different mechanisms.
The emissions inventory specialist should access the emissions inventory records that are available via the Internet to determine whether the data are in a format consistent with OZIP. Discuss with the chief modeler whether mass emissions data or emissions fractions data will be useful.
The meteorologist should work with the chief modeler to determine what meteorological data are necessary. The meteorologist can obtain data from a variety of Internet sources. A mixing height calculation should be done using National Weather Service data and applying the online program.

The environmental policy/economics specialist should build a spreadsheet that calculates cost of reduction of various percentages of VOCs, NO_x and CO. A major part of our job will be to determine the lowest cost combinations of reductions that will achieve compliance with the new standards. For this exercise, assume the following:

Table of Costs per 1% Reduction of Emissions

Species	1-5% total reduction	6-10% total reduction	11-20% total reduction	21-30% total reduction	31-40% total reduction	41-50% total reduction
VOCs	$10,000	$15,000	$25,000	$35,000	$45,000	$55,000
NO_x	$5,000	$7,500	$15,000	$20,000	$25,000	$30,000
CO	$1,000	$1,500	$2,500	$3,500	$4,500	$5,500

For example, if total NOx is to be reduced by 15%, the cost will be:

15 x $15,000 = $225,,000

Assume that these numbers represent the annual cost of the initial capital cost plus operating costs, averaged over a 5-year period. A total annual value over $1M will be unacceptable to Lotsonox. [NOTE: The reduction costs given above are intended to indicate the relative importance of reductions for each species (i.e., reduction of VOCs will yield the highest ozone level reduction). As the percentage of reductions increases for each of the three species, the cost increases in a nonlinear fashion. The cleaner the air gets, the harder it is to make it even cleaner! These cost figures are fictitious. Actual costs would be determined on a site-specific basis and would involve a complex evaluation of emissions control equipment options as well as examination of potential pollution prevention options (e.g., chemical substitution of less volatile materials, process reengineering to eliminate some chemicals).]

In addition, the policy/economics expert should calculate the appropriate design ratio. Senior management at AQS has requested a ruling from the EPA on the choice of a design ratio. EPA's memorandum should be consulted and followed.

Once the appropriate meteorological and emissions data have been gathered, and the design ratio calculated, initiate a series of OZIP runs to determine a range of reductions that will result in achieving an ozone level of 0.08 ppm or less.
The team should convene to discuss and come to a consensus on the recommended action for Lotsonox. Prepare a report to the CEO of Lotsonox, outlining the procedure followed in calculating emission reductions to achieve compliance with the standard. It may be helpful to include an executive summary at the beginning of the report. In the main body of the report, discuss data sources for the input files. Remember to explain any choices that the team made in the modeling runs.
At the very least:
1. The modeler should describe the basic steps of the modeling process, and include a discussion of the design ratio used and why (consult the policy/economics specialist if s/he made the design ratio calculation).
2. The meteorologist should describe how and why s/he chose values for temperature, humidity, pressure, and current ozone concentrations.
3. The chemist should describe which mechanisms and reactivities s/he chose and why.
4. The emissions inventory specialist should describe where emissions data were obtained, and when mass emissions versus fractions emissions values were used.
5. The policy/economics specialist should thoroughly explain the costs associated with the emission reductions. This should include a discussion of the estimated cost to achieve the 0.08 ppm standard. If this cost is over $1M, the memo should discuss what reductions can be achieved for $1M.
The team should advise Lotsonox regarding the materials Lotsonox will need to keep on file in order to build and support a credible defense in the event that our modeling indicates that compliance will not be economically feasible. Their legal counsel must be confident that our results are scientifically rigorous. Lotsonox will make the final determination regarding the nature of their comments to EPA.

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