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Record Details

Use of beta ARM2 Technique as an Alternative Model
Record No: 15-IV-01      Last Update: 04/28/2016

EPA Region: 4     Fiscal Year: 2015
States: TN
Record Type: Action
Pollutants: NO2     Sources: Generic to Any Stationary Source
Models: AERMOD     Urban/Rural: Rural
Terrain: Both High & Low     Regulations: PSD
Guideline: Guideline     Database: Both
Oral/Written: Written     Involvement: Review and Comment
Subjects: Technical Credibility of Nonguideline Techniques        
Comments: 
Issue:  Region IV is seeking concurrence from the Model 
Clearinghouse for the approval of an alternative modeling 
demonstration for the use of the beta Ambient Ratio Method 2 
(ARM2) Tier 2 NO2 modeling technique.  The ARM2 technique 
will be applied in an compliance demonstration for a PSD 
permit at the Hankook Tire manufacturing facility in 
Clarksville, TN.

C/H Response:  The Model Clearinghouse concurs with Region IV’s 
position that ARM2 is an appropriate technique for modeling 
NO2 impacts from the Hankook Tire manufacturing 
facility.  From our review of the material provided through 
out exchanges, the facility meets the requirements for the 
usage of ARM2 set forth in the September 20, 2014 EPA 
clarification memorandum, “Clarification on the Use of AERMOD 
Dispersion Modeling for Demonstrating Compliance with the NO2 
National Ambient Air Quality Standard.”  We believe the 
minimum ambient NO2/NOx ratio of 0.20 is appropriately 
justified and conservative for this proposed Hankook Tire 
manufacturing facility project.  Additionally, the background 
ozone is not high enough to cause concern for excessive 
NO-to-NO2 conversion, which would cause ambient NO2/NOx 
ratios to increase rapidly.
Memoranda: 

Memo:  Model Clearinghouse Review of the Use of the 
Ambient Ratio Method 2 (ARM2) Default AERMOD Option for Hankook 
Tires Facility NO2 Ambient Impact Analysis
          Dated: December 22, 2015
          From:  George Bridgers, Model Clearinghouse Director
                   Air Quality Modeling Group, EPA
                 Chris Owen, Physical Scientist
                   Air Quality Modeling Group, EPA
            To:  Todd Rinck, Chief
                   Air Data and Analysis Section, Region 4, EPA
                 Stanley Krivo, Environmental Scientist
                   Air Data and Analysis Section, Region 4, EPA

Memo:  Concurrence Request - Approval of Ambient Ratio Method 2 
(ARM2) Default AERMOD Option for Hankook Tires Facility NO2 
Ambient Impact Analysis
          Dated: November 30, 2015
          From:  Stanley Krivo, Environmental Scientist
                   Air Data and Analysis Section, Region 4, EPA
            To:  George Bridgers, Director of Model Clearinghouse
                   Air Quality Modeling Group, EPA

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