Model Clearinghouse Information Storage and Retrieval System
Record Details

Issue:  

The U.S. Environmental Protection Agency (EPA) Region 6 seeks concurrence 
from the Model Clearinghouse regarding the prospective EPA Region 6 approval 
of an alternative model for a CAA Prevention of Significant Deterioration (PSD)
permitting effort. Sea Port Oil Terminal Terminal Services has 
requested the use of the Coupled Ocean-Atmosphere Response Experiment (COARE) 
bulk flux algorithm, as implemented in the AERCOARE meteorological data 
preprocessor program to prepare meteorological data for use in the American 
Meteorological Society/Environmental Protection Agency Regulatory Model 
(AERMOD) dispersion program in order to assess ambient impacts in a marine 
environment for a Deepwater Port project (SPOT DWP).

The coupling of AERCOARE with AERMOD is considered an alternative model 
application requiring Regional Office approval with Model Clearinghouse 
concurrence per Section 3.2 of the Guideline on Air Quality Models, 
Appendix W to 40 CFR Part 51. For the SPOT DWP project, the preferred 
nearfield dispersion model would normally be the Offshore and Coastal 
Dispersion, OCD, model given its offshore location and potential for 
onshore impacts over coastal regions. Additionally, AERMET is the 
preferred meteorological preprocessor for AERMOD, but is limited to 
overland applications. So, the use of AERCOARE for marine environments 
in lieu of AERMET must be considered as a part of the alternative model 
review and approval. EPA Region 6 has conducted a thorough review of the 
request and currently intends to approve the use of AERCOARE/AERMOD as 
an alternative model to conduct the air quality modeling analysis as part 
of the SPOT Terminal Services LLC PSD permit application.

C/H Response:  

The Model Clearinghouse fully concurs with EPA Region 6 proposed approval 
of a coupled AERCOARE-AERMOD approach for the compliance demonstration 
analysis required in the SPOT DWP project PSD application based on the 
alternative model justification package provided by SPOT Terminal Services 
and the technical review documentation provided by EPA Region 6. Given the 
possible importance of platform downwash and shoreline fumigation, the 
Model Clearinghouse recommends caution and careful review before additional 
alternative model considerations of the coupled AERCOARE-AERMOD approach 
in other projects. As similarly stated in a May 2011, EPA Region 10 concurrence 
response (reference ID No. 11-X-01), this case-specific Model Clearinghouse 
concurrence does not constitute a generic approval of a coupled AERCOARE-AERMOD 
approach for other applications elsewhere. However, the scope of the technical 
assessment submitted with this EPA Region 6 Model Clearinghouse and the 
previous EPA Region 10 requests provide a good basis for such considerations.

Memo:  Model Clearinghouse review of an alternative model application of AERCOARE
in conjunction with AERMOD for the proposed Sea Port Oil Terminal SPOT
Terminal Services LLCs Deepwater Port Project
        Dated: November 19, 2019
        From:  George Bridgers, Model Clearinghouse Director
                 Air Quality Modeling Group, Air Quality Assessment Division, 
                 Office of Air Quality Planning and Standards
        To:    Ashley Mohr, Regional Air Permit Modeler
                 Air Permits Section, Air and Radiation Division
                 EPA Region 6
               Jeffrey Robinson, Chief
                 Monitoring and Grants Branch, Air and Radiation Division
                 EPA Region 6
                 
Memo:  Concurrence Request for Approval of Alternative Model AERCOARE in Conjunction
with AERMOD, in Support of Clean Air Act CAA Permitting Effort
        Dated: October 29, 2019
        From:  Ashley Mohr, Regional Air Permit Modeler
                 Air Permits Section, Air and Radiation Division 
                 EPA Region 6, Dallas, Texas
        Thru:  Jeffrey Robinson, Chief
                 Monitoring and Grants Branch, Air and Radiation Division 
                 EPA Region 6, Dallas, Texas
        To:    George Bridgers, Model Clearinghouse Director
                 Air Quality Modeling Group, Office of Air Quality Planning and Standards

Memo:  Technical Review of Sea Port Oil Terminal SPOT Terminal Services LLC request 
to use the AERCOARE meteorological data preprocessor program in conjunction with 
AERMOD in support of their Prevention of Significant Deterioration PSD Permit 
Application
        Dated: October 18, 2019

Memo:  Request for Approval for Use of COARE Bulk Flux Algorithm to Generate Hourly 
Meteorological Data for use with AERMOD
        Dated: October 1, 2019
        Submitted To: Environmental Protection Agency, Region 6
        Prepared By: Sea Port Oil Terminal SPOT Terminal Services LLC