June 12, 1996

MEMORANDUM

SUBJECT: Fluid Modeling to Establish GEP
         Kammer Power Plant, WV

FROM     Dennis Doll, Environmental Scientist
         Model Clearinghouse (MD-14)

TO:      Denis Lohman, Meteorologist
         Technical Assessment Section , Region III (3AT22)

     In response to your request the Model Clearinghouse has
reviewed your analysis and questions relating to fluid modeling and
the NAAQS for Kammer.  In a follow up conversation we discussed
with you the applicability of guidance contained in Appendix E of
the 1985 Workshop on Implementing the Stack Height Regulations.  It
is our understanding that after reviewing that guidance you agree
that by following that guidance your technical questions contained
in your June 4 memorandum are obviated  and there is no need for
further discussions relative to them.

     The only other point that should be mentioned is that Appendix
E also discusses the contribution of background concentrations to
the 3-hour and 24-hour concentrations to determine if there are
violations of the NAAQS at the 40% increase level.  This background
is apparently not included in your analysis in the June 4 memo, but
you are aware of that issue and will deal with it separately.

     If we can be of further assistance, please contact me at
919-541-5693.

cc: J. Dicke
     J. Tikvart
     D. Wilson
Excerpt from June 4 1996 memomorandum from Denis Lohman to Dennis
Doll

...
In summary, we have two questions to answer in evaluating the
infeasibility analysis. (l) What is the appropriate way to convert
wind tunnel measurements to concentrations at the time periods of
the NAAQS?  (2)Should the fluid modeling demonstration be analyzed
to minimize stack height credit or to eliminate all NAAQS
exceedances?
...