May 10, 1990 MEMORANDUM SUBJECT: Four Billings Montana Modeling Proposals FROM: Joseph A. Tikvart, Chief Source Receptor Analysis Branch (MD-14) TO: Douglas M. Skie, Chief Air Programs Branch, Region VIII (8AT-AP) In response to your request, the Model Clearinghouse has reviewed John Notar's evaluation of the four proposals for modeling SO2 in Billings/Laurel, MT. Our conclusion is that John has done a thorough review and we agree with his comments and conclusions. In our estimation, with the possible exception of the fumigation phenomenon, the Billings/Laurel situation can be handled well by models and screening techniques recommended in the Guideline on Air Quality Models (Revised). The situation is not unlike many we have dealt with in the Ohio Valley and in Appalachia with sources located in river valleys with surrounding marginally complex terrain. These situations generally require the application of two models, a simple terrain model such as ISC and a complex terrain model such as COMPLEX I. Intermediate terrain between stack height and plume height needs to be evaluated with both of these models and the higher of the two estimates chosen. Regarding fumigation, we suggest that the technique contained in the EPA SCREEN model be tried before spending a lot of contract monies in developing, testing and applying a nonguideline technique. If the SCREEN results show underestimates of the fumigation concentrations, and such concentrations are associated with the design value, then perhaps a more rigorous technique could be pursued. We agree with John that it is important to carefully determine whether the area is urban or rural before selecting the models to be applied. We also agree that priority for spending contract monies should be on the emission inventory, including building dimension data needed for downwash calculations. Also, it might be useful to require collection of very short term, e.g. 3-5 minute, emissions and air quality data so we can understand the potential for emergency episodes, which has recently been raised as an issue in this area. If you have any questions, please contact Dean Wilson at FTS 629-5683. cc: D. Grano W. Laxton D. Wilson