ALL4's Dan Dix presented at the 23rd Virginia Environmental Symposium about 1-Hour SO2 Implementation Modeling. Dan's presentation consisted of a summary of the NAAQS, an update on NAAQS implementation, NAAQS modeling demonstration approach, and a summary of ambient SO2 monitoring.
3. About ALL4
Environmental consulting firm
Founded 2002 – currently 30+ employees
Offices in Kimberton, PA and Columbus, GA
Specialize in air quality consulting:
• Complex air permitting and strategy development
• Air dispersion modeling
• Ambient air quality monitoring
Dispersion modeling as a company-wide initiative
www.all4inc.com
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5. NAAQS Background
“Backdrop” of the Clean Air Act
States design their SIPs and enforce and
implement their regulations to meet the
NAAQS
Air quality construction permit programs are
designed around NAAQS compliance
• PSD: Maintaining NAAQS attainment
• NNSR: Getting into NAAQS attainment
NAAQS reevaluated every 5 years
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7. Attainment/Nonattainment Designations
U.S. EPA philosophy on the SO2 NAAQS
implementation process:
• Proposed NAAQS – designations based on
ambient monitoring data
• Final NAAQS – designations based primarily
on air quality modeling data
Shift to reliance on air quality modeling
will become a critical issue for individual
facilities
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9. SO2 NAAQS Implementation
NAAQS Implementation Schedule:
• June 2011: Initial state nonattainment
recommendations to U.S. EPA (most counties were
“unclassifiable”)
• June 2012: EPA to finalize attainment status (most
states will still be “unclassifiable” or attainment)
• June 2013: Maintenance SIP submittals including
individual facility modeling to achieve compliance
with the NAAQS
• August 2017: Full NAAQS compliance in all areas
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10. Implementation Update
Draft guidance for states to evaluate
designations using AERMOD was released on
September 22, 2011
Most states are currently reviewing the U.S. EPA
guidance and crafting their plans
States or facilities conducting modeling?
U.S. EPA indicated at 10th Conference on Air
Quality Models that final guidance will not be
released this year due to the scope of comments
made.
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11. SO2 Maintenance SIP Submittals
U.S. EPA: Revising PSD/NNSR programs to include
new NAAQS is not sufficient. Five components are
required:
• “Attainment Emission Inventory”
• Maintenance Demonstration
• Control Strategy
• Contingency Plan
• Verification of Continued Attainment
Maintenance SIP will list enforceable 1-hour emission
limits (August 2017)
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12. SO2 NAAQS Implementation
State SIPs will be based on AERMOD dispersion
modeling for the following individual facilities (by
order of priority):
• SO2 Actual Emissions > 100 tons per year
• SO2 PTE > 100 tons per year
• Smaller facilities “with a potential to cause or
contribute” to a NAAQS violation
States are considering other options based on
population
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13. SO2 NAAQS Implementation
Legal challenges ongoing:
• Science behind NAAQS levels
• Approach of using modeling
Under the current approach, if states don’t
perform modeling, U.S. EPA will through
Federal Implementation Plan (FIP)
Some states don’t have the resources to
complete evaluations and don’t think U.S.
EPA does either.
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14. SO2 NAAQS Implementation
What are other States doing?
• Maine - >100TPY Actual, Protocols due June 30, 2012, and final
analysis due December 31, 2012.
• Lake Michigan Air Directors Consortium (LADCO) has developed
Protocol for states to follow.
Wisconsin, Michigan, Minnesota, Indiana, and Illinois included.
>100 TPY PTE, facilities given option to complete themselves or
have state complete.
Michigan were due December 31, 2011.
Minnesota completed March 12, 2012.
• Nebraska – Power plants have joined to conduct modeling themselves
and conducting tracer study.
• Missouri – Facilities conducting modeling due by April 2012.
• Connecticut - >15TPY PTE, conducted by State by July 2012.
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16. AERMOD Process
Hourly Wind Speed
Hourly Wind Direction
Hourly Ambient
Temperature
Land Use Patterns Predicted Ground Level
Topography Ambient
Concentrations (µg/m3)
Building Dimensions for all averaging times
Stack Dimensions
Exhaust Velocity
Exhaust Temperature
Emission Rates
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17. Air Quality Modeling Steps
1. Emission Inventory
2. Meteorological Data
(AERMET/AERSURFACE)
3. Terrain Data (AERMAP)
4. Building Downwash (BPIPPRM)
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18. Emission Inventories
Short-term (1-hour) emission rates
Potential to be used as permit limits
Intermittent emission units (e.g., emergency
generators, intermittent emission scenarios such as
startup/shutdown operations or alternative fuels)
• Latest guidance indicates following form of
standard as guideline for what to include (i.e., 99th
percentile (4th highest))
Stack characteristics (height, temperature, velocity,
diameter, location)
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21. Meteorological Data
5 years of National Weather Service data
Minimum of 1 year of onsite data
Surface characteristics and topography
surrounding the facility should be similar to
(representative of) those surrounding the
meteorological station
If no representative meteorological data are
available, SO2 implementation guidance
suggests possibility of using AERSCREEN (with
agency approval)
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22. Terrain Data
“Ambient Air”
“that portion of the
atmosphere, external to
buildings, to which the
general public has access”
or “the air everywhere
outside of a contiguous plant
property to which public
access is precluded by a
fence or other effective
physical barrier”
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26. Full NAAQS Evaluation
Includes facility and other local facilities
Any modeled emission rates should be
acceptable as a 1-hour permit limit with
the appropriate margin for compliance
Considerations for accounting for
emissions during startup and shutdown
Emergency unit considerations
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27. Local Sources
NAAQS evaluation must include sources
that result in a “significant concentration
gradient” in the vicinity of the facility
Same emission rate considerations apply
for local sources (although permit limit
concerns wouldn’t apply)
State agency typically dictates which local
sources to include in evaluation
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28. NAAQS Modeling Strategy
Start with an evaluation of each individual
emission source
Each source will have different factors that
drive resulting ambient concentrations
The cumulative ambient concentration
from all sources (plus background) will be
evaluated against the NAAQS
Evaluate each source against the NAAQS
as a first step
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29. NAAQS Modeling Strategy
Big picture factors that will drive ambient
concentrations for individual sources:
• Elevated emission rates
• Stack velocity (orientation of release and
flowrate)
• Stack temperature (plume buoyancy)
• Stack height versus surrounding terrain
• Surrounding buildings and structures (i.e.,
building downwash)
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30. Hypothetical Modeling Examples
Modeling of a hypothetical facility with the
following SO2 emission sources:
• Process SO2 source
• Fuel oil combustion SO2 source
• Backup engine source
NAAQS modeling evaluation is based on
SO2 potential-to-emit
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34. Process SO2 Source Impacts
Highest impacts in complex terrain far from
facility
Wind speed doesn’t match location of elevated
concentrations
Impacts occur during periods of atmospheric
stability and low mixing heights (typically early
morning, low wind speed conditions)
High concentrations due partially to the
limitations of the AERMOD dispersion model
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35. Combustion SO2 Source
SO2 Emission Rate: 20 lb/hr (AP-42)
Stack Height: 60 feet
Stack Diameter: 2 feet
Exhaust Temp: 225 °F
Exhaust Flow: 16,000 acfm
Buoyant source, short stack (shorter than
the tallest buildings at the facility)
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37. Combustion SO2 Source Impacts
Elevated concentrations are closer to the
facility
Building downwash effects have a
noticeable impact on ambient
concentrations
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40. Engine SO2 Source Impacts
Elevated ambient concentrations at the
facility fenceline for two reasons:
• Low stack height (10 feet)
• No plume buoyancy due to horizontal
discharge
Ambient air considerations become very
important (i.e., public access)
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41. Modeling Refinements
“Process” SO2 Emission Source:
• Stack height increase is technically and
economically infeasible
• Raw materials are fixed due to product
and consumer demand
• Upgrades to the scrubber could achieve
control: ~30% more control (~170 lb/hr)
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44. Modeling Refinements
Combustion SO2 Emission Source:
• Stack height increase is technically and
economically infeasible
• Fuel oil firing is desirable due to cost savings
considerations
• Raw materials to the source bring inherent
scrubbing capacity: 50 to 65% based on
previous studies
• 50% inherent scrubbing brings emission rate
to 10 lb/hr (justify through testing)
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47. Modeling Refinements
Engine SO2 Emission Source:
• Simplest fix is to change the stack
discharge orientation from horizontal to
vertical
• No changes to the vendor-guaranteed
emission rate of the engine
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50. Cumulative Concentrations
The facility must cumulatively comply with
the NAAQS
Addressing each individual source helps
as a first cut
This scenario still exceeds the 1-hour
NAAQS for SO2 when the sources are
taken cumulatively
Haven’t even considered ambient
background concentrations
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51. Modeling Strategies
Emissions Strategies
• Actual Distribution of Emissions
• Evaluate adequacy of emission limits
• Evaluate emissions control options
• Evaluate alternate fuels and fuel specifications
• Evaluate alternate raw material
Facility Fence Line Strategies
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54. Modeling Strategies
Use of PTE emissions and AERMOD can
over estimate concentrations
Know issues with certain terrain and
meteorological conditions
Consider Ambient SO2 Monitoring to
compare to AERMOD results
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56. Ambient SO2 Monitoring
What’s involved in conducting an ambient
SO2 Monitoring program?
• Who should consider?
• Equipment
• Sighting Considerations
• Pros/Cons
• Cost
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57. Ambient SO2 Monitoring
Who Should Consider?
• Facilities that have conducted modeling with
unfavorable results, however:
Recommend conducting exploratory
monitoring to assess conditions first.
If favorable work with state to develop a
approved monitoring plan.
Who Should Not Consider?
• Facilities that have conducted modeling with
favorable results.
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60. Ambient SO2 Monitoring
How do you decide where to site an
ambient SO2 monitor?
• Typically sighted using air dispersion
modeling (i.e., AERMOD).
• Should Consider multiple monitors if
possible.
Up-wind, down-wind, and other “hot
zones” (i.e., building downwash)
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61. Ambient SO2 Monitoring Pros
Pros
• Collection of monitoring data below the SO2
NAAQS.
• Monitoring data could be used to discount air
quality modeling results.
• Potentially avoid need for permit limits,
pollution controls, fuel restrictions, or shutting
down operations.
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62. Ambient SO2 Monitoring Cons
Cons
• Collection of monitoring data above the SO2
NAAQS.
• Potential changes to SO2 NAAQS SIP
maintenance process.
• Time involved.
• Cost
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64. Final Thoughts
States developing their modeling plans now
States will reach out to request information and/or modeling
Be involved with the SIP process:
• Provide states with good information
• Conduct your own modeling (either for the state or in
parallel with the state)
Avoid surprises (new limits) at the end of the SIP process
Consider collection of ambient SO2 monitoring data
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65. Questions?
Dan Dix
ddix@all4inc.com
(610) 933-5246 x18
2393 Kimberton Road
PO Box 299
Kimberton, PA 19442
All4 Inc.
www.all4inc.com
www.enviroreview.com
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Editor's Notes
Meteorologists – Affects everybody We are concerned you should concerned
Primary Secondary Column
Distinction between project requirment
State conducting modeling not modeling strategies.Why you should consider completing yourselves.SIP will include requirements and to change SIP requirement is very difficult. Not like change and TV permit limit.Deadline can slip but then Enviro Groups get involved.
States that are pushing back.
If States SIP fail to satisfy the SIP then EPA will likely implement a FIP
State doesn’t have these.
Limits on operating hours.
Receptor Spacing
Local Source Information. First strategy cut without local sources.
Figure out strategy. Maybe blinded by doing everything together.
Include – Top
NO PTE on an hourly basis. SIP Limit 500 ppm not realistic.
SODAR - Meteorological data
Similar. State does not complete this
Transition between Modeling and Monitoring.
Power, Secure Area
in preparing and obtaining agency approval for monitoring plan, installation, processing the data and interpreting the results.
Engineering includes sitting, plan development, regulatory correspondence, procurement of equipment States not setting up monitors.