pm2.5 modeling for psd

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Dan Dix from ALL4 Inc., presented the following workshop on PM2.5 Measurement and Modeling for Compliance Demonstrations at the NCASI 2013 Northern Regional Meeting. The presentation includes: a review of PM2.5 modeling updates from the last 6 months, a case study of PM2.5 NAAQS modeling analysis from a pulp and paper mill, findings and recommendations from the case study, and general recommendations for PM2.5 modeling.

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  • 1. PM2.5 Modeling for PSD Presented to Workshop on PM2.5 Measurement and Modeling for Compliance Demonstrations by All4 Inc. Dan Dix | ddix@all4inc.com | 610.933.5246 x118 May 7, 2013www.all4inc.com Kimberton, PA | 610.933.5246 Columbus, GA | 706.221.7688

2. Agenda 2Review of PM2.5 modeling updates from the last 6 months. Case study of PM2.5 NAAQS modeling analysis from a pulp and paper mill. Findings & recommendations from case study. General recommendations for PM2.5 modeling.Your environmental compliance is clearly our business. 3. PM2.5 Modeling Updates 3December 14, 2012 U.S. EPA announced revised annual average PM2.5 National Ambient Air Quality Standards (NAAQS) reduced from 15 g/m3 to 12 g/m3. December 17, 2012 U.S. EPAs Office of Air Quality Planning and Standards (OAQPS) releases regulatory modeling update to AERMET and AERMOD (AKA Version 12345). January 22, 2013 DC Circuit Court vacated and remanded PM2.5 Significant Monitoring Concentrations (SMCs) and Significant Impact Levels (SILs). March 4, 2013 U.S. EPA OAQPS issues draft PM2.5 modeling guidance for regulatory applications that addresses secondary formed PM2.5.Your environmental compliance is clearly our business. 4. PM2.5 Modeling Updates 412 g/m3 Annual PM2.5NAAQS leaves very little room when included background concentrations of PM2.5 from State run ambient monitors for NAAQS modeling demonstrations. 35 g/m3 24-hour PM2.5NAAQS determined during review to be adequate. New Version of AERMOD/AERMET released December 17, 2013. New beta options for evaluating low wind speed events.Your environmental compliance is clearly our business. 5. PM2.5 Modeling Updates 5What does recent DC Court Decision mean for PSD modeling? PM2.5 Significant Impact Levels (SILs) (0.3 g/m3 & 1.2 g/m3) Vacated & Remanded. Permit Applicants should not rely alone on PM2.5 SILs. Need to also demonstrate that an increase below the SILs will not lead to a NAAQS violation. PM2.5 Significant Monitoring Concentration (SMC) (4 g/m3) Vacated. Must rely upon representative State ambient monitoring data. Much more scrutiny will be placed on whether the monitor is representative of the site. Although court decision addressed PM2.5 other pollutants will also be under same scrutiny for their respective SILs & SMCs. Your environmental compliance is clearly our business. 6. PM2.5 Modeling Updates 6PSD permits must now address secondary formed PM2.5 emission from precursors pollutants (i.e., NO2 & SO2) in NAAQS & PSD Increment air quality modeling demonstrations. Four (4) tiered approach for addressing secondary formed PM2.5 emissions laid out in guidance document based on which pollutants are greater than significant emission increase levels. Still time to comment since the comment period has been extended 45 days from May 31, 2013 to July 15, 2013.Your environmental compliance is clearly our business. 7. PM2.5 Case Study 7Pulp & Paper Mill AERMOD Fugitive Emissions Included Roadways Chip Piles Chip Drops Emergency Generators Included NWS Meteorological Data (w/AERMINUTE) 24-Hour and annual PM2.5 concentrations evaluated Large property boundary (No onsite receptors included) Building Downwash Included Rolling Terrain Your environmental compliance is clearly our business. 8. PM2.5 Case Study Emission UnitPeak 98th Percentile of Modeled 24Hour Concentrations ( g/m3)Natural Gas Fired Power Boiler1.63Recovery Furnace1.69Smelt Dissolving Tank7.98Lime Kiln15.93Slaker1.16Combination Boiler1.70Chip Drops (Fugitive)NegligibleStarch Silos16.90Chip Piles (Fugitive)1.92Paper Machine Dryers0.29Pulp Dryers42.15Emergency Generators7.72Roadways (Fugitive) 8115.80 Your environmental compliance is clearly our business. 9. PM2.5 Case Study Emission UnitPeak Annual Modeled Concentrations ( g/m3)Natural Gas Fired Power Boiler0.31Recovery Furnace0.31Smelt Dissolving Tank1.59Lime Kiln2.77Slaker0.16Combination Boiler0.31Chip Drops (Fugitive)NegligibleStarch Silos Chip Piles (Fugitive)0.23Paper Machine Dryers0.07Pulp Dryers6.74Emergency Generators0.82Roadways (Fugitive) 92.8516.90 Your environmental compliance is clearly our business. 10. PM2.5 Case Study 10Facility wide peak 98th percentile modeled 24-Hour and annual Concentration 129 g/m3 and 20.9 g/m3, respectively. WI DNR Regional Background Level for rural areas is 25.6 g/m3 for 24-hour PM2.5 and 8.7 g/m3 for annual PM2.5. 24-Hour PM2.5 NAAQS 35 g/m3 & annual PM2.5 NAAQS 12 g/m3. Not much room for facility contribution.Your environmental compliance is clearly our business. 11. PM2.5 Case Study 11Peak facility wide concentration being driven by roadway & low stack height sources (Lime Kiln-90ft/Pulp Dryers-46ft). Elevated concentrations from emergency generators due to horizontal release (no vertical dispersion accounted for in AERMOD from horizontal or rain capped sources). PM2.5 concentration driven by dispersion characteristics more than emission rates.Your environmental compliance is clearly our business. 12. PM2.5 Case Study 12So whats the facility doing to refine the PM2.5 NAAQS modeling analysis? Conducting surface/bulk dust loading sampling to develop site specific silt loading for roadway fugitive emission calculations (currently using default AP-42 silt loading levels). Turning emergency generators stacks from horizontal to vertical. Undertaking a meteorological monitoring program to develop a site specific dataset. Includes collecting data not collected by NWS (i.e., vertical winds speed/solar radiation) to enable AERMOD to more accurately predict PM2.5 concentrations.Your environmental compliance is clearly our business. 13. PM2.5 Modeling Recommendations 13What other things can facilities do to demonstrate compliance with the PM2.5 NAAQS? Avoid tripping PSD PM2.5 significant emission increase (i.e., 10 TPY) through over-control or emission reductions. PAL Evaluate your PM2.5 emission limits. Determine if a lower limit can be taken. NAAQS modeling demonstrations based on potential-to-emit (PTE) emission rates. PM2.5 ambient monitoring could be beneficial because representative site-specific background levels can be developed and not double-counted. Variability in how fugitive (especially roadway) emissions are characterized in AERMOD from state to state. Refer the Haul Road Workgroup Final Report to EPA-OAQPS for different Your environmental compliance is clearly our business. 14. Final Comments on PM2.5 Modeling 14Even though the results arent always favorable its always good to know where your facility stands with regard to all the NAAQS to help in long range planning at your facility. Allows your facility to identify issues that arent always obvious (e.g., smaller fugitive sources). Allows your facility to plan for activities that could substantially affect timing of projects (i.e., ambient pollutant or meteorological monitoring require a year of data). Consider input from counsel before undertaking air quality modeling/monitoring evaluations.Your environmental compliance is clearly our business. 15. PM2.5 Modeling for PSDDan Dix| ddix@all4inc.com | 610.933.52.46 x118www.all4inc.com Kimberton, PA | 610.933.5246 Columbus, GA | 706.221.7688

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