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Modeling Challenges Case Study

This case study presents air quality modeling challenges faced during the establishment of a new ceramic poppant facility in rural Allendale County, SC. The project, categorized at 250 tons per year, analyzed significant emissions of PM10, PM2.5, SO2, NOx, CO, and VOCs. Various modeling methodologies, including AERMOD and exceedance analysis, were employed to evaluate compliance with National Ambient Air Quality Standards (NAAQS). Key findings included potential exceedances of several criteria pollutants, prompting further investigation and public feedback regarding environmental impacts and facility operations.

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Modeling Challenges Case Study

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  1. Modeling Challenges Case Study John Glass SC Bureau of Air Quality

  2. Background Information • New Ceramic Poppant Facility • 250 tpy category • Project Emissions: • PM10 : 317.3 tpy • PM2.5 : 213.1 • SO2 : 205.5 • NOx : 683.7 • CO : 1226.1 • VOCs : 250.5 • Fluorides: 0.4

  3. Background (cont.) • Location: Rural Allendale County, SC • Flat Terrain • SC/GA state line approximately 18 km • Other major facilities close by • Lumber Mill: • 141 tpy PM10, 82 tpy PM2.5, 257 tpy NOx • approx. 2 km SE • OSB Mill: • 600 tpy PM10/ PM2.5, 247 tpy SO2, 847 tpy NOx • approx. 11 km SE

  4. Modeling Details • Class I AQRV • Screened out using Q/D ≤ 10 • Class I Significant Impact • All but PM2.5 screened out using AERMOD at 50 km

  5. Modeling Details • Class II Significant Impact: • PM10: 24-hr - 2.04 km SIA, Annual - 1.5 km SIA • PM2.5: 24-hr - 3.8 km SIA, Annual - 2.2 km SIA • SO2: 1-hr - 2.2 km SIA • NO2: 1-hr - 12.9 km SIA, Annual - 12.9 SIA • Above SMC for PM10 and PM2.5 • Existing state data approved for background concentrations

  6. Modeling Details • Class I Full Impact Inventory • Only 1 other PM2.5 increment consuming facility • Class II Full Impact Inventory • Used 20D to screen background sources • Final inventory included: • Nearby major facilities (2 and 11 km SE) • Coal-fired power plant (5,506 tpy NOx) located approx. 46 km NE • Major coal-fired boilers on SRS (19,300 tpy SO2) located approx. 42 km NW

  7. Modeling Results • Full Impact Class I passed using 50 km results • Full Impact NAAQS • Passed NO2 Annual • Possible exceedances of several NAAQS • 24-hr PM10 • 24-hr and Annual PM2.5 • 1-hr SO2 • 1-hr NO2 • Full Impact Class II Increments • All pollutants passed easily

  8. NAAQS Modeling Results

  9. Exceedance Analysis • Facility ran AERMOD Maxi Event Files for exceedances • Event files indicated project facility not significant at any exceeding ambient receptor • Project facility passes modeling • Permit put on public notice • SC BAQ initiates investigation of exceedances

  10. PM10 24-Hr Results

  11. PM2.5 Annual Results

  12. PM2.5 24-Hr Results

  13. SO2 1-Hr Results

  14. NO2 1-Hr Results

  15. NO2 1-Hr Results

  16. Exceedance Analysis • SC BAQ performed more detailed investigation of sources causing exceedances • PM10 exceedances not in ambient air • PM2.5 ambient air exceedances caused by use of PM10 emissions • SO2 1-hr exceedances caused by double counting SRS emissions • NO2 1-hr ambient air exceedances caused by double counting OSB emissions

  17. Public Comments • Comments concerning zoning, noise, odor, disposal of dust from baghouse, etc. • Comments on BACT • Comments on predicted exceedances • Comments on omission of sources in GA • 8 Georgia sources had screened out • 1 proposed facility was erroneously left out of NO2 1-hr modeling • Facility submitted revised modeling

  18. Lessons Learned • Long Run Times • Glitches in MAX AERMOD • Consultants don’t read details of inventories • Lack of background data for 1-hr modeling • Consultants will leave you holding the bag • Check with neighboring states early if state line within screening area • Review takes a lot of time and resources

  19. Questions? John Glass 803-898-4074 glassjp@dhec.sc.gov

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