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Record Details
Alternative Model Techniques to Address Two Issues with Modeling Buoyant Line Sources in AERMOD
Record No: 18-IV-01 Last Update: 08/07/2018
EPA Region: | 4 | Fiscal Year: | 2018 | |
States: | SC | |||
Record Type: | Action | |||
Pollutants: | NO2 | Sources: | Steel Facility | |
Models: | AERMOD | Urban/Rural: | Both Urban & Rural | |
Terrain: | Both High & Low | Regulations: | PSD | |
Guideline: | Guideline | Database: | Both | |
Oral/Written: | Written | Involvement: | Review and Comment | |
Subjects: | Emissions Characterization Technical Credibility of Nonguideline Techniques |
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Comments: | ||||
Issue: Region IV is seeking concurrence from the Model Clearinghouseon on the use of an approach proposed by the State of South Carolina Department of Health and Environmental Control (SCDHEC) on behalf of Nucor Steel in Darlington, South Carolina, to address two issues within AERMOD (version 16216r) related to buoyant line sources. Region IV staff have reviewed the proposed approach and corresponding equivalency demonstration submitted by SCDHEC and has determined that it is justifiable and appropriate. C/H Response: The Model Clearinghouse has reviewed Region 4’s technical summary and recommendations for approving the use of an alternative model technique proposed by the SCDHEC to address two identified issues with modeling buoyant line sources using the preferred near-field model, AERMOD for the PSD compliance demonstration of the Nucor Steel facility in Darlington, South Carolina. First, the current version of AERMOD, version 16216r, is limited to a single group of buoyant line sources that are described with identical characteristics (e.g., requires an average building width, line length, and buoyancy parameter and assumes all lines are parallel to each other with an average separation distance), which creates a limitation in modeling a facility with multiple buoyant line sources with dissimilar characteristics in one model run. Second, the modeling consultant for the Nucor Steel facility identified a coding issue or bug within AERMOD that adds the modeled NO2 impacts from buoyant lines sources to other modeled NO2 impacts after the Tier 2 and 3 NO2 methodologies are applied to the modeled NOx concentrations from other source types. This results in an inappropriate NOx to NO2 conversion calculations for the modeling simulation. Both of these modeling issues are subsequently addressed through a multi-step alternative modeling technique using the AERPOST program as summarized by Region IV in your concurrence memorandum and more fully described in the documentation and equivalency demonstration provided by the SCDHEC. Considering that both Region IV and the Model Clearinghouse found equivalency consistent with Appendix W, Section 3.2.2(b)(1) for the alternative modeling technique proposed by the SCDHEC, we concur with Region IV on the alternative model approval. |
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Memoranda: | ||||
Memo: Model Clearinghouse Review of Alternative Model Techniques to Address Two Issues with Modeling Buoyant Line Sources in AERMOD for the PSD Compliance Demonstration of the Nucor Steel Facility in Darlington, South Carolina Dated: March 13, 2018 From: George Bridgers, Model Clearinghouse Director Air Quality Modeling Group, EPA To: Christopher M. Howard, Physical Scientist Air Analysis and Support Branch, Region 4 Memo: Model Clearinghouse Concurrence Request - AERMOD Buoyant Line Source Issue Resolution and Model Equivalency Demonstration Nucor Steel, Darlington, South Carolina PSD Air Quality Modeling Dated: February 27, 2018 From: Christopher M. Howard, Physical Scientist Air Data and Analysis Section Air Analysis and Support Branch Air, Pesticides & Toxics Management Division US EPA Region 4 To: George Bridgers, Director Model Clearinghouse Air Quality Modeling Group Office of Air Quality Planning and Standards US EPA Memo: Proposed Workaround Related to Buoyant Line Source Implementation Issues in AERMOD Dated: December 13, 2017 From: Richard Hamel Environmental Resources Management (ERM) To: John Glass South Carolina Department of Health and Environmental Control (SCDHEC) |