Report Template - Recinto de Arecibo

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Energy Answers Arecibo, LLC
PSD Air Quality Modeling Analysis
Amendment for NO2 During Startup
Periods
For the proposed
Arecibo Renewable Energy Project
Arecibo, Puerto Rico
Barrio Cambalache, Arecibo, Puerto Rico
Submitted February 2012
Energy Answers Arecibo
Renewable Energy Project
Arecibo, Puerto Rico
PSD Air Quality Modeling
Amendment for NO2 During
Startup
Prepared for:
Energy Answers Arecibo, LLC
Prepared by:
ARCADIS
801 Corporate Center Drive
Suite 300
Raleigh, North Carolina 27607
Tel 919.854.1282
Fax 919.854.5448
Our Ref.:
NCENRGY1.0005
Date:
February 2012
Table of Contents
1.0 Introduction
2
2.0 Project and Site Description
2
3.0 Approach
3
4.0 Source Description and Operating Scenarios
3
4.1 Boiler Operating Load Scenarios
4
4.2 Boiler Startup and Shutdown
4
4.3 Other Sources
5
4.4 Pollutants Evaluated
6
5.0 Modeling Methodology
6
5.1 Receptor Arrays
7
5.2 Source Input Data
7
6.0 Model Results for Evaluating Significance
9
6.1 Identifying the Significant Impact Area (SIA)
10
6.2 Full (Cumulative) Impact Analysis
10
6.2.1 Background Air Quality
11
6.2.2 Off-Site Source Inventory
11
6.3 Evaluating 1-hour NO2 Cumulative Impacts
13
7.0 Environmental Justice
13
8.0 References
15
Figures
2-1
Project Location Map
2-2
Site Location Map
2-3
Site Layout With Emission Points
A
Emission Rate Calculations
B
Air Modeling Files on DVD
Appendix
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PSD Air Quality
Modeling Analysis
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Emissions
1.0 Introduction
Energy Answers Arecibo, LLC (Energy Answers) is proposing to construct and operate
a 77 megawatt (MW) renewable energy facility at the former site of the Global Fibers
paper mill in Barrio Cambalache, Arecibo, Puerto Rico, referred herein as the Arecibo
Renewable Energy Project (AREP). Energy Answers prepared an application for PSD
permit to construct, including an ambient air impact analysis using air dispersion
modeling methods. The PSD application with a dispersion modeling analysis was
submitted to EPA Region 2 in February 2011. Following EPA’s release of an updated
version of the AERMOD dispersion model, a revised air modeling analysis was
submitted in July 2011 per the request of EPA Region 2. A revised modeling analysis
was submitted in October 2011 to address a change in potential emissions of
condensable particulate matter and also to address comments to the July submittal.
Potential elevated emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO)
during startup were subsequently evaluated in a submittal titled PSD Air Quality
Modeling Analysis – Amendment for Startup Periods (February 2012). Subsequent
changes to the potential emission rate of NOx during startup periods warranted further
analysis, which is the focus of this submittal.
The modeling analysis was completed in accordance with the modeling protocols
submitted in May 2011 and September 2011 (PM10/PM2.5 Addendum) and approved
July 5, 2011 and October 11, 2011.
2.0 Project and Site Description
The facility will be located in Barrio Cambalache, Municipality of Arecibo, Puerto Rico.
Figure 2-1 shows the location of the site on the island, and Figure 2-2 provides the
location of the site on a United States Geological Survey (USGS) topographic map.
The approximate UTM coordinates for the facility are 742.688 km E and 2,042.698 km
N (UTM Zone 19) with the design plant grade at approximately 20 feet (3.2 meters)
above mean sea level (MSL). The facility will be built such that the waste receiving,
waste processing, and energy recovery operations are conducted within the
boundaries of the site.
The topography in the immediate vicinity of the site is generally flat. The shoreline is
approximately 1 mile to the north. To the south, the terrain becomes hilly and
eventually mountainous (complex). A review of USGS 7.5-minute quadrangle map
indicates that most of the surrounding terrain within 5 kilometers (km) of the site is
below the proposed stack height. A scaled design site layout is provided in Figure 2-3.
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The nearest Class I area to the proposed plant site is the Virgin Island National Park on
the Island of St. John, located approximately 125 miles to the east.
3.0 Approach
This air quality analysis begins with a preliminary analysis of the significant increase in
potential emissions from a proposed new source. The results of the preliminary
analysis are compared with accepted interim significant impact levels (SIL) to
determine whether a full impact analysis is necessary and, if so, to define the area
where the analysis must be completed. If the preliminary analysis indicates that
predicted ambient air impacts are below the SIL, it is deemed insignificant or de
minimis, and no further analysis is required. Should potential air quality impacts
exceed the SIL, a full impact analysis must be conducted with respect to the NAAQS
and PSD allowable increments, including off-site emission sources. Per the approved
protocol, and consistent with prior modeling analyses submitted for this project, an
3
interim SIL of 7.5 µg/m for the 1-hour NO2 is used.
4.0 Source Description and Operating Scenarios
The proposed AREP will have the following air emission sources:
•
Two (2) spreader-stoker boilers with a maximum heat input rating of 500
MMBTU/hr each, equipped with three (3) 167 MMBTU/hr No 2 Fuel Oil-fired
burners each;
•
One (1) cooling tower, with 4-cells (air-cooled condenser type);
•
Fly and bottom ash transfer, processing and storage operations;
•
Three (3) Storage Silos (lime, pulverized activated carbon, flyash);
•
One (1) diesel fuel-fired emergency generator; and
•
One (1) diesel fuel-fired emergency firewater pump
Energy Answers proposes to install advanced air quality control systems that qualify as
the Best Available Control Technology (BACT) for its operations. Independently
operating air quality control systems will be proposed for each boiler, consisting of the
following technologies:
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
An activated carbon injection system to remove heavy metals, including
mercury and dioxins/furans;

A Turbosorp Dry Circulating Fluid Bed Scrubber system to remove acid
gases using lime injection

A fabric filter (baghouse) to control particulate emissions (including metals);
and,

A regenerative selective catalytic reduction (RSCR) system for reducing
emissions of NOx and CO.
4.1 Boiler Operating Load Scenarios
Under normal operating conditions, the boilers are expected to operate at an average
heat input rating of 500 MMBTU/hr each. For the purposes of this air quality impact
analysis, 500 MMBTU/hr is defined as the 100% load scenario. This analysis includes
multiple scenarios where one boiler is undergoing startup while the second is operating
at 80%, 100%, 110% load corresponding to 400 MMBTU/hr, 500 MMBTU/hr,
550MMBTU/hr, respectively, or is inactive.
In October 2011, Energy Answers submitted the PSD Air Quality Modeling Analysis
(Revised PM10/PM2.5 Analysis) to USEPA Region 2 which addresses each of these
operating scenarios under normal operating conditions. There are no changes to
normal operating conditions from what was modeled in October 2011. Details for
potential air quality impacts during normal operations are given in that report. This
analysis represents a revision to startup conditions only.
4.2 Boiler Startup and Shutdown
The proposed AREP will use No. 2 fuel oil for startup and shutdown, and intermittently
during short-term plant upsets in order to maintain boiler temperatures. Each boiler
unit will be started up using auxiliary burners firing No. 2 fuel oil (ultra low sulfur
content) to preheat the flue gas until the temperature can be maintained at or above
1800°F. At that point, processed refuse fuel (PRF) will be introduced into the boiler.
Energy Answers estimates that a cold start will take approximately 7 hours. Although
Energy Answers initially thought that the RSCR could be brought on line prior to firing
the fuel oil burners, the vendor has indicated that the RSCR will not begin to effectively
control both NOx and CO during the startup period. This is because the temperature of
the boiler flue will not be sufficient to enable proper atomization of ammonia for NOx
reduction. There are also concerns that the flue during startup will have a cooling
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effect on the catalysts for some portion of the startup period so they will not support the
chemical reactions necessary for controlling NOx. Emission calculations for startup
periods have been adjusted to account for these uncertainties, conservatively
assuming that no control by the RSCR is achieved during startup. The revised
emission calculations for startup are given in Appendix A.
For the purposes of this modeling demonstration, the emission rate of NOx during
startup was conservatively developed assuming that the oil burners our operating at
400 MMBTU/hr continuously for the entire 7 hour period. Due to the change in the
predicted maximum emissions of NOx from previous estimates, potential impacts of
NO2 on a 1-hour average are provided.
Shutdown is expected to take an estimated 6 hours or less to complete. During
shutdown events, the general procedure will be to stop feeding PRF and fire fuel oil
until the burnout of remaining PRF is completed and the grates are clear. Fuel oil
burners will begin firing when PRF feed has stopped. Energy Answers will take
measures to minimize emissions during shutdown by keeping the air quality control
system functioning until the grates are cleared of PRF and PRF burnout has been
completed. Emissions during the shutdown process are not subject to change at this
time. No additional limits from the proposed BACT for normal operations are
requested for shutdown. Therefore, no additional modeling has been completed for the
shutdown periods.
Modeling was completed for four potential startup scenarios: one each for the
emissions while one boiler is undergoing startup and the second boiler is inactive, or
operating at 80%, 100%, and 110% load. Energy Answers proposes to accept a timeof-day (TOD) restriction for initiating startup of either boiler. Startup will begin between
7:00 AM and 12:00 PM only. Also, simultaneous startup of the boilers will not occur. It
is understood that this proposed TOD limit is consistent with the recent EPA guidance
memorandum (USEPA 2011) issued for the purposes of conducting the air quality
impact analysis for the 1-hour NO2 and SO2 standards pursuant to the PSD permitting
requirements.
4.3 Other Sources
Emissions from the following sources have not changed from the October analysis:

Cooling Tower

Ash Processing Operations
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
Storage Silos

Firewater Pump

Emergency Diesel Generator

Fugitive Emissions.
Therefore, please reference the PSD Air Quality Modeling Analysis (Revised
PM10/PM2.5 Analysis) submitted in October 2011 for further details on emission
calculations, assumptions and model input information for these listed sources.
4.4 Pollutants Evaluated
The Facility will have a potential to emit CO, NO2, SO2, PM, PM10, PM2.5,VOC, Lead,
Beryllium, Fluoride, Mercury, Sulfuric Acid Mist, MWC Organics, MWC Acid Gases and
GHG. With the exception of lead, each of these is projected to exceed the applicable
PSD significant emission rate (SER) threshold. Potential emissions from the facility are
below the applicable PSD SER levels for all other PSD regulated pollutants listed in 40
CFR Subpart 52. Accordingly, the facility is subject to the PSD air quality impact
analysis requirements for CO, NO2, SO2, PM10 and PM2.5. There are no applicable
ambient air standards for the other constituents and, therefore, no air quality modeling
impact analysis is required. This analysis focuses on emissions of NOx during startup
periods.
5.0 Modeling Methodology
The modeling analysis was completed in accordance with the modeling protocols
submitted in May 2011 and September 2011 (PM10/PM2.5 Addendum) and approved
July 5, 2011 and October 11, 2011. Details regarding the model selection, land use
classification, receptor grid specifications, meteorological data set, receptor grid arrays,
Good Engineering Practice (GEP) stack height analysis, building downwash
parameters, and the background ambient air concentrations used for this analysis can
be found in the protocol documents and prior submittal dated October 2012.
Energy Answers used the most current version of EPA’s AERMOD (11353) dispersion
model to predict ambient concentrations in simple, complex and intermediate terrain.
The AERMOD Modeling System includes preprocessor programs (AERMET (11059),
AERSURFACE (updated January 2008), and AERMAP (11103)) to create the required
input files for meteorology and receptor terrain elevations. AERMOD is the
recommended model in USEPA’s Guideline on Air Quality Models (40 CFR Part 51,
Appendix W) (USEPA 2005).
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Per the recommendation of USEPA and the approved modeling protocol, one year of
meteorological data (August 1992 to August 1993) obtained from the Puerto Rico
Energy Power Authority (PREPA) facility in Cambalache Barrio (located within one mile
of the proposed AREP site) was used. The onsite parameters, as well as the National
Weather Service (NWS) surface and upper air input files for AERMOD were prepared
using the AERMET utility. Further details regarding the meteorological data can be
found in the May 2011 protocol.
5.1 Receptor Arrays
Coarse and fine grid receptors grids are used to evaluate potential impacts. The dense
grid is a Cartesian system that covers of 8 km by 8 km in area centered at the
proposed project location. Receptors begin at the project boundary. Receptor spacing
from the project boundary is specified as follows:

Inner grid = 25 m spacing out to a distance of 200 m;

Second grid = 50 m spacing out to a distance of 400 m;

Third grid = 100 m spacing to 0.5 km;

Fourth grid = 500 m spacing out to a distance of 4 km;

Outer grid = 1,000 m spacing out to a distance of 8 km.
The coarse grid also includes a polar coordinate grid extending out to 24 km from the
center of the project location. Grid radials are spaced every ten degrees and rings are
placed at 1-km intervals beginning 2 km from the project location center. Receptor
elevations are assigned using the EPA’s AERMAP software tool (version 11103),
which is designed to extract elevations from USGS National Elevation Dataset data at
1 degree (approximately 90 m) resolution in GeoTIFF format (USGS 2002). While 7.5minute DEM data would be preferable for better resolution, these data are not available
for Puerto Rico. The one degree datum is acceptable internationally and adequately
captures changes in elevation such as the mountainous region southwest of the
subject site.
5.2 Source Input Data
The air dispersion model program AERMOD requires the input of certain site-specific
data to produce results that are representative of the actual site conditions. These data
include stack coordinates, height, diameter, emission rates, exit temperature and exit
velocity. The primary sources of emissions at the new facility are the boiler units. The
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boiler emissions will be exhausted from a tall stack which contains two identical flues
(one for each of the two identical boilers). The two identical flues will be adjacent to
each other within an outer concrete shell. Table 5-1 provides a list of these data for the
maximum, (110% firing rate), average (100% firing rate), and minimum (80% firing
rate) operating scenarios. Note that the emission rates represent the worst case
emissions regardless of the fuel mix including the proposed supplemental fuels.
Emission rates from normal operating conditions remain unchanged from the October
2011 analysis PSD Air Quality Modeling Analysis (Revised PM10/PM2.5 Analysis).
Figure 2-3 shows the approximate location of each modeled emission point.
Table 5-1 Source Input Parameters – Normal Operations
Source ID
Vent #
Stack
Diameter
(m)
110%
Boilers 1 &
2
P-5
(each unit -
P-6
100%
95.52
2.13
80%
normal ops)
(a)
Load
Stack
Height
(m)
Exit
Velocity
(m/s)
Temperature
(K)
NOx
(g/s)
32.17
434.82
5.53
29.09
429.82
5.04
22.35
424.82
4.05
Gen
P-16
(c)
10
0.152
99.4
779
0.032(c)
Firepump
P-17
(c)
10
0.152
49.2
708
0.016(c)
A 50% operating factor is applied to the emergency generator and fire water pump to reflect a 30
minute duration of routine equipment testing.
Whereas the flues were merged for the modeling analysis submitted in October 2011
for normal operations, each flue is modeled separately for the purposes of this
demonstration for startup. This was necessary since it is no longer appropriate to
merge flues when the exit velocities differ appreciably as they will during startup. The
following four startup conditions were identified and modeled:
1. One boiler in startup; The second boiler inactive (0% load)
2. One boiler in startup; The second boiler at minimum (80%) load.
3. Once boiler in startup; The second boiler at average (100%) load.
4. One boiler in startup; The second boiler at maximum (110%) load.
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Emission rate data and stack flow and temperature data for the boiler startup phases
are provided in Table 5-2 and in Appendix A.
Table 5-2 Source Input Parameters – Boiler Startup
Stack
Height
(m)
Stack
Diameter
(m)
Exit
Velocity
(m/s)
Temp
(K)
NOx
(g/s)
95.52
2.13
21.93
416
8.64
6.0 Model Results for Evaluating Significance
Following USEPA guidance (USEPA, 1990), a preliminary analysis was conducted to
determine if the NOx emissions from the proposed facility during startup resulted in a
significant impact on ambient air quality. A time of day restriction is requested for
initiating the 7 hour startup, beginning between 7:00 AM and 12:00 PM. Table 6-1
provides maximum results for startup under the multiple scenarios. Results in Table 61 are limited to the 1-hour NO2 due to the relatively short period that the boilers
undergo startup.
Table 6-1: Model Results - Significant Impact Levels Evaluation – Boiler Startup
2nd Boiler
Operating
Level
Averaging
Period
Class II SIL
(µg/m3)
Maximum
Concentration
(µg/m3)
UTM
Northing
(meters)
UTM
Easting
(meters)
Distance from
Stack
(meters)
110%
1
7.5
86.6
742302.13
2043051.00
619
100%
1
7.5
87.0
742352.13
2043051.00
594
80%
1
7.5
86.8
742352.13
2042951.00
1452
0%
1
7.5
60.0
742352.13
Includes a 0.8 default ambient ratio per March 01, 2011 Modeling Guidance Memo..
2042951.00
1452
Parameter
NO2 a
(a)
Since maximum impacts of NO2 on a 1-hour basis were found to exceed the SIL, an
additional full impact multi-source analysis is required. The full impact analysis for NO2
on a 1-hour average is discussed in the following sections. Note that the annual
averaging periods are not relevant when modeling startup conditions and, therefore,
are not evaluated as part of this demonstration.
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6.1 Identifying the Significant Impact Area (SIA)
Considering the probabilistic form of the standard and commentary provided in the
March 1, 2011 USEPA memo regarding intermittent emissions and the overly
conservative representation of intermittent emissions when modeling them as if they
occur every day over the 1-year period (as in this case), there is a heightened degree
of conservativism when evaluating SIA distances for NO2 during startup. As discussed
in the referenced memorandum, the over-estimation is due to the improbable
circumstance that the maximum emissions during the startup process occur on the
worst-case meteorological hour when in fact, the facility is restricted to only 32 startups
per year for both boilers combined. The calculated maximum SIA distance for this
analysis is approximately 9 km based on the distances for the maximum, or highest
first-high, 1-hour impacts among the various load scenarios as determined from the
preliminary impact analysis. Note that the Ambient Ratio Method (ARM) is applied for
the SIA evaluation.
6.2 Full (Cumulative) Impact Analysis
A cumulative air modeling analysis was completed in accordance with EPA’s Guideline
on Air Quality Models (40 CFR 51 Appendix W) to demonstrate compliance with the 1hour NAAQS for NO2. This 1-hour cumulative modeling analysis is required following
the SIL evaluation described above in which potential concentrations of NO2 were
found to exceed the respective interim SIL on the 1-hour averaging period as shown in
Table 6-1. In the cumulative modeling analysis, emissions from existing off-site
sources and representative background concentrations are included to assess the
ambient impact at the receptor location within the SIA. The 8th highest daily 1-hour
maximum concentration at each receptor (98th percentile) was used for comparing the
impacts to the 1-hour NO2 NAAQS.
If the full impact analysis indicates a potential modeled exceedance, the determination
as to whether the proposed facility may potentially cause or contribute to this modeled
exceedance may be based on both spatial (at locations where the SIL is exceeded)
and temporal (at the time of a potential modeled exceedances in terms of year, month,
day, and hour) conditions. This is demonstrated (where necessary) by using the
MAXDCONT report generated by AERMOD.
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6.2.1 Background Air Quality
Background air monitoring data must also be evaluated for the purposes of conducting
a cumulative (full) impact analysis for demonstrating that potential emissions do not
result in an exceedance of the NAAQS. Per USEPA recommendation and the
approved modeling protocol, the most recent three years of background data is
referenced for the 1-hour NO2 impacts. For the purposes of this analysis, a tiered
approach was followed in accordance with the recommendations made in the March 1,
1
2011 guidance memorandum (USEPA 2011). The following tiers were used for
developing a conservative representation of background concentrations for conducting
the cumulative 1-hour assessments (as described in the modeling protocol approved
by EPA):
Tier 1:
Maximum 1-hour value in recent 3 years;
Tier 2:
3 year average of the maximum 1-hour values in each year of the
most recent 3 years;
Tier 3:
3 year average of the 98 percentile of the daily maximum 1-hour
concentrations of NO2.
th
The tiered approach provides a mechanism for progressively evaluating ambient
concentrations using a simple conservative assumption (Tier 1) to a more data
intensive statistical computation (Tier 3). For this analysis, a background value of 65.2
3
µg/m is used for NO2 calculated from the most recent 3 year period (2005-07) from the
monitor in Catano (Monitor ID 72-033-0008) according to the Tier 2 approach. This
value is unchanged from the value used for the October 2011 analysis.
6.2.2 Off-Site Source Inventory
Per the EPA’s Draft New Source Review Workshop Manual (October 1990), the scope
of the off-site sources that must include in a cumulative impact analysis, starts by
defining the SIA. This was done in the process of completing the SIL evaluation
described above. Initial air dispersion modeling in the February 2011 PSD application
indicates that the predicted maximum impacts for NO2 that are equal to and greater
1
The modeling protocol included an additional tier, but based on comments in the EPA approval letter of July
5,2011, only three tiers are included.
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than the interim 1-hour SIL occurred out to a distance of approximately 11 km from the
site. As a result, major and minor facilities within this distance from the site were
identified and incorporated in the full impact analysis, and the major sources that are
located within an additional 50 km past the pollutant-specific SIA distance must be
evaluated.
The process of identifying potential off-site sources included in this analysis started by
consulting the PREQB Air Quality Division and USEPA Region 2. Energy Answers
reviewed permit files, including copies of the air permits and permit applications.
Energy Answers also coordinated with PREQB on obtaining necessary modeling input
data directly from some of the sources via data requests made by PREQB. In addition
to these efforts, the EPA’s Air Facility System and National Emissions Inventory
databases were searched for major sources in the modeling inventory area. The offsite source inventory is unchanged from the inventory used for the October 2011
analysis.
The following sources were previously determined to have an insignificant
concentration gradient in the AREP project study area. Please refer to the October
2011 modeling analysis for further details regarding the AERSCREEN evaluation of
these sources completed in support of this conclusion.
Table 6-2: AERSCREEN Model Results for Sources Located to the South of the
Central Mountain Range
Source
Location
Distance to
Maximum
Concentration
(m)
Approximate
Distance to
Project Area
(m)
Cemex de Puerto
Rico, Inc.
Ponce
477
49,000
Destilleria Serralles
Ponce
1,376
51,200
Ecoelectrica LP
Penuelas
6,550
53,600
PREPA Costa Sur
Guayanilla
3,780
51,200
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6.3 Evaluating 1-hour NO2 Cumulative Impacts
Multisource modeling was completed for all receptors used in the preliminary analysis.
The MAXDCONT utility is relied upon for determining whether the proposed AREP is a
3
significant contributor (i.e. contributing 7.5 µg/m or more) to the cumulative impact at
th
the times and locations of predicted exceedances. The 8 highest value is taken,
adjusted by a factor of 0.8 per the Tier 2 Ambient Ratio Method (ARM), and then added
to the background concentration. In executing the model, the adjustment per the ARM
3
3
was made by specifying a threshold value of [(188 μg/m – 65.2 μg/m ) ÷ 0.8 = ] 153.5
for the MAXDCONT report. As discussed in Section 6.2.1, the background value is
taken as the 3-year average of the maximum 1-hour values measured between 20052007 at the monitor in Catano, PR. A review of the MAXDCONT table indicates that
there are no modeled exceedances of the standard at the receptors and times when
the potential AREP impacts are significant. When exceedances are predicted to occur,
the proposed AREP is shown to have an insignificant contribution.
A secondary model run was executed for each startup scenario in order to demonstrate
that the proposed AREP does not cause or contribute to a potential exceedance at
th
rankings lower than the 8 highest. The additional runs were limited to include only the
th
receptors where potential exceedances continued to occur at rankings below the 8
highest. This was done so that the model output files were kept to a reasonable and
manageable size.
This modeling analysis confirms that the proposed AREP will not cause or contribute to
a violation of the NAAQS during any of the startup scenarios at the proposed emission
rates. All model input and output files are provided on DVD in Appendix B. It should
be noted that the results reported in the MAXDCONT tables show exceedances at
different levels and locations than the October 2011 analysis because the receptor field
in this analysis was not limited to only those where Energy Answers is significant. All
receptors as described in Section 5.1 were included.
7.0 Environmental Justice
Energy Answers prepared an Environmental Justice Evaluation for the proposed
AREP, which consolidates several analyses and public outreach efforts made in and
around the Arecibo area. This evaluation is supplied to EPA under separate cover at
the time this report is submitted. The Environmental Justice study was performed
following the EPA guidelines and definitions. The EPA defines the concept of
environmental justice as the fair treatment and meaningful involvement of all people
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regardless of race, color, national origin, or income with respect to the development,
implementation, and enforcement of environmental laws, regulations, and policies.
The main purpose the analysis is to evaluate whether the community that the proposed
project will be located is an environmental justice community given its race and/or
origin or rather that the proposed community is considered economically
disadvantaged when compared to other areas.
Energy Answers has taken extensive measures related to Public Outreach, which are
described in the Environmental Justice Evaluation. Additionally, Energy Answers
prepared an environmental justice study as part of the Environmental Impact
Statement (EIS) for the development of the proposed AREP. These studies were
performed in compliance with the Environmental Quality Board, “Regulation for
presentation, evaluation, and procedures of environmental documents,” Regulation No.
6510.
The proposed AREP is located in Cambalache and the predicted maximum impacts
from the proposed AREP during startup are located in the immediate vicinity of the
facility (within 1452 meters of the boiler stack – see Table 6-1). The findings of the
Environmental Justice Evaluation submitted to USEPA Region 2 in October 2011
indicate no disproportionate impacts are predicted to occur in the low-income barrios
around Arecibo. The findings of this evaluation are consistent with the conclusions
drawn from the October 2011 analysis.
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8.0 References
Auer, August H. Jr. 1978: “Correlation of Land Use and Cover with Meteorological
Anomalies.” Journal of Applied Meteorology, pp 636-643. 1978.
Alaska Department of Environmental Conservation (ADEC). 2009. “ADEC Guidance
re AERMET Geometric Means.” Revised April 7, 2009.
PREQB, 1993. “Source Specific Acidic Deposition. Impacts for Permit Applications,”
L. Sedefian. March 4.
PREQB. 1997. Policy DAR-1: Guidelines for the Control of Toxic Ambient Air
Contaminants. November.
PREQB. 2006. PREQB DAR-10: Guidelines on Dispersion Modeling Procedures for
Air Quality Impact Analyses. May.
Schulman, et al. 1997. “The PRIME Plume Rise and Building Downwash Model,”
Addendum to ISC3 User’s Guide. November.
United States Environmental Protection Agency (USEPA). 1980. “A Screening
Procedure for the Impacts of Air Pollution Sources on Plants, Soils and
Animals.” EPA 450/2-81-078. December 12.
USEPA. 1987. Ambient Monitoring Guidelines for Prevention of Significant
Deterioration, EPA-450/4-87-007. Revised May 1987. Research Triangle
Park, NC.
USEPA. 1990. Draft EPA NSR Workshop Manual: PSD and NonAttainment Area
Permitting Manual. October.
USEPA. 1995. User's Guide To The Building Profile Input Program. EPA-454/R-93038. Revised February 8, 1995.
USEPA. 1996. PCRAMMET User’s Guide. EPA-454/B-96-001. OAQPS, Research
Triangle Park, NC.
USEPA. 2000. Meteorological Monitoring Guidance for Regulatory Modeling
Applications. EPA-454/R-99-005. OAQPS, Research Triangle Park, NC.
15
Energy Answers
PSD Air Quality
Modeling Analysis
Revised for NO2 Startup
Emissions
USEPA. 2004a. User's Guide for the AMS/EPA Regulatory Model – AERMOD. EPA454/B-03-001. September.
USEPA. 2004b. User's Guide For The AERMOD Terrain Preprocessor (AERMAP).
EPA-454/B-03-003. October.
USEPA. 2005. Guideline on Air Quality Models. November.
USEPA. 2008. AERSURFACE User’s Guide. EPA-454/B-08-001. OAQPS,
Research Triangle Park, NC.
USEPA. 2010a. Notice Regarding Modeling for New Hourly NO2 NAAQS. Office of
Air Quality Planning and Standards (OAQPS), Air Quality Modeling Group
(AQMG). February 25.
USEPA. 2010b. Modeling Procedures for Demonstrating Compliance with PM2.5
NAAQS. Office of Air Quality Planning and Standards (OAQPS).
Memorandum from Stephen D. Page to Regional Air Division Directors dated
March 23, 2010.
USEPA. 2010c. General Guidance for Implementing the 1-hour NO2 national Ambient
Air Quality Standard in Prevention of Significant Deterioration Permits,
Including an Interim 1-hour NO2 Significant Impact Level. Office of Air Quality
Planning and Standards (OAQPS). Memorandum from Anna Marie Wood to
Regional Air Division Directors dated June 28, 2010.
USEPA. 2010d. Applicability of Appendix W Modeling guidance for the 1-hour NO2
National Ambient Air Quality Standard. Office of Air Quality Planning and
Standards (OAQPS). Memorandum from Tyler Fox to Regional Air Division
Directors dated June 28, 2010.
USEPA. 2010e. Guidance Concerning Implementation of the 1-hour NO2 NAAQS for
the Prevention of Significant Deterioration Program. Office of Air Quality
Planning and Standards (OAQPS). Memorandum from Stephen D. Page to
Regional Air Division Directors dated June 29, 2010.
16
Energy Answers
PSD Air Quality
Modeling Analysis
Revised for NO2 Startup
Emissions
USEPA. 2010f. Guidance Concerning the Implementation of the 1-hour SO2 NAAQS
for the Prevention of Significant Deterioration Program. Office of Air Quality
Planning and Standards (OAQPS). Memorandum from Stephen D. Page to
Regional Air Division Directors dated August 23, 2010.
USEPA. 2010g. General Guidance for Implementing the 1-hour SO2 National
Ambient Air Quality Standard in Prevention of Significant Deterioration
Permits, Including an Interim 1-hour SO2 Significant Impact Level. Office of
Air Quality Planning and Standards (OAQPS). Memorandum from Anna Marie
Wood to Regional Air Division Directors.
USEPA. 2010h. Applicability of Appendix W Modeling Guidance for the 1-hour SO2
National Ambient Air Quality Standard. Office of Air Quality Planning and
Standards (OAQPS). Memorandum from Tyler Fox to Regional Air Division
Directors dated August 23, 2010.
USEPA. 2011. Additional Clarification Regarding Application of Appendix W Modeling
Guidance for the 1-hour NO2 National Ambient Air Quality Standard. Office of
Air Quality Planning and Standards (OAQPS). Memorandum from Tyler Fox
to Regional Air Division Directors dated March 1, 2011.
United States Geological Survey (USGS). 2002. The National Map – Elevation, Fact
Sheet 106-02. http://egsc.usgs.gov/isb/pubs/factsheets/fs10602.html, U.S.
Department of the Interior. November.
17
Figures
I
AT L A N T I C O C E A N
SITE LOCATION
Dorado
Isabela
Aguadilla
Camuy
Hatillo
Loíza
#
*
Vega Baja
Manatí
Toa Baja
Arecibo
San Juan
Fajardo
Carolina
Moca
Luquillo
Toa Alta
Aguada
Rincón
San Sebastián
Morovis
Lares
Añasco
Río Grande
P
u
Ciales
Utuado
e
r
t
Las Marías
Jayuya
Corozal
o
R
i
Comerío
Orocovis
o
Juncos
Ceiba
Naguabo
Cidra
Adjuntas
San Germán
Humacao
San Lorenzo
Aibonito
Villalba
Cayey
Coamo
Yauco
Yabucoa
Peñuelas
Cabo Rojo
c
Caguas
Mayagüez
Maricao
Gurabo
Naranjito
Ponce
Patillas
Juana Díaz
Salinas
Lajas
Maunabo
Guayama
Santa Isabel
0
10
20
Miles
PROJECT NUMBER:
CITY:NOVI DIV/GROUP:ENV
DB:
PIC:
PM:
TM:
TR:
Arroyo
Guánica
ENERGY ANSWERS INTERNATIONAL, INC.
ARECIBO, PUERTO RICO
PROJECT LOCATION MAP
FIGURE
2-1
I
TM:
TR:
SITE LOCATION
0.4
0.8
PM:
0
PROJECT NUMBER:
CITY:NOVI DIV/GROUP:ENV
DB:
PIC:
Miles
SITE LOCATION
ENERGY ANSWERS INTERNATIONAL, INC.
ARECIBO, PUERTO RICO
#
*
SITE LOCATION MAP
P
P uu ee rr tt oo
R
R ii cc oo
FIGURE
2-2
Appendix A
Emission Rate Calculations
APPENDIX A
ENERGY ANSWERS ARECIBO
Potential Emissions Calculations
During Startup
Firing No. 2 Fuel Oil
Time Elapsed
0 - 7 hours:
Average Heat Input
400 MMBTU/hr
No. 2 Fuel Oil Heating Value:
Fuel Use Rate - 80% load:
Pollutant
% Load
80
Flow (ACFM)
166,126
(DSCFM)
99,610
Temp (F)
290
140000 BTU/gal
2857 Gal/hour
Emission
Factor
lb/1000 gal
lb/hr
Emission Rate
g/s
mg/dscm
ppmvd
PM
Filterable
2.0
5.71
7.20E-01
0.4337
---
PM10
PM10
PM10
PM2.5
PM2.5
PM2.5
SO2
NOx
VOC
Filterable
1.0
1.3
2.3
0.25
1.3
1.55
0.213
24
0.2
2.86
3.71
6.57
0.71
3.71
4.43
0.61
69
0.57
3.60E-01
4.68E-01
8.28E-01
9.00E-02
4.68E-01
5.58E-01
7.67E-02
8.64E+00
7.20E-02
0.2168
0.282
0.499
0.05421
0.282
0.336
-------
------------0.6
90
0.78
5.0
---
14.3
---
1.80E+00
0.329
---
31
5.60E-04
2.75E-03
4.20E-04
4.20E-04
4.20E-04
8.17E-04
3.73E-02
4.80E-02
1.26E-03
8.40E-04
4.20E-04
2.36E-04
3.33E-04
4.20E-04
3.30E-03
2.10E-03
7.97E-02
1.40E-03
1.60E-03
7.86E-03
1.20E-03
1.20E-03
1.20E-03
2.34E-03
1.07E-01
1.37E-01
3.60E-03
2.40E-03
1.20E-03
6.74E-04
9.51E-04
1.20E-03
9.43E-03
6.00E-03
2.28E-01
4.00E-03
2.02E-04
9.90E-04
1.51E-04
1.51E-04
1.51E-04
2.94E-04
1.34E-02
1.73E-02
4.54E-04
3.02E-04
1.51E-04
8.50E-05
1.20E-04
1.51E-04
1.19E-03
7.56E-04
2.87E-02
5.04E-04
Condensable
Total
Filterable
Condensable
Total
CO
Ammonia Slip - 10 ppmv @ 7%O2 - 5.5- 7.0 hr
HAP
Arsenic
Benzene
Beryllium
Cadmium
Chromium
Ethylbenzene
Fluoride
Formaldehyde
Lead
Manganese
Mercury
Methyl Chloroform
Naphthalene
Nickel
POM
Selenium Compounds
Toluene
Xylenes
Notes:
1) Emission factors taken from AP-42 "Compilation of Air Pollutant Emission Factors", 5th edition, Tables 1.3-1 and 1.3-2.
2) Sulfur content = 15 ppmw
Appendix B
Air Modeling Files on DVD