DSHW-2013-002866 - 0901a0688036968c

4/12/13 State of Utah Mail - RE: Air Dispersion Modeling Protocol Review
RE: Air Dispersion Modeling Protocol Review
Smith, Michael <[e-mail]> Tue, Apr 9, 2013 at 7:33 AM
To: Jeff Vandel <[e-mail]>
Cc: Brad Maulding <[e-mail]>, Eric Baiden <[e-mail]>
Jeff, -
The pages look fine to me. The "issues" appearto be addressed satisfactorily. Let me know ifyou need
TechLaw to submit a letter for the record.
Division of
Best, Solid and Hazardous Waste
Mike APS* ? 2013
From: Jeff Vandel [mailto:[e-mail]]
Sent: Thursday, April 04, 2013 1:59 PM ;
To: Smith, Michael
Cc: Brad Maulding; Eric Baiden
Subject: Fwd: Air Dispersion Modeling Protocol Review
Hello-
ATK has submitted the "change pages" we requested for the Feb. 2013 air dispersion protocol. Please take a
look at them when you get the chance, Mike and let us know what you think.
Thanks,
Jeff
Forwarded message
From: Palmer, Blair <[e-mail]>
Date: Wed, Apr 3, 2013 at 1:15 PM
Subject: RE: Air Dispersion Modeling Protocol Review
To: Jeff Vandel <[e-mail]>
Hi Jeff, attached are the updated pages to the Protocol. Let me know if the changes address the
comments given by Mike.
httDs://mail.gopgle.corTV^ 1/3
4/12/13 State of Utah Mail - RE: Air Dispersion Modeling Protocol Review
Thanks,
Blair
From: Jeff Vandel [mailto:[e-mail]]
Sent: Tuesday, March 19, 2013 9:30 AM
To: Palmer, Blair
Cc: Brad Maulding; Smith, Michael; Eric Baiden
Subject: Air Dispersion Modeling Protocol Review
Hi Blair-
Mike Smith has finished his review ofthe Feb. 22, 2013 protocol document. He reports that overall, the protocol
looks good. However, he has identified a few issues, which appear to be minor, that we would like ATK to
address by submitting some "change pages" for the protocol document. Mike's summary of his evaluation, and
his comments are pasted below:
"The document was reviewed to ensure all issues raised by Utah DEQ in previous reviews of ATK's
Addendum Air Dispersion Modeling Protocol have been adequately addressed in this latest revision.
The text ofthe Revised Hybrid Air Modeling Protocol reflects ATK's expected responses to the majority
of the issues raised by Utah DEQ in the technical review of the Addendum Air Dispersion Modeling
Protocol for Open Burning and Open Detonation at ATK Launch Systems in Promontory, Utah, submitted
by ATK in November 2012 (Hybrid Air Modeling Protocol).
However, TechLaw identified two issues during the technical review that require clarification. The
issues are outlined below.
1. The Revised Hybrid Air Modeling Protocol identifies all the locations of interest in the forthcoming
risk assessment but does not explain how these locations will be incorporated into the receptor
grids for air modeling. Section 4.4, Receptor Grids, presents a thorough discussion of receptor
grids for modeling NAAQS and air toxics impacts. However, the discussions for risk assessment
receptors presented in Sections 6.1 and 7.0 do little more than identify the receptors. Neither
Section6.1 nor 7.0 references the NAAQS/air toxics receptor grid discussion. Based on the
information provided it is not clear whether different grids will be generated for risk assessment
modeling or whether the risk assessment receptor locations will be integrated into the off-site grid
proposed for NAAQS/air toxics modeling. Additional information explaining how the risk
assessment receptor locations will be incorporated into the AERMOD modeling runs should be
provided. This information should reference Section 4.4 of the Revised Hybrid Air Modeling
Protocol and the discussion of the receptor grids for risk assessment presented in Section 4.6,
Receptor Networks, contained in Attachment C, Revised Section 4, ATK Air Dispersion Modeling
Protocol dated 2/7/2011, as appropriate. In lieu of submitting a new, revised protocol document,
https://mail.gc»gle.corrvYrBil/^
4/12/13 State of Utah Mail - RE: Air Dispersion Modeling Protocol Review
it is recommended that the expanded discussion be provided in Section 7.0 and only those pages
modified in response to this issue be submitted to Utah DEQ.
2. As of January 18, 2013, there is a new version of AERSURFACE that should be used in the hybrid
modeling effort. ATK should ensure the most recently available version of AERSURFACE (at the
time the air modeling analysis is performed) is used in the OB/OD hybrid modeling analysis.
Unless all AERSURFACE runs were completed before January 18, 2013, it is recommended that the
new version of the model be used in the OB/OD hybrid air modeling analysis. The changes to the
code appear significant and should improve accuracy and mitigate uncertainties associated with
the AERSURFACE model. It is recommended that the discussion in Section 4.2, Land Use and
Surface Characteristics, be modified to parenthetically note which version of AERSURFACE will be
used (as done in Sections 4.0 and 4.1 for AERMOD and AERMET, respectively). In lieu of
submitting a new, revised protocol document, ATK should submit only the pages modified in
addressing this issue to Utah DEQ."
In addition, there is a minor correction that should be made to Section 6.5. In the first paragraph, "Section 5.4"
should be replaced with Section 6.4. Page 19 could then be replaced. We're thinking that if ATK could address
these issues by a formal submittal of change pages, we could respond with a letter approving the air dispersion
protocol.
Please let me know ifyou would like to discuss this or have any questions,
Jeff
DISCLAIMER:
Statements made in this e-mail -do not constitute the official position of the
Executive Secretary of the Utah Solid and Hazardous Waste Control Board. If you
desire a statement of the Executive Secretary's position, please submit a written
request to this office, on paper, including copies of documents relevant to your
request.
https://mail.gcogle.conVmail/u/0/?ui=2&ik=72b7c801e2&«ew=pt&sea 3/3
4.0 AERMOD Input Data Processing
The latest version of USEPA's AERMOD model (version 12345) will be used for estimating
concentration and deposition of the vapor cloud on downwind receptors. AERMOD requires
processing of several key input parameters. These are discussed in this section.
4.1 Meteorological Data Processing
Five years (1997 through 2001) of on-site meteorological data obtained from the site have been
used in previous modeling. The same meteorological data will be used after reprocessing the
data for AERMOD using the latest version of the preprocessor, AERMET (version 12345).
Non-urban (i.e., rural) land use determined from previous modeling will be used in AERMET.
The five years (1997 through 2001) of on-site hourly meteorological data will be obtained from
the site in CD-144 format and will include wind speed, wind direction, temperature, and
barometric pressure monitored at the site along with concurrent ceiling height and opaque cloud
cover from Hill Air Force Base. Twice daily upper air data for Salt Lake City will be obtained in
Forecast Systems Laboratory (FSL) format from the National Oceanic and Atmospheric
Administration, Earth System Research Laboratory (NOAA/ESRL) Radiosonde Database. The
hourly surface meteorological observations will then be used along with the twice daily Salt
Lake City upper air data in the AERMET pre-preprocessor to develop surface and vertical profile
meteorological data bases for use in AERMOD. This processing will be conducted in accordance
with the latest USEPA AERMOD Implementation Guide dated March 19, 2009.
4.2 Land Use and Surface Characteristics
The surface characteristics to be used in processing the meteorological data in AERMET will be
developed using the EPA's AERSURFACE program (version 13016). The AERSURFACE
program requires the input of digital land cover data from the U.S. Geological Survey (USGS)
National Land Cover Data 1992 archives (NLCD92), which it uses to determine the land cover
types for the user-specified location. AERSURFACE matches the NLCD92 land cover
categories to seasonal values of albedo, Bowen ratio, and surface roughness. Values of surface
characteristics are calculated based on the land cover data for the area surrounding the site of the
surface meteorological data collection.
For this application, the land use data will be obtained for the area surrounding the ATK Launch
Systems site and will be used in AERSURFACE to generate values of albedo, Bowen ratio, and
surface roughness as a function of the four seasons (i.e. winter, spring, summer, and fall) and for
each of six 60-degree directional sectors. This approach of generating surface characteristics at
the site of the surface meteorological data collection is consistent with the latest EPA guidance
(i.e., AERMOD Implementation Guide dated March 19, 2009, Ref. 7.7).
Addendum
Air Dispersion Modeling Protocol 9 ATK Launch Systems
Promontory, Utah
be determined for each year at the on-site MEI, off-site MEI, and at each of the discrete receptors
and averaged to provide five-year averaged maximum 1-hour ADF values.
6.4 Annual ADF for Concentration
This will be determined individually from the 1-hour ADF concentration as follows:
ADFarmual
1-hr
8760
Where:
ADFannual -5
Maximum annual average concentration in u,g/m
Qannual Annual quantity of reactive wastes in OB/OD (lbs)
Qdaily Daily quantity of reactive wastes in OB/OD (lbs)
Maximum 1-hour ADF based on daily reactive wastes quantity ADFl-hr
8760 Number of hours per year
Note: The term [Qannual/Qdaily] represents the total number of days per year the
OB/OD events can occur to reach the annual permitted quantities.
Annual ADF will be calculated for each of the five years of meteorological data at each receptor
and averaged to provide five-year average annual values.
6.5 Annual ADF for Deposition
The procedure will be similar to the calculation of the annual ADF for concentration. First, the
1-hour ADF for deposition will be determined and then annual ADF will be determined using the
equation shown in Section 6.4 above.
Physical characteristics of particulates such as mass mean diameter, size distribution, and density
will be used as listed in previous deposition modeling by TetraTech.
Addendum
Air Dispersion Modeling Protocol 19 ATK Launch Systems
Promontory, Ulah
7.0 Receptor Grid
As discussed in Section 4.4, the NAAQS and air toxics analysis will utilize a Cartesian receptor
grid starting from the boundary of the facility and extending to 10 km from M-136 and M-225 in
all directions. The grid will have spacing of 100 meters up to a 3-km distance and a spacing of
500 meters between 3 km to 10 km. This receptor grid will also be used for determining the off-
site MEI locations in support of the risk assessment.
In addition to the off-site receptor grid, the risk assessment will also incorporate an on-site
receptor grid for determining the on-site MEI locations. The on-site receptor grid will consist of
a Cartesian grid with 100-m spacing to cover the area bounded by the facility property boundary.
The worker safety buffer zones, consisting of approximately a 2000-foot radius around the M-
136 location and approximately a 2,500-foot radius around the M-225 location will be excluded
from the on-site receptor grid when modeling each scenario, respectively. These buffer zones
represent the area from which field personnel are excluded during OB/OD events.
The site boundary will be included in both on-site and off-site receptor grids for consistency. As
identified in Section 6.1, the risk assessment will also consider sensitive receptors located in and
around the facility. Terrain elevations for each receptor will be obtained from national elevation
dataset files and running the preprocessor, AERMAP, as discussed in Section 4.3.
Addendum
Air Dispersion Modeling Protocol 20 ATK Launch Systems
Promontory, Utah