Loading...
HomeMy WebLinkAboutDSHW-2013-006087 - 0901a068803cc1c3State Department of Environmental Quality Amanda Smith Erecutive Director DIVISION OF SOLID AND HAZARDOUS WASTE Scott T. Anderson Director Solid rDd HazardoNWrste Control Borrd Kevin M!ft^y, C hoir Dennis Riding, I/r'ce-Crat Eugene Col€, DIPH JeffCoombs, MPH, LEHS Mark Franc Brett Mickelson Amanda Smith Shane Whihey Dwayne Woolley Scott T. Anderson Executive Secrctory GARY R. HERBERT SPENCER J, COX Lieuterant Gorenor November 19.2013 George Gooch, Manager ATK Environmental Services ATK Launch Systems - Promontory P.O. Box 707 Brigham City, UT 84302-0707 RE: Air Dispersion Modeling Report Addendum for Open Burning and Open Detonation ATK Launch Systems - Promontory Facility uTD009081357 Dear Mr. Gooch: The Division of Solid and Hazardous Waste has completed its review of the Air Dispersion Modeling Addendum Report for open burning and open detonation at the ATK Promontory facility. Comments are enclosed. This modeling was conducted with a hybrid approach that utilized preliminary modeling work conducted with OBODM and dispersion modeling that was conducted with the EPA prefened model AERMOD. In general, the Hybrid Air Dispersion Modeling Report appears to follow the methodology outlined in the 2013 Addendum Air Dispersion Modeling Protocol for Open Burning And Open Detonation at ATK Launch Systems in Promontory, Utah Hybrid Air Dispersion Modeling Protocol. However, some sections ofthe report text lack the level ofdetail necessary to determine how portions ofthe air modeling analysis (e.g., calculation ofthe emission rates listed in Tables 4 -2, 4-3, 4-5, and 4-6) were completed. The enclosed general and specific comments identify the areas of the text where additional information is needed as well as specifying the type of information that should be provided. Please provide responses to the enclosed comments on or before December 20,2013. Ifyou have any questions, please call JeffVandel at (801) 536-0257. 195 Norrh 1950 West - Salt Lake City,I-IT Mailing Address: P.O. Box 144880. Salt Lake City, L_fT 841144880 Telephone (Eol) 5364200. Fax (801) 536{222. T.D.D. (801) 536-44t4 r&xo.dcq ah.gov Pdnted on I 00% recycled paper Division of Solid and Hazardous Waste DSHW-2013406087 Page 2 STA/JV/KK Enclosure c: Blair Palmer, ATK Launch Systems Paul Hancock, ATK Launch SYstems Cheryl Overskeet, EPA Region 8 Grant Koford, EHS, Environmental Health Director, Bear fuver Health Deparhnent UTAH DIVISION OF'SOLID AI{D HAZARDOUS WASTE TECTINICAL REVIEW OF' ADDENDUM AIR DISPERSION MODELING REPORT F'OR OPEN BURNING AND OPEN DETONATION AT ATKLAUNCH SYSTEMS IN PROMONTORY. UTAH JUNE 2OI3 The following comments were generated based on an evaluation of the Addendum Air Dispersion Modeling Report for Open Buming and Open Detonation at ATK Launch Systems in Promontory, Utah dated Jure 2013 (Hybrid Air Modeling Report). GENERAL COMMENTS: 1. The third sentence of the first paragraph in Section 4.3.1, Open Buming, indicates that cloud diameter for OB was assumed to be four times the equivalent diameter of the bum pans with the equivalent diameter calculated from the total area covered by the reactive waste to te treated. No other information regarding the determination of the vapor cloud diameter for OB is provided. In addition, Section 4.3.2, Open Detonation, states the initial dimension ofthe vapor cloud for OD operations was obtained directly from OBODM for each combination of wind speed category and atrnospheric stability. Based on the information currently provided, it is not clear why this same approach was not used to determine the vapor cloud diameters for OB operations as the text does not indicate that OBODM carurot calculate the initial release diameter for quasi-continuous releases (i.e., open bums). Please revise Section 4.3.1 to explain how the equivalent diameter is calculated from the total area covered by reactive waste. The explanation should be accompanied by an example calculation. In addition, a table of all the vapor cloud diameters used in the OBODM of OB operations should be included in the text. Finally, please ensure that the expanded discussion notes this approach for estimating the vapor cloud diameter was proposed in the March 2013 Hybrid Air Modeling Protocol and discussed with the Division of Solid and Hazardous Waste. 2. Based on the information available in Attachment 4, Modeling Inputs/Outputs, it is not clear that all AERMOD files used in the hybrid air modeling analysis have been submitted to the Division. Please review the files already submitted and determine ifadditional files should be provided. For example, it is not clear that the AERMOD output files containing the air concentrations and deposition fluxes (based on a unit emission rate) that will be used in the risk assessment have been submitted for review. Please revise Attachment 4 to ensure all modeling files used in the assessment of ambient air quality impacts and to be used in the risk assessment are submitted to the Division. 3. The protocols and preliminary modeling that the hybrid modeling is based on should be clearly identified either in the Introduction or Section 2.0 of the report. For example, in Section 3.1, at the bottom of page 4, it states that "The NAAQS modeling used emission rates from the preliminary modeling," but the preliminary modeling report is not referenced. In addition, the protocol for the preliminary modeling is mentioned at the beginning ofparagraph four, but the document is not referenced. Also, please add "ODOBi test chamber" to the fourth paragraph in the Introduction where the Dugway Proving Ground Bang Box is discussed to clarify that the emission factors are based on data collected at the ODOBi test chamber. SPECIFIC COMMENTS: 1. Section 3.1, NAAQS Analysis, Page 4: The first end note to Table 3-1, Criteria Pollutants Considered in NAAQS Compliance Demonstration, indicates that carbon monoxide (CO) and lead (Pb) NAAQS were not included in the NAAQS analysis because previous modeling had demonstrated compliance with NAAQS. No additional information on the previous modeling analysis is provided. Please revise this end note to include a reference to the regulatory report containing the modeling that demonstmtes compliance with the NAAQS for CO and Pb. 2. Table 3-3, Acute and Chronic Air Toxic Screening Levels, Page 6: It appears that the Utah TSLs listed for acrylonitrile, benzene, arsenic and cobalt may be incorrect based on a comparison to the 2012 ACGIH - TSLs and ETVs - Final Table that is currently used by the Utah Division of Air Quality. Based on this Table, it appears that the TSLs should be as follows: Acrylonitrile - 145 ug/mr Benzene ------ l8 ug/m' Arsenic--------- 0.1 I uglmr Cobalt ------ 0.67 ug/m' 3. Section 4.1.1, M-136 Stations, Page 9: Please clarify the discussion at the beginning ofthis section regarding the different buming and detonation scenarios tlat could occur at M-l36. What does "any one of the following altemative and mutually exclusive scenarios" mean exactly? The different scenarios that could occur should be identified and it may be helpful to give a few examples of the scenarios that are likely to occur. Also, please explain how the modeling that was done supports all ofthe potential treatrnent scenarios at M-l36. 4. Section 4.1.2,M-225 Stations, Page 10: As requested above, please clarifr what is meant by the statement describtrg potential teatrnent scenarios at M-225, "any one ofthe following altemative and mutually exclusive scenarios could occur." Please clarify the different scenarios that could occur at M-225 and explain how the modeling that was done supports all ofthe potential treatment scenarios at M-225. 5. Section 4.2.1, Open Burning, Page 1l: The next to last sentence in the paragraph at the top of Page 1l states: "To ensure a conservative impact assessment, the minimum cloud height out of these three wind speeds were considered for each combination of atmospheric stability and wind speed category." The Draft Hybrid Air Modeling Report does not provide any additional information on this approach. This discussion should be expanded to include information supporting the assertion that use ofthe minimum vapor cloud height results in a conservative estimate of potential air quality impacts for the combinations of atmospheric stability and wind speed categories addressed in the hybrid air modeling analysis. Please revise Section 4.2.1 to address this issue. Please demonstrate tlat selection of the minimum cloud height produces the most conservative results with respect to the magnitude ofpredicted air quality impacts at the facility fence line and at discrete receptor locations of interest in the risk assessment (i.e., receptors located relatively close to the modeled source, receptors located relatively far from the modeled source, and receptors located in complex tenain). Please ensure the expanded discussion notes this approach was proposed in the March 2013 Hybrid Air Modeling Protocol and discussed with the Division. 6. Section 4.2.1, Open Burning, Page 11: The last sentence ofthe paragraph at the top of page 11 indicates that an example ofthe cloud height calculation is presented in Attachment 1, Example for the Cloud Height Calculation. Attachment 1 lists the predicted cloud heights predicted by OBODM for atmospheric stability class D and wind speeds l0 miles per hour (mph), 1 1.25 mph, and 12.5 mph. The attachment also identifies the predicted cloud heights that will be used as inputs to AERMOD for this combination of atmospheric stability class and range of wind speeds. Attachment I does not actually illustrate the calculation ofthe cloud heights; the calculation is performed by OBODM. Rather, Attachment I lists the results obtained from the model. As such, tables similar to Attachment I should be provided for each atmospheric stability class and range of wind speeds included in the OBODM modeling effort. Please revise Attachment 1 to include a table for each atrnospheric stability class and range of wind speeds addressed using OBODM. 7. Section 4-2.2, Open Detonation, Page 11: Section 4.2.2 indicates the same procedure described for OB in Section 4.2.1 was used to determine vapor cloud height for OD operations. Tables listing the vapor cloud heights for OD predicted by OBODM should be presented in tl-re text. Similar to the tabulated information requested for OB, a separate table should be provided for each combination of atrnospheric stability class and range of wind speeds. Please revise the Draft Hybrid Modeling Report to address this issue. '8. Section 4.3.2, Open Detonation, Page 11: Section 4.3.2 indicates the initial dimension ofthe vapor cloud for OD operations was obtained directly from OBODM for each combination of wind speed category and atrnospheric stability. Tables listing the initial vapor cloud dimensions for OD predicted by OBODM should be presented in the text. A separate table should be provided for each combination of atmospheric stability class and range of wind speeds. Please revise the Draft Hybrid Modeling Report to address this issue. 9. Section 4.5.1, M-136 Stations, Page 13: Table 4-1 lists the source characteristics used as inputs to OBODM when modeling the five potential operation scenarios at M-136 addressed in the Draft Hybrid Modeling Report. Four of rhe scenarios, M-136-Al, M-136-A2, M-136-A3, and M-136-B are for OB operations. The fifth, M-136-C addresses OD at M-136 Stations 13 and 14. However, the information curently presented in the table implies that all scenarios are associated with OB. For clarity, a row indicating whether the scenario is associated with OB or OD should be added to Table 4-1. Please revise Table 4-1 to address this issue. 10. Section 4.5.1, M-136 stations, Page 13: Table 4-1 lists a single volume source diameter for operating scenario M-136-C. Section 4.3.2 previously noted that initial vapor cloud dimensions were obtained directly from OBODM "for each combination of wind speed category and atmospheric stability." It is not clear why a single diameter value is provided in the table. Please revise Table 4-1 to explain how the value listed in the table for M-136-C is sufficient to represent all combinations of wind speed and atmospheric stability addressed in the OBODM modeling effort. If a technically defensible explanation cannot be provided, please revise Table 4-1 to include a reference to the location ofthe volume source diameters obtained directly from OBODM for each combination of wind speed and atmospheric stability. 11. Section 4.5.1, M-136 Stations, Page 13: Tables 4-2 and 4-3list the actual emissions rates used in the analysis of ambient impacts for Criteria Pollutants and Air Toxics, respectively. However, it is not clear how the values listed in the tables were calculated. The explanation offered in Section 4.5.1 (and in Section 3.2, Air Toxics Analysis) indicates the emission rates were multiplied by the daily quantity treated for each scenario (listed in Table 4-1) but does not indicate the number of treatment events occurring each day and does not clearly explain how the time (i.e., duration) ofeach event is incorporated into the calculation. While the calculation appears to be based on an event duration ofone hour, Table 4-1 lists durations between 15 and 45 minutes for OB and five seconds for OD. Please revise Sections 3.2 and 4.5.1 to include a more detailed description of the calculation of these emissions rates. For clarity, it is recommended that an example calculation be included as part of the description. In addition, it appears that the title of Table 3-4 and the right hand column heading should be changed to indicate that the emission factors are not rates. 12. Section 4.5.2,M-225 Stations, Page 15: Table 4-2lists the source characteristics used as inputs to OBODM when modeling the two potential operation scenarios atM-225 addressed in the Draft Hybrid Modeling Report. One the scenarios, M-225-A represents an OB operation. Scenario M-225-B addresses OD atM-225 Station l. However, the information cunently presented in the table implies that all scenarios are associated with OB. For clarity, a row indicating whether the scenario is associated with OB or OD should be added to Table 4-2. Please revise Table 4-2 to address this issue. 13. Section 4.5,2,M-225 Stations, Page 15: Table 4-2lists a single volume source diameter for operating scenario M-225-8. Section 4.3.2 previously noted that initial vapor cloud dimensions were obtained directly from OBODM "for each combination of wind speed category and atmospheric stability." It is not clear why a single diameter value is provided in the table. Please revise Table 4-2 to explain how the value listed in the table for M-225-B is sufficient to represent all combinations of wind speed and atmospheric stability addressed in the OBODM modeling effort. If a technically defensible explanation cannot be provided, please revise Table 4'2 to include a reference to the location of the volume source diameters obtained directly from OBODM for each combination of wind speed and atmospheric stability. 14. Section 4.5.2, M-225 Stations, Pages 15 and 16: Tables 4-5 and 4-6 list the actual emissions rates used in the analysis of ambient impacts for Criteria Pollutants and Air Toxics, respectively. However, it is not clear how the values listed in the tables were calculated. The explanation offered in Section 4.5.2 (as well as in Section 3.2) indicates the emission rates were multiplied by the daily quantity treated for each scenario (listed in Table 4-4) but does not indicate the number of treatment events occurring each day and does not clearly explain how the time of each event is incorporated into the calculation. The calculation appears to be based on an event duration of one hour. However, Table 4-4 lists a duration between 15 and 45 minutes for OB and five seconds for OD. Please revise Section 4.5.2 to include a more detailed description of the calculation of these emissions rates. For clarity, it is recommended that an example calculation be included as part of the description. 15. Section 6.0, Meteorological Data, Page 18: The first paragraph of Section 6.0 indicates frve years of meteorological data were obtained from the site for use in the preliminary modeling. However, this description does not provide the level of detail needed to determine the location at which the data were collected or identifu the model application in which the data were used. In addition, no additional information on the location (e.g., figure or discussion that establishes the relationship between the data collection site and the location ofthe modeled sources) or the preliminary modeling is provided in Section 6.0. Please revise Section 6.0 to identif the location at which the meteorological data were collected. Please illustrate or otherwise establish the spatial relationship between the data collection site and the location ofthe modeled sources. Also, please identify the preliminary modeling analysis mentioned in the frst sentence ofthe first paragraph of Section 6.0. Ifthis phrase does not refer to the modeling ofinitial vapor cloud dimensions using OBODM, the meteorological data used in predicting those dimensions should be identified and discussed. 16. Section 6.0, Meteorological Data, Page 18: The last sentence of Section 6.0 refers readers to the March 2013 Hybrid Air Modeling Protocol for details regarding the land use and surface characteristics used in processing the meteorological data. To ensure a clear and complete description of the air modeling analyses are provided in the Draft Hybrid Air Modeling Repor! the information from the protocol document should be included in Section 6.0. In addition, copies ofany maps, photographs, or figures used in determining land use should be provided. Please revise the Draft Hybrid Air Modeling Report to include the information on land use and surface characteristics refened to in the last sentence of Section 6.0. Please include copies of any maps, photographs, or figures used in determining land use and/or surface characteristics. 17. Section 6.0, Meteorological Data, Page 18: The AERSURFACE files from the hybrid air modeling effort were not found in Attachment 4, Modeling Inputs/Oulputs. Please ensure that all AERSURIACE files are submitted along with future revisions of the Hybrid Air Modeling Report. 18. Section 6.0, Meteorological Data, Page 18: The model-ready meteorological data file used in OBODM to determine vapor cloud dimensions was not found among the meteorological files submitted in Attachment 4 of the Draft Hybrid Air Modeling Report. Please ensure this frle is submitted along with future revisions of the report document. 19. Section 7.0, Receptor Grid Layout, Page 19: The Draft Hybrid Air Modeling Report does not include figures illustrating the modeled receptor grids. Lists ofthe receptors are provided in the AERMAP files found in Attachment 4. Please revise the report to include plots of these receptor locations overlaid on a site and/or topographic map (depending on scale). In addition, please include the on and off-site maximum locations modeled by AERMOD for each pollutant phase and source on the receptor plots (e.g. see the l,iy 2012 Air Dispersion Modeling Report, Figures 3-l and 3-2). 20. Section 9.0, Compliance Demonstration with NAAQS and Air Toxic Standards, Page 22: At the beginning ofSection 3.0, on page four, it states that the objective ofthe air quality analysis was to determine compliance with all applicable NAAQS and air toxics. At the beginning ofSection 9.0, on page 22, it states that the objective of the modeling was to determine cornpliance with all applicable NAAQS and air toxics. Please revise the report to indicate that another objective ofthe modeling was to provide the necessary input for the HHRA. 21. Section 10,2, Pollutant Phases, Page 28: The first full paragraph on Page 28 indicates a velocity of 0.03 meters per second (m/sec) was used in the AERMOD modeling of gas phase dry deposition. The discussion indicates the value was taken from EPA's HHRAP. However, Section 3.6.1 of the HHRAP recommends using a value of 0.5 centimeters per second (cm/sec) (0.005 m/sec) to model the gas phase dry deposition for organic contaminants, chlorine gas, and hydrochloric acid (HCl). In addition, the HHRAP recommends a value of 2.9 cm/sec (0.029 m/sec) for modeling gas phase dry deposition for mercury. The value used by ATK, 0.03 m/sec, agrees with value recommended for divalent mercury in the HHRAP but as indicated in the Hybrid Air Modeling Report, represents a "conservative deposition velocity" for organic constituents. The discussion in this paragraph should be expanded to provide additional justification for use ofthe proposed value. For example, the discussion ofgas phase dry deposition velocity contained in the Hybrid Air Modeling Protocol should be added to Section 10.2. Please revise Section 10.2 to provide additional justification for using 0.03 m/sec to model gas phase dry deposition for all gaseous phase constituents emitted from OB and OD operations. Please ensure the revised discussion notes this approach was proposed in the March 2013 Hybrid Air Modeling Protocol and discussed with the Division. 22. Section 10.3, One-Hour ADF for Concentrationo Page 30: Section 8.1 indicates that AERMOD was used to model one-hour impacts from treatment by OB and OD. However, the Draft Hybrid Air Modeling Report does not include figures illustrating the modeled ADFs. These figures typically present the modeled results as contour lines overlaid on a topographical map or site map of the modeling domain. Please revise the Draft Hybrid Air Modeling Report to include plots of the ADFs predicted by AERMAP for the worst-case bum event for OB and OD at both bum grounds. Please include plots for annual particle dry deposition, and air concentrations for both one-hour and annual results. If other plots that don't represent the worst- case bum events are requested by a stakeholder, the Division will request that they are provided by ATK. 23. Section 11.0, Conclusion, Page 32: Please clariff the statement'1o ensure the AERMOD results represent a significant refinement, the air quality modeling results consider that the OB and OD events occur for only one hour per day and must meet the following criteria:" What is meant by a"significant refinemenf in the context of burning ground restrictions? 24. Attachment 4, Modeling Inputs/Outputs: The text files contained in folder Hourly Emission Rate Files furnish four parameter values to AERMOD for each hour of meteorological data processed during a model run. However, neither Attachment 4 nor the text of the Hybrid Air Modeling Report identifies the four parameter values listed in these files. Please revise the Hybrid Air Modeling Report to identifu the four parameten contained in these hourly emission rate files.