DSHW-2013-007222 - 0901a068803ebbd5

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Division of
Solid and Hazardous Waste
December 17,2013
8200-FY14-062
DEC 2 0 2013
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: ATK Launch Systems Inc. EPA ID number UTD009081357 ^
Response to Comment on the Hybrid Air Dispersion Modeling Report for Open
Burning and Open Detonation Treatment Units
Dear Mr. Anderson:
In reply to your letter dated November 19, 2013, ATK Launch Systems Inc. ("ATK") has
prepared responses to the comments provided by the Utah Department of Solid and
Hazardous Waste (UDSHW) regarding the Hybrid Air Dispersion Modeling Report. The
AERMOD Hybrid modeling results will be used to conduct the Human Health Risk
Assessments for ATK's OB/OD operations.
Also enclosed with the responses to comments, is an attachment directory indicating the
location of several modeling files noted in some of the Divisions comments. These files
were submitted with the Air Dispersion Modeling Report in June, 2013
Please contact Blair Palmer at [phone] or myself at [phone], if you have
any questions concerning this submittal.
Sincerely,
George Gooch
Manager, Environmental Services
ATK Launch Systems Inc.
TECHNICAL REVIEW OF
ADDENDUM AIR DISPERSION MODELING REPORT FOR OPEN BURNING
AND OPEN DETONATION AT ATK LAUNCH SYSTEMS IN PROMONTORY,
UTAH
JUNE 2013
The following comments were generated based on evaluation of the Addendum Air
Dispersion Modeling Report for Open Burning and Open Detonation at ATK Launch
Systems in Promontory, Utah dated June 2013 (Hybrid Air Modeling Report).
GENERAL COMMENTS
1. The third sentence of the first paragraph in Section 4.3.1, Open Burning, indicates
that cloud diameter for OB was assumed to be four times the equivalent diameter
of the burn pans with the equivalent diameter calculated from the total area
covered by the reactive waste to be 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 of the vapor cloud for
OD operations was obtained directly from OBODM for each combination of wind
speed category and atmospheric 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 cannot calculate the initial release diameter for quasi-continuous
releases (i.e., open burns). 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, ensure 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 Utah DEQ.
Shaw Response:
OBODM does not calculate the initial release diameter for quasi-continuous
releases, such as open burns. Therefore, site observations of burn operations were
utilized in estimating this parameter. Additional details will be provided in
Section 4.3.1 to explain the vapor cloud diameter for OB. An example calculation
demonstrating the parameters for Scenario M-136A-1 will be included. The
vapor cloud diameter calculated for each modeled scenario is included in Table 4-
1.
1
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 Utah DEQ. Please review the files already submitted and
determine if additional 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. 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 Utah DEQ.
Shaw Response:
All the necessary AERMOD files have been included for the ambient air quality
impacts in Attachment 4, Modeling Inputs/Outputs. The air concentration and
deposition fluxes (based on emission unit rate) are under the Risk ADF
AERMOD Files folder in Attachment 4. A file directory has been developed to
correctly identify all files in the Attachments.
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 of paragraph 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.
Shaw Response:
Preliminary modeling refers to the report entitled "Revised Air Dispersion
Modeling Assessment Report for Open Burn and Open Detonation Treatment
Unit at ATK Launch Systems", which was completed by Terra Tech and initially
dated March 2012 with the revised version dated July 2012. The modeling
protocol for the preliminary modeling is presented in Section 2.0 of the July 2012
preliminary modeling report. The referenced protocol and preliminary modeling
will be identified in the text of the hybrid modeling report. In addition, "ODOBi
test chamber" will be added to the text in the Introduction and in Section 3.0 for
clarification.
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.
2
No additional information on the previous modeling analysis is provided. Revise
this end note to include a reference to the regulatory report containing the
modeling that demonstrates compliance with the NAAQS for CO and Pb.
Shaw Response:
As stated in the March 2013 Hybrid Air Modeling Protocol, modeling was not
completed for carbon monoxide (CO) and lead (Pb) because the results from the
preliminary modeling report, entitled "Revised Air Dispersion Modeling
Assessment Report for Open Burn and Open Detonation Treatment Units at ATK
Launch Systems" dated July 2012, completed by Terra Tech showed compliance
with NAAQS. The end note to Table 3-1, Criteria Pollutants Considered in
NAAQS Compliance Demonstration will be revised to provide the name of the
report from the preliminary modeling.
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/m3
Benzene 18 ug/m3
Arsenic 0.11 ug/m3
Cobalt 0.67 ug/m3
Shaw Response:
The TSLs listed above will be revised in Table 3-3 of the hybrid modeling report.
Note that in review of Table 3-3 with respect to the above comment, it was
noticed that acetonitrile had been inadvertently omitted from the TSL analyses.
Acetonitrile will be included in the revised report as a chronic air toxic. This
addition will affect Tables 3-3, 3-4, 4-3, 4-6, and 9-3.
3. Section 4.1.1, M-136 Stations, Page 9: Please clarify the discussion at the
beginning of this section regarding the different burning and detonation scenarios
that could occur at M-136. What does "any one of the following alternative 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 of the potential treatment scenarios at M-136.
Shaw Response:
Describing the scenarios at M-136 as "alternative and mutually exclusive" is
meant to convey that any one of the Scenarios A, B, or C could occur during a
single treatment event and that these scenarios would not occur simultaneously.
Furthermore, only one treatment event - either Scenario A, B, or C- is considered
to occur at M-136 per day.
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Section 4.1.1 will be revised to provide clarification on the OB and OD scenarios
considered for M-136 and to explain how the modeling supports these scenarios.
4. Section 4.1.2, M-225 Stations, Page 10: As requested above, please clarify what
is meant by the statement describing potential treatment scenarios at M-225 -
"any one of the following alternative 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 of the potential treatment
scenarios at M-225.
Shaw Response:
Describing the scenarios at M-225 as "alternative and mutually exclusive" is
meant to convey that either of the Scenarios A or B could occur during a single
treatment event and that these scenarios would not occur simultaneously.
Furthermore, only one treatment event - either Scenario A or B - is considered to
occur at M-225 per day.
Section 4.1.2 will be revised to provide clarification on the OB and OD scenarios
considered for M-225 and to explain how the modeling supports these scenarios.
5. Section 4.2.1, Open Burning, Page 11: The next to last sentence in the
paragraph at the top of Page 11 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 of the 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. Revise Section 4.2.1 to address this issue.
Demonstrate that selection of the minimum cloud height produces the most
conservative results with respect to the magnitude of predicted air quality impacts
at the facility fenceline 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 terrain). Ensure the expanded discussion notes this approach was
proposed in the March 2013 Hybrid Air Modeling Protocol and discussed with
Utah DEQ.
Shaw Response:
During the fall of 2012, Shaw, Utah DEQ, and Utah DEQ's consultant (TechLaw)
held discussions to identify an appropriate approach in selecting cloud heights to
represent the range of wind speeds and atmospheric stability classes modeled.
These discussions resulted in the current approach in which the minimum cloud
height over each wind speed category was chosen for each combination of
atmospheric stability and wind speed category.
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This approach, as detailed in the March 2013 Hybrid Air Modeling Protocol, was
initially presented in an earlier air modeling protocol dated November 2012. Utah
DEQ's consultant, TechLaw, reviewed the preliminary modeling results based on
the November 2012 version of the protocol and concluded that the cloud heights
predicted by OBODM were appropriately applied in the AERMOD analysis.
Section 4.2.1 of the modeling report will be revised to indicate that this approach,
as presented in the March 2013 protocol, was discussed with and accepted by
Utah DEQ.
6. Section 4.2.1, Open Burning, Page 11: The last sentence of the paragraph at the
top of Page 11 indicates that an example of the 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 10 miles per hour (mph), 11.25
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 1 does not actually illustrate
the calculation of the cloud heights; the calculation is performed by OBODM.
Rather, Attachment 1 lists the results obtained from the model. As such, tables
similar to Attachment 1 should be provided for each atmospheric stability class
and range of wind speeds included in the OBODM modeling effort. Revise
Attachment 1 to include a table for each atmospheric stability class and range of
wind speeds addressed using OBODM.
Shaw Response:
Attachment 1 will be revised to include Tables A-l and A-2. Table A-l identifies
the vapor cloud heights for each combination of the PG atmospheric stability class
and wind speed categories for OB; and Table A-2 includes a summary of the
minimum cloud height for each scenario for OB.
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 the text. Similar to the tabulated information
requested for OB, a separate table should be provided for each combination of
atmospheric stability class and range of wind speeds. Revise the Draft Hybrid
Modeling Report to address this issue.
Shaw Response:
Attachment 1 will be revised to include Tables A-3 and A-4. Table A-3 identifies
the vapor cloud heights for each combination of the PG atmospheric stability class
and wind speed categories for OD; and Table A-4 includes a summary of the
minimum cloud height for each scenario for OD.
5
8. Section 4.3.2, Open Detonation, Page 11: Section 4.3.2 indicates the initial
dimension of the vapor cloud for OD operations was obtained directly from
OBODM for each combination of wind speed category and atmospheric 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. Revise the
Draft Hybrid Modeling Report to address this issue.
Shaw Response:
The initial vapor cloud diameter for each OD source was determined by OBODM.
The calculation used within OBODM for initial diameter for detonations does not
incorporate wind speed or stability class, but is a function of heat content and
quantity detonated. Therefore, the initial vapor cloud diameter does not vary with
meteorological conditions. The Draft Hybrid Modeling Report will be revised to
remove text that implies that the initial diameter would be different for each wind
speed and atmospheric stability combination.
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 the scenarios,
M-136-A1, 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 currently 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. Revise Table 4-1 to
address this issue.
Shaw Response:
An OB/OD identification parameter will be added to Table 4-1 to correctly
identify each source.
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." Thus, it is not
clear why a single diameter value is provided in the table. 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,
revise Table 4-1 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.
Shaw Response:
As indicated in Comment 8, the initial vapor cloud diameter for each OD source
was determined by OBODM. The calculation used within OBODM for initial
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diameter for detonations does not incorporate wind speed or stability class, but is
a function of heat content and quantity detonated. Therefore, the initial vapor
cloud diameter does not vary with meteorological conditions. The Draft Hybrid
Modeling Report will be revised to remove text that implies that the initial
diameter would be different for each wind speed and atmospheric stability
combination.
11. Section 4.5.1, M-136 Stations, Page 13: Tables 4-2 and 4-3 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 4.5.1 (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 indicate the
number of treatment events occurring each day and does not clearly explain how
the time (i.e., duration) of each event is incorporated into the calculation. While
the calculation appears to be based on an event duration of 1 hour, Table 4-1 lists
durations between 15 and 45 minutes for OB and 5 seconds for OD. 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.
Shaw Response:
Although Table 4-1 indicates the actual duration of each event, AERMOD
assumes the emissions from each event are released over one hour. The emission
rates were determined based on the reactive waste for each scenario and assuming
only one event would occur per hour. Sections 3.2 and 4.5.1 will be revised to
include more details about the calculation for the emission rate. An example
calculation will be provided in this section. Both Tables 3-2 and 3-4 will be
revised to indicate that the values in the tables are emission factors. In addition,
the event duration row will be removed from Table 4-1 to avoid confusion with
the calculated emission rates.
12. Section 4.5.2, M-225 Stations, Page 15: Table 4-2 lists the source characteristics
used as inputs to OBODM when modeling the two potential operation scenarios at
M-225 addressed in the Draft Hybrid Modeling Report. One the scenarios, M-
225-A represents an OB operation. Scenario M-225-B addresses OD at M-225
Station 1. However, the information currently 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. Revise Table
4- 2 to address this issue.
Shaw Response:
This comment should be addressed for Table 4-4. An OB/OD identification
parameter will be added to Table 4-4 to correctly identify each source.
7
13. Section 4.5.2, M-225 Stations, Page 15: Table 4-2 lists a single volume source
diameter for operating scenario M-225-B. 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." Thus, it is not
clear why a single diameter value is provided in the table. 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,
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.
Shaw Response:
As indicated in Comments 8 and 10, the initial vapor cloud diameter for each OD
source was determined by OBODM. The calculation used within OBODM for
initial diameter for detonations does not incorporate wind speed or stability class,
but is a function of heat content and quantity detonated. Therefore, the initial
vapor cloud diameter does not vary with meteorological conditions. The Draft
Hybrid Modeling Report will be revised to remove text that implies that the initial
diameter would be different for each wind speed and atmospheric stability
combination.
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 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 1 hour; however, Table 4-4 lists a
duration between 15 and 45 minutes for OB and 5 seconds for OD. 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.
Shaw Response:
Although Table 4-4 indicates the actual duration of each event, AERMOD
assumes the emissions from each event are released over one hour. The emission
rates were determined based on the reactive waste for each scenario and assuming
only one event would occur per hour. Sections 3.2 and 4.5.2 will be revised to
include more details about the calculation for the emission rate. An example
calculation will be provided in this section. In addition, the event duration row
will be removed from Table 4-4 to avoid confusion with the calculated emission
rates.
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15. Section 6.0, Meteorological Data, Page 18: The first paragraph of Section 6.0
indicates five 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
identify 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 of the modeled
sources) or the preliminary modeling is provided in Section 6.0. Revise Section
6.0 to identify the location at which the meteorological data were collected.
Illustrate or otherwise establish the spatial relationship between the data collection
site and the location of the modeled sources. Also, identify the preliminary
modeling analysis mentioned in the first sentence of the first paragraph of Section
6.0. If this phrase does not refer to the modeling of initial vapor cloud dimensions
using OBODM, the meteorological data used in predicting those dimensions
should be identified and discussed.
Shaw Response:
The preliminary modeling referenced in Section 6.0 refers to the "Revised
Preliminary Air Dispersion Modeling Assessment Draft Report for Open Burn
and Open Detonation Treatment Unit at ATK Launch Systems" dated July 2012
completed by Tetra Tech. Section 6.0 will be revised to include details of the
location at which the data was collected.
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 Report, the
information from the protocol document should be included in Section 6.0. In
addition, copies of any maps, photographs, or figures used in determining land
use should be provided. Revise the Draft Hybrid Air Modeling Report to include
the information on land use and surface characteristics referred to in the last
sentence of Section 6.0. Include copies of any maps, photographs, or figures used
in determining land use and/or surface characteristics.
Shaw Response:
The details regarding the land use and surface characteristics used in processing
the meteorological data discussed in the March 2013 Hybrid Air Modeling
Protocol will be included in Section 6.0. The land use and surface characteristic
analysis was presented in the preliminary modeling completed by Tetra Tech in
July 2012. Figures of the land use analysis from the preliminary modeling are
provided in Appendix A of the "Revised Air Dispersion Modeling Assessment
Report for Open Burn and Open Detonation Treatment Units at ATK Launch
Systems" dated July 2012.
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For the Draft Hybrid Air Modeling Report, the land use was not reevaluated;
however the surface characteristics were evaluated using AERSURFACE. Digital
data was utilized for AERSURFACE; therefore no figures are available.
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/Outputs. Ensure that all AERSURFACE files are submitted along with
future revisions of the Hybrid Air Modeling Report.
Shaw Response:
The AERSURFACE files from the hybrid air modeling effort were provided in
Attachment 4, Modeling Inputs/Outputs under the following directory:
AERMOD Files/Met Data/AERMET vl2345
A file directory has been developed to correctly identify all files in the
Attachments.
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. Ensure this file is submitted along with future revisions of the
report document.
Shaw Response:
A meteorological data file was not used in OBODM modeling to determine the
vapor cloud dimensions. Each combination of wind speed and atmospheric
stability were directly input to OBODM and modeled individually.
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 of
the receptors are provided in the AERMAP files found in Attachment 4. Please
revise the report document 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 July 2012 Air Dispersion
Modeling Report, Figures 3-1 and 3-2).
Shaw Response:
A figure showing the off-site/boundary receptor grid overlaid on a Google Earth
image of the surrounding area will be included in Section 7.0. Figures showing
the onsite receptor grids for M-136 and M-225 and the discrete receptor grid will
be provided in Section 10. Additionally, the on-site and off-site maximum
locations modeled by AERMOD for each pollutant phase and source, which were
considered in developing the ADFs for the HHRA, will be included on a figure.
10
20. Section 9.0, Compliance Demonstration with NAAQS and Air Toxic
Standards, Page 22: At the beginning of Section 3.0, on page four, it states that
"the objective of the air quality analysis was to determine compliance with all
applicable NAAQS and air toxics." At the beginning of Section 9.0, on page 22,
it states that "the objective of the modeling was to determine compliance with all
applicable NAAQS and air toxics." Please revise the report to indicate that
another objective of the modeling was to provide the necessary input for the
HHRA.
Shaw Response:
The report will be revised where applicable to include the additional objective of
modeling in support of 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 (HC1). 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 of the
proposed value. For example, the discussion of gas phase dry deposition velocity
contained in the Hybrid Air Modeling Protocol should be added to Section 10.2.
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. Ensure the revised discussion notes this approach was
proposed in the March 2013 Hybrid Air Modeling Protocol and discussed with
Utah DEQ.
Shaw Response:
A velocity of 0.03 m/s was used in modeling gas phase dry deposition to be
consistent with the preliminary modeling performed by Tetra Tech and presented
in the March 2012 and July 2012 versions of their modeling report. According to
Tetra Tech, this velocity had been accepted by TechLaw in review of the protocol
for the preliminary modeling.
Section 10.2 will be revised to indicate that a velocity of 0.03 m/s was accepted
by Utah DEQ. This section will further be revised to clarify selection of 0.03 m/s
as the most conservative of the default values recommended in the HHRAP. It is
the largest of the recommended default velocity values and is therefore expected
to give the highest deposition rate.
22. Section 10.3, One-Hour ADF for Concentration, 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 burn event
for OB and OD at both burn 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 burn events are requested by a
stakeholder, the Division will request that they are provided by ATK.
Shaw Response:
As discussed with UDSHW on 12/5/2013, contour plots for the annual particle
dry deposition and annual vapor air concentration will be provided for the worst-
case burn event for OB and OD at both burn grounds. Results at both the on-site
and off-site receptors will be presented.
Scenario M-136-A is the worst-case OB scenario for this treatment location and
consists of three sub-scenarios: M-136-A1, M-136-A2, and M-136-A3. Each sub-
scenario was modeled separately for developing the ADFs, and individual results
were obtained for each sub-scenario. As a result, it is not possible to plot the
combined impact from the three sub-scenarios. Since Scenario M-136-A1 is the
driver and contributes the greatest impact compared to M-136-A2 and M-136-A3,
results from this sub-scenario will be plotted as representative of M-136-A.
Furthermore, Scenario M-136-A1 was modeled considering simultaneous burns in
six separate burn stations. Since individual results were obtained for each burn
station, the results from one burn station will be plotted and considered as
representative.
Similarly, the OD scenario for this treatment area, M-136-C, was modeled
considering two separate stations. The results from one station will be plotted as
representative.
Details on the selection of the source results presented in the plots will be
provided in the report.
23. Section 11.0, Conclusion, Page 32: Please clarify the statement "to 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 refinement" in
the context of burning ground restrictions?
12
Shaw Response:
Section 11.0 will be revised to clarify the conclusions of the modeling report, as
follows:
"To ensure the AERMOD results represent a significant refinement over the
preliminary modeling conducted solely with OBODM and to allow for evaluation
of more realistic operating conditions, 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...".
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. Revise the Hybrid Air Modeling Report to
identify the four parameters contained in these hourly emission rate files.
Shaw Response:
The four parameters in the Hourly Emission Rate files are emission rate (g/s),
release height (m), initial horizontal diameter (m), and initial vertical diameter
(m), respectively. A description of the hourly emission rate file used with
AERMOD will be provided in Section 5.0.
13
Air Dispersion Modeling Report for Open Burning and Open Detonation at
ATK Launch Systems in Promontory, Utah
Attachment Directory
Attachment 1: Vapor Cloud Heights
Table Description
Table A-l Open Burning - Summary of Lowest Total Cloud Heights
Table A-2 Open Burning - Evaluation of Total Cloud Heights for all Stability Categories and Wind Speed Groups
Table A-3 Open Detonation - Summary of Lowest Total Cloud Heights
Table A-4 Open Detonation - Evaluation of Total Cloud Heights for all Stability Categories and Wind Speed Groups
Attachment 2: Summary of Screened Hours
Table of screened hours based on operating hours and wind speed restrictions
Attachment 3: Detailed Modeling RcsyJtsJNAAQS and Air Toxics)
Scenarios
M136andM225
File Name
ATK Results Summary (Criteria Pollutants)
M136 Includes:
M136A1-3
M136B
M136C
M136 CO Results
M136 N02 Results
M136 PM2.5 Results
M136 PM10 Results
M136 S02 Results
M225 Includes:
M225A
M225B
M225 CO Results
M225 N02 Results
M225 PM2.5 Results
M225 PM10 Results
M225 S02 Results
M136andM225 M136 and M225 Air Toxics Results
Attachment 4: Modeling Inputs/Outputs
See details on next the tab
Attachment 5: Summary of ADFs for the Risk Assessment
Filename Description
ADF_Discrete_May2013.xlsx Summary of discrete receptors ADF
ADF_Offsite_MEI_May2013.xlsx Summary of ADFs for the Off-Site MEI (1-hr and annual concentration, and annual deposition)
ADF_Onsite_MEI_May2013,xlsx Summary of ADFs for the On-Site MEI (1-hr and annual concentration, and annual deposition)
Air Dispersion Modeling Report for Open Burning and Open Detonation at
ATK Launch Systems in Promontory, Utah
Attachment Directory
Attachment 4: Modeling Inputs/Outputs
AERMAP Files
Filename Description
AERMAP_R1SK (Includes .MAP, .Mot, .ref, and . Rmp files)
MAPDETAIL.0UT AERMAP Files associated with the discrete receptors
MAPPARAMS.OUT
ATK (Includes .MAP, .Mot, .ref, and . Rmp files)
MAPDETAIL.0UT
MAPPARAMS.OUT
AERMAP Files associated with the off-site and property
boundary receptors
AERMAP_RISK_QNSITE (Includes .MAP, .Mot, .ref, and . Rmp files)
MAPDETAIL.OUT AERMAP Files associated with the on-site receptors
MAPPARAMS.OUT
Off-site Receptor AERMOD Files
AERMOD Files/AERMOD Files_Offsite Receptors
Input files *.BST and *.DTA; Output files *.LST, *.GRF, *.SUM
Scenarios
Modeled
Year Averaging
Time
Output Receptors Base Filename
M136A Includes:
M136A1-3
M136B
M136C
1997
1998
1999
2000
2001
1-Hr Max 1-hr cone Off-site, including site boundary
ATK Scenari
ATK Scenari
ATK Scenari
ATK Scenari
ATK Scenari
M136A
M136A.
M136A
M136A.
M136A
050213.
050213.
050213.
050213.
050213
1997
.1998
.1999
.2000
2001
M136B
1997
1998
1999
2000
2001
1-Hr Max 1-hr cone Off-site, including site boundary
ATK Scenari
ATK Scenari
ATK Scenari
ATK Scenari
ATK Scenari
.M136B.
.M136B.
.M136B.
.M136B.
M136B
.050213.
.050213.
.050213.
.050213.
050213
.1997
.1998
.1999
.2000
2001
M136C
1997
1998
1999
2000
2001
1-Hr Max 1-hr cone Off-site, including site boundary
ATK Scenari
ATK Scenari
ATK Scenari
ATK Scenari
ATK Scenari
.M136C.
.M136C.
.M136C.
.M136C.
M136C
.050213.
.050213.
.050213.
.050213.
050213
.1997
.1998
.1999
.2000
2001
M225A
1997
1998
1999
2000
1-Hr Max 1-hr cone Off-site, including site boundary
ATK Scenari
ATK Scenari
ATK Scenari
ATK Scenari
.M225A.
.M225A.
.M225A.
M225A
.050213.
.050213.
.050213.
050213
.1997
.1998
.1999
2000
2001 ATK Scenarios M225A 050213 2001
M225B
1997
1998
1999
2000
2001
1-Hr Max 1-hr cone Off-site, including site boundary
ATK Scenarios_M225B_050213_1997
ATK Scenarios_M225B_050213_1998
ATK Scenarios_M225B_050213_1999
ATK Scenarios_M225B_050213_2000
ATK Scenarios M225B 050213 2001
Filename
M136A_1997.txt, M136A_1998.txt, M136A_1999.txt, M136A_2000.txt, M136A_2001.txt
M136B_1997.txt, M136B_1998.txt, M136B_1999.txt, M136B_2000.txt, M136B_2001.txt
M136C 1997.txt, M136C_1998.txt, M136C_1999.txt, M136C_2000.txt, M136C_2001.txt
M225A_1997.txt, M225A_1998.txt, M225A_1999.txt, M225A_2000.txt, M225A_2001.txt
M225B_1997.txt, M225B_1998.txt, M225B_1999.txt, M225B_2000.txt, M225B_2001.txt
Description
Hourly emission rate files for each met
year, using PM2.5 emission rate as a
baseline emission rate. Incorporates
operating restrictions.
Meterological Data Files
AERMOD Met Data
AERMOD/Met Data/AERMET vl2345/ATK_met_aermod_03-19-13
Filename Description
ATK1997.SFC, ATK1998.SFC, ATK1999.SCF, ATK2000.SCF, ATK2001.SCF
ATK1997.SFC, ATK1998.SFC, ATK1999.PFL, ATK2000.PFL, ATK2001.PFL Individual meteroological data for each year, processed with AERMET v!2345
ATK1997 2001.SFC
ATK1997 2001.PFL
Combined 5 years of meteorological data for the period 1997-2001, processed
with AERMET V12345
AERMET and AERSURFACE Processing Files
AERMOD/Met Data/AERMET V12345/ATK AERMET processing files_031913
Input files *.inp and *.DTA; Output files *.OUT and .RPT
Hourly Emission Rate Files
Hourly Emission Rate Files
The hourly emission rate text files are also included in this folder. These files were also provided in the AERMOD Files/AERMOD Files_Offsite Receptors path and are described
above.
Filename
atkl997_HrlyEF_HRWSCI.xlsx
atkl998_HrlyEF_HRWSCI.xlsx
atk!999_HrlyEF_HRWSCI.xlsx
atk2000_HrlyEF_HRWSCI.xlsx
atk2001_HrlyEF_HRWSCI.xlsx
Description
Hourly Emission Rate spreadsheets used to
develop text files used in AERMOD
OBODM Output files - A separate directory was included on the flash drive. See "OBODM File Directory_May2013.xlsx".
Risk ADFs - AERMOD Files - A separate directory was included on the flash drive. See "AERMOD Risk File Dir_May2013.xls".
May 2013 - OBODM Modeling for Plume Dimensions - M-136 Unit and M-225 Unit, ATK Promontory
Evaluation of Range of Stability Categories and Wind Speed Groups for Unrestricted Operating Hours
Wind Speed
Group
Wind Speed
Range (m/s)
Wind Speed Range (mph)
Low MidPoint High
Group 0 1.34<=WS<=2.23
Group 1 2.23<=WS<3.35 6.25 7.5
Group 2 3.35<=WS<4.47 7.5 8.75 10
Group 3 4.47<=WS<5.59 10 11.25 12.5
Group 4 5.59<=WS<6.71 12.5 13.75 15
File Naming Convention = ATK_{Wind Speed Group ID} {Wind Speed Range Value ID} {Stability Category}.OUT
Base
Filename*
Wind
Speed
Group
Wind Speed
Range
Value
Modeled Wind Speed
(mph) (m/s)
ATK GOLx Group 0 [GO] Low [L] 1.34
ATK GOMx Group 0 [GO] Midpoint [M] 1.79
ATK GILx Group 1 [Gl] Low [L]
Equivalent to Group 0, High wind speed range value
2.24
ATK GIMx Group 1 [Gl] Midpoint [M] 6.25 2.79
ATK GlHx Group 1 [Gl] High [H] 7.5
Equivalent to Group 2, Low wind speed range value
3.35
ATK G2Mx Midpoint [M] 8.75 Group 2 [G2]
Group 2 [G2] High [H] 10
Equivalent to Group 3, Low wind speed range value
3.91
ATK G2Hx 4.47
ATK G3Mx Group 3 [G3] Midpoint [M] 11.25 5.03
ATK G3Hx Group 3 [G3] High [H] 12.5
Equivalent to Group 4, Low wind speed range value
5.59
ATK G4Mx Group 4 [G4] Midpoint [M] 13.75 6.15
ATK G4Hx Group 4 [G4] High [H] 15 6.71
x in filename is specified by the stability category (x = A, B, C, or D)
OBODM File Directory_May2013.xlsx
Summary of AERMOD Modeling Files in Support of the Risk Assessment - ACUTE RISK
ATK Promontory Input files *.DTA; Output files *.LST and *.GRF
Modeling was conducted using a 5-year meteorological data file for 1997-2001.
Scenarios
Modeled
Pollutant
Type
Conc/Dep Averaging
Time
Output Receptors Base Filename
M136A
Includes:
M136A1
M136A2
M136A3
Gas Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M136A_Gas
On-site, including site boundary ATK Risk May2013_Max Onsite_M136A_Gas
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M136A_Gas
Particle Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M136A_Part
On-site, including site boundary ATK Risk May2013_Max Onsite_M136A_Part
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M136A_Part
Particle-Bound Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M136A_PtBd
On-site, including site boundary ATK Risk May2013_Max Onsite_M136A_PtBd
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M136A_PtBd
M136B Gas Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M136B_Gas
On-site, including site boundary ATK Risk May2013_Max Onsite_M136B_Gas
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M136B_Gas
Particle Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M136B_Pait
On-site, including site boundary ATK Risk May2013_Max Onsite_M136B_Part
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M136B_Part
Particle-Bound Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M136B_PtBd
On-site, including site boundary ATK Risk May2013_Max Onsite_M136B_PtBd
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M136B_PtBd
M136C Gas Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M136C_Gas
On-site, including site boundary ATK Risk May2013_Max Onsite_M136C_Gas
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M136C_Gas
Particle Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M136C_Part
On-site, including site boundary ATK Risk May2013_Max Onsite_M136C_Part
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M136C_Part
Particle-Bound Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M136C_PtBd
On-site, including site boundary ATK Risk May2013_Max Onsite_M136C_PtBd
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M136C_PtBd
AERMOD Risk File Dir_May2013.xls\Acute Risk lof 2
Summary of AERMOD Modeling Files in Support of the Risk Assessment - ACUTE RISK
ATK Promontory Input files *.DTA; Output files *.LST and *.GRF
Modeling was conducted using a 5-year meteorological data file for 1997-2001.
Scenarios
Modeled
Pollutant
Type
Conc/Dep Averaging
Time
Output Receptors Base Filename
M225A Gas Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M225A_Gas
On-site, including site boundary ATK Risk May2013_Max Onsite_M225A_Gas
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M225A_Gas
Particle Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M225A_Part
On-site, including site boundary ATK Risk May2013_Max Onsite_M225A_Part
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M225A_Part
Particle-Bound Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M225A_PtBd
On-site, including site boundary ATK Risk May2013_Max Onsite_M225A_PtBd
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M225A_PtBd
M225B Gas Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M225B_Gas
On-site, including site boundary ATK Risk May2013_Max Onsite_M225B_Gas
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M225B_Gas
Particle Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M225B_Part
On-site, including site boundary ATK Risk May2013_Max Onsite_M225B_Part
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M225B_Part
Particle-Bound Cone; Dry Dep 1-Hr Max 1-hr cone
during the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Max Offsite_M225B_PtBd
On-site, including site boundary ATK Risk May2013_Max Onsite_M225B_PtBd
Discrete (Sensitive) ATK Risk May2013_Max Discrete_M225B_PtBd
AERMOD Risk File Dir_May2013.xls\Acute Risk 2 of 2
Summary of AERMOD Modeling Files in Support of the Risk Assessment - CHRONIC RISK, CONCENTRATION
ATK Promontory Input files *.DTA; Output files *.LST and *.GRF
Modeling was conducted using a 5-year meteorological data file for 1997-2001.
Scenarios
Modeled
Pollutant
Type
Conc/Dep Averaging
Time
Output Receptors Base Filename
M136A
Includes:
M136A1
M136A2
M136A3
Gas Cone 1-Hr Average cone
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M136A_Gas
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M136A_Gas
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M136A_Gas
Particle Cone 1-Hr Average cone
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M136A_Part
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M136A_Part
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M136A_Part
Particle-Bound Cone 1-Hr Average cone
over the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M136A_PtBd
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M136A_PtBd
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M136A_PtBd
M136B Gas Cone 1-Hr Average cone
over the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M136B_Gas
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M136B_Gas
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M136B_Gas
Particle Cone 1-Hr Average cone
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M136B_Part
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M136B_Part
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M136B_Part
Particle-Bound Cone 1-Hr Average cone
over the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M136B_PtBd
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M136B_PtBd
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M136B_PtBd
M136C Gas Cone 1-Hr Average cone
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M136C_Gas
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M136C_Gas
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M136C_Gas
Particle Cone 1-Hr Average cone
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M136C_Part
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M136C_Part
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M136C_Part
Particle-Bound Cone 1-Hr Average cone
over the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M136C_PtBd
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M136C_PtBd
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M136C_PtBd
AERMOD Risk File Dir_May2013 (4).xls\Chronic Risk - Cone lof2
Summary of AERMOD Modeling Files in Support of the Risk Assessment - CHRONIC RISK, CONCENTRATION
ATK Promontory Input files *.DTA; Output files *.LST and *.GRF
Modeling was conducted using a 5-year meteorological data file for 1997-2001.
Scenarios
Modeled
Pollutant
Type
Conc/Dep Averaging
Time
Output Receptors Base Filename
M225A Gas Cone 1-Hr Average cone
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M225A_Gas
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M225A_Gas
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M225A_Gas
Particle Cone 1-Hr Average cone
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M225A_Part
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M225A_Part
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M225A_Part
Particle-Bound Cone 1-Hr Average cone
over the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M225A_PtBd
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M225A_PtBd
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M225A_PtBd
M225B Gas Cone 1-Hr Average cone
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M225B_Gas
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M225B_Gas
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M225B_Gas
Particle Cone 1-Hr Average cone
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M225B_Part
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M225B_Part
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M225B_Part
Particle-Bound Cone 1-Hr Average cone
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg Cone Offsite_M225B_PtBd
On-site, including site boundary ATK Risk May2013_Avg Cone Onsite_M225B_PtBd
Discrete (Sensitive) ATK Risk May2013_Avg Cone Discrete_M225B_PtBd
AERMOD Risk File Dir_May2013 (4).xls\Chronic Risk - Cone 2 of 2
Summary of AERMOD Modeling Files in Support of the Risk Assessment - CHRONIC RISK, DEPOSITION
ATK Promontory Input files *.DTA; Output files *.LST and *.GRF
Modeling was conducted using a 5-year meteorological data file for 1997-2001.
Scenarios
Modeled
Pollutant
Type
Conc/Dep Averaging
Time
Output Receptors Base Filename
M136A
Includes:
M136A1
M136A2
M136A3
Gas Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M136A_Gas
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M136A_Gas
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M136A_Gas
Particle Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M136A_Part
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M136A_Part
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M136A_Part
Particle-Bound Dry Dep 1-Hr Average dry dep
over the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M136A_PtBd
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M136A_PtBd
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M136A_PtBd
M136B Gas Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M136B_Gas
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M136B_Gas
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M136B_Gas
Particle Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M136B_Part
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M136B_Part
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M136B_Part
Particle-Bound Dry Dep 1-Hr Average dry dep
over the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M136B_PtBd
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M136B_PtBd
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M136B_PtBd
M136C Gas Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M136C_Gas
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M136C_Gas
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M136C_Gas
Particle Dry Dep 1-Hr Average dry dep
over the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M136C_Part
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M136C_Part
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M136C_Part
Particle-Bound Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M136C_PtBd
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M136C_PtBd
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M136C_PtBd
AERMOD Risk File Dir_May2013 (4).xls\Chronic Risk - Dep lof2
Summary of AERMOD Modeling Files in Support of the Risk Assessment - CHRONIC RISK, DEPOSITION
ATK Promontory Input files *.DTA; Output files *.LST and *.GRF
Modeling was conducted using a 5-year meteorological data file for 1997-2001.
Scenarios
Modeled
Pollutant
Type
Conc/Dep Averaging
Time
Output Receptors Base Filename
M225A Gas Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M225A_Gas
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M225A_Gas
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M225A_Gas
Particle Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M225A_Part
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M225A_Part
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M225A_Part
Particle-Bound Dry Dep 1-Hr Average dry dep
over the 5-yr
met. period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M225A_PtBd
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M225A_PtBd
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M225A_PtBd
M225B Gas Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M225B_Gas
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M225B_Gas
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M225B_Gas
Particle Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M225B_Part
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M225B_Part
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M225B_Part
Particle-Bound Dry Dep 1-Hr Average dry dep
over the 5-yr
met, period
Off-site, including site boundary ATK Risk May2013_Avg DDEP Offsite_M225B_PtBd
On-site, including site boundary ATK Risk May2013_Avg DDEP Onsite_M225B_PtBd
Discrete (Sensitive) ATK Risk May2013_Avg DDEP Discrete_M225B_PtBd
AERMOD Risk File Dir_May2013 (4).xls\Chronic Risk - Dep 2 of 2
Summary of AERMOD Modeling Files in Support of the Risk Assessment - Supporting Files
ATK Promontory
Modeling was conducted using a 5-year meteorological data file for 1997-2001.
Filename Description
ATK1997_2001.SFC
ATK1997 2001.PFL
Combined 5 years of meteorological data for the period
1997-2001, processed with AERMET V12345
M136A_lG_5Yr.txt
M136B_lG_5Yr.txt
M136C_lG_5Yr.txt
M225A_lG_5Yr.txt
M225B 1G 5Yr.txt
Hourly emission rate files for the 5-year met period,
unit emission rate basis of 1 g/s.
Incorporates operating restrictions.