Using Physical Modeling to Refine Downwash Inputs to AERMOD at a Food Processing Facility
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The document discusses a wind tunnel study conducted to demonstrate compliance with particulate matter standards at Basic American Foods' facilities in Idaho. The study outlines a historical timeline of regulatory challenges and permits, detailing the need for significant reductions in PM10 emissions and the adoption of innovative modeling methods. Following a promising response from regulators, the company plans to resubmit its compliance plan leveraging the findings from the wind tunnel analysis, which could provide more operational flexibility moving forward.
Using Physical Modeling to Refine Downwash Inputs to AERMOD at a Food Processing Facility
- 1. Using a Wind Tunnel Study to Show Compliance with Particulate Standards 2017 Food & Beverage Environmental Conference, Isle of Palms, SC John S. Kirkpatrick; Basic American Foods Steve Nelson; Coal Creek Environmental Sergio A. Guerra, Ron Petersen, CPP March 29, 2017 COAL CREEK ENVIRONMENTAL ASSOCIATES
- 2. Basic American Foods (BAF) Overview • Family owned and operated since 1933 – Ongoing innovation (40+ patents) – Shelf-stable potatoes and beans • Food Service • Limited Retail – Hungry Jack • Facility Locations – Idaho • Blackfoot • Shelley • Rexburg – Washington • Moses Lake
- 6. Project History 2002 - ? Year Event 2002 DEQ requires submittal of ambient impacts analysis for all three BAF facilities in SE Idaho 2003 BAF submits ambient impacts analysis with excess PM-10 impacts. 2004-2008 BAF development of PM-10 compliance plan 2007 EPA adopts AERMOD as the dispersion model. Large increases in estimated impacts. 2009 BAF submits permit application with proposed PM10 compliance plan.
- 7. Project History Year Event 2011 DEQ issues revised facility permit. Includes a 3-year time period to prepare an Alternate Compliance Plan 2012 BAF prepares alternate plan for DEQ review. DEQ requests that alternate plan consider impacts from adjacent dehydration facility (Regional Outlook – feel good exercise) . 2012 With the addition of the adjacent facility, to the model, overall combined PM-10 impacts are more than 4x the air quality standard 2013 BAF buys the adjacent facility creating a combined operation.
- 8. Project History Year Event 2013 - 2015 BAF refines Alternate Compliance Plan to demonstrate that air quality is better at all locations under the combined plan 2015 DEQ rejects Alternate Compliance Plan. BAF required to submit a plan that shows compliance with air quality standards. Next Option????
- 9. Permitting and Modeling Challenges • No clear path to show needed reductions in PM10 impact (need 80% reductions in impact) – Modeling options exhausted – No apparent treatment options (most of the PM10 is non-filterable materials) – Stack height increases unfeasible • Wind Tunnel analysis of downwash appeared promising
- 10. Downwash Screening – Stack CXX
- 11. Downwash Screening – Stack EU_15
- 12. AERMOD OVERVIEW • Required model to estimate air quality impacts from industrial sources • Model include source emission rates and stack parameters, and fenceline • Also uses input data for site meteorology and building downwash effects
- 13. Building Downwash Image from Lakes Environmental Software
- 14. AERMOD/PRIME Overestimates Downwash Reality AERMOD Building Downwash Height of Building Downwash Zone Overestimated in PRIME
- 15. Equivalent Building Dimension Method for Downwash
- 16. How to Use EBD for Regulatory Purposes? Step 1: Develop a protocol outlining the EBD study Step 2: Submit EBD protocol for approval to regulatory agency. Also need to involve Model Clearinghouse Step 3: Perform wind tunnel testing Step 4: Use building geometry from EBD study in AERMOD to show compliance Step 5: Submit final report for agency review and approval
- 17. Baseline Case (with BPIP values)
- 18. Model Design and Construction • Obtain source/site data • Specify test wind speeds and directions • Compute model operating conditions • Construct scale model
- 19. Phase 1 Testing: Flakers
- 20. Phase 2 Testing: Dehydrators
- 21. Measure Ground-level Concentrations Data taken until good fit and max obtained Automated Max GL Concentration Mapper
- 22. Identify Wind Tunnel Determined EBD that Match Dispersion with Site Structures Present
- 24. EBD Results for EU11
- 25. Baseline Case (with BPIP values)
- 26. WT EBD values for EU 11,12,13,14 (Phase 1) & EU 24, 25, 26, 27, 31,32,33 & 34 (Phase 2) Max PM10 H6H = 89.3 ug/m3
- 27. What Happens Next • DEQ has enthusiastically responded to the information obtained • EPA has reviewed the study and indicated general approval • BAF is resubmitting Alternate Compliance Plan using the EBD study results • With Alternate Compliance Plan approved, BAF will have greater flexibility to make future changes at the facility.
- 28. Questions?