Technical Support Document Updating Hazardous Air .

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Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsBureau of Evaluation and PlanningDivision of Air QualityNew Jersey Department of Environmental ProtectionP.O. Box 420, Mail Code 401-02Trenton, New Jersey 08625-0420June 5th, 2017

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsAs outlined in the Rule Proposal, “Air Emission Control and Permitting Exemptions, Hazardous Air PollutantReporting Thresholds, and CO2 and NOx Budget Trading Programs,” the Department developed updated HazardousAir Pollutant (HAP) reporting thresholds. This document provides a detailed description of this evaluation. Theobjective of this effort is to establish HAP reporting thresholds for Air Pollution Control Preconstruction Permits andOperating Permits. This ensures that any new or modified source operation under review by the Department wouldbe subject to a health risk assessment if there was the potential for HAP emissions to cause a significant health risk.This methodology is also being used to update the Department’s Risk Screening Worksheet and Technical Manual1003. The methodology consists of the following three parts: Part 1: Modeling methodology; Part 2: Processing themodeling results; and Part 3: Identifying proposed threshold values.Part 1: Modeling methodologyDispersion ModelThe American Meteorological Society/United States Environmental Protection Agency (USEPA) Regulatory Model(AERMOD) modeling system (Version 15181) was used for this evaluation. AERMOD is the USEPA preferredmodel for regulatory modeling applications. AERMOD is a steady-state plume model that incorporates air dispersionbased on planetary boundary layer turbulence structure and scaling concepts, including treatment of both surface andelevated sources, and both simple and complex terrains.Land UseAERMOD was run in both the rural and urban modes. In the urban mode, a population parameter of 1,000,000 wasused.Meteorological DataMeteorological data sets from three different surface National Weather Service stations along with concurrent upperair stations for the years 2010-2014 were used. The data sets used were: Newark International Airport, PhiladelphiaInternational Airport, and Trenton Mercer Airport. Both the Trenton and Philadelphia data sets used concurrentupper air data from Sterling, Virginia while the Newark site was paired with upper air data from Brookhaven, NewYork. For a detailed description of the methodology used to compile the meteorological datasets, refer to “NJDEPProcessed Meteorological Files (2010-2014) for use in AERMOD Dispersion Modeling Analyses” dated July, 2015(available on request). Figure 1 shows the five-year wind roses of the three meteorological stations used.NJDEP Bureau of Evaluation and Planning26/05/2017

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsFigure 1. Location of Meteorological Stations Showing Five-Year Wind RosesNJDEP Bureau of Evaluation and Planning36/05/2017

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsStack Parameters and Emission RatesHypothetical emission points and structures were entered into the model to represent a range of aerodynamicdownwash scenarios for stacks. The stack parameters and emission rates used to generate the normalized air impactvalues (micrograms per cubic meter (µg/m3) /pound per hour of HAP emitted for short term impacts, µg/m3 / ton peryear of HAP emitted for long term impacts) are listed in Table 1. The stack exit velocity and exit temperature valueswere selected so that plume rise would be minimal. Emissions were assumed to occur 24 hours per day, 365 daysper year. All stacks are located in the middle of the buildings.Table 1. Stack Parameters and Emission RatesParameterValueAnnual Emission Rate1-Hour Emission RateStack HeightsStack DiameterExit VelocityExit temperature1 ton per year (normalized)1 pounds per hour (lb/hr) (normalized)15, 20, 25, 30, 40, 50, 75, 100, 150, 200, 250 feet (ft)1 foot0.33 feet per second80 degrees Fahrenheit (oF)Building DownwashThe building dimensions were selected so that the plume was subjected to aerodynamic downwash in all winddirections. The building dimensions used, including assumed horizontal dimensions, are listed in Table 2. Allstacks are below the Good Engineering Practice (GEP) stack height of 2.5 times higher than the building height. Forstacks heights of 15 ft and 20 ft, the stack was assumed to be a factor of 1.25 times higher than the building height.For all other stack heights (25 ft through 250 ft), the stack was assumed to be a factor of 1.5 times higher than thebuilding height. For stack heights between 15 and 50 ft, the building’s horizontal dimensions were assumed constantat 50 ft. As stack heights increased above 50 ft, the building’s horizontal dimensions also increase. The assumedbuilding’s horizontal dimensions are also shown in Table 2.The USEPA’s Building Profile Input Program (BPIP-PRIME) was used to generate building downwash parametersfor input into AERMOD.NJDEP Bureau of Evaluation and Planning46/05/2017

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsTable 2. Stack Heights and Assumed Building DimensionsStack Height (ft)15202530405075100150200250Building Height (ft)121616.72026.733.45066.7100133.4166.7Building Width and Length (ft)50 x 5050 x 5050 x 5050 x 5050 x 5050 x 5075 x 75100 x 100150 x 150200 x 200200 x 200Receptor GridModeling was performed assuming flat terrain. A polar receptor grid with 864 receptors was used that was centeredon the stack (midpoint of the building) with 36 radials spaced every 10 degrees. The spacing of receptors along theradials were as follows: 20 ft, 30 ft, 40 ft, 50 ft, 60 ft, 70 ft, 80 ft, 90 ft, 100 ft, 150 ft, 200 ft, 250 ft, 300 ft, 400 ft,500 ft, 600 ft, 700 ft, 800 ft, 900 ft, 1000 ft, 1500 ft, 2000 ft, 2500 ft, 3000 ft.Modeling MethodologyThe AERMOD model was run with USEPA’s regulatory default parameters and the parameters discussed above.AERMOD was run to calculate hourly, daily, and annual concentrations. Conversion factors were used to scale thehourly concentrations to longer-term averaging times of 4 hours (0.92), 6 hours (0.87), 7 hours (0.84), 8 hours(0.82), and 24 hours (0.4).Part 2: Processing the modeling resultsThe above modeling methodology resulted in thirty model runs being performed for each of the eleven hypotheticalstacks. A total of 855,360 impacts were generated (3 meteorological data sets x 5 years of data x 2 dispersionenvironments x 846 receptors x 11 stacks x 3 averaging times). Each averaging time generated 285,120 impacts toprocess. In order to identify the maximum air concentration impact by site, distance, urban or rural setting,averaging time, and stack height, the large data files needed to be reformatted. Text editing software was used toreformat the raw model data output in order to process the data.After the data was formatted, it was necessary to write custom macros using VBA scripting tools in Microsoft Excelto combine all the output into a master file that could be used to identify the worst-case impact by distance for eachstack and generate a lookup table to be used for establishing the reporting thresholds. To identify these impacts, theR statistical software (version 3.3.1) was used to extract the maximum predicted air impact value for each modeledNJDEP Bureau of Evaluation and Planning56/05/2017

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting Thresholdsdistance and stack. For stack heights and distances not explicitly modeled, linear interpolation across stack heightsfor a specified distance was performed.Using this process, tables of worst-case hourly and annual impacts by stack height and distance were created forstacks from 15 ft to 250 ft and distances from 20 ft to 3,000 ft. This resulted in tables containing 2,550 values.However, for the purpose of setting HAP reporting threshold values, it is expected that the worst-case impacts willoccur from shorter stacks at distances closer to property line. Review of the Department’s permit database showedthat 71% of approximately 27,000 stacks permitted in NJ (not including general permits) are less than 35 ft high. Ofthese 27,000 stacks, 41% are located 100 ft or less from the facility property line. Based on this analysis, onlyhourly and annual impacts for stacks less than 35 ft and within 100 ft were considered. Figure 2 illustrates theresulting table of normalized annual impacts. The area bounded by the box represents the subset of values used toestablish the HAP reporting thresholds.NJDEP Bureau of Evaluation and Planning66/05/2017

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsFigure 2. Modeling Results (Annual Concentration Per Ton of HAP Emitted) (a)(a)HAP reporting thresholds to be based on concentrations from stacks less than 35 feet high and within a distance of 100 ft fromproperty lineNJDEP Bureau of Evaluation and Planning76/05/2017

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsPart 3: Identifying proposed threshold valuesRather than arbitrarily basing the proposed HAP reporting thresholds on a single stack height/property-linecombination, a robust statistical approach was utilized. This approach considered all modeled stack height/propertyline distance combinations predicted for stacks less than 35 ft high and property lines less than 100 ft from the stack.A percentage frequency distribution of the modeled impacts was evaluated. The resulting percentiles represent aconservative concentration that could reasonably be expected to occur for multiple stack property-line combinations.The dataset contained normalized air concentration values for more than 300 combinations of stack heights andreceptor distances. To generate the proposed HAP threshold values, the 80th, 85th, 90th, and 98th percentiles of themodeled annual impacts were calculated. A percentile identifies the normalized air concentration value where thepercentage of modeled impacts in the dataset are less than the indicated air concentration value. Figure 3 shows thedistribution of modeled normalized annual impacts. The x axis shows the range of the normalized air impact values.The y axis shows the percent occurrence of an annual impact value within the dataset. A normal curve overlays thedataset to illustrate that the dataset is normally distributed. The vertical blue line identifies the 90th percentile at 45µg/m3. This equates to 14 stack/property-line combinations that result in an annual concentration of approximately45 µg/m3. Figures 4 through 6 show the combinations of stack height and distances for the 90th, 85th, and 80thpercentiles respectively. All data analysis and graphs were generated using R statistical software (version 3.3.1).Each of the considered percentiles are shown in the upper right corner.NJDEP Bureau of Evaluation and Planning86/05/2017

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsFigure 3. Percentage Frequency Distribution of Normalized Annual Air ConcentrationsNJDEP Bureau of Evaluation and Planning96/05/2017

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsFigure 4. Stack Height /Distance to Property Line Combinations at the 90th 100Stack re 5. Stack Height /Distance to Property Line Combinations at the 85th 100Stack 732.6331.1930.1129.0228.1627.3026.5025.69NJDEP Bureau of Evaluation and 724.1523.4322.7122.0521.38

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsFigure 6. Stack Height /Distance to Property Line Combinations at the 80th 100Stack 9320.3219.7019.1218.55Evaluation MethodologyEquations 1 and 2 below were used to calculate proposed reporting thresholds for emissions of HAP with availableinhalation exposure toxicity data. Both equations were derived from the Department’s Technical Manual 1003“Guidance on Risk Assessment for Air Contaminant oads/techman/1003.pdf). The normalized annual air impact values (C’ in theequations) were obtained from Figure 3. The 80th, 85th, 90th, and 98th normalized annual impact percentiles wereused. These percentile impact values represent the concentration from multiple combinations of stack heights anddistances to property line that are reasonably expected to occur when one ton per year of a HAP is emitted. Unit riskfactors (URF) and reference concentrations (RfC) used in the equations are based on toxicity data from the latestupdates of USEPA Integrated Risk Information System (IRIS, www.epa.gov/iris), CalEPA Toxicity CriteriaDatabase (oehha.ca.gov/tcdb/index.asp), and Agency for Toxic Substances and Disease Registry “Minimal RiskLevels for Hazardous Substances”, (MRLs, www.atsdr.cdc.gov/mrls/index.asp). Please refer to Appendix C for theURF and the RfC values.Using the normalized annual impacts (C’) and the HAP specific URF or RfC, the equations were used to solve forthe emission threshold that would not exceed the Departments risk guidelines (no more than one-in-one millionexcess cancer risk or a hazard quotient of one).NJDEP Bureau of Evaluation and Planning116/05/2017

Technical Support DocumentUpdating Hazardous Air Pollutant Reporting ThresholdsEquation 1:𝑄𝑄 𝐶𝐶𝐶𝐶𝑈𝑈𝑈𝑈𝑈𝑈 𝐶𝐶′where:Q maximum annual emission rate, ton/yrCR cancer risk; assumed to be 1 x 10-6URF pollutant-specific inhalation unit risk factor, (µg/m3)-1C’ normalized annual emission rate, (µg/m3)/(ton/yr)Equation 2:𝑄𝑄 𝑅𝑅𝑅𝑅𝑅𝑅𝐶𝐶′where:Q maximum annual emission rate, ton/yrRfC pollutant-specific reference concentration, µg/m3C’ normalized annual emission rate, (µg/m3)/(ton/yr)Risk Guidelines for the Proposed HAP Reporting ThresholdsThe Risk Guidelines used in the evaluation are the negligible risk values as listed in Section 5 of Technical Manual1003. The cancer risk guideline is an accumulative cancer risk of less than or equal to one in a million. The noncancer risk guideline is a hazard quotient less than or equal to one. Cancer risk based thresholds were compared tolong-term non-cancer risk thresholds for those HAP that have carcinogenic and non-carcinogenic impacts. Allselected thresholds were analyzed with the Department’s most current “Risk Screening html) to corroborate that no threshold would show a non-negligible risk for ashort-term exposure.The following are principles that have been used to develop the HAP reporting thresholds.1. The maximum HAP reporting threshold has been established as 2000 pounds per year. This is the currentmaximum in N.J.A.C. 7:27-8 and -22 and is not being increased even if the risk evaluation conducteddemonstrates that a threshold above this level would result in a negligible risk. The “2000 lb/yr” is a largeemission rate and facilities should continue to list these HAP in their applications so that the Department canverify the emissions were determined correctly and the contaminants are being adequately controlled, asnecessary.NJDEP Bureau of Evaluation and Plann

In order to identify the maximum air concentration impact by site, distance, urban or rural setting, averaging time, and stack height, the large data files needed to be reformatted. Text editing software was used to reformat the raw model data output in order to process the data.

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