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Compliance Challenges After AERMOD: Impact of Updated Met Data and AERSURFACE on Facilities

Recent modeling using updated meteorological data and the new AERSURFACE method has revealed significant increases in air quality results for many facilities, leading to costly compliance changes. For instance, "Facility X," when modeled with recent CHS data (2002-06) versus older data (1987-91), showed a more than tenfold increase in emissions for some sources. This shift raises questions about the representativeness of meteorological sites versus facility sites. Various methods to assess this representativeness, along with their drawbacks, are discussed in detail.

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Compliance Challenges After AERMOD: Impact of Updated Met Data and AERSURFACE on Facilities

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  1. ISSUE #1:►AERMOD results are generally greater when based on recent met data and “new” AERSURFACE (08009) vs. “old” (met data / “old” AERSURFACE).Impact►Many facilities will suddenly face costly changes to remain in compliance as demonstrated via AERMOD.

  2. Example: “Facility X” • Previously modeled using CHS 1987-91 met data, which used “Old” AERSURFACE. • Recently modeled (same emission rates) using CHS 2002-06 met data, which used “New” AERSURFACE (08009). • Results of latter are >10 times larger for some volume & point sources; >2 times larger overall.

  3. Comparison Summary

  4. “Facility X” Sample AERMOD Results►Volume Sources

  5. “Facility X” Sample AERMOD Results►Point Sources

  6. CHS Sfc Roughness – “New” vs. “Old”

  7. Some AERSURFACE Differences

  8. #2 – How to Determine Representativeness of Met. Site vs. Facility Site ?

  9. Possible Methods (cont’d) A)Model using 2 met. stations, using the higher results. B)Model using met. data from 1 met station and 1) sfc characteristics from the met. station, and 2) sfc characteristics from the facility site; use the higher results ►Drawbacks for A) & B): - “double modeling” time/cost - EPA recommends using sfc roughness from the met site (Bowen Ratio & Albedo can be from facility site).

  10. Possibililties (cont’d) C) Compare Surface Characteristics, land use, terrain, climatology, etc. between met. and facility site. ► How is representativeness defined ? ► Is there a recommended numerical or statistical approach ??

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