## St. Clair Power Plant

St. Clair, Michigan

Evaluation of Compliance wi th the 1-hour NAAQS for SO 2


## September 17, 2015

Conducted by:

Steven Klafka, P.E., BCEE

Wingra Engineering, S.C.

Madison, WisconsinEvaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 2

1. Introduction

Wingra Engineering, S.C. was hi red by Sierra Club to conduct an air modeling impact analysis to help the U.S. Environmental Prot ection Agency (USEPA), state an d local air agencies identify
facilities that are likely causing exceedances of the 1-hour su lfur dioxide (SO 2 ) national ambient air quality standard (NAAQS). This doc ument describes the results and procedures for an evaluation
conducted for the St. Clair Power Plant located in St. Clair, M ichigan.

To ensure the modeling analysis reflected the cumulative concen tration of SO 2 emissions, it included
emissions from the Belle River P ower Plant in St. Clair, Michig an, which is an additional source of
SO 2 emissions located within 50 kilome ters of the St. Clair Power Plant.

The dispersion modeling analysis predicted ambient air concentr ations for comparison with the 1-
hour SO 2 NAAQS. The modeling was performe d using the most recent versi on of AERMOD, AERMET, and AERMINUTE, with data provided to Sierra Club by reg ulatory air agencies and through other publicly-available so urces as documented below. The analysis was conducted in
adherence to all available USEP A guidance for evaluating source impacts on attainment of the 1-
hour SO 2 NAAQS via aerial dispersion mode ling, including the AERMOD Imp lementation Guide; USEPA's Applicability of Appendi x W Modeling Guidance for the 1 -hour SO 2 National Ambient Air Quality Standard, August 23, 2010; modeling guidance promul gated by USEPA in Appendix W to 40 CFR Part 51; USEPA’s Ma rch 2011 Modeling Guidance for SO 2 NAAQS Designations; 1 and
USEPA’s December 2013 SO 2 NAAQS Designations Technical Assistance Document. 2

2. Compliance with the 1-hour SO 2 NAAQS

2.1 1-hour SO 2 NAAQS

The 1-hour SO 2 NAAQS takes the form of a t hree-year average of the 99 th -percentile of the annual distribution of daily maximum 1- hour concentrations, which cann ot exceed 75 ppb. 3 Compliance
with this standard w as verified using USEPA’s AERMOD air disper sion model, which produces air concentrations in units of μg/m 3 . The 1-hour SO 2 NAAQS of 75 parts per b illion (ppb) equals 196.2 μg/m 3 , and this is the value used for de termining whether modeled im pacts exceed the NAAQS. 4

The 99 th -percentile of the annual dist ribution of daily maximum 1-hour concentrations corresponds to the fourth-highest value at e ach receptor for a given year.

1 http://www.epa.gov/scram001/ so2_modeling_guidance.htm

2 http://www.epa.gov/oaqps001/sulfurdioxide/pdfs/SO2ModelingTAD. pdf

3 USEPA, Applicability of Appendix W Modeling Guidance for the 1- hour SO 2 National Ambient Air Quality Standard, August 23, 2010.

4 The ppb to μg/m 3 conversion is found in the source code to AERMOD v. 14134, sub routine Modules. The conversion calculation is 75/0.3823 = 196.2 μg/m 3

.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 3

2.2 Modeling Results

Model results for both sources i ncluded in the analysis of SO 2 are summarized in Table 1. Results are provided for each source alone, and for both sources combin ed.

Modeling results for St. Clair P ower Plant are summarized in Table 1. It was determined that based
on either current allowable emissions or measured actual emissi ons, the St. Clair Power Plant is
estimated to create downwind SO 2 concentrations which exceed the 1-hour NAAQS.

More specifically, the modeling results presented in Table 1, s how exceedances of the NAAQS by the plant’s allowable and actua l emissions. “Allowable” is the peak emission rate from each unit as approved by the current air quali ty operation permit for the fa cility. “Actual” are the measured emissions for each hour between January 1, 2012 and December 31 , 2014 as taken from USEPA Air Markets Program Data

. 5

In addition, the emissions from t he Belle River significantly c ontribute to the ambient SO 2 concentration in the area imp acted by St. Clair power plant.

Air quality impacts in Michi gan are based on a background conce ntration of 23.5 μg/m 3 . This is the 2011-13 design value for Kent County, M ichigan – the lowest mea sured background concentration in the state. This is the most recently available design value . See Section 5 for f urther discussion of the background concentrations used for this analysis.

Table 1 - SO 2 Modeling Results for St. Clair Power Plant Modeling Analysis

Emission Rates Averaging Period 99 th Percentile 1-hour Daily Maximum (μg/m 3 ) Complies with NAAQS? Impact Background Total NAAQS

Allowable Belle River 246.5 23.5 270.0 196.2 No

Actual 101.0 23.5 124.5 196.2 Yes

Allowable St. Clair 513.1 23.5 536.6 196.2 No

Actual 238.9 23.5 262.4 196.2 No

Allowable Both 622.3 23.5 645.8 196.2 No

Actual 246.7 23.5 270.2 196.2 No

The emissions used for the mode ling analysis are summarized in Table 2.

5 http://ampd.epa.gov/ampd/Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 4

Table 2 - Modeled SO 2 Emissions 6

Stack

ID Unit ID Allowable Emissions Monthly Average (lbs/hr) B01 Unit 1 8,176.8 B02 Unit 2 8,176.8 Belle River Power Plant Subtotal 16,353.6 S01 Unit 1 2,355.0 S02 Unit 2 2,355.0 S03 Unit 3 2,354.7 S04 Unit 4 2,357.7 S06 Unit 6 5,187.0 S07 Unit 7 7,840.7 St. Clair Power Plant Subtotal 22,450.1 Both Stations Total 38,803.7

Based on the modeling results, Table 3 provides the emission re ductions from current allowable rates necessary to achieve com pliance with the 1-hour NAAQS. T his assumes a one-hour averaging period for the emission rate and that the emission rate is bind ing at all times. However, given the conservative aspects of this modeling protocol, it is extremely likely that this limit is too high to protect the NAAQS. For example , startup or shutdown periods wer e not evaluated. During these periods, decreased gas velocities and temperatures may lead to greater ambient impacts at ground level. Further, the hypothetic al emission limitation in Table 3 would allow St. Clair Power Plant to consume the entire NAAQS, leav ing little to no room for any oth er source of SO 2 in the area. No margin of safety has been incl uded in the hypothetical emission limitation.

Table 3 - Required Emission Reduct ions from St. Clair Power Plant for Compliance with the 1-
hour NAAQS for SO 2 Acceptable Impact (NAAQS - Background) 99th Percentile 1-hour Daily Max (μg/m 3 ) Required Total Facility Reduction Based on Allowable Emissions (%) Required Total Facility Emission Rate (lbs/hr) Required Total Facility 1-hour Average Emission Rate

(lbs/mmbtu)
172.7 72% 6,230.3 0.46

Predicted exceedances of the 1-hour NAAQS for SO 2 based on allowable emissions extend throughout the region to a maxim um distance of 46 kilometers.

6 Michigan Department of Environmental Quality, Renewal Operatin g Permit MI-ROP-B2796-2009, June 1, 2009. The emission limit for each boiler at the Belle River Power Plant i s 1.2 lbs/mbtu heat input (3-hour average) and for each boiler at the St. Clair Power Plant is 1.67 lbs/mmbtu (monthly average).Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 5

Figure 1 shows the extent of NAA QS violations based on allowabl e emissions from both sources.

Figure 2 shows the extent of NAA QS violations based on actual h ourly emissions from both sources.

2.3 Conservative Modeling Assumptions

A dispersion modeling analysis requires the selection of numero us parameters which affect the predicted concentrations. For the enclosed analysis, several pa rameters were selected which underpredict facility impacts.

Assumptions used in this modeli ng analysis which likely under-e stimate concentrations include the following:

 Allowable emissions are base d on a limitation with an averaging period which is greater than the 1-hour average used for the SO 2 air quality standard. Emissions and impacts during any 1-hour period may be higher than assumed for the modeling analy sis.

 No consideration of facility operation at less than 100% load. Stack parameters such as exit flow rate and temperature are typically lower at less than full load, reducing pollutant dispersion and increasing predic ted air quality impacts.

 No consideration of building or s tructure downwash. These downw ash effects typically increase predicted concentr ations near the facility.

 No evaluation has been conducted t o determine if the stack heig ht exceeds Good Engineering Practice (GEP) height. If the stack height exceeds GEP, the pre dicted concentrations will increase.

 Except for the Belle River Pow er Plant, no consideration of off -site sources. These other sources of SO 2 will increase the predicted impacts.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 6

Figure 1 - Regional View of Impacts Due to Allowable Emissions from Both SourcesEvaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 7

Figure 2 - Regional View of Impacts Due to Actual Emissions for the 2012-14 Period from Both SourcesEvaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 8

3. Modeling Methodology

3.1 Air Dispersion Model

The modeling analysis used U SEPA’s AERMOD program, v. 14134. A ERMOD, as available from the Support Center for Regulator y Atmospheric Modeling (SCRAM) website, was used in conjunction with a third-par ty modeling software program, AERMOD View , sold by Lakes
Environmental Software.

3.2 Control Options

The AERMOD model was run with t he following control options:

 1-hour average air concentrations

 Regulatory defaults

 Flagpole receptors
To reflect a representative i nhalation level, a flagpole height of 1.5 meters was used for all modeled receptors. This parameter was added to the receptor file when running AERMAP, as described in
Section 4.4.

An evaluation was conducted to det ermine if the modeled facilit y was located in a rural or urban setting using USEPA’s methodology outlined in Section 7.2.3 of the Guideline on Air Quality
Models. 7 For urban sources, the URBANOPT option is used in conjunction with the urban population from an appropriate ne arby city and a default surfac e roughness of 1.0 meter. Methods
described in Section 4.1 were used t o determine whether rural o r urban dispersion coefficients were appropriate for the modeling analysis.

3.3 Output Options

The AERMOD analysis was based on three years of recent meteorol ogical data. The modeling analyses used one run with three ye ars of sequential meteorolog ical data from 2012-2014. Consistent with USEPA’s Modeling Guidance for SO 2 NAAQS Designations, AER MOD provided a table of fourth-high 1-hour SO 2 impacts concentrations consiste nt with the form of the 1-hour SO 2 NAAQS. 8

Please refer to Table 1 for the modeling results.

7 USEPA, Revision to the Guidelin e on Air Quality Models: Adopti on of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions, Appendix W to 40 CFR Part 51, November 9, 2005.

8 USEPA, Area Designations for the 2010 Revised Primary Sulfur Di oxide National Ambient Air Quality Standards, Attachment 3, March 24, 2011, pp. 24-26.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 9

4. Model Inputs

4.1 Geographical Inputs

The “ground floor” of all air dis persion modeling analyses is e stablishing a coordinate system for identifying the geographical loc ation of emission sources and r eceptors. These geographical
locations are used to determine local characteristics (such as land use and elevation), and also to ascertain source to receptor di stances and relationships.

The Universal Transverse Merca tor (UTM) NAD83 coordinate system was used for identifying the easting (x) and northing (y) coordi nates of the modeled sources and receptors. Stac k locations were obtained from facility permits and prior modeling files provide d by the state regulatory agency. The
stack locations were then veri fied using aerial photographs.

The facility was evaluated to de termine if it should be modeled using the rural o r urban dispersion coefficient option in AERMOD. A Geographic Information System (GIS) was used to determine whether rural or urban dispersi on coefficients apply to a site. Land use within a three-kilometer radius circle surrounding the f acility was considered. USEPA gu idance states that urban dispersion
coefficients are used if more t han 50% of the area within 3 kil ometers has urban land uses. Otherwise, rural dispersion c oefficients are appropriate. 9

USEPA’s AERSURFACE v. 13016 was use d to develop the meteorologi cal data for the modeling analysis. This model was also us ed to evaluate surrounding land use within 3 kilometers. The evaluated power plants are locat ed on the Canadian border with the U.S. The 1992 National Land Cover Data or NLCD data require d by AERSURFACE does not extend into Canada. For this reason,
AERSURFACE was not used to eval uate surrounding land use. Inste ad, based on a review of aerial photographs, it was clear the l and use surrounding both power p lants is rural. It was concluded that the rural option would be used f or the modeling summarized in t his report.

9 USEPA, Revision to the Guidelin e on Air Quality Models: Adopti on of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions, Appendix W to 40 CFR Part 51, November 9, 2005, Section 7.2.3.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 10

4.2 Emission Rates and Source Parameters

Concentrations were predicted f or the scenarios shown in Tables 1 and 2:

1) allowable emissions based on t he current permit issued by th e regulatory agency, and

2) actual hourly emissions meas ured each hour between January 1 , 2012 and December 31,
2014 as taken from USEPA Air Markets Program Data

. 10

Stack parameters and emissions use d for the modeling analysis a re summarized in Table 4.

Table 4 – Facility Stack Parameters and Emissions 11

Facility Belle River St. Clair

Stack B01 B02 S01 S02 S03 S04 S06 S07

Description Unit 1 Unit 2 Unit 1 Unit 2 Unit 3 Unit 4 Unit 6 Un it 7

X Coord. [m] 377804 377713 379538 379538 379538 379538 379597 3 79629

Y Coord. [m] 4736933 4736972 4735415 4735415 4735415 4735415 47 35659 4735718

Base Elevation [m] 179.91 179.81 177.63 177.63 177.63 177.63 17 7.4 177.35

Release Height [m] 200.04 200.04 182.58 182.58 182.58 182.58 12 9.54 182.88

Gas Exit Temperature [°K] 416.48 416.48 422.04 424.82 422.04 42 4.82 422.04 408.15

Gas Exit Velocity [m/s] 27.432 27.432 27.889 32.034 30.267 27.7 06 49.225 40.234

Inside Diameter [m] 7.772 7.772 4.06 4.06 4.06 4.06 4.054 4.877

Allowable Emission Rate [g/s] 1,030 1,030 296.7 296.7 296.7 296 .7 653.6 987.9

Actual Emission Rate [g /s] - - - - - - - -

The above stack parameters and emissions were obtained from reg ulatory agency documents and
databases identified in Secti on 2.2. The analysis was conducted based on 100% operating load using
maximum exhaust flow rates and t emperatures. Operation at less than full capacity loads was not considered. This assumption te nds to under-predict impacts sinc e stack parameters such as exit flow rate and temperature are typically lower at less than full load , reducing pollutant dispersion and increasing predicted air qualit y impacts. Stack location, heigh t and diameter were verified using aerial photographs, and flue gas fl ow rate and temperature were verified using combustion
calculations.

10 http://ampd.epa.gov/ampd/

11 Stack parameters were obtained fro m an AERMOD input file from a previous modeling anlaysis provided by the Michigan Department of Environmental Quality, SCPP BRPP 1Hr SO2 SIA Run 50km 05_09 Aux DG 15PPM_5yrs_SO2.DTA, April 24, 2012Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 11

4.3 Building Dimensions and Good Engineering Practice Height

No building dimensions or prior dow nwash evaluations were avail able. Therefore this modeling analysis did not address the e ffects of downwash and this may u nder-predict impacts.

In addition, no evaluation has b een conducted to determine if t he stack height exceeds GEP height. If the stack height exceeds GEP, the predicted concentrations may under-predict impacts.

4.4 Receptors

For St. Clair Power Plant, three receptor grids were employed:

1. A 100-meter Cartesian receptor grid centered on St. Clair Power Plant and extending out 5
kilometers.
2. A 500-meter Cartesian receptor grid centered on St. Clair Power Plant and extending out 10
kilometers. 3. A 1,000-meter Cartesian receptor grid centered on St. Clair Pow er Plant and extending out 50 kilometers. 50 kilometers is the maximum distance accepted by U SEPA for the use of the AERMOD dispersion model. 12

A flagpole height of 1.5 meters w as used for all these receptor s. Elevations from stacks and recep tors were obtained from Nationa l Elevation Dataset (NED) GeoTiff data. GeoTiff is a binary file tha t includes data descriptors a nd geo-referencing information necessary for extract ing terrain elevations. These elevations w ere extracted from 1 arc-second (30 meter) resolution NED files. The U SEPA software program AERMAP v. 11103 is used for these
tasks.

4.5 Meteorological Data

To improve the accuracy of the modeling analysis, recent meteor ological data for the 2012- 2014period were prepared using the U SEPA’s program AERMET which creates the model-ready surface and profile data files required by AERMOD. Required d ata inputs to AERMET included surface meteorological measurements, twice-daily soundings of u pper air measurements, and the micrometeorological parameters surface roughness, albedo, and B owen ratio. One-minute ASOS
data were available so USEPA met hods were used to reduce calm a nd missing hours. 13 The USEPA software program AERMINUTE v. 14237 is used for these tasks.

12 USEPA, Revision to the Guideline on Air Quality Models: Adopti on of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions, Appendix W to 40 CFR Part 51, Section A.1.(1), November 9, 2005.

13 USEPA, Area Designations for the 2010 Revised Primary Sulfur D ioxide National Ambient Air Quality Standards, Attachment 3, March 24, 2011, p. 19.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 12

For this modeling project, pre-pr ocessed meteorological data we re provided by the Michigan Department of Environmental Quality (DEQ). 14, 15 Data for the 2012 to 2013 period were downloaded from the DEQ web site and data for the 2014 period w ere provided directly by DEQ. The agency prepared its meteoro logical data usin g the procedure s described in this report.

This section discusses how the meteorological data was prepared for use in the 1-hour SO 2 NAAQS modeling analyses. The USEPA software program AERMET v. 14134 is used for these tasks.

4.5.1 Surface Meteorology

Surface meteorology was obtained for St. Clair International Ai rport located near the St. Clair Power Plant. Integrated Surface Hour ly (ISH) data for the 2012-2014 p eriod were obtained from the National Climatic Data Center ( NCDC). The ISH surface data wa s processed through AERMET Stage 1, which performs data ex traction and quality control che cks.

4.5.2 Upper Air Data

Upper-air data are collected by a “ weather balloon” that is rel eased twice per day at selected
locations. As the balloon is rel eased, it rises through the at mosphere, and radios the data back to the surface. The measuring and transmitting device is known as eit her a radiosonde, or rawindsonde.
Data collected and radioed back i nclude: air pressure, height, temperature, dew point, wind speed, and wind direction. The upper air data were processed through AERMET Stage 1, which performs data extraction and quality control checks.

For St. Clair Power Plant, t he concurrent 2012-2014 upper air d ata from twice-daily radiosonde
measurements obtained at the most representative location were used. This location was the White Lake, Michigan measurement station. These data are in Forecast Systems Laboratory (FSL) format
and were downloaded in ASCII textformat from NOAA’s FSL websit e. 16 All reporting levels were downloaded and processed with AERMET.

4.5.3 AERSURFACE

AERSURFACE is a program that ex tracts surface roughness, albedo , and daytime Bowen ratio for an area surrounding a given locatio n. AERSURFACE uses land use and land cover (LULC) data in the U.S. Geological Survey’s 1992 National Land Cover Dataset t o extract the necessary

14 Michigan Department of Environmental Quality, Map of Available Meteorological Stations, http://www.michigan.gov/documents/deq/deq-aqd-mm-met_support_25 6121_7.pdf

15 Email from J. Haywood – MDEQ to S. Klafka – Wingra Engineering , S.C., Request for AERMOD Modeling Meteorology for Michigan Power Plants, May 18, 2015.

16 Available at: http://esrl.noaa.gov/raobs/Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 13

micrometeorological data. LULC data was used for processing me teorological data sets used as input to AERMOD.

AERSURFACE v. 13016 was used to deve lop surface roughness, albe do, and daytime Bowen ratio values in a region surrounding the meteorological data collecti on site. AERSURFACE was used to develop surface roughness in a one kilometer radius surrounding the data collection site. Bowen ratio and albedo was developed for a 10 kilometer by 10 kilomet er area centered on the meteorological data collection si te. These micrometeorological data were processed for seasonal periods using 30-degree sectors.

4.5.4 Data Review

Missing meteorological data were not filled as the data file me t USEPA’s 90% data completeness requirement. 17 The AERMOD output file shows th ere were 0.12% missing data.

To confirm the representativene ss of the airport meteorological data, the surface characteristics of the airport data collection s ite and the modeled source locatio n were compared. Since the St. Clair International Airport is locate d close to St. Clair Power Plant , this meteorological data set was considered appropriate for this modeling analysis. 18 This weather stati on provided high quality surface measurements for the most recent 3-year time, and had s imilar land use, surface characteristics, terrain featur es and climate. Finally, DEQ pro vided pre-processed meteorological data for this project, whichha d concluded the weather stations were representative of the project
location.

5. Background SO 2 Concentrations

Background concentrations were determined consistent with USEPA ’s Modeling Guidance for SO 2 NAAQS Designations. 19, 20 To preserve the form of the 1-hour SO 2 standard, based on the 99 th percentile of the annual distri bution of daily maximum 1-hour c oncentrations averaged across the number of years modeled, the b ackground fourth-highest daily ma ximum 1-hour SO 2 concentration
was added to the modeled fourth-h ighest daily maximum 1-hour SO 2 concentration. 21 Background
concentrations were based on the 2011-13 design value measured by the ambient monitors located in

17 USEPA, Meteorological Monitoring Guidance for Regulatory Modeli ng Applications, EPA-454/R-99-05, February 2000, Section 5.3.2, pp. 5-4 to 5-5.

18 USEPA, AERMOD Implementation Guide, March 19, 2009, pp. 3-4.

19 USEPA, Area Designations for the 2010 Revised Primary Sulfur D ioxide National Ambient Air Quality Standards, Attachment 3, March 24, 2011, pp. 20-23.

20 USEPA, SO 2 NAAQS Designations Modeling Te chnical Assistance Document, Dec . 2013, section 8.1, pp 27-28.

21 USEPA, Applicability of Appendix W Modeling Guidance for the 1- hour SO 2 National Ambient Air Quality Standard, August 23, 2010, p. 3.Evaluation of Compliance with the 1-hour NAAQS for SO 2 September 17, 2015 Page 14

Michigan. 22

6. Reporting

All files from the programs used for this modeling analysis are available to regulatory agencies. These include analyses prepared w ith AERSURFACE, AERMET, AERMAP , and AERMOD.

22 http://www.epa.gov/airtrends/values.html