Missouri Department of Natural Reso urces’ Air Pollution Control Program

Airport Selection —Meteorological Data Rep resentative of Exide Technologies-Canon

Hollow

Background and Purpose

The Exide Technologies’ Canon Hollow facility (Exide) is located on about 640 acres 4 miles northwest of Forest City, Missouri, in Holt County. Exide is an active facility that recycles leadacid storage batteries and other lead-bearing ra w materials purchased offsite by smelting the material into new lead ingots. The facility uses four pot furnaces and a blast furnace to smelt the recycled lead components. The plastic and acid are collected and shipped off site. The installation uses baghouses, an af ter-burner, a scrubber, and stre et sweepers to control sulfur, lead, volatile organic compounds and particulate matter emissions. This facility is a major source of volatile organic compound ( VOC) and sulfur dioxide (SO 2 ) emissions.

Monitoring data from March through September 2012 indicate that Exid e is violating the 2008 lead National Ambient Air Quality Standard ( NAAQS). The Missouri Department of Natural Resources’ Air Pollution Control Program and Exide are working cooperatively on developing a State Implementation Plan (SIP) to address this i ssue and bring the facility into compliance with the 2008 lead NAAQS as expeditiously as prac ticable. The Air Program, Exide and EPA Region 7 met on November 6, 2012 to kick off the SIP development process. The group agreed to submit the SIP to EPA on an expedited timeline, no later than April 2014.

A key component of the SIP will be an air disp ersion modeling analysis showing that Exide will attain and maintain the lead NAAQS based on propos ed control measures taken by the facility. Based on EPA modeling guidance, it is preferable that one year or more, up to five years, of onsite meteorological data be used in the disp ersion modeling exercise (40 CFR Part 51 Appendix W (November 2005)). The document entitled “Meteorological Mon itoring Guidance for Regulatory Modeling Applications” describes the criteria that s hould be considered when siting meteorological instruments for modeling purpos es. Typically, wind instruments should be placed on a boom that is located at least two meters away from an open lattice ten-meter tower in an area that is free from obstructions. The pl acement of wind instrume nts on buildings, cooling

towers or stacks should be avoided due to the potential for downwash influences. The effect on the wind speed and direction can be significant an d can result in non-repres entative, poor quality data. If an instrument is placed on a building, the probe would have to be clear of any wake zones that are present and should be representati ve of the conditions that are occurring at the point of release (minimum of ten meters). Due to the fact that Exide’s meteorological station is located on a roof of a building, it was determined that data collected by it is not appropriate for a SIP attainment demonstration modeling evaluation.

Due to the expedited SIP development schedu le, at the November 6, 2012 meeting, the group agreed that collecting one year of on-site meteorological data is not feasible at this time. Instead, meteorological data collected at a representative airport should be used for the SIP modeling analysis. This document will evaluate three airports’ meteorological data (Kansas City International Airport, Rosecrans Memorial Airport, and Brenner Field located near Falls City, Nebraska) to determine which data most closel y represent conditions at the facility. Theseairports were selected since they are the closest to Exide. Other airports located farther away have weather patterns which are quite different from that of the facility.

Representative Airport Determination

To determine a representative airport for Exide, three characteristics that describe the surface surrounding the airport and facility must be compared: the surface roughness length, albedo and Bowen ratio. The surface roughness le ngth is related to the height of obstacles to the wind flow and is, in principle, the height at which th e mean horizontal wind speed is zero based on a logarithmic profile. The surface roughness length influences the surface sh ear stress and is an important factor in determining the magnitude of mechanical turbulence and the stability of the boundary layer. The albedo is the fraction of to tal incident solar radiation reflected by the surface back to space without absorption. The daytime Bowen ratio, an indicator of surface moisture, is the ratio of sensible heat flux to la tent heat flux and, togeth er with albedo and other meteorological observations, is used for determ ining planetary boundary layer parameters for convective conditions driven by the surface se nsible heat flux. Because these surface characteristics can influence the similarity prof iles that are utilized by the dispersion model, AERMOD, one must determine if the surface charact eristics at the meteorological site are similar to those at the facility site . A direct comparison between the surface characteristics at the meteorological site and those at th e surface site is necessary to de termine if the differences that result will significantly impact the ov erall pollutant concentrations.

In order to provide a consistent method for determining surface characteristics, the EPA developed a mathematical tool, AERSURFACE, to determine surface roughness length, Bowen ratio, and albedo values fo r input into AERMET.

AERSURFACE employs land cover data from the United States Geological Survey 1992

National Land Cover data archives. Each of th e 21 land use categories contained within the land

cover database are linked to a se t of seasonal surface characteristics as defined in Tables A-1, A2, A-3 and 2-2 of the AERSURFACE User’s Guide. The seasonal categories represent the same categories employed by the AERMOD system for its gas deposition algorithms.

As noted in the AERSURFACE User’s Guide, EPA’s recommendations for determining surface

characteristics in Section 3.1 of the AERM OD Implementation Guide dated, March 19, 2009, have been incorporated into the AERSURFACE tool. The Department’s Air Pollution Control Program executed AERSURFACE using th e default values described below:

 Bowen ratio

o Ten kilometer by ten kilometer domain centered on the site.

 Albedo

o Ten kilometer by ten kilometer domain centered on the site.

 Surface roughness length

o Default upwind distance of one k ilometer centered on the site.

o Twelve, 30 degree meteorological sectors.Other considerations made in the execution of th e AERSURFACE tool include the site type (is the site an airport?), site clim atology (arid or not?) and surface moisture (dry, average, wet). Because the surface moisture can vary base d upon the meteorological period, AERSURFACE

was executed for each moisture condition.

For this project, the surface characteristics surro unding three airports (Kansas City International Airport, Rosecrans Memorial Air port, and Brenner Field located n ear Falls City, Nebraska) were compared to the surface characteristics surroundi ng Exide. Figures 1, 2, 3 and 4 show aerial photos at Exide, Kansas City International Air port, Rosecrans Memorial Airport, and Brenner Field, Nebraska, respectively. In addition, each of the three airports was evaluated based upon proximity to Exide, shown in Figure 5. Refer to the attached Excel document (Exide & Airports Site Characteristics Tables.xls) for th e surface characteristics results.

The first site under consideration was Brenner Field, Nebraska. This airport is the closest to the Exide facility at a distance of 31-kilometers; refer to Figures 4 and 5, and “Brenner Field, NE” sheet in the attached Excel document. The prim ary difference in the land use between Exide and Brenner Field is the presence of the forested ar eas immediately surrounding Exide. In addition, 8% and 1% of the land uses are developed area s around Brenner Field and Exide, respectively; refer to the pie charts in “Brenner Field, NE” wo rksheet in the Excel document. The similarity in land use is the presence of large areas of herbaceous (89%) surrounding the airport and large herbaceous (67%) to the west of Exide within the Missouri River floodplain as shown in Figure 1 and the pie charts. Based upon surface ch aracteristics, without terrain considerations,

the land use between the two sites is not iden tical, with greater roughne ss values noted near Exide due to the presence of trees; refer to the pie charts in “Brenner Field, NE” worksheet and

Table 3 in the Excel document.

The second site under considera tion was the Kansas City Inte rnational Airport. It is approximately 92-kilometers from Exide and has similar land use characteristics to the Brenner Field, Nebraska airport site, refer to Figure 2. Kansas City Intern ational does have some forested areas, however. The surface roughness parameters for Brenner Field, Nebraska are slightly better than those at Kansas City International as compar ed to the parameters at Exide as shown in Table 3 and Table 1 in the “Brenner Field, NE” and “Kansas City International” worksheets, respectively. For example, as shown in these tables, the differences in average surface roughness between Exide and Brenner airport for average moisture conditions in winter, spring, summer and fall are 0.0550, 0.1105, 0.1975 and 0.2024, respectively. While the differences in average surface roughness between Exide and Kansas City airport for average moisture conditions in winter, spring, summer and fall ar e 0.0613, 0.1264, 0.2619 and 0.2696, respectively.

Rosecrans Memorial Airport ha s the least surf ace roughness amongst the three airports as compared to Exide. In addition, 43% of the la nd surrounding the airport is developed, as shown in the pie chart in “Rosecrans Memorial” worksh eet, as compared to on ly 1%, 8% and 16% of the lands surrounding Exide, Brenner Field and Kans as City International Airport, respectively. Therefore, this airport is the least similar and wa s not considered in the final airport selection.Based upon the information that is available and given the similar land use characteristics to both Kansas City International and Br enner Field airports, the proxim ity of Brenner Field, Nebraska to the Exide facility indicate s that it is the best choice for the Exide model evaluation.

Figure 1: Aerial Photo Showing Exide Site CharacteristicsFigure 2: Aerial Photo Showi ng Kansas City International Airport Site CharacteristicsFigure 3: Aerial Ph oto Showing Rosecrans Memorial Airport Site CharacteristicsFigure 4: Aerial Photo Showing Brenner Field, Ne braska Site CharacteristicsFigure 5: Proximity of the Three Airports to Exide

Brenner Field

, NE