### AERMOD Modeling of Air Quality Impacts of the Proposed Morrow Pacific Project

Final Report

October 2012

Prepared for

Ms. Jessica Loarie
SIERRA CLUB San Francisco, California

Prepared by
Mr. Khanh T. Tran Principal



### AMI Environmental 206 Black Eagle Ave Henderson, NV 89002

Tel. (714)679-73632 Table of Contents

Page
I. Introduction 4

II. Modeling Methodologies 4
A. Model Version 4

B. Source Emissions 4
C. Stack Parameters 6

D. Receptors 6

E. Meteorological and Ozone Data 7

F. Background Concentrations 7

III. Modeling Results 11
A. 1-hour NO 2 Impacts 11

B. 1-hour SO 2 Impacts 18
C. 24-hour PM 2.5 Impacts 19

D. Annual NO 2 Impacts 22

E. Nitrogen Deposition Impacts 24

IV. Conclusions 27

V. References 28

Appendix A - Summary of AE RMOD-Predicted 1-hour NO 2 Impacts (Full Conversion) of Port of Morrow Operations

Appendix B - Summary of AE RMOD-Predicted 1-hour NO 2 Impacts (Tier 3-OLM) of Port of Morrow Operations

Appendix C - Summary of AE RMOD-Predicted 1-hour NO 2 Impacts (Tier 3-PVMRM) of Port of Morrow Operations

Appendix D - Summary of AE RMOD-Predicted 1-hour NO 2 Impacts (Full Conversion) of Port Westward Operations with Transloader using Emergency Power

Appendix E - Summary of AE RMOD-Predicted 1-hour NO 2 Impacts (Full Conversion) of Port Westward Operations w ith Transloader using Shore Power

Appendix F - Summary of AE RMOD-Predicted 1-hour SO 2 Impacts of Port of Morrow Operations with Ultra Low Sulfur Fuel3 Table of Contents (continued)

Appendix G - Summary of AE RMOD-Predicted 1-hour SO 2 Impacts of Port Westward Operations with Ultra Low Sulfur Fuel

Appendix H - Summary of AE RMOD-Predicted 24-hour PM 2.5 Impacts of Port of Morrow Operations with Encl osed Barges and Trains

Appendix I - Summary of AE RMOD-Predicted 24-hour PM 2.5 Impacts of Port of Morrow Operations with Open Barges and Closed Trains

Appendix J - Summary of AE RMOD-Predicted 24-hour PM 2.5 Impacts of Port of Morrow Operations with Closed Barges and Open Trains

Appendix K - Summary of AERMOD-Predicted Annual NO 2 Impacts of Port of Morrow Operations

Appendix M - Summary of AERMOD-Predicted NO 2 Deposition Impacts of Port of Morrow Operations4 I. INTRODUCTION

This document presents the methodologies a nd results of a modeli ng analysis of air quality impacts of the proposed Morrow P acific Project (MPP) in Oregon. The MPP includes three operating stages. In the first stage, coal will be offloaded from trains at the
Port of Morrow via enclosed f acilities into enclosed storage buildings and transferred into enclosed barges by enclosed conveyors. In th e second stage, coal will be shipped down the Columbia River by enclosed barges to Port Westward in Columbia County. The MPP third stage involves the coal transloading from barges in to ocean-going vessels (OGV). An Environmental Review (ER) and an ai r pollution permit application have been prepared for the MPP. However, no disper sion modeling has been performed in these documents to quantify the project impacts. Hence, AMI Environmental has been asked by
Sierra Club to conduct an air quality modeling analysis usi ng the regulatory dispersion model AERMOD to predict project impacts of criteria pollutants, such as nitrogen dioxide (NO 2 ), sulfur dioxide (SO 2 ) and fine particulates (PM 2.5 ). Project impacts are compared against applicable national am bient air quality standards (NAAQS).

II. MODELING METHODOLOGIES

This section documents the methodologies a nd assumptions used in the generation of modeling inputs such as source emissions, st ack parameters, receptors, meteorological data and background concentrations.

A. Model Version

Version 12060 of the AERMOD model has b een used in the modeling study. It is currently the latest version of the mo del that has been approved by the U.S. Environmental Protection Agency (USEPA, 20 12). The most recent modeling guidance by US EPA has been implemented in the AERMOD model and it is fully capable of predicting project impacts for comparison ag ainst recent short-term NAAQS, e.g. the 1-
hour NO 2 NAAQS of 100 ppb (188 ug/m 3 ), the 1-hour SO 2 NAAQS of 75 ppb (196 ug/m 3 and the 24-hour PM 2.5 NAAQS of 35 ug/m 3 as well as the annual NO 2 NAAQS of 53ppb (100 ug/m 3 ).

B. Source Emissions

Two basic scenarios are considered for m odeling by the AERMOD model. In the first scenario, coal is unloading from trains while barges are loading at the dock in Port of
Morrow. The second scenario involves coal loading at Port Westward onto a Panamax while the transloader is testing the emergenc y generator and a tug boa t assisting the barge unloading operation. For both scenarios, AERMOD modeling has been performed for 1-
hour and annual NO 2 and SO 2 . PM 2.5 impacts are only modeled for the first scenario.5 Pollutant annual emissions for all modeled s ources are taken from the Project ER. Table
1 shows total annual emissions for each pollutant (NO

x , SO 2 and PM 2.5 ) at Port of
Morrow. To convert these annual emissi ons into hourly emissions required by AERMOD, information about train and tug boat activities documented in the project ER are used. For trains, there will be 607 trains per year and 12 hours for train unloading. For tug boats, there will be 630 trips and 9 hours for barge load ing. The storage facility is assumed to be a continuous source (365 days, 24 hours per day).

Table 1 also shows the PM 2.5 emissions from wind erosi on of coal on open barges and open trains (railcars). The project ER states that the four-barge tow is 650 ft long by 84 ft wide, resulting in an exposed surface area of A=1.256 acre. Using the emission factor in
Table 11.9-1 of AP-42 for wind erosion from co al piles, wind erosion emissions of open barges can be estimated from:

PM 2.5 of open barge (lb/hr) = 0.72*u*A* F = 4.341 lb/hr

where u is the wind speed (=2*32 where 32 mph is the highest daily wind speed averaged over daytime hours at Hermis ton during 2007-2011 and the factor 2 is to account for wind gust), A is the exposed surface area (=1.256 acre)
F is the fraction of PM 2.5 (=0.075 from AP-42 Section 13.2.5.3)

The length of a unit train is 5,800 ft (ER p. 2- 6) and it has a width of 9.5 ft. Its exposed
surface area is calculated to be A = 1.26 acre. Windblown dust emissions from railcars of a unit train are then estimated using the sa me AP-42 formula above (Phyllis Fox, Train Staging, Oct. 28, 2012):

PM 2.5 of open train (lb/hr) = 0.72*64*1.26* 0.075 = 4.35 lb/hr

Table 1
Pollutant Emissions for Modeled Sources at Port of Morrow

Emission
Sources NO
x (tpy) 1-hr NO
x (lb/hr) SO 2 (tpy) 1-hr
SO 2 (lb/hr) PM 2.5 (tpy) 24-hr

PM 2.5 (lb/hr) Train unloading 492 135.09 0.3 0.824 12.8 3.51 Tug boat 39 13.76 0.0088 0.0031 0.92 0.32 Storage facility -- -- -- -- 0.012 0.0027 Open barge -- -- -- -- -- 4.341 Open train -- -- -- -- -- 4.356 Table 2 shows the modeled sources and em issions at Port Westward. Total annual emissions have been taken from the projec t ER. For converting these annual emissions into hourly emission rates, all modeled sour ces are assumed to operate continuously (365 days, 24 hours per day) as stated in the project ER.

Table 2
Pollutant Emissions for Modeled Sources at Port Westward

Emission Sources NO
x (tpy) 1-hr
NO
x (lb/hr) SO 2 (tpy) 1-hr
SO 2 (lb/hr)

Panamax 81.5 18.61 14.7 3.36 Transloader (emergency power) 281 64.16 0.048 0.011 Transloader (shore power) 0.33 0.0753 7.9e-5 1.80e-5 Tug boat 32 7.31 0.0042 0.00096

B. Stack Parameters

Project emissions are modeled as point sources. Stack parameters (stack height, diameter, temperature and exit velocity) for the modele d sources are shown in Table 3. They are taken from the modeling studies of port operations conducted by the California Air Resources Board (CARB, 2006) and New Je rsey Department of Environmental Protection (NJDEP, 2009). Emissions from t ug boats and barges are released from a height of 20 ft. Windblown dust emissions from railcars are modeled as area source with a release height of 16 ft (CARB, 2006).

Table 3. Stack Parameters for Modeled Emission Sources

Source Height (m) Diameter (m) Temperature (K) Velocity (m/s) Train engine 4.572 0.61 372.0 3.47 Tug Boat 6.0 0.5 300.0 0.0 Barge 6.0 0.5 300.0 0.0 Open train 5.0 -- -- -

Panamax 43.0 0.50 618.0 16.0

Generator 35.97 0.47 699.82 30.0 Note: Emissions from open tr ains are modeled as area source7 C. Receptors

The AERMOD modeling uses a Cartesian grid of discrete receptors that are located
within a radius of 5 km ar ound the ports of Morrow and West ward. The receptor grid has varying resolutions: 50 m within the firs t 2 km and 100 m between 2 km and 5 km. Receptors located on the leased property at Port of Morrow have been removed from consideration. A total of 16,739 receptors have been used in the AERMOD modeling for Port of Morrow. The modeling at Port Westward has 16,762 receptors. A flagpole height of 1.5 m was also assigned to the modeled receptors. The preprocessor AERMAP has been employed to obtain terrain elevat ions at these receptors using the National Elevation Data (NED).

D. Meteorological and Ozone Data

For Port of Morrow, the AERMOD mode ling uses the 2007-2011 surface meteorological data (including 1-min ASOS wind data to minimize calm hours) from Hermiston and upper-air data from Salem. The dataset has 589 calm hours and 1,662 hours with missing data (3.79% of possible 43,824 hours). The wind rose from Hermiston in Figure 1 shows predominant winds from the southwest.

The modeling for Port Westward uses the 2006-2010 surface data (including 1-min ASOS wind data) from Astoria and upper-air da ta from Salem. This dataset has 523 calm hours and 1,554 hours with missing data (3.55 % of possible 43,824 hours). The wind rose of Astoria surface winds is shown in Figure 2. Wind directions at this station are highly variable, from east to northwest.

For 1-hour NO 2 modeling at Port of Morrow, th e AERMOD model uses the Ozone Limiting Method (OLM) and the Plume Volu me Molar Ratio Method (PVMRM). Both techniques are considered as Tier 3 by th e US EPA and require hourly ozone data as input. Hourly ozone measurements at Herm iston during the same years (2007-2011) as the meteorological data are used as input to the AERMOD model.

E. Background Concentrations

For comparison with the NAAQS, background concentrations at a monitoring station are added to the concentrations predicted by the AERMOD model. Monitoring data during 2007-2008 tabulated in the Oregon DEQ 2011 Ai r Quality Annual Report (ODEQ, 2012)
indicate that a 98 th percentile of daily maximum NO 2 of 37 ppb (69.6 ug/m 3 ) and a 99 th
percentile of daily maximum SO 2 of 9 ppb (23.5 ug/m 3 ) were measured at the Hermiston municipal airport. Monitoring data in 2007 at the Hermiston pump station show a 98 th
percentile of daily maximum PM 2.5 of 24 ug/m 3 . An annual-averaged NO 2 concentration of 8 ppb (15.0 ug/m 3 ) was also measured at the Herm iston airport. These pollutant8 measurements are used as background concen trations for modeling impacts at Port of

Morrow.

For modeling at Port Westward, the b ackground concentrations are: 35.3 ppb (66.4 ug/m 3 ) recorded in Portland as the 2009-2011 average of the 98 th percentile of daily
maximum 1-hour NO 2 and 8.7 ppb (22.8 ug/m 3 ) recorded in Portland as the 2009-2011 average of the 99 th percentile of daily maximum 1-hour SO 2 . For 24-hour PM 2.5 , the 2009-2011 design value of 20 ug/m 3 for the Dalles monitoring station is used as background. Background concentrations used in the modeling are shown Table 4 below.

While we included background conc entrations to be consistent with applicable guidance, even if the background concentrations were al l assumed to be zero, it would not affect any of the NAAQS violations discussed in this report.

Table 4. Pollutant Background Concentrations (ug/m 3 )

Modeled
Port 1-hour
NO 2 1-hour
SO 2 24-hour

PM 2.5 Annual
NO 2

Morrow 69.6 23.5 24.0 15.0

Westward 66.4 22.8 20.0 --9 Figure 1 – Wind Rose of He rmiston 2007-2011 Surface Winds10 Figure 2 – Wind Rose of Astoria 2006-2010 Surface Winds11 III. MODELING RESULTS

A. 1-Hour NO 2 Impacts

In January 2010, US EPA announced a new 1-hour NAAQS which is attained when the 3-year average of the 98 th percentile of the daily maximum 1-hour NO 2 concentrations does not exceed 100 ppb (or 188 ug/m 3 ). Subsequently, US EPA issued in June 2010 a modeling guidance for using the AERM OD model with one year of onsite meteorological data or five years of offsite meteorological data (USEPA, 2010). According to the US EPA, the 8 th highest maximum daily 1- hour concentration obtained with one year of onsite data or averaged over five years of offsite data should be used in the NAAQS comparison.

For 1-hour NO 2 modeling, US EPA has recommended several techniques that can be
divided into three tiers:

1. Tier 1: Full conversion where the NO x emissions are assumed to be 100%
converted into NO 2 ,

2. Tier 2: The Tier 2 technique is known as the Ambient Ratio Method (ARM). In this technique, a default conversion ra te of 0.80 recommended in the US EPA March 2011 guidance is applied to the predicted NO

x concentrations, and

3. Tier 3: Two Tier 3 techniques known as Ozone Limiting Method (OLM) and Plume Volume Molar Ratio Method (PVM RM) are currently available in the
AERMOD model.

The Tier 1 and Tier 2 methods are fully approved by the US EPA. The OLM and PVMRM techniques in Tier 3 are considered to be non-regulatory defaults and their use requires the approval of US EPA and state agencies on a case by case basis (US EPA, 2011). AMI Environmental co ntacted ODEQ regarding the appropriate Tier 3 methodology to use in this setting. ODEQ recommended the use of both techniques (OLM and PVMRM) and, hence, they have been employed in this modeling analysis.

A.1 Impacts of Port of Morrow Operations

1-hour NO 2 impacts from NO

x emissions from train unloadi ng and a tug boat assisting barge loading at Port of Morrow have been modeled by all the above modeling techniques recommended by the US EPA: Tier 1 with full conversi on; Tier 2 with 80% conversion; OLM and PVMRM in Tier 3. Th e Tier 3 techniques use in-stack NO 2 /NO
x ratios of 0.15 for locomotive and 0.10 for tug boat. The in-stack ratio for locomotive is obtained from source tests conducted by Southw est Research Institute (Fritz, 2007). The ratio for tug boat is taken from sour ce tests included in the in-stack NO 2 /NO
x ratio12 database that has recently been setup by the US EPA OAQPS. Hourly ozone measurements at the Hermiston airport from 2007-2011 have also been used as inputs.

Three AERMOD modeling runs (Tier 1, OLM a nd PVMRM) have been performed with the 2007-2011 meteorological data. Both the train and the tug boat are assumed to operate only during daytime hour s (0600-1800). This is a cons ervative assumption that may understate the impacts since daytime hour s typically have stronger wind and more
unstable conditions than nighttime hours.

NO 2 modeling results for the 8 th highest concentrations ar e summarized in Appendices AC and presented in Table 5. As shown in th is table, the AERMOD model has predicted, with all modeling techniques, large ex ceedances of the 1-hour NAAQS of 188 ug/m 3 by project emissions al one. The highest 8 th highest concentrations obtained with Tier 1 (12,000.4 ug/m 3 ) and Tier 2 (9,600.3 ug/m 3 ) are much higher than those predicted by Tier 3 techniques. The highest concen tration predicted by PVMRM (2,064.3 ug/m 3 ) is slightly higher than that of the OLM technique (1,872.6 ug/m 3 ).

For Tier 1, a plot of the contour of 188 ug/m 3 is shown in Figure 3. The area with concentrations exceeding 188 ug/m 3 , i.e., violating the 1-hr NAAQS due to project emissions alone, has a radius of about 5 km north and west of the project site. These exceedances are also predicted within 3 km east and south of the project. Figure 4 shows that the area of NAAQS exceed ances predicted with OLM is much smaller. PVMRM has predicted a much larger area of exceedances than OLM, albeit sm aller than that of Tier 1.

Table 5. Predicted 1-Hour NO 2 Impacts of Port of Morrow Operations

Modeling

Method Project
Conc. (ug/m 3 ) Backgr.
Conc. (ug/m 3 ) Total
Conc. (ug/m 3 ) NAAQS

(ug/m 3 ) Percent
Over NAAQS

Tier 1 -100% 12,000.4 69.6 12,070.0 188 6,320% Tier 2 - 80% 9,600.3 69.6 9,669.9 188 5,044% Tier 3-OLM 1,872.6 69.6 1,942.2 188 933% Tier 3-PVMRM 2,064.3 69.6 2,133.9 188 1,035%13 Figure 3. Area with Highest 8 th Highest 1-hour NO 2 Concentrations (Tier 1-Full Conversion) Exceeding the 1-Hour NAAQS of 188 ug/m 3 by Port of Morrow Operations Alone14 Figure 4. Area with Highest 8 th Highest 1-hour NO 2 Concentrations (Tier 3-OLM) Exceeding the 1-Hour NAAQS of 188 ug/m 3 by Port of Morrow Operations Alone15 Figure 5. Area with Highest 8 th Highest 1-hour NO 2 Concentrations (Tier 3- PVMRM) Exceeding the 1-Hour NAAQS of 188 ug/m 3 by Port of Morrow Operations Alone

A.2 Impacts of Port Westward Operations

1-hour NO 2 impacts from NOx emissions from the OGV Panamax loading, the transloader operating on emergency power and a tug boat assisting th e barge unloading at Port Westward have been modeled by Tier 1 with full conversion and Tier 2 with 80% conversion. No Tier 3 technique, OLM or PV MRM, has been performed since Astoria does not have hourly ozone measurements pub licly available. Modeling results are summarized in Appendix D. As shown in this Appendix and Table 6, the highest 8 th16 highest concentrations of from project emissions alone (4,670 ug/m 3 for Tier 1 and 3,736 ug/m 3 for Tier 2) largely exceed the NAAQS of 188 ug/m 3 . With the added background of 66.4 ug/m 3 , the NAAQS is predicted to be exceeded by 2,419% (Tier 1) and 1,923% (Tier 2).

Another AERMOD run has been performed wher e the transloader is operating on shore power. As shown in Appendix E and Table 7 below, the highest 8 th highest NO 2 of 4,670 ug/m 3 is the same as in the previous modeli ng scenario with the transloader operating on emergency power. Thus, the NAAQS is pred icted to be largely exceeded by 2,419% (Tier 1) and 1,923% (Tier 2) fo r both modeling scenarios.

The areas of NAAQS exceedances are shown in Figure 6 for the scenario with emergency power and Figure 7 for the scenario with shore power. Compari ng these two figures
shows that the area of exceedances of the former scenario is larger than that of the latter. Due to the emissions of the emergency gene rator, the area of ex ceedances extends about 3 km northwest of the project site.

Table 6. Predicted 1-Hour NO 2 Impacts of Port Westward Operations With Transloader on Emergency Power

Modeling

Method Project
Conc. (ug/m 3 ) Backgr.
Conc. (ug/m 3 ) Total
Conc. (ug/m 3 ) NAAQS

(ug/m 3 ) Percent
Over NAAQS

Tier 1 -100% 4,670.0 66.4 4,736.4 188 2,419% Tier 2 - 80% 3,736.0 66.4 3,802.4 188 1,923%

Table 7. Predicted 1-Hour NO 2 Impacts of Port Westward Operations
With Transloader on Shore Power

Modeling

Method Project
Conc. (ug/m 3 ) Backgr.
Conc. (ug/m 3 ) Total
Conc. (ug/m 3 ) NAAQS

(ug/m 3 ) Percent
Over NAAQS

Tier 1 -100% 4,670.0 66.4 4,736.4 188 2,419% Tier 2 - 80% 3,736.0 66.4 3,802.4 188 1,923%17 Figure 6. Area with Highest 8 th Highest 1-hour NO 2 Concentrations (Tier 1-Full Conversion) Exceeding the 1-Hour NAAQS of 188 ug/m 3 by Port Westward Operations Alone (wit h Transloader on Emergency Power)18 Figure 7. Area with Highest 8 th Highest 1-hour NO 2 Concentrations (Tier 1-Full Conversion) Exceeding the 1-Hour NAAQS of 188 ug/m 3 by Port Westward Operations Alone (with Transloader on Shore Power)

B. 1-Hour SO 2 Impacts

In June 2010, US EPA announced a new 1-hour NAAQS which is at tained when the 3- year average of the 99 th percentile of the daily maximum 1-hour SO 2 concentrations does not exceed 75 ppb (or 196 ug/m 3 ). Subsequently, US EPA issued in August 2010 a modeling guidance for using the AERMOD mode l with one year or five years of meteorological data (USEPA, 2010b). According to the US EPA, the 4 th highest19 maximum daily 1-hour concentrations obtained w ith one year of onsite data or averaged over the modeled five years of offsite data should be used in the NAAQS comparison.

Impacts from SO 2 emissions from operations from both ports have been modeled. Modeling results are summarized in Appendix F (for Port of Morrow) and Appendix G (for Port Westward). As shown in Tabl e 8 below, the AERMOD model has predicted the highest 4 th highest SO 2 concentrations of 7.7 ug/m 3 for the Port of Morrow and 87.1 ug/m 3 for Port Westward. With the added background concentrations, the NAAQS is predicted not to be exceede d at both ports. The low SO 2 concentrations ar e due to the use
of SO 2 emissions that are shown in the project ER. These emissions have been calculated
based on the use of ultra low sulfur diesel for both locomotive and boats. We note that the locomotive and boats are currently legally a llowed to use much higher sulfur content
diesel fuel that what was assumed in the ER. See 77 Fed. Reg. 61281 (Oct. 9, 2012).

Table 8. Predicted 1-hour SO 2 (ug/m3) of Port Operations

Modeling
Scenario Project
Conc. Backgr.
Conc. Total
Conc. NAAQS NAAQS
Exceeded?

Port of Morrow 7.7 23.5 31.2 196.0 NO

Port Westward 87.1 22.8 109.9 196.0 NO

C. 24-Hour PM 2.5 Impacts

In September 2006, US EPA revised the 24-hour PM 2.5 NAAQS which is attained when the 3-year average of the 98 th percentile 24-hour concentrations must not exceed 35 ug/m 3 . Subsequently, US EPA issued in A ugust 2010 a modeling guid ance for using the AERMOD model with one year of onsite data or five years of offsite meteorological data (USEPA, 2010d). According to the US EPA, the highest 24-hour average concentration obtained with one year of onsite data or the highest average of the maximum 24-hour averages across five years of offsite data should be used in th e NAAQS comparison.

Impacts from PM 2.5 emissions from operations at Po rt of Morrow with enclosed and open barges and trains have been mode led. Modeling results are summarized in Appendix H (for enclosed barges and trains ) and Appendix I (for open barges and closed trains). As shown in Table 9 below, th e AERMOD model has pr edicted exceedances of the 24-hour NAAQS of 35 ug/m 3 by the highest 24-hour PM 2.5 concentrations of 96.3 ug/m 3 for the enclosed barges and 219.0 ug/m 3 for the open barges. With the added background concentration of 24 ug/m 3 , the 24-hour NAAQS is predicted to be exceeded by both types of barges, by 2.4 times with the enclosed barges and by 5.9 times with the open barges.20 Due to high emissions from wind erosion, im pacts from open barges are much higher than those from enclosed barges. NAAQS ex ceedances are plotted in Figure 8 for the closed barge/closed train scenario and Figur e 9 for the open barge/closed train scenario. In both figures, the NAAQS exceedances are denoted by the contour of 12 ug/m 3 (plus the background of 24 ug/m 3 ). Figure 8 shows these exceedances for the closed barge/train scenario are predic ted to only occur close to the project site in Oregon, i.e.
south of the state line on the Columbia River. For the ope n barge/closed train scenario, they will extend north of the stat e line, i.e. in Washington.

Another AERMOD modeling run has been perfor med to assess the impacts of the closed barge/open train scenario. The project ER i ndicates that up to two unit trains can be present onsite in any given hour (ER, p. 2- 6). Their emissions ( 8.7 lb/hr=2*4.35 lb/hr) are
modeled as area source with a length of 1500 ft (the length of rail lines within the MPP property) and a width of 19 ft (9.5 ft x 2). Modeling results are summarized in Appendix
J. Table 9 shows that the highest 24-hour PM 2.5 concentration of 388.6 ug/m 3 is the largest among the modeled scenarios. The 24-hr NAAQS is also predicted to be exceeded by 10.8 times with the open trains. Figure 10 shows that the closed barge/open train scenario has the largest zone of exceedances among the modeled scenarios. The NAAQS exceedances are also predicted to occur in the Washington portion of the Columbia River.

Table 9. Predicted 24-hour PM 2.5 (ug/m 3 ) of Port of Morrow Operations

Modeling
Scenario Project
Conc. Backgr.
Conc. Total
Conc. NAAQS Percent Over NAAQS

Operation with closed barges &

closed trains 96.3 24.0 120.3 35.0 244%

Operation with open barges &

closed trains 219.0 24.0 243.0 35.0 594%

Operation with closed barges & open trains 388.6 24.0 412.6 35.0 1,079%21 Figure 8. Area with Highest 24-hour PM 2.5 Concentrations (ug/m 3 ) Exceeding the 24-Hour NAAQS of 35 ug/m 3 by Port of Morrow Operations with Closed Barges and Trains22 Figure 9. Area with Highest 24-hour PM 2.5 Concentrations (ug/m 3 ) Exceeding the 24-Hour NAAQS of 35 ug/m 3 by Port of Morrow Operations with Open Barges and Closed Trains23 Figure 10. Area with Highest 24-hour PM 2.5 Concentrations (ug/m 3 ) Exceeding the 24-Hour NAAQS of 35 ug/m 3 by Port of Morrow Operations with Closed Barges and Open Trains

D. Annual NO 2 Impacts

Annual NO 2 impacts from the operations at Port of Morrow have been analyzed with the
AERMOD run. This run uses NOx emissions from train unloading, a tug boat assisting the barge loading and a tug boat tr avelling on the Columbia River. NO

x emissions of the traveling tug are 3.62 tpy (790/218 where the to tal emissions are 790 tpy and the distance traveled is 218 miles as shown in the pr oject ER). Table 10 shows that the annualaveraged concentrations pr edicted for 2007 are the highe st among the modeled annual
NO 2 concentrations. Modeling results for the year 2007 are summarized in Appendix K.24 With the added background of 15 ug/m 3 , the annual NAAQS of 100 ug/m 3 is predicted to be largely exceeded, by 16 times with Tier 1 a nd 12 times with Tier 2 as shown in Table 11. Figure 11 shows these exceedances occurring near the project site. No Tier 3 technique (OLM or PVMRM) has been performed. However, based on the large magnitude of the exceedances predicted by Tier 1 and Tier 2 and the results of applying Tier 3 techniques in 1-hour NO 2 modeling described in Section III. A.1 above, exceedances of the annual NAAQS are also expe cted with Tier 3 techniques (OLM or PVMRM).

Table 10. Predicted Annual NO 2 (ug/m 3 ) of Port of Morrow Operations

Modeling

Method 2007 2008 2009 2010 2011

Tier 1 -100% 1,750.9 1,660.5 1,366.5 1,430.8 1,572.8
Tier 2 - 75% 1,313.2 1,245.4 1,024.9 1,073.1 1,179.6

Table 11. Predicted Maximum Annual NO 2 Impacts (ug/m 3 ) of Port of Morrow Operations

Modeling

Method Project
Conc. Backgr.
Conc. Total
Conc. NAAQS Percent Over NAAQS

Tier 1 -100% 1,750.9 15.0 1,765.9 100.0 1,666%
Tier 2 - 75% 1,313.2 15.0 1,327.2 100.0 1,227%25 Figure 11. Area with Annual NO 2 (ug/m 3 ) Exceeding the NAAQS of 100 ug/m 3 by Port of Morrow Operations Alone

E. Nitrogen Deposition Impacts

Nitrogen deposition impacts due to dry and wet deposition from the operations at Port of Morrow have been analyzed with the AERMOD run. This run uses NO

x emissions from trains unloading and tug boats assisting th e barge loading. A tug boat travelling on the
Columbia River with NO

x emissions of 3.62 tpy is also in cluded. Modeling results for the year 2011 with the highest NO 2 deposition fluxes are summarized in Appendix M. The
maximum NO 2 deposition fluxes (in g/m 2 /yr) predicted by AERMOD are converted into kg N/ha/yr by multiplying them by 3.043 = 10*(14 /46) where 10 is the conversion factor from g/m 2 to kg/ha and (14/46) is the mass ratio of nitrogen (N) over NO 2 . The converted maximum impacts are presented in Table 12 an d a plot of the predicted deposition in26 Figure 12 below. The predicted deposition fluxe s largely exceed the ecological screening level (ESL) of 0.5 g/m 2 /yr or 5 kg/ha/yr recommended by US EPA (US EPA, 2008).

Table 12. Predicted Nitrogen Deposition (kg N/ha/yr) of Port of Morrow Operations

Modeling

Method 2007 2008 2009 2010 2011 ESL

Tier 1 -100% 164.4 155.1 185.7 128.9 261.2 5
Tier 2 - 75% 123.3 116.3 139.3 96.7 195.9 5

Figure 12. Area with Annual NO 2 Deposition (g/m 2 /yr) by Port of Morrow Operations Alone27 IV. CONCLUSIONS

Air quality impacts of NO

x , PM 2.5 and SO 2 emissions from the proposed operations at
Port of Morrow and Port Westward of the Morrow Pacific Project have been analyzed
with the AERMOD model. For NO 2 , modeling techniques known as Tier 1 (full conversion) and Tier 2 recommended by the US EPA have been used for modeling at both ports. Tier 3 techniques (OLM and PVMR M) have also been used for modeling impacts at Port of Morrow. Using primarily project emissions documented in the project ER and the latest US EPA modeling guidan ce, the AERMOD model has predicted large
exceedances of the NO 2 1-hour NAAQS of 196 ug/m 3 (by 9-63 times the NAAQS at Port of Morrow and by 19-24 times the NAAQ S at Port Westward), the 24-hour PM 2.5 at Port of Morrow (by 2.4-10.8 times the NAAQS of 35 ug/m 3 ) and the annual NO 2 NAAQS at Port of Morrow (by 12-17 times the NAAQS of 100 ug/m 3 ). These large exceedances have been predicted to occur due to project emissions alone, i.e., without the addition of background concentrations a nd also in large areas around the project sites. NAAQS exceedances will occur in both Oregon and Washington. SO 2 impacts are insignificant due to low emissions from th e use of ultra low sulfur fuel for both locomotive and boat engines. The AERMOD m odel has also predicted large nitrogen deposition around the Port of Morrow. Thus , the proposed Morrow Pacific Project will cause very adverse air quality imp acts in both Oregon and Washington.

The AERMOD modeling files, including input/o utput files, meteorological data, ozone data and model executable, have been uploaded to box.com and are available from the
folder: https://www.box.com/s/tseqhg95g7fe1jdw57lk

.

V. REFERENCES

California Air Resources Board, 2006. Diesel Particulate Matter Exposure Assessment Study for the Ports of Los Angeles and Long Beach . Available at http://www.arb.ca.gov/ports/mar inevess/documents/portstudy0406.pdf

Fritz, S, 2007. US Locomotive After-treatme nt Retrofit Progress Report: SwRI Test Programs. Southwest Research Institute. Available at http://www.arb.ca.gov/raily ard/ryagreement/112807fritz.pdf

New Jersey DEP, 2009. Estimated Air Quality Impacts on Surrounding Communities of

PM 2.5 and SO 2 Emissions Resulting from Marine Oper ations at Elizabeth Port Authority
Marine Terminal and Port Newark . Available at http://www.state.nj.us/dep/stopthesoo t/Port%20risk%20Summary-final%2010-9-09.pdf

Oregon DEQ, 2012. 2011 Oregon Air Quality Data Summaries. Available at: http://www.deq.state.or.us/aq/for ms/2011AirQualityAnnualReport.pdf28 U.S. EPA, 2012. Addendum to User’s Gu ide of the AMS/EPA Regulatory Model AERMOD version 12060, Febr uary 2012. Available at: http://www.epa.gov/ttn/scram/models/aermod/aermod_userguide.zip

U.S. EPA, 2011. Additional Clarification Regard ing Application of Appendix W Modeling Guidance for the 1-hour NO 2 NAAQS . Memorandum issued on March 1st, 2011 from Tyler Fox, Leader of Air Quality Modeling Group, OAQPS. Available at http://www.epa.gov/region7/air/nsr/nsrmemos/appwNO2_2.pdf

U.S. EPA, 2010a. Applicability of Appendix W M odeling Guidance for the 1-hour NO 2 NAAQS . Memorandum issued on June 28, 2010 from Tyler Fox, Leader of Air Quality Modeling Group, OAQPS. Available at http://www.epa.gov/ttn/scram/guidance/clarif ication/Clarificati onMemo_AppendixW_Ho urly-NO2-NAAQS_FINAL_06-28-2010.pdf

U.S. EPA, 2010b. Guidance Concerning the Impl ementation of the 1-hour SO 2 NAAQS for the Prevention of Significant Deterioration Program . Memorandum issued on August 23, 2010 from Stephen D. Page, Dir ector of OAQPS. Available at http://www.epa.gov/region07/air/nsr/nsrmemos/appwso2.pdf

U.S. EPA, 2010c. Applicability of Appendix W M odeling Guidance for the 1-hour SO 2 NAAQS . Memorandum issued on August 23, 20 10 from Tyler Fox, Leader of Air Quality Modeling Group, OAQPS. Available at http://www.epa.gov/region07/air/nsr/nsrmemos/appwso2.pdf

U.S. EPA, 2010d. Modeling Procedures for Demonstrating Compliance with PM 2.5 NAAQS . Memorandum issued on March 23, 2010 by Stephen D. Page, Director of OAQPS. Available at: http://www.epa.gov/region07/air/nsr/nsrmemos/pm25memo.pdf

U.S. EPA, 2008. Biological Assessment for Gateway Energy and Coke Company, Granite City, Illinois . Available at: http://yosemite.epa.gov/r5/r5ar d.nsf/c408a2009710018f8625716f 004d9038/bab8e1b0ab5 0bdfc86257412006c2f20/$FILE/GatewayBioAssessment.pdf29 Appendix A

Summary of AERMOD-Predicted 1-hour NO 2 Impacts (Full Conversion) of Port of Morrow Operations30 *** AERMOD - VERSION 12060 *** *** Port of Morrow - 1-hr NO2 *** 10/01/12
*** *** 19:50:07
PAGE 616

**MODELOPTs: CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 8TH-HIGHEST MAX DAILY 1-HR RESULTS AVERAGED
OVER 5 YEARS ***

** CONC OF NO2 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 12000.43671 AT ( 293682.00, 5081859.00, 88.36, 88.36, 1.50) DC 2ND HIGHEST VALUE IS 11011.15662 AT ( 293495.00, 5081933. 00, 81.42, 81.42, 1.50) DC 3RD HIGHEST VALUE IS 9546.46567 AT ( 293634.00, 5081812.00, 88.06, 88.06, 1.50) DC 4TH HIGHEST VALUE IS 8619.08562 AT ( 293535.00, 5081880.00, 84.73, 90.01, 1.50) DC 5TH HIGHEST VALUE IS 8446.96889 AT ( 293486.00, 5081914.00, 81.42, 90.01, 1.50) DC 6TH HIGHEST VALUE IS 7982.12692 AT ( 293695.00, 5081883.00, 88.89, 88.89, 1.50) DC 7TH HIGHEST VALUE IS 6129.74109 AT ( 293495.00, 5081983.00, 81.42, 81.42, 1.50) DC 8TH HIGHEST VALUE IS 5478.30847 AT ( 293645.00, 5081883.00, 88.58, 88.58, 1.50) DC 9TH HIGHEST VALUE IS 5425.12949 AT ( 293436.00, 5081947.00, 81.42, 81.42, 1.50) DC 10TH HIGHEST VALUE IS 5407.11800 AT ( 293545.00, 5081933. 00, 81.42, 88.09, 1.50) DC31 Appendix B

Summary of AERMOD-Predicted 1-hour NO 2 Impacts (Tier 3-OLM) of Port of Morrow Operations32 *** AERMOD - VERSION 12060 *** *** Port of Morrow - 1-hr NO2 -OLM ***
10/12/12
*** *** 18:19:34

PAGE 5
**MODELOPTs: NonDFAULT CONC ELEV FLGPOL
OLM

*** THE SUMMARY OF MAXIMUM 8TH-HIGHEST MAX DAILY 1-HR RESULTS AVERAGED
OVER 5 YEARS ***

** CONC OF NO2 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 1872.57842 AT ( 293682.00, 5081859.00, 88.36, 88.36, 1.50) DC 2ND HIGHEST VALUE IS 1506.09918 AT ( 293634.00, 5081812.00, 88.06, 88.06, 1.50) DC 3RD HIGHEST VALUE IS 1269.56877 AT ( 293695.00, 5081883.00, 88.89, 88.89, 1.50) DC 4TH HIGHEST VALUE IS 1157.13116 AT ( 293495.00, 5081933.00, 81.42, 81.42, 1.50) DC 5TH HIGHEST VALUE IS 930.96011 AT ( 293535.00, 5081880.00, 84.73, 90.01, 1.50) DC 6TH HIGHEST VALUE IS 898.70613 AT ( 293486.00, 5081914.00, 81.42, 90.01, 1.50) DC 7TH HIGHEST VALUE IS 888.67937 AT ( 293645.00, 5081883.00, 88.58, 88.58, 1.50) DC 8TH HIGHEST VALUE IS 804.59597 AT ( 293729.00, 5081905.00, 89.36, 89.36, 1.50) DC 9TH HIGHEST VALUE IS 708.92971 AT ( 293645.00, 5081933.00, 88.68, 88.68, 1.50) DC 10TH HIGHEST VALUE IS 708.92971 AT ( 293645.00, 5081933.00, 88.68, 88.68, 1.50) DC33 Appendix C

Summary of AERMOD-Predicted 1-hour NO 2 Impacts (Tier 3-PVMRM) of Port of Morrow Operations34 *** AERMOD - VERSION 12060 *** *** Port of Morrow - 1-hr NO2 -PVMRM ***
10/12/12
*** *** 20:48:14

PAGE 5
**MODELOPTs: NonDFAULT CONC ELEV FLGPOL

PVMRM

*** THE SUMMARY OF MAXIMUM 8TH-HIGHEST MAX DAILY 1-HR RESULTS AVERAGED
OVER 5 YEARS ***

** CONC OF NO2 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 2064.26610 AT ( 293682.00, 5081859.00, 88.36, 88.36, 1.50) DC 2ND HIGHEST VALUE IS 1640.03383 AT ( 293634.00, 5081812.00, 88.06, 88.06, 1.50) DC 3RD HIGHEST VALUE IS 1453.05752 AT ( 293495.00, 5081933.00, 81.42, 81.42, 1.50) DC 4TH HIGHEST VALUE IS 1349.15566 AT ( 293695.00, 5081883.00, 88.89, 88.89, 1.50) DC 5TH HIGHEST VALUE IS 1276.62739 AT ( 293486.00, 5081914.00, 81.42, 90.01, 1.50) DC 6TH HIGHEST VALUE IS 1137.14103 AT ( 293535.00, 5081880.00, 84.73, 90.01, 1.50) DC 7TH HIGHEST VALUE IS 932.58202 AT ( 293645.00, 5081883.00, 88.58, 88.58, 1.50) DC 8TH HIGHEST VALUE IS 854.25416 AT ( 293495.00, 5081983.00, 81.42, 81.42, 1.50) DC 9TH HIGHEST VALUE IS 826.47500 AT ( 293436.00, 5081947.00, 81.42, 81.42, 1.50) DC 10TH HIGHEST VALUE IS 819.38900 AT ( 293729.00, 5081905.00, 89.36, 89.36, 1.50) DC35 Appendix D

Summary of AERMOD-Predicted 1-hour NO 2 Impacts (Full Conversion) of Port Westward Operations with Transloader using Emergency Power36 *** AERMOD - VERSION 12060 *** *** Port Westward - 1-hr NO2 *** 09/24/12
*** *** 16:37:47

PAGE 5

**MODELOPTs: CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 8TH-HIGHEST MAX DAILY 1-HR RESULTS AVERAGED
OVER 5 YEARS ***

** CONC OF NO2 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 4669.95119 AT ( 485884.00, 5114327.00, 1.82, 173.28, 1.50) DC 2ND HIGHEST VALUE IS 4019.45010 AT ( 485834.00, 5114327.00, 1.84, 173.28, 1.50) DC 3RD HIGHEST VALUE IS 4019.45010 AT ( 485834.00, 5114327.00, 1.84, 173.28, 1.50) DC 4TH HIGHEST VALUE IS 3552.36381 AT ( 485884.00, 5114377.00, 1.86, 173.28, 1.50) DC 5TH HIGHEST VALUE IS 3464.09646 AT ( 485934.00, 5114327.00, 1.81, 173.28, 1.50) DC 6TH HIGHEST VALUE IS 3464.09646 AT ( 485934.00, 5114327.00, 1.81, 173.28, 1.50) DC 7TH HIGHEST VALUE IS 3308.75055 AT ( 485834.00, 5114377.00, 1.88, 173.28, 1.50) DC 8TH HIGHEST VALUE IS 2985.93516 AT ( 485784.00, 5114327.00, 1.86, 178.84, 1.50) DC 9TH HIGHEST VALUE IS 2979.22153 AT ( 485884.00, 5114277.00, 1.79, 173.28, 1.50) DC 10TH HIGHEST VALUE IS 2935.63381 AT ( 485934.00, 5114377. 00, 1.85, 173.28, 1.50) DC37 Appendix E

Summary of AERMOD-Predicted 1-hour NO 2 Impacts (Full Conversion) of Port Westward Operations with Transloader using Shore Power38 *** AERMOD - VERSION 12060 *** *** Port Westward/Sho re Power - 1-hr NO2 ***
10/10/12
*** *** 09:16:03

PAGE 5

**MODELOPTs: CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 8TH-HIGHEST MAX DAILY 1-HR RESULTS AVERAGED
OVER 5 YEARS ***

** CONC OF NO2 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 4669.94844 AT ( 485884.00, 5114327.00, 1.82, 173.28, 1.50) DC 2ND HIGHEST VALUE IS 4019.45010 AT ( 485834.00, 5114327.00, 1.84, 173.28, 1.50) DC 3RD HIGHEST VALUE IS 4019.45010 AT ( 485834.00, 5114327.00, 1.84, 173.28, 1.50) DC 4TH HIGHEST VALUE IS 3552.36381 AT ( 485884.00, 5114377.00, 1.86, 173.28, 1.50) DC 5TH HIGHEST VALUE IS 3464.09646 AT ( 485934.00, 5114327.00, 1.81, 173.28, 1.50) DC 6TH HIGHEST VALUE IS 3464.09646 AT ( 485934.00, 5114327.00, 1.81, 173.28, 1.50) DC 7TH HIGHEST VALUE IS 3308.75055 AT ( 485834.00, 5114377.00, 1.88, 173.28, 1.50) DC 8TH HIGHEST VALUE IS 2985.93516 AT ( 485784.00, 5114327.00, 1.86, 178.84, 1.50) DC 9TH HIGHEST VALUE IS 2979.22153 AT ( 485884.00, 5114277.00, 1.79, 173.28, 1.50) DC 10TH HIGHEST VALUE IS 2935.63381 AT ( 485934.00, 5114377. 00, 1.85, 173.28, 1.50) DC39 Appendix F

Summary of AERMOD-Predicted 1-hour SO 2 Impacts of Port of Morrow Operations with Ultra Low Sulfur Fuel40 *** AERMOD - VERSION 12060 *** *** Port of Morrow - 1-hr SO2 *** 10/05/12
*** *** 06:29:15

PAGE 5

**MODELOPTs: CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 4TH-HIGHEST MAX DAILY 1-HR RESULTS AVERAGED
OVER 5 YEARS ***

** CONC OF SO2 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 7.71659 AT ( 293682.00, 5081859.00, 88.36, 88.36, 1.50) DC 2ND HIGHEST VALUE IS 6.87149 AT ( 293634.00, 5081812.00, 88.06, 88.06, 1.50) DC 3RD HIGHEST VALUE IS 5.11050 AT ( 293695.00, 5081883.00, 88.89, 88.89, 1.50) DC 4TH HIGHEST VALUE IS 4.23968 AT ( 293645.00, 5081883.00, 88.58, 88.58, 1.50) DC 5TH HIGHEST VALUE IS 3.29040 AT ( 293729.00, 5081905.00, 89.36, 89.36, 1.50) DC 6TH HIGHEST VALUE IS 3.11441 AT ( 293645.00, 5081933.00, 88.68, 88.68, 1.50) DC 7TH HIGHEST VALUE IS 3.11441 AT ( 293645.00, 5081933.00, 88.68, 88.68, 1.50) DC 8TH HIGHEST VALUE IS 3.01923 AT ( 293495.00, 5081933.00, 81.42, 81.42, 1.50) DC 9TH HIGHEST VALUE IS 2.90729 AT ( 293695.00, 5081933.00, 88.78, 88.78, 1.50) DC 10TH HIGHEST VALUE IS 2.85823 AT ( 293591.00, 5081747.00, 87.42, 87.42, 1.50) DC41 Appendix G

Summary of AERMOD-Predicted 1-hour SO 2 Impacts of

Port Westward Operations with Ultra Low Sulfur Fuel42 *** AERMOD - VERSION 12060 *** *** Port Westward - 1-hr SO2 *** 10/05/12
*** *** 09:08:23

PAGE 5

**MODELOPTs: CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 4TH-HIGHEST MAX DAILY 1-HR RESULTS AVERAGED
OVER 5 YEARS ***

** CONC OF SO2 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 87.08375 AT ( 485384.00, 5114627.00, 66.26, 173.28, 1.50) DC 2ND HIGHEST VALUE IS 80.86337 AT ( 485434.00, 5114677.00, 72.72, 173.28, 1.50) DC 3RD HIGHEST VALUE IS 71.77678 AT ( 485184.00, 5114527.00, 71.23, 173.28, 1.50) DC 4TH HIGHEST VALUE IS 71.62989 AT ( 485284.00, 5114577.00, 73.47, 173.28, 1.50) DC 5TH HIGHEST VALUE IS 68.69739 AT ( 485534.00, 5114727.00, 80.33, 173.28, 1.50) DC 6TH HIGHEST VALUE IS 68.69739 AT ( 485534.00, 5114727.00, 80.33, 173.28, 1.50) DC 7TH HIGHEST VALUE IS 66.50215 AT ( 485084.00, 5114477.00, 66.86, 178.84, 1.50) DC 8TH HIGHEST VALUE IS 65.75496 AT ( 485484.00, 5114727.00, 81.25, 173.28, 1.50) DC 9TH HIGHEST VALUE IS 65.43326 AT ( 485334.00, 5114627.00, 78.25, 173.28, 1.50) DC 10TH HIGHEST VALUE IS 65.43326 AT ( 485334.00, 5114627.00, 78.25, 173.28, 1.50) DC43 Appendix H

Summary of AERMOD-Predicted 24-hour PM 2.5 Impacts of Port of Morrow Operations with Enclosed Barges and Trains44 *** AERMOD - VERSION 12060 *** *** Port of Morrow - 24hr PM2.5 ***
10/06/12
*** *** 12:32:11

PAGE 4

**MODELOPTs: CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 1ST-HIGHEST 24-HR RESULTS AVERAGED OVER 5
YEARS ***

** CONC OF PM25 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 96.34646 AT ( 293634.00, 5081812.00, 88.06, 88.06, 1.50) DC 2ND HIGHEST VALUE IS 92.71799 AT ( 293682.00, 5081859.00, 88.36, 88.36, 1.50) DC 3RD HIGHEST VALUE IS 49.79568 AT ( 293695.00, 5081883.00, 88.89, 88.89, 1.50) DC 4TH HIGHEST VALUE IS 43.46942 AT ( 293645.00, 5081883.00, 88.58, 88.58, 1.50) DC 5TH HIGHEST VALUE IS 39.06540 AT ( 293486.00, 5081914.00, 81.42, 90.01, 1.50) DC 6TH HIGHEST VALUE IS 33.96834 AT ( 293535.00, 5081880.00, 84.73, 90.01, 1.50) DC 7TH HIGHEST VALUE IS 31.94523 AT ( 293495.00, 5081933.00, 81.42, 81.42, 1.50) DC 8TH HIGHEST VALUE IS 30.02961 AT ( 293729.00, 5081905.00, 89.36, 89.36, 1.50) DC 9TH HIGHEST VALUE IS 29.26999 AT ( 293591.00, 5081747.00, 87.42, 87.42, 1.50) DC 10TH HIGHEST VALUE IS 26.18454 AT ( 293595.00, 5081733.00, 87.43, 87.43, 1.50) DC45 Appendix I

Summary of AERMOD-Predicted 24-hour PM 2.5 Impacts of Port of Morrow Operations with Open Barges and Closed Trains46 *** AERMOD - VERSION 12060 *** *** Port of Morrow - Open barge - 24hr PM2.5 ***
10/12/12
*** *** 03:28:27

PAGE 4

**MODELOPTs: CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 1ST-HIGHEST 24-HR RESULTS AVERAGED OVER 5
YEARS ***

** CONC OF PM25 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 96.39479 AT ( 293634.00, 5081812.00, 88.06, 88.06, 1.50) DC 2ND HIGHEST VALUE IS 93.31912 AT ( 293682.00, 5081859.00, 88.36, 88.36, 1.50) DC 3RD HIGHEST VALUE IS 74.26387 AT ( 293385.00, 5081765.00, 81.44, 89.12, 1.50) DC 4TH HIGHEST VALUE IS 58.07956 AT ( 293486.00, 5081914.00, 81.42, 90.01, 1.50) DC 5TH HIGHEST VALUE IS 52.50092 AT ( 293535.00, 5081880.00, 84.73, 90.01, 1.50) DC 6TH HIGHEST VALUE IS 51.74925 AT ( 293495.00, 5081933.00, 81.42, 81.42, 1.50) DC 7TH HIGHEST VALUE IS 50.58559 AT ( 293436.00, 5081947.00, 81.42, 81.42, 1.50) DC 8TH HIGHEST VALUE IS 50.00263 AT ( 293695.00, 5081883.00, 88.89, 88.89, 1.50) DC 9TH HIGHEST VALUE IS 48.44197 AT ( 293436.00, 5081761.00, 86.93, 86.93, 1.50) DC 10TH HIGHEST VALUE IS 47.93824 AT ( 293303.00, 5081902.00, 81.42, 81.42, 1.50) DC47 Appendix J

Summary of AERMOD-Predicted 24-hour PM 2.5 Impacts of Port of Morrow Operations with Closed Barges and Open Trains48 *** AERMOD - VERSION 12060 *** *** Port of Morrow - Open Train - 24hrPM2.5 ***
10/28/12
*** *** 21:07:10

PAGE 4

**MODELOPTs: CONC ELEV FLGPOL

*** THE SUMMARY OF MAXIMUM 1ST-HIGHEST 24-HR RESULTS AVERAGED OVER 5
YEARS ***

** CONC OF PM25 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 388.58720 AT ( 293395.00, 5081533.00 , 92.82, 92.82, 1.50) DC 2ND HIGHEST VALUE IS 369.14316 AT ( 293445.00, 5081483.00, 93.82, 93.82, 1.50) DC 3RD HIGHEST VALUE IS 329.09982 AT ( 293495.00, 5081433.00, 94.48, 94.48, 1.50) DC 4TH HIGHEST VALUE IS 321.34654 AT ( 293545.00, 5081383.00, 94.61, 94.61, 1.50) DC 5TH HIGHEST VALUE IS 320.74418 AT ( 293595.00, 5081333.00, 94.54, 96.30, 1.50) DC 6TH HIGHEST VALUE IS 206.12712 AT ( 293395.00, 5081583.00, 91.05, 91.05, 1.50) DC 7TH HIGHEST VALUE IS 203.49253 AT ( 293645.00, 5081283.00, 96.25, 96.25, 1.50) DC 8TH HIGHEST VALUE IS 175.37558 AT ( 293445.00, 5081533.00, 92.35, 92.35, 1.50) DC 9TH HIGHEST VALUE IS 175.37558 AT ( 293445.00, 5081533.00, 92.35, 92.35, 1.50) DC 10TH HIGHEST VALUE IS 174.66553 AT ( 293345.00, 5081633.00, 91.60, 91.60, 1.50) DC49 Appendix K

Summary of AERMOD-Predicted Annual NO 2 Impacts of Port of Morrow Operations50 *** AERMOD - VERSION 12060 *** *** Port of Morrow - NO2 DEPOSITION - 2007 ***
10/11/12
*** *** 08:34:29

PAGE 4
**MODELOPTs: NonDFAULT CONC DEPOS ELEV FLGPOL

DRYDPLT WETDPLT

*** THE SUMMARY OF MAXIMUM ANNUAL RESULTS AVERAGED OVER 1 YEARS

***

** CONC OF NO2 IN MICROGRAMS/M**3 **

NETWORK
GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ALL 1ST HIGHEST VALUE IS 1750.88666 AT ( 293682.00, 5081859.00, 88.36, 88.36, 1.50) DC 2ND HIGHEST VALUE IS 1052.50428 AT ( 293695.00, 5081883.00, 88.89, 88.89, 1.50) DC 3RD HIGHEST VALUE IS 635.06315 AT ( 293729.00, 5081905.00, 89.36, 89.36, 1.50) DC 4TH HIGHEST VALUE IS 435.52880 AT ( 293745.00, 5081933.00, 89.41, 89.41, 1.50) DC 5TH HIGHEST VALUE IS 435.52880 AT ( 293745.00, 5081933.00, 89.41, 89.41, 1.50) DC 6TH HIGHEST VALUE IS 354.24233 AT ( 293695.00, 5081933.00, 88.78, 88.78, 1.50) DC 7TH HIGHEST VALUE IS 330.98272 AT ( 293545.00, 5081933.00, 81.42, 88.09, 1.50) DC 8TH HIGHEST VALUE IS 330.98272 AT ( 293545.00, 5081933.00, 81.42, 88.09, 1.50) DC 9TH HIGHEST VALUE IS 316.01375 AT ( 293495.00, 5081983.00, 81.42, 81.42, 1.50) DC 10TH HIGHEST VALUE IS 305.49073 AT ( 293795.00, 5081933.00, 89.75, 89.75, 1.50) DC51 Appendix M

Summary of AERMOD-Predicted Nitr ogen Deposition Impacts of Port of Morrow Operations52 *** AERMOD - VERSION 12060 *** *** Port of Morrow - NO2 DEPOSITION-2011 ***
10/11/12*
*** *** 21:26:50
PAGE 5
**MODELOPTs: NonDFAULT CONC DEPOS ELEV FLGPOL

DRYDPLT WETDPLT

*** THE SUMMARY OF MAXIMUM ANNUAL RE SULTS AVERAGED OVER 1 YEARS ***

** DEPO OF NO2 IN GRAMS/M**2/YR **

NETWORK GROUP ID TOTAL DEPO RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE
GRID-ID

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ALL 1ST HIGHEST VALUE IS 85.83330 AT ( 293645.00, 5081883.00, 88.58, 88.58, 1.50) DC 2ND HIGHEST VALUE IS 59.12736 AT ( 293695.00, 5081933.00, 88.78, 88.78, 1.50) DC 3RD HIGHEST VALUE IS 56.41767 AT ( 293695.00, 5081883.00, 88.89, 88.89, 1.50) DC 4TH HIGHEST VALUE IS 53.31785 AT ( 293682.00, 5081859.00, 88.36, 88.36, 1.50) DC 5TH HIGHEST VALUE IS 50.98385 AT ( 293645.00, 5081933.00, 88.68, 88.68, 1.50) DC 6TH HIGHEST VALUE IS 50.98385 AT ( 293645.00, 5081933.00, 88.68, 88.68, 1.50) DC 7TH HIGHEST VALUE IS 38.15760 AT ( 293695.00, 5081983.00, 86.48, 89.33, 1.50) DC 8TH HIGHEST VALUE IS 33.88791 AT ( 293645.00, 5081983.00, 87.43, 87.43, 1.50) DC 9TH HIGHEST VALUE IS 26.27295 AT ( 293495.00, 5081983.00, 81.42, 81.42, 1.50) DC
10TH HIGHEST VALUE IS 25.56387 AT ( 293745.00, 5081983.00, 88.92, 88.92, 1.50) DC