Aqia
Aqia
Prepared By
Robin Cobbs
Charlotte Mountain
June 2020
Image Courtesy of:
https://www.slideshare.net/gauravpahuja3012/11-air-pollution-dispersion
https://www.shutterstock.com/
TABLE OF CONTENTS
1. Introduction ........................................................................................................................... 1
1.1 Applicability ................................................................................................................................. 1
1.2 Prevention of Significant Deterioration Modeling for Major Sources.......................................... 1
2. Emissions ................................................................................................................................ 2
2.1 Pollutants and Averaging Periods ................................................................................................. 2
2.1.1 Criteria Pollutants .................................................................................................................... 2
2.1.2 Other Pollutants ........................................................................................................................ 3
2.2 Emission Sources .......................................................................................................................... 3
2.2.1 NSR AQIA with Only New Equipment ...................................................................................... 3
2.2.2 NSR AQIA with Existing Equipment ......................................................................................... 3
2.2.3 CEQA AQIA .............................................................................................................................. 4
2.3 Emission Calculations ................................................................................................................... 4
3. Air Dispersion Model ............................................................................................................ 4
3.1 Offshore Platforms ........................................................................................................................ 5
3.2 Control Options ............................................................................................................................. 5
3.2.1 Conversion of NOX to NO2 ........................................................................................................ 5
3.2.2 Special Processing Options for the AAQS Analysis for NO2 .................................................... 6
3.2.3 Special Processing Options for the AAQS Analysis for SO2 ..................................................... 6
3.2.4 Special Processing Options for the AAQS Analysis for PM2.5 .................................................. 7
3.2.5 Annual Averaging Period Options ............................................................................................ 7
3.3 Defining Urban and Rural Conditions .......................................................................................... 7
3.4 UTM Coordinate System .............................................................................................................. 9
3.5 Source Parameters ......................................................................................................................... 9
3.5.1 Point Sources – POINT, POINTCAP, POINTHOR .................................................................. 9
3.5.2 Area Sources – AREA, AREAPOLY, AREACIRC ................................................................... 10
3.5.3 OPENPIT Sources................................................................................................................... 11
3.5.4 VOLUME Sources ................................................................................................................... 12
3.5.5 LINE Sources .......................................................................................................................... 13
3.6 Building Impacts ......................................................................................................................... 14
3.7 Terrain ......................................................................................................................................... 14
3.8 Meteorological Data.................................................................................................................... 15
3.9 Receptors..................................................................................................................................... 15
3.9.1 Cartesian Receptor Grids ....................................................................................................... 15
3.9.2 Class I Receptors .................................................................................................................... 16
4. Results ................................................................................................................................... 17
4.1 Ambient Air Quality Standard Analysis ..................................................................................... 17
4.1.1 Background Concentration ..................................................................................................... 20
4.2 Increment Analysis ..................................................................................................................... 21
5. Air Quality Impact Assessment Report ............................................................................. 22
5.1 Facility Information .................................................................................................................... 23
5.2 Source and Emission Inventory Information .............................................................................. 23
5.3 Emission Quantification.............................................................................................................. 23
5.4 Air Dispersion Information ......................................................................................................... 24
5.5 Summary of Results .................................................................................................................... 24
5.5.1 Results of the AAQS Analysis .................................................................................................. 24
5.5.2 Results of the Increment Analysis ........................................................................................... 25
5.6 Air Quality Impact Driver Tables ............................................................................................... 26
5.7 Required Files ............................................................................................................................. 26
6. References............................................................................................................................. 27
7. Contacts ................................................................................................................................ 28
Appendix A – Variable Emissions Modeling ........................................................................... A1
A.1 Non-Continuous Emissions .....................................................................................................A1
A.2 Plant Shutdowns and Start-Ups ..............................................................................................A1
Appendix B – Modeling Specific Source Types ........................................................................ B1
B.1 Liquid Storage Tanks ..............................................................................................................B1
Appendix C – Modeling Emissions from Roadways............................................................... C1
C.1 Modeling Roadways with LINE Sources ................................................................................ C1
C.2 Modeling Roadways with RLINE Sources ............................................................................. C2
C.3 Modeling Roadways with VOLUME Sources ........................................................................ C4
C.5 References for Appendix C..................................................................................................... C7
Appendix D – Placement of Portable Equipment ................................................................... D1
LIST OF FIGURES
Figure 3.3-1: Auer Method for Determining Urban or Rural Dispersion ....................................... 8
Figure 3.9.2-1: Class I Impact Area .............................................................................................. 17
Figure 1-8: Exact and Approximate Representations of a Line Source by Multiple Volume
Sources (Reproduced from USEPA’s ISC3 User’s Guide Volume II)......................................... C5
LIST OF TABLES
Table 2.1.1-1: Air Quality Standards and Increments for Criteria Pollutants ................................ 2
Table 2.1.2-1: Air Quality Standards for Other Pollutants ............................................................. 3
Table 3.3-1: Urban Land Use.......................................................................................................... 8
Table 3.3-2: Population Data for Urban Dispersion Modeling....................................................... 9
Table 3.5.4-1: Summary of Suggested Procedures for Estimating Initial Lateral Dimensions for
Volume Sources ............................................................................................................................ 13
Table 3.5.4-2: Summary of Suggested Procedures for Estimating Initial Vertical Dimensions for
Volume Sources ............................................................................................................................ 13
Table 3.8-1: Meteorological Data Sets in Santa Barbara County ................................................. 15
Table 3.9.2-1: Class I Receptor Lists ............................................................................................ 17
Table 4.1-1: Reporting Results for the AAQS Analysis .............................................................. 19
Table 4.1.1-1: Background Concentrations for the AAQS Analysis ........................................... 21
Table 4.2-1: Reporting Results for the Increment Analysis ......................................................... 22
Table 5.5.1-1: Example AAQS Modeling Results........................................................................ 25
Table 5.5.2-1: Example Increment Analysis Modeling Results for Class II Impacts................... 26
Table A.2-1: Example Variable Emission Scenario (Hour of Day) ........................................... A2
Table B.1.1-1: Stack Parameters for Modeling Tanks .................................................................. B1
1. Introduction
This document explains the requirements for performing air quality impact assessments for the Santa
Barbara County Air Pollution Control District (District) using AERMOD. It is assumed that the reader
has some modeling experience with this program; therefore, this document is not intended as a user’s
guide for AERMOD. The AERMOD user’s guide, written by U.S. Environmental Protection Agency
(EPA), is noted in the References section of this document and should be consulted for troubleshooting or
when background information is needed.
1.1 Applicability
An air quality impact assessment (AQIA) must be completed for any of the following situations:
1. An AQIA is required as part of the District’s New Source Review (NSR) permitting program
according to District Rule 802.F. for any new or modified stationary source that meets at least one
of the following criteria:
a. The source has a potential to emit of any pollutant or its precursors which is equal to or
greater than any threshold shown in Table 4 of District Rule 802; or
b. The Control Officer determined that the new or modified stationary source has the potential
to cause or contribute to a violation of any ambient air quality standard or increment; or
c. The new or modified stationary source has the potential to emit more than 20 pounds per hour
of any attainment pollutant or total suspended particulates (TSP).
2. An AQIA is necessary as part of the California Environmental Quality Act (CEQA) process.
An AQIA can consist of modeling one or multiple pollutants and averaging periods for an increment
analysis, ambient air quality standard (AAQS) analysis, or both. Typically, both an increment analysis
and an AAQS analysis are required for the District’s NSR permitting program, while only an AAQS
analysis is required for the CEQA process. Confirm the modeling requirements with the District before
submitting the AQIA.
Table 2.1.1-1: Air Quality Standards and Increments for Criteria Pollutants
Maximum Allowable Ambient Air
Increase – Increments Quality Standard
(μg/m3) (μg/m3)
Pollutant:
Averaging Period Class I Area1 Class II Area2 California National
Total Suspended Particulates:
Annual Average 5 19 — —
24-Hour Maximum 10 37 — —
Sulfur Dioxide:
Annual Average 2 20 — 80
24-Hour Maximum 5 91 105 —
3-Hour Maximum 25 512 — 1,300
1-Hour Maximum — — 655 196
Nitrogen Dioxide:
Annual Average 2.5 25 57 100
1-Hour Maximum 10 100-188 339 188
Carbon Monoxide:
8-Hour Maximum 200 2,500 10,000 10,000
1-Hour Maximum 800 10,000 23,000 40,000
Reactive Organic Compounds:
3-Hour Maximum 3 40-160 — —
Particulate Matter (< 10 μm):
Annual Average 4 17 20 —
24-Hour Maximum 8 12-30 50 150
Particulate Matter (< 2.5 μm):
Annual Average 1 4 12 12
24-Hour Maximum 2 9 — 35
1
“Class I Area” means any area having air quality or air quality related values requiring special protection, and
which has been designated Class I by a federal or state authority empowered to make such designation.
2
“Class II Area” means any area not designated as a Class I or Class III Area pursuant to 40 CFR 51.166(e).
1
Although lead is a criteria pollutant, it is addressed below in Section 2.1.2, Other Pollutants.
For toxic air contaminants included in Table 4 of District Rule 802, but not included in Table 2.1.2-1
below, a health risk assessment is required in lieu of an AAQS analysis. For other pollutants that are not
toxics, the AQIA is required for informational purposes only.
Please contact the District for the applicable requirements for municipal waste combustors.
Existing equipment at the stationary source that is determined by the District to not be part of the project
should not be included in the AAQS analysis or the increment analysis. The air quality impacts of
Because AERMOD requires the emission rates to be entered in units of grams per second (g/s), it is useful
to first calculate the emissions on an annual, 24-hour, 8-hour, 3-hour or 1-hour basis, and then convert to
g/s. The maximum possible emissions during each averaging period should be used to model the impacts.
For example, an emergency flare is installed at an oilfield, resulting in SO2 emission higher than normal
during certain short term operations. The worst case short term flaring scenario is when produced sour
gas is routed to the emergency flare for a maximum of 5 minutes in a day. For modeling purposes, the
24-hour, the 3-hour and the 1 hour-SO2 mass emissions from the flare are all equal (e.g., 1 lb) because the
flaring event occurs within 5 minutes. However, the emission rate (g/s) varies for each averaging period.
If the ratio of PM2.5 to PM10 is not known, all PM10 can be assumed to be PM2.5. This is a conservative
assumption that should be refined if the PM2.5 impacts exceed an AAQS or increment threshold. The use
of a PM2.5/PM10 ratio less than 1 requires justification from the applicant and is subject to approval by the
District.
For most projects, the District recommends using the Tier 2 Ambient Ratio Method Version 2
(ARM2), which uses the EPA polynomial equation to predict NO2/NOX ratios and does not require
additional site-specific information. Please contact the District for approval prior to using any
other Tier or method.
EPA provides additional clarification on the conversion of NOX species to NO2 in the following
document:
• EPA’s July 2015 Technical support document (TSD) for NO2-related AERMOD modifications,
available at: https://www3.epa.gov/scram001/11thmodconf/AERMOD_NO2_changes_TSD.pdf.
The California Air Pollution Control Officers Association (CAPCOA) provides guidance on
demonstrating compliance with the 1-hour NAAQS, but does not discuss the new Tier 2 ARM2 or Tier 3
PVMRM2:
• CAPCOA’s October 2011 Guidance Document, Modeling Compliance of The Federal 1-Hour
NO2 NAAQS, available at:
http://www.valleyair.org/busind/pto/tox_resources/CAPCOANO2GuidanceDocument10-27-
11.pdf.
The methods available in AERMOD to account for the conversion of NOX species to NO2 are described
in Sections 3.2.1.1 through 3.2.1.4 below.
For more information on the Tier 2 ARM2, see EPA’s Technical support document (TSD) for NO2-
related AERMOD modifications and Section 3.2.4, Input parameters for NO2 conversion options, of the
AERMOD user’s guide, noted in the References section of this document.
3.2.1.3 Tier 3
The two Tier 3 methods for estimating the conversion of NOX to NO2 are the Ozone Limiting Method
(OLM) and the Plume Volume Molar Ratio Method Version 2 (PVMRM2).
The Tier 3 methods require background ozone concentrations. Other parameters for the Tier 3 methods
are:
• Equilibrium NO2/NOX Ratio: The default value used by the model is 0.90. A user-specified value
can be defined here between 0.10 and 1.00.
• Default In-Stack NO2/NOX Ratio: A default value of 0.50 will be used for all sources unless a
user-specified value is provided for the source in the NO2 Ratios screen of the Source Pathway
dialog. The default value specified will also be used if the user did not specify a value for a
specific source in Source Pathway - NO2 Ratios.
3.2.2 Special Processing Options for the AAQS Analysis for NO2
To meet the 1-hour NAAQS, the 3-year average of the annual 98th percentile of the 1-hour daily
maximum concentrations must not exceed 100 ppb (188 µg/m3). If Lakes’ AERMOD View is used to
complete the AQIA, select the option for 1-hour NO2 NAAQS processing in the Control pathway, which
will prompt the model to display the 8th Highest High (98th percentile) of the maximum daily 1-hour
results. If Lakes’ AERMO View is not used, the user may directly enter the appropriate
keywords/parameters in the AERMOD input file. See Section 3.2.15, Processing for 1-hour NO2 and SO2
NAAQS, of the AERMOD user’s guide for more information on the NO2 processing in AERMOD.
3.2.3 Special Processing Options for the AAQS Analysis for SO2
To meet the 1-hour NAAQS, the 3-year average of the annual 99th percentile of the 1-hour daily
maximum concentrations must not exceed 75 ppb (196 µg/m3). If Lakes’ AERMOD View is used to
complete the AQIA, select the option for 1-hour SO2 NAAQS processing in the Control pathway, which
will prompt the model to display the 4th Highest High (99th percentile) of the maximum daily 1-hour
results. If Lakes’ AERMOD View is not used, the user may directly enter the appropriate
The 3-hour NAAQS for SO2 is not to be exceeded more than once a year. For that reason, report the 2nd
Highest High for the 3-hour SO2 value. In Lakes’ AERMOD View, the 2nd Highest High can be selected
under the Output Options, Tabular Outputs Screen. If Lakes’ AERMOD View is not used, the user may
directly enter the appropriate keywords/parameters in the AERMOD input file.
In addition to the special processing options noted above, AERMOD will automatically apply a 4-hour
half-life decay coefficient for urban SO2 sources.
3.2.4 Special Processing Options for the AAQS Analysis for PM2.5
To meet the 24-hour NAAQS for PM2.5, the 3-year average of the annual 98th percentile of the 24-hour
concentration must be equal to or less than 35 μg/m3. If Lakes’ AERMOD View is used to complete the
AQIA, select the option for 24-hour PM2.5 NAAQS processing in the Control pathway, which will prompt
the model to display the 8th Highest High (98th percentile) of the 24-hour results averaged over 5 years
(assuming a 5-year meteorological data set is used). If Lakes’ AERMOD View is not used, the user may
directly enter the appropriate keywords/parameters in the AERMOD input file. See Section 3.2.14.1,
Processing for fine particulate matter (PM-2.5), of the AERMOD user’s guide for more information on
the PM2.5 processing in AERMOD.
Auer defines an area as urban if it has less than 35% vegetation coverage or if the area falls into one of the
land use types described in Table 3.3-1.
After the site classification has been determined, apply it to all sources (i.e., do not model some sources as
rural and other sources as urban). If the urban option is selected, enter the population of the city where
the project is located. If the facility is located in an unincorporated area, use the closest city listed in
Table 3.3-2. The default value of 1 meter for urban surface roughness length is appropriate for most
urban sites. Use of any value other than 1 meter for the urban surface roughness is considered a non-
regulatory option, and requires appropriate documentation and justification.
After entering all the source information into AERMOD, the user should create a separate source group
for each source, as well as including a source group containing all the sources in the model. The source
group of all sources will allow the impact from all sources to be easily identified. The separate source
groups for each source will help identify the air quality impact driving devices.
The source parameter inputs for each of the area source types are described in Sections 3.5.2.1 through
3.5.2.3 below.
The only option for defining the area is a rectangle or square. The maximum length/width aspect ratio for
area sources is 10 to 1. If the aspect ratio is greater than 10, use the AREAPOLY source type. See
Section 3.3.2.4, AREA source inputs, of the AERMOD user’s guide for more information on the AREA
source inputs.
The only option for defining the open pit is a rectangle or square. The maximum length/width aspect
ratio for open pit sources is 10 to 1. Because the open pit algorithm generates an effective area for
modeling emissions from the pit, and the size, shape and location of the effective area is a function of
wind direction, an open pit cannot be divided into a series of smaller sources. If the aspect ratio is greater
than 10, the user should model the pit as a rectangular shape of equal area. See Section 3.3.2.7,
OPENPIT source inputs, of the AERMOD user’s guide for more information on the OPENPIT source
inputs.
An irregularly-shaped volume can be represented by dividing the volume source into multiple smaller
volume sources. The user should create volume sources that cover approximately the same area where
the emissions actually occur.
Table 3.5.4-2: Summary of Suggested Procedures for Estimating Initial Vertical Dimensions
for Volume Sources
Procedure for Obtaining
Type of Source
Initial Vertical Dimension
Surface-Based Source (Vertical dimension of source in meters)
(he ~ 0) 2.15
Elevated Source (Building height in meters)
(he > 0) on or adjacent to a building 2.15
Elevated Source (Vertical dimension of source in meters)
(he > 0) NOT on or adjacent to a building 4.3
2
See Figure 1-8 (a) of USEPA’s User’s Guide for the Industrial Source Complex (ISC3) Dispersion Models,
Volume II – Description of Model Algorithms. Figure 1-8 (a) is reproduced in Appendix C of this document.
3
See Figure 1-8 (b) of USEPA’s User’s Guide for the Industrial Source Complex (ISC3) Dispersion Models,
Volume II – Description of Model Algorithms. Figure 1-8 (b) is reproduced in Appendix C of this document.
The PBW is the maximum length of a building that could affect air flow around and over the structure.
For more information on building downwash and PBW, see EPA’s Guideline for Determination of Good
Engineering Practice Stack Height (Technical Support Document For the Stack Height Regulations),
noted in the References section of this document.
AERMOD requires the user to input the UTM coordinates for all building corners and the height of each
building. For buildings with more than one height or roofline, the UTM coordinates and height are
required for each building tier.
3.7 Terrain
All sources, buildings and receptors are required to have a base elevation, which is affected by the terrain
of the site. Terrain elevations can have a large impact on the air dispersion modeling results. Elevation
data can be obtained from digital elevation map (DEM) files by running AERMAP in AERMOD.
Alternatively, if the site will be graded and post-grading elevations are known, those elevations should be
entered when defining the source parameters and building information in AERMOD. Do not import
source and building elevation data from the DEM file(s) when running AERMAP if graded elevations are
used. Furthermore, the AQIA report must clearly identify that graded elevations were used, and include a
spreadsheet with the graded elevations. The preferred format for submitting these graded elevations to
the District is the Lakes’ AERMOD View source file (*_Sources.xlsx) and the building file
(*_Buildings.xlsx) that are generated when the user exports the source data and the building data from
AERMOD View. If Lakes’ AERMOD View was not used for the AQIA, spreadsheets should be
submitted to the District that show the graded elevations for each source and building with the
corresponding Source IDs and Building IDs.
The PROFBASE parameter is used to specify the base elevation above mean sea level of the primary met
tower. The elevations of the Santa Barbara County sites are displayed in Table 3.8-1. All coordinates in
Table 3.8-1 are in the NAD83 datum.
3.9 Receptors
The receptor network must provide adequate coverage to capture the maximum pollutant concentrations.
The receptor network shall include a Cartesian grid, property boundary receptors and Class I receptors (if
applicable). The flagpole height of all receptors shall be set to 0 meters.
If it appears that the grid receptors are not close enough to capture the maximum pollutant concentrations,
the District may require the AQIA to be rerun with a finer grid. For facilities with a large number of
emitting sources and a large property boundary, fine grid spacing will significantly impede the model run
time. It may be necessary to run the AQIA with a coarse grid to determine the areas of highest
concentration and then rerun the AQIA with finer grids in those areas. If this method is used, finer grids
shall be used for all areas with high concentrations, not just the single area with the highest concentration.
AERMOD allows for multiple grids to be included in one dispersion run.
Class I Areas include national parks, national wilderness areas, and national monuments. These areas are
granted special air quality protections under Section 162(a) of the federal Clean Air Act. The only Class I
Area in Santa Barbara County is the San Rafael Wilderness in the northeastern section of the county. The
Class I Impact Area extends 10 kilometers from the wilderness in all directions, as shown in
Figure 3.9.2-1.
4
“Class I Impact Area” means all lands outside of a Class I Area but within 10 kilometers (6.2 miles) of the
boundary of a Class I Area, or other areas established by the Control Officer based on standard meteorological
techniques such as hourly wind roses, frequency distribution of atmospheric wind classes, morning and afternoon
mixing depths and any other meteorological or geographical considerations needed to establish the Class I Impact
Area.
The District has generated Class I receptors 25 meters apart around the entire San Rafael Wilderness
boundary in UTM coordinates, in the NAD83 datum. The list of Class I receptors is available in Zone 10
and Zone 11, in a simple .xlsx format and in a .csv format compatible with Lakes’ AERMOD View.
Table 3.9.2-1 contains links to download the receptor lists. This information is also available online at
the District’s AQIA: Class I Area webpage, noted in the References section of this document.
4. Results
Once all the AERMOD runs are complete, the results should be compiled into tables for ease of review.
Explanations of how each concentration was determined from the AERMOD output files should be
included in the AQIA report.
The highest modeled result (i.e., 1st Highest High) is not required to be compared to the NAAQS for all
averaging periods and pollutants. For example, the reportable concentration for the 24-hour averaging
period for PM2.5 is the 98th percentile, multi-year average. This means that the 8th Highest High can be
reported and compared to the NAAQS for PM2.5 for the 24-hour averaging period. California Ambient
Air Quality Standards (CAAQS) for CO, SO2 (1-hour and 24-hour), NO2, and particulate matter (PM10
and PM2.5), are values that are not to be exceeded. This means that the 1st Highest High is reported and
compared to the CAAQS. Because the form, or reportable concentration, of the CAAQS is different from
the NAAQS for 1-hour SO2 and 1-hour NO2, and the concentration for the NAAQS is lower than the
CAAQS, it is possible for the 1-hour SO2 or 1-hour NO2 to meet either one of the standards but exceed
the other. Therefore, SO2 and NO2 must be modeled for comparison to both the 1-hour CAAQS and the
1-hour NAAQS.
The NAAQS for PM2.5 is based on the annual mean, averaged over 3 years. The NAAQS for SO2 and
NO2 are based on the highest annual average from an individual year, rather than an average across the
years modeled.
For convenience, the modeler may choose to report the most conservative result, the highest
modeled concentration (i.e., 1st Highest High) for the specified averaging period. This option may be
preferable in situations with very low concentrations, as it will avoid the requirement of multiple runs for
the same pollutant and averaging period (e.g., 1 hour SO2 is run only once and the 1st Highest High is
compared to the lowest AAQS, 196 µg/m3). When this option is used, the result must be clearly
presented as the 1st Highest High, with language explaining that performing separate runs for the NAAQS
and CAAQS is not necessary due to the low concentration.
Santa Barbara County is currently in nonattainment status for PM10 on both an annual and 24-hour basis.
Because the background concentrations for annual PM10 and 24-hour PM10 are above the AAQS, all
projects emitting PM10 will result in a PM10 concentration in exceedance of the AAQS. The District has
determined that projects will not contribute significantly to an exceedance of an AAQS if the project’s
contribution is less than ten percent of the AAQS. Therefore, the District typically approves projects with
annual and 24-hour PM10 impacts less than ten percent of the AAQS.
If the EPA’s Air Data is used to determine the background concentrations, exceptional events5 may be
excluded from the data set. The pre-generated .csv data files available for download on the EPA’s Air
Data website contain a column that indicates whether exceptional events are included or excluded from
the data (or if there were no exceptional events during that year for a given pollutant).
Please note that although older EPA guidance recommended the use of the maximum 24-hour monitored
PM2.5 concentration, current guidance 6,7 recommends that the three-year average of 98th percentile
24-hour monitored PM2.5 concentrations be used to determine compliance with the NAAQS. However, as
previously mentioned in this section, the modeler may choose to use the more conservative method of
reporting the background concentration as the highest recorded concentration from the most recent three
years of data.
5
Exceptional events are unusual or naturally occurring events that can affect air quality but are not reasonably
controllable using techniques that tribal, state or local air agencies may implement; exceptional events may include
wildfires, high wind dust events, prescribed fires, stratospheric ozone intrusions, and volcanic and seismic activities.
More information about exceptional events may be found here: https://www.epa.gov/air-quality-analysis/treatment-
air-quality-data-influenced-exceptional-events-homepage-exceptional.
6
U.S. Environmental Protection Agency. Memorandum. May 20, 2014. Guidance for PM2.5 Permit Modeling.
https://www3.epa.gov/ttn/scram/guidance/guide/Guidance_for_PM25_Permit_Modeling.pdf
7
U.S. Environmental Protection Agency. Memorandum. February 10, 2020. DRAFT Guidance for Ozone and Fine
Particulate Matter Permit Modeling.
https://www3.epa.gov/ttn/scram/guidance/guide/Draft_Guidance_for_O3_PM25_Permit_Modeling.pdf
Averaging
Pollutant Form Description Background Concentration
Period
Highest recorded hourly concentration
CAAQS: Not to be exceeded
from the most recent three years of data
1-hour NAAQS: 99th percentile of 1-hour Average of the 4th highest hourly
daily maximum concentrations, concentrations for the most recent three
multi-year average years of data
The applicant may consume the full increment range for 1-hour NO2, 3-hour ROC and 24-hour PM10;
mitigation fees for consuming part or all of the increment are required and discussed in Section F.3 of the
District’s Rule 805, noted in the References section of this document.
Class I Class II
Averaging Form (Reportable
Pollutant Increment Increment Form Description
Period Concentration)
(µg/m3) (µg/m3)
24-hour 10 37 Not to be exceeded 1st Highest High
TSP Annual average for
Annual1 5 19 1st Highest High
individual year
Not to be exceeded more
3-hour 25 512 2nd Highest High
than once per year
SO2 Not to be exceeded more
24-hour 5 91 2nd Highest High
than once per year
Annual average for
Annual 2 20 1st Highest High
individual year
1-hour 10 100-188 Not to be exceeded 1st Highest High
NO2
Annual 2.5 25 Not to be exceeded 1st Highest High
1-hour 800 10,000 Not to be exceeded 1st Highest High
CO
8-hour 200 2,500 Not to be exceeded 1st Highest High
ROC 3-hour 3 40-160 Not to be exceeded 1st Highest High
Not to be exceeded more
24-hour 8 12-30 2nd Highest High
than once per year
PM10
Annual average for
Annual 4 17 1st Highest High
individual year
Not to be exceeded more
24-hour 2 9 2nd Highest High
than once per year
PM2.5
Annual average for
Annual 1 4 1st Highest High
individual year
1
The form of the annual increment threshold for TSP is the “Annual Geometric Mean.” AERMOD calculates the
annual arithmetic mean, not the annual geometric mean. However, the District will accept the annual arithmetic
mean as an approximation of the annual geometric mean.
8
Section 163(a) of the Clean Air Act stipulates that EPA’s short-term increments “can be exceeded during one such
period per year”.
The description and operating schedule for each device should be reported in table format including the
following information:
• Device name and identification number
• Number of operating hours per day and per year, including which hours the device operates in a
24-hour day
• Number of operating days per week, including which days the device operates in a 7-day week
• Number of operating days or weeks per year
• Source identification number(s) for the AERMOD sources where emissions are released
Table 5.5.2-1: Example Increment Analysis Modeling Results for Class II Impacts
If the AQIA or AQIA report fail to comply with these guidelines, the AQIA and AQIA report will be
returned, with District comments, to the applicant for revision.
6. References
• California Air Resources Board. Accessed June 29, 2020. ADAM: Air Quality Data Statistics.
https://www.arb.ca.gov/adam/index.html.
• California Air Resources Board. Accessed June 29, 2020. California Ambient Air Quality
Standards. https://ww2.arb.ca.gov/resources/california-ambient-air-quality-standards.
• California Air Resources Board. Accessed June 29, 2020. National Ambient Air Quality
Standards. https://ww2.arb.ca.gov/resources/national-ambient-air-quality-standards.
• Lakes Environmental. 1995-2020. AERMOD ViewTM.
• Providence Oris. 2020. BEEST Suite.
• Santa Barbara County Air Pollution Control District. March 17, 2005. Rule 210. Fees.
https://www.ourair.org/wp-content/uploads/rule210.pdf.
• Santa Barbara County Air Pollution Control District. August 25, 2016. Rule 802. New Source
Review. https://www.ourair.org/wp-content/uploads/rule802.pdf.
• Santa Barbara County Air Pollution Control District. August 25, 2016. Rule 805. Air Quality
Impact Analysis, Modeling, Monitoring, and Air Quality Increment Consumption.
https://www.ourair.org/wp-content/uploads/rule805.pdf.
• Santa Barbara County Air Pollution Control District. 2020. AQIA: Class I Area.
https://www.ourair.org/aqia-class-i-area/.
• Santa Barbara County Air Pollution Control District. 2020. Annual Air Quality Report.
https://www.ourair.org/sbc/annual-air-quality-report/.
• Santa Barbara County Air Pollution Control District. 2020. Meteorological Data.
http://www.ourair.org/metdata/.
• U.S. Environmental Protection Agency. June 1985. Guideline for Determination of Good
Engineering Practice Stack Height (Technical Support Document For the Stack Height
Regulations). https://www3.epa.gov/scram001/guidance/guide/gep.pdf.
• U.S. Environmental Protection Agency. November 9, 2005. 40 CFR Part 51 Appendix W. Federal
Register. https://www3.epa.gov/ttn/scram/guidance/guide/appw_05.pdf.
7. Contacts
For questions about the District’s requirements for modeling, contact the District at:
phone: 805-961-8800
email: engr@sbcapcd.org
For questions about AERMOD, contact EPA’s Region IX Modeling Contact, Carol Bohnenkamp, at:
phone: 415-947-4130
email: bohnenkamp.carol@epa.gov
AERMOD includes options for modeling source emissions that fluctuate over time. With the variable
emissions option, the modeler can select the hours of operation and the emission rate for each individual
source. Emission variations can be characterized across many different periods, including hourly, daily,
monthly and seasonally. If variable emissions are used, the applicant must submit documentation with
the AQIA that justifies using that variable emissions scenario. The District may require permit conditions
to enforce the operating hours, days, months, etc. selected in the variable emissions scenario.
1
EPA - Office of Solid Waste and Emergency Response, July 1998. Human Health Risk Assessment Protocol for
Hazardous Waste Combustion Facilities. EPA530-D-98-001A. U. S. Environmental Protection Agency, Research
Triangle Park, NC.
It is important to note that the hours of the day displayed in AERMOD correspond to the hour ending at
the time displayed. Therefore, hour 7 corresponds to the hour from 6AM to 7AM, and hour 20
corresponds to the hour from 7PM to 8PM.
1 0 13 1
2 0 14 1
3 0 15 1
4 0 16 1
5 0 17 1
6 0 18 1
7 2 19 1
8 1 20 2
9 1 21 0
10 1 22 0
11 1 23 0
12 1 24 0
Approaches for modeling emission impacts from various types of storage tanks are outlined in Sections
B.1.1 and B.1.2 below.
There is virtually no plume rise from tanks. Therefore, the stack parameters for the stack gas exit velocity
and stack diameter should be set to near zero for the stacks representing the emissions. In addition, stack
temperature should be set equal to the ambient temperature. This can be accomplished in AERMOD by
inputting a value of 0 for the stack gas temperature.
Note that it is very important for the diameter to be at or near zero. With low exit velocities and larger
diameters, stack tip downwash will be calculated. A very small stack diameter effectively eliminates the
stack tip downwash. Because all downwash effects are being modeled with the building downwash
algorithm, the additional stack tip downwash calculations would be inappropriate.
Groups of idling vehicles may also be modeled as one or more VOLUME sources. In those cases, the
initial dimensions of the source, dispersion coefficients, and release heights should be calculated
assuming that the vehicles themselves are inducing no turbulence. Source characterization should be
based on the type of vehicles idling; e.g., if the vehicles idling are primarily heavy-duty trucks, then the
release height would be 4 meters. Furthermore, sources should be placed in the location(s) where the
majority of emissions occur. For example, if buses enter and exit a bus terminal from a single driveway,
the bus exhaust emissions should be modeled using one or more VOLUME sources at the location of that
driveway, rather than spreading the emissions across the entire terminal yard.
Sources that may be modeled as LINE sources may include roadways and areas within which emissions
occur relatively evenly. USEPA recommends that the LINE source keyword be used for modeling
roadway sources as it greatly simplifies defining the physical location and orientation of sources. The
LINE source type option allows users to specify line-type sources based on a start-point and end-point of
the line and the width of the line.
The District’s recommended method for calculating LINE source modeling parameters is described in
Sections C.1.1 through C.1.3 below.
The initial vertical dimension coefficient, Szinit, is then estimated by dividing the Top of Plume
Height by 2.15. For typical light-duty vehicles, this corresponds to a Szinit of 1.2 meters. For typical
heavy-duty vehicles, the value of Szinit is 3.2 meters.
An alternate method to determine source parameters that vary with different fractions of light-duty and
heavy-duty traffic is to create two overlapping versions of each roadway source, corresponding to either
light-duty or heavy-duty traffic. These two sources would be superimposed in the same space, but would
have emission rates, initial vertical dimensions and release heights that are specific to light-duty or heavy-
duty vehicles.
1
If multiple pollutants are being modeled and the emission factors vary significantly for different vehicle types, then
determine the Top of Plume Height based on the traffic volume weighted approach.
The URBAN option applied to the RLINE source type is an ALPHA feature and shall not be used in
Santa Barbara County at this time.
The District’s recommended method for calculating RLINE source modeling parameters is described in
Sections C.2.1 through C.2.3 below.
2
If multiple pollutants are being modeled and the emission factors vary significantly for different vehicle types, then
determine the Top of Plume Height based on the traffic volume weighted approach.
The initial vertical dimension coefficient, Szinit, is then estimated by dividing the Top of Plume
Height by 2.15. For typical light-duty vehicles, this corresponds to a Szinit of 1.2 meters. For typical
heavy-duty vehicles, the value of Szinit is 3.2 meters.
An alternate method to determine source parameters that vary with different fractions of light-duty and
heavy-duty traffic is to create two overlapping versions of each roadway source, corresponding to either
light-duty or heavy-duty traffic. These two sources would be superimposed in the same space, but would
have emission rates, initial vertical dimensions and release heights that are specific to light-duty or heavy-
duty vehicles.
The VOLUME source algorithms are applicable to line sources with some initial plume depth, such haul
roads, areas designated for truck or bus queuing or idling, driveways and pass-throughs in transit or
freight terminals, and locomotive emissions. USEPA recommends modeling fugitive dust from haul
roads as adjacent VOLUME sources, unless there are receptors located within the volume source
exclusion area, which is further explained in Section C.3.3.
The goal of using VOLUME sources to represent a roadway is to create a uniform emissions
characterization. Ensure that VOLUME sources are not spaced too widely along the roadway. Adjacent
VOLUME sources should overlap and the distance between the center of one VOLUME source to the
next should be equal to the width of each source, as described in the AERMOD user’s guide and
represented in Figure 1-8(a) of USEPA’s September 1995 User’s Guide for the Industrial Source
Complex (ISC3) Dispersion Models, Volume II – Description of Model Algorithms (and reproduced on the
following page). Any other approximation of roadways with VOLUME sources will result in nearby
receptors being over or under-estimated depending on their proximity to the center of the volume source.
The District’s recommended method for calculating VOLUME source modeling parameters is described
in Sections C.3.1 through C.3.3 below.
The initial vertical dimension coefficient, Szinit, is then estimated by dividing the Top of Plume Height
by 2.15. For typical light-duty vehicles, this corresponds to a Szinit of 1.2 meters. For typical heavy-duty
vehicles, the value of Szinit is 3.2 meters.
3
If multiple pollutants are being modeled and the emission factors vary significantly for different vehicle types, then
determine the Top of Plume Height based on the traffic volume weighted approach.
In addition, when the source-receptor spacing in AERMOD is shorter than the distance between adjacent
volume sources, AERMOD may produce aberrant results. Therefore, ensure that no receptors are placed
within a distance of (2.15 x Syinit + 1 meter) of the center of a VOLUME source, known as the “receptor
exclusion zone.” 4 As a practical recommendation, when using VOLUME sources to simulate a roadway
where receptors are placed five meters from the edge of the roadway, the width of a volume source should
be less than eight meters. This will ensure that no receptors fall within the receptor exclusion zone. If the
width of the roadway is larger than eight meters, it is recommended that additional VOLUME sources be
defined (e.g., separate each lane of traffic), or LINE sources be used.
4
Ambient air receptors, including Cartesian grid receptors and property boundary receptors must not be excluded.
If any ambient air receptors fall within the “receptor exclusion zone” and using adjacent VOLUME sources results
in aberrant modeled concentrations, then the LINE source type must be used instead of adjacent VOLUME sources.
If there is no consistent operational schedule for the portable equipment, use the following methodology
to apportion the emissions:
1. The annual emissions should be distributed evenly throughout all locations where the equipment
emits throughout the year.
2. When determining the short-term (i.e., 24-hour, 8-hour, 3-hour and 1-hour) impacts, the model
should first be run with the short-term emissions from any portable equipment set to zero. After
the point of maximum impact (PMI) is determined, a second analysis should be performed with
the short-term emissions for all portable equipment assigned to the closest location to the PMI
that the equipment will operate.
3. If there is concern that emissions from the portable equipment may be the main contributor to a
short-term averaging period concentration for any of the pollutants, a third short-term modeling
run should be performed. In this modeling run, the portable equipment should be placed at the
location closest to the property boundary that it will operate. The short-term impacts at the PMI
from this run should be compared to the short-term impacts at the PMI for the second modeling
run as described in Step 2, with the higher of the two values reported as the PMI for that pollutant
and averaging period.
An example of the methodology described above is well drilling at an oil and gas facility. In this
example, a total of 50 wells will be drilled over a 10-year period:
1. One volume source is modeled at each well location. The average annual emissions for each
volume source are equal to the total well drilling emissions over the lifetime of the project
divided by 10 years and by 50 wells.
2. Next, the short-term impacts are analyzed without any short-term emissions from well drilling.
The initial PMI for each pollutant and averaging period for this analysis is determined, and then
the short-term emissions for each pollutant are assigned to the well located closest to the PMI for
that pollutant and averaging period, as there will be only one drilling rig in operation at a time.
For this second analysis, the closest well location to the PMI for 24-hour PM10 is approximately
300 meters from the property boundary, and the resulting 24-hour PM10 concentration at the PMI
is 3.7 μg/m3.
3. Additionally, a 24-hour PM10 modeling run is performed with the maximum 24-hour well drilling
PM10 emissions assigned to the well located closest to the property boundary, which is
approximately 60 meters from the property boundary. The resulting 24-hour PM10 concentration
at the PMI is 3.0 μg/m3. Therefore, the reported modeled 24-hour PM10 concentration is the PMI
from the second analysis, 3.7 μg/m3, which must be added to the background concentration for
comparison to the AAQS. This same methodology must be implemented for each pollutant
and short-term averaging period.