Air Quality Permitting Challenges for the National Bio and Agro-Defense Facility (NBAF)

Ron Petersen, CCM, CPP, Inc

The NBAF will provide the nation with the first integrated agricultural and zoonotic disease, research, diagnostics, training and evaluation (RDT&E) facility with the capability to address threats from high-consequence zoonotic diseases agents and foreign animal disease (FAD) agents. The NBAF project scope consists of two laboratory facilities and three outbuildings within the site itself located in Manhattan, Kansas. This talk will focus on boiler and generator emissions associated with the CUP and emissions from two identical medical waste incinerators associated with the laboratories.

The CUP will have seven 800 BHP fire-tube, scotch marine type boilers to provide steam service to the main lab building. All boilers will be equipped with dual fuel burners (natural gas and #2 fuel oil). One of the seven boilers will serve as a redundant unit and is not required to operate for meeting design steam loads. Fuel oil is only used for emergency operation of the boilers.  

In addition, the CUP will be equipped with seven 2,000 kW diesel generators that will be used for emergency purposes only.  The generators will be operated intermittently for testing and emergency situations (maximum of 500 hours per year). The generators will be EPA Tier 2 certified. One of the seven generators will serve as a redundant unit and is not required to operate for meeting design loads under emergency conditions. Generators will be tested during the daytime (6am - 6pm).

Early in the project the Kansas Department of Health and Environment (KDHE) designated the NBAF as a major pollutant source which requires that the owner and/or operator demonstrate that emissions from the boilers, generators and incinerators will not cause or contribute to air pollution in violation of any National Ambient Air Quality Standard (NAAQS) or Prevention of Significant Deterioration (PSD) increments for the following pollutants PM10, SO2, or NO2.

To assess compliance with NAAQS and PSD increments, the EPA approved AERMOD modeling system was used to evaluate the air quality impacts that will result from the proposed NBAF boiler, generator and incinerator exhausts  Initial modeling showed that compliance with NAAQS would be a problem based on the worst-case boiler operating scenario. Additional analysis of the realistic boiler operating scenarios and alternate stack heights showed that NAAQS and PSD increments could be met and a permit to operate was obtained with these operating restrictions.

This talk will document the steps that were undertaken to demonstrate compliance with NAAQS and PSD increments and highlight when projects may be required to conduct this type of analysis prior to being able to obtain a construction permit.

Biography:

Dr. Petersen, Principal at CPP, Inc., has over 35 years experience in modeling exhaust dispersion and has conducted numerous studies related to exhaust/intake design and pollutant transport for many laboratories. He presented on behalf of the A&WMA's meteorology committee at past EPA Modeling Conferences regarding revisions to the "Guideline on Air Quality Modeling.” He is the primary author of the Labs21 BPG on “Modeling Exhaust Dispersion” and has been the principal investigator on several ASHRAE research studies. He was the primary contributor to the 2011 ASHRAE Applications Chapter 45 -Building Intake and Exhaust Design. Since 2000, he has presented at Labs21 Conferences on energy savings and exhaust/intake design. He also has provided short courses for ASHRAE, IS2L and AIHA and  published several peered reviewed papers on the subject of modeling exhaust dispersion. He has a Ph.D. in Civil Engineering from CSU and a M.S. in Meteorology and B.S. in Mathematics from SDM&T.

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