COMMUNITY AIR QUALITY IMPROVEMENT PLAN: EFFECTS ON A SUGAR BEET PROCESSING FACILITY
Dean C. DeLorey
Corporate Environmental Engineering Manager The Amalgamated Sugar Company LLC
P. O. Box 8787 Nampa, Idaho 83653-8787
1.0 INTRODUCTION
The Amalgamated Sugar Company LLC facility located in Nampa, Idaho has recently participated in the development of an air quality improvement plan for a neighboring county. This improvement plan was required by the Idaho Department of Environmental Quality (IDEQ) to ensure particulate matter (PM-lO) concentrations in Northern Ada County remain in compliance with federal health standards. The highest measured daily PM -10 concentrations occur during wintertime inversions. A detailed analysis of all emission sources in the area was conducted. Predominant sources impacting air quality are associated with motor vehicles and wood stoves. On a regional basis, industrial sources have only a very small impact. However, predictive models indicate higher local impacts from industry including Amalgamated, which is the largest industrial source in the area. As a result, Amalgamated is required to complete a series of emissions reduction projects, including the replacement of two direct-fired pulp dryers with a steam dryer by 2007.
2.0 BACKGROUND
Northern Ada County, in southwestern Idaho, was previously designated as an area not in compliance with daily National Ambient Air Quality Standard (NAAQS) fOF PM-I0 (particulate matter less than 10 microns). This designation resulted from seven (7) measured PM-I0 concentrations above the NAAQS from 1986 through 1991 during wintertime inversions. The primary cause of these exceedances was woodstoves. As a result of these previous exceedances and the need to address large increases in the number of motor vehicles in the area, IDEQ was required to submit a PM-I0 air quality improvement plan to the Environmental Protection Agency (EPA).
2.1 Purpose
In September 2002, the IDEQ completed a plan called "Northern Ada County PM-I0 SIP Maintenance Plan and Redesignation Request". The plan was submitted to EPA Region X to ensure PM-l 0 ambient concentrations in Northern Ada County (which includes the City of Boise) remain below the NAAQS's. The IDEQ expanded the scope of the maintenance plan to also include emission sources in the entire Boise metropolitan area known as the Treasure Valley (Figure I). This includes Canyon County which is where The Amalgamated Sugar Company LLC, Nampa facility is located. The PM-IO maintenance plan mandates control measures to address these previous exceedances and provides emissions budgets for all emission sources through the year 2015. Specifically,
the plan includes a motor vehicle emissions budget (MVEB) as required by the 1990 Clean Air Act and federal transportation laws known as the Transportation Conformity Act.
2.2 National Ambient Air Quality Standards (NAAQS's)
NAAQS's have been established by the EPA to protect public health and the environment. . Primary standards were developed to protect the air" which people breathe. The standards are based on relationships between pollutant exposure levels and effects to health. Secondary standards protect public welfare including visibility and damage to crops. NAAQS's have been developed for particulate matter (TSP, PM-lO and PM2.5), sulfur dioxide (S02), nitrogen oxides (NOx), carbon monoxide (CO), ozone (03) and lead
(Pb). Table 1 provides a summary of the NAAQS's for these air contaminants.
2.3 Plan Components
The key components of the PM-IO maintenance plan were: 1) Comprehensive inventories for all sources of emissions; 2) Air quality impact analyses using air dispersion models to predict ambient PM -10 concentrations; and 3) Control measures to ensure ambient PM-IO concentrations throughout Northern Ada County remain in compliance with the PM-IO 24-hour NAAQS. The plan focused on emissions and air quality impacts during 1991 wintertime inversion events.
2.3.1 Emissions
IDEQ compiled 1999 base year and future emissions inventories for all sources in the Treasure Valley. Both daily and annual emissions inventories were estimated for the following source categories: 1) On-road mobile (motor vehicle exhaust, fugitive rbad dust); 2) Non-road mobile (exhaust from aircraft, lawn equipment, locomotives, . . construction equipment, etc.); 3) Area sources (residential fuel combustion including woodstoves, open burning, agricultural activities, etc.); and 4) Industrial emissions. Pollutants inventoried were PM-IO, NO", S02(CO), anunonia (NH3), and volatile organic
compounds (VOC's).
Amalgamated and other industries were required to submit detailed emissions inventories and supporting documentation. Actual emissions data was compiled for a 1999 wintertime daily period and the 1999 calendar year. Future allowable emissions, for air permitting, were also tabulated.
2.3.2 Air Quality Impact Analysis
Air quality impact analyses were conducted using ambient air dispersion models to predict PM-IO concentrations. The air dispersion models required several inputs including emissions and weather data. To determine the relative contribution of each emission source category a source apportionment study was also conducted. Air quality
impacts were evaluated for several different periods and focused on wintertime inversion episodes.
3.0 COMMUNITY WIDE EVALUATION
This section provides a discussion of the PM -10 Maintenance Plan and Redesignation Request. Summaries of the emission data -and air quality impact evaluations for all emissions sources in the Treasure Valley (Ada and Canyon Counties) are discussed. Consultants were utilized by IDEQ to prepare the plan.
3.1 Emissions Inventory
Estimated 1999 wintertime daily emissions for all emission sources are provided in Table 2. As shown, non-industrial sources (i.e., on-road mobile, non-road mobile, and area sources) were by far the largest overall contributor to air pollution in the Treasure Valley. Industry accounted for only three percent (3%) of the total PM-1O emissions. Over half of the estimated industrial PM-I0 emissions were from The Amalgamated Sugar Company LLC, Nampa facility.
3.2 Air Quality Impact Analysis
Air dispersion modeling was used to ensure future PM -10 concentrations in the area remain in compliance with the PM-I0 NAAQS's. The model selected by IDEQ was CAMx, which was developed by ENVIRON. CAMx predicts ambient PM-IO
concentrations from particulates directly emitted from emissions sources. The model also predicts PM -10 concentrations produced from atmospheric chemical reactions of ammorua, sulfate, and nitrate compounds. These are known as secondary PM-I0 aerosols.
The CAMx model was calibrated using 1999 measured ambient PM-10
concentrations. The calibration was accomplished by modeling 1999 emissions data with 1999 wintertime weather data and comparing the predicted results to the measured concentrations. For the future compliance demonstration analysis, IDEQ selected a worst case 1991 wintertime inversion episode along with future predicted emission rates for 2010,2015, and 2020.
Table 3 provides the future maximum predicted PM-I0 concentrations for Northern Ada County. As shown, initial predicted PM-I0 concentrations were above the 150 ~g/m3 daily NAAQS. In order to demonstrate compliance, emissions had to be reduced from residential wood burning based on assumptions for a voluntary wood burning ban. IDEQ assumed a 43% reduction in wood smoke emissions. With the bum ban in effect, PM-I0 concentrations dropped from a range of 170-193 )lg/m3 to 122-130 )lg/m3.
3.3 Source Apportionment
A receptor modeling study was conducted to determine the relative contribution of mobile sources, wood smoke, road dust, and other combustion sources impacting PM 10 concentrations in the Boise area. This study compared the ambient PM -10 chemical species to emission source chemical species. Modeling results for wintertime inversiori events in 1991 and 1999 are included in Figure 3. As sho.wn, non-industrial sources including gasoline powered vehicles, diesel powered vehicles, and wood combustion were predicted to account for over 98% of the ambient impacts in Boise. Impacts from industrial sources including Amalgamated, accounted for less than one-percent (1 %) of the ambient PM-10 impacts.
4.0 THE AMALGAMATED SUGAR COMPANY LLC
Based on the CAMx modeling results discussed in Section 3, Amalgamated's impacts to Northern Ada County were not significant. However, predicted concentrations near the facility were elevated and required further assessment including commitments to reduce emissions. This section discusses Amalgamated's local impacts and improvements.
4.1 Facility Description & Emission Sources
The sugar beet processing facility, which began operation in 1942, is located in the City of Nampa (population 55,000) in southwestern Idaho (Figure 2). Boise, which is the capitol of Idaho, is located approximately twenty miles east of the facility. During the beet campaign, which typically occurs from October through January, the facility processes approximately 12,000 tons of beets per day. The facility produces approximately 650 tons of dried pulp and 18,000 cwt of sugar per day. Following the beet processing campaign, the facility processes thick juice and molasses for the remainder of the year.
The largest emissions sources at the facility are three coal-fired boilers, three coal-fired pulp dryers, and two coke-fired lime kilns. Other minor sources of emissions are dried pulp pellet coolers, sugar processing equipment, material handling, main mill vents and fugitive dust. Estimated hourly emission rates for these sources are included in Table 4.
4.2 Air Quality Impact Assessment - Existing Operations
Facility wide PM-10 air dispersion modeling was conducted using ISC Prime. Modeled concentrations represent worst-case impacts and are likely well above actual measured concentrations. Conservative assumptions were used for modeling including allowable emission estimates and severe wintertime inversion weather data. Modeling was conducted using Boise's most severe wintertime weather inversions, which occurred during 1987 through 199 L In addition to PM-I 0, Amalgamated was required to evaluate S02, CO, and N02ambient air impacts. In order to determine the overall local air quality
impacts, background air pollutant concentrations from all other sources in the area, were also included.
Based on a review of the modeled results, predicted concentrations above the NAAQS occurred only occasionally. Overall, for the majority of the time, predicted concentrations were in compliance with the NAAQS. Maximum predicted concentrations were heavily influenced by building downwash associated with the tall sugar silos on the south side of the facility. Table 5 provides a summary of the maximum predicted air pollutant concentrations from current facility operations. The highest concentrations occurred on the public roadways closest to the main factory area. Total modeled concentrations for PM-10, S02, and N02 were above the NAAQS. CO impacts were below the NAAQS. Figure 4 provides the maximum predicted PM-10 concentrations surrounding the facility. As shown, compliance with the NAAQS was within less than one mile from the facility. S02, N02, and CO have similar distributions, however, compliance with the NAAQS occurred much closer to the plant boundaries.
4.3 Air Quality Assessment - Future Operations
Based on the PM-10, S02, and N02 modeled concentrations associated with current operations, the Nampa facility was required to commit to a series of control measures to reduce local air quality impacts. The purpose of the control measures was to ensure future operations remain in compliance with the NAAQS in all areas surrounding the facility. Because of the seasonal nature of the facility, all final emission rates were conservatively established at maximum operating rates while providing the facility with operating flexibility to process beet crops. To address the ~levated impacts, several alternatives were evaluated including emissions reductions and/or increasing stack heights of the boilers/pulp dryers at the facility. Amalgamated committed to the following improvements:
• Replacement of two coal-fired pulp dryers with a steam dryer. • Replacement of the pellet cooler cyclones with a baghouse. • Fugitive Dust Management Plan
• Increase the height of the Riley Boiler stack.
The steam dryers, pellet cooler baghouse, and fugitive dust management will result in a significant reduction in future emissions from the facility. Future hourly emissions for PM-10, NOx, S02, and CO will be reduced by 101 lbslh, 120 lbslh, 50 lbslh, and 286 lbslh respectively. Future predicted ambient concentrations following the completion of these projects, are shown in Table 6. An area wide distribution of future predicted PM-10 concentrations is included in Figure 5.
IDEQ issued the Nampa facility an industrial air pollution source permit (known as a Tier II permit) on September 30, 2002, requiring the completion of the control measures by 2007. The permit also includes facility wide emission limitations, monitoring, record keeping, and reporting requirements.
5.0 CONCLUSIONS
The Northern Ada County PM-I 0 SIP Maintenance Plan and Redesignation Plan was prepared by IDEQ to ensure PM-lO ambient air quality concentrations remain in compliance with NAAQS. The focus of the plan was to address air quality impacts during wintertime inversions. Non-industrial sources including woodstoves and motor vehicles account for the largest source of emissions in the area. Industries are a much
smaller source of community wide emissions. To ensure future PM-lO compliance,
Northern Ada County must continue to implement the voluntary wood bum program. The Amalgamated Sugar Company LLC, Nampa facility emissions have very little impact on the air quality in Northern Ada County. This is due to Amalgamated's relatively small PM-IO emission rates compared to the non-industrial sources and the great distance (approximately 20 miles) between the Nampa facility and the Boise area PM-IO monitor.
Based on air dispersion modeling results, Amalgamated's most significant impacts occurred at the plant boundaries. Because the predicted concentrations were above the NAAQS, Amalgamated was required to commit to a series of improvements including the installation of a steam dryer.
Table 1 - National Ambient Air Quality Standards
I POLLUTANT I STANDARD VALUE I STANDARD TYPE I
Particulate (PM-IO)a Annual Arithmetic Mean 24-hour Average
50 )..tg/m3 150 )..tg/m3
Primary & Secondary Primary & Secondary Particulate (PM 2.5)b
Annual Arithmetic Mean 24-hour Average
15 )..tg/m3 65 )..tg/m3
Primary & Secondary Primary & Secondary Sulfur Dioxide (S02)
Annual Arithmetic Mean 24-hour Average 3-hour Average 80 )..tg/m3 365 )..tg/m3 1300 )..tg/m3 Primary Primary Secondary Nitrogen Dioxide (N02)
Annual Arithmetic Mean 100 )..tg/m3 Primary & Secondary Carbon Monoxide (CO)
8-hour Average I-hour Average 10,000 )..tg/m3 40,000 )..tg/m3 Primary Primary Ozone (03) I-hour Average 8-hour Average 235 )..tg/m3 157 )..tg/m3
Primary & Secondary Primary & Secondary Lead (Pb)
Quarterly Average 1.5 )..tg/m3 Primary & Secondary a PartIcles wIth dIameters of 10 mIcrometers or less
..,,
N
-
QTable 2 - Ada and Canyon Counties - 1999 Wintertime Emission Inventories
PMIO NO
x
sox
NH3 YOCSource Category Tons/day % of tons/day % of tons/day % of tons/day % of tons/day % of
total total total total total
On-Road Mobile Sources 65.43 88.7% 21.9 54.3% 0.84 6.7% 0.37 2.2% 11.87 22.8%
Vehicle Emissions (Exhaust, 0.41 0.6% 2l.9 54.3% 0.84 6.7% 0.37 2.2% 1l.87 22.8%
Tire Wear, and Brake Wear)
Fugitive Road Dust 65.02 88.2% 0.00 0.0% 0.00 0.0% 0.00 0.0% 0.00 0.0%
Area Sources 5.60 7.6% 4.83 12.0% 0.38 3.0% 14.48 87.1% 33.97 65.1%
Residential Wood Combustion 5.06 6.9% 0.46 1.1% 0.07 0.6% 0.00 0.0% 2l.71 4l.6%
Other Fuel Combustion 0.52 0.7% 3.69 9.1% 0.31 2.5% 0.03 0.2% 0.19 0.4%
Open Burning 0.02 0.0% 0.00 0.0% 0.00 0.0% 0.00 0.0% 0.01 0.0%
Agricultural Acti vities 0.00 0.0% 0.00 0.0% 0.00 0.0% 0.00 0.0% 0.00 0.0%
Other Fugitive Dust 0.00 0.0% 0.00 0.0% 0.00 0.0% 0.00 0.0% 0.00 0.0%
Ammonia Sources 0.00 0.0% 0.00 0.0% 0.00 0.0% 14.45 86.9% 0.00 0.0%
Biogenic Emissions 0.00 0.0% 0.67 1.7% 0.00 0.0% 0.00 0.0% 2.87 5.5%
VOC Sources 0.00 0.0% 0.00 0.0% 0.00 0.0% 0.00 0.0% 9.19 17.6%
Non-Road Mobile Sources 0.51 0.7% 6.26 15.5% 1.24 9.9% 0.01 0.1% 4.39 8.4%
Aircraft 0.03 0.0% 0.42 1.0% 0.05 0.4% 0.00 0.0% 0.88 l.7%
Airport Ground Support Equipment 0.01 0.0% 0.27 0.7% 0.01 0.1% 0.00 0.0% 0.3 0.6%
Lawn and Garden Equipment 0.06 0.1% 0.21 0.5% 0.04 0.3% 0.00 0.0% l.54 3.0% , Recreational Equipment 0.01 0.0% 0.05 0.1% 0.01 0.1% 0.00 0.0% 0.32 0.6%
Commercial and Industrial 0.16 0.2% l.62 4.0% 0.44 3.5% 0.00 0.0% 0.74 ' 1.4%
Equipment
Construction and Mining Equipment 0.12 0.2% 1.11 2.7% 0.35 2.8% 0.00 0.0% 0.21 0.4%
Agricultural Equipment 0.05 0.1% 0.69 l.7% 0.17 1.3% 0.00 0.0% 0.12 0.2%
Recreational Marine Vessels 0.01 0.0% 0.02 0.0% 0.00 0.0% 0.00 0.0% 0.19 0.4%
Industrial Point Sources 2.19 3.0% 7.38 18.3% 10.01 80.3% 1.77 10.6% 1.94 3.7%
TOTAL 73.74 40.36 12.46 16.62 52.16
co
tons/day % of total 203.57 64.2% 203 .57 64.2% 0.00 0.0% 39.25 12.4% 36.88 1l.6% 2.32 0.7% 0.05 0.0% 0.00 0.0% 0.00 0.0% 0.00 0.0% 0.00 0.0% 0.00 0.0% 57.8 18.2% 16.48 5.2% 5.54 l.7% I 13.54 4..3%1 4.09 1.3% 15.59 4.9% 1.37 0.4% 0.54 0.2% 0.46 0.1% 16.7 5.3% 317.32TabJe 3 - Maximum Predicted 24-hour PM-10 Concentrations (llg/m3) In Northern Ada County Using January 5,1991
Wintertime Inversion Episode Weather
VOLUNTARY WOOD BURN BAN YEAR WITHOUT WITH 170 2010 122 188 2015 126 2020 193 130
Table 4 - Maximum Emissions Estimates (lbs/day) For The Amalgamated Sugar Company LLC, Nampa facility
POLLUTANTS SOURCE PM-10 NOx S02 VOC CO Boilers 140 606 1,074 3 42 Pulp Dryers 103 158 70 10 305 Pellet Coolers 12 -- -- -- -- Lime Kilns 2 12 30 -- 1,481 Sugar Processes 2 -- -- 2 -- Other 9 -- 4 10 -- Total 268 776 1, 17~ 25 1,828
Table 5 - Summary Of NAAQS Analysis For Current Operations At The Amalgamated Sugar Company LLC, Nampa Facility
Total Conc. Pollutant Averaging Period Modeled Conc. J,lg/m3 Background Conc. J,lg/m3 (Modeled plus Background) Ilg/m3 NAAQS J,lglm3 Percent of NAAQS PM-1O 24-Hour a 354 90 444 150 296 PM-I0 Annual 98 28.5 126 50 253 S02 2-Hour 1,743 374 2,117 1,300 163 S02 24-Hour 920 120 1,040 365 285 S02 Annual 125 18.3 144 80 180 NOx Annual 130 40 170 100 170 CO I-Hour 7,488 12,700 20,188 40,000 50 CO 8-Hour 3,488 5,726 9,214 10,000 92
a Modeling results based on current equipment configuration at TASCa, does not include
control measures outlined in the Emission Control Plan submitted to IDEQ by The Amalgamated Sugar Company LLC (TASCa).
Table 6 - Summary Of NAAQS Analysis For Future Operations For The Amalgamated Sugar Company LLC Nampa Facility
Pollutant Averaging Period Maximum Predicted (a) (J.1g/m3) Background (J.l.g/m3 ) Total (J.l.g/m3 ) " NAAQS (J.l.g/m3 ) PM-10 24-Hour 59.1 90 .149 150 Annual 19.8 28.5 48.3 50 SOz 3-Hour 253 374 627 1,300 24-Hour 113 120 233 365 Annual 15.9 18.3 34.2 80 CO I-Hour 9,262 12,700 21,962 40,000 8-Hour 2,816 7,100 9,916 10,000 NOz (b) Annual 26.6 40 66.6 100 Lead Calendar Quarter 0.59 0.15 0.74 1.5
(a) Predicted concentrations for annual periods are based on the maximum predicted concentration in five years. 24-Hour PM-10 design concentrations based on sixth highest concentration at the same receptor in 5 years. Design concentrations for all short-term averaging periods other than PM-IO, based on highest second high predicted concentration.
(b) All NO" is conservatively assumed to be converted to NOz.
Reference: Tier II Operating Permit Application for The Amalgamated Sugar Company LLC, Nampa Facility (July 30, 2002).
Figure 1 - Map Of The Boise Metropolitan Area
490 500 510 520 530 540 550 560 570 580
From: ENVIRON
From: IDEQ's Draft Final Report entitled "Northern Ada County PM-10 SIP Maintenance Plan & Redesignation Request" (July 30, 2002).
Figure 2 - Vicinity Of Tasco - Nampa Study Area
g
Ol C z ::2: I ::::> 526000 ~ 482800 482200 482000 481800 -- 1 ! . 528000 530000 532000 534000 536000 538000 540000 542000 544000 UTM Easting (m)Reference: Tier II Operating Permit Application (May 1,2002)
Figure 3 - Receptor Modeling Results for 1991
&
1999 Wintertime Days
In Boise, Idaho At Fire Station No.5
Source Contribution Estimates
1991 (163
f.1g/m3)
Road Dust (6% (9.9 Jlg/m3 ) Other Comb. Gas Vehicles (12% (19.1 Jlg/m3 ) (30% (48.5 Jlg/m3 )Res. Wood Comb.
Diesel Vehicles (28% (44.4 Jlg/m3 ) (24% (39.2 Jlg/m3 ) M E ~ : l ' - ' <0 ~ c... Primary vs. Secondary PM 200 150 100 50 0 1991 1m secondary • primary 1999
.
1999 (69.5
~g/m3)
Road Dust Other Comb. (45% (31.2 Jlg/m3) (6% (4.0 Jlg/m3 ) "' Gas Vehicles (10% (7.1 Jlg/m3 )Res. Wood Comb.
(29% (19.9 Jlg/m3
) Diesel Vehicles
From: Dr. John Cooper & Bruce E.
(10% (7.2 Jlg/m3
)
Figure 4 - Predicted 24h PM-10 Concentrations For Existing Operations The Amalgamated Sugar Company LLC, Nampa Facility
I
,.c. :; o en 1:. t ~ 4827~ ~' f :J 482700o-,i ~ , 4e26500-.! ", 482600~ , 4S2550~ .) 4825000, i . ~ ,.
'y . .~ . :-.. ' --~, -,---,--,-~~ 532'000 LL-.c--'~'-'--" '~---;-' ~-;- -'j -;- , - - .,-;-,""~~""'I '.'--;--~. , ---i'>-.,--~ 534000 53>' 500 535000 535'500 536000 536500 532500 UTM East-West (m) )Lines of equal concentration (i e, . 150 ~g/mA3
Receptor where concentration exceeds PM10 24-hour
The Amalgamated Sugar Company (TASCO)
24·Hour Average PM10 Concentrations For 8asecase For Met. Years 1987·91
6th Highest High At Each Receptor Legend:
'~ • YO ,
NAAQS of 150 ~g/mA3
Reference: Tier II Operating Permit Technical Analysis (September 30, 2002)
Figure 5 - ISCPRIME Predicted Maximum 24h PM-10 (Jlg/m 3) For Future
Operations
The Amalgamated Sugar Company LLC, Nampa Facility
4831ooO+-- - ' - -_______---'---L..----'---'---'---~-"---'---'----+
