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Air Dispersion Modeling for the Idaho National Laboratory Permit to Construct P-2020.0045 Facility Emission Cap Revision Request

The U.S. Department of Energy Idaho Operations Office (DOE-ID) is seeking to modify permit to construct (PTC) P-2020.0045 issued to U S Dept. of Energy – Idaho National Laboratory (INL) on January 29, 2021 by the Idaho Department of Environmental Quality (DEQ). This PTC allowed the INL to become a synthetic minor source of air pollutants using a facility emission cap (FEC). Air dispersion modeling was performed as part of the permit revision application process to demonstrate that the modifications will comply with the National Ambient Air Quality Standards (NAAQS). This report documents the modeling methodology and complete results for the air dispersion impact analysis and is supplied as an appendix to the permit revision request, Idaho National Laboratory Permit to Construct P-2020.0045 (INL 2025). All criteria air pollutants (CAPs) regulated under Section 109 of the Clean Air Act were modeled with the exception of lead (Pb) and ozone which are not required to be modeled by DEQ. Consistent with the original permit application, modeling was not performed for toxic air pollutants (TAPs) as uncontrolled emissions did not exceed screening emission levels for carcinogenic and non-carcinogenic TAPs. Acceptable model design values (concentrations) for each CAP and averaging period were summed with average background concentrations and compared to NAAQS. The results demonstrate the impacts of requested FEC limits for CAPs are less than applicable standards and demonstrate emissions up to FEC limits will not cause a violation of ambient air quality standards.

54 ENVIRONMENTAL SCIENCES

Biochemical Conversion of Herbaceous Biomass to Renewable Diesel: Biorefinery Marginal Air Quality Impacts and Comparison to Feedstock Production

This study assesses the air quality impacts of an advanced biorefinery that produces renewable diesel blendstock (RDB) from lignocellulosic biomass via aerobic respiration (Davis et al. 2022) by estimating fine particulate matter (PM2.5) impacts from biorefinery emissions. It continues a prior analysis that used a geospatial assessment to identify source regions for biomass feedstocks and studied the impact of feedstock production emissions on air quality (Thind et al. 2022). Thind et al. (2022) identified RDB biorefineries that can use corn stover feedstocks of 2,000; 5,200; and 9,100 dry metric tons per day (DMT/day), based in Iowa, and suggested 7 unique counties can serve as hosts for a biorefinery that draws biomass feedstock from neighboring counties. Given 13 unique county-biorefinery size combinations and two waste lignin end uses at the biorefinery (lignin as a fuel for electricity generation and lignin for pellet production), the air-quality-related sustainability aspects of each of these 26 scenarios are assessed by estimating the annual average impacts of biorefinery emissions on the dispersion and formation of secondary PM2.5 in the atmosphere using a novel reduced-complexity air quality model called the Intervention Model for Air Pollution (InMAP). The 26 biorefinery design combinations help capture how a biorefinery's emissions of air pollutants and their resulting impact on local and regional air quality are influenced by the magnitude of production scale, lignin utilization strategy, and location of a proposed biorefinery. Methods developed in Thind et al. (2022) are applied to estimate the constraints on primary PM2.5 and secondary PM2.5 precursor emissions based on compliance with U.S. Environmental Protection Agency's (EPA's) annual primary National Ambient Air Quality Standard (NAAQS) of PM2.5 (i.e.12.0 micrograms per cubic meter (microgram/m3)) at downwind receptors of a biorefinery. Incremental PM2.5 concentrations caused by the emission of biorefining corn stover into RDB are assessed and compared to those of corn stover production. To illuminate which upstream supply chain stage of renewable diesel production contributes most to air quality impacts, marginal PM2.5 concentrations are compared between both stages at multiple downwind air quality monitor locations. In addition, through a hotspot analysis, we identify the primary contributing factors of emissions within the feedstock production and biorefinery stage operations. In doing so, we provide insights for improving the air pollutant emission-related sustainability of advanced lignocellulosic biofuel production.

09 BIOMASS FUELS