Bane of Air Quality Modeling: Bridging The Communication Gap Between Mill Staff and Environmental Consultants in Developing Mill Emissions Data..., 1993 Environmental Conference Proceedings

Expansions and upgrades to existing mills have become the predominant mode of capital investment for the pulp and paper industry. Most of these projects require an air permit and an accompanying demonstration of compliance with applicable ambient air quality standards via dispersion modeling. The need to demonstrate compliance with ambient standards via modeling for such a mill upgrade or expansion project imposes a specialized burden on both mill staff and the permitting consultant. Often, it seems that mill engineering staff and air quality modelers speak different languages in attempting to assemble the data required for air quality modeling. This paper draws on considerable recent air permitting experience at James River mills to help bridge that communication gap by presenting a methodology and a “language” by which mill and environmental staff can avoid many of the problems that typically arise in these situations.

On the one hand, air quality modelers require specific model input data: on emissions expressed in terms of grams per second, on buoyancy flux in terms of volumetric flow rate and temperature, and on stack/building configurations in exacting three-dimensional detail. On the other hand, mill records typically consist of fuel consumption in gallons per month, steam production in pounds per hour, engineering design drawings, and an occasional stack test. With these extreme differences between the available data at the mill and the requirements of the modelers, problems often arise.

This paper uses as an example our experience with expansions/upgrades at several integrated pulp and paper mills to show how environmental consultants can express modeling data needs in terms that are understandable to mill staff and that recognize the usual limitations of mill records. A key communication tool in this example is a checklist that provides an overall picture of the process and a means to focus on the objective. Finally, the paper describes and explains a quality assurance program, an essential component of the data compilation and input process. All inputs to air quality models must be carefully checked for accuracy and representativeness to avoid needless repetition of the modeling exercise and to avoid making critical permitting decisions on modeling results that are based on non- representative source input data. This paper should go a long way towards avoiding problems in air permitting by helping bridge that critical communication gap between the mill staff and environmental consultant air quality modelers.