Environment

Environment
Submitted to:
Covanta Hennepin Energy Resource Company
Minneapolis, MN
Submitted by:
AECOM
Westford, MA
60144287
December 2010
Human Health Risk Assessment for the Capacity
Optimization Project
Hennepin Energy Resource Company
Minneapolis, Minnesota
Environment
Submitted to:
Covanta Hennepin Energy Resource Company
Minneapolis, MN
Submitted by:
AECOM
Westford, MA
60144287
December 2010
Human Health Risk Assessment for the Capacity
Optimization Project
Hennepin Energy Resource Company
Minneapolis, Minnesota
_________________________________
Prepared By Matthew Stresing
________________________________
Reviewed By David W. Heinold, CCM
AECOM Environment
i
Contents
1.0 Introduction ...................................................................................................................... 1-1 1.1 Project Overview ................................................................................................................. 1-1 1.2 Health Risk Assessment Process Overview ...................................................................... 1-1 1.3 Contents of the Health Risk Assessment ........................................................................... 1-2 2.0 Source Characterization ................................................................................................. 2-1 2.1 Facility Overview ................................................................................................................. 2-1 2.2 Emission Estimates ............................................................................................................. 2-1 3.0 Air Dispersion/Deposition Modeling ............................................................................. 3-1 3.1 Source Parameters ............................................................................................................. 3-1 3.2 Meteorological Data ............................................................................................................ 3-2 3.3 Receptor Data and Processing ........................................................................................... 3-2 3.4 Model Options ..................................................................................................................... 3-3 3.5 Application of AERMOD ...................................................................................................... 3-4 3.6 Modeling Results ................................................................................................................. 3-5 4.0 Health Risk Assessment Methods ................................................................................. 4-1 4.1 Hazard Identification ............................................................................................................ 4-1 4.2 Exposure Assessment ........................................................................................................ 4-1 4.2.1 Resident ................................................................................................................ 4-2 4.2.2 Acute Inhalation Receptor .................................................................................... 4-3 4.2.3 Farmer .................................................................................................................. 4-3 4.2.4 Fisher .................................................................................................................... 4-3 4.2.5 Quantification of Potential Exposure.................................................................... 4-4 4.3 Toxicity Assessment............................................................................................................ 4-4 4.3.1 Chronic Toxicity Values ........................................................................................ 4-5 4.3.2 Acute Toxicity Values ........................................................................................... 4-6 4.4 Risk Characterization .......................................................................................................... 4-6 4.4.1 Carcinogenic Risk Characterization..................................................................... 4-7 4.4.2 Non-carcinogenic Risk Characterization ............................................................. 4-7 4.4.3 Acute Risk Characterization ................................................................................. 4-8 5.0 Risk Characterization ...................................................................................................... 5-1 HERC Risk Assessment Report
December 2010
AECOM Environment
ii
List of Tables
Table 2-1 Existing and Proposed Permit Limits ................................................................................ 2-2 Table 2-2 Permitted/Proposed Permitted COPC Emission Rates(4) Supplemented with Estimated
Emissions for COPCs That Do Not Permit Limits(1,2,3,6) .................................................... 2-4 Table 2-3 Actual COPC Emission Rates ........................................................................................... 2-5 Table 3-1 Stack Parameters .............................................................................................................. 3-6 Table 3-2 Particle Size Distribution .................................................................................................... 3-6 Table 3-3 Seasonal Categories for Vapor Deposition....................................................................... 3-7 Table 3-4 Land Use Categories for Each 10° Sector ........................................................................ 3-7 Table 3-5 Physical Parameters used in the Vapor Deposition Modeling ......................................... 3-8 Table 3-6 Flagpole Receptors ............................................................................................................ 3-1 Table 4-1 Inhalation Toxicity Values .................................................................................................. 4-9 Table 4-2 Oral Toxicity Values ......................................................................................................... 4-10 Table 4-3 Acute Benchmarks ........................................................................................................... 4-11 Table 5-1 Summary of Long term Risk .............................................................................................. 5-2 Table 5-2 Summary of Acute Inhalation Risk based on Maximum Modeled 1-hour Concentration 5-3 Table 5-3 IEUBK Modeled Incremental Blood Lead Levels ............................................................. 5-3 Table 5-4 Cumulative Inhalation Risk ................................................................................................ 5-4 List of Figures
Figure 2-1 Facility Location ................................................................................................................. 2-3 Figure 3-1 50km Polar Receptor Grid ................................................................................................. 3-1 Figure 3-2 Location of Flagpole Receptors......................................................................................... 3-2 Figure 3-3 Watershed Receptors ........................................................................................................ 3-3 Figure 3-4 Buildings Included in Downwash Analysis (near-field view) Showing Building Height
(distances in meters).......................................................................................................... 3-4 Figure 3-5 Contours of Annual Average Air Concentrations .............................................................. 3-5 Figure 3-6 Contours Showing Average Annual Total Deposition ...................................................... 3-6 Figure 4-1 Map Showing Key Receptor Locations ........................................................................... 4-12 Figure 4-2 Water Bodies and Watersheds Considered in the HRA................................................. 4-13 Figure 5-1 Isopleth of Residential Lifetime Cancer Risk .................................................................... 5-5 Figure 5-2 Isopleth of residential Lifetime Hazard Index .................................................................... 5-6 Figure 5-3 Isopleth of Residential Acute Hazard Index ...................................................................... 5-7 HERC Risk Assessment Report
December 2010
AECOM Environment
iii
List of Appendices
Appendix A
Emissions Estimation Spreadsheets
Appendix B
GEP Analysis
HERC Risk Assessment Report
December 2010
AECOM Environment
1.0
Introduction
1.1
Project Overview
1-1
The Hennepin Energy Resource Center (HERC) facility is a mass-burn municipal waste combustor with
a design combustion capacity of 1,212 tons per day of municipal solid waste in two identical combustion
units. Steam produced from combustion is used to turn a 39-megawatt turbine/generator. The facility
sells approximately 35 megawatts of electricity (the power usage of approximately 26,000 single family
homes) to Xcel Energy. The HERC facility has operated continuously since startup in October 1989.
The facility was designed and built by Blount Projects and includes the following major equipment for
combustion and air emissions control: two excess-air grate-fired water wall furnaces, two dry scrubbers
for acid gas neutralization, a reverse-air fabric filter bag house to capture particulates, and an activated
carbon injection system for capture of gaseous mercury. The HERC facility is owned by Hennepin
County and operated by Covanta Hennepin Energy Resource Company, LP. (CHERC)
CHERC is proposing to remove the state-only annual permit limit on fuel usage of 365,000 tons per year
and allow the facility to process MSW at its design capacity of 442,380 tons per year. The purpose of
this risk assessment is to examine the incremental risk associated with this proposed change in annually
permitted fuel use.
1.2
Health Risk Assessment Process Overview
This Health Risk Assessment (HRA), which evaluates the potential for health risk from air emissions
associated with continued operation of the HERC under the proposed annual capacity, is part of the
Environmental Assessment Worksheet (EAW) that CHERC is submitting to the Minnesota Pollution
Control Agency in support of the proposed change in annual fuel limit. The procedures and data used
for this assessment are provided in the Protocol for the Human Health Risk Assessment for the Covanta
Hennepin Energy Resource Company Facility in Minneapolis, Minnesota, which was submitted to the
MPCA for review in April, 2010. MPCA protocol comments were received in June 2010 and have been
incorporated into the analysis. The HRA was conducted in general accordance with USEPA’s Human
Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities (USEPA, 2005,
http://www.epa.gov/osw/hazard/tsd/td/combust/risk.htm) supplemented MPCA’s Air Emissions Risk Analysis
guidance (http://www.pca.state.mn.us/air/aera.html) regarding application of the Risk Assessment Screening
Spreadsheet (RASS) used to identify chemicals, as well as fish ingestion rates and dioxin/furan doseresponse used in the HRA . Because details of the methodology are included in the protocol, this HRA
report will summarize the data used in the assessment and present and discuss HRA findings.
The HRA addresses non-criteria air pollutants plus NO2 emitted from the two CHERC combustor stacks.
The exposure scenarios include: a) residential exposure; b) farming exposure; and c) fish consumption
exposure. These exposure scenarios consider potential exposure of both adults and children through
direct and indirect pathways associated with these scenarios. The potential exposure pathways include
inhalation of compounds emitted from the stack (a direct exposure pathway) and incidental ingestion of
trace compounds that may enter the food chain through deposition from the air to soil, plants or water
bodies in the vicinity of the facility (indirect exposure pathways). A cumulative analysis of inhalation risk
was also conducted based on the facility’s contribution to ambient airborne concentrations plus
background concentrations measured by MPCA in Minneapolis.
HERC Risk Assessment Report
December 2010
AECOM Environment
1.3
1-2
Contents of the Health Risk Assessment
The HRA consists of the following sections and appendices:
Section 2 -
Source Description and Emissions
Section 3-
Air Dispersion/Deposition Modeling
Section 4 -
Health Risk Assessment Methods
Section 5-
Risk Assessment Findings
Appendix A
Emissions Estimation Spreadsheets
Appendix B
GEP Analysis
HERC Risk Assessment Report
December 2010
AECOM Environment
2.0
Source Characterization
2.1
Facility Overview
2-1
The HERC facility is a mass-burn municipal waste combustor with a design combustion capacity of
1,212 tons per day of municipal solid waste in two identical combustion units. Steam produced from
combustion is used to turn a 39-megawatt turbine/generator. The facility includes the following major
equipment for combustion and air emissions control: two excess-air grate-fired water wall furnaces, two
dry scrubbers for acid gas neutralization, a reverse-air fabric filter bag house to capture particulates,
select non-catalytic reduction of nitrogen oxides, and an activated carbon injection system for capture of
gaseous mercury.
The location of the HERC facility is shown in Figure 2-1.
2.2
Emission Estimates
As discussed in the protocol, 15 Compounds of Potential Concern (COPC) were identified for inclusion
in the HRA. At the request of MPCA, NO2 was added to the analysis. As noted in the EAW, given that
measured actual emission rates are well below currently permitted levels, CHERC has proposed to
change the the permitted limit of mercury. The short term limit will be 50 µg/dscm with an annual limit of
0.0314 tons per year. Table 2-1 lists the existing and proposed limits. These limits are reflected in the
permitted emissions provided in Table 2-2. As discussed in the protocol, for COPCs for which no permit
limits apply, estimates provided in stack testing for other facilities (some provided by MPCA and some
from stack tests at other Covanta facilities of similar design) were applied.
Potential emissions from the HERC facility were calculated on a short terms and annual basis. The
majority of the rates are best expressed as a unit of concentration per unit of flow multiplied by the
exhaust gas flow rate (e.g. µg/dscm x dscm) from the combustion units.
The exhaust flow rate is directly proportional to the steam flow rate. The original design steam flow rate
for the HERC is 171,380 pounds of steam per hour. The exhaust flow rate corresponding to that steam
flow rate was calculated using actual stack test data from 2008 and 2009. During those stack tests, both
exhaust flow rate and steam flow rate were measured. These stack tests were chosen because they
were conducted at a short term fuel use rate of greater than 50.5 tons per hour. Using the stack test
data, the design exhaust flow rate was calculated to be 63,735 dry standard cubic feet per minute
(dscfm) of exhaust at 7% oxygen content (dscfm @ 7% O2) per combustion unit. The design exhaust
flow rate was used to calculate the annual average hourly emission rates.
In accordance with the provisions of New Source Performance Standard Subpart Cb, the maximum
steam flow rate allowed at HERC is 195,000 pounds of steam per hour. Using the exhaust flow rate to
steam flow rate ratio the short term maximum allowable exhaust flow rate was calculated to be 72,519
dscfm @ 7% O2 per unit. The maximum allowable flow rate was used to calculate the short term hourly
emission rates. This method provides a high estimate of the maximum hourly emission rate as the
HERC facility has never produced 195,000 lb steam /hour.
For the pollutants that have a regulatory or permit limit, the maximum allowable emission concentration
was multiplied by the short term or long terms exhaust flow rate to calculate a pound per hour emission
HERC Risk Assessment Report
December 2010
AECOM Environment
2-2
rate. This pound per hour emission rate was then converted to a gram per second rate for use in the
risk assessment.
For the pollutants that did not have a regulatory or permit limit, performance test data from a similar
facility, or data provided by the MPCA were multiplied by the short term or long terms exhaust flow rate
to calculate a pound per hour emission rate. This pound per hour emission rate was then converted to a
gram per second rate for use in the risk assessment.
The above calculation methodology provides a conservatively high estimate of emissions, short term
and annual.
The results of the last three years of source testing for permitted COPCs were used to estimate actual
emissions (at full load) provided in Table 2-2.
The permit limits are for total dioxin/furan emissions rather than total 2,3,7,8-TCDD TEQ emissions
which are required for the HHRA. To estimate the permitted total TEQ emissions, the permitted
dioxin/furan emission rate was multiplied by the average ratio of total TEQ to total dioxin/furan (0.0102)
as determined from the 2007, 2008 and 2009 emission tests.
Details of the emission estimate calculations were provided electronically in Appendix A.
The emission rates provided in these tables were used to estimate health risks for three cases:
1) COPCs continuously emitted at their present and proposed permitted rates with estimated
emissions from source test data for COPCs without permit limits assuming an annual MSW thro,
2) COPCs continuously emitted at their proposed permitted rates with estimated emissions from
source test data for COPCs without permit limits,
3) CHERC continuously operated at the proposed permitted load with actual (measured) emission
rates of COPCs.
Table 2-1
Existing and Proposed Permit Limits
COPC
Permit Limit (@ 7% O2)
Cadmium
35 µg/dscm
Lead
400 µg/dscm
Short Term 50 µg/dscm
(1)
Mercury
(1)
Annual limit 0.0314 tons per year
Total Dioxin/Furan
30 ng/dscm
Hydrochloric Acid
29
ppm
Proposed reduced permit limits for mercury
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 2-1
2-3
Facility Location
HERC Risk Assessment Report
December 2010
AECOM Environment
2-4
Permitted/Proposed Permitted COPC Emission Rates(4) Supplemented with Estimated
Emissions for COPCs That Do Not Permit Limits(1,2,3,6)
Table 2-2
COPC
Acrolein (1,8)
(2,7)
Arsenic
(3,8)
Benzo (a) pyrene
(4,7)
Cadmium
(4,7)
Chromium
Dibenz (a,h) anthracene
Dioxins/Furans TEQ
H2SO4
(3,8)
(4,5,7)
(6,8)
(4,7)
Hydrochloric Acid
(4,7)
Lead
Manganese
(3,8)
(4,7)
Mercury
(2,7)
Nickel
Nitrobenzene
(1,8)
N-Nitroso-di-n-propylamine
Nitrogen Dioxide
(1,8)
Long Term
Emission Rate
(g/s)
Maximum Short Term
Emission Rate
(g/s)
2.89E-04
3.09E-04
2.78E-04
2.61E-04
3.91E-07
4.45E-07
2.11E-03
2.40E-03
5.71E-04
5.36E-04
3.91E-07
4.45E-07
1.83E-08
2.37E-08
2.35E-02
1.13E-01
2.60E+00
2.96E+00
2.41E-02
2.74E-02
1.91E-03
2.18E-03
9.03E-04
2.74E-02
4.99E-04
4.69E-04
1.28E-05
1.55E-05
1.09E-04
1.33E-04
2.32E+01
2.64E+01
(1)
For COPC with no limit, representative emission rate derived from 2004 Olmstead Waste to Energy test data
For COPC with no limit, derived from MPCA emission estimate
(3)
Representative emission rates derived from 2009 Covanta Stanislaus test data
(4)
Derived from Title V permit limit, with proposed 25 µg/dscm for mercury
(5)
Total Dioxin/Furan emission rate scaled by average TEQ from stack test data (2007-2009)
(6)
Representative emission rate derived from 2007-2009 Huntington Resource Recovery Facility test data
(2)
HERC Risk Assessment Report
December 2010
AECOM Environment
Table 2-3
2-5
Actual COPC Emission Rates
COPC
Acrolein (1)
(2)
Arsenic
(3)
Benzo (a) pyrene
(4)
Cadmium
(2)
Chromium
Dibenz (a,h) anthracene
Dioxins/Furans TEQ
H2SO4
(3)
(4,5)
(6)
(4)
Hydrochloric Acid
(4)
Lead
Manganese
(3)
(4)
Mercury
(2)
Nickel
Nitrobenzene
(1)
N-Nitroso-di-n-propylamine
(1)
Nitrogen Dioxide
Long Term
Emission Rate
(g/s)
Maximum Short Term
Emission Rate
(g/s)
2.38E-04
3.09E-04
2.61E-04
2.97E-04
3.91E-07
4.45E-07
2.38E-05
2.85E-05
5.36E-04
6.10E-04
3.91E-07
4.45E-07
9.59E-10
1.31E-09
2.35E-02
1.13E-01
1.64E+00
1.96E+00
9.89E-05
1.19E-04
1.91E-03
2.18E-03
1.09E-04
1.31E-04
4.69E-04
5.34E-04
1.28E-05
1.55E-05
1.09E-04
1.33E-04
1.55E+01
1.86E+01
(1)
Representative emission rate derived from 2004 Olmstead Waste to Energy test data
(2)
Derived from MPCA emission estimate
(3)
Representative emission rates derived from 2009 Covanta Stanislaus test data
(4)
Derived from average of 2007, 2008 and 2009 emission test reports
(5)
Total Dioxin/Furan emission rate scaled by average TEQ from stack test data (2007-2009)
(6)
Representative emission rate derived from 2007-2009 Huntington Resource Recovery Facility test data
HERC Risk Assessment Report
December 2010
AECOM Environment
3.0
3-1
Air Dispersion/Deposition Modeling
Air dispersion and deposition modeling were conducted to estimate air concentrations and deposition
rates to support the HHRA. Modeling was conducted with the AERMOD model (Version 09292) in
accordance with USEPA Guideline on Air Quality Models (GAQM; as incorporated in Appendix W of 40
CFR Part 51). Stack emissions were modeled using AERMOD with a unit emission rate and then scaled
by the appropriate emission rate (in g/sec) for each compound. In addition to requiring ground level air
concentrations, the multipathway HRA calculations require dry and wet deposition for both particle and
vapor components. AERMOD model output files containing concentration and deposition results were
generated for input to software developed by Lakes Environmental, “IRAP-h-view” (Version 3.3), which
incorporates USEPA’s health risk models and equations in the HHRAP.
3.1
Source Parameters
The stack parameters to be used in the air modeling conducted for the multipathway HRA are presented
in Table 3-1. In addition to the physical stack parameters and exhaust stack parameters, particle size
data on stack emissions are required to perform deposition modeling. Site-specific particle size data to
be used in this analysis is based on the results of compliance testing that was conducted at the Covanta
Hempstead Energy from Waste Facility in Hempstead, NY in September 1989. Emission-control
systems at the Hempstead facility are deemed to be sufficiently similar to CHERC so that the particle
size distribution for Hempstead should be applied in this assessment. These systems apply dry
scrubbing with bag house particulate controls. Two size distributions, one according to particle mass
and another according to particle surface area were utilized. Table 3-2 provides the mass-weighted
(particle) and surface area-weighted (particle-bound) size distributions that were developed from the
compliance testing data. This approach accounts for COPCS that are distributed by particle mass and
other COPCS that are more likely to be vaporized during combustion and, thereafter, condense on the
surface of particles in the exhaust stream.
The seasonal categories for each calendar month and the land use category must be defined for
modeling vapor deposition. The specification of the seasonal categories is provided in Table 3-3. A
single land use category is required to be specified for each of 36 10° sectors about the source.
Inspection of the region within 3 km of the Facility indicates the land-use to be predominantly urban and
suburban. The land use category for each sector is presented in Table 3-4.
AERMOD also requires pollutant-specific physical parameters for vapor deposition modeling, including
diffusivity in air (“Da”), diffusivity in water (“Dw”), cuticular resistance to uptake by lipids for leaves (“rcl”),
and Henry’s Law constant (H). The User’s Guide addendum (USEPA, 2006) suggests using an
Argonne National Laboratory (ANL) report (Wesley, et al, 2002) as a source for these data.
For vapor deposition, the HHRAP risk modeling approach, and subsequently the IRAP-h software, was
developed based on modeling results provided by ISCST, not AERMOD. Although the HHRAP
(finalized prior to promulgation of AERMOD) recognizes that AERMOD would be a potential preferred
model, the guidance is tailored for ISCST vapor deposition modeling results. Specifically, IRAP-h will
accept only 2 sets of vapor deposition model results: one set of normalized results (based on 1 g/sec)
representing all compounds with the exception of mercury, and one set of normalized results specifically
for mercury (This limitation was verified through a phone conversation with a technical advisor at LakesEnvironmental). AERMOD vapor deposition can be generated using unitized emission rates; however,
pollutant specific data (physical parameters discussed above) are required. Therefore, the mercury
HERC Risk Assessment Report
December 2010
AECOM Environment
3-2
specific vapor deposition results can be input to IRAP, but “generic” vapor deposition modeling results
representative of all other compounds is not facilitated by AERMOD. Table 3-5 presents the physical
parameters for Hg vapor model runs and the “generic” vapor model runs. The generic physical
parameters are based on Benzo(a)pyrene as requested by MPCA. This substance is deemed suitable
because it deposits more readily than most other organic compounds.
3.2
Meteorological Data
Because at least one year of onsite meteorological data is not available, five years of meteorological
data from the nearest representative National Weather Service station are used to conduct the
dispersion and deposition modeling. For this application, five years (2004-2008) of AERMOD-ready
data surface meteorological data from Minneapolis-St. Paul Airport and concurrent upper air data from
Chanhassen, MN was applied. The pre-processed meteorological data was provided by Ms. Melissa
Sheffer at MPCA. The AERMET (ver. 06341) files were incorporated yearly averaged moisture
conditions for the Bowen ratio and surface characteristics were determined by AERSURFACE (ver.
08009) using default settings.
3.3
Receptor Data and Processing
AERMOD requires specification of receptor locations, within a defined study area, at which the model
computes air concentrations and deposition rates.
The risk assessment study area and modeling domain included the area within 50 kilometers of the
HERC facility. This domain was sufficient to resolve the maximum modeled impacts and covered the
watersheds associated with the water bodies likely to receive the highest facility impacts.
The modeling analysis utilized a comprehensive Polar receptor grid as recommended in the MPCA
guidance (October 2004) with the following distances and spacing:
•
Discrete receptors every 10 m along fence line;
•
Polar grid with 36 directions and distances of 25m to 250m every 25m;
•
Polar grid with 36 directions and distances of 300m to 500m every 50m;
•
Polar grid with 36 directions and distances of 600m to 1000m every 100m;
•
Polar grid with 36 directions and distances of 1200m to 2000m every 200m;
•
Polar grid with 36 directions and distances of 1200m to 2000m every 200m;
•
Polar grid with 36 directions and distances of 2500m to 4500m every 500m;
•
Polar grid with 36 directions and distances of 5000m to 9000m every 1000m; and
•
Polar grid with 36 directions and distances of 10000m to 50000m every 10000m.
Figure 3-1 shows the 50km Polar Grid.
In addition, flagpole receptors were placed at each building listed in Table 3-6. These represent nearby
residencies within 1 mile of the HERC facility. According to MPCA modeling guidance, “FLAGPOLE
receptors should clearly focus on elevated areas likely to see plume “hits”. Short structures and lower
portions of tall structures may use ground-level receptors only – this is reasonable for building
downwash area (building cavity and near wake regions) with relatively uniform vertical concentrations.
HERC Risk Assessment Report
December 2010
AECOM Environment
3-3
This means using ground-level receptors instead of multi-level FLAGPOLE receptors if FLAGPOLE
receptors are less than key stack heights – a nominal breakpoint height of 20 m may be reasonable for
most FLAGPOLE receptors in most areas”. Although a four story building is less than 20 meters tall, to
ensure conservatism, residences of four or more stories were included as flagpole receptors.
Based on referenced examples in MPCA guidance, each identified building has a flagpole receptor at:
•
Ground level;
•
25% of the building height;
•
50% of the building height;
•
75% of the building height; and
•
Rooftop
For building with 4-6 stories, the 25%-75% of building height locations are less than 20 meters.
Therefore for these building receptors were placed at ground level and rooftop only. Figure 3-2 shows
the location of the flagpole receptors.
Receptor terrain elevations and receptor information required by AERMOD were developed through
application of the receptor/terrain processor AERMAP (Version 09040). AERMAP were applied with the
National Elevation Dataset (NED) from USGS 1 .
The results of the modeling analysis using the 10 kilometer Polar receptor grid were used to determine
the location of key receptors (e.g. the resident and fisher receptors). The selection process is discussed
futher in Section 4.2.
To estimate the average deposition across a watershed (required in various risk calculations),
AERMOD-predicted deposition rates at evenly spaced receptor locations is required. Therefore, a
subset of receptors with 500 meter spacing, as recommended in USEPA (2005), was developed from
the 50km grid. AERMOD results for this subset of receptors, extending over the watersheds of interest,
were used in the exposure assessment described in Section 4.2. Figure 3-3 shows the watershed
receptors.
3.4
Model Options
AERMOD was applied with the “TOXICS” option to facilitate computation of air concentrations
(“CONC”), particle deposition (“WDEP” and DDEP”, wet and dry components), and vapor (gaseous)
deposition (wet and dry components). In addition, options for plume depletion (“DRYDPLT” and
WETDPLT”), as recommended in the HHRAP were also used. Also, the “URBANOPT” option was
specified with a population of 382,618 and the default surface roughness of 1.0 meters.
The five years of pre-processed meteorological data was combined into a single meteorological data file
for input to AERMOD to compute five-year averages of air concentrations and deposition rates. As
such, AERMOD will be applied with the “ANNUAL” averaging time option. The use of this option
1
http://seamless.usgs.gov/
HERC Risk Assessment Report
December 2010
AECOM Environment
3-4
facilitates obtaining annual average deposition rates and air concentrations when using the multi-year
meteorological data files.
For particle deposition, “Method 1” specified in the User’s Guide Addendum was used. Method 1 is
recommended for particle size distributions where the mass of particles greater than or equal to 10 µm
exceeds 10 percent as is the case for the proposed distribution (see Table 3-2).
As discussed in Section 3.1, AERMOD requires pollutant-specific physical parameters including
diffusivity in air (“Da”), diffusivity in water (“Dw”), cuticular resistance (“rcl”) to uptake by lipids for leaves,
and Henry’s Law constant (H). The User’s Guide addendum provides an Argonne National Laboratory
(ANL) reference 2 as a source for these data. The physical parameters for Hg and Benzo(a)pyrene are
presented in Table 3-5.
AERMOD default values will be used for the reactivity factor, fraction of maximum green leaf area index
for seasonal categories 2 and 5 with the exception of the model run for mercury gas deposition. For
mercury, as recommended in the AERMOD User’s Guide Addendum, the reactivity factor will be set to 1
and a value of 1.0 will be used for seasonal categories 1, 3, and 4.
Aerodynamic downwash was simulated following EPA guidance, accounting for the influence of CHERC
buildings and structures and the nearby Target Field. A detailed description of the building downwash
considerations is provided in the risk assessment conducted for the Twins ballpark (Air Dispersion
Modeling and Risk Assessment for the Hennepin Energy Recovery Center, Hennepin County,
Minnesota (Revised) AECOM Document, No. 03433-001-600R, June 2007). Figure 3-4 shows the
buildings and structures in the near-field included in the analysis. Appendix B provides details of the
GEP analysis.
3.5
Application of AERMOD
AERMOD was applied to determine maximum short-term (1-hour average) air concentrations for
assessing acute health risk and long-term average (based on five years modeled) of air concentrations
and wet, dry, and total deposition for vapors, particles, and particle-bound chemicals. As such multiple
iterations were conducted with AERMOD to obtain the modeled air concentrations and deposition rates
required for input to the IRAP-h software:
2
1)
wet and dry deposition of particles, based on mass-weighted particle distribution including
plume depletion;
2)
wet and dry deposition of particles, based on surface area-weighted particle size distribution
including plume depletion; and
3)
wet and dry deposition of vaporous gases with plume depletion.
Wesely, M.L, P.V. Doskey, and J.D. Shannon, 2002: Deposition Parameterizations for the Industrial Source
Complex (ISC3) Model. Draft ANL report ANL/ER/TR–01/003, DOE/xx-nnnn, Argonne National Laboratory,
Argonne, Illinois 60439.
HERC Risk Assessment Report
December 2010
AECOM Environment
3-5
Tthe agency’s position on plume depletion expressed during the protocol review is noted. The
suggestion that plume depletion should not be applied is based on EPA’s Guideline on Air Quality
Models (Appendix W to 40 CFR Part 51), which is applicable to criteria pollutant modeling. However,
the Guideline does not address air toxics or health risk assessment. For mult-pathway human health
risk assessment EPA’s guidance on plume depletion is contained in the HHRAP (Section 3.6.1, page
41), which specifies that both wet and dry depletion should be simulated. This is specified because not
including depletion violates the concept of mass balance in tracing the fate and transport of emissions.
It is also noted that MPCA has applied plume depletion in previous health risk assessments conducted
by MPCA, such as for the Olmstead County wate-to-energy facility.
3.6
Modeling Results
The modeling results are presented as isopleths of unitized air concentrations and total deposition rates
in Figures 3-5 and 3-6 respectively. The figures identify the receptor location corresponding to the
maximum modeled concentration or deposition rate depending on the figure The key receptor locations
evaluated in the health risk calculations are based on these results and are discussed in Section 4.2 Exposure Assessment.
All model input and output files were provided to the MPCA on CDROM.
HERC Risk Assessment Report
December 2010
AECOM Environment
Table 3-1
3-6
Stack Parameters
Source
Stack Height
(m)
Exit Temperature
(K)
Short Term
Exit Velocity
(m/s)
Annual Exit
Velocity
(m/s)
Stack Diameter
(m)
Unit 1
65.84
399.82
28.01
24.62
1.92
Unit 2
65.84
399.82
28.01
24.62
1.92
Table 3-2
Particle Size Distribution
Mean Particle Diameter
(µm)(1)
Mass Fraction(1)
Surface Area Fraction(2)
0.11
0.237
0.878
0.61
0.0661
0.0442
1.00
0.0577
0.0235
1.70
0.0717
0.0172
2.93
0.0785
0.0109
4.53
0.114
0.0102
6.68
0.174
0.0106
10.23
0.0877
0.00349
25.16
0.114
0.00184
(1) Compliance test at the Covanta Hempstead EfW Facility (Radian, 1989)
(2) Calculated based on assumed spherical particle diameter and mass fraction
HERC Risk Assessment Report
December 2010
AECOM Environment
Table 3-3
3-7
Seasonal Categories for Vapor Deposition
Month
AERMOD Seasonal
Category
January
4
February
4
March
5
April
5
May
5
June
1
July
1
August
1
September
1
October
3
November
3
December
3
Seasonal Categories
1. Midsummer with lush vegetation
2. Autumn with unharvested cropland
3. Late autumn after frost and harvest
or winter with no snow
4. Winter with snow on ground
5. Transitional spring with partial green
coverage or short annuals
Table 3-4
Land Use Categories for Each 10° Sector
Sector
Land Use Category
1-2
1
3-10
5
11-14
1
15-36
5
Land Use Categories
1. Urban land, no vegetation
2. Agricultural land
3. Rangeland
4. Forest
HERC Risk Assessment Report
5.
6.
7.
8.
9.
Suburban areas, grassy
Suburban areas, forested
Bodies of water
Barren land, mostly desert
Non-forested wetlands
December 2010
AECOM Environment
Table 3-5
3-8
Physical Parameters used in the Vapor Deposition Modeling
Pollutant
Diffusivity in
Air
(cm2/s)
Diffusivity in
Water
(cm2/s)
Cuticular
Resistance
(s/cm)
Henry’s Law
Constant
(Pa-m3/mol)
Benzo(a)pyrene
5.13E-02
4.44E-06
4.41E-01
4.60E-02
Hg
6.0E-02
5.25E-06
1.0E+05
6.0E-06
HERC Risk Assessment Report
December 2010
AECOM Environment
Table 3-6
Flagpole Receptors
ID
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
3-1
Building Name
The Carlyle
Marquette Place
The Churchill
One Ten Grant
Symphony Place Apartments
Hotel Ivy + Residence
Hennepin Crossing Apartments
Centre Village
Loring Green East
River Towers B
Wilson Park Tower
Booth Manor Apartments
Nicollet Towers West
The Crossings
River Towers A2
The Tower of 1200 on the Mall
The Metro Apartments
Loring Green West
Riverwest
Rivergate Apartments
LaSalle Apartments
International Market Square
River Towers A1
Atrium Apartments
Art Love Manor
Parkview Apartments
Six Quebec
Loring Towers
730 Lofts
1200 on the Mall
HERC Risk Assessment Report
Address
100-198 3rd Avenue South
1314-1318 Marquette
Avenue
109-111 Marquette Avenue
110 West Grant Street
1113-1125 Marquette
Avenue
201 11th Street South
1100-1160 Hennepin
Avenue
413-433 7th Street South
1201 Yale Place
19-63 1st Street South
1400 Laurel Avenue
1421 Yale Place
1350-1380 Nicollet Avenue
250 2nd Avenue South
17 1st St S
1225 LaSalle Avenue
82-90 9th Street South
75 13th Street South
401 1st Street South
115 2nd Avenue South
32-38 9th Street South
275 Market Street
15 1st Street South
300-324 Hennepin Avenue
800 5th Avenue North
1201 12th Avenue North
601-617 Marquette Avenue
15 East Grant Street
730 4th Street North
1200 Nicollet Mall
41
Height
(m)
142.85
UTM X
(m)
479264.58
UTM Y
(m)
4980750.97
36
33
32
131.67
120.70
117.04
478188.34
479102.46
477887.81
4979448.05
4980840.81
4979517.85
26
25
95.10
91.92
478366.24
478501.44
4979632.96
4979597.52
25
26
23
27
21
21
20
19
22
23
17
17
20
16
13
11
16
16
12
12
9
10
10
9
91.44
84.43
84.12
82.07
76.81
76.81
73.15
69.49
66.87
62.79
62.18
62.18
59.89
58.52
55.84
55.17
53.25
46.09
43.89
43.89
37.06
36.52
34.14
32.92
477911.19
479012.05
478005.65
479045.49
477697.59
477738.66
478022.78
479015.72
479042.78
478060.35
478504.41
477912.70
479443.52
479198.59
478270.49
477219.97
478976.56
478628.96
477155.93
476565.43
478709.51
478152.21
477923.72
478134.94
4980032.55
4979840.77
4979709.29
4980899.54
4979921.53
4979577.02
4979394.30
4980573.48
4980892.33
4979633.23
4979963.43
4979622.74
4980640.75
4980751.96
4980092.41
4980627.18
4980892.21
4980660.30
4980931.34
4981754.97
4980202.69
4979398.85
4981328.67
4979675.52
Stories
December 2010
AECOM Environment
ID
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
3-2
Building Name
Rock Island Lofts
Heritage Landing
Loring Way
Bookmen Stacks
720 Lofts
5th Avenue Lofts
Lindsay Lofts
Harvester Lofts
401 Apartments
Eitel Building City Apartments,
North Building
The Itasca
Exodus Residence
212 Lofts
Salvation Army Harbor Light Center
SOHO Minneapolis
Tower Lofts
Lamoreaux Building
Ogden Apartments
Stage Apartments
Riverwalk
Security Lofts
Gaar Scott Historic Lofts
Bassett Creek Lofts
Bookmen Lofts (eastern portion)
Bookmen Lofts (western portion)
Park Plaza Apartments I
Park Plaza Apartments II
HERC Risk Assessment Report
101-111 4th Avenue North
401-415 1st Street North
210 West Grant Street
345 6th Avenue North
720 4th Street North
401-429 2nd Street North
408 1st Street North
612-618 Washington
Avenue North
401-413 1st Avenue North
8
8
8
9
8
7
7
Height
(m)
29.26
29.26
29.26
29.03
28.65
26.82
25.60
7
6
25.60
25.60
478225.02
478598.74
4981395.84
4981336.70
1360 Spruce Place
710-722 1st Street North
819 2nd Avenue South
212 1st Street North
1010-1028 Currie Avenue
714-720 Washington
Avenue North
622-710 Washington
Avenue North
700-708 1st Avenue North
66-68 12th Street South
814-818 Hennepin Avenue
400-406 1st Street North
404-406 Washington
Avenue North
610-614 1st Street North
901 3rd Street North
517-519 3rd Street North
523-529 3rd Street North
525-527 Humboldt Avenue
North
505-507 Humboldt Avenue
North
6
6
8
6
6
25.60
24.38
23.47
21.95
21.95
477812.94
478315.55
478667.85
478764.03
477962.11
4979394.58
4981658.59
4979885.78
4981208.62
4980321.64
6
21.95
478138.60
4981483.90
6
6
6
6
6
21.95
21.95
21.95
21.95
21.95
478186.22
478188.18
478122.08
478183.77
478616.98
4981437.75
4980394.96
4979742.22
4980211.57
4981367.97
6
6
6
6
6
21.95
21.95
21.95
21.95
21.95
478432.01
478412.12
477815.67
478175.99
478158.73
4981199.18
4981565.95
4981522.45
4981166.73
4981190.00
6
21.95
476428.20
4980968.98
6
21.95
476430.43
4980889.32
Address
Stories
December 2010
UTM X
(m)
478606.51
478565.21
477783.65
478113.77
477986.48
478453.32
478580.69
UTM Y
(m)
4981279.58
4981330.71
4979497.99
4981138.28
4981263.13
4981252.66
4981408.64
AECOM Environment
ID
58
59
60
61
62
63
64
65
66
67
3-3
Building Name
Park Plaza Apartments III
Herschel Lofts
111 Washington Avenue North
Evergreen Residence
Lyndale Manor
918 Lofts
710 Lofts
Whitney Square Lofts
River Station
Heritage Commons at Pond's Edge
HERC Risk Assessment Report
Address
1315 Olson Memorial
Highway
748 3rd Street North
109-111 Washington
Avenue North
177 Glenwood Avenue
600 18th Avenue North
918 3rd St N
710 4th St N
210 2nd Ave N
645 1st St N
350 Van White Memorial
Boulevard
Stories
Height
(m)
UTM X
(m)
UTM Y
(m)
6
6
21.95
21.34
476580.49
478003.16
4981024.96
4981435.82
5
5
5
5
5
5
4
18.29
18.29
18.29
18.29
18.29
18.29
14.63
478641.12
477431.16
477455.79
477860.66
478014.80
478684.17
478348.85
4980878.22
4980417.36
4982482.06
4981560.39
4981246.37
4981092.36
4981435.86
4
14.63
476786.69
4980706.83
December 2010
AECOM Environment
Figure 3-1
3-1
50km Polar Receptor Grid
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 3-2
3-2
Location of Flagpole Receptors
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 3-3
3-3
Watershed Receptors
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 3-4
3-4
Buildings Included in Downwash Analysis (near-field view) Showing Building Height
(distances in meters)
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 3-5
3-5
Contours of Annual Average Air Concentrations
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 3-6
3-6
Contours Showing Average Annual Total Deposition
HERC Risk Assessment Report
December 2010
AECOM Environment
4.0
Health Risk Assessment Methods
4.1
Hazard Identification
4-1
The hazard identification identified COPCs for quantitative evaluation in the HRA. COPCs were
selected based on (1) compounds listed in the MPCA Title V Air Emission Permit #05300400002(www.pca.state.mn.us/air/permits/issued/05300400-002-aqpermit.pdf), (2) additional compounds
listed by MPCA in a table entitled “Preliminary Emission Estimates for Calendar Year 2005” (MPCA,
2005) and (3) additional HAPs listed in a spreadsheet provided by MPCA (PopeDouglasEmissions.xls).
Nitrogen dioxide was added per MPCA protocol comments. MPCAs Risk Assessment Screening
Spreadsheet (RASS) was applied to remove COPCs that pose virtually no risk potential.
The list of 16 COPCs include:
4.2
•
Hydrochloric acid
•
Lead
•
Cadmium
•
Mercury
•
Polychlorinated dibenzo-p-dioxins/polychlorinated dibenzo-p-furans (dioxins)
•
Arsenic
•
Chromium
•
Nickel
•
Acrolein
•
Benzo(a)pyrene
•
Dibenz(a,h)anthrecene
•
Manganese
•
Nitrobenzene
•
N-Nitroso-di-n-proplymine
•
Sulfuric acid
•
Nitrogen Dioxide
Exposure Assessment
The goal of the exposure assessment is to predict the magnitude of possible human exposure to
airborne emissions from the facility through potential exposure pathways. Exposure and risk calculations
were conducted using the IRAP software which implements EPA’s Human Health Risk Assessment
Protocol (HHRAP) guidance. IRAP computes Excess Lifetime Cancer Risk (ELCR) and noncarcinogenic Hazard Index (HI) for each of the exposure/receptor scenarios evaluated based on the
emissions and AERMOD-modeled impacts of the facility.
HERC Risk Assessment Report
December 2010
AECOM Environment
4-2
The HHRAP analysis is a comprehensive assessment that addresses a wide variety of exposure routes
that are pertinent to Hennepin County. Using AERMOD, the analysis applies representative
meteorological data to evaluate concentrations of COPCs in the ambient air, at elevated locations such
as high rise apartments and roof top gardens (e.g. flag pole receptors) and the deposition to the ground
surface. Conservative methods are then applied to estimate the concentration in the soil, surface water
and eventually fish, home-grown vegetables as farm-raised animals, cow’s milk and eggs that people
consume.
For the fish ingestion pathway the non-cancer risk is mostly associated with mercury. At the direction of
MPCA, the risk associated with mercury through this pathway was independently evaluated using the
Mercury Risk Estimation Method (MMREM) spreadsheet developed by MPCA. The MMREM hazard
index for mercury was then added to the HHRAP hazard index (excluding the fish pathway for mercury)
to estimate the combined non-cancer hazard index for all COPCs and exposure routes. MMREM
requires that the concentration of mercury in fish tissue be specified. The latest available fish tissue
database was provided by MPCA and based on data from Lake Calhoun, Crystal Lake, Lake of the
Isles, and Wirth Lake. A value of 0.33 ppm was applied. The MMREM spreadsheets are provided in the
appendicies.
The HRA evaluated four categories of receptors: 1) a resident who lives in a low-rise or high-rise
building and eats local produce from his backyard garden and eats eggs from chickens husbanded at
his residence; 2) a farmer who lives at the nearest agricultural area and lives off his produce and
livestock; 3) a subsidence fisher who lives at a low-rise residential location and for dietary protein relies
on fish caught from local water bodies and 4) a recreational fisher who eats occasionally eats locally
caught fish (about one fifth of the subsidence fisher.) In addition, an acute receptor location was
evaluated for the inhalation pathway alone.
Locations of receptors described below are provided in Figure 4-1.
4.2.1
Resident
The Resident receptor represents a hypothetical local resident (adult and child) living in a low-rise or
high-rise dwelling whose long-term exposure to facility emissions is through the following potential
pathways:
•
Direct inhalation of vapors and particles
•
Incidental ingestion of soil
•
Ingestion of homegrown produce (from a backyard garden)
•
Ingestion of dioxins in breast milk by a nursing infant (assuming that the mother is the resident)
•
Ingestion of homegrown eggs
The only default exposure pathway that was not evaluated for the Resident (as well as for all other
receptors) is the ingestion of drinking water from surface water sources. The residents of Minneapolis
receive water treated at the Ultrfiltration Plant at Columbia Heights located about 5 miles upstream of
Minneapolis about 5 miles north of the city. According to the City of Minneapolis website
(http://www.ci.minneapolis.mn.us/water/plant_home.asp), the facility processes up to 70 million gallons
of Mississippi River water per day. Large rivers such as the Mississippi typically do not efficiencly
concentrate deposited pollutants because of their high flow relative to their local watershed. That is,
nearly all of the water flowing down the river at the water treatment plant originates from far upstream.
HERC Risk Assessment Report
December 2010
AECOM Environment
4-3
Since these northern reaches of Mississippi watershed are distant from the modeled impact area of the
facility it would not be possible for the facility to materially contribute to concentrations. As importantly
the drinking water supply is highly treated such that impurities, whether natural or manmade, are
effectively removed.
Resident receptor locations were selected based on the dispersion and deposition modeling results and
aerial photographs. The locations of the high-rise resident locations were chosen based on visual
inspection of aerial photographs and research done at Emporis.com.
4.2.2
Acute Inhalation Receptor
The acute inhalation receptor represents a hypothetical local resident (adult and child) whose short-term
(1-hour) exposure to facility emissions is through the direct inhalation pathway only. The Acute
Inhalation receptor location was selected based dispersion modeling results where the location of the
maximum 1-hour air concentration was used for the Acute Inhalation locations. These included both
ground-level and flagpole receptors.
4.2.3
Farmer
The Farmer receptor is assumed to grow and consume crops, and raise and consume beef cattle, dairy
cattle, pork, and poultry at a farm location. The Farmer is assumed to live and consume crops and
produce from the farm and whose long-term exposure to facility emissions is through the following
potential pathways:
•
Direct inhalation of vapors and particles
•
Incidental ingestion of soil
•
Ingestion of produce from the farm
•
Ingestion of dioxins in breast milk by a nursing infant (assuming that the mother is the farmer)
•
Ingestion of homegrown beef
•
Ingestion of milk from homegrown cows
•
Ingestion of homegrown chicken and eggs
•
Ingestion of homegrown pork
The Farmer receptor location was selected to be the closest location (about 15 km northwest of the
facility) where land-use data and aerial photographs indicated that farmland was present.
4.2.4
Fisher
For the fish ingestion pathway the non-cancer risk is mostly associated with mercury. At the direction of
MPCA, the risk associated with mercury through this pathway was independently evaluated using the
Mercury Risk Estimation Method (MMREM) spreadsheet developed by MPCA. The MMREM hazard
index for mercury was then added to the HHRAP hazard index (excluding the fish pathway for mercury)
to estimate the combined non-cancer hazard index for all COPCs and exposure routes.
Three categories of people living near the facility were evaluated; 1) a resident who lives in a low-rise or
high-rise building and eats local produce from his backyard garden and eats eggs from chickens
husbanded at his residence; 2) a farmer who lives at the nearest agricultural area and lives off his
HERC Risk Assessment Report
December 2010
AECOM Environment
4-4
produce and livestock; 3) a subsidence fisher who lives at a low-rise residential location and for dietary
protein relies on fish caught from local water bodies and 4) a recreational fisher who eats occasionally
eats locally caught fish (about one fifth of the subsidence fisher.)
The Fisher receptor is assumed to fish in a local water body. The Fisher represents a hypothetical local
fisher (adult and child) whose long-term exposure to facility emissions is through the following potential
pathways:
•
Direct inhalation of vapors and particles
•
Incidental ingestion of soil
•
Ingestion of homegrown produce (from a backyard garden)
•
Ingestion of dioxins in breast milk by a nursing infant (assuming that the mother is the fisher)
•
Ingestion of fish
Two ingestion rate scenarios were considered for the adult and child Fisher in the risk assessment:
1. Subsistence fisher ingestion rate of 142 g/day for an adult; 21.5 g/day for a child
2. Recreational fisher ingestion rate of 30 g/day for an adult; 4.5 g/day for a child
There are a large number of lakes in the vicinity that could be identified for a risk assessment. The
resources required to collect data and evaluate risks required that thew study be limited to four nearby
lakes that are 1) likely to experience the highest degree of deposition from the the Facility, 2) be
commonly fished, 3) which span a wide range of directions. There are essentially no notable nearby
lakes in the north to southeast sector form the Facility, and as noted above the Mississippi is not a
sutable water body because of the very high low rate and vast watershed would dilute rather than
concentrate nearby deposited pollutants. In the southern sector the closest lake is Lake Calhoun, Lake
of the Isles to the south-southwest, Lake Wirth to the west, and Crystal Lake to the northwest. Thus, due
to their size and nearby locations relative to the Facility, these four lakes, Lake Calhoun, Lake of the
Isles, Crystal Lake, and Wirth Lake, were evaluated for both a recreational and subsidence fisher. The
recreational fisher was assumed to fish only at his or her favorite lake, whereas, in accordance to MPCA
guidance a subsidence fisher would catch fish from all four lakes.
Both types of fisher were assumed to live at the same location as the low-rise Resident and be exposed
through the other Resident exposure pathways.
4.2.5
Quantification of Potential Exposure
COPC concentrations in soil, water and vegetation were estimated in this cumulative health risk
assessment based on the results of the dispersion and deposition modeling. The modeled deposition
rates to soil and water were utilized, along with site-specific and COPC-specific information, in fate and
transport modeling to estimate concentrations of COPC in other media (such as locally raised
agricultural products and fish) to which humans may be exposed in the vicinity of the facility. The fate
and transport modeling approach utilized in this cumulative health risk assessment was consistent with
the algorithms and assumptions defined in HHRAP.
4.3
Toxicity Assessment
The toxicity assessment identifies the relationship between the dose of that compound and the likelihood
and magnitude of a health effect (response). Chronic health effects are characterized by USEPA as
potentially carcinogenic or non-carcinogenic. Combining the results of the toxicity assessment with
HERC Risk Assessment Report
December 2010
AECOM Environment
4-5
information on the magnitude of potential human exposure provides an estimate, usually conservative,
of potential health risk. In addition, acute inhalation of maximum short-term (1-hour) air concentrations
was evaluated.
For lead, per MPCA guidance, a supplemental analysis was conducted to evaluate the maximum
contribution of inhaled lead and lead deposited onto soil to blood lead level in children associated with
long-term CHERC emissions using the USEPA Integrated Exposure Uptake Biokinetic Model (IEUBK).
A blood lead level exceeding 10 µg/dL is deemed to be significant.
4.3.1
Chronic Toxicity Values
Both potentially carcinogenic and non-carcinogenic health effects were evaluated in the HHRA.
Published toxicity values used in this HHRA were selected in accordance with recommendations from
the MPCA and Minnesota Department of Health (MDH), and generally followed the following hierarchy:
•
Minnesota Department of Health (MDH),
•
USEPA's Integrated Risk Information System (IRIS), and
•
California EPA.
4.3.1.1 Inhalation Toxicity Values
The toxicity values used to evaluate potential carcinogenic health effects resulting from long-term
inhalation exposure to COPC are called unit risk factors, and are expressed in units of the inverse of
micrograms of the compound per cubic meter of air (μg/m3)-1. Unit risk refers to the upper bound excess
cancer risk from a continuous lifetime exposure to a compound at one microgram per cubic meter (1
μg/m3) in air. The typical toxicity value used to evaluate potential noncarcinogenic health effects
resulting from long-term inhalation exposure to COPC is called a reference concentration (RfC) and is
expressed in units of μg/m3. The RfC is defined as an estimate, with uncertainty spanning perhaps an
order of magnitude, of a continuous inhalation exposure to the human population, including sensitive
subgroups, which are likely to be without an appreciable risk or deleterious effects during a lifetime. It
can be derived from a no observed adverse effects level (NOAEL), lowest observed adverse effects
level (LOAEL), or benchmark concentration, with uncertainty factors generally applied to reflect
limitations on the scientific data available. MDH has also developed chronic health risk values (HRV);
the HRV is defined as the concentration of a compound or defined mixture of compounds in ambient air,
at or below which the compound is unlikely to cause an adverse health effect to the general public when
exposure occurs daily throughout a person's lifetime
(http://www.health.state.mn.us/divs/eh/air/rules.htm).
Table 4-1 lists inhalation toxicity values for chronic cancer and noncancer effects for the COPC that
were evaluated for the inhalation pathway. For dioxins, MPCA uses an inhalation unit risk factor of 400
(μg/m3)-1 for 2,3,7,8-TCDD toxic equivalents based on extrapolation from the oral slope factor, and
assuming an inhalation rate of 20 m3/day and body weight of 70 kg
(http://www.health.state.mn.us/divs/eh/risk/guidance/dioxinmemo2.html).
4.3.1.2 Oral Toxicity Values
The toxicity values used to evaluate potential carcinogenic health effects resulting from long-term oral
exposure to COPC are called Cancer Slope Factors (CSFs). A CSF is generally defined as an upper
bound, approximating a 95 percent confidence limit, on the increased cancer risk from a lifetime
exposure to a compound or defined mixture of compounds. This estimate, usually expressed in units of
HERC Risk Assessment Report
December 2010
AECOM Environment
4-6
proportion (of a population) affected per mg/kg/day, is generally reserved for use in the low-dose region
of the dose-response relationship, that is, for exposures corresponding to risks less than one in 100.
This number is derived from a mathematical extrapolation model that uses toxicological data specific to
each carcinogen.
The CSF for the ingestion route is expressed in units of the inverse of milligrams of the compound or
defined mixture of compounds per kilogram of body weight per day (mg/kg-day)-1
(http://www.health.state.mn.us/divs/eh/air/rules.htm).
The typical toxicity value used to evaluate potential noncarcinogenic health effects resulting from longterm oral exposure to COPC is called a reference dose (RfD). The RfD is defined as an estimate, with
uncertainty spanning perhaps an order of magnitude, of a daily oral exposure to the human population,
including sensitive subgroups, which is likely to be without an appreciable risk of deleterious effects
during a lifetime. It can be derived from a no observed adverse effects level (NOAEL), lowest observed
adverse effects level (LOAEL), or benchmark dose, with uncertainty factors generally applied to reflect
limitations of the scientific data available. The RfD is expressed in units of milligrams of the compound or
defined mixture of compounds per kilogram of body weight per day (mg/kg-day). MDH has also
developed multimedia health risk values (MHRV), which are defined as the total daily dose of a
compound or defined mixture of compounds that results from an emission to ambient air, at or below
which is unlikely to cause an adverse health effect to the general public over a lifetime exposure. Total
daily dose is the sum of the exposure doses calculated from applicable inhalation or non-inhalation
exposure pathways. The MHRV is expressed in units of mg/kg-day
(http://www.health.state.mn.us/divs/eh/air/rules.htm). It is noted that the oral CSF for 2,3,7,8-TCDD
developed by MDH of 1.4x106/mg/kg-day is 10-fold higher (i.e., 10-fold more conservative) than
USEPA’s CSF of 1.5x105/mg/kg-day. If the USEPA CSF were used, then the cancer risk estimate
would be 10-fold lower.
Table 4-2 lists oral toxicity values for chronic cancer and noncancer effects for the COPC that were
evaluated for the oral pathway.
4.3.2
Acute Toxicity Values
Potential risks due to short-term inhalation exposure (such as respiratory or irritant health effects), in
addition to the more commonly evaluated chronic risks to human health discussed above, were
evaluated in the HHRA. Acute benchmarks used in the HHRA are acute health risk values (acute
HRVs) developed by MDH and acute Reference Exposure Levels (RELs) developed by CalEPA (2000).
The acute HRV is defined as the concentration of a compound, at or below which the compound is
unlikely to cause an adverse health effect to the general public when exposure occurs over a prescribed
time. Acute HRVs are compared to one-hour averaged concentrations of compounds in air
(http://www.health.state.mn.us/divs/eh/air/rules.htm). The acute REL values are also generally
compared against a 1-hour concentration in air.
Table 4-3 lists the acute benchmarks for the COPCs
4.4
Risk Characterization
The Risk Characterization combines the results of the Exposure Assessment with the results of the
Toxicity Assessment to derive an estimate of potential risk to human health. In this HHRA, the potential
for occurrence of carcinogenic and non-carcinogenic health effects was evaluated for various receptors
under the exposure scenarios identified. In addition, acute inhalation risks were also evaluated.
HERC Risk Assessment Report
December 2010
AECOM Environment
4.4.1
4-7
Carcinogenic Risk Characterization
The purpose of carcinogenic risk characterization is to estimate the upper-bound likelihood, over and
above the background cancer rate, that a receptor will develop cancer in his or her lifetime as a result of
exposure to a compound in environmental media at the site. This likelihood is a function of the dose of a
compound (described in the Exposure Assessment) and the Cancer Slope Factor (CSF) (described in
the Toxicity Assessment) for that compound. The Excess Lifetime Cancer Risk (ELCR) is the likelihood
over and above the background cancer rate that an individual will contract cancer in his or her lifetime.
The risk value is expressed as a probability (e.g., 10-6, or one in one million). For oral cancer risk
estimates, a Lifetime Average Daily Dose (LADD) is calculated that averages a receptor’s exposure
dose over a lifetime. The relationship between the ELCR and the estimated LADD of a compound may
be expressed as:
ELCR = 1-e-(CSF x LADD)
When the product of the CSF and the LADD is much greater than 1, the ELCR approaches 1 (i.e., 100
percent probability). When the product is less than 0.01 (one chance in 100), the equation can be closely
approximated by:
ELCR = LADD (mg/kg-day) x CSF (mg/kg-day)-1
The product of the CSF and the LADD is unitless, and provides an upper-bound estimate of the potential
carcinogenic risk associated with a receptor’s exposure to that compound via that pathway.
For inhalation cancer risk estimates, an adjusted lifetime air concentration was calculated for each
receptor accounting for the specific exposure frequency and duration for that receptor. This
concentration is multiplied by the unit risk factor, as shown in the following equation:
ELCR = Adjusted lifetime air concentration (μg/m3) x unit risk factor (μg/m3)-1
The ELCR was compared to the cancer risk guideline defined by USEPA (2005) and MPCA of 1x10-5 (1
in 100,000).
4.4.2
Non-carcinogenic Risk Characterization
For oral noncancer risk estimates, a Chronic Average Daily Dose (CADD) is calculated that averages a
receptor’s exposure dose over the exposure duration. The potential risk of adverse non-carcinogenic
health effects is estimated for each receptor by comparing the CADD for each compound with the RfD
for that compound. The resulting ratio, which is unitless, is known as the Hazard Quotient (HQ) for that
compound. The HQ is calculated using the following equation:
HQ =
CADD (mg/kg − day)
RfD (mg/kg − day
For inhalation noncancer risk estimates, an adjusted chronic air concentration is estimated which
represents the air concentration that the receptor could inhale averaged over the exposure duration, and
accounts for the specific exposure frequency and duration of that receptor. This concentration is divided
by the Reference Concentration (RfC), as shown in the following equation:
HERC Risk Assessment Report
December 2010
AECOM Environment
4-8
3
m
/
g
u
n
o
i
t
a
r
t
n
e 3
c m
n /
o g
c u
r
i
C
a
f
c R
i
n
o
r
h
c
d
e
t
s
u
j
d
A
Q
H
︵
=
︵
︶
)
The total Hazard Index (HI) for each receptor was calculated by summing the HQs for each pathway and
compound within that pathway. The total HI was compared to the acceptable HI defined by USEPA and
MPCA of 1.
4.4.3
Acute Risk Characterization
Potential acute (maximum 1-hour) risks to human health were evaluated only for the inhalation exposure
pathway, as recommended in USEPA guidance (USEPA, 2005). Acute risks to human health were
evaluated for the maximum one hour air concentration for all COPCs. Acute hazard quotients were
calculated using the following equation:
HQ =
3
AC (ug/m )
3
acute benchmark (ug/m )
Where:
HQ = hazard quotient
AC = estimated 1-hour maximum air concentration
Acute benchmark = compound-specific acute benchmark or toxicity value.
HERC Risk Assessment Report
December 2010
AECOM Environment
Table 4-1
4-9
Inhalation Toxicity Values
COPC
Acrolein
Arsenic
Benzo(a)pyrene
Cadmium
Chromium VI
Dibenz (a,h)
anthracene
H2SO4
HCl
Lead
Manganese
Mercury
Cancer Assessment
Toxicological Value
Unit Risk
Source(1)
(µg/m3)-1
NA
NA
4.30E-03
HRV
1.10E-03
CAL EPA
1.80E-03
HRV
1.20E-02
HRV
Chronic Non Cancer Assessment
Reference
Toxicological
Conc. (µg/m3)
Value Source
2.00E-02
IRIS
0.015
CAL EPA
NA
NA
2.00E-02
CAL EPA
1.00E-01
IRIS
1.20E-03
CAL EPA
NA
NA
NA
NA
1.2E-05
NA
NA
NA
NA
1.0
2.00E+01
1.5
2.00E-01
3.00E-01
CAL EPA
HRV
5.00E-02
CAL EPA
9.00E-06
IRIS
Nickel
4.8E-04
Nitrobenzene
N-Nitroso-di-npropylamine
4.0E-05
NA
NA
MDH HRV for nickel
sulfide
IRIS
2.00E-03
CAL EPA
NA
NA
4.00E+02
MDH
4.00E-05
CAL EPA
2,3,7,8 TCDD
TEQ(2)
(1)
(2)
HRV
IRIS
Toxicological Value Source
•
CalEPA - California Office of Environmental Health Hazard Assessment
•
HRV - Minnesota Department of Health Risk Value (http://www.health.state.mn.us/divs/eh/air/rules.htm)
•
IRIS - EPA Integrated Risk Information System
•
MDH - Minnesota Department of Health value (http://www.health.state.mn.us/divs/eh/risk/guidance/dioxinmemo2.html)
Individual dioxin/furan congeners were expressed as toxic equivalents of 2,3,7,8-TCDD using the World Health Organization’s
2005 Toxic Equivalency Factors (TEF's)
HERC Risk Assessment Report
December 2010
AECOM Environment
Table 4-2
4-10
Oral Toxicity Values
COPC
Chronic Non Cancer
Assessment
Cancer Assessment
Oral CSF(mg/kg-d)-
Oral CSF
Source
NA
IRIS
HHRAP
NA
NA
CAL EPA
NA
NA
RfD (mg/kg-d)
RfD Source
Acrolein
Arsenic
Benzo(a)pyrene
Cadmium
Chromium VI
Dibenz (a,h) anthracene
H2SO4
HCl
Lead
Manganese
Mercury
Nickel
Nitrobenzene
N-Nitroso-di-npropylamine
5.0E-04
3.00E-04
NA
5.00E-04
3.00E-03
NA
NA
NA
4.29E-04
0.14
3.00E-04
2.00E-02
5.00E-04
IRIS
IRIS
NA
mHRV
IRIS
NA
NA
NA
HHRAP
IRIS
IRIS
mHRV
HHRAP
NA
1.50E+00
7.3
NA
NA
4.1
NA
NA
0.0085
NA
NA
NA
NA
NA
NA
7.0
HHRAP
2,3,7,8 TCDD TEQ(2)
1.00E-09
HHRAP
1.40E+06
MDH
(1)
(2)
1
NA
NA
NA
AN
Toxicological Value Source
•
CalEPA - California Office of Environmental Health Hazard Assessment
•
HRV - Minnesota Department of Health Risk Value (http://www.health.state.mn.us/divs/eh/air/rules.htm)
•
IRIS - EPA Integrated Risk Information System
•
MDH - Minnesota Department of Health value (http://www.health.state.mn.us/divs/eh/risk/guidance/dioxinmemo2.html)
•
HHRAP – Human Health Risk Assessment Protocol Default Database
Individual dioxin/furan congeners were expressed as toxic equivalents of 2,3,7,8-TCDD using the World Health Organization’s
2005 Toxic Equivalency Factors (TEF's)
HERC Risk Assessment Report
December 2010
AECOM Environment
Table 4-3
Acute Benchmarks
COPC
Acrolein
Arsenic
Benzo(a)pyrene
Cadmium
Chromium VI
Dibenz (a,h) anthracene
H2SO4
HCl
Lead
Manganese
Mercury
Nickel
Nitrobenzene
N-Nitroso-di-n-propylamine
2,3,7,8 TCDD TEQ(2)
(1)
(2)
4-11
Acute Air Concentration
(mg/m3)
0.002
1.90E-04
0.6
0.03
NA
30
120
2.70
0.15
NA
6.0E-04
1.10E-02
NA
NA
0.0015
Toxicological Value Source
MDH (HBV)
CAL EPA
HHRAP
HHRAP
NA
HHRAP
CAL EPA
HRV
HHRAP
NA
CAL EPA
HRV
NA
NA
HHRAP
Toxicological Value Source
•
CalEPA - California Office of Environmental Health Hazard Assessment
•
HRV - Minnesota Department of Health Risk Value (http://www.health.state.mn.us/divs/eh/air/rules.htm)
•
IRIS - EPA Integrated Risk Information System
•
HHRAP – HHRAP Default Database
Used the HHRAP value for TCDD 2,3,7,8- as a surrogate
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 4-1
4-12
Map Showing Key Receptor Locations
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 4-2
4-13
Water Bodies and Watersheds Considered in the HRA
HERC Risk Assessment Report
December 2010
AECOM Environment
5.0
5-1
Risk Characterization
The MPCA significant risk thresholds are 1 x 10-5 for lifetime cancer risk and 1.0 for both the longterm and acute non-cancer hazard indices. The results in these tables indicate that risks
associated with proposed future permitted emissions for all model receptor types modeled risks
are below MPCA risk thresholds and that for actual emissions the modeled risks are very low in
comparison to these thresholds. This analysis confirms that CHERC does not and will not
contribute to community health risk.
Table 5-1 summarizes the multi-pathway risks for two cases:
•
•
Chronic cancer risks and non-cancer hazard indices from current actual emissions
based on 2007-2009 stack testing;
Chronic cancer risks and non-cancer hazard indices from the projected total Facility
PTE.
HERC Risk Assessment Report
December 2010
AECOM Environment
Table 5-1
5-2
Summary of Long term Risk
Emissions Case
Proposed Permitted Emissions
Actual Emissions(3)
Cancer Risk
Hazard Index
Cancer
Risk
Hazard
Index
resident adult
1.2E-06
0.20
4.3E-07
0.18
resident child
3.2E-07
0.20
9.4E-08
0.18
farmer adult
4.8E-06
0.02
2.9E-07
0.01
farmer child
1.0E-06
0.02
6.1E-08
0.01
Recreational
Fisher at
Lake Calhoun
fisher adult
1.1E-06
0.19
2.1E-07
0.08
fisher child
2.9E-07
0.20
5.2E-08
0.08
Recreational
Fisher at
Crystal Lake
fisher adult
2.2E-06
0.42
2.7E-07
0.10
fisher child
4.5E-07
0.43
6.1E-08
0.10
Recreational
Fisher at
Lake of the Isles
fisher adult
1.3E-06
0.24
2.2E-07
0.08
fisher child
3.2E-07
0.25
5.4E-08
0.08
Recreational
Fisher at
Lake Wirth
fisher adult
1.8E-06
0.27
2.8E-07
0.09
fisher child
4.0E-07
0.28
6.2E-08
0.09
fisher adult
3.5E-06
0.98
3.1E-07
0.17
fisher child
6.1E-07
0.98
6.6E-08
0.17
Receptor Type(1)
Resident
Farmer
Subsistence
Fisher(2)
(1) "Resident" receptor type represents the highest risk among residents living in low-rise buildings (ground-level
receptors) and high rise buildings (flag pole receptors). The highest residential risk in the table corresponds to a high-rise
building. All other types of receptors were assumed to live in low-rise buildings.
(2) Per MPCA guidance, the risk for the subsistence fisher based on the average concentration over all watersheds and
water bodies
(3) Based on average of 2007-2009 stack tests
HERC Risk Assessment Report
December 2010
AECOM Environment
5-3
Table 5-2 summarizes the acute inhalation risk for two cases:
•
•
Table 5-2
Acute non-cancer hazard indices from current actual emissions based on 2007-2009
stack testing;
Acute non-cancer hazard indices from the projected total Facility PTE.
Summary of Acute Inhalation Risk based on Maximum Modeled 1-hour Concentration
Receptor
Proposed
Permitted
Emissions
Actual
Emissions
Resident (High Rise Dwelling)
0.39
0.27
Resident (Low Rise Dwelling)
0.10
0.07
Farmer
0.03
0.02
For lead, per MPCA guidance, a supplemental analysis was conducted to evaluate the
maximum contribution of inhaled lead and lead deposited onto soil to blood lead level in
children associated with long-term CHERC emissions using the USEPA Integrated Exposure
Uptake Biokinetic Model (IEUBK). A blood lead level exceeding 10 ug/dL is deemed to be
significant. The results of this assessment for the resident with the highest modeled
concentrations provided in Table 5-3, indicates that the contribution from CHERC to
children’s blood lead levels is insignificant.
Table 5-3
IEUBK Modeled Incremental Blood Lead Levels
Neighborhood Area
Modeled Pb
Soil
Concentration
(mg/kg)
Modeled LongTerm Pb Air
Concentration
(ug/m3)
Incremental
Blood Hg In
Children
(ug/dL)
Comment
Proposed Permitted
Emissions
1.64E-04
1.64E-04
2.90E-03
Below
threshold
Actual Emissions
6.74E-07
6.74E-07
1.19E-05
Below
Threshold
HERC Risk Assessment Report
December 2010
AECOM Environment
5-4
In addition to the incremental assessments of CHERC emissions, per MPCA guidance, the
cumulative hazard index and cancer risk associated with inhalation of urban air pollution in
the Minneapolis area was also evaluated. Table 20 shows that according to the upper 95%
estimate of 2006 to 2008 ambient measurements of selected toxic air pollutants reported by
MPCA, the existing Minneapolis urban-average chronic hazard index is about 1.2, the
individual lifetime cancer risk is about 4.4 x 10¬-5 and acute hazard index is about 0.5. If
these background inhalation risks are assumed to be representative for locations of maximum
modeled inhalation risk from CHERC the total future cumulative risk inhalation risk can be
computed by adding the maximum modeled risks to these background levels. This method is
conservative because MPCA’s computed background risk estimates already include the
actual contribution from CHERC emissions. The maximum modeled inhalation risk
corresponds to high rise apartment. The results of this conservative analysis are provided in
Table 5-4.
Table 5-4
Cumulative Inhalation Risk
95th
Percentile
Urban
Background
Risk*
Maximum
Proposed
Permitted
Inhalation
Risk
Cancer Risk x 100,000
4.38
0.10
4.48
Chronic Hazard Index
1.17
0.20
1.37
Acute Hazard Index
0.51
0.35
0.86
Risk Index
Cumulative
Inhalation
Risk
*Provided by MPCA: 2006-2008 risk sheetsummary.xls
Figures 5-1 through 5-3 provide isopleths of lifetime cancer risk, chronic hazard index and acute
hazard index for adult residential receptors, respectively, associated with the future PTE case. As
can be seen in these figures the permitted risks associated with HERC are well below MPCA
guidleines at all locations and decrease rapidly with distance from the Facility.
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 5-1
5-5
Isopleth of Residential Lifetime Cancer Risk
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 5-2
5-6
Isopleth of residential Lifetime Hazard Index
HERC Risk Assessment Report
December 2010
AECOM Environment
Figure 5-3
5-7
Isopleth of Residential Acute Hazard Index
HERC Risk Assessment Report
December 2010
AECOM Environment
1
Appendix A
Emissions Estimation
Spreadsheets
HERC Risk Assessment Report
December 2010
Covanta HERC
Hennepin County, MN
Summary of Future Potential Emission for Use in IRAP
COPC
Long Term Maximum Short Term Emission Rate (g/s) Emission Rate (g/s)
Acrolein (1)
Arsenic(2)(7)
Benzo (a) pyrene (3)
Cadmium(4)(7)
Chromium(7)
Dibenz (a,h) anthracene (3)(8)
Dioxins/Furans TEQ (5)(7)
H2SO4 (6)(8)
2.89E‐04
2.78E‐04
3.91E‐07
2.11E‐03
5.71E‐04
3.91E‐07
1.83E‐08
2.35E‐02
3.09E‐04
2.61E‐04
4.45E‐07
2.40E‐03
5.36E‐04
4.45E‐07
2.37E‐08
1.13E‐01
Hydrochloric Acid(4)(7)
Lead(4)(7)
Manganese (3)(8)
Mercury(4)(7)
Nickel(2)(7)
Nitrobenzene (1)(8)
N‐Nitroso‐di‐n‐propylamine (1)(8)
Nitrogen oxides (as NO2)
2.60E+00
2.41E‐02
1.91E‐03
9.03E‐04
4.99E‐04
1 28E‐05
1.28E‐05
1.09E‐04
2.32E+01
2.96E+00
2.74E‐02
2.18E‐03
2.74E‐02
4.69E‐04
1.55E‐05
1.33E‐04
2.64E+01
(1)
Representative emission rates derived from 2004 Olmstead Waste to Energy test data
Derived from MPCA emission estimate
(3)
Representative emission rates derived from 2009 Covanta Stanislaus test data
(4)
Derived from Title V permit limit
(2)
(5)
Total Dioxin/Furan emission rate scaled by average TEQ from stack test data (2007‐2009)
Annual TEQ Factor:
1.01E‐02 Short Term TEQ Factor: 1.15E‐02
(6)
Representative emission rate derived from 2007‐2009 Huntignton Resource Recovery Facility test data
Short term emission rate reflects a 14% increase from long term rate
(7)
(8)
Long term permitted emission rates scaled by a factor of 1.212 to account for theincrease in annual fuel use
Conversions and Constants
tpy‐‐‐‐‐>g/s
lb/hr‐‐‐‐>g/s
0.02877
0.125998
Factor
1.212
Covanta HERC
Hennepin County, MN
Summary of Actual Emissions for Use in IRAP
COPC
Long Term Maximum Short Term Emission Rate (g/s) Emission Rate (g/s)
Acrolein (1)
Arsenic(2)(7)
Benzo (a) pyrene (3)
Cadmium(4)(7)
Chromium(7)
Dibenz (a,h) anthracene (3)(8)
Dioxins/Furans TEQ (5)(7)
H2SO4 (6)(8)
2.38E‐04
2.61E‐04
3.91E‐07
2.38E‐05
5.36E‐04
3.91E‐07
9.59E‐10
2.35E‐02
3.09E‐04
2.97E‐04
4.45E‐07
2.85E‐05
6.10E‐04
4.45E‐07
1.31E‐09
1.13E‐01
Hydrochloric Acid(4)(7)
Lead(4)(7)
Manganese (3)(8)
Mercury(4)(7)
Nickel(2)(7)
Nitrobenzene (1)(8)
N‐Nitroso‐di‐n‐propylamine (1)(8)
Nitrogen oxides (as NO2)
1.64E+00
9.89E‐05
1.91E‐03
1.09E‐04
4.69E‐04
1 28E‐05
1.28E‐05
1.09E‐04
1.55E+01
1.96E+00
1.19E‐04
2.18E‐03
1.31E‐04
5.34E‐04
1.55E‐05
1.33E‐04
1.86E+01
(1)
Representative emission rates derived from 2004 Olmstead Waste to Energy test data
Derived from MPCA emission estimate
(3)
Representative emission rates derived from 2009 Covanta Stanislaus test data
(4)
Derived from Title V permit limit
(2)
(5)
Total Dioxin/Furan emission rate scaled by average TEQ from stack test data (2007‐2009)
(6)
Representative emission rate derived from 2007‐2009 Huntignton Resource Recovery Facility test data
Short term emission rate reflects a 14% increase from long term rate
(7)
Conversions and Constants
tpy‐‐‐‐‐>g/s
lb/hr‐‐‐‐>g/s
0.02877
0.125998
Annual TEQ Factor:
1.01E‐02 Short Term TEQ Factor: 1.15E‐02
AECOM Environment
1
Appendix B
GEP Analysis
AECOM Environment
Building Downwash
The analysis used to evaluate the potential for building downwash is referred to as a physical
“Good Engineering Practice” (“GEP”) stack height analysis. Stacks with heights below physical
GEP are considered to be subject to building downwash.
A GEP stack height analysis was performed in accordance with US EPA’s guidelines (US EPA,
1985). Per the guidelines, the physical GEP height (“HGEP”) is determined from the dimensions of
all buildings which are within the region of influence using the following equation:
HGEP = H + 1.5L
where:
H = height of the structure within 5L of the stack which maximizes HGEP, and
L = lesser dimension (height or projected width) of the structure.
For a squat structure, i.e., height less than projected width, the formula reduces to:
HGEP = 2.5H
In the absence of influencing structures, a “default” GEP stack height is credited up to 65 meters
(213 feet).
AECOM obtained pertinent source information for the HERC stacks including stack parameters,
permitted emission rates of criteria and hazardous air pollutants, and building dimensions for all
existing and future structures within a distance of 5 x the lesser of structure height or width from
the HERC stacks. Plan view and cross sections were provided for the new ballpark based on
present design, including the footprint, height and dimensions of the field and stands. Figure A
and Figure B provide far-field and near-field views of the stack locations and all of the buildings
and structures that could result in aerodynamic downwash.
The direction-specific building dimensions were determined using the latest version of USEPA’s
Building Profile Input Program software (BPIP PRIME Dated 04274) using the design values of the
stack and building heights.
Detailed BPIP PRIME input and output data are provided at the end of this appendix
2
AECOM Environment
Figure A Buildings Included in Downwash Analysis (far-field view) Showing Building Height
(distances in meters)
3
AECOM Environment
Figure B Buildings Included in Downwash Analysis (near-field view) Showing Building Height
(distances in meters)
4
AECOM Environment
BPIP PRIME Input Data
'J:\AQES\Projects\HennepinCounty\TwinsBallpark\Modeling\Lakes\Bllpk.i'
'P'
'METERS' 1.00000000
'UTMY' 0.0000
34
'COOLTWR' 1
250.546 'Cooling Tower'
4
22.555
477859.393
4980952.812
477887.433
4980922.923
477866.480
4980903.818
477837.462
4980934.651
'BGHSE' 1
250.546 'Baghouse'
4
19.812
477892.980
4980946.342
477911.912
4980962.808
477923.424
4980951.099
477904.689
4980934.016
'SPRYDRY' 1
250.546 'Spray Dryers'
4
38.100
477909.191
4980933.088
477915.896
4980927.222
477928.886
4980939.793
477923.019
4980946.078
'CARBON' 1
250.546 'Carbon Silo'
32
17.374
477931.400
4980951.260
477931.043
4980951.224
477930.700
4980951.120
477930.384
4980950.951
477930.107
4980950.724
477929.879
4980950.447
477929.710
4980950.131
477929.606
4980949.788
477929.571
4980949.431
477929.606
4980949.074
477929.710
4980948.731
477929.879
4980948.415
477930.107
4980948.138
477930.384
4980947.910
477930.700
4980947.741
477931.043
4980947.637
477931.400
4980947.602
477931.757
4980947.637
477932.100
4980947.741
477932.416
4980947.910
477932.693
4980948.138
477932.920
4980948.415
477933.089
4980948.731
477933.193
4980949.074
477933.229
4980949.431
477933.193
4980949.788
477933.089
4980950.131
477932.920
4980950.447
477932.693
4980950.724
477932.416
4980950.951
477932.100
4980951.120
477931.757
4980951.224
'TESISORB' 1
250.546 'Tesisorb Silo'
32
15.545
477926.790
4980955.450
477926.434
4980955.415
477926.091
4980955.311
477925.774
4980955.142
477925.497
4980954.914
477925.270
4980954.637
477925.101
4980954.321
5
AECOM Environment
'LIME'
32
'ASH'
8
1
1
477924.997
477924.962
477924.997
477925.101
477925.270
477925.497
477925.774
477926.091
477926.434
477926.790
477927.147
477927.490
477927.806
477928.084
477928.311
477928.480
477928.584
477928.619
477928.584
477928.480
477928.311
477928.084
477927.806
477927.490
477927.147
250.546
25.298
477928.886
477928.440
477928.011
477927.616
477927.269
477926.985
477926.774
477926.644
477926.600
477926.644
477926.774
477926.985
477927.269
477927.616
477928.011
477928.440
477928.886
477929.332
477929.760
477930.156
477930.502
477930.786
477930.998
477931.128
477931.172
477931.128
477930.998
477930.786
477930.502
477930.156
477929.760
477929.332
250.546
14.021
477897.877
477915.058
477904.163
477910.029
477906.302
477889.077
6
4980953.978
4980953.621
4980953.264
4980952.921
4980952.605
4980952.328
4980952.100
4980951.931
4980951.827
4980951.792
4980951.827
4980951.931
4980952.100
4980952.328
4980952.605
4980952.921
4980953.264
4980953.621
4980953.978
4980954.321
4980954.637
4980954.914
4980955.142
4980955.311
4980955.415
'Lime Silo'
4980934.955
4980934.911
4980934.781
4980934.570
4980934.286
4980933.939
4980933.544
4980933.115
4980932.669
4980932.223
4980931.795
4980931.399
4980931.053
4980930.769
4980930.557
4980930.427
4980930.383
4980930.427
4980930.557
4980930.769
4980931.053
4980931.399
4980931.795
4980932.223
4980932.669
4980933.115
4980933.544
4980933.939
4980934.286
4980934.570
4980934.781
4980934.911
'Ash Storage Building'
4980879.871
4980861.853
4980852.215
4980845.069
4980840.857
4980858.501
AECOM Environment
477892.011
4980861.015
477885.306
4980868.072
'CLASSIF' 1
250.546 'Classification Room'
4
14.935
477913.800
4980886.576
477924.695
4980876.519
477929.305
4980880.709
477918.829
4980891.604
'BIG' 5
250.546
20
3.658
477981.265
4980943.145
478007.664
4980918.841
477998.026
4980908.365
478000.914
4980905.430
477994.964
4980900.049
478026.939
4980868.557
477987.969
4980830.006
477977.074
4980838.387
477954.866
4980830.844
477938.942
4980846.349
477951.787
4980858.526
477936.084
4980874.582
477952.771
4980889.928
477922.253
4980918.698
477945.760
4980939.333
477957.725
4980929.114
477966.009
4980937.219
477979.073
4980925.813
477983.997
4980930.635
477975.909
4980938.004
8
34.442
477974.387
4980914.968
477985.036
4980925.127
477992.274
4980917.951
477990.163
4980915.573
478000.540
4980905.851
477951.932
4980858.501
477936.428
4980874.424
477976.845
4980912.500
4
19.202
477965.872
4980936.813
477982.307
4980922.890
477974.230
4980914.967
477957.675
4980928.866
4
37.490
477945.692
4980938.947
477922.177
4980918.765
477952.798
4980890.199
477976.772
4980912.375
8
19.202
477976.706
4980882.444
478000.657
4980905.593
477994.924
4980899.714
478026.832
4980868.487
477987.976
4980830.081
477977.126
4980838.595
477954.831
4980831.023
477939.078
4980846.327
'OFFICE' 1
250.546 'Existing Office Building'
4
9.754
478053.029
4980903.493
478086.845
4980935.888
478108.555
4980913.810
478075.806
4980880.693
'PARK_1' 3
251.765 'Sections A-C'
38
9.754
478068.352
4980756.446
7
AECOM Environment
39
478107.552
478117.778
478137.717
478151.418
478137.378
478159.109
478159.109
478125.874
478118.857
478092.867
478068.845
478025.119
478011.354
478005.932
478004.073
478003.919
478007.056
478012.984
478021.586
478035.147
478050.641
478069.024
478078.973
478084.826
478108.089
478129.775
478176.291
478174.874
478144.196
478148.883
478129.283
478108.404
478096.900
478081.134
478069.204
478065.369
478065.369
18.898
478129.647
478117.702
478096.716
478082.213
478056.250
478044.452
478039.477
478036.632
478039.179
478047.258
478089.283
478105.956
478125.806
478138.518
478137.346
478158.962
478158.926
478126.165
478119.413
478092.623
478068.596
478025.263
478011.773
478005.835
478004.654
478004.547
478007.504
478013.199
478020.682
8
4980794.795
4980801.612
4980807.981
4980821.485
4980838.682
4980843.369
4980853.169
4980861.265
4980864.503
4980856.745
4980842.684
4980801.440
4980784.773
4980770.749
4980756.762
4980741.533
4980726.540
4980712.707
4980700.116
4980685.431
4980670.092
4980651.424
4980643.349
4980653.905
4980646.099
4980640.126
4980654.506
4980662.706
4980664.411
4980675.489
4980695.515
4980702.759
4980709.576
4980726.620
4980738.551
4980744.942
4980750.055
4980666.332
4980670.308
4980677.487
4980686.895
4980711.919
4980724.661
4980734.676
4980746.478
4980761.401
4980775.364
4980815.270
4980827.277
4980833.461
4980837.134
4980838.848
4980843.584
4980852.878
4980861.001
4980864.437
4980855.937
4980841.880
4980801.089
4980784.922
4980770.919
4980756.440
4980741.070
4980726.821
4980712.803
4980701.545
AECOM Environment
38
'PARK_2'
5
4
'PARK_3'
5
478030.835
4980690.518
478046.739
4980674.851
478065.359
4980654.987
478078.985
4980643.909
478084.554
4980654.152
478105.711
4980646.950
478129.559
4980640.318
478176.212
4980654.526
478174.731
4980662.549
478140.509
4980664.706
42.062
478030.247
4980751.169
478032.693
4980763.804
478041.660
4980778.885
478085.273
4980819.645
478102.800
4980831.873
478125.625
4980839.210
478159.101
4980843.640
478158.694
4980852.687
478126.033
4980860.812
478119.104
4980863.883
478093.425
4980856.572
478069.080
4980842.359
478024.462
4980799.916
478011.964
4980784.618
478006.258
4980770.569
478004.463
4980755.245
478004.437
4980740.735
478007.316
4980726.850
478013.404
4980712.722
478021.635
4980700.738
478030.602
4980691.336
478045.874
4980675.223
478065.576
4980655.468
478079.082
4980643.827
478084.696
4980654.061
478105.866
4980647.084
478129.735
4980640.380
478176.187
4980654.650
478175.590
4980657.829
478153.342
4980659.051
478129.701
4980660.682
478115.435
4980664.758
478093.833
4980672.910
478076.306
4980685.138
478052.258
4980707.148
478039.622
4980720.191
478033.508
4980732.827
478031.063
4980744.239
2
251.765 'Section D'
26.213
478151.271
4980821.696
478172.076
4980842.850
478214.909
4980800.017
478189.734
4980784.457
478186.062
4980791.101
50.902
478205.643
4980801.940
478207.916
4980804.213
478172.950
4980835.857
478169.803
4980832.885
1
251.765 'Section E'
21.641
478198.811
4980790.002
478213.655
4980765.140
478227.671
4980770.821
478219.454
4980785.506
9
AECOM Environment
478211.412
4980797.919
1
251.765 'Section F'
21.641
478203.195
4980761.380
478219.105
4980767.499
478215.433
4980729.211
478199.699
4980733.233
'PARK_5' 2
251.765 'Section G'
5
21.641
478199.699
4980733.407
478179.943
4980698.442
478189.034
4980693.721
478197.426
4980701.239
478214.384
4980729.386
4
45.415
478214.052
4980729.008
478210.459
4980730.260
478193.958
4980702.801
478197.365
4980701.307
'PARK_6' 1
251.765 'Section H'
5
8.534
478182.217
4980702.820
478157.071
4980683.617
478163.929
4980676.530
478183.360
4980696.647
478180.160
4980698.019
'PARK_7' 1
251.765 'Section J'
5
9.754
478148.383
4980675.844
478156.842
4980683.617
478173.987
4980667.614
478174.902
4980662.585
478144.269
4980664.642
'PARK_8' 1
251.765 'Section K'
14
24.384
478078.840
4980643.722
478087.261
4980637.778
478107.817
4980630.596
478126.639
4980626.881
478143.480
4980626.881
478147.690
4980626.881
478157.101
4980628.615
478179.390
4980636.045
478187.563
4980640.502
478193.507
4980645.456
478174.933
4980662.297
478176.171
4980655.610
478129.363
4980640.502
478084.537
4980654.124
'TRGT_CTR' 1
256.337 'Target Center'
8
48.158
478241.384
4980567.326
478284.013
4980567.326
478317.865
4980534.727
478319.119
4980492.098
478262.698
4980436.931
478220.069
4980436.931
478186.217
4980469.530
478184.963
4980509.651
'BLD_20' 1
257.556
11
27.432
478053.315
4980619.985
477988.118
4980577.356
478048.300
4980467.022
478044.538
4980242.593
478054.569
4980218.771
478105.974
4980246.354
'PARK_4'
4
10
AECOM Environment
'BLD_21'
4
'BLD_22'
4
'BLD_23'
4
'BLD_24'
4
'BLD_25'
4
'BLD_26'
4
'BLD_27'
4
'BLD_28'
4
'BLD_29'
4
'BLD_30'
4
'BLD_31'
3
478126.035
4980273.938
478136.065
4980296.506
478143.588
4980326.597
478141.080
4980357.942
478141.080
4980510.905
1
252.984
45.720
478097.198
4980956.002
478129.796
4980991.108
478171.817
4980954.127
478141.093
4980915.880
1
256.032
28.956
478335.418
4980912.119
478369.271
4980950.986
478482.112
4980846.922
478445.752
4980809.308
1
259.080
45.720
478380.555
4980672.644
478416.282
4980708.359
478438.850
4980685.194
478402.515
4980648.189
1
259.080
31.090
478406.885
4980645.061
478445.512
4980681.769
478474.590
4980651.330
478441.991
4980614.970
1
259.080
32.918
478440.097
4980699.552
478471.566
4980732.883
478511.344
4980697.164
478479.111
4980660.634
1
256.946
35.052
478356.291
4980602.996
478390.816
4980633.558
478421.664
4980599.701
478387.951
4980567.277
1
256.946
33.528
478312.454
4980637.903
478385.516
4980565.654
478348.173
4980526.687
478276.735
4980601.373
1
259.080
33.528
478200.832
4980261.433
478216.662
4980279.698
478249.540
4980251.691
478230.057
4980230.990
1
259.080
32.918
478227.621
4980288.222
478244.669
4980302.834
478275.111
4980276.045
478262.934
4980261.433
1
259.690
44.196
478419.349
4980231.611
478443.225
4980270.577
478491.861
4980245.603
478471.184
4980204.177
1
259.690
35.357
11
AECOM Environment
'BLD_32'
4
'BLD_33'
4
'BLD_34'
4
2
'STCK1'
'STCK2'
12
478427.249
4980296.797
478480.902
4980325.970
478479.642
4980265.564
1
259.690
62.179
478471.160
4980345.454
478494.945
4980383.904
478550.986
4980355.923
478528.418
4980315.038
1
259.690
37.490
478545.392
4980381.245
478569.865
4980419.160
478637.984
4980378.331
478614.896
4980338.100
1
259.690
71.933
478643.890
4980314.987
478676.863
4980365.379
478711.701
4980343.604
478678.107
4980295.079
250.546
250.546
65.837
65.837
477892.090
477897.770
4980961.160
4980965.700
AECOM Environment
13
Detailed BPIP PRIME Output Data
J:\AQES\Projects\HennepinCounty\TwinsBallpark\Modeling\Lakes\Bllpk.i
BPIP (Dated: 04274)
DATE : 11/10/2006
TIME : 14:15:49
J:\AQES\Projects\HennepinCounty\TwinsBallpark\Modeling\Lakes\Bllpk.i
============================
BPIP PROCESSING INFORMATION:
============================
The P
flag has been set for preparing downwash related data
for a model run utilizing the PRIME algorithm.
Inputs entered in METERS
a conversion factor of
will be converted to meters using
1.0000. Output will be in meters.
The UTMP variable is set to UTMY. The input is assumed to be in
UTM coordinates. BPIP will move the UTM origin to the first pair of
UTM coordinates read. The UTM coordinates of the new origin will
be subtracted from all the other UTM coordinates entered to form
this new local coordinate system.
Plant north is set to
0.00 degrees with respect to True North.
J:\AQES\Projects\HennepinCounty\TwinsBallpark\Modeling\Lakes\Bllpk.i
PRELIMINARY* GEP STACK HEIGHT RESULTS TABLE
(Output Units: meters)
Stack
Name
Stack
Height
Stack-Building
Base Elevation
Differences
65.84
65.84
-2.44
-2.44
STCK1
STCK2
GEP**
EQN1
116.74
116.74
Preliminary*
GEP Stack
Height Value
116.74
116.74
* Results are based on Determinants 1 & 2 on pages 1 & 2 of the GEP
Technical Support Document. Determinant 3 may be investigated for
additional stack height credit. Final values result after
Determinant 3 has been taken into consideration.
** Results were derived from Equation 1 on page 6 of GEP Technical
Support Document. Values have been adjusted for any stack-building
base elevation differences.
Note: Criteria for determining stack heights for modeling emission
limitations for a source can be found in Table 3.1 of the
GEP Technical Support Document.
BPIP (Dated: 04274)
DATE : 11/10/2006
TIME : 14:15:49
J:\AQES\Projects\HennepinCounty\TwinsBallpark\Modeling\Lakes\Bllpk.i
AECOM Environment
14
BPIP output is in meters
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
BUILDHGT
BUILDHGT
BUILDHGT
BUILDHGT
BUILDHGT
BUILDHGT
BUILDWID
BUILDWID
BUILDWID
BUILDWID
BUILDWID
BUILDWID
BUILDLEN
BUILDLEN
BUILDLEN
BUILDLEN
BUILDLEN
BUILDLEN
XBADJ
XBADJ
XBADJ
XBADJ
XBADJ
XBADJ
YBADJ
YBADJ
YBADJ
YBADJ
YBADJ
YBADJ
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
STCK1
22.56
22.56
22.56
22.56
22.56
22.56
22.56
22.56
37.49
37.49
37.49
37.49
37.49
37.49
37.49
37.49
37.49
37.49
22.56
22.56
22.56
22.56
22.56
22.56
22.56
45.72
45.72
45.72
42.06
42.06
42.06
42.06
42.06
37.49
37.49
37.49
51.25
50.97
49.14
45.82
42.27
45.97
48.46
49.48
55.88
46.77
43.38
38.66
32.78
37.71
44.09
49.12
62.96
67.58
51.25
50.97
49.14
45.82
42.27
45.97
48.46
76.05
75.23
72.12 223.49 220.68
211.17 202.66 195.81
49.12
62.96
67.58
47.02
43.62
38.89
32.98
30.74
37.41
42.95
47.18
67.58
54.88
53.49
50.48
45.93
41.91
45.77
48.24
60.20
55.88
47.02
43.62
38.89
32.98
30.74
37.41
42.95
73.16
74.62
73.81 199.33 207.21
209.60 212.64 216.25
48.24
60.20
55.88
-60.92 -62.64 -62.46 -60.39 -58.89 -60.56
-60.40 -58.40
17.10
36.99
42.77
47.25
50.30
51.47
46.04
39.21
20.22
15.08
13.90
19.03
23.58
27.41
28.15
23.15
17.45 -274.26 -279.73 -276.70 -371.80 -399.29
-414.65 -417.41 -407.49 -87.44 -80.42 -70.96
23.57
16.78
9.48
1.90
-6.33 -13.87
-20.89 -27.28 -43.02 -35.95 -24.23 -11.77
1.05
14.65
26.90
38.33
43.45
50.89
-23.57 -16.78
-9.48
-1.90
6.33
13.87
20.89
49.81
7.67 -34.71 122.49
70.98
17.31 -33.17 -78.75 -38.33 -43.45 -50.89
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
SO
BUILDHGT
BUILDHGT
BUILDHGT
BUILDHGT
BUILDHGT
BUILDHGT
BUILDWID
BUILDWID
BUILDWID
BUILDWID
BUILDWID
BUILDWID
BUILDLEN
BUILDLEN
BUILDLEN
BUILDLEN
BUILDLEN
BUILDLEN
XBADJ
XBADJ
XBADJ
XBADJ
XBADJ
XBADJ
YBADJ
YBADJ
YBADJ
YBADJ
YBADJ
YBADJ
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
STCK2
37.49
22.56
22.56
22.56
22.56
22.56
22.56
22.56
19.81
37.49
37.49
37.49
37.49
37.49
37.49
37.49
37.49
37.49
37.49
22.56
22.56
22.56
22.56
22.56
22.56
45.72
45.72
45.72
42.06
42.06
42.06
42.06
42.06
37.49
37.49
37.49
70.15
50.97
49.14
45.82
42.27
45.97
48.46
49.48
28.79
46.77
43.38
38.66
32.78
37.71
44.09
49.12
52.66
67.58
70.15
50.97
49.14
45.82
42.27
45.97
48.46
76.05
75.23
72.12 223.49 220.68
211.17 202.66 195.81
49.12
52.66
67.58
49.86
43.62
38.89
32.98
30.74
37.41
42.95
47.18
30.44
54.88
53.49
50.48
45.93
41.91
45.77
48.24
49.24
55.88
49.86
43.62
38.89
32.98
30.74
37.41
42.95
73.16
74.62
73.81 199.33 207.21
209.60 212.64 216.25
48.24
49.24
55.88
-64.80 -68.85 -69.24 -67.52 -66.16 -67.75
-67.29 -64.78
-4.79
32.19
38.99
44.60
48.87
51.30
47.13
41.53
34.67
19.62
14.94
25.24
30.35
34.54
35.42
30.34
24.34 -267.87 -274.05 -271.89 -368.01 -396.64
-413.22 -417.24 -408.59 -89.77 -83.91 -75.50
-51.99
20.57
12.13
3.33
-6.16 -14.96
-23.22 -30.77 -17.29 -41.41 -30.44 -18.54
-6.08
7.39
19.71
31.44
42.21
45.21
51.99 -20.57 -12.13
-3.33
6.16
14.96
23.22
53.29
12.21 -29.25 128.70
77.75
24.44 -25.90 -71.56 -31.44 -42.21 -45.21