Presented at the 86th Annual AWMA Conference

Denver, Colorado, June 14-18, 1993

EFFECT OF A NEARBY HILL ON

GOOD ENGINEERING PRACTICE STACK HEIGHT

Ronald L. Petersen
and
Douglas K. Parce
Cermak Peterka Petersen, Inc.
1415 Blue Spruce Drive
Fort Collins, Colorado 80524

Jeffrey L. West
Metropolitan Edison Company
2800 Edison Company
Reading, Pennsylvania 19640

Richard Londergan
ENSR
95 Glastonbury Boulevard
Glastonbury, Connecticut 06033
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INTRODUCTION

This paper describes the study conducted to determine the effect of a nearby hill on the "good
engineering practice" (GEP) stack height for Metropolitan Edison Company's (Met-Ed) Titus Generating
Station (TGS). TGS is located along the Schuylkill River about 3 km south of Reading, Pennsylvania as
shown in Figure 1. The station has three 61.0 m (200 ft) stacks with a base elevation of 59.1 m, MSL (194
ft, MSL). To the west of the facility the terrain rises 73 m (240 ft) above plant grade within 1 km. A cross-
section of the plant and nearby terrain is shown in Figure 2.

Recent ISCST modeling conducted by Met-Ed has shown that the three existing stacks may
contribute to modeled accedences of the NAAQS. The high predicted concentrations are due to the combined
effects of short stack heights, nearby elevated terrain and building downwash. If the existing stacks are raised
to some taller height, the modeled accedences may be eliminated.

Before a source can consider a taller stack as a control measure, the EPA stack height regulations
(40 CFR 51.118) requires that the source demonstrate that "excessive concentrations" occur due to the
existing stack in the immediate vicinity of the source as a result of downwash created by nearby structures
and/or terrain. Once this demonstration is made a source can construct and receive regulatory modeling credit
for a taller stack. The maximum stack height that is creditable for regulatory modeling purposes is the GEP
stack height. Credit for a formula GEP stack height can be obtained without further analysis. Credit for a
GEP stack height taller than the formula must be proven through the use of wind tunnel modeling.

The formula based "good engineering practice" (GEP) stack height for TGS is approximately 98.3 m
(322.5 ft) based on the height of the 39.3 m (129 ft) high fan room building. This height stack would be
above the hill as indicated in Figure 2, but past studies by Castro and Snyder1 and Petersen and Ratcliff2
suggest that terrain wakes could still increase ground level concentrations by as much as a factor of two.
Hence, the GEP stack height based on the nearby terrain feature (Highs Hill) may significantly taller than
the formula height.

So the that Met-Ed can evaluate the feasibility of stack height increases for reducing maximum
ground level concentrations (as opposed to emission reduction), a study will following objective was
undertaken.

1) demonstrate whether excessive ground-level SO2 concentrations occur due to the existing
stacks (if they do occur a taller stack can be considered); and

2) determine the GEP stack height based on the nearby terrain.

To meet the project objectives, physical modeling of the atmospheric boundary layer and plume
dispersion was used. A 1:600 scale model of the construction features of the generating station and
appropriate terrain features was constructed and placed in CPP's Environmental Wind Tunnel. Ground-level
concentrations of sulfur dioxide were determined with and without the nearby upwind terrain and structures
present by sampling concentrations of a tracer gas released from the model stacks. Tests were conducted to
simulate various plant and meteorological conditions to demonstrate excessive concentration for the existing
stacks and the maximum creditable (GEP) stack height for new stacks at TGS.

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Included in this paper are a brief description of the similarity requirements for wind tunnel modeling,
a discussion of various technical issues, an explanation of the test methodology, and the results the
evaluation.

TECHNICAL CONSIDERATIONS
Similarity Requirements
An accurate simulation of the boundary-layer winds and stack gas flow is an essential prerequisite
to any wind-tunnel study of diffusion for power plant stack exhaust. The similarity requirements can be
obtained from dimensional arguments derived from the equations governing fluid motion. A detailed
discussion on these requirements is given in the EPA fluid modeling guideline3. The scaling criteria that were
used for this evaluation are summarized below:
• match (equal in model and full scale) momentum ratio, Mo
2
V  (1)
M 0 = λ  e 
U H 
• match density ratio,

ρs (2)
λ=
ρa

• ensure a fully turbulent stack gas flow — stack Reynolds number ( Re s = dV e / υ ) greater
than 670 for buoyant plumes or 2000 for turbulent jets4, or in-stack trip;

• ensure a fully turbulent wake flow — terrain or building Reynolds

number ( Re t = U H H t / υ or Re b = U H H b / υ ) greater than 11,000 and/or Reynolds
number independence verification tests.

• identical geometric proportions;

• [ ]
equivalent stability — Richardson number Ri = ( g ∆ θ H b ) /(T U H2 ) in model equal
to that in full scale, equal to zero for neutral stratification; and

• equality of dimensionless boundary and approach flow conditions;

where

Ve = stack gas exit velocity (m/s),

UH = ambient velocity at building top (m/s),
d = stack diameter (m),
ρa = ambient air density (kg/m3),

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∆θ = potential temperature difference between Hb and the ground (K),

T = mean temperature (K),
ρs = stack gas density (kg/m3),
υ = viscosity (m2/s),
Hb = typical building height (m), and
Ht = typical hill top height (m).

Using the above criteria and source characteristics supplied by Met-Ed, the model test conditions
were computed for the stacks under evaluation. Model and full-scale parameters for one of the stacks with
a 4 m/s wind speed (at 6.1 m above grade at a nearby anemometer site) is presented in Table 1.

Determination of GEP Stack Height

In the stack height regulation, GEP stack height is defined to be the greater of:

(1) 65 meters,

(2) Hg = 2.5H (for stacks in existence in January 12, 1979), or Hg = H + 1.5L (for all other stacks),
where Hg is the good engineering practice stack height, H is the height of nearby structure(s) and L
is the lesser of the projected height or width of the structure,

(3) The height demonstrated by a fluid model or a field study approved by the EPA, State or local
control agency, which ensures that the emissions from a stack do not result in excessive
concentrations of any air pollutant as a result of atmospheric downwash, wakes, or eddy effects
created by the source itself, nearby structures or nearby terrain features."

When a source wants to increase the existing stack height up to the GEP stack height (and receive
credit for the increased stack height), the EPA stack height regulation also requires one of the following:

"(1) demonstrate by fluid modeling or a field study that both excessive concentration
criteria (discussed below) are met using the existing stack height and emission rate and
adding in background air quality, or

(2) show, by site specific information, that the stack is causing a local nuisance."

Since no site specific nuisance information was available for TGS, physical modeling was used to
conduct this demonstration. Once this demonstration is made for the existing stack, a new stack up to the
formula GEP stack height, or a height determined through physical modeling in the wind tunnel, may be
constructed. This wind tunnel determined height could be greater than the height determined from the
formulas discussed above.

To quantitatively determine the GEP height through physical modeling, the stack height regulation
goes on to define excessive concentration as:

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"a maximum ground-level concentration due to emissions from a stack due in whole or in part to
downwash, wakes, and eddy effects produced by nearby structures or nearby terrain features which
individually is at least 40 percent in excess of the maximum concentration experienced in the
absence of such downwash, wakes, or eddy effects and which contributes to a total concentration
due to emissions from all sources that is greater than an ambient air quality standard."

Based on the above definitions, maximum ground level concentrations measured in the wind tunnel
due to each source with and without the nearby structures and terrain present are first compared. If the ratio
of these concentrations is greater than 1.4, one of the criteria for demonstrating an excessive concentration
will have been met. Next, the maximum concentration due to the combined impact of the three units is
determined and compared with NAAQS. If an accedence of the NAAQS is shown, then both excessive
concentration criteria will have been met. For the later determination, the background concentration due to
other sources can also be considered, to show an accedence. The 3- and 24-hour background values for this
region are 229.6 and 111.8 µg/m3, respectively5,6.

Emission Rates
For the purpose of comparing wind-tunnel modeling estimates with NAAQS, SO2 emission rates
must be specified. To demonstrate excessive concentrations for the existing stacks an SO2 emission rate of
3.6 lbs/MMBTU was used (i.e., existing emission rate).

The stack height regulation requires that New Source Performance Standards (NSPS) be used to
define the emission rate when conducting a wind tunnel study to demonstrate a GEP stack height taller than
the formula height unless approval is obtained to use a different rate. The NSPS rate of 1.2 lbs SO2/MMBTU
was used for the terrain effects GEP stack height evaluation for the purpose of calculating full-scale
concentrations.

Nearby Structures and Terrain

In this study, the effect of nearby terrain features was primarily used to determine the GEP stack
height for TGS. However, nearby structures were also considered in the evaluation in case the structures
added additional turbulence to the flow. To evaluate the combined effects of nearby terrain and structures,
tests are first conducted with all terrain and structures included in the model. Next tests are conducted with
the nearby terrain and structures removed. A structure is defined as nearby7 when the distance from the stack
to the structure is less than or equal to five times the lesser of the height or cross-wind width of the structure.
The structures which were treated as nearby are shown in Figure 3.

A terrain feature is defined as nearby (40 CFR 51.1(jj)) if the feature achieves a height greater than
40 % of the formula GEP stack height within 0.8 km from the stack. Once a feature is defined as nearby the
portion of the feature that can be removed from the model is 10 times the maximum height of the feature,
not to exceed 3.2 km. Based on this definition, the terrain feature identified as Highs Hill in Figure 4 is
nearby. Figure 5 shows the nearby terrain "Out" configuration.
Wind Speed, Direction and Persistence
The EPA stack height guideline8 requires that the design wind speed less than the 2 percent wind
speed (speed that is exceeded less than 2 percent of the time) unless it can be demonstrated that higher speeds
cause accedences of NAAQS limits. The 2 percent wind speed was determined by analyzing meteorological
data collected at two different anemometers located with 20 km of TGS. The results of the analysis

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demonstrated that the 2% wind speed for the site is approximately 7.5 m/s at the 6.1 m height. All tests to
justify GEP stack height were conducted at or below this wind speed.

Wind speeds in the tunnel were set at a reference height of 600 m above plant grade. The speed at
this height was determined by scaling the 6.1 m wind speed up to the free stream height, 600 m above ground
level. At this height, is it assumed that wind speeds at the site and at the anemometer location are the same
(i.e., local topographic effects are not important). The following equation define the procedure:

na
 z  (3)
U ∞ = U anem  ∞ 
 z anem 

where U ∞ is wind speed at free stream height (m/s), z ∞ is free stream height (600 m), Uanem is wind speed
at 6.1 m height, zanem is height above grade for Uanem and Usite (6.1 m), and na is wind power law exponent at
the anemometer (taken to be 0.16).

WIND TUNNEL MODELING METHODOLOGY

Scale Model
A 1:600 scale model of TGS and surrounding terrain was designed and constructed. The entire area
modeled is depicted in Figure 1. A plan view of the turntable which was at the center of the modeled area
is given in Figures 4 and 4 for the terrain-in and terrain-out configurations, respectively. The location of the
TGS buildings is shown in Figure 3. The model included all significant terrain within a 1040 m (3400 ft)
radius of the stacks under evaluation. Upwind and downwind of the turntable, additional model terrain and
roughness elements were installed.

Model stacks were constructed of brass tubes. Trips were installed within the stacks to ensure that
the flow was fully turbulent upon exiting the stacks. The stacks were supplied with a premixed certified
air-helium-hydrocarbon mixture. A precision gas flow meter was used to monitor and regulate the discharge
velocity. The stack parameters for all tests are provided in Table 1.

Concentration sampling taps were installed at numerous downwind sampling locations and were
positioned relative to the turntable center. For each test, appropriate sampling locations were used to ensure
that the maximum concentration was measured.

Wind Tunnel
All testing was carried out in CPP's environmental wind tunnel. A general description of the tunnel
is contained in Figure 6. A total of 10.7 m (35 ft) of model terrain was installed in the tunnel. Sheets of
cubical roughness elements arranged in a staggered pattern were placed up and downwind of the modeled
terrain to assist in the development and maintenance of an appropriate boundary layer. Additionally, eight
semi-elliptical spires and a two-dimensional trip were placed near the entrance of the tunnel to aid in
boundary-layer development.

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Evaluation of Simulated Boundary Layer and Dispersion Comparability

The EPA fluid modeling guideline for determining excessive concentrations requires that certain
information be collected to document the boundary-layer and dispersion characteristics. All information as
required in the EPA Guidelines was obtained. In general, the results showed that a representative atmospheric
boundary layer was established and that the dispersion were characteristic of that observed in the atmosphere.
These test have been performed for many such studies and similar results have been found9.

Calculation of Full-Scale Concentrations

The concentrations measured in the wind tunnel were converted to full-scale concentrations using
the following equation3:
2
 CU r   Lm   Q  (4)
Cf =    

  × 10 6
 C oV  m  L f  Ur f
where
Cf = full-scale concentration for pollutant of concern (µg/m3),
(Co)m = tracer gas initial concentration in model (ppm),
L = model (m) and full-scale (f) length scales,
Ur = model (m) and full-scale (f) reference wind speeds (m/s),
Qf = full-scale SO2 emission rate (g/s),
V = model (m) and full-scale (f) volume flow rates (m3/s), and
(C)m = tracer gas concentration less background in model (ppm).

The full scale concentrations as determined from Equation 1 above represent 15 minute to one-hour
average concentrations in the full scale. For this evaluation, it will be assumed that the 1-hour averaging time
is appropriate. For conversion of hourly concentrations to equivalent 3-hour average concentrations, the EPA
guideline10,11 recommends a multiplication factor of 0.9 ± 0.1. To convert hourly values to 24-hour values
EPA11 suggests a factor of 0.4 ± 0.2. The guideline also notes that it may be desirable to increase the
conversion factors if terrain or building downwash is of concern. The guideline suggests that the appropriate
conversion factors be determined based on representative meteorological data for the site. Accordingly, a
wind persistence analysis was conducted that demonstrated a 0.542 24-hour conversion factor for a 347.5
degree wind direction (the direction with the terrain upwind of the stack).

Reynolds Number Independence Tests

Prior to conducting the evaluation of terrain wakes effects various documentation test were
conducted, one of which was to evaluate the effect of Reynolds number on the concentration results. Even
though the Reynolds number based on the height of the terrain was sufficiently high (17,600) such that
Reynolds number tests may not have been required, the tests were conducted to confirm Reynolds number
independence. For these tests, a neutrally buoyant tracer gas was released from each of the stacks under
evaluation. The exit velocities for each of the stacks were set to be 1.5 times the wind velocity at the top of
the stacks (200 ft).

Three different model wind speeds (2, 4 and 6 m/s) were set at the reference height (600 m full scale)
and ground-level concentrations were measured for the "in" and "out" configurations. The maximum values
found at each downwind distance did not vary significantly for the range of wind tunnel speeds tested (terrain

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Reynolds numbers of 8,810, 17,600 and 26,400). All testing to evaluate the GEP stack height was conducted
using a wind tunnel speed of 4 m/s, where Reynolds number effects were shown to be insignificant.

EVALUATION OF GEP STACK HEIGHT

Excessive Concentrations for the Existing Stacks
The first step in evaluating the GEP stack height is to determine whether excessive concentrations
(as defined previously) occur for the exiting 61 m stacks. To make this determination, ground-level
concentrations were measured for various wind directions and wind speeds and the model concentrations
were converted to full scale values using equation 1.

A summary of the maximum hourly, 3-hourly and 24-hourly ground-level SO2 concentrations for the
existing stack configuration is given in Table 2. Three and 24-hour average concentrations were computed
from the hourly values using the conversions factors previously discussed. Table 2 shows that the maximum
hourly SO2 concentrations for existing Units 1, 2 and 3 stacks are 2823, 2960 and 3070 µg/m3. The maximum
combined concentration due all three stacks is 8812 µg/m3. The individual maxima do not all occur at the
same spacial location, however, the overall maximum is based on a single location. The table also shows that
the 3- and 24-hour concentrations are above the NAAQS for SO2 for each stack individually and for all stacks
combined. Hence, the first criteria for demonstrating an excessive concentration is met.

Table 2 also shows the ratios of maximum concentrations with and without the terrain and buildings
present. For the 247.5 degree wind direction with 6, 8 and 9.6 m/s wind speeds (at 6.1 m height), the ratios
are found to be greater than the critical value of 1.4 and the second excessive concentration criteria is met.

Hence, these results demonstrate that excessive concentration occur for the existing stacks serving
Units 1, 2 and 3 as a results of adverse aerodynamic downwash effects created by nearby terrain and
buildings. Based on this result, Met-Ed can construct and receive credit for a taller stack, provided the stack
height is less than or equal to the GEP stack height. The results from the next phase testing will be used to
specify the actual GEP stack height.

Wind Tunnel Determined GEP Stack Height

As discussed previously, wind tunnel modeling must also be used to determine the GEP stack height
based on the effect of nearby terrain if a stack height taller than the EPA formula height is desired. For this
determination the EPA stack height regulation defines GEP stack height as one that avoids excessive
concentrations (as defined previously).

Preliminary tests were conducted to determine the wind direction and wind speed that produce the
highest concentration and largest differences in concentrations with and without the nearby terrain. The
preliminary tests to evaluate wind direction indicated that the highest ground-level concentrations occur for
a wind coming from 247.5 degrees (see Figure 1). The wind speed tests showed that the highest ground level
concentrations occur for an anemometer wind speed of 4 m/s (6.1 m height). The effect of stack height was
then evaluated for the critical wind direction and wind speed. Figures 7 and 8 summarize the results. Figure
7 shows the maximum 3 and 24-hour SO2 concentration versus stack height for the 347.5 wind direction tests
with all terrain and structures present. The figure shows that the 3-hr NAAQS is exceeded at a 115 m stack
height and the 24-hour NAAQS is exceeded at a 175 m stack height.

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Figure 8 shows the concentration ratio (terrain amplification factor) versus stack height (normalized
by hill height). The figure shows that the concentration ratio is approximately 1.4 at a normalized stack
height of 575 ft (175 m). The figure also shows a comparison of the TGS data with curves developed by
Castro and Snyder1for an idealized 3-dimensional hill with a width to height ratio of 6 and infinity (2-
dimensional ridge) and a stack located at 1.25 times the cavity length distance (xr). The figures shows that
the TGS concentration ratios compare well with those presented by Castro and Snyder1.

Based these results, a 175 m stack was selected as the preliminary GEP stack height. Documentation
tests were then conducted to verify and validate that 175 m is the GEP stack height for TGS. The results of
these tests are summarized in Table 3. The table shows that the maximum hourly ground-level SO2
concentration for a 175 m stack at the existing Unit 2 stack location is 479 µg/m3. The hourly values were
converted to 3-hour 24-hour averages using the 0.9 and 0.542 conversion factors discussed previously. This
resulted in 3 and 24-hour maximum concentrations of 431.2 and 259.5 µg/m3. Adding the ambient
background concentrations to these values gives concentrations of 661 and 371 µg/m3. The 3-hour
concentration is below the NAAQS for SO2 (1300 µg/m3), but the 24-hour concentration exceeds the NAAQS
for SO2 (365 µg/m3). Table 3 also shows the ratios of the maximum concentration with and without the
nearby terrain present. All ratios measured for a 175 m stack are greater than the critical value of 1.4. Hence,
the documentation tests have proven that the GEP stack height is 175 m for TGS.

SUMMARY
This paper has described the methods whereby the GEP stack height for TGS was determined based
on the effect of nearby terrain. To make this determination, excessive concentrations were first demonstrated
for the exiting 61 m stack. Thereafter, testing was conducted to find the GEP stack height. This testing
showed that a 175 m stack is GEP based on the nearby Highs Hill. This stack height is 2.6 times the height
of the hill. The concentration ratios (terrain amplification factors) measured as part of this study were
compared with those obtained by Castro and Snyder1 for idealized 3-dimensional hills. Good agreement was
observed.

REFERENCES

1. Castro,I.P., and W.H. Synder, “A Wind Tunnel Study of Dispersion From Sources Downwind of
Three-Dimensional Hills,” Atmospheric Environment, Vol. 16, No. 8, pp. 1869-1887, 1982.

2. Petersen, R.L. and M. A. Ratcliff, "Terrain Wake Effect On Dispersion Coefficients and Ground
Level Concentrations" AM Eighth Symposium on Turbulence and Diffusion, San Diego, CA, April
26-29, 1988

3. Snyder, W.H., "Guideline for Fluid Modeling of Atmospheric Diffusion," US EPA, Environmental
Sciences Research Laboratory, Office of Research and Development, Research Triangle Park, NC,
27711, Report No. EPA-600/8-81-009, 1981.

4. Arya, S.P.S., and J.F. Lape, Jr., "A Comparative Study of the Different Criteria for the Physical
Modeling of Buoyant Plume Rise in a Neutral Atmosphere," Atmospheric Environment, Vol. 24A,
No. 2, pp. 289-295, 1990.

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5. Pennsylvania Commonwealth, "1990 Air Quality Report," Commonwealth of Pennsylvania,

Department of Environmental Resources, Bureau of Air Quality Control, Division of Technical
Services and Monitoring, DER#407-5/91.

6. Simonson, B., Personal Communication, June 1, 1992.

7. EPA, "Guideline for Determination of Good Engineering Practice Stack Height (Technical Support
Document for the Stack Height Regulation)," US EPA Office of Air Quality, Planning and
Standards, Research Triangle Park, NC, EPA-45014-80-023R, 1985a.

8. EPA, "Guideline for Use of Fluid Modeling to Determine Good Engineering Practice Stack Height,"
US EPA Office of Air Quality, Planning and Standards, Research Triangle Park, NC, EPA-450/4-81-
003, July, 1981.

9. Petersen, R.L., "Dispersion Comparability of the Wind Tunnel and Atmosphere for Adiabatic
Boundary Layers with Uniform Roughness," AMS Seventh Symposium on Turbulence and
Diffusion, Boulder, CO, November 12-15, 1985.

10. EPA, "Guidelines for Air Quality Maintenance Planning and Analysis Volume 10 (Revised):
Procedures for Evaluating Air Quality Impact of New Stationary Sources," US EPA Office of Air
Quality Planning and Standards, Research Triangle Park, North Carolina, EPA-450/4-77-011, 1977.

11. EPA, "Procedures for Implementing the Excessive Concentration Criteria Using Data from a Wind
Tunnel Demonstration," Fluid Modeling Demonstration of Good-Engineering-Practice Stack Height
in Complex Terrain, EPA 600/3-85-022, 1985b.

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Figure 1. Map showing Location of Titus Generating Station and area modeled.

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Figure 2. WSW through NNE terrain/plant cross-section for the Titus Generating Station.

Figure 3. Close-up plan view of Titus Generating Station showing the nearby buildings removed
configuration.

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Figure 4. Plan view of Titus Generating Station and turntable area modeled showing the nearby terrain
present configuration.

Figure 5. Plan view of Titus Generating Station and turntable area modeled showing the nearby terrain
removed configuration.

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Figure 6.CPP Boundary Layer Wind Tunnel

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Figure 7.Maximum 3- and 24-hour SO2 concentrations versus stack height.

Figure 8. Concentration ratio (or amplification factor) versus stack height for TGS compared with
values observed by Castro and Snyder1.

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