Comment Log Display

The modeling files do not appear to provide reasonable accurate
inputs by vessel type, including providing for appropriate vessel
structure x,y,z parameters necessary to include stack downwash
effects. Disagree with using the noted 2006 study approach and
assumptions that does not factor in downwash, the previous modeling
methods that can be improved on should be improved. OGVs at berth
are obviously stationary and many or most of the stacks with these
OGVs are connected to or are closely associated with other tall
structures on these OGVs (primarily the bridge structures). Not
including appropriate downwash parameters will clearly affect the
results of the modeling analysis and this certainly would not be
allowed for the modeling of other "stationary" sources and should
not be allowed here. Other old 2006 study critical input
assumptions including the stack height, the stack velocity, and
stack diameter should have been confirmed/revised as necessary.
These factors can be related to the size/type of vessel more
explicitly, including the use of assumed engine size and load
factors available from POLA/POLB emissions inventory documents to
relate to appropriate diameter/velocity (total flow/plume rise) and
assumed stack height by vessel type can be better reasoned using
many available data sources...not improving on these old and most
likely inaccurate and overly static 2006 study input data
assumptions means the HRA analysis is severely flawed before
running the model.

Original File Name:

Date and Time Comment Was Submitted: 2018-12-17 14:27:26