***
The Scheffe memo has been used as a screening method to demonstrate compliance with ozone standards based on a facility's VOC and NOx PTEs. The first link below is a poor-quality scanned version of the memo with "draft" stamped on several pages. The second link is from a Nevada web site; it's cleaner and doesn't have the draft markings, but it cautions that it's a recreation of the original and they don't guarantee its accuracy.
Scanned original (marked "draft")
Cleaned version on Nevada web site
Here's a table and chart based on the Scheffe method that was used for permitting a previous incarnation of the Montana Advanced Biofuels project (stored in project folder ACT203382).
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Thursday, August 18, 2011
Wednesday, August 17, 2011
Caterpillar Presentation - NESHAP Z4 & NSPS J4
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This is a presentation that Jeff picked up attending an Air Quality Technology Transfer meeting in Wyoming recently. It's from Caterpillar and describes requirements of the various tiers in the NESHAP ZZZZ and NSPS JJJJ subparts.
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This is a presentation that Jeff picked up attending an Air Quality Technology Transfer meeting in Wyoming recently. It's from Caterpillar and describes requirements of the various tiers in the NESHAP ZZZZ and NSPS JJJJ subparts.
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Biomass Wars
***
Here are two well-done web sites with opposite views on the benefits of using biomass for heat and power.
Partnership for Policy Integrity (OFPI)
National Alliance of Forestry Owners
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Here are two well-done web sites with opposite views on the benefits of using biomass for heat and power.
Partnership for Policy Integrity (OFPI)
National Alliance of Forestry Owners
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Sunday, August 7, 2011
State & Local Modeling Guidelines
***
Minnesota PCA. 10/2004.
MPCA modeling page. See especially modeling protocol forms and spreadsheet. (Page contains link to above guidance, but link didn't work when access attempted 8/11.)
San Joaquin Valley. Lots of useful guidance and data, especially regarding NOx modeling.
Iowa DNR. Lots of good stuff including:
Texas Commission on Enironmental Quality (TCEQ). As of today (8/19/11), modeling guidelines not posted but in work. Includes draft checklist and e-mail discussion group.
Arizona DEQ modeling guidance. This page links to a 2004 guidance document and includes a March 2011 update memo. The memo mostly adds AERMOD as the prefered short-range model and clarifies air toxics modeling requirements. The page also includes links to some EPA resources such as the RBLC, the applicability determination index, and two policy databases.
Bay Area Air Quality Management District (BAAQMD). June 2007. Mostly outlines requirements; not much by way of practical guidance.
New Mexico Environment Department Dispersion Modeling and Emissions Inventory Section. Extensive guidance, updated April 2010. Noticed it says the following about modeling wind erosion from piles: "Wind erosion of storage piles should not be modeled, as it says in AP42 not to use the equations for wind erosion in a steady state model." Site includes links to other resources.
South Carolina Dept. of Health and Environmental Control. 2001
Michigan DEQ. Last revised September 2009.
Ohio EPA. 2003. Q&A format. Not a lot here.
Haul Road Emissions Modeling. Last updated June 2004. According to this presentation at the May 2010 Modeler's Workshop in Portland, OR, the Haul Road Work Group is working to update its recommendations with a report due out early 2011. (This EPA R5 presentation says a report should be issued by fall 2011. I found nothing on the internet as of 11/7/11.)
Albuquerque Modeling Guidance. Includes road dust emissions guidelines, including this introductory discussion:
Minnesota PCA. 10/2004.
MPCA modeling page. See especially modeling protocol forms and spreadsheet. (Page contains link to above guidance, but link didn't work when access attempted 8/11.)
Iowa DNR. Lots of good stuff including:
- 20D "Screening Threshold Method for PSD Modeling; North Carolina Air Quality Section." Screening method for selecting nearby sources to include in a cumulative impacts analysis.
- Source Characterization Guidance and Tools. These include spreadsheets for calculating flare parameters and building volume source parameters. Documents provide guidelines on modeling haul roads, storage piles, storage tanks, truck and rail loadouts, and other specific types of sources.
- They also include guidance on the ambient ratio method for modeling annual average NO2 NAAQS compliance. But it hasn't been updated with any new information for modling 1-hour average compliance.
- They have a PSD modeling protocol template, but it's only a couple of pages and isn't nearly as extensive as we would need.
- VISCREEN tool.
- A spreadsheet that calculates shortest distance from a Class I area.
Texas Commission on Enironmental Quality (TCEQ). As of today (8/19/11), modeling guidelines not posted but in work. Includes draft checklist and e-mail discussion group.
Arizona DEQ modeling guidance. This page links to a 2004 guidance document and includes a March 2011 update memo. The memo mostly adds AERMOD as the prefered short-range model and clarifies air toxics modeling requirements. The page also includes links to some EPA resources such as the RBLC, the applicability determination index, and two policy databases.
Bay Area Air Quality Management District (BAAQMD). June 2007. Mostly outlines requirements; not much by way of practical guidance.
New Mexico Environment Department Dispersion Modeling and Emissions Inventory Section. Extensive guidance, updated April 2010. Noticed it says the following about modeling wind erosion from piles: "Wind erosion of storage piles should not be modeled, as it says in AP42 not to use the equations for wind erosion in a steady state model." Site includes links to other resources.
South Carolina Dept. of Health and Environmental Control. 2001
Michigan DEQ. Last revised September 2009.
Ohio EPA. 2003. Q&A format. Not a lot here.
Haul Road Emissions Modeling. Last updated June 2004. According to this presentation at the May 2010 Modeler's Workshop in Portland, OR, the Haul Road Work Group is working to update its recommendations with a report due out early 2011. (This EPA R5 presentation says a report should be issued by fall 2011. I found nothing on the internet as of 11/7/11.)
Albuquerque Modeling Guidance. Includes road dust emissions guidelines, including this introductory discussion:
"Careful examination of AP-42 for both Paved and Unpaved Roads shows the science of haul road modeling is dubious in nature. Furthermore, the WRAP Fugitive Dust handbook published November 2004 shows paving of haul roads and keeping those roads clean results in nearly 100 percent control of PM10 emissions. Modeling of paved haul roads will not be required if the applicant is willing to implement reasonably available control measures as specified below or if the applicant implements a department approved best management practices plan."
Monday, August 1, 2011
NEPA Significance
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Full article. Excerpt:
"According to the NEPA Regulations adopted by the President’s Council on Environmental Quality (CEQ) (40 CFR 1500-1508), the term significantly is based on the twin criteria of context and intensity (40 CFR 1508.27).
"Context means the affected environment in which a proposed action would occur; it can be local, regional, national, or all three, depending upon the circumstances."
"Intensity means the degree to which the proposed action would involve one or more of the following 10 factors:
• Adverse effects associated with “beneficial projects”;
• effects on public health or safety;
• unique characteristics of the geographic area (e.g., historic resources, park lands, prime farmland, wetlands, wild and scenic rivers, ecologically critical areas);
• degree of controversy;
• degree of highly uncertain effects or unique or unknown risks;
• precedent-setting effects;
• cumulative effects;
• adverse effects on scientific, cultural, or historical resources;
• adverse effects on endangered or threatened species or designated critical habitat (pursuant to the Endangered Species Act); and
• violations of federal, state, or local environmental law."
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Full article. Excerpt:
"According to the NEPA Regulations adopted by the President’s Council on Environmental Quality (CEQ) (40 CFR 1500-1508), the term significantly is based on the twin criteria of context and intensity (40 CFR 1508.27).
"Context means the affected environment in which a proposed action would occur; it can be local, regional, national, or all three, depending upon the circumstances."
"Intensity means the degree to which the proposed action would involve one or more of the following 10 factors:
• Adverse effects associated with “beneficial projects”;
• effects on public health or safety;
• unique characteristics of the geographic area (e.g., historic resources, park lands, prime farmland, wetlands, wild and scenic rivers, ecologically critical areas);
• degree of controversy;
• degree of highly uncertain effects or unique or unknown risks;
• precedent-setting effects;
• cumulative effects;
• adverse effects on scientific, cultural, or historical resources;
• adverse effects on endangered or threatened species or designated critical habitat (pursuant to the Endangered Species Act); and
• violations of federal, state, or local environmental law."
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Tuesday, July 26, 2011
NAAQS Statutory Requirements
***
From 42 U.S.C. §7409 (Chapter 85, Subchapter I, Part A; CAA §109)
(b) Protection of public health and welfare
From 42 U.S.C. §7409 (Chapter 85, Subchapter I, Part A; CAA §109)
(b) Protection of public health and welfare
(1) National primary ambient air quality standards, prescribed under subsection (a) of this section shall be ambient air quality standards the attainment and maintenance of which in the judgment of the Administrator, based on such criteria and allowing an adequate margin of safety, are requisite to protect the public health. Such primary standards may be revised in the same manner as promulgated.
(2) Any national secondary ambient air quality standard prescribed under subsection (a) of this section shall specify a level of air quality the attainment and maintenance of which in the judgment of the Administrator, based on such criteria, is requisite to protect the public welfare from any known or anticipated adverse effects associated with the presence of such air pollutant in the ambient air. Such secondary standards may be revised in the same manner as promulgated.
40 CFR 50.2 says:
(b) National primary ambient air quality standards define levels of air quality which the Administrator judges are necessary, with an adequate margin of safety, to protect the public health. National secondary ambient air quality standards define levels of air quality which the Administrator judges necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant. Such standards are subject to revision, and additional primary and secondary standards may be promulgated as the Administrator deems necessary to protect the public health and welfare.
I expected to see language about protecting sensitive populations but didn't. The only place that language is used (that I found during this quick investigation) is at 42 U.S.C. §7408(f)(1)(C) under the heading "Information regarding processes, procedures, and methods to reduce or control pollutants in transportation; reduction of mobile source related pollutants; reduction of impact on public health."It requires "information on other measures which may be employed to reduce the impact on public health or protect the health of sensitive or susceptible individuals or groups."
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40 CFR 50.2 says:
(b) National primary ambient air quality standards define levels of air quality which the Administrator judges are necessary, with an adequate margin of safety, to protect the public health. National secondary ambient air quality standards define levels of air quality which the Administrator judges necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant. Such standards are subject to revision, and additional primary and secondary standards may be promulgated as the Administrator deems necessary to protect the public health and welfare.
I expected to see language about protecting sensitive populations but didn't. The only place that language is used (that I found during this quick investigation) is at 42 U.S.C. §7408(f)(1)(C) under the heading "Information regarding processes, procedures, and methods to reduce or control pollutants in transportation; reduction of mobile source related pollutants; reduction of impact on public health."It requires "information on other measures which may be employed to reduce the impact on public health or protect the health of sensitive or susceptible individuals or groups."
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Tuesday, July 12, 2011
FAA Regulations Regarding Tall Stacks
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This regulation describes when and how one needs to consult with the FAA before building a tall structure that could potentially interfere with flight patterns. (14 CFR 77.9)
This study addresses potential safety risks due to thermal and visible exhaust plumes interfering with aircraft. They conclude the risk is very small.
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This regulation describes when and how one needs to consult with the FAA before building a tall structure that could potentially interfere with flight patterns. (14 CFR 77.9)
This study addresses potential safety risks due to thermal and visible exhaust plumes interfering with aircraft. They conclude the risk is very small.
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