Updated FLAG Document

Click on title to go to a National Park Service page with a link to the October 2010 updated FLAG document.

MDEQ Modeling Guidance

1998 Policy Memo -- When Modeling is Required

Draft 2007 Modeling Guideline Document
...

Wind Erosion Calculation

Notes on wind erosion calculations, AP-42 13.2.5 method:

AP-42 13.2.5 with notes

Calculation Notes

Fastest mile vs. 3-sec gusts 1

Fastest mile vs. 3-sec gusts 2

Fastest mile vs. 3-sec gusts 3

ASOS User's Guide
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Wyoming 3-Year Emissions Inventory

Wyoming DEQ website for emission inventory information:
http://deq.state.wy.us/aqd/ei.asp

Here's the introduction with my assumed updates inserted:

In accordance with 40 CFR part 51, Subpart A, states are required to report total state-wide emissions to the United States Environmental Protection Agency (EPA) every three years. Calendar year 2008 [2011] marks the third [fourth] year for the reporting period for which emission inventories are required to be collected by each state and submitted to EPA for the National Emissions Inventory. As such, the Wyoming Department of Environmental Quality (DEQ), Air Quality Division (AQD) is requiring each minor source located in the state of Wyoming to complete an air emissions inventory for calendar year 2008 [2011]. The completed 2008 [2011] Annual Minor Source inventory should be returned to the AQD no later than September 15, 2009 [presumably 2012]. This emission inventory information is required to be submitted to the Division, pursuant to W.S. 35-11-110(a)(vii).

WDEQ recently conducted a series of workshops around the state to share information about completing inventories for O&G sources. I e-mailed Scott Faber asking for presentation materials from these sessions. Here's his reply:

Kevin,

At the workshops, we had an introductory powerpoint presentation that gave some general background information on emission inventories, and then we went through the minor source inventory forms (spreadsheets). We will be posting the powerpoint presentation on our website in the coming weeks, and the tri-annual minor source inventory forms for 2008 are still posted on our website at http://deq.state.wy.us/aqd/ei.asp. You can look over those forms to see what kind of emissions information we will be requesting for 2011, and we will post the forms for 2011 later next year when we have made some updates to them. The main change being that we will be asking for PM2.5 emissions along with PM10.

Tailoring Rule Guidance, November 2010

GHG PSD and Title V Guidance

Regarding biogenic emissions sources, EPA indicates that it's still unsure of how to account for them and plans to issue further guidance next year. It's interesting how they think May of 2011 is "well before the start of the second phase of PSD implementation pursuant to the Tailoring Rule"; heck, that could give someone one or two whole months to respond! Here's a relevant section from the document:

“…numerous stakeholders requested that EPA exclude, either partially or wholly, emissions of GHG from bioenergy and other biogenic sources for the purposes of the BACT analysis and the PSD program based on the view that the biomass used to produce bioenergy feedstocks can also be a carbon sink and therefore management of that biomass can play a role in reducing GHGs. EPA plans to provide further guidance on the [sic] how to consider the unique GHG attributes of biomass as fuel.

“Even before EPA takes further action, however, permitting authorities may consider, when carrying out their BACT analyses for GHG, the environmental, energy and economic benefits that may accrue from the use of certain types of biomass and other biogenic sources (e.g., biogas from landfills) for energy generation, consistent with existing air quality standards. In particular, a variety of federal and state policies have recognized that some types of biomass can be part of a national strategy to reduce dependence on fossil fuels and to reduce emissions of GHGs. Federal and state policies, along with a number of state and regional efforts, are currently under way to foster the expansion of renewable resources and promote biomass as a way of addressing climate change and enhancing forest-management. EPA believes that it is appropriate for permitting authorities to account for both existing federal and state policies and their underlying objectives in evaluating the environmental, energy and economic benefits of biomass fuel. Based on these considerations, permitting authorities might determine that, with respect to the biomass component of a facility’s fuel stream, certain types of biomass by themselves are BACT for GHGs. To assist permitting authorities further in considering these factors, as well as to provide a measure of national consistency and certainty, EPA intends to issue guidance in January 2011 that will provide a suggested framework for undertaking an analysis of the environmental, energy and economic benefits of biomass in Step 4 of the top-down BACT process, that, as a result, may enable permitting authorities to simplify and streamline BACT determinations with respect to certain types of biomass.

“… Finally, EPA also plans to determine by May 2011, well before the start of the second phase of PSD implementation pursuant to the Tailoring Rule, whether the issuance of a supplemental rule is appropriate to address whether the Clean Air Act would allow the Agency and permitting authorities or permitted sources, when determining the applicability of PSD permitting requirements to sources of biogenic emissions, to quantify carbon emissions from bioenergy or biogenic sources by applying separate accounting rules for different types of feedstocks that reflect the net impact of their carbon emissions.” pages 9 & 10

Regarding BACT:
Refers to technical “white papers” that provide industry-sector-specific GHG BACT guidance, but it doesn’t say where to find these documents. (page 21)

The guidance explicitly requires consideration of alternate processes that may have better energy efficiency. They offer an example of comparing a supercritical and subcritical coal fired boiler (page 22). The guidance presents a detailed analysis of this issue starting on page 27.
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GHG Reporting, Subpart W, Petroleum and Natural Gas Systems

Final rule published 11/8/10; published in Federal Register 11/30.
Final Rule

Here's an overview article published March 2011 in the Air Pollution Consultant on-line magazine (available through Cyber Regs). (Added 6/14/11, KMM)


All the Part 98 subparts are collected here:
GHG Reporting Rule Web Site

Here's the text relating monitoring and QA/QC requirements (§98.234):

The GHG emissions data for petroleum and natural gas emissions sources must be quality assured as applicable as specified in this section. Offshore petroleum and natural gas production facilities shall adhere to the monitoring and QA/QC requirements as set forth in 30 CFR 250.

(a) You must use any of the methods described as follows in this paragraph to conduct leak detection(s) of equipment leaks and through-valve leakage from all source types listed in §98.233(k), (o), (p) and (q) that occur during a calendar year, except as provided in paragraph (a)(4) of this section [which requires optical imaging for inaccessible areas as defined].

(1) Optical gas imaging instrument. Use an optical gas imaging instrument for equipment leak detection in accordance with 40 CFR part 60, subpart A, §60.18(i)(1) and (2) of the Alternative work practice for monitoring equipment leaks [This is italicised in the original. It would seem to refer to some document, but word searching this rule yielded no other occurrence.]. Any emissions detected by the optical gas imaging instrument is a leak unless screened with Method 21 (40 CFR part 60, appendix A-7) monitoring, in which case 10,000 ppm or greater is designated a leak. In addition, you must operate the optical gas imaging instrument to image the source types required by this subpart in accordance with the instrument manufacturer’s operating parameters.

(2) Method 21. Use the equipment leak detection methods in 40 CFR part 60, appendix A-7, Method 21. If using Method 21 monitoring, if an instrument reading of 10,000 ppm or greater is measured, a leak is detected. Inaccessible emissions sources, as defined in 40 CFR part 60, are not exempt from this subpart. Owners or operators must use alternative leak detection devices as described in paragraph(a)(1) of this section to monitor inaccessible equipment leaks or vented emissions.

(3) Infrared laser beam illuminated instrument. Use an infrared laser beam illuminated instrument for equipment leak detection. Any emissions detected by the infrared laser beam illuminated instrument is a leak unless screened with Method 21 monitoring, in which case 10,000 ppm or greater is designated a leak. In addition, you must operate the infrared laser beam illuminated instrument to detect the source types required by this subpart in accordance with the instrument manufacturer’s operating parameters.

(4) Optical gas imaging instrument. An optical gas imaging instrument must be used for all source types that are inaccessible and cannot be monitored without elevating the monitoring personnel more than 2 meters above a support surface.

(5) Acoustic leak detection device. Use the acoustic leak detection device to detect through-valve leakage. When using the acoustic leak detection device to quantify the through-valve leakage, you must use the instrument manufacturer’s calculation methods to quantify the through-valve leak. When using the acoustic leak detection device, if a leak of 3.1 scf per hour or greater is calculated, a leak is detected. In addition, you must operate the acoustic leak detection device to monitor the source valves required by this subpart in accordance with the instrument manufacturer’s operating parameters.

Comments:

• Is acoustic leak detection (5) limited to only a subset of required monitoring? Appears that way.
• It looks like (4) is an extension of (1) and indicates that, in some cases, using a camera is the only option.

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SO2 Modeling Guidance

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Although this guidance offers a "first tier" approach of using the "overall highest hourly background SO2 concentration from a representative monitor" (emphasis added), it goes on to seemingly stress the appropriateness of applying professional judgment when characterizing background by modeling nearby sources and by using monitoring data. It even goes so far as to suggest that you don't necessarily have to follow the modeling guidance in the 1980 Draft NSR Workshop Manual.

EPA SO2 Modeling Policy Memo, August 2010

I noticed, too, that Appendix W seems to encourage efforts to avoid double counting through use of modeling and monitored data. This link accesses a copy of the current version of Appendix W:

EPA SCRAM site with link to Appendix W

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PM2.5 Implementation History and BACT Analysis

This is something I submitted to Indiana Department of Environmental Quality for the Synergy Management lime plant permit application in September 2010. The implementation history may be of general interest (though as of a couple of weeks ago, a third implementation rule was finalized). Its usefulness is limited now and rapidly diminishing, but interesting nonetheless. Don't know yet if the agency bought everything, but they at least seem to be seriously considering it.

PM2.5 Implementation Discussion

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Nexterra - Gasification Technology

This is the gasification technology targetted for the proposed U of M Missoula biomass boiler:

Nexterra - Gasification Technology

NSPS & NESHAP References

Texas Commission on Environmental Quality (CEQ) collection of NSPS and NESHAP. Many include flow charts and requirement reference tables:

NSPS

NESHAP

______________________

Nebraska DEQ website with lots of helpful information regarding specific NESHAPs (true at least for Subpart ZZZZ):

Nebraska DEQ Air Toxics Notebook -- Guide to NESHAPs

Nebraska DEQ NSPS notebook
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Refinery Emissions Estimation

EPA's proposed guidelines for estimating emissions from oil refinery sources:

Review Version Dec. 2009

Public Comments March 2010

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Montana Legislature: Publications and Reports - Environmental Quality Council

Several possibly useful publications from the Montana Environmental Quality Council. Note especially the 2010 "Permitting in Montana" document and the 2008 "Montana Index of Environmental Permits" documents. The first includes a nice graphic of permitting steps and timelines for air quality. The second is a 261 page description of all the permits that may apply to a large variety of projects.

Montana Legislature: Publications and Reports - Environmental Quality Council

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PM2.5 Implementation

Cyra sent this summary to Joe Peterson on 10/6:

PM2.5 Implementation Highlights

Notice the increments don't become effective until one year after publication in the federal register, which occurred October 20, 2010:

Final Rule, Federal Register Notice, October 20, 2010

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MDEQ Confidential Business Information Policy

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MDEQ Confidential Business Information Policy

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Equipment Leak Fugitive VOC Emissions Estimation

EPA-453/R-95-017

See Tables 2-1 through 2-4 for source-category-specific emission factors. Multiply kg/hr by 2.2046 to get lb/hr.

1995 Protocol for Equipment Leak Emissions Estimates

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GHG Tailoring Rule

The rule (via the preamble only) will allow Step 1 "anyway" sources to commence construction after January 2, 2011 without considering GHG emissions as long as their permit was issued before that date. But Step 2 sources (those who become major after July 1, 2011 due solely to GHG emissions) must "begin actual construction" before 7/1/11. If they have a final permit but don't begin actual construction--which does not include the consideration of having entered into binding contracts--they will have to reopen the permit to include consideration of GHGs. See 75 FR 31527. A discussion of reasoning behind this begins on 75 FR 31593.

The rule establishes a "subject to regulation" definition for GHGs that contains the 100K and 75K tpy thresholds for CO2e. Once these thresholds are surpassed, then the source must determine major source/modification status based on the mass emissions of combined GHGs relative to the standard 100/250 tpy thresholds. In this case, the source may not be major if it has low CO2 emissions and moderate emissions of a high GWP pollutant such as N2O (because each GHG is added based on its mass only, without multiplying by its GWP).

This "subject to regulation" approach somehow facilitates adoption by SIP-approved states such that the rule becomes effective in all states at the same time.

It appears that, in Step 2, a major modification must 1) result in a net CO2e increase greater than 75k tpy and 2) occur at a facility with a CO2e PTE of >100k tpy. CONFIRM

Highwood Generating Station nears last hurdle

Forest Service NEPA Handbook

Handbook Chapters

New Transmission Siting and Permitting

Three 2009 Marten Law articles

March
Battle Over Transmission Siting: Congress Considers Federalizing Permit Process, While Fourth Circuit Upholds States’ Right to Control It

May
Sparks Fly as Agencies, Courts, States, and Congress Battle Over Who Is In Charge of Transmission Lines

December
Federal Agencies Issue MOU to Speed Siting of Electric Transmission Lines on Federal Land; Congress Still Debating Siting Legislation

NEPA & Climate Change

Two Marten Law articles:

Ninth Circuit Requires Climate Change Analysis under NEPA; 11/2007

CEQ Marks 40th Anniversary of NEPA With New Guidance on Greenhouse Gas Impacts, Mitigation and Categorical Exclusions; 2/2010

_______________________________________________
Excerpts from 2/2010 Draft guidance from the CEQ:

"NEPA demands informed, realistic governmental decision making. CEQ proposes to advise Federal agencies to consider, in scoping their NEPA analyses, whether analysis of the direct and indirect GHG emissions from their proposed actions may provide meaningful information to decision makers and the public. Specifically, if a proposed action would be reasonably anticipated to cause direct emissions of 25,000 metric tons or more of CO2-equivalent GHG emissions on an annual basis, agencies should consider this an indicator that a quantitative and qualitative assessment may be meaningful to decision makers and the public. For long-term actions that have annual direct emissions of less than 25,000 metric tons of CO2-equivalent, CEQ encourages Federal agencies to consider whether the action’s long-term emissions should receive similar analysis. CEQ does not propose this as an indicator of a threshold of significant effects, but rather as an indicator of a minimum level of GHG emissions that may warrant some description in the appropriate NEPA analysis for agency actions involving direct emissions of GHGs."

"With regards to the effects of climate change on the design of a proposed action and alternatives, Federal agencies must ensure the scientific and professional integrity of their assessment of the ways in which climate change is affecting or could affect environmental effects of the proposed action. 40 CFR 1502.24. Under this proposed guidance, agencies should use the scoping process to set reasonable spatial and temporal boundaries for this assessment and focus on aspects of climate change that may lead to changes in the impacts, sustainability, vulnerability and design of the proposed action and alternative courses of action. At the same time, agencies should recognize the scientific limits of their ability to accurately predict climate change effects, especially of a short-term nature, and not devote effort to analyzing wholly speculative effects. Agencies can use the NEPA process to reduce vulnerability to climate change impacts, adapt to changes in our environment, and mitigate the impacts of Federal agency actions that are exacerbated by climate change."

_________________________________________________

Climate Change Impacts Report; 6/2009

From the report home page:

"This web page will introduce and lead you through the content of the most comprehensive and authoritative report of its kind. The report summarizes the science and the impacts of climate change on the United States, now and in the future. It focuses on climate change impacts in different regions of the U.S. and on various aspects of society and the economy such as energy, water, agriculture, and health."

"In addition to discussing the impacts of climate change in the U.S., the report also highlights the choices we face in response to human-induced climate change. It is clear that impacts in the United States are already occurring and are projected to increase in the future, particularly if the concentration of heat-trapping greenhouse gases in the atmosphere continues to rise. So, choices about how we manage greenhouse gas emissions will have far-reaching consequences for climate change impacts. Similarly, there are choices to be made about adaptation strategies that can help to reduce or avoid some of the undesirable impacts of climate change. This report provides many of the scientific underpinnings for effective decisions to be made – at the national and at the regional level."

King County, WA, Climate change worksheet

"King County is the first local government in the nation to officially add greenhouse gas emissions to the environmental review of construction projects. King County's policy covers projects undergoing environmental review mandated by the SEPA and applies to the County's own developments as well as projects where the County is the lead permitting agency.

 

"GHG emissions associated with development come from multiple sources:

• The extraction, processing, transportation, construction and disposal of building materials
• Landscape disturbance
• Energy demands created by the development after it is completed 

"Transportation demands created by the development after it is completed.
King County has developed a GHG emissions worksheet that can assist applicants in answering the SEPA checklist question relating to GHG emissions. The worksheet is available as a fill-in Excel spreadsheet** or in PDF** format."

The SEPA GHG emissions worksheet estimates all GHG emissions that will be created over the life span of a building project. This includes emissions associated with obtaining construction materials, fuel used during construction, energy consumed during the buildings operation, and transportation by building occupants."

 

Dept. of Development and Environmental Services Climate Change Home Page

North Dakota Air Toxics Policy Revision

Primarily a significant increase in the unit risk factor for formaldehyde and case-specific option for use of screening model other than ISC Screen3.

Memo

Industrial Stormwater Links & Guidance, Minnesota PCA

Lots of useful tips and guidance on this web site provided by the Minnesota Pollution Control Agency:

MPCA Industrial Stormwater Home Page

"Running With Oil" Stories About North Dakota's Oil Boom

""Running with Oil,” a series of reports on North Dakota’s booming oil industry, appeared Aug. 15 through Aug. 22 2010 in the North Dakota newspapers of Forum Communications Co.: The Dickinson Press, The Forum of Fargo-Moorhead, the Grand Forks Herald and the Jamestown Sun. Each day of the series is archived on this site. Choose the day you'd like to view from the navigation bar above." (Click on title to go to home page.)

North Dakota O&G Map

Zoom in to location of any well or gas plant within the state.

Legal Challenge to MACT Methodology

Challenge is based on two points:

• EPA looks at separate facilities acheiving low emission rates for distinct pollutants, then combines all those into one standard.
• EPA bases their achievability determinations on performance for a single year, ignoring multi-year variability.

Because of these two factors, EPA's MACT floors are not "achieved in practice."

InsideEPA.com Article

Amendments to Cement MACT & NSPS

"On August 6, 2010, EPA issued amendments to two rules that will significantly reduce emissions of mercury and other air toxics and particle-forming pollutants from new and existing Portland cement kilns across the United States. The rules also will limit emissions of ozone- and particle-forming pollutants from new kilns."

Cement MACT-NSPS Fact Sheet

Final Rule 9/9/2010

Flare Guidance (Modeling, Emissions, etc)

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Flare Modeling Guidance from NDDH

Iowa DNR guidance and spreadsheet tool -- links on this page

Texas Natural Resources Conservation Commission


(updated post 8/19/2011, KMM)
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Proposed Transport Rule (CAIR Replacement) Article

"A new rule proposed by the Environmental Protection Agency would regulate emissions from coal-fired power plants in Eastern and Midwestern states.[1] Known as the Transport Rule, EPA’s proposed regulation replaces EPA’s Clean Air Interstate Rule (CAIR), which would have established an interstate trading program for sulfur dioxide (SO2) and nitrogen oxides (NOx) emissions from power plants."

Proposed Transport Rule Article
(Martin Law article)

WCI Final Design of C&T System

"On July 27, 2010, the Western Climate Initiative (WCI) released the Final Design for its regional cap-and-trade program...However, the sustained economic downturn has withered state-level support for the WCI and cast doubt over the extent to which the program will be implemented by WCI’s January 2012 deadline. Some member states have expressly withdrawn support for the program, while others have indicated that they will not have regulations in place necessary to meet the January 1, 2012, implementation deadline. Nonetheless, the Final Design represents the clearest and most detailed articulation of an alternative to comprehensive federal climate change regulation."

WCI C and T Final Design Article
(Martin Law article)

Congressional Opposition to Proposed CCR Rule

"Republicans are considering using the Congressional Review Act (CRA) to formally disapprove and undo EPA's pending final coal waste disposal rule if the agency classifies the waste as hazardous, with the GOP saying it expects bipartisan support for the legislative maneuver given lawmakers' existing concerns over the proposed rule."

CCR Rule Congressional Oposition Article
(InsideEPA.com article)

Oil & Gas Regulation Developments

“A recently created task force in EPA Region III is exploring options to use existing tools such as targeted enforcement and permit objections to impose stricter environmental protection standards on fossil fuel extraction in the key energy states of Pennsylvania, Virginia and West Virginia -- which include growing natural gas drilling operations and a heavy coal mining presence.”

EPA Resource Extraction Task Force article


An article from InsideEPA.com focusing on Texas vs. EPA differences in aggregating O&G facilities. It includes a link to TCEQ’s proposed rule (also linked below) which contains a wealth of information about O&G field operations and much detail regarding proposed regulations. There’s a lot there in 121 pages. One thing I noted that seemed a little strange is that any refined modeling would be done using ISC.

Proposed TCEQ OG Rules Article

TCEQ proposed OG rules

Handling Pricing Pressure

"The experts say that competing on price does little to ensure customer loyalty and everything to ensure that you’ll play the price game each time you bid on a project. In the environmental industry, slashing prices has become a knee-jerk reaction for those who are unprepared to counter pricing pushback from potential clients with value-based sales tactics."

Pricing Pressure Article

Montana Standard Article: Crowd rails on MSTI proposal

MSTI Article

Engineering Math Science Calculators

A whole bunch of scientific and engineering calculators:

Calculators Home Page

Refinery NSPS

Here are a couple articles about Petroleum Refinery NSPS Subparts J and Ja:

Summary 1 of NSPS Subparts J and Ja

Shorter Summary of NSPS Subparts J and Ja

This article focuses specifically on enforcement and regulation of flare emissions at refineries:

Flare Enforcement Trends

Air Dispersion Conversions and Formulas

Web site for the "Fundamentals of Stack Gas Dispersion" book.

This page includes:

• mg/m3 <--> ppmv
• calculation of gas densities
• Pasquill stability classes
• mass flow rates <--> volume flow rates
• exhaust gas generated from combustion of fuels
• correcting concentrations to reference conditions
• etc.......

 

Conversions and Formulas

Oil Production Air Registration and Permitting - General

MDEQ and MPA training presentation, August 2009:

MDEQ O&G Permitting and Registration Training Presentation, 8/2009

Montana Oil and Gas Registration & Compliance Flow Chart

Bret prepared this for some of his clients, July 2010:

Flow Chart

Proposed Solid Waste Definition and Incineration Rules

Proposed changes to CISWI NSPS and emission guidelines. Note that cement kilns were exempt but would not be under the proposed rule.

Proposed Changes to CISWI NSPS

Proposed definition of solid waste would generally exclude clean biofuel and TDF (after removal of steel belts and wires).

New Solid Waste Definition Proposed

Final 1-hr SO2 Standard and Fact Sheet

1-hr SO2 Fact Sheet

SO2 1-hr Stnd, Final 6/22/10

New NO2 Air Standards Prove Technically Challenging

This article from Trinity Consultants refers to June 28, 2010 modeling guidance from EPA (link below) that doesn't actually provide much guidance, but it does suggest an interim SIL. It also reports a SIL that NESCAUM states are using. The article discusses methods for estimating NO/NO2 ratios.

Trinity Consultants - New NO2 Air Standards Prove Technically Challenging

EPA NO2 Modeling Guidance 6/2010

MAR Proposal of De Minimis Rule Change

Proposed de minimis rule change:
Administrative Rules of the State of Montana

Handy Pocket Reference

This is a useful general reference from GE Energy. It seems to be geared toward air quality regulations and related calculations. In addition to conversion factors and equations, it includes a map of EPA regions and listings of air regulations and HAPs.

GE Energy Pocket Reference Book

Plant Cost Indices

June 2010 Economic Indicators

Valve Stem Sealing to Minimize Fugitive VOC Emissions

Chem Engineering article about standards and seals for valve stems.

Article

NO / NO2 Ratios

Here's some background information on estimating ratios of NO and NO2:

2000 Proposed Appendix W OLM Discussion

NO2 Estimating Review

1996 EPA OLM Memo

Diesel Engine NO2 MDEQ E-mail

PM2.5 PSD Implementation

Address SILs, condensibles, precursors, significant increase thresholds, increment (none yet), etc.

Proposed Rule, September 2007

Final Rule, May 2008

Ethanol Major Source Exclusion

Federal Exclusion of Ethanol Manufacturing from PSD Listed Sources

Billings-Laurel FIP

Billings-Laurel FIP - proposed

Billings-Laurel FIP - final

Sample Checklist of New Project Environmental Requirements

Environmental Rqmnts Checklist Sample

Tank Flashing Emissions - New Mexico guidelines

Tank Flashing Emissions Guidelines, New Mexico

Proposed CBC MACT Guidance

Article about state comments to proposed rule/guidance. They'd rather EPA focused on fixing whatever situation is requiring case-by-case analysis.

Article

NWE Starts New Ad Campaign (MSTI Related)

2010 State/Local Modelers Workshop

Presentations from the:

EPA Regional State/Local Modelers Workshop

Excerpts of PSD visibility rules

Selection of PSD Visibility Rules

Lifecycle Assessment

Even if we don't work on any true lifecycle assessments, many EIS climate change analyses will likely employ LCA methodology. Here are a couple LCA references.

EPA / AWMA LCA Webinar slides

LCA article

Portable & Temporary Source Applicability Notes

This issue has come up many times. One example was Title V major source applicability and inclusion, or not, of generators for lights at a mine. Another example was the need to permit a power generator for construction at a power plant. There are a variety of considerations and applications. Thompson River Power was forced to add to their permit combustion emissions related to curing their refractory brick. During the power shortages of the early 2000's, MDEQ forced the permitting of diesel locomotives that were going to be used as temporary generators, even though it could be argued that they were temporary and mobile sources (and MAR 17.8.744 specifically excludes from permitting requirements "mobile emitting units, including motor vehicles, trains, aircraft, and other such self-propelled vehicles.")

Federal rules key on the definition of "stationary source." (Surprisingly, the Montana minor source rules don't use that term.) Mobile sources are obviously not stationary. Non-road engines too are seemingly not meant to be included in the CAA rules that govern stationary sources. First, they have their own (extensive) set of rules. Second, the three alternative defining characteristics speak to mobility: "self propelled", "propelled", and "portable or transportable."

It's the last nonroad engine characteristic, though, that muddies the waters a bit. First, there is a caveat that the otherwise-nonroad engine must not stay in one location for more than 12 months - or less for a seasonal source. Note, too, that a "location" is any "single site at a building, structure, facility or installation." (See links below to my notes and Iowa guidance.) The implication is that a nonroad engine that stays in one place for too long becomes a stationary source.

Then there's potentially some confusion about permitting requirements for a "portable" source. On one hand, nonroad engines that are classified as such due to their portability, would seem to be exempt from stationary source permitting. On the other hand, federal and state regs require permitting of portable sources. The federal rules refer to a "portable stationary source" and provide for moving it without going through the permitting process; but the provision assumes the source was permitted in the first place. Montana regs don't use the "portable stationary source" terminology, but provide for transferring a permit from one location to another (ARM 17.8.765). By that, they clearly mean moving an already-permitted piece of equipment.

So here's one interpretive summary:
-- Emissions from self-propelled sources do not need to be permitted and should not be included in a facility's PTE. (An exception to this, at least in practice, is fugitive road dust that results from the operation of self-propelled sources. These emissions typically are included in a source's PTE. I suppose the distinction is that road dust is an indirect, not a direct, mobile source emission.)
-- Nonroad engines that are portable but not self- or otherwise propelled do not need to be permitted and should not be included in a facility's PTE, EXCEPT...
-- Nonroad engines that will stay in one location for more than a year (or more than 3 months each year for a seasonal source) should be considered a stationary source. But, the engine can move even within the facility to be considered as having not stayed at one location.
-- Other, non-engine portable sources should be considered to be stationary sources and require permitting.
-- It appears that, from the regulatory definitions, construction-related emissions should be considered to be secondary and to not contribute to the potential emissions of the source being constructed.
-- I suppose, though, that the construction emissions could constitute a permittable source in and of themselves. This gets into the concept of "temporary" sources which is even less clear than mobile and portable. At least one bit of EPA policy indicates that temporary sources should not be permitted under federal rules. But I've seen no definition of "temporary", and EPA may no longer fully agree with that policy. Further, I'm not aware of any guidance at all on the state level regarding temporary sources. One thing to consider would be whether a source is temporary only in the sense that it will operate at a single location for a limited time, in which case it may be more appropriately deemed a portable source.

Advanced NSR Guidance notes and Regulatory definition

EPA letter addressing "portable stationary" sources

ICE NSPS and NESHAP Applicability FAQs, Iowa DNR, 11/2209


More stuff specific to off-road engines (8/6/2010):

Cloud Peak Energy prepared the following letter to MDEQ analyzing NSPS, PSD and Title V exclusions for off-road engines.

Off-road Engine Emissions for Major Source Determinations

Here's a more complete citation of the NSPS exclusion:

40 CFR Part 60‚ Section 4219‚ Paragraph (Stationary_internal_co) [NSPS Subpart IIII]

Stationary internal combustion engine means any internal combustion engine, except combustion turbines, that converts heat energy into mechanical work and is not mobile. Stationary ICE differ from mobile ICE in that a stationary internal combustion engine is not a nonroad engine as defined at 40 CFR 1068.30 (excluding paragraph (2)(ii) of that definition), and is not used to propel a motor vehicle or a vehicle used solely for competition. Stationary ICE include reciprocating ICE, rotary ICE, and other ICE, except combustion turbines.

40 CFR Part 1068‚ Section 30‚ Paragraph (Nonroad_engine)

Nonroad engine means:

(1) Except as discussed in paragraph (2) of this definition, a nonroad engine is an internal combustion engine that meets any of the following criteria:
(i) It is (or will be) used in or on a piece of equipment that is self-propelled or serves a dual purpose by both propelling itself and performing another function (such as garden tractors, off-highway mobile cranes and bulldozers).
(ii) It is (or will be) used in or on a piece of equipment that is intended to be propelled while performing its function (such as lawnmowers and string trimmers).
(iii) By itself or in or on a piece of equipment, it is portable or transportable, meaning designed to be and capable of being carried or moved from one location to another. Indicia of transportability include, but are not limited to, wheels, skids, carrying handles, dolly, trailer, or platform.

(2) An internal combustion engine is not a nonroad engine if it meets any of the following criteria:

(i) The engine is used to propel a motor vehicle, an aircraft, or equipment used solely for competition.

(ii) The engine is regulated under 40 CFR part 60, (or otherwise regulated by a federal New Source Performance Standard promulgated under section 111 of the Clean Air Act (42 U.S.C. 7411)).

(iii) The engine otherwise included in paragraph (1)(iii) of this definition remains or will remain at a location for more than 12 consecutive months or a shorter period of time for an engine located at a seasonal source. A location is any single site at a building, structure, facility, or installation. Any engine (or engines) that replaces an engine at a location and that is intended to perform the same or similar function as the engine replaced will be included in calculating the consecutive time period. An engine located at a seasonal source is an engine that remains at a seasonal source during the full annual operating period of the seasonal source. A seasonal source is a stationary source that remains in a single location on a permanent basis (i.e., at least two years) and that operates at that single location approximately three months (or more) each year. See §1068.31 for provisions that apply if the engine is removed from the location.

Suit Filed Over MSTI

Another fly in the ointment.

Senate Climate Bill Introduced Amid Considerable Fanfare, and an Uncertain Future

Good summary and analysis of the new Senate cap & trade bill...

Senate Climate Bill article (Marten Law)

Accounting for fugitive eimssions in determining major PSD modifications

In December of 2008 EPA issued a final rule that revised the NSR rules so that fugitives would be considered consistantly for major source and major modification determinations. Previously, all sources had to credit fugitive emissions in determining whether a change was major, but only listed sources had to include fugitives when determining major source status. With the December 2008 rule change, only listed sources had to credit fugitive emissions for both major source and major modification determinations. Unlisted sources would not have to inlclude fugitives for either type of determination.

On Sept. 30, 2009, EPA stayed the December 2008 rule change for 3 months and issued an additional 3-month stay on December 31, 2009. Then, on March 31, 2010, EPA extended the stay for an additional 18 months. As a result, at least until October 3, 2011, all sources -- listed and unlisted -- must count fugitive emissions toward determination of a major modification. Major source determination remains as it always has been (count fugitives only if you're a listed source).

Here's a link to the December 2008 fact sheet.
EPA New Source Review: Fact Sheet

GHG Tailoring Rule

Highlights:

Jan 2, 1011 to June 30, 2011:
Only sources that are major due to emissions of a non-GHG pollutant would be subject to PSD and Title V if their CO2e PTE is 75,000 tpy or more.

July 1, 2011 and on:
Sources would not have to be major for a non-GHG in order to be major due to GHG emissions. The major source threshold for PSD and Title V will be 100,000 tpy CO2e. The major modification threshold for PSD will be 75,000 tpy CO2e.

By July 1, 2012:
EPA will complete rulemaking to address smaller sources of GHGs.

The rule does not provide any BACT guidance, but EPA recognizes the need and is working on it. They plan to issue technical guidance and tools by June 2010 and policy guidance by the end of 2010.

Fact sheet link

Final rule link

EPA's Science Advisory Committee comments on potential PM standards revisions

The Clean Air Scientific Advisory Committee's Particulate Matter Review Panel supports:
-- setting secondary PM standards in terms of light extinction values rather than mass concentration values, and
-- lowering current primary PM2.5 standards

BNA article

Part 71 Minor Source Transition Policy

2/11/2010 e-mail from EPA R8 to Marathon Oil Company regarding implementation of the "Part 71 50% PTE Transition Policy." Link to the policy memo is included at the end of the post.

_________________________________________
Mr. Blanco,

EPA Region 8 received your letters dated February 10, 2009, announcing Marathon Oil's intention of utilizing the Part 71 50% PTE Transition Policy. Three facilities were identified in your submittals:

--Wolding 14-24H Oil & Gas Production Facility operating on the Fort Berthold Reservation

--Jay Sandstrom 34-31H Oil & Gas Production Facility operating on the Fort Berthold Reservation

--AH 34-23H Oil and Gas Production Facility operating on the Fort Berthold Reservation.

The purpose of the Transition Policy is allow those sources not otherwise subject to Part 71 permitting whose PTE is less than 50% of the trigger level for Part 71 (100 tpy) to avoid part 71 permitting until such time that a minor pre-construction permitting program is promulgated for sources operating in Indian Country.

This policy does not apply to avoiding pre-construction PSD permitting or NESHAP standards. It only applies to avoiding the Part 71 operating permit program for those sources who are not subject to any other CAA requirements and whose actual emissions for the previous year are less than or equal to 50 tpy. Please note that Part 71 is triggered upon start-up and an application is due with in one year of the start-up date.

Examples of ways that facilities can otherwise trigger Part 71 as defined in 71.3 and in the transition policy memo you attached to each of your letters, includes:

-- Any major source. Major source as defined in Part 71 includes major PSD and NESHAP sources.

-- Any source (including minor sources) subject to NSPS (part 60) requirements promulgated after July 21, 1992 unless the NSPS specifically exempts minor sources from Part 71 permitting.

-- Any source (including minor sources)subject to NESHAP (part 61 and 63 ) requirements promulgated after July 21, 1992 unless the NESHAP specifically exempts minor sources from Part 71 permitting.

-- Any Acid Rain source

You have identified each of these facilities as having potential uncontrolled VOC emissions of 106.82, 102.94 and 135.65 tons per year each, respectively; and actual VOC emissions of 25.18, 25.18, and 35.97
tpy, respectively. In addition, your submittal states that these facilities are not otherwise subject to Part 71.

Based on the information you provided, it appears these facilities are eligible for the Part 71 permitting exemption under the Part 71 50% PTE Transition Policy.

Please be aware that upon promulgation of the Federal Minor New Source Review Permitting program for sources located in Indian Country, the 50% PTE Policy will no longer be in effect. All facilities that utilized
this policy will be required to submit a minor NSR application to the EPA to make the actual emissions legally enforceable.

If you have any questions, please feel free to call or email me.

Kathy

***********************************************************
Kathleen Paser
Region 8 Air Program
303-312-6526
***********************************************************
US EPA Region 8
1595 Wynkoop Street
M/C 8P-AR
Denver, Colorado 80202
***********************************************************

Link to 1999 Transition Policy Memo

Non-Road and Stationary Engines Regulations

Non-road engines (excluding locomotives, marine vessels, underground mining equipment, and hobby engines) are regulated under 40 CFR 89. Here are a couple of useful summaries:

Emission Standards: USA: Nonroad Diesel Engines

John Deere Brochure


This web site summarizes stationary diesel engine regulation under NSPS Subpart IIII and NESHAP ZZZZ:

Emission Standards: USA: Stationary Diesel Engines

These are good overviews of stationary engine regs (CI & SI):

Final Rules Promulgated for Stationary RICE

Iowa DNR Fact Sheet

8/20/2010 UDATE:
New amendment of NESHAP Subpart ZZZZ to cover SI RICE at area sources and at major sources for small engines (LTE 500 bHp).

Final regulation:

Final Amendment, NESHAP ZZZZ, Small and Area Srcs

Helpful resources:
Iowa DNR ZZZZ page

Nebraska DEQ collection of ZZZZ references
Note especially the "4Z Important Dates" document.

Texas CEQ ZZZZ references
Here's an article from Air Pollution Consultant, March 2011: "Comment Sought on Operating Emergency Engines in Demand Response Programs."

NAAQS - Status of EPA Proposals -May, 2010

This is a summary of the status of EPA various proposals (or completed) changes to the ambient air quality standards. It's a good 'one page' summary of the numbers, proposal dates, adoption dates, etc.

NAAQS Status Table - May 2010

Boilers NESHAP Proposal - April 2010

"Boiler operators would be required to reduce mercury emissions by 50 percent as part of two new proposed rules to control air toxics from large and small boilers released by the Environmental Protection Agency April 30."

Would require annual testing for major and area sources. Existing small boilers and process heaters (L.T.E 10 MMBtu/hr) would need biannual tuning. Existing large boilers (area sources > 10 MMBtu/hr) would have to perform an energy assessment. Will cover boilers that burn coal, oil, biomass, and other non-hazardous materials. AWMA article includes link to EPA web site.

AWMA article

Trinity article

Of Boiler Rules and Biofuels
Martin Law article added 8/20/2010. Includes concise background and good short discussion of hazardous waste issue. Here's an excerpt:

"The key is whether the unit burns any “solid waste.” This leads to the question: when is biomass also solid waste? EPA’s original approach to this question was to exempt most materials that would be considered biomass (e.g., wood, food, agricultural byproducts – even manure, if burned) because they had not been “discarded.” However, EPA has now changed its rule to include an additional criterion: these materials are only exempted from treatment as solid waste if they remain in control of the generator. If these materials leave the point of generation, operators are now required to petition EPA for a “non-waste determination.”

EPA has indicated it will grant a non-waste determination if the boiler operator can establish that market participants treat the biomass stock as a fuel rather than a solid waste, and that the fuel stock has a chemical and physical identity comparable to commercial fuels, will be used in a reasonable timeframe, and has air emissions when burned comparable to traditional fuels. EPA’s determination is subject to notice, comment and hearing requirements, and, presumably, judicial review. Depending on how EPA handles this process, it could pose a significant administrative burden and uncertain time delays for fuel supply contracts between biomass energy project developers and timberland managers, farmers, and other suppliers of biomass."


Proposed Area Source Boiler MACT:
Here are some graphical outlines of the area source boiler MACT proposal. There are three graphics files: one overview and two subcategory expansions. The original file was created in a free mind mapping application called XMind which can be downloaded from this address: http://www.xmind.net/

XMind mind map

Overview jpg

Emission Standards jpg

Continuous Compliance jpg

Here are the proposed rules as published in the Federal Register. To access them, you'll have to log into Cyber Regs. You can use username 'kevinmathews' and password 'bisoneng'.

Major Source Boilers

Area Source Boilers

RCRA Waste Definition

CISWI NSPS Modification

Here's an MDEQ summary presented to CAAAC in July 2010:

MDEQ Summary Presentation

Coal Ash Proposed Rule

Pre-publication proposal released 5/4.

Coal Combustion Residuals Industrial Waste US EPA


E-mail from EPA to Grant regarding proposed rule's applicability to other fuel residues:


From: Livnat.Alexander@epamail.epa.gov [mailto:Livnat.Alexander@epamail.epa.gov]
Sent: Monday, May 10, 2010 1:15 PM
To: Grant Rodway
Cc: Souders.Steve@epamail.epa.gov
Subject: Re: Clarification on the Definition of CCR in the Proposed Rule to Regulate CCR Under RCRA

Mr. Rodway,

Your conclusion about the narrow definition of FFCs, to the effect that 'Waste from the combustion of oil, natural gas, and petroleum coke would not be subject to this proposed rule" is correct. This goes back to the May 2000 Regulatory Determination on Wastes from the Combustion of Fossil Fuels (http://www.epa.gov/fedrgstr/EPA-WASTE/2000/May/Day-22/f11138.htm) where we said that fossil fuel combustion wastes do not warrant regulation under subtitle C: "The Agency has concluded that no additional regulations are warranted for coal combustion wastes that are used beneficially (other than for minefilling) and for oil and gas combustion wastes (emphasis added)....However, EPA has also determined national regulations under subtitle D of RCRA are warranted for coal combustion wastes when they are disposed in landfills or surface impoundments...". This is the reason why since the 2000 Regulatory Determination we have focused on coal combustion wastes/residuals.

Regards,

Alex Livnat, Ph.D
Materials Recovery and Waste Management Division
Office of Resource Conservation and Recovery
US EPA (MC: 5304P)
1200 Pennsylvania Ave, NW
Washington, DC 20460-0001
Tel: (703) 308-7251
Fax: (703) 605-0595
Email: livnat.alexander@epa.gov

Proposed Gold Ore Processing NESHAP

“EPA is proposing to add the gold mine ore processing and production area source category to the list of source categories subject to regulation under the hazardous air pollutant section of the Clean Air Act (CAA) due to their mercury emissions. EPA is also proposing national mercury emission standards for this category based on the emissions level of the best performing facilities which are well controlled for mercury.”


“The gold mine ore processing and production area source category consists of facilities engaged in processing gold ore to recover gold using one or more of the following process units: roasters, autoclaves, carbon kilns, melt furnaces, mercury retorts, electrowinning, and/or pregnant solution tanks. There were approximately 21 gold mine ore processing and production facilities operating these processes in the United States (U.S.) in 2008. The majority and the largest of these facilities are located in Nevada. The other facilities currently operating are in Alaska, California, Colorado, Montana, and Washington.”

Notice:
http://companyweb/General%20Documents/Docs%20for%20posting/Gold%20Ore%20Processing%20NESHAP/NESHAP%20proposal%20-%20Au%20ore%20processing.pdf

MACT development:
http://companyweb/General%20Documents/Docs%20for%20posting/Gold%20Ore%20Processing%20NESHAP/MACT%20development%20-%20Au%20ore%20processing%20NESHAP.pdf

Mercury emissions evaluation report:
http://companyweb/General%20Documents/Docs%20for%20posting/Gold%20Ore%20Processing%20NESHAP/Hg%20emissions%20eval%20-%20Au%20ore%20processing%20NESHAP.pdf

Mercury emissions factors:
http://companyweb/General%20Documents/Docs%20for%20posting/Gold%20Ore%20Processing%20NESHAP/Hg%20Em%20Fctrs%20-%20Au%20ore%20processing.pdf

Townsend residents voice concern over MSTI, substation

From the Montana Standard.

Proposed MHA Nation Refinery - Region 8 Page

Proposed MHA Nation Clean Fuels Refinery Region 8 US EPA

Biofuels Articles

Series of articles from AIChE Society for Biological Engineering. Focus is mainly on ethanol and biodiesel. Individual titles are:
** SBE Update: Engineering Advanced Biofuels
** The Role for Biofuels
** Minimize Scale-Up Risk (this includes discussions of raw material preprocessing)
** Ionic Liquid Pretreatment
** Converting Cellulose to Biofuels

http://companyweb/General%20Documents/Docs%20for%20posting/Biofuels%20reports.pdf

GHG Reporting Nuts and Bolts - Article

Helpful article with some detailed guidelines and suggestions regarding GHG reporting:

GHG Reporting Article

GHG Reporting - Subpart W, brief summary

"EPA has changed the proposal in three ways. First, the rules add two new reporting segments within the sector—onshore petroleum and natural gas production and natural gas distribution facilities. Second, the rule seeks to reduce the burden on the regulated community by taking a new approach to emissions monitoring in the sector. EPA’s previous proposal relied heavily on comprehensive leak detection and direct measurements for capturing emissions data. Because emissions sources in this sector are relatively diffuse, i.e., thousands of miles of pipelines and valves, EPA recognized that direct emissions monitoring would impose a significant cost on the industry. As a result, EPA’s current proposal allows most facilities to measure emissions through engineering estimates, emission modeling software, and emission factors.[4] Third, EPA seeks to alleviate confusion caused by the previous proposal by providing separate definitions for “vented” and “fugitive” emissions instead of collectively defining both sources as “fugitive.”

"EPA’s proposal requires facilities that emit greater than 25,000 metric tons or more per year of CO2 equivalent to report their GHG emissions. Due to the diffuse nature of the storage facilities, wells, and associated pipelines in the industry sector, the proposal contains three different “facility” definitions for three different industry segments, all of which differ from the definition provided in the 2009 GHG Reporting Rule. For example, a facility in the onshore petroleum and natural gas production segment is defined to include all petroleum or natural gas equipment associated with production wells that are under common ownership or control and within one hydrocarbon basin.[5] Therefore, unlike the 2009 GHG Reporting Rule, an onshore production “facility” need not be connected or even located on adjacent properties; rather, the total fugitive and vented emissions from an unconnected network of wells, pipelines, and processing facilities would count towards the 25,000 metric ton reporting limit. Unique facility definitions are also provided for the offshore petroleum and natural gas production and natural gas distribution industry segments."

EPA Releases Additional Proposed Greenhouse Gas Emissions Reporting Rules for Three Industry Sectors Marten Law

Proposed GHG reporting for petroleum and natural gas production - Subpart W

March 22, 2010 "(P)roposed rule for the mandatory reporting of vented and fugitive methane (CH4) and carbon dioxide (CO2) emissions from petroleum and natural gas industry facilities emitting 25,000 metric tons or more of carbon dioxide equivalent per year."

Greenhouse Gas Reporting Rule Regulatory Initiatives Climate Change U.S. EPA

NAAQS/MAAQS/Increment Tables

***
Up-to-date NAAQS on EPA's web site:

National Ambient Air Quality Standards (NAAQS) Air and Radiation US EPA

Here's a table of NAAQS, MAAQS, increments, SILs, SMCs, significant emission rates, etc. Last updated 5/20/2011.

PM2.5 Modeling - Minnesota presentation, 11/2008

Suggests including background emissions as an area source in the model instead of adding a worst-case background value to the modeling results. One drawback is that a very large area source in Aermod took up to seven hours to run -- with one receptor!

Minnesota PM2.5 Modeling Presentation

Projected attainment maps for new and proposed NAAQS - 2/2010

Attached to a 3/12/2010 e-mail meeting announcement from the Montana Petroleum Association:

http://companyweb/General%20Documents/Docs%20for%20posting/NAAQS%20Update%202-23-10.ppt

Letters regarding EPA regulation of GHGs -- MPA and others

Here are some letters regarding EPA regulation of GHG emissions:

MPA letters to Baucus --
http://companyweb/General%20Documents/Docs%20for%20posting/GHG%20letters/MPA%20letter%20to%20Baucus%202-10.pdf

http://companyweb/General%20Documents/Docs%20for%20posting/GHG%20letters/MPA%20letter%20to%20Baucus%203-10.pdf

MPA letter to Attny Gen Bullock --
http://companyweb/General%20Documents/Docs%20for%20posting/GHG%20letters/Intervention%20Endangerment-Bullock%20final.pdf

Letter to EPA Adminstrator Jackson from group of senators including Baucus --
http://companyweb/General%20Documents/Docs%20for%20posting/GHG%20letters/Rockefeller%20Letter%20-%202-10.pdf

Response from Jackson to Baucus --
http://companyweb/General%20Documents/Docs%20for%20posting/GHG%20letters/Jackson%20Response%20Letter%20-%202-10.pdf

PM10 & 2.5 Conformity Update, March 24, 2010

Update on implementing PM10 and PM2.5 NAAQS revisions for conformity demonstrations. Includes update on hotspot analyses requirements.

PM10-PM2.5 Conformity Rule Update, March 2010

Minor Sources in Indian Country - EPA Policy

March 7, 1999 policy memo.

"This memorandum discusses EPA’s transition policy concerning potential to emit (PTE) limits for stationary air pollution sources located in Indian country. Under this policy, EPA would treat a source as nonmajor for the purposes of the Federal Operating Permits Program (part 71) if its actual emissions area nd remain below 50 percent of the PTE thresholds for major source status, for every consecutive 12-month period (beginning with the 12 months immediately preceding the date of this memorandum) and it maintains adequate records to demonstrate that its actual emissions are kept below these levels."

EPA - Policy and Guidance Record - Potential to Emit (PTE) Transition Policy for Part 71 Implementation in Indian Country

Availability of Meteorological Data

Surface Meteorological Data:

For dispersion modeling, we have on hand here in Billings the Integrated Surface Hourly Observations (ISH) data sets for 1995-2008. These are published on DVD annually by the National Climatic Data Center (NCDC). ISH data are directly usable without modification in AERMET; for CALMET, they must be converted to one of CALMET's supported formats. I've written a little utility to convert ISH formatted data to CD144 formatted data, which CALMET can read.

For wind erosion calculations, we can obtain Local Climatological Data (LCD) for any of several hundred locations nationwide. The LCD data sets include the 3-second or 5-second wind speed data needed for the wind erosion calculations. These data are available by subscription for $29 annually per station from here:

https://nes.ncdc.noaa.gov/sub-login.html

We already subscribe to a number of stations in Montana. The LCD data can also be used for modeling, but they must be converted to a format supported by the model. I've written a little utility to convert LCD data to CD144 format, which can be used by both AERMET and CALMET.

Upper Air Meteorological Data

Radiosonde data are available at no cost from here:

http://esrl.noaa.gov/raobs/

When you download the data, be sure to select the "Original FSL format (ASCII text)" option, as AERMET and CALMET do not support the new FSL format.

ALSO....

WebMET (offered through Lakes Environmental) provides easy access to surface and upper air data. It also provides station information such as anemometer height, time zone (+ x zones relative to GMT), and lat/long. (Note: this was the only place I was able to find anemometer height info.)
(added 5/19/2011, KMM)

Wyoming Ozone marketing letter

Sent March 2010

http://companyweb/General%20Documents/Docs%20for%20posting/WY%20Ozone%20Marketing%20Letter.doc

VOC Testing

VOC Emissions

Influence of VOC Measurement and Reporting Methods on Regulatory Policy and Emissions Estimations

NC Division of Air Quality

Stationary Source Compliance Branch

December 6, 1996

"The most commonly used methods for quantifying VOCs in gas streams are in the Code of Federal Regulations (40 CFR 60) Appendix A, Methods 18, 25, and 25A. Each method has advantages and disadvantages relative to the other methods. The choice of measurement and reporting techniques depends on the purpose that the data will serve. Due to differing analytical limitations for each of the VOC test methods, all sources may not be able to use the same test method and data manipulation procedures."

http://companyweb/General%20Documents/Docs%20for%20posting/VOCemission%20testing_NCDAQpdf.pdf

Updated modeling guidance

Procedures for calculating the NO2 design value for comparison to the 1-hour NAAQS. Hopefully the BEEST post processor, and maybe others, will avoid the need to do this by hand.
EPA 1-hr NO2 Modeling Guidance


Excerpt from Comments of the Air and Waste Management Association's AB-3 Meteorology Committee Regarding New Dispersion Modeling Issues: PM2.5 and 1-hour for NO2 and SO2; March 12, 2010

"We now find ourselves in a unique regulatory period in which several new modeling procedures need to be established for both a newly regulated pollutant(PM2.5) and for 1-hour probabilistic standards for NO2 in spring 2010 and for SO2 in summer 2010. Associated with these pollutants and standards are important modeling issues that are not currently addressed in the Guideline. Regulatory dispersion modeling analyses have historically employed, in practice, several assumptions used to assure a conservative estimate of the modeled design concentration. Many of these assumptions are used only to simplify the analyses in the absence of more robust, scientifically sound information about the emissions sources and atmospheric conditions that affect the ambient pollutant concentrations. With the advent of several more stringent air quality standards, it is no longer practical to use redundant, overly conservative assumptions for simplicity or convenience. We encourage the development and implementation of robust methods for conducting regulatory air quality modeling analyses."

The document is here:
AWMA PM2.5 modeling comments


Here's a memo from EPA on modeling PM2.5. Basically, it "recommends" that, when modeling five years of NWS data for compliance with the 24-hr PM2.5 NAAQS, you should add the average of the first-highest 24-hr values for all five years to the 98% percentile of background measurements for three years.

2/26 & 2/24 EPA reviews and comments re. PM2.5 modeling

This supplemental EPA PM10/PM2.5 modeling memo addresses PM10 surrogacy demonstration and provides more extensive modeling guidance for PM2.5. The way I interpret it, it suggests using the highest 3-yr average across 5 years of NWS results for the annual average. For the 24-hr average, use the highest 3-yr avg. of H1H 24-hr results across 5 years of NWS model results.

March 23rd PM2.5 modeling guidance

Conference calling

Here’s the procedure for connecting with two different phones using our desk phones:

• Press “Handsfree / Mute” button for speaker phone (optional).
  
• Dial first party.
  
• Press “Hold” button.
  
• Press second “Intercom” button.
  
• Dial second party – dial “9” first.
  
• Press “Conf/Trans” button.
  
• Press the “Intercom” button next to the blinking arrow.

EPA Regs Update - 12/09

Here’s a link to a database of brief status reports regarding EPA regulatory activity: http://www.reginfo.gov/public/do/eAgendaMain.

The status reports are compiled in a semiannual report available in pdf format. Here is a portion of the table of contents with some topics highlighted that I thought might be of interest to some of us.

http://companyweb/General%20Documents/Docs%20for%20posting/EPA%20reg%20status%20TOC.pdf

Test

Hey! Look at me! I'm blogging!

EPA Raises Initial Threshold for Greenhouse-Gas Regulation - WSJ.com

The U.S. Environmental Protection Agency will set an emissions threshold of at least 75,000 tons a year—and possibly more than 100,000 tons a year—for power plants and other industrial projects for the initial stage of stationary-source greenhouse-gas regulations between 2011 to 2012, the head of the agency said Wednesday [3/3/2010].

EPA Raises Initial Threshold for Greenhouse-Gas Regulation - WSJ.com

RICE NESHAP Final Rule

RICE NESHAP Final Rule (from Trinity Consultans March 2010 newsletter)

On February 17, 2010 EPA finalized portions of the National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (RICE NESHAP). The rule will be incorporated into the already existing RICE standards located in 40 CFR Part 63, Subpart ZZZZ. The standards apply to only stationary RICE and were originally proposed on February 25, 2009. The proposed standards included provisions for RICE located at area sources of hazardous air pollutants (HAP) and RICE with a site rating of less than or equal to 500 brake horsepower (bhp) located at major sources of HAP. In addition, the proposal included standards for existing non-emergency compression ignition (CI) engines with a site rating of greater than 500 bhp at major sources and revised provisions related to Startup, Shutdown, and Malfunction (SSM) events for engines previously regulated under the rule.

The promulgation of these regulations means that many previously unregulated engines, including those designated for emergency use, will be subject to federal regulation, including emission standards, control requirements, or management practices.
Following public comment on the proposed rule, the EPA made a number of significant changes to the promulgated rule. Following is a summary of those changes:

- The EPA did not finalize the proposed provisions for spark ignition (SI) engines. Although the original proposal included SI engines at area sources as well as those less than or equal to 500 bhp located at major sources, the EPA has determined that additional data is needed prior to finalizing rules for these sources. The EPA expects to finalize the rules associated with SI engines by August 10, 2010. (final rule to include SI RICE published 8/20/2010, KMM)

- Existing emergency engines at area sources that are located at residential, commercial, or institutional facilities are not subject to the final rule. A definition for residential/commercial/institutional facility has been included in the final rule.

- Several numerical standards originally proposed for some categories of engines have been replaced with management practices.

- The EPA revised the numerical emission limit for several engine categories based on a re-evaluation of the MACT floor.

- The EPA added an option to the management practices to use an oil change analysis program to extend the oil change frequencies listed in the final rule. Details of the analysis program are included in the final rule.

- The EPA eliminated the numerical standards originally proposed during periods of SSM, instead promulgating operational standards that apply during startup. Additionally, the standards that apply during normal operation now also apply during periods of shutdown and malfunction.

- The EPA included an additional requirement to reduce metallic HAP emissions for certain engine categories, including existing non-emergency CI greater than 300 bhp. A closed crankcase ventilation system or open crankcase filtration system must be installed on these engines, if the engine is not already equipped with a closed crankcase ventilation system.

- An exclusion from the numerical emission limits has been included for existing non-emergency CI RICE greater than 300 bhp located at area sources in Alaska that are not accessible by the Federal Aid Highway System. These engines are required to meet the management practices listed for non-emergency CI RICE less than or equal to 300 bhp.

- A definition for emergency stationary RICE has been added to the final rule. The majority of the requirements that apply to emergency stationary RICE listed in §63.6640(f) are identical to the proposed rule; however, the final rule allows an emergency unit to participate in an emergency demand response program as a part of a financial arrangement with another entity for up to 15 hours per year. Additional requirements also apply to units participating in emergency demand response programs. The detailed requirements are listed in §63.6640(f) of the final rule.

The compliance date for all applicable emission limitations and operating limitations for the affected units is three years from the effective date of the rule. The compliance date for the sources affected by the current revision to the rule is May 3, 2013. Sources with affected RICE should review the final rule carefully to determine compliance requirements based on the promulgated standard.

For more information or to view a copy of the final rule, go to the following EPA web site:

http://www.epa.gov/ttn/oarpg/new.html

Advanced NSR Workshop

Training offered by RTP Environmental Associates. Typically offered twice per year - in April in Las Vegas and in September in Albuquerque or Scottsdale.

http://www.rtpenv.com/tais.html

North Dakota growth analysis

A Basic Analysis of the Bakken Oil Boom: Precautions and Planning

"The oil industry began booming in northwestern North Dakota in 2006 with developments in the Bakken formation. This paper is an analysis of the boom and its impact upon the economies in a six county region identified by the high numbers of drilling and permits pulled in the region. Counties in the study region include Billings, Burke, Dunn, McKenzie, Mountrail, and Williams counties.

The boom is evidenced by 28% per annum job growth from 2005‐08 in mining industry employment in the region, an increase in the share of mining jobs in the regions basic industry mix (from 28% in 2000 to 55% in 2008), and a 2008 location quotient of 10.6 for the region’s mining industry relative to the state. This increased mining activity has also corresponded with average annual continuous growth in state‐wide oil and gas extraction tax revenues of 33%. Nearly 25% of all oil and gas extraction tax revenue collected in the state since the institution of the tax in 1981 has happened in the 2008 and 2009 fiscal years. The increased employment and tax revenues are by and large benefits to the state, which is currently one of only a few states experiencing a budget surplus."

Above from the executive summary. (Click on blog title to go to report.)

NEPA and Climate Change on Federal Lands

PowerPoint presentation:
http://www.eli.org/pdf/research/NEPA_and_Climate_Change.pdf

CADD support services in Missoula

We recieved this e-mail on 3/12/2010:

Hello, my name is Peter Costello and I own CadMont, LLC in Missoula. I do contract drafting and consulting for a variety of businesses. I’ve worked in the civil, survey, mechanical, electrical and architectural fields. With over 25 years of experience, I’m and AutoCAD expert. I can improve your efficiency by delivering more accurate drawings, faster, at a lower cost.

I also do training and consulting for Autodesk products. I’ve been teaching AutoCAD in Missoula for the last 17 years and am actively involved with the new Computer Aided Design program at the U of M College of Technology.

I’m planning a trip to Helena next week so if there is anything that CadMont, LLC can do for you, please call me to schedule an appointment at your convenience?

Regards,

Peter Costello
CadMont, LLC
406-396-7191
www.cadmont.com

Upload Files To Blogger

I've started a 'General Documents \ Docs for posting' folder on the Bison internal web site. You can upload documents there and paste the link in the blog post. To paste the link:

• Right click the file name in the Bison web 'General Documents \ Docs for posting' folder
• Select 'copy shortcut' from the dropdown menu
• Paste the shortcut into the blog editor
• With the shortcut address highlighted, click the editor's 'Link' button

 This seems to work. Here's some directions that pointed me in this direction. Seems, though, that you don't need to insert the HTML code:

"You can only upload image files to your Blogger blog. These can only be uploaded through your blog posts...

There is a total limit of 300MB on the pictures you are uploading through Blogger, Picasa, or Hello to a free BlogSpot blog...

Individual pages of your blog are limited to 1MB size..

There is no limit to number of blogs you have or number of posts you can make...

To overcome the size and file-type limit in your free blog try uploading your pictures to a freehostlike Googlepages...

After uploading the files place your mouse cursor over the filename and right-click and choose Copy Link Location. This copies the location/URL/link of your file at the freehost. Then paste it into this code in your blog :

<a href="LINK OF YOUR FILE AT FREE HOST">DOWNLOAD FILE</a>

When viewers click on "DOWNLOAD FILE" they will get a dialog box prompting them to download your file.

These directions come from here: Upload Files To Blogger. ~ The Blog Doctor.

EPA MT SIP rulings 3-10-10

March 10, 2010

From:  Don Allen, Executive Driector

To:  WETA Environmental/Regulatory Committee

Subject:  EPA Announces Montana SIP Approvals and Disapprovals

cc: WETA Board of Directors

Attached is a new EPA communication in which they list State Implementation Plan provisions that are approved, others not approved and others that are still in limbo, some of those at the request of the State. A quick read of the document reveals some issues that need more clarification, such as some of the definitions. DEQ’s Dave Klemp, who heads the Air Resources Bureau say they are beginning an analysis of EPA’s decisions and will want to discuss their conclusions with industry when they can complete their evaluation. This document is a good example of how the EPA has not been focused, with some of Montana’s SIP’s having been submitted over a decade ago. 

Click here to read the document "EPA MT SIP rulings 3-10-10":

http://companyweb/General%20Documents/Docs%20for%20posting/EPA%20MT%20SIP%20rulings%203-10-10.doc

Critique of carbon markets

"December 2009 saw world leaders come together in Copenhagen to try to agree on a post-Kyoto deal to save the planet from global warming. But the attempts to hammer out a new deal met with an apparent failure. But was it a failure? Many commentators would argue that the apparent failure can be seen as a welcome breathing space to question the underlying mechanisms that are supposed to help us fight climate change. In this way, Upsetting the Offset is a very timely book, as it critically engages with the political economy of carbon markets, which have emerged as the dominant instrument to mitigate climate change."

Upsetting the Offset

Science vs. Policy - opposing view

"The problem is not that reason fails. The problem is that politics fails to be reasonable. Blaming reason for the failure of politics is about as backwards as you can get something."

Daniel Sarewitz is Wrong

Science vs. Politics - Slate editorial

"A dangerous idea has taken hold in modern politics, and the sooner it is discredited, the better. The idea is that political disagreements can be resolved by science."

"When people hold strongly conflicting values, interests, and beliefs, there is not much that science can do to compel action. Indeed, more research and more facts often make a conflict worse by providing support to competing sides in the debate, and by distracting decision-makers and the public from the underlying, political disagreement. In such cases each side will claim to have the scientific high ground."

Science won't tell us what to do about climate change, but it can make the controversy worse. - By Daniel Sarewitz - Slate Magazine

Montana Board of Oil and Gas New Activities Reports

Updates on new permitting activities from the Montana Board of Oil and Gas

bogc.dnrc.mt.gov - /ActivityLetters/

Western Business Roundtable News

Good source of news of environmental, technology, and politcal news...

News

Oil, Natural Gas and CBM maps

Maps: Exploration, Resources, Reserves, and Production

Proposed O3 NAAQS

EPA regulatory actions summary web page
Regulatory Actions Ground-level Ozone US EPA

1/19/10 proposal in FR
http://www.epa.gov/air/ozonepollution/fr/20100119.pdf

1/19/10 proposal fact sheet
http://www.epa.gov/air/ozonepollution/pdfs/fs20100106std.pdf

In Draft Mitigation Guidance, CEQ Moves Toward Adding Substantive Mitigation to NEPA’s Procedural Requirements | Marten Law

CEQ proposed guidance, issued 2/10, encourages federal agencies to follow up when a “finding of no significant impact” relies on mitigation of environmental impacts, and when agencies commit to mitigation in an Environmental Impact Statement. The Draft Mitigation Guidance arguably moves CEQ from its traditional mission of protecting the environmental review process, toward a mission of requiring substantive mitigation of impacts identified during NEPA reviews.

In Draft Mitigation Guidance, CEQ Moves Toward Adding Substantive Mitigation to NEPA’s Procedural Requirements Marten Law

Minnesota MPCA GHG guidelines

Climate Change web page
http://www.pca.state.mn.us/climatechange/

Environmental review web page
http://www.pca.state.mn.us/programs/envr_p.html

General Guidance for Carbon Footprint Development in Environmental Review
http://www.pca.state.mn.us/publications/p-ear1-07.pdf

Completion of a Greenhouse Gas Emissions Evaluation
7/16/2008 policy memo
http://www.pca.state.mn.us/publications/greenhousegas-memo0708.pdf

EPA GHG Endangerement and Cause & Contribute Findings

Final findings on 12/7/2009.

http://www.epa.gov/climatechange/endangerment.html