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HomeMy WebLinkAboutThe Design of a Planning Program to Help Mitigate Energy Facility-Related Air Quality Impacts-1982TC ?_ - 4 . rj18 i !iT982 rro.11 4, The Design of a Planning Program To Help Mitigate Energy Facility -Related Air Quality Impacts in the Washington County, North Carolina Area CL ' t' R Rogers, Golden & Halpern" , 11872D Sunrise Valley Dr. Reston, VA 22091 Engineers for Energy and the Environment 3 Brower Court Marlton, NY 08053 SEPTEMBER 1982 North Carolina Coastal Energy Impact Program Office of Coastal Management North Carolina Department of Natural Resources and Community Development CEIP REPORT NO.14 PROPERTY OF DIVISION OF COASTAL MANAGEMENT PLEASE DO NOT REMOVE To order: Residents of North Carolina may receive a single copy of a publication free upon request. Non-residents may purchase publications for the prices listed. Because of the production costs involved, some of the publications carry a minimal charge regardless of residency. Prices for these are indicated in the price list as being "for all requests". When ordering publications please provide the publication number and title and enclose a check made payable to DNRCD. For a complete list of CEIP publications - or to place an order - contact: Coastal Energy Impact Program Office of Coastal Management N.C. Department of Natural Resources and Community Development Box 27687 Raleigh, NC 27611 Series Edited by James F. Smith Cover Design by Jill Miller THE DESIGN OF A PLANNING PROGRAM TO HELP MVP MITIGATE ENERGY FACILITY -RELATED AIR QUALITY IMPACTS IN THE WASHINGTON COUNTY, NORTH CAROLINA AREA Prepared for Washington County, N. C. by Rogers, Golden & Halpern 11872D Sunrise Valley Drive Reston, VA 22091 Engineers for Energy and the Environment 3 Brower Court Marlton, N. J. 08053 The preparation of this report was financed through a Coastal Energy Impact Program grant provided by the North Carolina Coastal Management Program, through funds provided by the Coastal Zone Management Act of 1972, as amended, which is administered by the Office of Coastal Zone Management, National Oceanic and Atmoshperic Admin- istration. This CEIP grant was part of NOAA grant NA-80-AA-D-CZ149. Project No. 80-02 Contract No. C-6041 September 1982 CEIP Report No. 14 PREFACE This report is the result of a cooperative effort by the State of North Carolina and Washington County to make an objective appraisal of the potential costs and benefits to our region's air quality should any of the proposed uses of peat as an energy resource become more fully developed. It presents the opinions and perspectives of a wide range of individuals and organizations who have an interest in the develop- ment of peat as an energy resource in North Carolina. Using the best source and environmental data available at the time, the authors of the report have used the simplest "worst case" extrapolation of air quality impacts from the proposed methanol facility to reach their conclusions on possible limits to its expansion. Reviewers of the draft report have disagreed with this approach and seem able to demonstrate that advanced control technologies, careful siting, close monitoring, and •adequate models will greatly change these conclusions. Their comments and questions have been reproduced in the appendix in -an effort to insure objectivity. The conclusions, recommendations, and comments included in this report have been provided to the State of North Carolina, local governments on the Pamlico -Albemarle Peninsula, and other interested parties. This valuable information that will aid in our efforts to make decisions based on reliable, objective information. Should large scale development of peat as an energy resource take place, mitigation and monitoring information will be readily available as a result of this report. On behalf of Washington County, I would like to express our appreciation to the Coastal Energy Impact Program for assistance in making this important project possible. y),l MrL blayme Davenport, Chairman Washington County Board of Commissioners TABLE OF CONTENTS 1. Introduction 1 Purpose of the Study 1 North Carolina's Peat Resources 3 First Colony Farms 6 American Peat Company 8 Peat Fuels, Inc. 8 Lantern Acres, Inc. 8 Whitetail Farms 8 Peat Methanol Associates 8 Ref erences 10 2. Air Quality Impacts of Peat Mining and Transportation 11 Relevant Air Quality Regulations 11 Peat Harvesting Methods 16 Manual Harvesting 18 Sod Peat Harvesting 18 Milled Peat Harvesting 18 Hydraulic Peat Harvesting 19 Peat Transportation 20 Trucks 20 Barges 22 Internal Rail or Conveyor System 23 References 24 3. Air Quality Impacts of Peat Utilization 26 End Uses for Peat 26 Industrial Process Heat 26 Space Heat . 27 Conversion to Domestic Briquettes 27 Conversion to Methanol 28 References 34 4. Air Quality Impacts of Industrial Facilities in the Region 35 Existing Ambient Air Quality 35 Existing Point Sources of Pollution in the Region 38 Primary Impacts of Existing Industrial Development in the Region 40 Impacts of Planned and Potential Energy Related Development 43 References 47 5. Air Quality Monitoring 48 Need for Monitoring 48 Monitoring of Regional Background and Trends 50 Lake Phelps 51 Pungo Lake 52 References 55 6. Regional Air Quality Modeling 56 Background and Need for Modeling 56 General Model Selection Considerations 57 Modeling Requirements Specific to the Study Region 59 Computation Periods 58 Receptors 58 Source Configurations 58 Pollutant Characteristics 59 Meteorological Data 59 Record -Keeping 59 Range of Possible Models 60 RAM 62 CRSTER 62 M PTER 62 TEM 62 ISC 62 Recommendation 63 Modeling Input Data Base 64 Model Validation/Calibration 72 Recommendation for an Air Quality Modeling System 73 Required Personnel Qualifications 74 References 76 Appendix A. Abstracts of Air Quality Dispersion Models Appendix B. Model Air Quality Ordinance Appendix C. Peat Bibliography Appendix D. Reviewers' Comments 1\ 77 81 90 94 LIST OF TABLES AND FIGURES TABLES 1. National Ambient Air Quality Standards (NAAQS) 12 2. Maximum allowable increases under Prevention of Significant Deterioration (PSD) regulations 14 3. N.C. emission control standards for potential peat -burning facilities 17 4. Criteria pollutant emissions from the peat methanol plant 30 5. Non -criteria pollutant emissions from the peat methanol plant 30 6. Peat Methanol Associates modeling results: maximum off property predicted concentrations 32 7. Measured annual concentrations for three criteria pollutants taken at Plymouth, N.C., from 1975-1980 36 S. Assumed concentrations for criteria pollutants in an eastern U.S. rural area 37 9. Stationary sources of pollution affecting the study region's air quality 39 10. Refined Gaussian candidate models generally acceptable for regulatory purposes 61 11. Model characteristics 65 12. Surface and upper air meterological data stations located nearest the study region 71 FIGURES 1. Map showing location of North Carolina peat deposits 4 2. Washington -Hyde -Tyrrell County study area 7 3. Location of active and proposed peat mining operations and the proposed peat methanol plant 9 4. Existing industrial sources of pollution in study area 39 5. Location of Department of Environmental Management monitoring stations 49 1. INTRODUCTION Purpose of the Study The governments of Washington, Hyde, and Tyrrell Counties recognize the importance of their extensive peat deposits as a potential source of energy for North Carolina. Planners in these counties are also fully aware that changes in the area's economy, social structure, and environment could result from develop- ment of this resource. Early recognition of the specific effects that could reasonably be expected will facilitate rational management of potential problems. The study area is predominantly rural and undeveloped. The existing air quality is relatively good. Two of the major factors influencing air quality in a region are the degree of energy -related development and the types of air pollution control technologies applied. The management of the air resource is, in most instances, effectively achieved at the regional or local level, where air quality planning can be integrated with local land use, zoning, and building decisions. Accordingly, the purpose of this study is to: o Identify environmental issues in the tri-county region, particularly potential air quality issues associated with peat development; o Recommend an air quality analysis and review system that will help local and regional planners anticipate and manage peat -related air quality impacts; and o Suggest ways to improve the existing air quality monitoring system. In the sections that follow, we will present a body of data, an approach to -1- air quality monitoring, and a quantitative, analytical approach that can be applied to the tri-county region to provide planners in Washington, Tyrrell, and Hyde Counties with a clearer understanding of energy -related development options and their impacts. Peat is the partially decomposed remains of reeds, mosses, leaves, pine needles, and other plant material. Because decomposition takes place in water rather than in air, the decomposing plant material retains much of its carbon content, while losing its fibrous structure. Peat varies from the textured, mossy material found on the surface of the bog, to the dense, sticky, highly - decomposed matter found in the deepest strata of the bog. In its raw state, the average water content of peat is approximately 94 percent, the amount varying from 97 percent at the bog surface to about 90 percent at the bog floor.I When exposed to sunlight and air, peat undergoes an irreversible drying process. For years, young peat (the fibrous, surficial matter) has been harvested, dried, and used as a soil conditioner. When combined with manure, it can be used, as a fertilizer. Dried peat can also be burned as fuel in fireplaces and coal stoves, and has been used in this manner for many years in other countries --most notably Ireland and Russia --as a source of energy for domestic heating and cooking. With the application of heat and pressure, peat can be further dried, milled, and compressed into charcoal -like briquettes. In this form, peat is useful both as a domestic fuel and as a feedstock for commercial boiler firing, for the generation of electricity or production of heat for district heating systems. Prior to 1960, peat was used as a commercial source of energy for electricity generation and district heat in Denmark, Sweden, Germany, and the Netherlands.2 By 1960, however, the relatively low per -Btu cost and availability of coal and oil caused these countries to suspend their use of peat for fuel. As a result of the 1973 Arab oil embargo, the days of "inexpensive" oil are over. Government and industry here and abroad now have the economic incentive to re-evaluate peat as an alternate energy source. Sweden, which ceased peat fuel production around 1960, is now planning three district heating/electricity generating plants. Finland has also embarked on a national -2- effort to develop its peat resources for energy. Greece has plans for utilizing a deep peat bog for electricity generation. Other countries that have used or are considering the greater use of peat are Germany, Holland, Great Britain, Scotland, and Canada.3 With existing and emerging technology, and the backing of Federal and State research and development programs, it now appears that peat could be used to generate amounts of synthetic natural gas (SNG), synthetic liquids (such as methanol), and electrical power adequate to meet limited national and regional energy needs. Within the peatland areas, peat -generated electrical power could be distributed through existing power grids to reduce the dependency on oil, meet future power demands, potentially reduce sulfur oxide emissions, and utilize in -State energy resources. There have been several experimental projects in the United States to explore the possibility of using peat as a source of fuel. In the early 1870's, a Minnesota legislative committee investigated the use of peat as fuel for locomotives. The Phoenix Building in Minneapolis was heated by powdered peat during the winter of 1919-1920.4 During the 1930's and 1940's, various groups in Minnesota studied the fuel potential of peat for such uses as taconite ore processing and boiler operations. The results of these early studies showed that, although peat could be used successfully as a fuel, other energy sources such as coal were cheaper. Although interest has revived in the use of Minnesota peat for fuel, the only current use of peat for energy production in the U.S. is in North Carolina. North Carolina's Peat Resources The major peatlands in North Carolina, shown in Figure 1, occupy the coastal plain. The widely distributed organic soils are derived from the accumulation of organic litter grown within a freshwater environment. Pollen studies indicate that this accumulation began approximately 9,000 years ago,5 -3- IIA y III.A -%k j LJ • IIE O I.A DISMAL SWAMP / I.8 PAMLIMARLE PENINSULA J-� I.0 GULL ROCK GAMELAND I.D GUM SWAMP -BAY CITY nCOSIN �ZK� X. LIGHT GROUND POCOSIN I.F CROATAN NATIONAL FOREST I.G OPEN GROUNDS POCOSIN I.H HOFMANN FOREST 1.1 HOLLY SHELTER SWAMP I.J ANGOLA SWAMP I.K GREEN SWAMP . IT.A CHOWAN RIVER II.B ROANOKE RIVER ZI.0 TAR RIVER II.0 NEUSE RIVER ME CAPE FEAR -NORTHEAST CAPE FEAR RIVERS III.A CAROLINA BAYS Figure 1. Map Showing Location of North Carolina Peat Deposits -4- and has proceeded at variable rates, generally controlled by changes in climate and sea level. The peat complexes along the Atlantic coast are not like the moss and sedge complexes of the northern United States and Canada. Instead, the organic materials are derived from decomposition of trees, shrubs, and other herbaceous materials common in a coastal marsh and woodland environment. Organic soil depths within the study area can reach a depth of 12 feet, but generally range from 2 to 6 feet.6 Peat is generally found in areas that lack other significant fossil energy resources. This is the case in North Carolina, and, for this reason, it may be economically beneficial for the State to develop its peat as an alternate energy source. North Carolina has an estimated 1,000 square miles (640,000 acres) of peatland, containing about 600 million tons of moisture -free peat. Most North Carolina peat is black, fine-grained, and highly decomposed. The ash content of this peat averages less than 5 percent, compared to 6-15 percent ash content in Eastern coal, which peat would be used to replace. The sulfur content of North Carolina peat averages .26 percent, compared to 1-8 percent for coal. Heating values of peat are high, ranging from 7,000 to 10,000_ Btu per pound, moisture - free, compared to 11,500 to 13,000 Btu per pound for coal. In short, it will take approximately four times the volume and twice the weight of 30 percent moisture content peat to replace Eastern coal.? Although the existence of these extensive peat deposits in eastern North Carolina has been known for at least a century, it has only been in the last five years that this peat has been recognized as a significant source of fuel. Four State permits have been issued for peat mining in the tri-county study area in the last three years (two to First Colony Farms, one to Peat Fuel, Inc., and one to American Peat Co., Inc.), and two applications (from Lantern Acres and Whitetail Farms) are pending. There is not yet an established market for North Carolina fuel peat, but a major market is expected to open up in about five years, when a proposed peat methanol plant is built in the area. The first peat sold has been bought by Weyerhauser paper mill to fuel its new boiler at Plymouth. This boiler can burn peat as well as wood chips, oil, or coal. Discussion of the approved and pending peat projects follows. Figure 2 shows the -5- Washington -Tyrrell -Hyde County study area. FIRST COLONY FARMS is a privately -owned corporation, located in Creswell, North Carolina. First Colony's Phelps Peat Mine covers approximately 15,012 acres in Washington, Tyrrell, and Hyde Counties. First Colony Farms plans to utilize its estimated 204 million tons of moisture -free peat to supply energy to North Carolina for the next several decades.8 To achieve this goal, First Colony has spent in excess of $1 million of private capital on peat development. Major expenditures have been in the research areas of peat harvesting and dewatering. First Colony expects to achieve two objectives by developing its peat resources: o Sale of peat fuel for direct combustion or conversion to synthetic natural gas or methanol; and o Development of fertile farmlands by reclaiming harvested peatlands. A number of studies on peat utilization have been conducted at First Colony Farms since 1974. First Colony has tested European peat harvesting technologies. Soviet" technicians demonstrated the milled peat process at First Colony Farms, and representatives from First Colony also traveled to the Soviet Union and Finland to observe commercial peat harvesting and utilization technologies. Most recently, First Colony Farms has investigated the feasibility of direct combustion of its low -sulfur peat for producing electrical energy. Koppers Corporation, an engineering firm based in Pittsburgh, was contracted to conduct peat gasification experiments at First Colony Farms. In analyzing the possibilities of peat as a fuel for steam generation, First Colony also conducted a joint study with Texasgulf (a fertilizer manufacturing and sulfur processing operation in Aurora, N.C.) on blending peat with fuel oil to reduce the cost of fuel for Texasgulf's drying kilns. Considerable savings could be achieved by such blending, and this pilot project suggests the feasibility of regional use of this supplemental fuel. _ 6- B 5 M q R L E Isi 1b ti U u Laurel Pt "Goat Neck 082Y - - - -_ •' River Neel► ' _- : T _ ~Ft Landi c 0 ^ice=i' ill `�•.. , _ - Ieasant . mb - _ 'f Grove a Travis ,s. _ _ _ / estover. SGuopernon- _ _ Creswel Z_ 'Cherry WA �Cam.r— ]I11_ 1V, t Al. Hinson _ N. _Holc�� �'�—`� :—', ;✓ 'C f Lr� _ `_'— Gum Reek- 7rs iKilkenny \�i _zs+l_ / tA1tE : tta�carrr.,.c�i• T - 1 �nalelhard 14TTAAIU314EET L fl1 '- Goes Ptiddletown aotan RAFtc AC. W LDLIFE REFUGE di LEGEND O County seat C City, town, or village. r� U.S. highway —— State highway Other principal roads —'—County boundary National wildlife refuge Scale 1:500,000 1 inch equals approximately 8 miles 1 Pt �%Z'• Swanouartet Gulrock - jY3_ .. _ N \ 9Ktiy Blutt Pt GrcatL SWANOUARTER NATIONA WILDLIFE REFUGE h PAMLICO SOUND kN, Figure 2. Washington - Tyrrell -Hyde County Study area -7- First Colony Farms' peat is currently being harvested using the milled peat process and the machine sod process. Descriptions of harvesting technologies can be found in Chapter 2 of this report. AMERICAN PEAT COMPANY'S "The 98" project, located on 98 acres in Hyde County, will mine peat at a maximum depth of 48 inches, using bulldozers, trucks, and front-end loaders. American Peat plans to reclaim the mined land by planting row crops on the mineral soil cleared by mine excavation. PEAT FUELS, INC. "Black Acres", the mining project proposed by Peat Fuels, Inc., covers 708 acres in Hyde County. Peat is to be mined by "scrape mining", a variation of the milled peat method, using a self -loading scraper and a tractor -pulled Finnish miller. Excavation may extend to a maximum depth of 4- 1/2 feet. Peat Fuels intends to form the peat into briquettes, which can be burned directly. The land is to be reclaimed for. agricultural production. LANTERN ACRES, INC: S "Phelps Unit", a project whose approval is pending, covers 650 acres in Tyrrell County. The proposed mining method is use of a conveyor and trailer. Maximum depth of excavation would be three feet. Lantern Acres proposes reforestation rather than crop planting as the reclama- tion method. WHITETAIL FARMS has a proposed (but as yet unapproved) peat mining project that covers 7,020 acres in Hyde County, between Lake Mattamuskeet and the Inland Waterway. Whitetail Farms has proposed using the milled peat method. PEAT METHANOL ASSOCIATES. As a one -tenth scale test for a projected 35,000 barrels per day (BPD) plant, Peat Methanol Associates plans to build a pilot plant capable of converting peat into 3,600 barrels of methanol per day. The plant will be located adjacent to First Colony Farms' peatlands, and will ultimately convert all the production from the Phelps Field into synthetic liquid fuel. Figure 3 shows the location of active and proposed peat mining operations and the proposed Peat Methanol plant. 10 /\ t• R i r x s t r s II . • M M LEG3VVE)*. i%First Colony Farms Peat Fuels ® American Peat Lantern Acres Farm ® Whitetail Farms -Proposed Peat Methanol Plant Site _ Z9 ¢V J Figure 3. Location of active and proposed peat mining operations and the proposed peat methanol plant -9- REFERENCES IDOE, Prelim. Eval. of Env. Issues on the Use of Peat as an Energy Source, p. 2- 4. 2ibid, p. 2-1. 3ibid, p. 2-1. 4Midwest Research Institute, Final Report, Peat Program, Phase 1. Environmental Effects and Preliminary Technology Assessment, P. 8. , 5DOE, Prelim. Evaluation of Env. Issues, p. 4-37. 6Heath, R.C., Hydrology of the Albemarle -Pamlico Region, North Carolina, USGS, Water Resources Investigations, 9-75, 1975. 7Campbell, R.N., Jr., First Colony Farms, Inc., Peat for Energy Program, Nov. 1, 1979, p. 3. 8DOE, Peat Prospectus, July 1979, p. 48. -10- 2. AIR QUALITY IMPACTS OF PEAT MINING AND TRANSPORTATION Revelevant Air Quality Regulations Both Federal and State air quality legislation regulates the emission levels of peat development activities in the study area. Pursuant to the Clean Air Act of 1970 as amended, the U.S. Environmental Protection Agency (EPA) has established National Ambient Air Quality Standards (NAAQS) for seven criteria pollutants. The latest version of these standards is shown in Table 1. The primary standards are designed to protect public health, while the secondary standards are intended to protect public welfare from any known or anticipated adverse effects.I In heavily polluted areas, EPA has historically concentrated efforts on attainment of the primary standards. Primary air quality standards are, in general, now being attained in most areas of the country. The notable exception to this trend is oxidants, with entire states not in attainment. Congress included in the Clean Air Act Amendments of 1977 new rules for the prevention of significant deterioration (PSD) of air quality in areas attaining both primary and secondary NAAQS. These regulations apply to the study region because the air in this part of the state is cleaner than the NAAQS dictate. The PSD regulations identify levels by which pollutants may increase within three different class areas. The class areas are defined as follows: o Class I applies to areas in which practically any air quality deteriora- tion would be considered significant, and therefore little or no energy or industrial development is allowed. o Class II applies to areas in which deterioration that would normally accompany normal, well -managed growth would not be considered significant. -11- Table 1. NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS) Pollutant Primary Secondary ug/m3 (ppm) ug/m3 (ppm) CO 80hr Maxa 10,000(9) Same 1-hr Maxa 40,000 (35) Same HCb 3-hr Maxa 160 (0.24) Same (6-9 a.m.) NO2 Annual Arithmethic Mean 100 (0.5) Same Photochemical Oxidants (ozone) 1-hr Maxc 235(0.12) Same Particulates Annual Geometric Mean 75 60 24-hr Maxa 260 150 502 Annual Arithmetic Mean 80 (0.03) -- 24-hr Maxa 365 (0.14) -- 3-hr Maxa -- 1300 (0.5) Lead 3-mo Max 1.5 Same dNot to be exceeded more than one time per year. bThe HC standard is a guide for use in devising plans to achieve the oxidant standard. cStandard is attained when the expected number of days per calendar year with maximum hourly average concentrations above 235 ug/m3 is equal to or less than one. SOURCE: Council on Environmental Quality, IIth Annual Report, December, 1980 -12- o Class III applies to areas in which deterioration would be permitted in order to allow concentrated or very large-scale energy or industrial development, as long as the NAAQS are not exceeded.2 For each designation, maximum allowable increases over baseline concen- trations are established for two of the seven criteria pollutants regulated by the NAAQS: sulfur dioxide (SO2) and total suspended particulates (TSP). These allowable increments are defined for both a long-term (annual) average concen- tration and maximum concentrations over short periods of time. The values are shown in Table 2. The Clean Air Act Amendments of 1977 automatically designated as Class I areas much of the park land and wilderness areas in the United States. The Swanquarter National Wildlife Refuge in Hyde County was included in this designation.3 The remainder of the tri-county study area is a Class II area. To assess emission levels from new sources and the consumption of the allowed increments, certain classes of proposed sources of pollution in PSD areas must be reviewed before construction can take place. Major stationary sources (generally defined as sources having the potential to emit 250 or more tons per year of any regulated pollutant), as well as certain industrial and power generation facilities specifically listed in the Act, require pre -construction review. Included in this latter category are fuel conversion plants, fossil fuel - fired steam electric plants, coal cleaning plants, and fossil fuel boilers.4 The proposed peat methanol plant, which is a fuel conversion plant, is one of these industrial facilities. Therefore, a PSD permit is required, outlining the control measures that will be taken to limit pollutant emissions to acceptable levels so that the designated allowed increments for either a Class II area or the nearby Class I area will not be exceeded. The proposed facility must also use the best available control technology (BACT) for each of the regulated pollutants emitted in significant quantities. Monitoring may be required for the facility to -13- Table 2. MAXIMUM ALLOWABLE INCREASES UNDER PREVENTION OF SIGNIFICANT DETERIORATION (PSD) REGULATIONS (Micrograms per cubic meter) CLASS I Pollutant Particulate Matter: Annual Geometric Mean 5 24-hr Maximum 10 Sulfur Dioxide: Annual Arithmetic Mean 2 24-hr Maximum 5 3-hr Maximum 25 CLASS II Particulate Matter: Annual Arithmetic Mean 19 24-hr Maximum 37 Sulfur Dioxide: Annual Arithmetic Mean 20 24-hr Maximum 91 3-hr Maximum 512 CLASS III Particulate Matter: Annual Geometric Mean 37 24-hr Maximum 75 Sulfur Dioxide: Annual Arithmetic Mean 40 24-hr Maximum 182 3-hr Maximum 700 SOURCE: The Clean Air Act Amendments of 1977 (U.S. Congress PL 95-95). -14- determine pre -construction air quality and/or the effect of its emissions after startup on the surrounding air quality. The Clean Air Act, as amended, is scheduled for reauthorization and is expected to be revised to some extent. Some of these revisions could affect the regulatory measures issued in support of the Act, which in turn might affect air quality planning for the study region. Although the extent of these revisions cannot be anticipated at this time, the Reagan administration has released drafts of its proposed revisions. Several of these proposed revisions have direct relevance to the study region and the existing and proposed peat mining and processing facilities. The more relevant suggested changes are as follows: o While no change is proposed for the health -based "primary" national air quality standards (NAAQS), the "secondary" standards designed to protect crops and property would be eliminated, leaving such regula- tion up to the States. • o Special protection for areas with air cleaner than the law provides (PSD areas) would be eliminated, except near national parks and wilderness areas. o There would be no mandatory penalties for polluters who fail 'to comply with the law. The Administrator of EPA would have discretion to determine whether and how to penalize violators.5 Hearings on these changes and others proposed by the administration are now ongoing in Congressional committees. Definitive action by the entire Congress is necessary before the changes, if any, can be implemented. However, air quality planners in the region should realize that the current Federal regulations are subject to revision and watch for further developments as the reauthorization process continues. -15- State air quality regulations control ambient levels of the same seven criteria pollutants that the Federal government regulates (particulates, sulfur dioxide, nitrogen dioxide, carbon monoxide, hydrocarbons, ozone and lead). The State standards coincide with the primary NAAQS for all seven pollutants and for all averaging times, except 24-hour particulate. The 3-hour SO2 standard is a secondary NAAQS; however, no primary 3-hour standard exists. The State of North Carolina changed its annual particulate standard from 60 ug/m3 to 75 ug/m3 on October 15, 1981. In addition to the ambient air quality standards, the State has emission limits for point sources of pollution for each of the regulated pollutants. The emission levels for potential peat -burning facilities, as defined in the North Carolina State Implementation Plan for Air Quality, are shown in Table 3. Peat Harvesting Methods The potential emissions from peat harvesting operations include two major types of pollutants: (1) fugitive dust emissions from peat harvesting, handling, and storage operations; and (2) exhaust emissions (carbon monoxide, hydro- carbons, nitrogen oxides, and particulates) from the machinery and vehicles associated with the harvesting operations. Windblown fugitive dust emissions will be the primary emissions from the harvesting site.? The amount of dust generated and then transported by wind depends on a number of factors. These include: o Meteorological factors, such as wind speed and direction and relative humidity; o The physical characteristics of the peat being mined, including its moisture content and particle size, shape, and surface texture; and o The harvesting procedures employed, including the dewatering tech- niques used to dry the peat before harvesting. -1 b- TABLE 3. N.C. EMISSION CONTROL STANDARDS FOR POTENTIAL PEAT -BURNING FACILITIES* Particulates: Heat Input (Million Btu/hour) Up to and including 10 100 1,000 10,000 and greater Maximum Allowable Emission (lbs/Million Btu) 0.60 0.33 0.18 0.10 S09: Maximum allowable emission not greater than 2.3 pounds of S02 per million Btu imput. NO?: Maximum allowable emission not greater than 1.3 pounds per million Btu of heat imput per hour from a coal-fired boiler with a capacity of 250 million Btu or more. SOURCE: North Carolina Administrative Code, Title 15, Chapter 2, subchapter 2D: Air Pollution Control Requirements. *Federal New Source Performance Standards (NSPS) may apply to certain peat - burning facilities. If found applicable, the NSPS supersede the above state limi- tations. For example, the coal NSPS for an industrial facility limits W02 emissions to 1.2 pounds per million Btu; NOx to 0.6 pounds per million Btu and TSP to 0.1 pounds per million Btu. -17- The last factor is the only one that can be significantly controlled to reduce emission levels. There are four methods currently employed for harvesting peat which vary in the amount of particulate emissions generated. These include manual, sod peat, milled peat, and hydraulic harvesting techniques. The potential air quality impacts of each method are discussed separately in the following sections. MANUAL HARVESTING. This method of harvesting is the simplest of the four harvesting methods and only involves mechanically digging large chunks of peat from the bog's surface and transporting them to a drying facility. Little or no air emissions are produced by this harvesting procedure since the peat is reined when it is wet and allowed to dry in covered facilities off -site. The manual method is the least efficient of the harvesting techniques and, therefore, is not applicable to large-scale commercial operations. SOD PEAT HARVESTING. During sod peat production, machines are used to excavate the peat, cut it into sods, or small chunks, and deposit these over the field to dry. The peat is then collected and stockpiled when the sods are dry enough for burning. There is little air quality impact during the excavation procedure as the peat retains 90 percent of its moisture during this procedure.$ Some fugitive dust emissions may occur during the drying and stockpiling stages of production. However, the peat is not in a fragmented state when drying, and dust emissions are significant only during extremely windy conditions. Also, since this harvesting method is not as efficient as the milled peat method for large tracts of land, it is usually only employed on smaller sections of the total harvesting area. This further reduces the windblown dust emissions that might result from the excavated area. MILLED PEAT HARVESTING. Milled peat is produced by slicing off a thin layer of peat and then cutting or milling this layer to smaller chunks to facilitate drying. The milled peat is also turned over several times during the drying stage. It can be harvested in two ways: by scraping the dried peat into ridges and then -18- stockpiling it in centrally located piles for collection, or by using a large vacuum collector, which sucks up the milled peat particles when passing over the field and collects them in a covered bin. All stages of this harvesting method are dusty. A field of loose particles is left exposed during the procedure, and any disturbance, such as wind or movements of machinery, will generate dust. Handling of the milled peat also generates dust, especially when it is collected with the vacuum collector. Quantification of the amount of fugitive dust emissions is not possible because of the different meterological and topographic conditions existing at each harvesting site. However, it has been estimated that these emissions could be as high as 10 percent of the total peat harvested.9 HYDRAULIC PEAT HARVESTING. Hydraulic harvesting of peat utilizes a portable pump and slurry pipeline system on peatlands that have been cleared of trees and roots and soaked with water. The slurry is then screened to separate the fine peat fibers from larger woody fibers and sent to a dewatering plant. After a mechanical dewatering process, the peat is ready for burning. This process is still in the developmental stages and is only being employed in experimental areas for research purposes. However, the technique has significant potential for areas with existing air quality problems since there are very few emissions associated with this harvesting method. Peat dust emissions will only occur after the peat is dried and then handled at the dewatering plant.10 Further research on hydraulic harvesting and mechanical dewatering techniques is expected to make this method commerically feasible for larger - scale peat operations in the near future.11 The harvesting technique expected to be used for peat operations in North Carolina is primarily the milled peat method.12 This harvesting method is most applicable to a large-scale peat operation since it is the most efficient and the least expensive means of production. However, this method also generates the -19- largest amount of fugitive dust and would possibly require mitigation measures to control excessive dust emissions from the harvesting site. The mitigation measures most commonly employed for milled peat harvesting operations include the following techniques: o Planting vegetative windbreaks on the prevailing wind side of the peat drying fields and/or between the fields; o Harvesting peatlands in narrow strips perpendicular to the prevailing winds; o Roughening the land surface by making a series of ridges in the fields which trap windblown particles and reduce the wind speed across the fields; o Wetting the fields to form a crust on the soil resistant to wind erosion.13 PEAT TRANSPORTATION Several modes exist for transporting the harvested peat to potential end uses. These include truck, rail, or barge tows. The mode used depends on the scale of mining operations, the location of the harvesting site, the type of end use receiving the peat, and its location. The major end uses expected for the existing and proposed peat operations on the Albemarle -Pamlico Peninsula are process heat and the proposed peat methanol plant.14 The following sections compare the economic feasibility and air quality effects of each of the transportation modes. TRUCKS. Current consumers of peat receive it via truck shipments. Given the small scale of peat operations at the present time, truck transport is the most economically favorable. -20- About two pounds of peat are required to replace a pound of coal for fuel purposes (generation of process heat). The increased weight and bulk of peat result in higher transportation costs per unit of energy. Thus, to be competitive, peat has to be available at the user site at a price, including transportation costs, roughly half that of delivered coal. Although economies of scale have yet to be accurately computed, some First Colony Farms officials believe that peat can compete with coal within a 60-mile radius of their Washington County operation.15 The emissions from truck transport include fugitive dust generated at the harvesting site and exhaust emissions. The dust emissions can be controlled by wetting the haul roads, a normal procedure for this type of mining facility. However, these emissions could be significant given large scale operations and long haul distances, even with application of such mitigation measures. Fugitive dust emissions from harvesting, stockpiling, and loading at the harvesting site are more difficult to control and -present a far greater source of air contamination than transport vehicles traveling to and from the site. Trucks used for transporting peat are commonly the heavy-duty type, with diesel engines. Diesel trucks emit pollutants from exhaust, crankcase blow -by, and fuel evaporation. Crankcase blow -by and fuel evaporation have been practically eliminated as major sources of pollution in the diesel engine. Blow - by has been practically eliminated because only air is in the cylinder during the compression sroke. The low volatility of diesel fuel, along with the use of closed injection systems, essentially eliminates fuel evaporation losses. Exhaust emissions from diesel engines have the same general character- istics as auto exhaust. Concentrations of some of the pollutants, however, may vary considerably. Emissions of sulfur dioxide are a direct function of the fuel composition. Thus, because of the higher average sulfur content of diesel fuel, as compared with gasoline, sulfur dioxide emissions are relatively higher from diesel exhausts. Because diesel engines allow more complete combustion and use less volatile fuels than spark -ignited engines, their hydrocarbon and carbon monoxide emissions are relatively low. Because hydrocarbons in diesel exhaust -21- are largely unburned diesel fuel, their emissions are related to the volume of fuel sprayed into the combustion chamber. New, improved, needle valve injectors, which reduce the amount of fuel burned, can reduce hydrocarbon emissions as much as 50 percent. High temperatures and large excesses of oxygen involved in diesel combustion are conducive to high nitrogen oxide emissions. Particulates from diesel exhaust are in two major forms --black smoke and white smoke. White smoke is emitted when the fuel droplets are kept cool in an environment abundant in oxygen (cold starts). Black smoke is emitted when the fuel droplets are subjected to high temperatures in an environment lacking oxygen (road conditions). A hot diesel engine properly adjusted and operated under design loads should emit no visible smoke.16 BARGES. Should future markets for peat be established at inland markets, near navigable waterways, barge tows could be used to transport peat from the Pamlimarle deposits. Factors contributing to the attractiveness of barging are its relatively low costs, the extensiveness of navigable waters between the peat deposits and potential consumers, and the large parcel of land First Colony owns along the Alligator River. First Colony Farms has tentative plans to build a barge terminal and loading facilities along the river. If peat is moved from Washington County deposits by barge, as many as four barges per day could be added to the Atlantic Intracoastal Waterway traffic between the Albemarle and Pamlico Sounds.17 Barges have diesel internal combustion engines; thus emissions from barge transport are much the same as those that could be expected from truck transport. Major pollutants emitted by barges would be nitrogen oxides, sulfur oxides, carbon monoxide, and particulate matter. Amounts of the pollutants emitted would vary with the speed of the vessel.18 Fugitive dust emissions could also be expected from barge transport. Fugitive dust emissions could occur at the loading terminals. The level of emissions would depend on the type of equipment used for loading and off - -22- loading, and whether the peat was covered by tarpaulins. None of these factors has been determined yet, since peat harvesting operations have not yet reached a level that would justify the construction of barge loading terminals. If and when the use of peat for process heat becomes more attractive, barge transport may become more economically feasible as well. INTERNAL RAIL OR CONVEYOR SYSTEM. Commercial rail transport is not a feasible mode for moving peat throughout the region at the present time. Rail service does not exist in Washington, Hyde, and Tyrrell Counties. It is also unlikely that rail lines to the west of the study area will extend their rail beds eastward for the sole purpose of transporting peat. Aside from the economic constraints to establishing new rail service to the peat country, physical constraints also exist. For example, the high water table and the sensitive hydrological systems characteristic of the peat region would make siting a rail bed both difficult and expensive. First Colony Farms management has indicated that, in order to minimize haul distance, peat to be converted to methanol would be moved on a privately - owned, internal transportation network. The network would consist of either railroads or conveyors from the peat fields to the methanol plant. It is anticipated that the peat transport system would be separate from any existing highway and/or rail system.19 The conveyers or rails would go from the fields to the methanol plant, located at the approximate midpoint of the peat deposits.20 Fugitive dust emissions when loading and harvesting peat would be the major source of pollutants from the conveyor mode. The emissions could be controlled by wetting the peat stockpiles before loading and covering the peat while it is being conveyed. -23- REFERENCES 1The Clean Air Act as Amended, 1977, U.S. Congress PL 95-11, U.S. Govt. Printing Office, Washington, D.C., p. 16. 2Martha H. Conklin, "The Potential Air Quality Impacts of Harvesting Peat in Northern Minnesota", prepared for the Minnesota Dept. of Natural Resources by Energy Research be Technology, Inc., St. Paul, Minnesota, 1978, p. 2-4 and 2-5. 3Committee on Prevention of Significant Deterioration of Air Quality, 1981, On Prevention of Significant Deterioration of Air Quality, National Academy Press, Washington, D.C., p.7. 4The Clean Air Act as Amended, op. cit., p. 88-89. 5Morris A. Ward, "The Clean Air Act Controversy: Congress Confronts the Issues" in Environment, vol. 23, no. 6, July/August, 1981, p.8. 6Russell Hageman, N.C. Dept. of Natural Resources and Community Development, oral communication, August 10, 1981. 7Altay Ertugrul and R.F. Sober, "Effects of Peat Harvesting and Gasification on Air Quality" in Management Assessment of Peat as an Energy Resource, Executive Conference Proceedings, July 22-24, 1979, Arlington, Virginia, p. 176. 8Conklin, 92. cit., p. 3-7. 9Ertugrul and Sober, oR. cit., p. 179. 10Conklin, op. cit., p. 3-9. 11Ertugrul and Sober, 92. cit., p. 179. 12James Simons, N.C. Dept. of Natural Resources and Community Development, oral communication, August 21, 1981. -24- 13Conklin, off. cit., p.4-1 to 4-4. 14James Smith, N.C. Department of Natural Resources and Community Development, written communication, August 3, 1981, p. 1. 15Campbell, R.N., Jr., First Colony Farms, Inc., Peat for Energy Programs, November 1, 1979. 16U.S. Environmental Protection Agency Compilation of Air Pollution Emission Factors, Second Edition, April 1973, p. 3.1.5-1 17University of North Carolina, Institute for Transportation Research and Education: Coastal Energy Transportation Study, Phase I Report, December 1980, p. 26. 18U.S. Environmental Protection Agency, op. cit., p. 3.1.5-1. 19Campbell, M. cit. 20Ibid. -25- 3. AIR QUALITY IMPACTS OF PEAT UTILIZATION End Uses for Peat The potential end uses for the peat produced from the Albemarle -Pamlico peninsula include the following: o industrial process heat, o space heat, o conversion to domestic briquettes, and o conversion to methanol.l Each of these uses has varying emission levels that could potentially affect the study region's ambient air quality. The expected pollutants and estimated level of impact are described briefly for each process in the following sections of the report. INDUSTRIAL PROCESS HEAT. Peat can be used as a fuel source, replacing other fuels such as coal, oil, or wood, to provide heat for industrial processes. This will be the greatest use of the peat deposits in eastern North Carolina until the proposed methanol plant comes on line in 1985. The direct combustion of peat results in air emissions similar to those produced by coal combustion. The major potential pollutants include particulates, sulfur oxides (SOX), nitrogen oxides (NO X), hydrocarbons (HC), carbon monoxide (CO), carbon dioxide (CO2), and trace elements such as mercury.2 Each of these pollutants can be reduced to acceptable levels using the same technologies normally employed for coal -burning facilities. These control measures include dust collectors and filters at the various handling points for peat, electrostatic precipitators or fabric filters for controlling particulate -2 6- emissions from the exhaust stacks, and regulated combustion techniques to ensure complete combustion of the peat and minimize formation of nitrogen oxides in the combustion chamber. Testing of peat samples from the peatlands owned by First Colony Farms indicates that this peat should burn considerably cleaner than Eastern coal.3 As stated in Chapter 1, peat has an average sulfur content of .26 percent compared to a range of 1 to 8 percent for coal. The average ash content for peat is 4.75 percent compared to a 6 to 15 percent average ash content in coal.4 These lower levels of sulfur and ash, which comprise two of the main pollutants from coal combustion, are a major advantage that the combustion of peat has over the high -sulfur Eastern coal normally used for process heat. SPACE HEAT. Peat can replace either oil or coal when combusted for space heat. The emissions will be less than those from coal used for this purpose due to the lower sulfur and particulate content of peat. CONVERSION TO DOMESTIC BRIQUETTES. Peat briquetting is mainly a compaction process whereby milled peat is formed into small briquettes that can be used for boiler firing and domestic heating. The peat is first screened and blended to produce a homogeneous feedstock, which is then dried to a moisture content of about 10 percent. This material is then compacted to produce the peat briquettes. The emissions expected from this process include particulates and fugitive dust from the handling and drying processes, and the same combustion pollutants discussed above, which result from burning the peat to provide process heat for the briquetting plant. The dust emissions can be mitigated for the most part by control measures employed at the plant site. These include such measures as enclosing the unloading facilities, using a dust collector to clean the air in the building before it is vented to the outside, and wetting or using encrusting agents on the stockpiles of peat to prevent wind erosion. Fugitive dust in the exhaust gases from the drying kiln can be controlled by electrostatic precipitators. The combustion pollutants emitted from the plant can be controlled by the tech- -27- nologies, listed previously, which are normally employed for coal -burning faci- lities. CONVERSION TO METHANOL. The process to produce methanol from peat combines the Koppers process, a well -established technology for converting high - carbon materials (coal, peat, wood, biomass, or garbage) to process gas (carbon monoxide and hydrogen) by controlled combustion at a very high temperature (+3,0000 F) and near -atmospheric pressure; and a catalytic process for converting process gas to methanol. A 200,000 gallon per day (4,762 barrels per day) peat -to -methanol pilot plant near Creswell, N.C., has been proposed for converting the peat mined from First Colony Farms' Phelps Peat Mine to methanol.6 This plant will use 2,500 tons of milled peat per day for its conversion operations. Construction is scheduled to begin during 1983, and full production is planned for the third quarter of 1985. The environmental permits, including a Prevention of Significant Deterioration (PSD) permit from the North Carolina Department of Natural Resources and Community Develop-ment, are now being obtained for the plant. Since fuel conversion represents one of the most significant future uses of peat mined in eastern North Carolina, its potential air quality impacts will be discussed in detail. General process descriptions, data, and analyses supporting permit applications for the pilot plant will be considered as representative of air quality concerns associated with this type of end use. A peat -to -methanol conversion plant requires several different operations to produce a fuel grade methanol product. First, the harvested peat is trucked to the site and stockpiled. The peat is then dried in a kiln and pulverized to produce the feedstock for gasification. It is then gasified, and the gas subsequently cleaned, cooled, compressed, desulfurized, and further processed to produce the fuel grade methanol. The methanol is stored before being sold to distributors for marketing as a liquid fuel for vehicles or for gas or steam generators. -28- The expected pollutants from a fuel conversion plant include particulates; sulfur oxides (SOX), nitrogen oxides (NO X), hydrocarbons (HC), carbon monoxide (CO), carbon dioxide (CO2) and certain hazardous pollutants. The first five listed are criteria pollutants and are regulated by Federal and State air pollution laws, as described in Chapter 2. The expected emissions of these five pollutants from the plant during normal operations are provided in Table 4. These emission levels were estimated by Peat Methanol Associates in its PSD permit application submitted to North Carolina's air quality review agency. The regulated limits of the pollutants requiring application of control technologies are also shown in Table 4. Three regulated but non -criteria pollutants are expected to be emitted by the plant --hydrogen sulfide (H25), carbonyl sulfide (COS), and mercury (H9)$. The emission level of only one of these, carbonyl sulfide, will exceed the minimum level requiring a PSD review (greater than 10 tons per year). The expected emissions for the trace elements are given in Table 5. . These pollutants can be controlled by a number of procedures utilized during the manufacturing process and by application of readily available pollution control technologies. These measures include: o chemical encrusting agents for peat stockpiles, o wet dust supression systems for peat dumping emissions and haul roads, o electrostatic precipitators, o flame incineration of miscellaneous process gases, o a sulfur recovery unit and sulfur emissions control equipment, o a baghouse for particulate emissions control and flyash removal, o a COS hydrolysis reactor for carbonyl sulfide emissions control, and o enclosed peat handling and storage facilities.9 These measures and other procedures employed by the plant will maintain the emission levels below State and Federal standards at each point source in the plant's manufacturing process. The Best Available Control Technology (BACT) has been applied to each source emitting any one of the criteria pollutants to achieve this control. -29- TABLE 4: CRITERIA POLLUTANT EMISSIONS FROM THE PEAT METHANOL PLANT 1 Minimum Emission Minimum Emission Potential Plant -Wide Levels Requiring Levels Requiring Pollutant Air Emissions (TPY)2 PSD Review (TPY) BACT Review (TPY) Particulates 120.4 100 25 Sulfur Oxides (SOX) 685.9 100 40 Nitrogen Oxides (NOYx) 560.0 100 40 Carbon Monoxide (CO) 1032.6 100 100 Hydrocarbons (HC) 95.0 100 40 Emission levels are subject to revision pending final permit approval. 2TPY = tons per year SOURCE: Peat Methanol Assoc., PSD Permit Application, Vol. 1, June 1, 1981. TABLE 5: NON -CRITERIA POLLUTANT EMISSIONS FROM THE PEAT METHANOL PLANT' Pollutant Hydrogen Sulfide (H2S) Carbonyl Sulfide (COS) Fluorides (HF) Mercury (HG) Beryllium (Be) Potential Plant -Wide Air Emissions (TPY)2 1.0 36 0 0.065 0 Minimum Emission Levels Requiring TSD Review (TPY) Emission levels are subject to revision pending final permit approval. 2TPY = tons per year SOURCE: Peat Methanol Assoc., PSD Permit Application, Vol. 1, June 1, 1981. !0 10 3 0.1 0.0004 -30- The expected emissions from that portion of First Colony Farms' mining operation associated with methanol production were modeled by Peat Methanol Associates, using the Industrial Source Complex (ISC) atmospheric dispersion model to determine the effect of these emissions on surrounding air quality. The results of this model are shown with the applicable Federal and State standards in Table 6. The predicted emissions from the plant, as shown in the table, are easily within the allowed PSD increment levels for a Class II area. Particulate emissions from First Colony Farms mining operations were also included in the model and, when combined with the particulate emissions from the plant, do not exceed either the PSD increment level or the State air quality standard for particulates. Furthermore, the predicted emissions from the plant and harvesting operations do not exceed the PSD Class I increments nor are they expected to cause significant visibility impairment at the nearest Class I area, Swanquarter National Wildlife Refuge, located 17 miles (27 km) south of the proposed plant site.10. Although the predicted emissions from a 4,762 barrel per day (BPD) peat - to -methanol plant in the study region are not expected to adversely affect the study region's air quality, the proposed 4,762 BPD plant is actually a pilot project for a possible 35,000 BPD plant, which would utilize more fully the vast peat deposits in eastern North Carolina, with a concomitant increase- in emissions. Simple scaling of the predicted pilot plant's impacts demonstrates that the region's air resources could not support the 35,000 BPD plant and, in fact, could not even support a 10,000 BPD plant without violation of Class II TSP increments. A 15,000 BPD plant would produce SO2 impacts exceeding the Class I increments at Swanquarter National Wildlife Refuge if its emissions were proportional to those expected from the 4,762 BPD plant and the same modeling methodology were followed. Due to the particulars of the process emissions, materials handling, and source -receptor geometry, simple scaling of TSP emissions probably results in overestimation of TSP impact from a full-scale plant in the Class II area. However, scaling should provide a reasonably valid indication of SO2 concentrations expected in the nearby Class I area so long as emissions are proportional. This finding implies that energy development in this area may be hampered by the proximity of the Class I area if the same emissions characteristics, meteorological data, and modeling techniques are used in the future as have already been used for the -31- TABLE 6: PEAT METHANOL ASSOCIATES MODELING RESULTS: MAXIMUM OFF PROPERTY PREDICTED CONCENTRATIONS1 Averaging New Mine Baseline Total Class II N.C. Air Pollutant Period Site Plant Background Predicted Increment Quality Standard Particulates Annual 3.24 0.12 40 43.36 19 60 24-Hour 12.40 7.34 40 59.7 37 150 Sulfur Dioxide Annual 0.98 - 20 20.98 20 80 24-Hour 6.42 - 20 26.42 91 365 3-Hour 26.41 - 20 46.41 512 1,300 Carbon Monoxide 8-Hour 80.12 - 1,000 1,080.12 - 10,000 ^' 1-Hour 230.05 - 1,000 1,230.05 - 40,000 Nitrogen Dioxide Annual 0.67 - 20 20.67 - 60 Carbonyl Sulfide (COS) 1-Hour 9.67 - 0 9.67 - - All minimum concentration and standards expressed in micrograms per cubic meter ug M . 2Subject to revision pending final permit approval. SOURCE: Peat Methanol Associates, PSD Permit Application, Vol. 2, June 1, 1981. Peat Methanol Associates pilot conversion plant. A discussion of air quality monitoring and modeling in this context is given in Chapters 5 and 6. -33- REFERENCES IJames Smith, N.C. Dept. of Natural Resources and Community Development, written communication, August 3, 1981, p. 1. 2Altay Ertugrul and R.F. Sober, "Effects of Peat Harvesting and Gasification on Air Quality" in Management Assessment of Peat as an Energy Resource, Executive Conference Proceedings, July 22-24, 1979, Arlington, Virginia, p. 174. 3R.N. Campbell, Jr., "First Colony Farms, Inc., Peat for Energy Program," November 1, 1979, p. 3. 4Ibid. 5UOP/SDC, A Joint Venture, "Peat Prospectus," report prepared for the U.S. Dept. of Energy, July 1979. 6Peat Methanol Associates, PSD Permit Application, Vol. 1, submitted to N.C. Division of Environmental Management, June 1, 1981, p. 1. 7Ertugrul and Sober, 22. cit., p. 174. 8Peat Methanol Associates, op. cit., p. 4. 9Ibid., p. 5-6. 10Peat Methanol Associates, PSD Permit Application, Vol. II, submitted to N.C. Division of Environmental Management, June 1, 1981, p. 27. 11 James Smith, "Methanol Conversion: Probable Fate of First Colony's Phelps Field Peat," internal report for N.C. Dept. of Environmental Management, 1980, P. 1. -34- 4. AIR QUALITY IMPACTS OF INDUSTRIAL FACILITIES IN THE REGION Existing Ambient Air Quality The ambient air quality of most of the study region is expected to be relatively clean, with the exception of particulates, which are probably present in moderate quantities. Emissions from several point sources outside the region and vehicular traffic and farming operations within the region contribute the major portion of the background pollutant levels. The only State -operated monitoring station in the study region is at Plymouth, in Washington County. The Plymouth air quality station is a "manual" station collecting 24-hour average samples once every six days. The SO2 sampler is a reference method bubbler, while the NO2 sampler is an equivalent sodium arsenite bubbler.1 The particulate sampler is a reference method High Volume sampler. The type of gaseous pollutant sampling equipment and procedures used at a manual station generally result in data of lesser resolution and quality than the more modern "continuous" analyzers, which are installed at numerous other locations around the State. Measurements of total suspended particulates taken at Plymouth should be comparable in accuracy to those taken elsewhere since the same type of equipment is used. The lack of modern, automated continuous air qualtiy monitoring stations in the study region seriously hampers analysis of existing air quality. The annual values for total suspended particulates (TSP), sulfur dioxide (S02), and nitrogen dioxide (NO2) concentrations recorded at the Plymouth station from 1975 to 1980 are shown in Table 7. The data for 502 and NO2 show the area to be remarkably free of these pollutants, . with annual average concentrations comprising less than 20 percent of the Federal and State standards. Although monitored values have trended upward in the last few years, they remain less than those commonly assumed by EPA to apply to a "clean" rural area. These EPA values are listed in Table 8. Considering the uncertainty resulting from the low frequency of sampling and the use of previous generation sampling equipment, it is recommended that these EPA rural values be -3 5- Table 7. MEASURED ANNUAL CONCENTRATIONS FOR THREE CRITERIA POLLUTANTS TAKEN AT PLYMOUTH, N.C., FROM 1975-1980 Year N.C. Air Quality Pollutant (ug/m3) 1975 1976 1977 1978 1979 1980 Standard TSP 44 49 44 43 48 56 60 S02 ' 5 5 f 5 6 12 8 80 NO2 13 12 17 18 11 18 100 SOURCE: N.C. DNR & CD, Division of Environmental Management, Air Quality Section, July, 1981. -36- Table 8. ASSUMED CONCENTRATIONS FOR CRITERIA POLLUTANTS IN AN EASTERN U.S. RURAL AREA (Micrograms per cubic meter) Pollutant 24 Hour 8 Hour 3 Hour 1 Hour Annual CO - 1,000 - 1,000 - NO2 - - - - 20 TSP 40 - - - 40 S02 20 - 20 - 20 : The Ambient Monitoring Guidelines for Yreven- 4nificant Deterioration (PSD). EPA 45012-78-019. -37- considered representative of 502 and NO2 background air quality in those portions of the study area remote from the point sources discussed in the next section. The recorded measurements of suspended particulates have significantly increased during the last two years. Measurements of this pollutant at other monitoring stations in eastern North Carolina are even higher but may not be representative of the Study Region. This trend, if truly region -wide, would have special relevance to peat mining in the area, since particulate emissions from mining operations can be significant. Based on the assumption that regional particulate loadings are primarily the result of agricultural activities and open burning, concentrations in much of the region probably approximate those measured at Plymouth --relatively high but still in compliance with the NAAQS. Even though a major SO2 and TSP source is located near Plymouth (the Weyerhauser paper plant), the Plymouth monitor is apparently receiving little contribution from this plant due to its distance from the source and the monitor's relative location with respect to the prevailing directions of effluent transport from the Weyerhauser sources. This conclusion is supported by the very low SO2 concentrations recorded at the Plymouth station. (Table 9 shows that Weyerhauser emits 18,445 tons to SO2 per year but only 3,693 tons of particulate matter per year). Existing Point Sources of Pollution in the Region The tri-county study region is primarily a rural area which enjoys, with the exception of particulates, relatively clean air, as discussed in the preceding section. Certain industrial facilities located primarily to the northwest of the region emit pollutants that affect the region's background air quality levels. The locations of these facilities are shown in Figure 4. Each facility shown is within a 50-kilometer (31-mile) radius of the study region and emits greater than 100 tons per year (TPY) of any one of the criteria pollutants. The emissions levels for each facility, as recorded by the Division of Environmental Management, are provided in Table 9. 0 -38- TABLE_ 9. STATIONARY SOURCES OF POLLUTION AFFECTING THE STUDY REGION'S AIR QUALITY Total Emissions (tons/year) Number Location Facility Particulates 502 NOx HC CO 1 Aulander National Peanut Corp. 397 1 1 - - 2 Lewiston Weyerhaeuser Co. 397 190 36 2 2 3 Windsor Coulbourn Lumber Co. 485 75 141 64 127 4 Windsor Gilliam Bros. Peanut Shelters 174 - - - - 5 Edenton United Piece Dye Works 54 322 59 229 4 6 Williamston Central Soya Grain 357 - - - - 7 Chocowinty Singer Furniture Co. 271 49 16 10 2 8 Aurora Texasgulf Sulfur Co. 904 210142 1,129 30 40 9 Plymouth Weyerhaeuser Co. 3,693 18,445 7,719 1,051 23,028 10 Plymouth Georgia Pacific Corp. 192 20 135 27 27 11 Plymouth True Temper Corp. 396 6 38 8 8 12 Creswell First Colony Farms 206 - - - - SOURCE: N.C. DNR & CD, Division of Environmental Management, Air Quality Section, August, 1981. Figure 4. Existing industrial sources of pollution in study area. -39- As evident in the table, the most significant stationary source affecting the study region's air quality is the Weyerhauser paper mill just outside of Plymouth. This paper mill is one of the largest. in the State and has undergone significant improvements in its control equipment and boilers to reduce emission levels during the last ten years.3 These measurements include replacement of outdated boilers with more efficient, multi -fuel burning units, installation of electrostatic precipitators to reduce particulate emissions, and the addition of sulfur emissions control equipment primarily for odor control. The plant is now in compliance with State and Federal regulations for each of the criteria pollutants. The second major stationary source of air pollution in the vincinty of the tri-county study area is the Texasgulf fertilizer manufacturing plant in Aurora. This plant is approximately 29 miles (46 km) away from the peat mining operations in the study region. However, the plant's SO2 emission levels are high enough to contribute to the SO2 background levels in the study region's air resource. The Texasgulf plant is currently in non-compliance with State SO2 emission regulations, as measured by the plant's own monitoring instruments. Sulfur emissions control equipment is now being added to alleviate this problem, and heights have been raised on three of the plant's exhaust stacks.4 The effect of these measures on ambient air quality has not yet been determined. The magnitude of SO2, NOx and TSP emissions from these two sources may reasonably be expected to periodically result in substantial ground -level concen- trations of these pollutants in those portions of the study region within 10 or 15 km downwind of the emission points. Primary Impacts of Existing Industrial Development in the Region There are only two industrial facilities located within the study area's boundaries that are emitting more than 100 tons per year of a criteria pollutant. These are Georgia-Pacific Corporation and True -Temper Corporation in Washington County. (The Plymouth Weyerhauser Plant is technically located just outside of the study region in Martin County). Background pollutant levels _►0- within the region are affected by these point sources, by other sources located just outside of the region, by transportation -related sources such as vehicular exhaust emissions and fugitive dust emissions from traffic on unpaved roads, and by miscellaneous sources such as agricultural tilling, land clearing, and peatland fires. Outside of Plymouth, transportation and miscellaneous sources of pollu- tion are the major contributors to emissions.5 Since gaseous pollutant (NO2, SO2, CO) air quality in the region appears to be very good and particulate concentrations appear to be within allowable limits, it would appear, on the surface, that substantial industrial development and accompanying emissions could be accomodated. This may not be the case. In fact, industrial development in most of the southern half of the region may be severely restricted due to the proximity of the Class I PSD area. This potential problem was previously identified and discussed in Chapter 3 in the context of the proposed Peat Methanol fuel conversion pilot plant. The large fraction of Class I, 24 hour average increments predicted to be consumed by this very small and relatively distant facility demonstrated the seriousness of this situation. The presence of this Class I area and the Federal regulatory requirements associated with it result in the following potential effects on future industrial development in the region as a whole and in the southern half in particular: 1. Permitting schedules for potential industrial facilities could be pro- tracted, and permitting costs relatively higher, due to the special analyses required. 2. Potential industries may be rquired to scale down facility sizes that would otherwise be desireable. 3. Potential industries may incur a heavy financial burden for air pollution control equipment and operations and maintenace costs to control pollutants to levels not required elsewhere. -41- 4. The total available increment may be consumed by the first few facilities locating in the region. This may have a constraining effect on future regional development, depending on the placement of additional sources in relation to receptors. The only other portion of the study region with potentially poor air quality is that portion of Hyde County closest to the Texasgulf fertilizer manufacturing plant in Aurora. When winds are blowing from the southwest quadrant, sulfur dioxide (SO2) emissions from this plant contribute to the ambient concentrations of SO2 in Hyde County. There are currently no monitoring stations in Hyde County to record the degree of impact that may be occurring. However, modeling efforts conducted by the State during 1979 predicted SO2 concen- trations averaged over a period of 24 hours to be approximately 200 ug/m3 in the vincinity of the Swanquarter National Wildlife Refuge.6 Although this predicted level does not violate either Federal or State standards for ambient SO2 concentrations (365 ug/m3 for a 24-hour period), it is considerably higher than the expected level for sulfur dioxide in a rural area (approximately 20 ug/m3). Other sources than the Texasgulf plant may also be contributing to the ambient SO2 concentration in this area; however, changes made by the plant since 1979 may have decreased the effect of its emissions. It is unlikely that a situation will ever arise wherein the air quality burden attributable to the existing Texasgulf facility interferes with permitting a new source in the extreme southern portion of Hyde County, since the presence of the Class I area above effectively precludes any new major source from locating there. The potential problems facing industrial and energy facility development in this region point out the need for accurate analytical tools to be used to maximize the region's development while minimizing consumption of the air resource. The two tools of primary importance in this respect are air quality monitoring and air quality modeling, which are discussed in the next two chapters. Impacts of Planned and Potential Energy Related Development There are, at present, no proposed energy -related facilities in the study area aside from the peat methanol plant. However, some long-range possibilities might be considered for purposes of advance planning. Peat Methanol Associates' proposal for a peat -to -methanol conversion plant is the only such plan pending. However, in view of the other peat harvesting projects proposed for the coastal area, Peat Methanol Associates' plant could be viewed as a pilot project for a series of other, possibly larger, methanol plants distributed throughout the region at other peat sites.7 There are, therefore, two types of development that need to be examined. The first is associated with the PMA project. The second is concerned with other development that may follow succesful completion and operation of the pilot plant. The second kind of development may include other peat -to -methanol or related peat harvesting/production facilities, plus secondary growth such as service establishments. The important question is what, if any, effect primary and related secondary growth will have on air quality. The geographic zone where growth will most likely occur as a result of the proposed peat -to -methanol project is the five -county area of Washington, Tyrrell, Beaufort, Hyde, and Dare Counties (see Figure 4). The five -county region comprises 5.6 percent of the State's total land area. The resident population in the five county area is estimated at 77,000 (1.3 percent of the State's total population); estimated population in the growth area (see Figure 4) was 55,000 in 1980. Population in the growth area increased 0.7 percent per year from 1970 to 1980; for the five -county region as a whole it increased 1.5 percent per year for the same time period. The State, by comparison, showed a net increase in population of 15 percent from 1970 to 1980.8 The five -county region is one of the most rural sections of the state. A total of 67.8 percent of the 1970 population resided in rural non -farm areas in 1970. Three of the five counties (Dare, Hyde, and Tyrrell) had no urban population at all in 1970. -43- In 1981, the labor force in the five -county region comprised 35,820 people. The average annual unemployment rate in the region totaled 8.4 percent. Dare, Hyde, and Tyrrell counties had -the highest unemployment rates (15, 12.2, and 14 percent, respectively). The unemployment rate is estimated by counting only the number of individuals who are actively seeking employment as a percentage of those actually holding jobs. The estimates do not include persons who are capable but not actively seeking employment. These individuals might be drawn into the labor force it economic activity picked up and jobs became more plentiful. As of 1979, there were 71 manufacturing industries located in the area. The firms provided approximately 6,500 jobs. The largest employers are Weyerhauser (2700 employees in 1974) and National Spinning, a textile firm (2700 persons). Washington and Plymouth are the towns dominating the retail market in the area. Gross retail sales in the five -county region totalled $422 million during the 1979-1980 fiscal year.9 The actual economic impact of the pilot peat -methanol plant in the five - county area will be minimal. It is estimated that the project will create 200 permanent jobs. The number of unemployed persons actually seeking jobs numbers 3000. Again, the number does not include discouraged unemployed workers who have quit looking for employment. Hence, the number of potential employees who could be found locally is probably greater than 3000. The official policy of PMA is to fill as many positions as possible from the local labor force; it is expected that most employees for the project will come from the existing labor force. Therefore, any influx of new residents into the area, and associated economic development and possible increased pollution, would be minimal. However, even a small increase in permanent jobs in the area would probably be reflected in increased local retail/commercial sales. This slight increase in trade could probably be accommodated by existing retail and service establishments. There probably will be no new major ambient air impacts due to increased commercial growth. -44- Other new industrial facilities in the area are not anticipated as a result of the methanol plant project. It is predicted that all of the products manufactured at the peat methanol plant will be trucked outside the area, thus no additional industries will be needed to process either products or byproducts, and no new ambient air impacts due to additional industrial growth are anticipated. In conclusion, it can be stated that no significant air quality impacts due to residential, commercial, or industrial related development are expected to occur as a result of the pilot peat methanol plant. However, if major new industrial development takes place in the five -county region, then the conclusion may not be true. Unfortunately, not enough information exists to develop alternative growth scenarios to examine directly related and induced, secondary air quality impacts. Possible peat -related developments may include congeneration, more methanol plants, and additional uses of peat for process heat, among others. The main factor determining whether additional peat -related development takes place and the extent to which an influx of labor may affect air quality is the availability and mix of the local labor supply. If the requisite labor supply and skills are not available locally, then labor will have to be imported into the region if economic growth is to occur or continue. The extent to which labor may have to be imported to meet demand will largely determine the amount of residential development, related economic growth, and potential impacts on air quality. Hence, planners responsible for development in the area should not only be aware of industrial growth that may affect air quality, but the not so obvious secondary growth, which may have air pollution implications as well. It is essential that all permit applications contain sufficient information to address both parts of the problem. -4 5- Other, minor, projects have been suggested for the study area: the use of water movement on the Roanoke River as a possible source of low-level hydropower for electrical generation, and co -generation at two paper mills. Since there have been no applications submitted to DNR&CD for the projects, it is difficult to predict the types of technologies that may be employed and the related impacts on air quality. With no real knowledge of equipment and control technologies that might be applied, it is impossible to predict accurately what the potential air quality impacts of these projects would be. It might be useful, however, for planners to research similar types of projects in comparable locales to get a preliminary idea of scales and general project impacts. -4 6- REFERENCES 1N.C. Division of Environmental Management, N.C. Air Quality Data, Annual Means for State Surveillance Monitoring of Particulates, Sulfur Dioxide, and Nitrogen Dioxide from 1975 to 1980, p.3. 2Ibid. 3Daniel, Lee, N.C. Dept. of Natural Resources and Community Development, Oral Communication, September 21, 1981. 4Ibid. SAllen, Tom "An Emissions Inventory of Miscellaneous Sources of Air Pollution in North Carolina" and "An Emissions Inventory of Transportation Related Sources for North Carolina," reports prepared for the N.C. Dept. of Natural Resources and Community Development, March 1979 and December 1978 respectively. 6Haynes, Eldo, N.C. Dept. of Natural Resources and Community Development, Oral Communication, Sept. 30, 1981. 7Smith, James, Methanol Conversion: Probable Fate of First Colony's Phelps Field Peat. 8Peat Methanol Associates, PSD Permit Application for Peat -to -Methanol Project, submitted to North Carolina Division of Environmental Management, June 1, 1981. 91bid. -47- 5. AIR QUALITY MONITORING Need for Monitoring Air quality monitoring is an essential component of an air quality maintenance/air pollution control program. Monitoring provides the information needed to judge compliance with air quality standards and chart trends or changes in air quality. In order for an air quality monitoring network to provide the required data, the design of the network must take into consideration factors such as existing pollution levels, meteorology, topography, population, and source distribution. The purpose of this chapter is to present several basic .concepts and requirements to be considered in upgrading the existing monitoring system to track more closely the air quality impacts of peat mining and various end uses in eastern North Carolina. Suggestions on the future placement of air quality monitors will be offered. These monitors will augment the existing State network to keep closer surveillance on emissions from peat mining, transpor- tation, and combustion, as well as conversion to peat methanol. In addition to regional surveillance, the use of specially designed intensive monitoring pro- grams will be suggested to improve knowledge of particulate emissions charac- teristic of various peat mining, transportation, handling and storage activities. Operation of the State monitoring network is the responsibility of the Division of Environmental Management (DEM). The Division operates twelve monitors that sample the air continuously as well as seventy-two manual monitors that sample the air for a 24-hour period once every six days. In the vicinity of the study area, there are only three DEM air quality monitoring stations: Plymouth (SO2, NO2 and particulates); Washington (particulates); and Elizabeth City (particulates). Figure 5 shows the locations of DEM monitoring stations. The existing State network is clearly inadequate to document air quality and trends in the study region, yet the air quality impacts of peat mining must be monitored in order to protect the area's natural resources and to ensure -48- VA LEGEND: ■ / Continuous 502 Monitor Manual State S02/NO2 Monitor Manual State TSP Monitor Figure S. Location of Department of Environmental Management monitoring stations -49- compliance with Federal and State environmental standards. A new monitoring system must be designed to complement the existing system. Effective resource management and the design of an effective monitoring system require a knowledge of the overall physical and ecological systems in the region where peat mining is now or will be occurring. Planners need to know about the components of the natural system, their natural variability, and vulnerability to disruptions caused by peat mining and reclamation, and the critical threshold levels beyond which a problem is created. Knowledge of all these elements is difficult to obtain, as the area in which peat mining is ongoing or contemplated is an isolated one, about which little has been documented. Any new monitoring system to be constructed must serve the following purposes, at a minimum: o Record compliance of peat mining and development activities with existing environmental standards; o Provide information for general protection of the Class I area (Swanquarter Wildlife Refuge), as well as the sensitive areas of Lake Phelps and Pungo Lake; o Provide information to determine the need for changes in environ- mental standards, permit conditions, or mitigation design; and o Provide information to more accurately quantify emissions from peat -related activities to make possible more accurate prediction of the effects of future development. Monitoring of Regional Background and Trends Good definition of regional air quality will require installation of at least two air quality monitoring stations having the following capabilities: -50- 1. Automated, continuous SO2 measurement; 2. Total suspended particulate measurement (high volume air sampler); 3. Respirable particulate measurement (dichotomous sampler); and 4. Meteorological parameters (wind speed, direction and sigma theta, solar-insolation, precipitation, evaporation, and dewpoint or relative humidity). One station should be located within the boundaries of the Class I area and the other should be located just downwind (to the east or northeast) of the active and proposed mining areas between Pungo Lake and Lake Phelps. The purpose of the Swanquarter monitor would be to determine current ambient air quality. Since the Swanquarter National Wildlife Refuge has been designated by the Federal government as a Class I area, the level of ambient particulates cannot be increased more than 5 micrograms per cubic meter as an annual geometric mean or 10 micrograms per cubic meter as a 24-hour average over the baseline. Similar, highly restrictive limitations apply to SO2 as shown in Table 2. There has not been any air quality monitoring within the Refuge, so accurate determination of the "baseline level' of ambient particulates or any of the other criteria pollutants is impossible. If the air quality of the Refuge is to be protected in the face of projected regional development, sampling must be initiated to establish the baseline air quality. However, such a monitor would not likely be capable of providing increment tracking information or dispersion modeling for increment consumption in that monitors are unable to differentiate between impacts from those sources consuming increment and variations in impacts from existing baseline sources. The overall purpose of the second monitoring station is to quantify air quality in the heart of the region near Lake Phelps and Pungo Lake. LAKE PHELPS is a sensitive area that may be adversely affected by peat operations. Lake Phelps borders the area where First Colony Farms and others are now or will soon be mining peat. -51- The sensitivity of this area tends to support the location of a monitoring station near Lake Phelps, at a location downwind from peat mining operations. PUNGO LAKE, a 12,350-acre National Wildlife Refuge, is another sensitive natural area within Washington County that the County feels should be preserved in the future for scientific, ecological, educational, and recreational purposes. The lake has been designated as a wildlife refuge because of its importance as a wildlife habitat, its representation of a protected pocosin ecosystem, and its illustration of geologic and geomorphic processes. Its proximity to present and proposed peat mining areas supports the placement of monitoring devices in the vicinity. Data collected by this second monitoring station will serve three useful purposes. First, when winds are blowing from the peat mining areas and fuel conversion plant toward the monitors, this station will record the general air quality impact of the aggregate of these activities. Second, when winds are from other directions, this station will be used to determine the true background pollutant levels for the study region. These background values may well be substantially different from the EPA values heretofore assumed. The third use of data from this station will be to monitor the trends in air quality caused by expansion or an increase in the number of nearby sources. In this manner, modeling need not be relied upon exclusively to keep track of increment. In addition to the new monitoring stations in Swanquarter and near Lake Phelps, upgrading of the existing North Carolina DEM monitoring station near Plymouth to an automated continuous station should be accomplished. This station is important in quantifying air quality in the western portion of the study region, especially considering the proximity of the large SO2 source near Plymouth. The sampling methods and equipment currently used at this station -52- (bubblers) have fallen out of favor with EPA due to accuracy and sensitivity problems. For instance, EPA requires that proposed major source owners not use these bubbler data in their PSD applications.) Neither are bubblers permitted in the National Air Monitoring System.2 The bubblers at Plymouth sample the air less than 20 percent of the time since they operate only 24 hours every six days. In addition, the SO2 manual method, being a 24-hour integrated sample, cannot easily be used to document compliance with the three-hour secondary NAAQS for SO2. For these reasons, the station should be upgraded to use. automated continuous monitors. All air quality monitoring equipment purchased for use in this network must be EPA reference method or designated equivalent continuous automated monitors (except reference method --manual for TSP and lead). Quality control and quality assurance procedures complying with 40 CFR 58 Appendix A.2.2 or B.2.2 must be developed, approved by the permit granting authority, and implemented. Current EPA guidance should be sought regarding the dichotomous sampler prior to purchase, since this equipment is still rapidly evolving and in the midst of evaluation. Meteorological equipment should conform to the requirements set forth in Reference 1 for applicable equipment. For equipment listed in this report but not covered by Reference 1, the advice of a competent professional meteorologist should be sought. The two new monitoring stations should be sited to be representative of their respective portions of the region. A meteorologist should review the particular locations chosen for representativeness and freedom from interference, since meteorological measurements are involved. A well - trained instrumentation technician must be available for calibration and maintenance of analyzers and associated data recording equipment. Guidance on siting, operation and quality assurance may be found in Reference 2 dealing with State and Local Air Monitoring Systems. In addition to augmentation of the existing State network for purposes of documenting overall regional air quality, implementation of special purpose particulate monitoring systems should also be considered. The primary purpose of such systems would be to determine fugitive emissions and their associated impacts. Reliable fugitive emissions factors simply do not exist for many peat- -53- related activities. Studies should be designed to determine emission factors as functions of wind speed, moisture (precipitation, evaporation, and relative humidity), and activity (vehicles per day or tons of material handled) for the following: o Peat mining, o Peat transportation, and o Peat handling and storage. The emission factors developed for these activities must include mass emission by particle size to be successfully used in the dispersion modeling discussed in the next chapter. Since the operation of monitoring programs entails some considerable expense, the responsibility for their implementation and maintenance should be shared by the applicants for peat mining and other peat -related licenses. The Department of Environmental Management anticipates that a monitoring network will eventually need to be established, and that a significant portion of the monitoring will likely have to be performed by the mining operators. The Division's approach to monitoring peat mining impacts is to allow limited initial mining to proceed while affording the opportunity to evaluate the mining impacts. From these evaluations, operational conditions and monitoring requirements can be applied to future permits or renewals. Currently, Air Quality Permits issued to peat mining operations are only issued for one year. Compliance monitoring can also be required under the State's Mining Act of 1971. Although the phrases "unduly adverse" and "significantly adverse" are used in the Mining Act in reference to effects on wildlife, fisheries, and publicly -owned parks, forests, and recreation areas, there are no concrete standards attached to these phrases. Revision of the Mining Act may be needed to quantify these standards, thus allowing lack of monitoring to be cited as a reason for denying mining permits. -54- REFERENCES 1United States Environmental Protection Agency: Ambient Monitoring Guidelines for the Prevention of Significant Deterioration (PSD); Research Triangle Park, North Carolina, 27711; November 1980; pp. 8 and 10. 240 CFR 58 and Appendices. 3State Permit #94-2, First Colony Farms, issued -55- 6. REGIONAL AIR QUALITY MODELING Background and Need for Modeling The Clean Air Act, as amended, requires that each State assure the attainment and maintenance of the National Ambient Air Quality Standards (NAAQS) within its borders. In addition, it requires that "significant deterior- ation" of air quality from its present status be prevented. These functions are carried out through a State Implementation Plan (SIP) developed by each State and approved by the Environmental Protection Agency (EPA). Assurance of long-term maintenance of the NAAQS can be aided through the use of simulation modeling. It is only through modeling that the vital questions of air quality impact of unbuilt facilities can be addressed. Through modeling, the desirability of various long-term growth scenarios can be evaluated. Models provide air quality planners with an important tool to make prudent judgements in assisting local governments to assure orderly development commensurate with regional socioeconomic goals. Thus, regional air quality modeling can be a valuable asset for use in resolving potential conflicts among economic, energy, and clean air needs and goals in the region. Based upon the data and analyses presented in the earlier chapters of this report, the potential for energy development/clean air conflict is clearly present in the Washington -Tyrrell -Hyde County region. As was discussed in Chapter 4, ambient levels of total suspended particulate are elevated, probably on a regionwide bases. Two large point sources of particulates and SO2 near the study region's borders probably have substantial impact on local areas within the study region itself. Finally, and most important, the Class I PSD area located within Hyde County is likely to introduce severe constraints upon the number, size and type of energy/industrial facilities that can locate within the study region. In this context, the importance of properly choosing, applying and then verifying an air quality model cannot be overemphasized. -56- General Model Selection Consideration Air quality modeling may be defined as the application of a mathematical description of the physical processes involved in transport, dispersion, and chemical and physical modifications of air pollutants to a particular region. Modeling is used to assess the ground -level pollutant concentrations to which a population might be exposed. Numerous sets of equations have been programmed for use in digital computers —each set is normally referred to as a "model." Since there are wide areas of disagreement among scientists as to the correct mathematical description of the processes involved (and even of the physical processes themselves), there are many models that purport to describe the same physical phenomena. This complexity is compounded by the number of physical and chemical processes to be described (for example, plume rise, plume dispersion, material deposition, photochemical reactions, flow around obstacles, etc.). The extent to which a specific air quality model is suitable for the evaluation of source impact and control strategies depends on: o the detail and accuracy of the data base, i.e., emission inventory, meteorological data, and air quality data; o the meteorological and topographic complexities of the area; o the technical competence of those undertaking such simulation modeling; and o the personnel and budgetary resources available. In view of the importance of the modeling results to the region, it is imperative that appropriate models be chosen, that proper and adequate input data be prepared, that the model applications be properly made, and that the results be interpreted will full knowledge of the limitations inherent in the process. -57- Since the scope of work under which this report is written calls only for a recommendation regarding the particular model appropriate for use in the tri- county region, it is important that proper staffing at the local or regional level be provided for this purpose. A summary of personnel qualifications for this position is provided at the end of this chapter. The remainder of this chapter is devoted to selection of the particular air quality model that will meet the anticipated requirements of Washington, Hyde, and Tyrrell counties. Several models are discussed and evaluated; one is recommended for purchase, installation, and use. It should be noted, however, that dispersion modeling is a continually evolving field. The model recommended in this report should be periodically reviewed and updated, or replaced should it become obsolete. Competent internal staff will be necessary to accomplish this. Modeling Requirements Specific to the Study Region Considering the region -specific topography, meteorology, existing source configuration, PSD classifications and expected type of development, an air quality model for use in the region should have the following capabilities: COMPUTATION PERIODS Concentration averaging periods corresponding to PSD and NAAQS averaging periods for TSP, 502 and NO2, i.e., 3 hours, 24 hours, and yearly. RECEPTORS Ability to arbitrarily locate numerous receptors so that receptor density can be increased both in sensitive areas and close to major sources. SOURCE CONFIGURATIONS Ability to treat point, area, line and volume sources. Peat combustion will most often be associated with point sources; peat mining with area sources; and peat handling (conveyors) and transportation (hauling) with line and volume sources. -58- POLLUTANT CHARACTERISTICS Must be able to handle inert/semi-inert gaseous pollutants (e.g., SO2, NO2, TSP, and reduced sulfur compounds) as well as particulate with appreciable gravitational settling velocity. For particulates, must treat emission rates as a function of wind speed and stability, predict ambient concentration considering depletion, and predict integrated deposition. METEOROLOGICAL DATA Designed to use hourly meteorological observations for the most realistic simulation. RECORD -KEEPING Should have capability to write a permanent magnetic tape or disk record of source contributions to total predicted ambient concentrations to minimize costs associated with repetitive computations in subsequent model runs. With the above capabilities, the air quality model will become part of an air quality impact evaluation system designed to help planners evaluate alternate development scenarios and keep track of increment consumption in both the Class I and Class II portions of the area. Range of Possible Models Literally hundreds of air quality models are currently in use throughout the country. They may differ in the theoretical treatment of the physical processes involved, in the types of processes simulated (e.g. photochemical reactions or deposition of particulate matter or long range transport), the detail in which the simulation is made, the complexity of situation which the model is capable of handling (e.g. multiple averaging periods, numerous sources and receptors, etc.), and the purpose for modeling (regulatory or research). Considering the specific needs of dispersion modeling in the study region, model selection should be made from that family of models employing the straight-line Gaussian theory of basic transport and dispersion, should exclude models not capable of handling complex situations, and should include models used for regulatory rather than research purposes. -59- The need to choose a model that will successfully operate irk a regulatory mode narrows the model choice to those recommended for this purpose by EPA. The EPA -recommended models may be generally divided into two groups — screening models and refined models. The screening models are generally limited in their capability to handle multiple sources, receptors and measured meteorological data. They are intended to provide conservative (i.e., upper bound) predictions for simple cases. As such, they may have some use in the study, for example, in determining which sources are important enough to model, but they cannot form the basis for a regional model. By the elimination of other possibilities, then, the model of choice must be Gaussian, refined, and acceptable for regulatory decision -making. Refined Gaussian models recommended for regulatory purposes may be found in the EPA modeling guidelines.l Two models not included in the guidelines but nevertheless supported by EPA are MPTER (multiple source CRSTER model) and ISC (industrial source complex model). These two refined models were developed too late to be included in the current guideline and will probably be incroporated into the revised guidelines expected to be published this year. Table 10 lists the refined Gaussian models considered as candidates for use in the study region, along with their source and a reference to a brief abstract in Appendix A. Each of the five models listed requires a large-scale digital computer facility for implementation. All of the models are available in the FORTRAN language. Implementation of the models on a computing system will require someone knowledgeable in computer programming, since system compatibility changes to the codes will likely be required. These models, when operating in an hour -by -hour prediction mode are all relatively large consumers of computer resources, especially when multiple annual periods of data must be processed. The computation resource requirement is strongly dependent upon the complexity of the situation being investigated. Numerous sources and receptors require substantial resources in certain models, notably RAM and ISC. The choice of an appropriate model from the five candidates is accomplished by eliminating those models that cannot satisfy the specific regional modeling requirements discussed earlier in this chapter without substantial modification. 0 TABLE 10. Refined Gaussian Candidaie Models Generally Acceptable for Regulatory Purposes Model Name Source Reference* RAM (and associated models) EPA (1) Single Source Model (CRSTER) EPA (2) Multiple Source CRSTER (MPTER) EPA (3) Texas Climatological/Episodic Models Texas Air (TCM/TEM) Control Board (4) Industrial Source Complex Models EPA (5) (ISCST and ISCLT) *Brief abstracts as numbered are presented for each of these models in Appendix A. -61- RAM does not treat line and volume sources nor particulate plume depletion due to gravitational settling. It does not compute particulate deposition. Since all of these items are important for prediction of air quality impacts of peat operations, the RAM models are eliminated from consideration. The CRSTER model is EPA's "benchmark" model for rural point source applications. Models used in comparable rural applications generally must produce results comparable to CRSTER. However, this model, in addition to suffering from the shortcoming already noted for RAM, can accommodate only one source (or collocated group of sources). This is clearly unacceptable in a region where the combined impacts of widely separated major sources must be addressed. MPTER, a more generalized version of CRSTER, is capable of handling multiple non -collocated point sources. However, it cannot accommodate line, area and volume sources nor predict impact where gravitational effects are important. MPTER is judged not acceptable for the stated purposes. The Texas Episodic Model (TEM) and its companion long- term model, the Texas Climatological Model (TEM), are not acceptable since they cannot treat line sources and TEM does not have the capability of processing more than three days of meteorological data in one run. Through the process of elimination, we have arrived at the Industrial Source Complex (ISC) models. These two models -- Short Term (ISCST) and Long Term (ISCLT) come closest to fulfilling the requirements listed earlier. The study situation is complicated and the model of choice to meet study requirements is equally complicated. The complexity of the ISC models requires competent staff to design and implement the study in which they will be used. Although ISC fulfills most requirements, it nevertheless has certain drawbacks. For instance, although usable on a regional scale, the models were designed for more limited spatial use. The ISCST model will probably prove to be the most expensive of the five models listed in Table 10 to operate on a regional scale. Also, its record -keeping ability is only partially realized and will have to be -62- enhanced as described in a subsequent section. Even with these drawbacks, ISC remains the model of choice. Recommendation It is recommended that the Industrial Source Complex Models ISCST and ISCLT be adopted for planning purposes in the study region. This recommen- dation is made because ISC has the capability to: o Perform computations for all NAAQS and PSD averaging periods; o Arbitrarily locate numerous receptors in fields of varying receptor density; o Treat all types of sources expected to be encountered in evaluating peat -related operations; o Treat inert gaseous pollutants as well as particulate emissions where appreciable settling velocities may be present; o Use hourly meteorological data from either National Weather Service stations or local measurement programs; and o Write a permanent record of predicted concentrations due to each source or group of sources at each modeling receptor for use in subsequent analyses. The ISC Short Term Model (ISCST) is basically a much -extended version of the EPA rural benchmark model CRSTER. The ISC Long Term model (ISCLT) is a sector -averaged model based on the EPA models AQDM and CDM. ISC accepts point, line, volume, or area sources with line sources being treated as a subset of volume sources. The steady state Gaussian plume equation for a continuous source is used to calculate ground -level concentrations resulting from stack and volume source emissions. Area source contributions to ground -level concen- - 63- trations are based on the equation for a continuous and finite crosswind line source. The generalized Briggs plume rise equations, including momentum, are used. Plume rise is, optionally, a function of downwind distance. Procedures suggested by Huber and Snyder are used to evaluate the effects of structure - induced aerodynamic wakes and eddies on plume dispersion. The model may be run in either the rural or urban mode. Wind' speeds are extrapolated from measurement height to emission height. Terrain is accounted for by reducing the plume centerline height by the elevation differences between the source and the receptor. For particulate computations, the effects of gravitational settling and dry deposition are simulated. All emission rates can vary per the seasonal or diurnal cycles. Particulate emission rates (fugitive) may vary by wind speed and atmospheric stability class. ISC utilizes a polar coordinate or right-handed cartesian coordinate system. The ISC model computer codes are written in FORTRAN IV and require a nominal 65,000 32 bit (min.) words of storage. If more than 100 sources and 400 receptors are required, the amount of storage increases beyond 65,000 words. A more detailed account of the characteristics of the ISC model, including input requirements is presented in Table 11. Complete model descriptions including equations may be found in the User's Guide.2 Modeling Input Data Bases Application of ISC will require three major data bases --receptors, sources and meteorology. The receptor data base consists simply of the coordinates and ground elevation above sea level of those locations for which model predictions are desired. Receptors should be carefully chosen by competent personnel using screening model methods to assure adequate density in the vicinity of maximum short-term impact, as well as adequate areal coverage and sufficient density in sensitive areas (Phelps Lake, Pungo Lake and Swanquarter National Wildlife Refuge). -64- TABLE 11. Model Characteristics Input Requirements Emissions Data: Location, emission rate, pollutant decay coefficient, elevation of source (MSL), stack height, stack exit velocity, stack inside diameter, stack exit temperature, particle size distribution with corresponding settling velocities, surface reflection coefficient dimensions of. adjacent buildings. Meteorological data: Short-term -- hourly surface weather data including cloud ceiling, wind direction, wind speed, temperature, opaque cloud cover. Daily mixing height is also required.* Long-term -- stability wind rose (STAR deck), average afternoon mixing height, average morning mixing height, and average air temperature. Output Concentration or deposition for any averaging time. High, second -high values and highest 50 table. Model Options Site -specific wind profile exponents, site -specific vertical temperature gradients, dry deposition terrain effects (limited), variable emission rates, stack and building downwash. Model Limitations Flat or gently rolling terrain. Pollutant Types Non -reactive Particulates with or without significant settling velocities. Reactive pollutants if they can be accounted for by the exponential decay term. -65- Source -Receptor Relationships Arbitrary location for point, line, area, and volume sources. Arbitrary receptor locations or receptor rings. Receptors at ground level at elevation not exceeding stack height. Plume Behavior Briggs, plume rise formulas. Building downwash and stack tip downwash If plume height exceeds mixing height, ground level concentrations set to zero. Does not treat fumigations. Horizontal Wind Field Uses user -supplied hourly wind speeds. Uses user -supplied hourly wind direction (nearest 10 degrees), internally modified by addition of a random integer value between -4 degrees and +5 degrees. Wind speeds corrected for release height based on power law variation, different exponents for different stability clases, reference height = 10 meters. Constant, uniform (steady-state) wind assumed within each hour. Vertical Wind Field Assumed equal to zero. Horizontal Dispersion Semi-empirical/Gaussian plume. Hourly stability class determined internally by Turner procedure, 6 classes used. Dispersion coefficients from McElroy and Pooler (urban) or Turner (rural). No further adjustments made for variations in surface roughness. Chemistry/Reaction Mechanism Exponential decay, user input time constant. Surface deposition when deposition calculations are requested. Physical Removal ' Settling and dry deposition of particulates is accounted for. Boundary Conditions Lower boundary: reflection efficiency supplied by user Upper boundary: perfect reflection Multiple reflections handled by summation of series until oZ = 1.6 x mixing height. Uniform vertical distribution thereafter Background Not treated. -67- The source data base is much more complex than the receptor data base and may require substantial effort to develop. Major emissions sources from as much as 50 km beyound the boundary of the study region must be included in this data base if they can have a significant impact on the region — especially on the Class I area. The source data base consists of an emissions inventory and descriptions of physical characteristics of the sources and nearby structures. This data must be as accurate as possible and should be field -checked. They include the following: o Stack sources stack height stack coordinates exit temperature emission rate for SO2, NO2, TSP or other pollutant being studied exit velocity stack inner diameter height, length and width of adjacent building o Area sources area sources coordinates effective emission height emission rate (units of mass/meter2) variation of TSP emission rates with wind speed and atmospheric stability gravitational settling category parameters for the type of particulate emitted by the area source IME o Volume Sources volume source coordinates elevation of the source vertical and horizontal source dimensions emission rate for 5O29 1VO22 .TSP or other pollutant being studied o Line Sources same as volume source except that the source has no areal dimensions To accomplish the most realistic simulation, the above data should be obtained on a diurnal, seasonal and annual basis. Quantification of the particulate emissions characteristic of peat mining, handling, and storage will require a modest field research program. This program should be designed in conjunction with EPA and a competent consultant, and result in emission factors based on easily quantifiable parameters such as active area, tons of material handled, . wind speed, moisture content, precipitation, etc: The results must include a determination of mass fraction and corresponding gravitational settling velocity by category. Meteorological data measured locally, quantification of TSP emission -inducing activities, and ambient particulate measurement by mass fraction will be required. For 'the purpose of studying PSD increment consumption by sources that could potentially locate in the region, it will be necessary to determine the amount of increment remaining at various receptor locations in both the Class I and Class II portions of the study region. This will require compilation of a special source data base (inventory) of emission changes both inside the region and at sources outside the region but having a significant effect upon the region. The following two special inventories will be required in addition to the current overall emissions data base described earlier: 1. An inventory of all emissions increases and decreases at major stationary sources (as defined in 40 CFR 51.21) resulting from construction that began after January 6, 1975. Ina 2. An inventory of all increases and decreases of emissions at all stationary sources that have occurred after the regional baseline dates for TSP and SO2. The meteorological data base, ideally, should be comprised of measure- ments taken on a continuous basis within the confines of the region and averaged over one -hour intervals. Because these data will not become available until after the monitoring program becomes operational, an alternate data source must be sought. Table 12 provides information on alternate data available to represent meteorological conditions over the study region. Listed in this table are: station name; service affiliation; distance and bearing from the center of the study region to the station; the period over which weather records were compiled; and the station number. Note that two of weather stations are listed -- surface and upper air. Data from both a surface and an upper air station are required by ISCST. Data from any of the used stations are available on magnetic tape from the National Climatic Center in Asheville, N.C. However, the type of observations taken prior to 1964 precludes their direct use in the ISCST model. The two nearest stations collecting data in 1964 and subsequent years are Hatteras (surface and upper air) and Elizabeth City (surface only). The surface stations most representative of the study area of all those listed are Edenton and Weeksville. It is recommended that the Edenton and Weeksville data be obtained and processed and then compared with the Elizabeth City and Hatteras data to determine which of the two —Elizabeth City or Hatteras --best represents study region conditions. However, before using data bases such as those in Edenton and Weeksville to determine comparable representative meteorological data, the circumstances under which these data were obtained (anemometer height and threshold velocity, etc.) should be studied. These variables could greatly influence the comparability of two otherwise similar data sets. Hatteras upper air data should be used in ISC. Greensboro and especially Charleston S.C. are simply too far from the study region to be representative, particularly when the upper air is coupled to surface data taken 200-300 km away. The Hatteras upper air data will continue to be used even when the regional monitoring system begins to provide data, since upper air conditions will -7 0- Table 12 Surface and Upper Air Meteorological Data Stations Located Nearest to the Study Region SURFACE STATIONS Approximate Location Station Station Date of With Respect to Region Name Number Service Record Distance (km) Bearing Cherry Point, N.C. 13754 Navy 3/45-present 60 SW Elizabeth City, N.C. 13786 FAA 1/49-12/70* 80 NNE Cape Hatteras, N.C. 93729 NWS 2/57-present 60 ESE Edenton, N.C. 13761 Navy 3/45-10/58* 20 NNW Weeksville, N.C. 13774 Navy 5/52-6/57* 30 NNE New Bern, N.C. 93719 FAA 1/49-12/54 55 SW * denotes less than 24 observations per day for all or part of the period of record. UPPER AIR STATIONS Standard Significant Approximate Location Station Station Level Level With Respect to Region Name Number Record Record Distance (km) Bearing Cape Hatteras, N.C. 93729 3/57-present 3/57-present 60 ESE Greensboro, N.C. 13727 1/48-present 7/57-present 192 WNW Charleston, S.C. 13880 1/48-present 7/57-present 288 SW Note: Data in this table taken from "Survey of TD-1440" and "Survey of Td-5600" issued by the National Climatic Center (unpublished). -71- not be sensed by the proposed network. Even though Hatteras is virtually surrounded by water, the prominent presence of water in and around the study region and the particular use to be made of the Hatteras data (determination of rural afternoon maximum mixing heights) argue strongly for use of this station when the alternatives are considered. Model Validation/Calibration Accuracy of dispersion model predictions is generally considered to be within a factor or two of the actual concentration. Modeling accuracy lessens as source -receptor distance increases or as influence of topographical features that violate model assumptions (such as nearby significant bodies of water) become important. Both of these problems leading to accuracy degradation are present when ISC is used for predictions in the Class I area. The most restrictive. Class I so PSD increment is less than 2 percent of the corresponding NAAQS. This almost infinitesimally small concentration increment is extremely difficult to predict accurately. It is almost beyond the current state of the art. In addition to the factor of two uncertainty generated simply by modeling theory and assumptions, other sources of possible inaccuracy are present. A modeling analysis can be no more accurate than the input source emissions data. Sources not included in the inventory that are actually present, sources that are included but are actually defunct, and errors in emissions or stack data may seriously degrade the modeling. For all the above reasons, a validation of modeling results for the Class I area is considered an absolute necessity. A validation program using quality assured monitored data and emission information from the sources now affecting the Class I area should be developed. Calibration of ISC for the study region may be possible if the validation results are disappointing. Highly competent staff will be necessary to design and accomplish this program; there is an extremely small margin for error when the model is used to keep track of Class I increment consumption. -72- Recommendation for an Air Quality Modeling System The ISC model is really only the predictive component of a system for evaluating potential changes in ambient air quality and threats to the NAAQS. In order for the system to operate on a routine and predictable basis, several steps should be taken. First, the specialized emissions inventory (source data base) required by the ISC model should be computerized to facilitate updating. Communications should be established with DNR&CD personnel to assure timely notification of all permitted changes in emission rates affecting the study area, all changes or updates in State -maintained emission inventories, and all PSD permit appli- cations or non-PSD applications which might, nevertheless, affect Class I or Class II increment. The local governments should, on their own initiative, field - check all information and regularly review the entire inventory (once a year is not too frequently). Sources go out of business, suffer breakdowns, have "good" or "bad" years, suffer strikes or "Acts of God" and these happenings are not necessarily reported to the State or reflected in State inventories. Considering the sensitivity of the modeling, they may be crucially important to the region. The computerized inventory should be easily accessible, easily updated and in a form suitable for use as input to the ISC model with a minimum of preprocessing. Second, a post -processing program needs to be developed for the ISC$T model. This model currently has the capability of writing. an output tape containing partial concentration contributions. A post -processor should be developed to make use of this tape in the following ways: o Sum chosen source contributions for given averaging periods for chosen receptors; o Produce frequency distributions of receptor -specific partial or total concentrations; and o Add together or subtract concentrations for given identical receptors and identical data periods from two separate ISCST executions. -73- The purpose of the above is to allow ISCST to be operated in a more economical mode and to facilitate evaluation of projected or alternative changes in emissions. In this manner ISC need be executed only once for a base case using multiple sources. Subsequent changes at a single source may be evaluated for compliance with NAAQS by simply modeling only the change and then using the much more economical post -processor to add or subtract the results, as appropriate, from the base case. Finally, due to economic considerations, it may be impossible to routinely execute ISCST using the normal 5 years of meteorological data. If this is the case, an initial set of runs using all sources and 5 years of data should be made. From this, the 50 or so days with the worst simulated air quality should be chosen. Future use of the model would depend on only these 50 days of meteorological data. This operation, if necessary, should be supervised by a competent meteorologist. - If reduction of the ISCST data base to less than five years is required, then all annual impact predictions should be made using the ISCLT model and five years of STAR weather data from the station deemed most representative of the study region. The ISCLT model has enhanced record keeping and updating capability already built into the code, hence a post -processor development task should not be necessary for this model. Required Personnel Qualifications The technical complexity of the tasks involved in evaluating the impacts of peat -related facilities will initially require the support of a qualified Senior Meteorologist/Air Quality Specialist. At a later date, when the air quality monitoring program becomes operational, the services of a trained instrumen- tation technician will be required for operation and maintenance of the network. The inital responsibilities of the Senior Meteorologist/Air Quality Specialist will likely center around planning studies and preliminary modeling. Later, he/she will be responsible for the operational phases of the program where substantially more personnel may be involved. -74- The Senior Meteorologist/Air Quality Specialist should have as a minimum an advanced degree and three years experience in air quality impact analyses. Five years experience is preferable. This individual must have previously applied dispersion models on a regional basis, must have a detailed knowledge of Federal and State regulations, must have participated in previous air quality and meteorological data collection programs and must be skilled in data processing and FORTRAN programming. The candidate individual must also have demon- strated verbal and written technical communications skills and leadership potential. -7 5- REFERENCES 1. Guideline on Air Quality Models; Environmental Protection Agency, Office of Air Quality Planning and Standards; Research Triangle Park, N.C.; April 1978; EPA-450/2-78-027. 2. Industrial Source Complex USC) Dispersion Model User's Guide, Volumes 1 and 2; Environmental Protection Agency; Source Receptor Analysis Branch; Research Triangle Park, N.C.; December 1979; EPA-450/4-79-030 -7 6- APPENDIX A ABSTRACTS OF AIR QUALITY DISPERSION MODELS* 1. AQDM Abstract: AQDM is a climatological steady-state Gaussian plume model that estimates annual arithmetic average sulfur dioxide and particulate concentrations at ground level in urban areas. A statistical model based on Larsen is used to transform the average concentration data from a limited number of receptors into expected geometric mean and maximum concentration values for several different avergaing times. Z. APRAC-IA Abstract: APRAC is a model that computes hourly average carbon monoxide concentrations for any urban location. The model calculates contributions from dispersion on various scales: extraurban, mainly from sources upwind of the city of interest; • intra-urban, from freeway, arterial and feeder street sources; and local, from dispersion within a street canyon. APRAC requires an extensive traffic inventory for the city of interest. 3. CDM and CDMQC Abstract: CDM is a climatological steady-state Gaussian plume model for determining long-term (seasonal or annual) arithmetic average pollutant concentrations at any ground -level receptor in an urban area. An expanded version (CDMQC) includes a statistical model based on Larsen to transform the average concentration data from a limited number of receptors into expected geometric mean and maximum concentrate values for several different averaging times. -77- 4. RAM and RAMR Abstract: RAM is a steady-state Gaussian plume model for estimating concentrations of relatively stable pollutants for averaging times from an hour to a day from point and area sources. Level or gently rolling terrain is assumed. Calculations are performed for each hour. Both rural and urban versions are available. 5. Single Source CRSTER Abstract: CRSTER is a steady-state Gaussian plume technique applicable to both rural and urban areas in uneven terrain. The purpose of the technique is: (1) to determine the maximum concentrations, for certain averaging times between 1-hour and 24-hours, over a one year period due to a single point source of up to 19 stacks, (2) to determine the meteorological conditions that cause the maximum concentrations, and (3) to store concentration information useful in calculating frequency distributions for various averaging times. The concentration for each hour of the year is calculated and midnight -to -midnight averages are determined for each 24-hour period. 6. Multiple Source CRSTER (MSTCRS) Similar to 5 above but for multiple sources. 7. Multiple Source CRSTER Similar to 5 above, but applicable to multiple sources up to 19 collocated elevated stack emissions. 8. Texas Climatological Model Abstract: The TCM is a climatological model that predicts long-term arithmetic mean concentrations of nonreactive pollutants from point sources and area sources. 9. Texas Episodic Model Abstract: The Texas Episodic Model (TEM) is a short-term (10 minute to 24 hour averaging time) Gaussian Plume Model for prediction of -78- concentrations of nonreactive pollutants due to up to 300 elevated point sources and up to 200 area sources. Concentrations are calculated for 1 to 24 scenarios of meteorological conditions, averaging time, and mixing height. 10. PTMAS Abstract: Performs an analysis of the maximum short-term concentrations from a single point source as a function of stability and wind speed. The final plume height is used for each computation. 11. Valley Abstract: This algorithm is a steady-state, univariate Gaussian plume dispersion algorithm designed for estimating either 24 hr. or annual concentrations resulting from emissions from up to 50 (total) point and area sources. Calculations of ground -level pollutant concentrations are made for each frequency designed in an array defined by six stabilities, 16 wind directions, and six wind speeds for 112 program -designed receptor sites on a radial grid of variable scale. Empirical dispersion coefficients are used and include adjustments for plume rise and limited mixing. Plume height is adjusted according to terrain elevations and stability classes. 12. PTMTP Abstract: Estimates for a number of arbitrarily located receptor points at or above ground -level, the concentration from a number of point sources. Plume rise is determined for each source. Downwind and crosswind distances are determined for each source -receptor pair. Concentrations at a receptor from various sources are assumed additive. Hourly meteorological data are used; both hourly concentrations and averages over any averaging time from one to 24 hours can be obtained. 13. ISC Abstract: The Industrial Source Complex dispersion models (ISC) are intended to address complicated air quality impact analysis problems that cannot be adequately handled by the existing, generally available -7 9- computerized models. The ISC short-term model (ISCST) is an extended version of the CRSTER model. The ISC long-term model (ISCLT) is a sector -averaged model that extends and combines basic features of AQDM and CDM. ISC accepts three source types -stack, area, and volume. The steady-state Gaussian plume equation for a continuous source is used to calculate ground -level concentrations for stack and volume sources. Area source contributions are computed based on the equation for a continuous and finite crosswind line sources. Area source contributions are computed based on the equation for a continuous and finite crosswind line source. The generalized Briggs plume rise equations, including momentum, are used. Plume rise is a function of. downwind distance. Procedures suggested by Huber and Snyder are used to evaluate the effects of structure -induced aerodynamic wakes and eddies on plume dispersion. The model has rural and urban options. Wind speeds are adjusted from measurement height to emission height. Terrain is accounted for by reducing the plume centerline height by the elevation difference between source and receptor. The model is also capable of accounting for the effects of gravitational settling and dry deposition. The ISC Model computer programs are written in FORTRAN IV and require approximately 65,000 words of storage. *Air quality dispersion models are made available by the Environmental Applicatons Branch. In addition to having executable programs on EPA's UNIVAC 1110 at Research Triangle Park, NC, a tape having FORTRAN source programs has been placed with NTIS (National Technical Information Service). U.S. Department of Commerce, Springfield, VA 22161. The current tape is called: UNAMAP (Version 3). Its accession number is PB-277-193. There are eleven dispersion models contained on the tape. -8 0- APPENDIX B. MODEL AIR QUALITY ORDINANCE Sec. 1-2. Ordinance. It is declared that the conservation and protection of air resources is a public responsibility; therefore, it is necessary -to promote and encourage air pollution control. Now therefore the Eastern North Carolina Regional Air Pollution Control Board adopts the following ordinance establishing the policies and procedures under which the Board will conduct the air pollution control program. Sec. 1-3. Authority. Section 143-215.3 (a) (11) of Article 21, Chapter 143 of the General Statutes of North Carolina authorizes the governing body of any county, municipality or group of counties or municipalities within a designated area of the State, subject to the. approval of the Environmental Management Commission, to establish, administer and enforce a local air pollution control program for the county, municipality, or designated area of the State. Sec. 1-4. Organization. A. Air Pollution Control Board. The Boards of County Commissioners of Washington, Hyde, and Tyrrell Counties hereby agree to the formation of a Regional Air Pollution Control Board to be called the Northeastern North Carolina Regional Air Pollution Control Board, which shall consist of members, with the members to be chosen in the following manner: 1. All members of the Board shall reside within the area of jurisdiction. 2. The Chairman is to be selected by vote of the Board. 3. A meeting may be called by the Chairman or any two (2) members of the Board. 4. The secretary of the Board will be the Air Pollution Control Program Director, or his authorized representative. -81- 5. The Board must meet at least once every three months. 6. The Board shall meet separately from the Council and the members shall serve without compensation, although subsistence and travel expenses incurred in the fulfillment of duty may be reimbursed. B. Advisory Council. There shall be established an Air Control Advisory Council, hereinafter called the Council. The Board shall appoint the members of the Council, which shall have at least members (to be decided on by the Board). All members shall reside within the area of jurisdiction. (Length of terms and number of members shall be mutually agreed upon by the County Commissioners of Washington, Hyde, and Tyrrell Counties.) A Chairman shall be elected annually from within the Advisory Council membership, and shall serve at the pleasure of the Council. The Council shall meet at least quarterly, and at more frequent intervals if called by the Chairman or majority of the Council. A simple majority of the membership shall constitute a quorum. The Air Pollution Control Program Director, or his authorized representative, shall act as secretary to the Council, and shall attend all meetings. The Council shall serve only in an advisory capacity to the Board and shall assist the Board in the development of rules, regulations, air quality and emission control standards, and shall advise in other matters relating to the Air Pollution Control Program which may be submitted to it by the Board. The Council shall meet separately from the Board and the members shall serve without compensation, although subsistence and travel expenses incurred in the fulfillment of duty may be reimbursed. Council members may from time to time be asked by the Board to attend Board meetings. -82- C. Administration. The Board, as established, shall: 1. Develop a comprehensive plan for the control and abatement of new and existing sources of air pollution. 2. Conduct air quality monitoring to determine existing air quality and to define problem areas, as well as to provide background data to show the effectiveness of a pollution abatement program. 3. Develop an emissions inventory to identify specific sources of air contamination and the contaminants emitted, together with the quantity of material discharged into the outdoor atmosphere. 4. Establish and keep current annually, a register of air contaminant sources within the area, and the registration of all persons operating or responsible for the operation of air contaminant sources. Such persons shall also, upon written request, file reports containing information concerning location, size and height of outlets, processes employed, fuels used, nature and rate and duration of emissions, and any other information which may be required. 5. Adopt, after notice and public hearing, air quality and emission control standards, or adopt by reference, without public hearing, any applicable rules, regulations and standards duly adopted by the Environmental Management Commission. 6. Provide for the establishment or approval of time schedules for the control or abatement of existing sources of air pollution and for the review of plans and specifications and issuance of approval documents covering the construction and operation of pollution abatement facilities at existing or new sources. 7. Declare an emergency when it is found that a generalized condition of air pollution is causing danger to the health or safety of the public -83- and issue an order to the responsible person or persons to reduce or discontinue immediately the emission of air contaminants. The person or persons so ordered may immediately appeal to the Board for a hearing. Upon request for such a hearing, the secretary shall fix a time and a place and such hearing shall be held not later than twenty-four (24) hours after the , request is received. After commencement of such a hearing and without adjournment thereof, the Board shall affirm, modify, or set aside the order previously issued. D. Staff. The air pollution control program director shall be appointed by the Board and shall be qualified in administration and technology. The Board shall also retain, employ and compensate such technical and other personnel as may be necessary to carry out the provisions of the ordinance and to secure necessary scientific, technical, administrative and operational services, including labora- tory facilities, as may be required. Sec. 1-5. Administrative Procedures. A. Adoption of Air Quality Standards, Emission Control Standards, and Regulations Governing Air Pollution. Prior to the adoption by the Board of air quality standards, emission control standards, and regulations governing air pollution, the Board shall give notice of its proposed action and shall conduct one or more public hearings on any rules, regulations and standards duly adopted by the Environmental Management Commission, or the Department of Natural Resources and Community Development of the State of North Carolina. Any standards, rules, and regulations adopted pursuant to the procedures set forth herein and pursuant to applicable law and any standards, rules and regulations of the Environmental Management Commission and the Department of Natural Resources and Community Development of the State of North Carolina adopted by reference by the Board may be amended, modified, or repealed without compliance with the procedures set forth in this Article III. At such hearing, opportunity to be heard by the Board with respect to the subject under -84- consideration shall be afforded to any interested person. Notice shall be published at least twice in a newspaper of general circulation within each county. The first notice must appear not less than thirty (30) days before the hearing and the second notice must appear not less than five (5) or more than ten (10) days before the date of the hearing. After the hearing is held, the Board shall permit anyone who so desires to file a written argument or other statement in relation to any proposed action of the Board any time within thirty (30) days following the conclusion of any public hearing, or within any such additional time as the Board may allow by such notice as specified for holding a hearing. The notice shall include the details of such proposed action or, where such proposed action is too lengthy for publi- cation, the notice shall specify that copies of such detailed proposed action shall be obtained upon request from the office of the Board. Upon the completion of the hearings and consideration of submitted evidence and arguments concerning the proposed action of the Board with respect to the adoption of standards, rules and regulations, the Board shall adopt its final actions with respect thereto. Upon approval by the State Boards, the Regional Board shall publish such final action as part of its official standards, rules and regulations. Final actions of the Board shall specify the effective date. B. Control of Sources of Air Pollution 1. Existing Sources - After the effective date established for any air quality standard, emission control standard, or regulations, no person shall discharge any air contaminants into the outdoor atmosphere in violation thereof except in compliance with the terms of a temporary permit, special order, or other appropriate instrument issued by the Board. 2. Control of new sources of air pollution - After the effective date established for any air quality standard, emission control standards, or regulation, no person shall do any of the following acts or carry out any of the following activities until or unless such person shall have applied for and shall have received, from the Board, a permit therefor and shall have complied with such conditions, if any, as are prescribed by such permit: -85- (a) Establish or operate any new air contaminant source; (b) Build, erect, use or operate any new equipment which may result in the emission of air contaminants or which is likely to cause air pollution; (c) Alter or change the construction or method of operation of any existing equipment or process from which contaminants are or may be emitted; (d) Enter into a contract for the construction and installation of any air cleaning device or allow or cause such device to be constructed, installed or operated. C. Board's Powers as to Permits, Temporary Permits, Construction Permits, and Operating Permits. I. The Board shall act upon all applications for permits, temporary permits, construction permits, and operating permits so as to prevent, insofar as is reasonably possible, any pollution or any increased pollution of the air. 2. Application for a permit shall be accompanied by plans and specifica- tions and such other information as the Board may deem necessary to the proper evaluation of the application for a permit. Failure of the Board to take action on an application for a permit within ninety (90) days shall be treated as approval of such application. Any person whose application for a permit is denied or is granted subject to conditions which are unacceptable to such person shall have the right to a hearing before the Board, provided that written request for such a hearing is submitted to the Board within thiry (30) days following the receipt by the applicant of such decision. 3. Any permit, temporary permit, construction permit, and operation permit granted by the Board may be modified, suspended, or revoked by the Board provided that written notice of such modification, MM suspension, or revocation shall be mailed to the holder of any such permit not less than ten (10) days prior to the effective date of any such modification, suspension, or revocation. Any person whose permit has been modified, suspended, or revoked may appeal to the Board for relief from such action within twenty (20) days from the mailing of the notice of such action as above provided by the mailing of a written notice of appeal to the Board. The action of the Board modifying, suspending, or revoking any permit shall become final if no notice of appeal is given in the manner provided above. 4. The Board shall have the power to grant any temporary permit, construction permit, and operating permit in such a manner, upon such conditions, and for such a period of time as the Board may specify. 5. All requests for a temporary permit, construction permit, and operating permit shall be made by making application to the Board in writing on forms provided by the Board. Any and all information, plans, specifications and data required by such application form shall be submitted with such application. The Board may require the applicant to submit additional information, plans, specifications, and data as it may deem necessary to the proper evaluation of the application for a permit. 6. The granting of any temporary permit, construction permit, or operating permit shall not limit the application of Regulation No. 7 entitled "Air Pollution Emergencies" of the Rules and Regulation Governing the Control of Air Pollution in Washington, Hyde, and Tyrrell Counties of the Eastern North Carolina Regional Air Pollution Agency and shall not relieve the holder of such permit from compliance with said Regulation No. 7. D. Inspection - Right of Entry The Board, through its authorized agents, shall have the authority to enter at all reasonable times upon any property for the purpose of investigating air -87- pollution, air contaminant sources, or the installation and operating of any air cleaning device. No person shall refuse entry, or access, to any authorized agent of the Board who requests entry for the purpose of inspection and who presents appropriate credentials, nor shall any person obstruct, hamper or interfere with any such representative while in the process of carrying out his official duties. E. Confidentiality of Certain Records Any records or other information furnished to the Board concerning any air contaminant source, which relate to secret or confidential processes or produc- tion, shall be treated confidentially and said information shall not be disclosed to the public by the Board or the Agency, unless the Board or the Director determines that the public health and safety require disclosure. F. Zoning and Planning The Board shall make available to any city or county zoning or planning agency, where such exists within the jurisdiction, those facts concerning air pollution which pertain to zoning or planning. These facts include information concerning such approved documents, as issued by the State covering air pollution devices, which will be installed within the local area. G. Limitations and Severability All Acts of the local Board shall be consistent with the provisions of Chapter 143, Article 21, North Carolina General Statutes, and all rules and regulations promulgated thereunder. If any provision or clause of this Ordinance shall be declared invalid, such declaration shall not affect the validity of the ordinance as a whole or any other provision or clause contained herein. Sec. 1-6. Appeals to and other appearances before Board. Any person taking exception to any decision ruling, violation notice or order issued by the director may appeal to Board. Any person wishing to bring a matter before the Board shall notify the director, in writing, and -88- furnish all facts necessary to enable the Board to consider the matter. To that end, any person is privileged to appear before the Board and bring representatives, consultants and witnesses to be heard relative to the matter concerning which he seeks action by the Board, provided advance notice is given to the director of the subject matter to be considered. Sec. 1-7. Opinions not binding. Opinions rendered by the director are not binding, but shall be considered recommendations only to the Board. -8 9- APPENDIX C. PEAT BIBLIOGRAPHY Center for Peat Research, A Report on European Peat Technology for Peat Program, Phase 1: prepared for the Upper Great Lakes Regional Commission and the Minnesota Department of Natural Resources. Minneapolis: Midwest Research Institute, 1976. Center for Peat Research, Final Report, Peat Program: Phase 1. Environmental Effects and Preliminary Technology Assessment. Minneapolis: Midwest Research Institute, n. d. Conklin, Martha H., The Potential Air Quality Impacts of Harvesting Peat in Northern Minnesota: prepared for the Minnesota Department of Natural Resources. 1978. Concord, Mass.: Environmental Research and Technology, Inc. Dynatech * R/D Company, Peat Biogasification Development Program: Quarterly Report No. 4 for the Period of July 1 - September 30, 1980: prepared for the U.S. Department of Energy. Cambridge, Mass., 1980. France, David. "Peat in the USA: A Future Energy Resource." Energy World 69 (1980). Fuchsman, Charles H., Peat: Industrial Chemistry and Technology. New York: Academic Press, 1980. Ingram, Roy L., and Otte, Lee J., Peat Deposits of Croatan Forest: Craven, Jones, and Carteret Counties, North Carolina: prepared for the U.S. Depart- ment of Energy and the North Carolina Energy Institute, 1981. .O Institute for Transportation Research and Education, Coastal Energy Transpor- tation Study: An Analysis of Transportation Needs to Support Major Energy Projects in North Carolina's Coastal Zone, Phase 1 Report. Research Triangle Park, N.C.: University of North Carolina, 1980. Institute of Gas Technology. Executive Conference Proceedings of Symposium on Management Assessment of Peat as An Energy Resource, Arlington, Va., July 22-24, 1979. Chicago, 1980. Institute of Gas Technology, Peat: A Major Energy Resource to Meet U.S. Clean Fuel Needs. Chicago, 1980. Johnson and others. "Environmentally Sound Peat Harvesting Techniques." Proceedings of America Institute of Mining . Engineers Symposium, Duluth, Minn., January 10-12, 1979. Kopstein, Melvin. "DOE Program for the Development of a Peat Utilization Technology." Proceedings of American International Conference on Coal and Gas, Liquefaction and Conversion to Electricity, Pittsburgh, Pa., August 1- 3, 1978. Lofton, S.M., Heterogeneity of Ecological Factors Affecting Development of Selected North American Peat Deposits. Tulsa: Williams Brothers Engineering Company, Ecosciences Group, n.d. McClosky, Michael. "The Environmental Impacts of Synthetic Fuels." Journal of Energy Law and Policy 2 (1981): 1-12. Mundale, Susan, ed., Energy from Peatlands: Options and Impacts. Minneapolis: University of Minnesota, Center for Urban and Regional Affairs, 1981. -91- NRCD Peat Mining Task Force. Report of Peat Mining Task Force. Raleigh: North Carolina Department Resources and Community Development, 1981. Paganessi, Joseph E., and others. "Peat Dewatering: Solvent Extraction." Proceedings of U.S. Department of Energy Third Technical Contractors' Conference on Peat, Bethesda, Md., April 29-30, 1981. Puwani, D.V., and others. "Synthetic Fuels from Peat Gasification." Proceedings of Fourteenth Intersociety Conversion Engineering Conference, Boston, Mass., August 5-10, 1979. Punwani, D.V., and others. "Synthetic Natural Gas Production from Peat." Proceedings of Alternative Energy Sources International Conference, Miami, Fla., December 5-7, 1977. Radian Corporation, Socioeconomic Issues Associated with Use of Peat as an Energy Resource: prepared for the U.S. Department of Energy, Division of Fossil Fuel Processing. Austin, 1980. Research Triangle Institute, Impact and Feasibility of Wood- or Peat -Fired Electric Generating Plants in the Coastal Zone of North Carolina: prepared for the North Carolina Department of Natural Resources and community Development, Division of Forest Resources. Research Triangle Park, N.C., 1980. Resource Science Center, Peat and the Environment: prepared for the Institute Gas Technology. Tulsa: William Brothers Engineering Company, 1979. -92- Rogers, Golden & Halpern and Engineers for Energy and the Environment, Design of a Planning Program to Help Mitigate Energy Facility -Related Air Quality Impacts in the Wilmington, North Carolina, Area: prepared for the Cape Fear Council of Governments. Philadelphia, Pa., 1981. Schora, F.O., and Punwani, D.V., "Peat: An Energy Alternative." Proceedings of Energy in the Third World Conference, Vienna, Austria, July 28-30, 1980. UOP/SDC, Peat Prospectus: prepared for the U.S. Department of Energy, Division of Fossil Fuel Processing. Washington, D.C., 1979. UOP Inc. and System Development Corporation, Preliminary Evaluation of Environmental Issues on the Use of Peat as an Energy Source: prepared for the U.S. Department of Energy, Division of Fossil Fuel Procesing. McLean, Va. 1980. UOP Inc. and System Development Corporation, Proceedings of U.S. Depart- ment of Energy Second Technical Contractors' Conference on Peat, October 16-17, 1980. McLean, Va., 1981. U.S. Congress. House. Committee on Goverment Operations. Peat as a Source of Energy. Hearings before a subcommittee of the House Committee on Government Operations, 95th Cong., 1st sess., 1977. Walters, Arden B., King, Robert J., and Richardson, Stuart I., Environmental Issure_ and Strategies for Peat Energy Development in the U.S. McLean, Va.: UOP Inc. and System Development Corporation, n.d. -93- APPENDIX D. REVIEWERS' COMMENTS The following are letters received by North Carolina Department of Natural Resources and Community Development in response to the first draft of this report (February 1982). In cases where the comment represented updated factual information (information not available to authors at the time the first draft was written), the new information was inserted into this final draft. Where the comment represented an opinion or projection based on speculation or information not in the public domain, the text remained unchanged and reflects the best information available at the time the first draft was written. All comments received are contained in the letters to follow. -94- DIVISION OF ENVIRONMENTAL MANAGEMENT March 17, 1982 MEMORANDUM MAR 18 198� TO: Jim Smith Office of Coastal Management COAM- L RESOURCES COMM. FROM: Marshall Rackley, Chie2� Air.Quality Section SUBJECT: Comments on "The Design of a Planning Program to Help Mitigate Energy Facility - Related Air Quality Impacts in the Washington County, We appreciate the opportunity to review and make comments on the subject document. In all, the document is well written, most descriptive, and should provide the Governments of Washington, Hyde, and Tyrrell counties with a greater understanding of the environmental issues and energy -related development options associated with the peat development. However, we feel that the following comments are worthy of consideration: 1. Page 16, paragraph one: The text states that N.C. State standards coincide with secondary NAAQS for all criteria pollutants. In fact, N.C. standards coincide with primary NAAQS for all pollutants and for all averaging times except 24-hr particulate. The 3-hr S02 standard is a secondary NAAQS, how- ever, no primary 3-hr standard exists. The statement that N.C. is more stringent than Federal primary standards for particulate and S02 is not correct. The State of N.C. changed its annual particulate standard from 60 ug/m3 to 75 ug/m3 on October 15, 1981. Future reference to the annual particulate standard should reflect this change. 2. Page 31, paragraph one: Only the fugitive particulate emissions from that portion of the First Colony Farms mining operation which is associated with the methanol plant were modeled. 5 Z 3. Page 31, paragraph two: The maximum modeled-T-81r impact on the Swanquarter Class I area occurred during a 24-hr period containing calm winds. The impacts during the calm hours can be (but were not) eliminated from the 24-hr average value. Therefore, the modeled concentration is an overestimate of the true non -calm maximum that would be determined with a more refined analysis. Also, in the full scale methanol facility, additional controls may be employed, as necessary, to further reduce emissions. -2- Therefore, to imply that energy development is severely hampered by the presence of a Class I area may be an overstatement. 4. Page 35-38, paragraph two: The monitoring equipment in. Plymouth, NC is sufficient to establish a reasonable estimate of background air quality for S02, NO2, and TSP. Monitoring estimates, unless biased by nearby sources, are preferable to EPA rural values. The 20 ug/m3 EPA S02 back- ground estimate is higher than the annual average S02 measured at most State monitors, urban or rural, in the entire state. The 7 ug/m3 annual average measured at Plymouth is typical of the coastal plain rural areas of N.C. 5. Page 39, Table 9: This table reflects annual potential emissions from existing industrial sources during the years 1978 and 1979. Further investigation of current actual emissions may reflect lower rates. 6. Page 41, paragraph three No. 1: There is no foundation for the statement that it would be impossible to license a major facility (with proper con- trols) within 10 km of the Swanquarter Refuge. Too many variables are involved in the analyses required. No. 2: Although permitting schedules are protracted for various reasons and analyses required can be costly for any facility, it is not apparent that either of these problems would necessarily arise with facilities locating in the area. Peat Methanol Associates encountered no protraction of the permitting schedule or high additional cost for the analyses due to the presence of the Class I area. No. 5: Total increment consumption by the first few sources in the area does not necessarily prohibit further growth since increment consumption is.a function of receptor location and averaging period. Additional sources due to their location and orientation may not interact with existing sources while impacting the Class 1 area. 7. Page 48, paragraph 3: Twelve (12), not eight (8), continuous monitors (two -CO, four-SO2, and six 03) are operated by the State agency. 8. Page 49, Figure 5: The State Ahoskie TSP ambient monitoring station is no longer in operation. 9. Page 51, No. 2: The need for continuous NO2 monitoring is not immediately obvious. -3- No. 4: There currently is no EPA respirable particulate standard or approved (40 CFR 53) method. 10. Page 51,'paragraph one: The proposed monitor at the Swanquarter Refuge could be used to determine current ambient air quality in the Class 1 area and would supply information conerning air quality trends. However, such a monitor would not likely be capable of providing increment tracking information or checking dispersion modeling for increment consumption in that monitors are unable to differentiate between impacts from those sources consuming increment and variations in impacts from existing baseline sources. 11. Page 53, paragraph two: Air monitoring equipment for any network must be reference or equivalent if*the data is to be used for PSD affected projects, or plan revisions. Quality control and quality assurance procedures comply- ing with 40 CFR 58 Appendix A.2.2 or B.2.2 must be developed, approved by the permit granting authority, and implemented. 12. Page 54, paragraph six: It is anticipated by this Agency that a monitoring network will eventpally need to be established and that a significant portion of the monitoring will likely have to be performed by the mining operators. The Division's approach to monitoring peat mining impacts is to allow limited initial mining to proceed while affording the opportunity to evaluate the mining impacts. From these evaluations operational conditions and monitoring requirements can be applied to future permits or renewals. Currently, Air Quality Permits issued to peat mining operations are only issued for one year. 13. Page 71, paragraph one: Before using data bases such as those in Edenton and Weeksville to determine comparable representative meteorological data, the circumstances underwhich these data were obtained (anemometer height and threshold velocity, etc.) should be studied. These variables can greatly influence the comparability of two otherwise similar datasets. We hope these comments will be of value in your assessment of this document. Please feel free to contact Mr. Sammy Amerson or myself at 733-6126 should further infor- mation be needed. /pwr cc: Paul Wilms Jim Mulligan Mike Sewell Sammy Amerson February 25, 1982 MEMORANDUM TO: Jim Smith FROM: Jim Simons SUBJECT: Review of Draft of Energy Facility Air Quality Impact Study by Rogers, Golden, and Halpern Although I do not have the expertise to comment on many of the technical aspects of air quality report, I offer the following comments or questions in the aspects familar to me. Page 5 and 8 Permit issued to Peatco, Incorporated for approximately 3600 acres in Pamlico County is not mentioned Page 8 Correct name for the American Peat Company mine is "The 98" Page 20 Under dust mitigation -terracing or benching - flat land and relatively shallow depths of excavation would seem to dictate such shallow benches as to make this technique for dust mitigation ineffective Page 21 Futitive dust from traffic on haul roads may be a significant problem with large scale operations with long haul distances Page 51 Bottom of page -"The only fish habitat in Lake (Phelps) is along the shoreline,..." -Wildlife Resources should address this but -the fishing reports I have heard indicated that the better fishing within weed/moss beds considerably out from the shoreline. In a shallow lake, I would think that the shoreline is less important for habitat or spawning. Jim Smith Page Two February 25, 1982 Page 54 Reference #3 relating to monitoring from the First Colony permit -water, ground water and air quality conditions have been modified significantly since -issuance of First Colony permit and will likely continue to be modified as our experience grows. Consequently, it is misleading to illustrate this exert as a typical monitoring condition in peat permits. Page 83 Air Control Advisory Council -A problem may exist finding persons residing within Washington, Hyde Tyrrell technically qualified to serve on the Council; necessitating,advisors to the Advisory Council. Why limit Advisory Council members to Washing, Hyde, and Tyrrell Counties? Page 84-85 The Board of Water and Air Resources is now the Environmental Management Commission. No Depart- ment of Water and Air.Resources exists and the Department of Natural.and Economic Resources is now the Department of Natural Resources and Community Development. General Comment - Is a local Air Quality ordinance and Air Pollution Control Board needed or advisable? n JDS:pg April 7, 1982 Mr. J. Smith Office of Coastal Management North Carolina Department of Natural Resources and Community Development 512 North Salisbury Street Raleigh, NC 27611 Dear Jim: I have attached my comments on the report entitled "The Design of a Planning Program to Help Mitigate Energy Facility --Related Air Quality Impacts .in the Washington County, North Carolina Area," by Rogers, Golden & Halpern and Engineers for Energy and the Environment. Thank you for providing the opportunity for Koppers to provide comments. As I mentioned to you in our conversation last week, the report was received somewhat belatedly and I was uncertain as to the procedure for presenting our thoughts. The report was well done and certainly is a timely document. I do feel, as reflected in the attached, that the report is perhaps overly pessimistic concerning the amount of industry the region's air resource could support. Thanks again. Very truly yours, M. G. Morris MGM: ss Attachment 1 COMMENTS ON THE ROGERS, GOLDEN & HALPERN REPORT FOR WASHINGTON COUNTY, NC I. Peat to Methanol Plant Expansion The following comments deal with that portion of the report (page 31) which indicates that the air resources of eastern North Carolina could not support the expansion of the peat -to -methanol project from the initial capacity of 4,672 barrels per day to the ultimate capacity of 35,000 barrels per day. The report points out that the initial module meets all of the PSD review criteria and that the installation of the module will not adversely affect the region's air quality. The report presents an analysis of the impact of expanding the plant beyond the initial module, which leads to the conclusion that expansion will be limited by PSD increment exceedances even at a two -module level. The assumptions made in order to arrive at this conclusion were that the emissions for each additional module would be the same as the initial module, and that the same meteorological data and modeling techniques would be used for the PSD review for the expansion as were used for the first module. I would like to state that the PSD Application for the initial module represents an extremely conservative analysis•of the plant's impact with respect to both the emissions inventory and the modeling technique used. It was obvious at the time of the initial application submittal that in order to site additional modules, a more refined approach would be required for emission control and modeling. In the PSD review procedure, there are many techniques and parameters which can be varied in order to meet the PSD criteria. The following points indicate various factors which could be used to prepare a more refined analysis to support future PSD Applications. 1. A monitoring program will be instigated as, past of the initial installation in order to collect data on actual emissions. Point source test data can also be obtained during operation. In addition, meteorological parameters will be monitored at the site. The information gathered from these various measurements will be helpful in refining future air quality analyses. 2. The control level for point source TSP emissions could be made more stringent if necessary. For instance, the present application is based on New Source Performance Standard requirements which could be tightened for future modules. Fugitive emissions from mining are a major source of TSP impact. The present application does not consider any control. Development of control techniques offers the possibility of reducing the mining emission appreciably. 3. S02 emissions could be reduced, if needed, by adding flue gas desulfurization systems on the boilers, which are the major source of SO2 impact on the Class I area. 4. The Air Quality Analysis could be refined by using five years of meteorological data; thereby permitting the use of the highest second high. This technique alone, based on a preliminary estimate, would bring the SO2 impact level on the Class I area for the ultimate plant within the short-term increment requirement. Other techniques, such as varying stack parameters and excluding Class I area calms, would also affect the analysis appreciably. I believe that the conclusion reached in the Rogers, Golden & Halpern report is overly pessimistic. Based on the above discussion and a recent experience in siting a large synfuel plant, relatively near two Class I areas, leads me to believe that air resources of eastern North Carolina will support the 35,000 barrels per day peat -to -methanol plant. 3 II. Industrial Development Restriction The following discussion concerns the statements made on Page 41 of the report, which notes that industrial development may be severely restricted in the region due to the location of a Class I area. The seriousness of the situation is established by referring to the large fraction of the 24-hour Class I increments consumed by the peat -to - methanol project. As indicated in Section I of these comments, the impact of the initial peat -to -methanol module on the Class I area is very conservative, and extrapolation of these impacts to the ultimate plant impact is not a valid representation. The other point to be considered is that the 24-hour increment consumption is place and time specific. In other words, the increment consumption is established by modeling the sources emission impact at each receptor for each 24-hour period (day) in a year. The increment consumption is established by taking the highest impact predicted for one day (24-hour averaging) at one receptor. The likelihood of another source having its maximum impact at the same receptor and on the same day is unlikely. Therefore, the consumption of a large portion of a short- term increment (i.e., 24 hour) by one source is not a good indication that industrial development will be severely restricted. III. Experimental, Pilot Plant References This section comments on the various references in the report (pages 6, 41) to the peat -to -methanol project as either a pilot plant or ` a plant to conduct peat gasification experiments. The peat -to -methanol project is neither a pilot or experimental plant, it is a commercial size methanol plant, which gasifies a peat feed stock to generate a synthesis gas for methanol production. n W IV. Lake Phelps Sedimentation 1A. The report states, on Page 52, that the Lake Phelps habitat is currently being affected by sedimentation suffocating fish eggs, fry and other aquatic life. I have discussed this situation with persons from Duke University and the National Wildiife•Federation in Raleigh, and was unable to confirm the information reported. Perhaps the consulting group could provide more detail on this subject. M. G. Morris MGM: ss 4/7/82 .,ames B. Hum, Jr., Governor �r�.._; Division o, industrial Development 0. M Faircloth - ''� Alvah H. Ward, Jr.. Director Secretary (919) 733-4151 NORTH CAROLINA DEPARTMENT OF COMAMERCE . larch 24, 1982 MAR 2 � 1982 Mr. Jim, Smith Office of Coastal Management COASTAL RESOURCES CGS•"} N.C. Deparnnent of Natural Resources and Coc minity Develop;nent 512 North Salisbury Street Raleigh, North Carolina 27611 Dear 11r. Smith: The Industrial Development Division of the North Carolina Department of Cccmerce would like to submit our written cents coacerning the report prepared by Rcgers, Golden and Halpern and Engineers for Energy and the Environment for Washington County, North Carolina. It is our hope that all of our comments may prove useful in the understanding of the air quality situation in the tri-county area. It is our firm belief that this area of the state has ample roan for new industrial developrient and there are more favorable air quality factors in this region of the state than unfavorable factors. Please forward to us any final reports on this subject matte_-- when available. DL:wep Sincerely,_ �.t,Aol%_ Derr Zjeonhardt Senior Environmental Consultant 430 N. Salisbury St., Raleigh, N.C. 27611 1 The following carmaents are offered with respect to the report entitled The Design of a Planning Program to Help Mitigate Enera Facility -Related Air Quality Irrm_ acts in the Washington County No Carolina Area. General Comments: We are pleased to see that Washington, Hyde and Tyrrell Counties recognize the imoortance of performing a study of this kind and highly commend their efforts. The Industrial Development Division (IDD) of the :forth Carolina Department of Carmerce is fully aware that if the raaxim = utilization of this energy resource is not achieved then the maximum econanic benefits to the citizens of the state and the region wdll also not be obtained. It is the IUD desire to see that this resource is developer: in a manner which is both enviromnentally sound and economically benef ical . The report contains alot of useful information concerning air quality issues in general and the local air quality situation in particular. The report is very comprehensive and well written. How- ever, the Industrial Development Division cannot agree with many of the statements contained in the report (See specific caaments) and the general tone of the report which seems to indicate that air quality factors my play a major role in constraining full utilization of peat as a energy resource. North Carolina air quality regulations are designed to allow for moderate industrial growth without significantly deteriorating local or regional air quality. Under -these regulations no new or expanding industry has ever been denied an air quality permit. It is very unlikely that after applying reasonable control techniques to new industries locating in the tri-county area of Washington, Hyde and Tyrrell counties (these control techniques are mandated by law) any new source would be prevented from operation. By proper plant siting techniques the PSD Class I area will not play a major role in constrain- ing new growth.as long as the proper sites are selected at the initial stages of the project. One problem with the report was the statement listed under the purpose of the report which said "identify environmental issues in the'tri-county region, particularly potential air quality probldms associated with peat development". This indicates that the report was drafted with the possible preconcieved idea that there would be air quality problems to begin with. If an ob- jective report is going to be produced the issues need to be identified and then decided if they are going to create problems. The report is comprehensive from the standpoint that most relevant issues with respect to air quality have been identified and discussed, however, alot of discussion was devoted to situations that would no longer appear to be a problem. For example, existing annual TSP air quality and the change in standard fran 60 to 75 ug/m3. Cue key area which deserves special comment is rh'e extraplation of results of the Peat I'4lethanol Analysis with respect to Class I impacts. This analysis was performed at the screening level, in other words, i! is very conservative and subject :o revision. It should not be used for extrapI.ating. For future Expansions by Peat Methanol Associates it is anticipated that a more refined analysis will be performed. Specific Comments Page 16: TOP paragraph. Gives general impressions that state standards are very restrictive. This is not true. North Carolina by law cannot have more restrictive standards than the federal government. Secondary and primary standards are often the same (refer to page 12). To the best of our knowledge the secondary 24 hour TSP standard and 3 hour 30, standard have never caused a new or expanding company to build in another state. Page 31: Second paragraph. A simple screening analysis was performed. Mai c approach is preferred were applicable since it requires less time to prepare and review and speeds up the permitting process. Scaling should not be used in this case since a detailed analysis was not performed Which would have included using 5 years of meteorological data, using highest second high predicted concentrations, excluding calms periods for Class .I impacts. All these techniques could be used in future analyses to reduce the present conserva- tive predicted impacts. Little difficulty is foreseen in permitting a 35,000 EPD plant in the future. Page 38: Second paragraph, First sentence ,State standard has been changed to 75 mg/m3. Statement inappropriate. The Class I area is not expected to cause any major problems in permitting unless new sources are locating extremely close to the Class I area. Conclus- ions drawn in this paragraph are totally misleading and are based on an in- appropriate scaling technique of a screening modeling analysis. Page 41: Third paragraph - Statement 1-5 Statement 1- Not true. If proper controls are applied,a major facility can receive a permit. However, control equipment cost may be excessive. Receivin a permit would also depend on the type of facility requesting to be licensed. Statement 2- Not true. All permits have to be issued in a certain time frame regardless of location once an application is considered complete. Cost will vary depending on situation. Statement 5- Not true. Increment consumption is hiWy spacially effected. It is possible for one source to consume the entire short term increment at one location in a Class I area and still leave rocr^ for future growth because of plume '.nteraction possibilities. Page 42: Second paragraph. This discussion is no longer valid since the annual particulate standard has been raised to 75,ug/m3. Page 42: Third paragraph. The analysis that was conducted by the State on Texasgulf has undergone many revisions since this statement was made by Mr. Haynes. Because of more recent modeling input data the expected impact from Texasgulf on the Class I area is exl,,ected to be greatly less than 200 ug/m3. Page 42-43: Forth paragraph. The existance of the Class I area in southern Hyde County will not preclude any new major source from locating there. A source locating in this area will undergo a review process which will determine if a new source could be constructed in this area. For example, with a few engineering modifications and better control techniques the possibility exist that a facility the size of the initial stage of PMA could locate very close to the Class I area. Page 51: Second paragraph We cannot agree with the placement of the two monitors. The location of a monitor in the Class I area would be a waste of time. Monitors cannot be used to track increment consumption. Tracking is best performed by modeling. Monitoring data is highly variable from diy to day and year to year and could not be used to determine increment consumption because it would be impossible to determine background, baseline and increment contributions. If monitors are sited at all, they should be located downwind of mining sites and industrial plants along predaninate wind vectors (Northeast, Southwest). This location should be determined by applying EPA recommended annual models. Page 57: Third paragraph We strongly disagree with this paragraph conclusions and tone. As discussed in earlier comments the possibility of fuiise energy development in this area are generally good without any severe constraints. This paragraph has the effect of crying "fire" in a theater when the fire consists of a man liting a cigarette. We agree the factors brought out in this Paragraph will need to be addressed but none of these factors are believed to impose any unreasonable constraints for this area in particular. These same factors generally are applicable for all regions of North Carolina. -Pa-.-ge 71: Second paragraph g It is very difficult to determine wtat is "representative data". Wind data can change rarkedly by simply raising and lowering a wind sensor, wend data are effected by bodies of water such as rivers and sounds and terrain features such as trees and buildings. To say one set of data for this area is appropriate over another set is misleading. All the data sets listed have good points and bad points and could possibly be used in future analyses. The best data set should be determined on a case by case basis in consultation with the regulatory agency. Page 73: Third paragraph The approach of model validation using ambient data collected in a Class I area is idealistic and next to impossible to perform. Because of plume travel times, the appropriateness of meteorological data, and modeling sources loo kilometers away from a Class I area, validation of a gall iann oriel would not be possible. Even calibration of a model may be highly questionable. This type of activity would be a waste of time and money. The standard gaussian models are best applied wren modeling near source receptors. 19 33 DATE DUE CEIP Publications 1. Hauser, E. W., P. D. Cribbins, P. D. Tschetter, and R. D. Latta. Coastal Energy Transportation Needs to Support Major Energy Projects in North Carolina's Coastal Zone. CEIP Report #1. September 1981. $10. 2. P. D. Cribbins. A Study of OCS Onshore Support Bases and Coal Export Terminals. CEIP Report #2. September 1981. $10. 3. Tschetter, P. D., M. Fisch, and R. D. Latta. An Assessment of Potential Impacts of Energy -Related Transportation Developments on North Carolina's Coastal Zone. CEIP Report #3. July 1981. $10. 4. Cribbins, P. S. An Analysis of State and Federal Policies Affecting Major Energy Projects in North Carolina's Coastal Zone. CEIP Report #4. September 1981. $10. 5. Brower, David, W. D. McElyea, D. R. Godschalk, and N. D. Lofaro. Outer Continental Shelf Development and the North Carolina Coast: A Guide for Local Planners. CEIP Report #5. August 1981. $10. 6. Rogers, Golden and Halpern, Inc., and Engineers for Energy and the Environment, Inc. Mitigating the Impacts of Energy Facilities: A Local Air Quality Program for the Wilmington, N. C. Area. CEIP Report #6. September 1981. $10. 7. Richardson, C. J. (editor). Pocosin Wetlands: an Integrated Analysis of Coastal Plain Freshwater Bogs in North Carolina. Stroudsburg (Pa): Hutchinson Ross. 364 pp. $25. Available from School of Forestry, Duke University, Durham, N. C. 27709. (This proceedings volume is for a conference partially funded by N. C..CEIP. It replaces the N. C. Peat Sourcebook in this publication list.) 8. McDonald, C. B., and A. M. Ash. Natural Areas Inventory of Tyrrell County, N. C. CEIP Report #8. October 1981. $10 for all requests. 9. Fussell, J., and E. J. Wilson. Natural Areas Inventory of Carteret County, N. C. CEIP Report #9. October 1981. $10 for all requests. 10. Nyfong, T. D. Natural Areas Inventory of Brunswick County, N. C. CEIP Report #10. October 1981. $10 for all requests. 11. Leonard, S. W., and R. J. Davis. Natural Areas Inventory for Pender County, N. C. CEIP Report #11. October 1981. $10 for all requests. 12. Cribbins, Paul D., and Latta, R. Daniel. Coastal Energy Transportation Study: Alternative Technologies for Transporting and Handling Export Coal. CEIP Report #12. January 1982. $10 for all requests. 13. Creveling, Kenneth. Beach Communities and Oil Spills: Environmental and Economic Consequences for Brunswick County, N. C. CEIP Report #13. May 1982. $10. 14. Rogers, Golden -and Halpern, Inc., and Engineers for Energy and the Environment. The Design of a Planning Program to Help Mitigate Energy Facility -Related Air Quality Impacts in the Washington County, North Carolina Area. CEIP Report #14. September 1982. $10. 19. Pate, Preston P., and Jones, Robert. Effects of Upland Drainage on Estuarine Nursery Areas of Pamlico Sound, North Carolina. CEIP Report #19. December, 1981. $1.00. 34. Roberts and Eichler Associates, Inc. Area Development Plan for Radio Island. CEIP Report #34. June 1982. $10. s� t..:�{���r>�jt�l1� i'r, �'t,� r ��� \�