HomeMy WebLinkAbout20181192 Ver 1_C540_Air_Quality_1217_20180122AIR QUALITY REPORT
__�s
�
• COMPLETE
�.. <��-0
�riar�gle Expressway
Southeast E�rtensian
Wake and Johnston Counties
WBS Element No. 37673.1.TA2, 35516.1.TA2 and 35517.1.TA1
TIP Project No. R-2721, R-2828 and R-2829
Prepared for:
North Carolina Department of Transportation
Environmental Analysis Unit
Traffic Noise and Air Quality Group
Submitted by:
H. W. Lochner, Inc.
LOCHNER
December 1, 2017
�Vake and Johnston Counties
WBS Element No. 37673.1.TA2, 35516.1.TA2 and 35517.1.TA1
TIP Project No. R-2721, R-2828 and R-2829
Prepared for:
Nortli Carolina Departm�nt of Transportation
Environmental Analysis Unit
Traffic Noise and Air Quality Group
�.
,�....� � ,,
,. �.
�' ��r --� .� --,..._� ..�._��_ �<��t���
David Shannon, Project Manager
Lochner
Accepted By:
NCDOT Environmental nalysis Unit
Traffic Noise & Air Quality Group
/.Z ' �" �%
Date �
1.
2.
3.
4.
5.
6.
7.
8.
..
.
9.
10.
Table of Contents
Introductio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
AirQuality Analysis ..........................................................................................1
AttainmentStatus ..............................................................................................4
CarbonMonoxide ..............................................................................................4
Ozone& Oxides ................................................................................................4
Particulate Matter & Sulfur ................................................................................5
Lead..................................................................................................................5
Mobile Source Air Toxics (MSAT) ....................................................................5
Background.......................................................................................................5
Motor Vehicle Emissions Simulator (MOVES) .................................................5
MSATResearch ................................................................................................6
NEPAContext ...................................................................................................8
Consideration of MSAT in NEPA Documents ....................................................8
Qualitative MSAT Analysis .............................................................................10
Incomplete or Unavailable Information for Project-Specific MSAT Health
ImpactsAnalysis .............................................................................................11
MSATConclusion ...........................................................................................13
Construction Air Quality ..................................................................................13
Summary.........................................................................................................13
List of Tables
Table 1. National and North Carolina Ambient Air Quality Standards (NAAQS) ........................3
Table 1. Vehicle Miles and Vehicle Hours Traveled Under Various Alternatives .....................10
List of Figures
Figure1. Project Location Map ...................................................................................................2
Figure 2. National MSAT Emission Trends 2010 - 2050 for Vehicles Operating on Roadways
Using EPA's MOVES2014a Mode1 .............................................................................................7
1. Introduction
The North Carolina Department of Transportation (NCDOT), in cooperation with the Federal
Highway Administration (FHWA), is proposing the completion of the 540 Outer Loop by way
of the Southeast Extension of the Triangle Expressway in Wake and Johnston Counties.
The proposed facility will be a new, limited-access highway from NC 55 Bypass in Apex, to
US 64/LTS 264 Bypass (I-495) in Knightdale—a distance of approximately 27 miles. The
proposed highway, known as Complete 540–Triangle Expressway South-east Extension, is
being proposed as a toll facility. A Project Location Map is attached as Figure 1.
As part of the Draft Environmental Impact Study (DEIS), 17 Detailed Study Alternatives
(DSA) were considered for this project which consisted of various combinations and portions of
the Orange, Lilac, Purple, Blue, Red, Green, Brown, Mint, Tan and Teal corridors. DSA 2 was
selected as the Preferred Alternative in the DEIS. Since the selection of the Preferred
Alternative, the design year has been changed from 2035 to 2040 and additional traffic data for
the 2016 Existing condition and the 2040 Build condition have been developed. Also, since the
DEIS was completed, Wake and Johnston Counties have been redesignated to attainment for all
criteria pollutants. This air report is an evaluation of DSA 2, the Preferred Alternative for the
Final EIS.
This project is included in the North Carolina Transportation Improvement Program (STIP) as
Projects R-2721, R-2828 and R-2829. This air quality report is part of an Environmental Impact
Statement being prepared for the project. The project is funded through the North Carolina
Turnpike Authority.
This Preferred Alternative has been shown to be the most practical solution for meeting the
purposes of the project, which are to improve mobility and reduce traffic congestion south and
east of the Raleigh area during peak travel periods. A secondary purpose of the project is to
improve system linkage in the regional roadway network by completing the 540 outer loop
around the greater Raleigh area, which would benefit commuters living south and east of
Raleigh as well as motorists making longer trips through the Triangle Region.
2. Air Quality Analysis
Air pollution originates from various sources. Emissions from industry and internal
combustion engines are the most prevalent sources. The impact resulting from highway
construction ranges from intensifying existing air pollution problems to improving the ambient
air quality. Changing traffic patterns are a primary concern when determining the impact of a
new highway facility or the improvement of an existing highway facility. Motor vehicles emit
carbon monoxide (CO), nitrogen oxide (NO), hydrocarbons (HC), particulate matter, sulfur
dioxide (SOa), and lead (Pb) (listed in order of decreasing emission rate).
The Federal Clean Air Act of 1970 established the National Ambient Air Quality Standards
(NAAQS). These were established in order to protect public health, safety, and welfare from
known or anticipated effects of air pollutants. The NAAQS contain criteria for SOa, particulate
matter (PMIo, 10-micron and smaller, PM2.s, 2.5 micron and smaller), CO, nitrogen dioxide
(NOa), ozone (03), and lead (Pb).
1
N
�� �Z, L,�-" y`a' � � - =�
� ' r I�, : � - . . �--•���
.J
��
55
= t, �'�'
RALEIGH
, ,:l
, D�,,, '�
� KNIGHTDALE
� � �
- -�4 ��/-. .. ._ .
C A R Y � ',� 64 264� _�_.'
�>, 64 `f � � �
� .'� �
.� i i
' � r
APEX �C - f� � �. 1
� � 1
� S t U D ��— . �
��^��,�.�---��� 401 �� � �,. ���e Ri�p ��
A._._,_--- F� �
TOLL
540
�'k
P�
heeler
,"�� /�n R
" tl.
; v u- -
� HOLLY
I
GARNER `r 1 -
_ !
. =+ '_ \�. / .
/
/
�' � �
/ ., �. .� - ' .,
dke f3r•ns�,n �� . � �
� � /
_ �
� SPRINGS �`_ TNOT�n 5O j CLAYTON l�I
1 � � �'c' I y
\ �
�\`, T - ;��+' 401 _,�,.
55 '
� %
` f
V %�Qek
♦� ` � �
� r� „,.b
�� , , ��
• �'� 42 r F�
�
� ti
FUQUAY-� —_�___
42 VARINA -- ------^— --
401 55
Figure 1
��REFERRED ALTERIVATYVE
Detailed Study Alternative 2
, ' 1
/ 1�']�
l,,�
' 70 , r
A ;. � ,.
.
2ek �� N
� 42 � O -_
�.5� ,�--� �—V � -... 0 1 2 3 4
� _'_--_-�� .
miles
\ � (ap0�oxlmate)
Of the seventeen Detailed Study Alternatives, Alternative 2 was selected by the Federal
Highway Administration and the North Carolina Department of Transportation as the
preferred alternative. This alternative consists of the Orange Segment from NC 55 Bypass
to east of I-40, and the Green Segment from east of I-40 to US 64/264 Bypass. The Green
Segment shifts to the Mint Green segment for a portion of its length, as shown here.
The National and North Carolina Ambient Air Quality Standards are presented in Table 1.
Table 1. National and North Carolina Ambient Air Quality Standards (NAAQS)
Pollutant Primary/ Averaging
Secondary Time Level Form
Carbon Monoxide 8 hours 9 ppm Not to be exceeded more than
primary
�C�� 1 hour 35 ppm once per year
primary and Rolling 3 month 3�i�
Lead (Pb) secondary average 0.15 µg/m Not to be exceeded
98th percentile of 1-hour daily
primary 1 hour 100 ppb maximum concentrations,
Nitrogen Dioxide averaged over 3 years
���� primary and �z�
secondary 1 year 53 ppb Annual Mean
primary and Annual fourth-highest daily
Ozone (03� secondary g hours 0.070 ppm �3� maximum 8-hour concentration,
averaged over 3 years
primary 1 year 12.0 µg/m3 annual mean, averaged over 3
years
3 annual mean, averaged over 3
pM2.5 secondary 1 year 15.0 µg/m
PartiCle years
P011utlOri primary and 24 hours 35 m3 98th percentile, averaged over 3
�pM� secondary µ� years
primary and 3 Not to be exceeded more than
PMI� secondary 24 hours 150 µg/m once per year on average over 3
years
99th percentile of 1-hour daily
primary 1 hour 75 ppb �4� maximum concentrations,
Sulfur Dioxide (SOz) averaged over 3 years
secondary 3 hours 0.5 ppm Not to be exceeded more than
once per year
(1) In areas designated nonattainment for the Pb standards prior to the promulgation of the current (2008) standards, and for
which implementation plans to attain or maintain the current (2008) standards have not been submitted and approved, the
previous standards (1.5 µg/m3 as a calendar quarter average) also remain in effect.
(2) The level of the annual NO2 standard is 0.053 ppm. It is shown here in terms of ppb for the purposes of clearer comparison
to the 1-hour standard level.
(3) Final rule signed October 1, 2015, and effective December 28, 2015. The previous (2008) Os standards additionally remain
in effect in some areas. Revocation of the previous (2008) Os standards and transitioning to the current (2015) standards will
be addressed in the implementation rule for the current standards.
(4) The previous S02 standards (0.14 ppm 24-hour and 0.03 ppm annual) will additionally remain in effect in certain areas: (1)
any area for which it is not yet 1 year since the effective date of designation under the current (2010) standards, and (2)any
area for which implementation plans providing for attainment of the current (2010) standard have not been submitted and
approved and which is designated nonattainment under the previous S02 standards or is not meeting the requirements of a SII'
call under the previous S02 standards (40 CFR 50.4(3)), A SII' call is an EPA action requiring a state to resubmit all or part of
its State Implementation Plan to demonstrate attainment of the require NAAQS.
Source: US EPA, https://www.epa.�ov/criteria-air-pollutants/naaqs-table, accessed October 6, 2017.
The primary pollutants from motor vehicles are unburned hydrocarbons (HC), Nitrogen oxides
(NOx), CO, and particulates. HC and NOx can combine in a complex series of reactions
catalyzed by sunlight to produce photochemical oxidants such as 03 and NOa. Because these
reactions take place over a period of several hours, maximum concentrations of photochemical
oxidants are often found far downwind of the precursor sources. These pollutants are regional
problems.
3. Attainment Status
The proposed project is located in Wake and Johnston Counties, which have been determined to
comply with the NAAQS. The proposed project is located in an attainment area; therefore, 40
CFR Parts 51 and 93 are not applicable. The proposed project is not anticipated to create any
adverse effects on the air quality of this attainment area.
4. Carbon Monoxide
Carbon monoxide is a colorless, odorless gas that is formed when carbon in fuel is not burned
completely. It is a component of motor vehicle exhaust, which contributes approximately 56
percent of all carbon emissions nationally. State and federal guidance suggests using CO
predictions as the primary indicator for vehicular induced pollution. CO is sensitive to
variations in temperature; emissions are twice as high in winter months as compared to summer
months. CO is also sensitive to vehicle speed; emissions decrease with an increase in speed (up
to 50 mph), and then increase again at higher speeds. Idling and low speeds (less than 15 mph)
can produce the highest CO levels. Recent trends in air quality indicate CO levels have
dramatically improved. The decline in CO concentrations is primarily due to stricter controls on
automobile exhaust resulting in cleaner cars. This drop is remarkable because it is occurring
while the nation's population is growing rapidly, yielding more traffic and urban sprawl.
CO regional and project-level conformity requirements in North Carolina have ended.
Therefore, regional and project-level transportation conformity requirements no longer apply to
CO in North Carolina. As such, project-level CO hot-spot analyses using MOVES2014 and
CAL3QHC emission and dispersion models are no longer required in North Carolina as part of
the NEPA/SEPA process.
5. Ozone & Oxides
Automobiles are regarded as sources of HC and NOx. HC and NOx emitted from cars are
carried into the atmosphere where they react with sunlight to form 03 and NOa. Automotive
emissions of HC and NOx are expected to decrease in the future due to the continued
installation and maintenance of pollution control devices on new cars. However, regarding
area-wide emissions, these technological improvements may be offset by the increasing number
of cars on the transportation facilities of the area.
The photochemical reactions that form 03 and NOa require several hours to occur. For this
reason, the peak levels of ozone generally occur ten to twenty kilometers downwind of the
source of HC emissions. Urban areas as a whole are regarded as sources of HC, not individual
streets and highways. The emissions of all sources in an urban area mix in the atmosphere, and,
in the presence of sunlight, this mixture reacts to form 03, NOa, and other photochemical
oxidants. The best example of this type of air pollution is the smog that forms in Los Angeles,
California.
4
6. Particulate Matter & Sulfur
Automobiles are not regarded as significant sources of particulate matter (PM) and SOa.
Nationwide, highway sources account for less than seven percent of PM emissions and less than
two percent of SOa emissions. PM and SOa emissions are predominantly the result of non-
highway sources (e.g., industrial, commercial, and agricultural). Because emissions of PM and
SOa from automobiles are very low, there is no reason to suspect that traffic on the proposed
project will cause air quality standards for PM and SOa to exceed the NAAQS.
This project is within an attainment area for PM2.s and PMIo and does not include significant
increases in diesel traffic. Therefore, no quantitative PM2.s or PMIo analysis is required.
7. Lead
Automobiles without catalytic converters can burn regular gasoline. The burning of regular
gasoline emits lead as a result of regular gasoline containing tetraethyl lead, which is added by
refineries to increase the octane rating of the fuel. Newer cars with catalytic converters burn
unleaded gasoline, thereby eliminating lead emissions. Also, the United States Environmental
Protection Agency (EPA) has required the reduction in the lead content of leaded gasoline. The
overall average lead content of gasoline in 1974 was approximately 0.53 gram per liter. By
1989, this composite average had dropped to 0.003 gram per liter. The Clean Air Act
Amendments of 1990 (CAAA) made the sale, supply, or transport of leaded gasoline or lead
additives unlawful after December 31, 1995. Because of these reasons, it is not expected that
traffic on the proposed project will cause the NAAQS for lead to be exceeded.
8. Mobile Source Air Toxics (MSAT)
8.1. Background
Controlling air toxic emissions became a national priority with the passage of the CAAA,
whereby Congress mandated that the EPA regulate 188 air toxics, also known as hazardous air
pollutants. The EPA assessed this expansive list in its rule on the Control of Hazardous Air
Pollutants from Mobile Sources (Federal Register, Vol. 72, No. 37, page 8430, February 26,
2007), and identified a group of 93 compounds emitted from mobile sources that are part of
EPA's Integrated Risk Information System (IRIS).1 In addition, EPA identified nine
compounds with significant contributions from mobile sources that are among the national and
regional-scale cancer risk drivers or contributors and non-cancer hazard contributors from the
2011 National Air Toxics Assessment (NATA).2 These are 1,3-butadiene, acetaldehyde,
acrolein, benzene, diesel particulate matter (diesel PM), ethylbenzene, formaldehyde,
naphthalene, and polycyclic organic matter. While FHWA considers these the priority MSAT,
the list is subject to change and may be adjusted in consideration of future EPA rules.
8.2. Motor Vehicle Emissions Simulator (MOVES)
According to EPA, MOVES2014 is a major revision to MOVES2010 and improves upon it in
many respects. MOVES2014 includes new data, new emissions standards, and new functional
improvements and features. It incorporates substantial new data for emissions, fleet, and
activity developed since the release of MOVES2010. These new emissions data are for light-
1 https://www.epa. og v/iris
z https://www.epa.gov/national-air-toxics-assessment
and heavy- duty vehicles, exhaust and evaporative emissions, and fuel effects. MOVES2014
also adds updated vehicle sales, population, age distribution, and vehicle miles travelled (VMT)
data.
MOVES2014 incorporates the effects of three new Federal emissions standard rules not
included in MOVES2010. These new standards are all expected to impact MSAT emissions
and include Tier 3 emissions and fuel standards starting in 2017 (79 FR 60344), heavy-duty
greenhouse gas regulations that phase in during model years 2014-2018 (79 FR 60344), and the
second phase of light duty greenhouse gas regulations that phase in during model years 2017-
2025 (79 FR 60344). Since the release of MOVES2014, EPA has released MOVES2014a. In
the November 2015 MOVES2014a Questions and Answers Guide,3 EPA states that for on-road
emissions, MOVES2014a adds new options requested by users for the input of local VMT,
includes minor updates to the default fuel tables, and corrects an error in MOVES2014 brake
wear emissions. The change in brake wear emissions results in small decreases in PM
emissions, while emissions for other criteria pollutants remain essentially the same as
MOVES2014.
Using EPA's MOVES2014a model, as shown in Figure 2, FHWA estimates that even if VMT
increases by 45 percent from 2010 to 2050 as forecast, a combined reduction of 91 percent in
the total annual emissions for the priority MSAT is projected for the same time period.
Diesel PM is the dominant component of MSAT emissions, making up 50 to 70 percent of all
priority MSAT pollutants by mass, depending on calendar year. Users of MOVES2014a will
notice some differences in emissions compared with MOVES2010b. MOVES2014a is based
on updated data on some emissions and pollutant processes compared to MOVES2010b, and
also reflects the latest Federal emissions standards in place at the time of its release. In
addition, MOVES2014a emissions forecasts are based on lower VMT projections than
MOVES2010b, consistent with recent trends suggesting reduced nationwide VMT growth
compared to historical trends.
8.3. MSAT Research
Air toxics analysis is a continuing area of research. While much work has been done to assess
the overall health risk of air toxics, many questions remain unanswered. In particular, the tools
and techniques for assessing project-specific health outcomes as a result of lifetime MSAT
exposure remain limited. These limitations impede the ability to evaluate how potential public
health risks posed by MSAT exposure should be factored into project-level decision-making
within the context of National Environmental Policy Act (NEPA).
Nonetheless, air toxics concerns continue to arise on highway projects during the National
Environmental Policy Act (NEPA) process. Even as the science emerges, the public and other
agencies expect FHWA to address MSAT impacts in its environmental documents. The
FHWA, EPA, the Health Effects Institute, and others have funded and conducted research
studies to try to more clearly define potential risks from MSAT emissions associated with
highway projects. The FHWA will continue to monitor the developing research in this field.
3 https://www.epa.gov/moves/moves2014a-latest-version-motor-vehicle-emission-simulatar-moves
0
Diesel PM
Benzene
Formaldehyde
0.16
{}.15
0.14
(}.13
0.12
{}.11
0.10
Q.09
0.08
�.�7
LJ.��
0.05
U.04
0.03
�.02
0.01
O.00 J
0.0035
0.0030
O.Q025
0.0020
0.�015
0.0010
0.0005
— — — VMT
Butadiene
Naphthalene
AcrQlein
Acetaldehyde
Ethylbenzene
Polycyclics
7
,�
5
2
1
0 A000 � —�,_ __-- � �—� -r-r,� -� -�r r,� r r- � 0
2010 2015 202D 2025 2030 2035 2040 2045 2050
Year
Source: EPA MOVES2014a.
Figure 2. National MSAT Emission Trends 2010 - 2050 for Vehicles Operating on
Roadways Using EPA's MOVES2014a Model
7
8.4. NEPA Context
The NEPA requires, to the fullest extent possible, that the policies, regulations, and laws of the
Federal Government be interpreted and administered in accordance with its environmental
protection goals, and that Federal agencies use an interdisciplinary approach in planning and
decision-making for any action that adversely impacts the environment (42 U.S.C. 4332). In
addition to evaluating the potential environmental effects, FHWA must also take into account
the need for safe and efficient transportation in reaching a decision that is in the best overall
public interest (23 U.S.C. 109(h)). The FHWA policies and procedures for implementing
NEPA are contained in regulation at 23 CFR Part 771.
8.5. Consideration of MSAT in NEPA Documents
The FHWA developed a tiered approach with three categories for analyzing MSAT in NEPA
documents, depending on specific project circumstances:
(1) No analysis for projects with no potential for meaningful MSAT effects;
(2) Qualitative analysis for projects with low potential MSAT effects; or
(3) Quantitative analysis to differentiate alternatives for projects with higher potential
MSAT effects.
For projects warranting MSAT analysis, all nine priority MSAT should be considered.
(1) Projects with No Meaningful Potential MSAT Effects, or Exempt Projects.
The types of projects included in this category are:
• Projects qualifying as a categorical exclusion under 23 CFR 771.117;
• Projects exempt under the Clean Air Act conformity rule under 40 CFR 93.126; and
• Other projects with no meaningful impacts on traffic volumes or vehicle mix.
For projects that are categorically excluded under 23 CFR 771.117, or are exempt from
conformity requirements under the Clean Air Act pursuant to 40 CFR 93.126, no analysis or
discussion of MSAT is necessary. Documentation sufficient to demonstrate that the project
qualifies as a categorical exclusion and/or exempt project will suffice. For other projects with
no or negligible traffic impacts, regardless of the class of NEPA environmental document, no
MSAT analysis is recommended. However, the project record should document the basis for
the determination of no meaningful potential impacts with a brief description of the factors
considered.
(2) Projects with Low Potential MSAT Effects
The types of projects included in this category are those that serve to improve operations of
highway, transit, or freight without adding substantial new capacity or without creating a
facility that is likely to meaningfully increase MSAT emissions. This category covers a broad
range of projects.
FHWA anticipates that most highway projects that need an MSAT assessment will fall into
this category. Examples of these types of projects are minor widening projects; new
interchanges; replacing a signalized intersection on a surface street; and projects where design
E3
year traffic is projected to be less than 140,000 to 150,000 annual average daily traffic
(AADT).
For these projects, a qualitative assessment of emissions projections should be conducted.
This qualitative assessment should compare, in narrative form, the expected effect of the
project on traffic volumes, vehicle mix, or routing of traffic and the associated changes in
MSAT for the project alternatives, including no-build, based on VMT, vehicle mix, and speed.
It should also discuss national trend data projecting substantial overall reductions in emissions
due to stricter engine and fuel regulations issued by EPA. Because the emission effects of
these projects typically are low, we expect there would be no appreciable difference in overall
MSAT emissions among the various alternatives.
In addition to the qualitative assessment, a NEPA document for this category of projects must
include a discussion of information that is incomplete or unavailable for a project specific
assessment of MSAT impacts, in compliance with the Council on Environmental Quality
(CEQ) regulations (40 CFR 1502.22(b)). This discussion should explain how current
scientific techniques, tools, and data are not sufficient to accurately estimate human health
impacts that could result from a transportation project in a way that would be useful to
decision-makers. Also in compliance with 40 CFR 150.22(b), this discussion should contain
information regarding the health impacts of MSAT.
(3) Projects with Higher Potential MSAT Effects
This category includes projects that have the potential for meaningful differences in MSAT
emissions among project alternatives. FHWA expects a limited number of projects to meet
this two-pronged test. To fall into this category, a project should:
• Create or significantly alter a major intermodal freight facility that has the potential to
concentrate high levels of diesel PM in a single location, involving a significant
number of diesel vehicles for new projects or accommodating with a significant
increase in the number of diesel vehicles for expansion projects; or
• Create new capacity or add significant capacity to urban highways such as Interstates,
urban arterials, or urban collector-distributor routes with traffic volumes where the
AADT is projected to be in the range of 140,000 to 150,0004 or greater by the design
year;
And also
• Be proposed to be located in proximity to populated areas.
Projects falling within this category should be more rigorously assessed for impacts. If a
project falls within this category, the project sponsor should contact the Office ofNatural
Environment (HEPl� and the Office of Project Development and Environmental Review
(HEPE) in FHWA Headquarters for assistance in developing a specific approach for assessing
4 Using EPA's MOVES2014a emissions model, FHWA determined that this range of AADT would result in
emissions significantly lower than the Clean Air Act definition of a major hazardous air pollutant (HAP) source, i.e.,
25 tons/yr. far all HAPs ar 10 tons/yr. for any single HAP. Variations in conditions such as congestion or vehicle
mix could warrant a different range for AADT.
�7
impacts. This approach would include a quantitative analysis to forecast local-specific
emission trends of the priority MSAT for each alternative, to use as a basis of comparison.
This analysis also may address the potential for cumulative impacts, where appropriate, based
on local conditions. How and when cumulative impacts should be considered would be
addressed as part of the assistance outlined above.
If the analysis for a project in this category indicates meaningful differences in levels of
MSAT emissions among alternatives, mitigation options should be identified and considered.
The project sponsor should also consult with HEPN and HEPE if a project does not fall within
any of the types of projects listed in Category (3) above, but may have the potential to
substantially increase future MSAT emissions.
Projects R-2721, R-2828 and R-2829 fall under Category (2) because they do not qualify as a
categorical exclusion under 23 CFR 771.117; are intended to improve the operations of the
existing road network; and the 2040 Design Year traffic is not projected to meet or exceed the
140,000 to 150,000 AADT criterion. The project's Design Year traffic ranges from 26,100 to
68,700 vehicles per day (VPD) along the proposed expressway.
8.6. Qualitative MSAT Analysis
A qualitative analysis provides a basis for identifying and comparing the potential differences
among MSAT emissions, if any, from the various alternatives. The qualitative assessment
presented below is derived in part from a study conducted by FHWA entitled A Methodology
for Evaluating Mobile Source Air Toxic Emissions Among Transportation Project Alternatives,
found at:
https://www.fllwa.dot.gov/environment/air quality/air_toxics/research and analysis/mobile_so
urce air toxics/msatemissions.cfin.
For each DSA in the EIS, the amount of MSAT emitted would be proportional to the vehicle
miles traveled, or VMT, assuming that other variables such as fleet mix are the same for each
DSA. See Table 2 for a comparison of the VMT and vehicle hours traveled (VHT) for the
Preferred Alternative (DSA 2) and the No-Build Alternative. As shown in the table, the VMT
under the DSA will increase 1.53% over the No-Build Alternative. Data in the table represents
VMT and VHT from the region-wide model, comparable to what was reported in the DEIS.
Table 2. Vehicle Miles and Vehicle Hours Traveled Under Various Alternatives
2040 Daily Percent 2040 Daily
Vehicle Change in Vehicle
Miles VMT Hours Percent Change
Traveled Compared Traveled in VHT Compared
(VMT) in to No-Build (VHT) in to No-Build
Scenario 1000's Alternative 1000's Alternative
No-Build Alternative 86,545 2,233
Preferred Alternative (DSA 2) - Orange g��g�3 1.53% 2,244 0.49%
to Green to Mint Green to Green
Source: HNTB, "First Tier Alternative Screening and Trattic ReassessmenY', December 2017
10
Also, emissions will likely be lower than present levels in the design year as a result of the
EPA's national control programs that are projected to reduce annual MSAT emissions by over
90 percent from 2010 to 2050 (Updated Interim Guidance on Mobile Source Air Toxic Analysis
in NEPA Documents, Federal Highway Administration, October 18, 2016). Local conditions
may differ from these national projections in terms of fleet mix and turnover, VMT growth
rates, and local control measures. However, the magnitude of the EPA-projected reductions is
so great (even after accounting for VMT growth) that MSAT emissions in the project study area
are likely to be lower in the future in virtually all locations.
Under the build alternative there may be localized areas where VMT would increase, and other
areas where VMT would decrease. Therefore, it is possible that localized increases and
decreases in MSAT emissions may occur. The localized increases in MSAT emissions would
likely be most pronounced near the proposed roadway sections of 540 that are closer to
residences. However, even if these increases do occur, they too will be substantially reduced in
the future due to implementation of EPA's vehicle and fuel regulations.
In sum, under the Preferred Alternative (DSA 2) in the design year, it is expected there would
be reduced MSAT emissions in the immediate area of the project, relative to the No-Build
Alternative, due to EPA's MSAT reduction programs.
8.7. Incomplete or Unavailable Information for Project-Specific MSAT Health
Impacts Analysis
In FHWA's view, information is incomplete or unavailable to credibly predict the project-
specific health impacts due to changes in MSAT emissions associated with a proposed set of
highway alternatives. The outcome of such an assessment, adverse or not, would be influenced
more by the uncertainty introduced into the process through assumption and speculation rather
than any genuine insight into the actual health impacts directly attributable to MSAT exposure
associated with a proposed action.
The EPA is responsible for protecting the public health and welfare from any known or
anticipated effect of an air pollutant. They are the lead authority for administering the Clean
Air Act and its amendments and have specific statutory obligations with respect to hazardous
air pollutants and MSAT. The EPA is in the continual process of assessing human health
effects, exposures, and risks posed by air pollutants. They maintain the Integrated Risk
Information System (IRIS), which is "a compilation of electronic reports on specific substances
found in the environment and their potential to cause human health effects" (EPA,
https://www.epa.gov/iris/). Each report contains assessments of non-cancerous and cancerous
effects for individual compounds and quantitative estimates of risk levels from lifetime oral and
inhalation exposures with uncertainty spanning perhaps an order of magnitude.
Other organizations are also active in the research and analyses of the human health effects of
MSAT, including the Health Effects Institute (HEI). A number of HEI studies are summarized
in Appendix D of FHWA's Updated Interim Guidance on Mobile Source Air Toxic Analysis in
NEPA Documents. Among the adverse health effects linked to MSAT compounds at high
exposures are: cancer in humans in occupational settings; cancer in animals; and irritation to the
respiratory tract, including the exacerbation of asthma. Less obvious is the adverse human
health effects of MSAT compounds at current environmental concentrations (HEI Special
Report 16, https://www.healtheffects.org/publication/mobile-source-air-toxics-critical-review-
literature-exposure-and-health-effects) or in the future as vehicle emissions substantially
11
decrease.
The methodologies for forecasting health impacts include emissions modeling; dispersion
modeling; exposure modeling; and then final determination of health impacts — each step in the
process building on the model predictions obtained in the previous step. All are encumbered by
technical shortcomings or uncertain science that prevents a more complete differentiation of the
MSAT health impacts among a set of project alternatives. These difficulties are magnified for
lifetime (i.e., 70 year) assessments, particularly because unsupportable assumptions would have
to be made regarding changes in travel patterns and vehicle technology (which affects
emissions rates) over that time frame, since such information is unavailable.
It is particularly difficult to reliably forecast 70-year lifetime MSAT concentrations and
exposure near roadways; to determine the portion of time that people are actually exposed at a
specific location; and to establish the extent attributable to a proposed action, especially given
that some of the information needed is unavailable.
There are considerable uncertainties associated with the existing estimates of toxicity of the
various MSAT, because of factors such as low-dose extrapolation and translation of
occupational exposure data to the general population, a concern expressed by HEI (Special
Report 16, https://www.healtheffects.org/publication/mobile-source-air-toxics-critical-review-
literature-exposure-and-health-effects). As a result, there is no national consensus on air dose-
response values assumed to protect the public health and welfare for MSAT compounds, and in
particular for diesel PM. The EPA states that with respect to diesel engine exhaust, "[t]he
absence of adequate data to develop a sufficiently confident dose-response relationship from the
epidemiologic studies has prevented the estimation of inhalation carcinogenic risk
(https://www. epa. gov/iris)."
There is also the lack of a national consensus on an acceptable level of risk. The current
context is the process used by the EPA as provided by the Clean Air Act to determine whether
more stringent controls are required in order to provide an ample margin of safety to protect
public health or to prevent an adverse environmental effect for industrial sources subject to the
maximum achievable control technology standards, such as benzene emissions from refineries.
The decision framework is a two-step process. The first step requires EPA to determine an
"acceptable" level of risk due to emissions from a source, which is generally no greater than
approximately 100 in a million. Additional factors are considered in the second step, the goal
of which is to maximize the number of people with risks less than 1 in a million due to
emissions from a source. The results of this statutory two-step process do not guarantee that
cancer risks from exposure to air toxics are less than 1 in a million; in some cases, the residual
risk determination could result in maximum individual cancer risks that are as high as
approximately 100 in a million. In a June 2008 decision, the U.S. Court of Appeals for the
District of Columbia Circuit upheld EPA's approach to addressing risk in its two-step decision
framework. Information is incomplete or unavailable to establish that even the largest of
highway projects would result in levels of risk greater than deemed acceptable
(https://www. cadc.uscourts. gov/internet/opinions. nsf/284E23 FFE079CD59852578000050C9D
A/$file/07-1053-1120274.pd�.
Because of the limitations in the methodologies for forecasting health impacts described, any
predicted difference in health impacts between alternatives is likely to be much smaller than the
uncertainties associated with predicting the impacts. Consequently, the results of such
12
assessments would not be useful to decision makers, who would need to weigh this information
against project benefits, such as reducing traffic congestion, accident rates, and fatalities plus
improved access for emergency response, that are better suited for quantitative analysis.
8.8. MSAT Conclusion
What is known about MSAT is still evolving. As the science progresses, FHWA will continue
to revise and update their guidance. FHWA is working with Stakeholders, EPA and others to
better understand the strengths and weaknesses of developing analysis tools and the
applicability on the project-level decision documentation process.
9. Construction Air Quality
Air quality impacts resulting from roadway construction activities are typically not a concern
when contractors utilize appropriate control measures. During construction of the proposed
project, all materials resulting from clearing and grubbing, demolition or other operations will
be removed from the project, burned or otherwise disposed of by the Contractor. Any burning
done will be done in accordance with applicable local laws and ordinances and regulations of
the North Carolina State Implementation Plan (SIP) for air quality in compliance with 15A
NCAC 2D.1903. Care will be taken to ensure burning will be done at the greatest distance
practical from dwellings and not when atmospheric conditions are such as to create a hazard to
the public. Operational agreements that reduce or redirect work or shift times to avoid
community exposures can have positive benefits. Burning will be performed under constant
surveillance.
During construction, measures will be taken to reduce the dust generated by construction, by
wet suppression or equivalent, when the control of dust is necessary for the protection and
comfort of motorists or area residents.
10. Summary
Vehicles are a major contributor to decreased air quality because they emit a variety of
pollutants into the air. Changing traffic patterns are a primary concern when determining the
impact of a new highway facility or the improvement of an existing highway facility. New
highways or the widening of existing highways increase localized levels of vehicle emissions,
but these increases could be offset due to increases in speeds from reductions in congestion and
because vehicle emissions will decrease in areas where traffic shifts to the new roadway.
Significant progress has been made in reducing criteria pollutant emissions from motor vehicles
and improving air quality, even as vehicle travel has increased rapidly.
The proposed project is located in Wake and Johnston Counties, which comply with the
NAAQS. The proposed project is located within an attainment area; therefore, 40 CFR Parts 51
and 93 are not applicable. Therefore, the project is not anticipated to create any adverse effects
on the air quality of this attainment area. This evaluation completes the assessment
requirements for air quality of the 1990 Clean Air Act Amendments and the NEPA process. No
additional reports are necessary.
13