03 MO Increment and Haul Road Questionnaire and Responses April2007 74f

7/29/2019 03 MO Increment and Haul Road Questionnaire and Responses April2007 74f

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Re: Increment and Haul Road Questionnaire

In the early part of 2007, the Missouri Department of Natural Resources Air Pollution

Control Program conducted a survey of other state regulatory agencies regarding HaulRoad and Increment standard modeling practices. We received responses from more than

half of the 50 states, and found that practices vary from state to state, regardless of

geographic location. We asked the following questions:

1. Does your State evaluate compliance with the increment standard(s) for minor source

permit applications?

2. Do you include fugitives in the modeling for minor source permits, i.e. haul roads andstorage piles?

3. If yes, what are the default source parameters that you use for haul roads (i.e. releaseheight, X & Y dimensions, and initial vertical dimension)?

4. How do you calculate the emission rate for both paved and unpaved haul roads?

5. What emission factor do you use in the haul road equation and where did you get this

information, i.e. AP-42, test data, etc?

6. What % control do you give for paving, washing, chemical, etc?

7. If you use AP-42’s paved haul road equation, do you have a default value that you

use for silt content?

The following state’s responses are in alphabetical order. This information comes frommany sources within state government. We would like to thank all of the states that

provided answers to our survey. This information is considered current as of April 2007,

however, as always, this information is subject to change. Contact list of individualrespondents follows the state responses. If you have any questions regarding this survey,

please contact me at the Air Pollution Control Program, P.O. Box 176, Jefferson City,

Missouri 65102 or you may telephone (573) 526-3835.

AIR POLLUTION CONTROL PROGRAM

Kyra L. Moore

Permits Section Chief (573) 526-3835



2

ALABAMA

1. Does your State evaluate compliance with the increment standard(s) for minorsource permit applications?

As a rule, NSR/PSD modeling is evaluated against the increments and NAAQS for major sources only. However, we reserve the right to evaluate any source’s impacts

at any time if there is a need.

2. Do you include fugitives in the modeling for minor source permits, i.e. haulroads and storage piles?

As a rule, we evaluate fugitive emissions based on two qualifiers; that the emissions

are process related and reliably quantifiable. Based on these criteria, we do not

typically model haul roads and storage piles. Once again, this modeling could andwill be required absent of these criteria on a case by case basis. (ex. Storage piles that

directly feed conveyor belts associated with process under review)

3. I f yes, what are the default source parameters that you use for haul roads (i.e.release height, X & Y dimensions, and initial vertical dimension)?

Some of the documents that we have looked at have been provided by the GeorgiaDept. of Environmental Protection and the North Carolina Dept. of Natural

Resources.


Please see response #3

5. What emission factor do you use in the haul road equation and where did youget this information, i.e. AP-42, test data, etc?

Please see response #3


No response given.

7. I f you use AP-42’s paved haul road equation, do you have a default value thatyou use for silt content?

No response given.



3

ALASKA

1. Does your State evaluate compliance with the increment standard(s) for minor

source permit applications?

In most cases, “no.” However, we do make them demonstrate compliance if they are

requesting to modify a permit condition that was previously established (basicallyunder our old regulations) to protect the increment.


Yes, if they’re substantive (case by case determination).

3.

I f yes, what are the default source parameters that you use for haul roads (i.e.release height, X & Y dimensions, and initial vertical dimension)?

Applicants may characterize haul roads as either volume sources or area sources. The

dimensions/heights are dependent on operation e.g., are they essentially using street-

legal trucks, or are they using “monster-size” dump trucks.


I think all of our haul roads are unpaved. I can’t think of any off the top of my head

that aren’t (most of our mines are in remote areas). We typically use AP-42.However, we recently approved an applicant’s request to use the “Wyoming Emission

Factors”


No response given.


They provide and justify their proposed control efficiency. Must also provide a dust

control plan which describes what they will do to control dust.


No. Silt content varies by location. They have to justify the value that they use. Soil

samples are very helpful.



4

ARKANSAS1. Does your State evaluate compliance with the increment standard(s) for minor

source permit applications?

Not usually, though we have at least once raised the issue in a non-PSD permit

application (that was later withdrawn).


For anything at or above Title V levels we do. Occasionally we will also do it for a

non-Title V source if there is reason, such a public concern over the facilitiesemissions.

3. If yes, what are the default source parameters that you use for haul roads (i.e.release height, X & Y dimensions, and initial vertical dimension)?

There is some stuff on the TNRCC site we have used, but we have no set policy or

guidance.


AP-42


AP-42


80-95% but we have not been consistent.


No, we have made one facility actually do a test.



5

COLORADO


No. Colorado’s modeling guideline states:“For minor sources and minor modifications, a compliance demonstration with the

Prevention of Significant Deterioration (PSD) increments is not required to obtain a

construction permit. A preliminary opinion in June 1998 from the Colorado AttorneyGeneral’s office suggests that rulemaking would be necessary before compliance with

PSD increments could be a permit issuance criterion for minor sources and minor

modifications. Therefore, increment consumption from minor source growth isassessed only during the modeling process for new sources and modifications subject

to PSD rules and during periodic increment studies. Nevertheless, since all sources,

including minor sources, can consume PSD increment in areas where the PSD minor source baseline date has been triggered, new minor sources and minor modifications

are encouraged to voluntarily demonstrate compliance with applicable increments.”


Yes.


Colorado does not have specific guidance for haul road modeling. Each approach isevaluated on a case-by-case basis. Below are two methods previously approved for

permit modeling in Colorado:

METHOD 1:

If using volume sources for the haul road:

1. Initial sigma y = (Width of haul road + 64% of haul road width)/4.3

2. Initial sigma z =(1.7 x height of haul truck in meters)/ 2.153. Release height = (1.7 x height of haul truck in meters)/ 2

4. Volume Source Locations = Series of volume sources centered on the haul road

centerline, spaced (Width of haul road + 64% of haul road width)/2.15 apart.

If using area sources for the haul road:

1. Adjusted haul road width = Width of haul road + 64% of haul road width2. Initial sigma z =(1.7 x height of haul truck in meters)/ 2.15

3. Release height = (1.7 x height of haul truck in meters)/ 2

4. Location = Area source centered on coordinates of the actual haul road.

Reference: ANALYSIS OF HAUL ROAD EMISSION TEST DATA FOR

DETERMINING



6

DISPERSION MODELING PARAMETERS. Trinity Consultants. NSSGA ESH

Forum. August 15, 2003.

METHOD 2:Use volume sources with a release height of 2 m and an initial vertical dispersion

term ( zo) of 3 m.

“A release height of 2 m approximates the level in the dust plume that equally divides

the mass flux. The 1992 source testing program (Muleski et al., 1994) found that themaximum particulate matter concentration in the profiled haul road dust plumes

typically occurred at a height of approximately 1.5 m. However, the mass flux (i.e.,

the product of concentration and wind speed) occurred at a height of approximately 2m.”

“The initial vertical dispersion (zo) of 3 m was estimated using guidance contained inthe ISC2 user's guide. The guide suggests setting zo equal to the height of the source

divided by 2.15. The 1992 source testing program (Muleski et al., 1994) found 7 m to be a reasonable estimate of the height of haul road emission plumes at a distance of 5

m downwind from the edge of the road.”

Reference: USEPA study "Modeling Fugitive Dust Impacts from surface Coal

Mining Operations - Phase II: Model Evaluation Protocol, October 25, 1994.


No response given.


No response given.


No response given.


No response given.



7

GEORGIA


No. It is GA EPD’s policy to require increment inventorying of PSD –major sourcesonly.


GA EPD has a policy of requiring only crushed stone quarries to model (for NAAQSPM10) as minor sources. No other minor source is required to model fugitive sources

such as haul roads and storage piles. The remainder of your questions are perhaps

best answered “in context”. For that reason, I am enclosing a copy of GA EPD’squarry modeling guideline. It is red-lined as it is in revision, however that form does

not appear to affect the answers to your particular questions. Please contact PeteCourtney at GA EPD, 404-363-7095, [email protected] for more info.


Please visit Georgia’s website for more information. Reference GA EPD’s quarry

modeling guideline.



modeling guideline.


Please visit Georgia’s website for more information. Reference GA EPD’s quarrymodeling guideline.



modeling guideline.



modeling guideline.



8

IDAHO


Idaho does not currently evaluate PSD increment consumption within the context of minor source permit issuance.


Idaho does not typically include haul roads and storage piles in the modelingdemonstration for minor sources. However, we do include emissions from

miscellaneous material handling operations and “fugitive” sources such as crushers,

screens, etc.

3.


The release parameters would depend on the type of vehicle traffic to some degree. A

typical release height might be 1-2 meters. We would divide the road into rectangular

segments and establish the initial dispersion coefficients according to guidance in theISC users guide.


We would likely use AP42 factors and the guidance given within the AP42 section.


Typically we use the AP42 data. We usually do not have site specific data.


If facility roads were paved we would often consider emissions to be negligible

unless it was a PSD permit. The effectiveness for water application would depend onthe frequency. For aggressive control we would use 90 to 95 percent. Chemical

suppression would have the same control efficiency, but a less frequent application

rate.


We don’t have a default silt content.



9

ILLINOIS


Normally, Illinois EPA doesn’t require an air quality analysis to accompany a minor source permit application but reserves the right to request an air quality analysis if the

applicant emits lead or air toxics at appreciable levels, or generates interest and

concern with the public. Also, if the source’s emission points are perceived to have poor dispersion characteristics, modeling may also be required.


We don’t exclude modeling these sources if we request modeling for a minor source,though these modeling involving a minor source with hauls roads and storage piles

have never come up with a minor source permit application. For major sources,modeling of haul roads, storage piles, and other fugitive processes is required.


Actually, that would depend on the operations. Normally, Illinois EPA advises

environmental consultants to model roads as volume sources except when located

close to other fugitive processes where emissions can be easily merged into areasource boxes. Release heights for the volume sources would correspond to the

wheel height of typical vehicles traveling the road. X and Y dimensions for a volumesource would correspond to the actual width of the road and the total number of

volume sources would extend to the length of the road.


Illinois EPA advises environmental consultants that AP42 be used to determine the

emissions for paved and unpaved hauls roads.


See the above answer.


It is up to the permit applicant to suggest what kind of a fugitive source control planthat they are willing to live with. Control efficiencies can go as high as 90%,

however, the applicant must submit an aggressive fugitive dust control plan to be

incorporated into the permit.



10

ILLINOIS Cont.


Illinois EPA generally accepts defaults or typical silt content expected from that particular industry, for its roads. Granted, the ranges can be wide and the proposed

operation does not have the benefit of knowing ahead of time what the silt content

will be exactly, so often, this value is difficult to derive. All the more reason whyIllinois EPA insists on aggressive fugitive dust control plans regardless of the amount

of control.



11

IOWA


The Iowa DNR currently tracks the minor source baseline date and the source thattriggered it for each of the 60 PM-10 baseline areas in the state (this is not necessary

for NO2 and SO2 since the minor source baseline date and area is statewide). To date,

21 of the 60 PM-10 baseline areas in the state have been triggered. The boundary of each minor source PM-10 baseline area has also been plotted in GIS to facilitate the

development of increment modeling inventories and to check whether un-triggered

areas are triggered when a complete PSD application is received.

While these tools allow the Iowa DNR to determine increment consumption or

expansion in the vicinity of the source that is going through a PSD review, they donot allow for continuous tracking of increment consumption or expansion in the

vicinity of each source located in each baseline area. Reasons for not trackingincrement include the difficulty in obtaining historical emissions inventory data, a

lack of guidance, and a lack of resources.


The current Iowa DNR modeling guidelines allow for fugitive emissions from haul

roads and material piles to be omitted form minor source modeling. In instanceswhere the minor source is located near a sensitive receptor or complaints indicate that

additional control of the haul road emissions may be necessary, modeling will be usedto further refine the best management practices to ensure that the PM-10 NAAQS is

not exceeded.

The currently approved model for evaluating predicted concentrations has been

shown to over-predict concentrations from haul roads. It is also costly and time

consuming for a minor source facility to obtain the site specific parameters required

for determining accurate emissions from its haul roads. Additionally, haul roademissions are only a concern at a small subset of minor sources where the haul roads

are used on a regular basis and may have a high volume of traffic. The emissions

from haul roads at minor sources with infrequent, low volume haul road traffic areconsidered to be accounted for in the PM-10 background values.


Iowa DNR does not have default source parameters for characterizing predicted haulroad impacts




12

The haul road emissions are generally calculated or reviewed on a case-by-case basis by the construction permitting staff using AP-42 emission factors.

5. What emission factor do you use in the haul road equation and where did you

get this information, i.e. AP-42, test data, etc?

See number 4 above.


Percent control is determined case-by-case using AP-42 and the Air PollutionEngineering Manual.


See number 4 above.



13

LOUISIANA


No.


Yes.


Height 1m, Diameter 1m, Velocity 0.001m, Temperature is 0 Kelvin. The source is

given a default location in the center of the facility.


We use the methods set forth in AP-42, Chapter 13.2.


We use the emission factor that is calculated as a result of using AP-42, Chapter

13.2.2.


It is assumed that the particulate control efficiency due to paving is inherent in the

equations set forth in AP-42, Chapter 13.2.1. Unless additional control measures are

utilized, no additional control efficiency is taken into account.

Regarding other control methods, we allow the applicant to propose a reasonable

control efficiency. We judge the efficiencies on a case-by-case basis.


No. We ask the applicant to supply all such data. Usually the most representative

mean silt loading value from AP-42 Table 13.2.1-4 is selected.



14

MASSACHUSETTS


No, since air quality levels continue to drop we assume that minor source growth isnot consuming increment


No, generally not. We do require applicants to minimize nuisance conditions fromsuch activities


No response given.


No response given.


No response given.


No response given.


No response given.



15

MICHIGAN


YES


NO FOR ROADS; SOMETIMES FOR PILES DEPENDING ON PROCESS


N/A


N/A


N/A


N/A


N/A



16

MINNESOTA


We have treated minor source increment modeling on a case-by-case basis, but arecurrently working on minor source modeling guidance that will make the process

more predictable and transparent.


Yes. Fugitive PM10 emissions are typically included in all refined modeling

analyses. We do allow some short-cuts for non-PSD projects. Please see our

modeling guidance for examples:http://www.pca.state.mn.us/air/modeling.html#guidance.


We recommend volume sources for representing haul road fugitives.

Height of volume source = 1.7 * vehicle heightRelease Height = Height of volume source / 2

Initial Sigma-Z = Height of volume source / 2.15

Initial Sigma-Y = Volume Source spacing / 2.15(spacing ~ 10 m for 1 lane each way, ~ 20 m for 2 lanes each way, ~ 25 m for 3 lanes

each way, etc.)


AP-42 equations, often with on-site silt loading testing. Some facilities have

conducted additional exposure profiling testing and calculated site-specific emission

rates (see: http://www.pca.state.mn.us/publications/presentations/aermod-

pm1006.pdf . Warning – large file).

We ask for maximum daily traffic counts for 24-hour PM10 modeling.


As mentioned above, AP-42 equations with some on-site testing.




17

We do not have standard control efficiencies. Some companies have tested pre- and

post-cleaning to determine the effects and help us determine the necessary frequencyand extent of cleaning.

7. I f you use AP-42’s paved haul road equation, do you have a default value that

you use for silt content?

Default = 10 g/m2 unless there is testing or other evidence to suggest a lower value.



18

MISSISSIPPI


Modeled all sources in the past. Currently do so for sources with public interest, etc..


Yes. Follow Texas guidance.


No response.


No response.


No response.


No response.


No response.



19

MISSOURI


Yes


Yes


Zero (0) for release height, X and Y are a 10:1 ratio based on width of traffic lane and

length of road (Also limited to the number of lanes that traffic passes over one road,i.e. staging areas), and the initial vertical is 1.3953.


Unpaved haul road equation w/95% for paving and washing. Another way is throughuse of the silt content, however this requires testing.


AP-42. Can use test data if approved by a permit engineer.


90-95%


Silt Content %Defaults Surface Material Range Mean Stone Quarry Haul Road-Pit 5.0 to 15 8.3Stone Quarry Plant Road 2.4 to 16 10.0Paved Road Default 8.3Sand & Gravel Plant Road 4.1 to 6.0 4.8Rural Road Gravel 5.0 to 13 6.4Rural Road Dirt 0.83 to 68 11.0



20

MONTANA


Montana only evaluates increment compliance in areas where the minor source baseline date has been triggered. We evaluate NAAQS (and MAAQS) compliance

for all permits, although modeling is only required for sources with PTE over 50 tpy,

sources in or near a non-attainment area, or in cases where we feel there could be a problem.


If modeling is required, we do model fugitive emissions. We usually treat the haulroads as a series of area or volume sources, material handling operations as a single

large volume source, and large piles as individual volume sources. With AERMOD,we avoid using area sources.


We don’t have ‘default’ values per se. If modeling is required, the applicant submits

the modeling and we are open to most modeling decisions, within reason. The

following are typical modeling parameters for fugitive volume sources:

• Haul road segments, as many as needed for length: Release height is usually 3 – 10 meters depending on vehicle height. σyo is typically total roadway width

divided by 2.15.σ

zo is the release height divided by 2.15, or ½ of the releaseheight, divided by 2.15.

• Typical sand or gravel crusher/screen operation with conveyor belts: Releaseheight of 10 meters, σyo equal to 100 feet divided by 2.15 (7.09 m), and σzo of 5

meters divided by 2.15 (2.32 m).

• Large aggregate storage piles: Release height is usually top-of-pile height, σyo is

pile width divided by 2.15. σzo is somewhat arbitrary, often 5 meters divided by2.15 (2.32 m).


Each permitter calculates emissions on a case-by-case basis; however, AP-42, Fire,and site-specific data are most often used.


See above.



21


See above.



We do not.



22

NEVADA


First, some background. Nevada’s planning areas (CAA 107(d) areas) are based onhydrologic basin boundary mapping. The boundaries of these basins typically follow

topographic ridge lines. This process was setup in our late 1970’s SIP submissions.

There are more than 250 planning areas in Nevada, but less than 30 areas aretriggered for one or more PSD increments. A map of these areas can be viewed at

http://ndep.nv.gov/BAQP/westar_psd_trigger_areas.pdf. Only 5 of these areas (those

with the most heavy recent industrial activity) have been completely analyzed for increment consumption. Nevada has developed an increment tracking system (ITS)

to continue to manage these areas. AERMOD is currently used to determine

cumulative increment impacts. The remaining increment triggered areas have not been analyzed for increment consumption. However, Nevada is in the process of

establishing baseline emission inventories for most of these remaining areas. Allminor sources area reviewed for increment compliance in some form. In the 5

increment tracked areas, a full cumulative increment analysis is performed prior toissuance of the minor source’s permit. In the remaining unanalyzed increment areas,

the minor source’s impact alone is compared to the increment standard for

compliance.


In the increment tracked areas, fugitive emissions are included, generally, throughoutthe entire planning area and are modeled as 1 km square grids. However, since the

fugitive emission are included as area sources, a specific facility fugitive inventory is

not considered. In the remaining unanalyzed increment areas, only the facility’s process emissions are included in the increment consumption analysis. When a

triggered basin becomes managed for increment in the ITS, a basin-wide fugitive

inventory will be considered in the cumulative effect analysis.


The following is an excerpt from an area source PM AERMOD model input file:

** AREA SOURCE I NFORMTI ON **

** l ocat i on SRCI D SRCTYPE X- LOC Y- LOC El ev **

** srcpar am SRCI D areami s r el ht x- i ni t y-i ni t angl e Szi ni t **

SO LOCATI ON 83- I I 6 AREA 273000. 00 4357000. 00 1960. 88SO SRCPARAM 83- I I 6 1. 57E- 08 10. 00 1000. 00 1000. 00 0. 00 4. 65

SO LOCATI ON 83- HH4 AREA 271000. 00 4358000. 00 2102. 62SO SRCPARAM 83-HH4 5. 74E- 08 10. 00 1000. 00 1000. 00 0. 00 4. 65



23


Generally, for increment consumption analyses in the ITS, much of the inventory is

taken from the NEI. So, specific emission calculations are not performed.


For the PSD permitting process, most emission calculations are based on AP-42.


It is somewhat variable and depends on the specifics of the circumstance.



No, different areas of Nevada have different silt characteristics.



24

NEW HAMPSHIRE


Yes, New Hampshire models all new and modified (after baseline) minor sources for Class II increment.


The only fugitive sources we have modeled for increment consumption are storage piles. Road emissions are not modeled. For individual sources with roadway traffic,

such as asphalt plants, we ask that they use best management practices to minimize

fugitive dust emissions.

3.


NA


Since we don’t permit or model these types of sources we don’t normally have the

need to calculate emissions.


NA


NA


NA



25

NEW J ERSEY


Yes


Yes, when they can be quantified.


We model haul roads volume sources, usually assuming 4.0 meters as the initial

vertical dimension and 2 meters as the midpoint in the vertical release. Therefore, aninitial sigma z of 1.9 meters input. The horizontal dimension of the volume will

correspond to the width of the road; there is no default value.


Using AP-42 emission factors.


See above.


For paving, we just use the paved road emission factor instead of the unpaved road

factor. We have never had washing submitted as a control. For application of water or

chemicals, we give from 50 - 90 percent depending on the frequency and amount of application and whether it is water or chemical dust suppressant.


No



26

NEW MEXICO


If a proposed minor source is located in the area where PSD minor source baselinedate has been established, the NMED Air Quality Bureau (AQB) evaluates

compliance with PSD increment standards for the minor source permit.


The NMED AQB includes fugitive emissions such as haul roads, storage piles, and

aggregate handling in modeling analysis.

3. I f yes, what are the default source parameters that you use for haul roads (i.e.

release height, X & Y dimensions, and initial vertical dimension)?

The modeling parameters of release height, sigma y, sigma z, and number of haulroad segment modeled as a volume source are calculated with the values of the actual

width and length of haul road and the height of vehicles. The NEMD AQB modeling

guideline available online provides information as to how to calculate such modeling parameters.


The NMED Air quality Bureau uses AP-42 Sections 13.2.1 and 13.2.2 to calculateemissions from paved and unpaved haul roads respectively. However, on haul roads

that experience high silt loading (crushing plants) the department uses AP-42 Section

13.2.2 with a percent control associated with watering or basecourse (60%), water and basecourse (80%), surfactant/chemicals (90%), and paved and swept (95%).


See answer to #4


See answer to #4. No % control credit is given to emissions from paved haul roadscalculated using AP-42 Section 13.2.1.




27

The Department uses default silt loading of 4.8%. The applicant may provide the

actual silt loading for their site, but the Department usually requires monitoringrecord-keeping and reporting requirements to show ongoing compliance.



28

NEW YORK


In general, PSD increment consumption modeling is confined to major sources, but ininstances where a modeled demonstration of standards compliance is required for

minor sources, the source impacts are also assured to be below the PSD increments.

However, this minor source PSD assessment is confined to the source under reviewand not in terms of a cumulative PSD source analysis, which could consider all

sources since the baseline dates which consume increment. For mobile sources, the

assessment assumes that ongoing controls since the baseline dates in the 1970s and80s have resulted in reduced emissions and more likely to an increment expansion. In

addition, PSD increment calculations are to exclude direct emissions from mobile

sources controlled under Title I of the Act.

2.

Do you include fugitives in the modeling for minor source permits, i.e. haulroads and storage piles?

If the fugitives are quantifiable, then these are included in the analysis. For example,

the emissions created by trucks at a landfill and from storage piles at processing

plants are addressed to the extent that these contribute to a standards compliancedemonstration. These explicit assessments are limited to the operations phase,

however, and not to an intermittent and short-term construction phase.


There are no set “default” values used, except that modeling guidance (e.g. Table 1-6

of the ISC3 model) is used to define initial dispersion when these are represented byeither contiguous volume sources or area sources. The source height is represented

by the physical height of release. For a line source created by mobile sources on the

road, we would ask the applicant to use CAL3QHC or CAL3QHCR.


By “haul roads”, we take it that you mean the roads into and out of industrialfacilities, as exemplified in Table 13.2.1-4 of AP-42 for paved roads, or Table 13.2.2-

1 of AP-42 for unpaved roads. We would ask the applicant to use the appropriate

mean values presented in those tables.


We would ask the applicant to use the appropriate mean values presented in the AP-

42 tables. Despite our concerns over the aptness of the AP-42 approach and the



29

general sense that it overestimates road dust, we are, for the present, limited to AP-42

as the only available tool.


Typically, we use a 50% discount for mitigating measures.


We would not use “silt content” in paved road estimates, only the mean “silt loading”

given in the last column in Table 13.2.1-4 of AP-42 for paved roads for the facilitytype named in the first column.

Note: The New York State Department of Environmental Conservation is skeptical of the utility of the entire AP-42 approach to road dust estimates. We have had recent

correspondence (available upon request) with EPA on this subject. Walt Pienta ( 518-402-8396; [email protected] ) has been our lead on this issue.



30

NORTH CAROLINA


Yes if the county they are in has been triggered for the pollutant of concern.


Yes!


Depends on the type of facility; e.g., quarry, concrete batch plant, asphalt plant, etc..


Separately, based on equations in AP-42.


Tables given in AP-42


Not sure - see comment below.


No - we use the tables provided in AP-42.

NOTE: our modelers will work with the permitting engineers to establish the

appropriate emission factors and source emissions using the equations andappropriate variable values as defined in AP-42 based on the type of facility

operations. Where available and when approved by our permitting staff, we will use

site-specific test data.



31

OKLAHOMA


No. We require any source that increases their emissions by 100 TPY to modelcompliance with the NAAQS for that pollutant but since there is no mechanism to

require compliance with the increment for those sources, we generally do not look at

increment. However, if a new facility in modeling compliance with the NAAQSshows that they are in violation of the increment by themselves, we may ask them to

reduce their impacts so that there is no increment violation. In the past, this has not

always been the case and AQD may have looked the other way even if there was anindication that there was a problem with the increment.


Yes and No. We generally require modeling of haul roads and storage piles for major

sources (PSD) and for facilities that increase emissions by 100 TPY or more of PM.


We generally follow Texas guidance on the subject. Release height ~ vehicle height;

x dimension ~ determined by dividing the length of road by the y dimension; ydimension ~ width of road plus 6 m.


We do not require a certain calculation for paved/unpaved roads. We allow theapplicant to determine the most accurate calculation and provide those emissions to

us since there is little confidence in AP-42 emission factors. However, I have not had

the time to evaluate the most recent updates to AP-42.


The applicant should use the best available data to calculate emissions.



7. If you use AP-42’s paved haul road equation, do you have a default value thatyou use for silt content?




32

All of these calculations are left up to the applicant. As far as verifying the emissioncalculations goes, we are dependent upon the permit writers to verify emission

calculations. Even though I am pretty sure that they accept any reasonable

calculation.



33

OREGON


Whenever the annual emissions (over the netting basis) of any source are greater or equal to the defined significant emission rate, modeling is required. If the source

impact is greater or equal to the significant impact level, they must demonstrate

compliance with the NAAQS and PSD Increment thresholds.


Generally, any emission source (point or fugitive) quantified in the plant-site detail

sheet is included in the modeling analysis. However, if the emission source (point or fugitive) is deemed insignificant by the permit engineer, it can be omitted upon

department approval.


Use area source procedures. Width of source equal to road width. Length of sourceno longer than 10 times the width. Release height equal to ½ truck height. Initial

sigma Z calculated by dividing the full truck height in meters by 2.15.


AP-42 procedures using vehicle miles traveled.


AP-42 procedures


Up to permit engineer


No, up to permit engineer. Sometimes testing is required.



34

TEXAS


No.


We do not request modeling for haul roads if the applicant will use best management

practices (conditions placed in the permit) to control emissions. We have modeledindividual storage piles primarily for nuisance conditions. We’ve have found that

contributions from storage piles are small compared to other activities/facilities at a

site. We do not quantify road emissions as a permit allowable. We do quantifyannual stockpile emissions; not hourly.


http://www.tceq.state.tx.us/assets/public/permitting/air/Guidance/NewSourceReview/rg25.pdf


If we were to calculate road emissions we would refer to the appropriate equation

provided by EPA in AP-42.


The emission factor would be determined through the AP-42 road equation

calculations. We do not have specific test data, nor separate emission factors for roads.


In the past, we had attempted to apply certain control efficiencies to paved or

unpaved surfaces. These control efficiencies may have come from literature searches.Today, we would look to AP-42 for suggested control methods and efficiencies (if

any listed) as determined through EPA evaluations/tests.




35

Texas requires you have an air quality authorization prior to construction and

operation. Therefore, specific site conditions, i.e., silt content or silt loading data, aretypically not available. We would normally revert to a listed default value in AP-42

using one closely aligned with the process being permitted.



36

UTAH


No


Yes


Height of vehicle, width of vehicle + 6m, height of vehicle


All emission rates are calculated using the most current versions of AP42 for paved

and unpaved haul roads.


As stated above, we use the most current versions of AP42.

Unpaved Haul Roads AP42 Section 13.2.2 Equation #1a E = k (s/12)^a *(W/3)^b

Paved Haul Roads AP42 Section 13.2.1 Equation #(1) E= k(sL/2)^0.65 * (W/3)^ 1.5-C

Note: We recommend that on-site silt load and silt content testing be performed.

Otherwise we use the AP42 default values.


Currently we do not give a control % for paving. If you look at the AP42 equation,

taking the on-site silt loading before and after control for a paved road determines thecontrol efficiency. So the sL is the control %.

7. If you use AP-42’s paved haul road equation, do you have a default value thatyou use for silt content?

No default is used other than those specified in the AP42 tables of 13.2.1 & 13.2.2.



37

VIRGINIA


No.


These would only be modeled for PSD sources or if there is some controversy aroundthe facility.


Visit website for our guidance document.


N/A


AP-42


No response.


No Response



38

WEST VIRGINIA


WV typically does not require modeling for minor source permit applications.However, compliance with the increment standard(s) is ensured through various rules

and regulations as identified in approved State Implementation Plans (SIPs).


WV does not routinely require modeling for minor source permit applications.


Since WV does not routinely model haul roads no default source parameters exist.

WV would examine haul roads on a case-by-case basis to determine source parameters in the event haul roads would need to be modeled.


AP-42 emission factors are used for both paved and unpaved haul roads.


Please see attached spreadsheet, which is available on WV DEP’s website at

http://www.wvdep.org/item.cfm?ssid=8.


For a water truck with chemical solution, 85%. For a water truck with water spray,70%.


Silt content is only used in unpaved equation (10%). Paved equation uses roadsurface silt loading (70g/ft

2).



39

WISCONSIN


Wisconsin DNR models minor source applications against increment standards,

where applicable (i.e. baseline previously set).


Wisconsin does not model fugitive dust for minor source permits, unless there is

significant concern and management intervention. We will model other types of

fugitive emissions such as building heaters and/or indoor releases that can be lost tothe atmosphere.


When modeling fugitive dust for PSD review, we generally model haul roads as a

series of volume sources with 1.0 meter height, and a sigma-z equivalent to the sizeof the truck tire. Sigma-y is generally set according to the ISCST3 and AERMOD

guidance for line sources.


Generally the applicant provides this information and they typically use AP-42

emission factors with estimates of their truck weights and amount of travel, modified

by controls such as application of water or other chemicals.


Generally, AP-42 emission factors are used, with representative parameters for silt

content.


In most cases, 50-75% control is allowed for “standard” water application. If thesource provides a detailed plan on when and how watering/chemicals will be used,

our permit engineers have allowed up to 90% control to be factored into the emission

calculation.




40

Wisconsin DNR does not have a default value for silt content, but leaves it up to the

applicant to propose a value. Our regional offices are then asked to confirm/denythese values.



41

WYOMING


Yes.


Yes, if the fugitive emissions are associated with coal mine operations or if fugitiveemissions are a large part of the emissions inventory for a source, (i.e., a gravel

quarry with crushing operations).


When modeling coal mines, we typically use a release height for the haul roads in acoal mine of 10 meters; considering the size of the haul trucks (i.e., height of the

exhaust stack, plume rise off the stack, 30 foot diameter tires, ... X and Y dimensions

are based on the width of the haul road, typically 10-30 meters, and the length istypically 100-300 meters, (10:1 aspect ratio), initial vertical dimension = 0 (typically).


AP-42 and State of Wyoming Division-specific emission factors for haul roads, wew

typically use a 50% control factor based on use of watering trucks on the haul roads,

sometimes scoria or mag chloride is used, which increases the control efficiency.


AP-42 and State of Wyoming Division-specific emission factors for coal and

overburden haul roads - based on many years of experience in dealing with thesetypes of sources, and coal mine personnel's experience. Emissions = [EF x (1-control

effcieincy (%)) x PM10/TSP ratio for particulate matter. Slightly different

calculation for NOx emissions.


Paved roads = 90-100%, water truck in use = 50%, mag chloride and chemical dustsuppressants used in addition to water trucks tends to be around 60-70%.

7. I f you use AP-42’s paved haul road equation, do you have a default value thatyou use for silt content?Road surface silt content value for coal and overburden haul roads, and water truck

emissions are typiaclly based on a silt loading of 8.6 %.



42

CONTACTS:

All of the data within this survey was derived from the comments and statements

made by the following people or their peers. For more information on an individual

state’s rules, please contact them directly. The email information provided below is

up-to-date as of 4/10/2007.

AL ABAMA: Leigh Barb Bacon, [email protected]

AL ASKA: Alan Schuler, [email protected]

ARKANSAS: Thomas Rheaume, [email protected]

COLORADO: Chuck Machovec, [email protected]

GEORGIA: Peter Courtney,[email protected]

IDAHO: Kevin Schilling, [email protected]

ILLINOIS: Matt Will,[email protected]

IOWA: Lori Hanson,[email protected]

LOUISIANA: Dustin Duhon,[email protected]

MASSACHUSETTS: Stephen Dennis, [email protected]

MICHIGAN: J ames G. Haywood, [email protected]

MINNESOTA: Christopher Nelson,[email protected] Dennis Becker, [email protected]

MISSISSIPPI: Bruce Ferguson, [email protected]

MISSOURI: Dawn Froning, [email protected] Kelly Robson, [email protected] Lance Horn, [email protected]

MONTANA: Carson Coate, [email protected]

NEVADA: Greg Remer, [email protected]

NEW HAMPSHIRE: J im Black, [email protected]

NEW J ERSEY: Alan Dresser, [email protected]



CONTACTS Continued

NEW MEXICO: Gi-Dong Kim, [email protected]

NEW YORK: Leon Sedefian, [email protected]

NORTH CAROLINA: J im Roller, [email protected]

OKLAHOMA: Eric Milligan, [email protected]

OREGON: Mark Bailey, [email protected]

TEXAS: Dom Ruggeri, [email protected]

UTAH: Tom Orth, [email protected]

VIRGINIA: Mike Kiss, [email protected]

WEST VIRGINIA: J on McClung, [email protected]

WISCONSIN: J ohn A. Roth, [email protected]

WYOMING: Ken Rairigh, [email protected]

The Missouri Department of Natural Resources Air Pollution Program thankseveryone for their time and efforts during this survey.

03 MO Increment and Haul Road Questionnaire and Responses April2007 74f

Documents

Transcript of 03 MO Increment and Haul Road Questionnaire and Responses April2007 74f