The Magazine for Environmental Managers August 2020

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Back In Time: A&WMA’s Annual Critical Review Turns 502002 Annual Critical Review:Visibility: Science and Regulationby John G. Watson

Air Toxics Across the United Statesby Teresa Raine

In recent years, air pollution regulators have started to see a shift in more public attention on air toxics—those gases,aerosols or particulates that can potentially result in serioushealth concerns or damage to the environment under specific concentrations and/or exposures. With increased public interest, different areas and regions are responding in different ways, resulting in a patchwork of air thresholds and permitting requirements. This issue looks at the changingview of air toxics, and how regulations and guidance are addressing growing public attention across the United States.

Features

The Changing View of Air Toxics on the West Coast of the United Statesby Grace Lee, Megan Moreen, Rodrigo Gonzalez-Abraham, and Monica Wright

Composting Solutions for Rural Municipalities inLebanon: Low Tech, Low Cost, and Locally Integratedby Antoine Abou Moussa

DepartmentsMessage from the President: Changing Views on Air Toxics …and Everything Elseby Kim Marcus

Summary of Air Toxics Permitting and HealthRisk Assessment in New York and New Jerseyby Josh Hemperly, David T. Murtha, Tracey A. Karatas, and Toby Hanna

Waste Management CornerIn this month’s article, Antoine Abou Moussa discusses composting solutions in Lebanon.

ColumnsYP Perspective: Global Disease and Air Quality in a Changing Climateby Kim Frauhammer

Through the lens of the current global pandemic, a look at some of the existing challenges, such asenvironmental degradation, decreasing air quality,and climate change, that continue to put the humanpopulation at risk.

em • The Magazine for Environmental Managers • A&WMA • August 2020

Table of Contents


Cover Story by Melanie L. SattlerMessage from the President

I suspect that your summer so far has been differentfrom past summers. The world is focused on a differentform of air toxic (COVID-19) than what we—environmen-tal managers—are accustom to and which cannot be regulated or controlled very easily. As we continue to grapple with the global pandemic, much of the world isalso focused on the intersecting topics of diversity, equity,and inclusion, and reweaving the fabric of our society intoa more positive and respectful tapestry.

This month’s EM focuses on compliance and regulationsaround the “old-fashioned” meaning of air toxics, with articles looking at how different U.S. states and regions areresponding to the changing views on air toxics in differentways, resulting in a patchwork of rules and guidance related to gases, particulates, and aerosols.

Many rules have been instituted or are in the pipeline tobe so. They span an array of topics and industries, includ-ing Integrated Iron and Steel Risk and Technology Review(RTR); Miscellaneous Organic NESHAP RTR; Miscella-neous Coating Manufacturing; Taconite Iron Ore Process-ing; Iron and Steel Foundries; Plywood and CompositeWood Products; Lime Manufacturing; and Rubber Manufacturing.

Alongside these regulatory changes, engineers, chemists,scientists, parents—people from all walks of life—have said that the changes we are adopting as a result of thepandemic are going to have a substantial impact on howwe communicate, travel, meet, go to school, and work

together moving forward. Online communication, amedium that seemed to belong exclusively to the youngergenerations, has now been adopted by nearly everyone.Perhaps not fully, but at least functionally. Certainly,A&WMA embraced—and succeeded at—using virtual platforms in developing, managing, and sharing contentand programming for this year’s ACE. Of course, face-to-face events will resume when prudent to do so becausethere is no digital replacement for in-person networkingand relationship-building. And let me assure you thatA&WMA has a packed and robust events calendar(https://www.awma.org/calendar_list.asp) planned for the remainder of the year.

The Association also promotes mentoring. Two-way men-toring is important during these critical times. For instance,I help my company staff work through strategies or approaches and they help me with message delivery, datamanagement, and visualization. Data presentation is somuch more sophisticated and visual now with all the greatsoftware available. Plumes can be monitored, mapped, and assessed in real time. Technological advances enableaudits, due diligence, stack emissions, and many otherfunctions to be performed or shared by onsite staff usingtablets with an internet connection. Tablets provide arecord of activities and enable real-time support, savinglabor and the cost of airplane trips, hotel stays, and meals.

I encourage you to reach out to one of the AssociationCouncils (http://www.awma.org/governance) to find amentor or to offer your mentoring services. em

Kim Marcus » [email protected]

Changing Views on Air Toxics … and Everything Else

Be sure to visit www.awma.orgregularly for the latest importantinformation from A&WMA.

In recent years, air pollution regulators have started to see a shift in more public at-tention on air toxics—those gases, aerosols or particulates that can potentially result inserious health concerns or damage to the environment under specific concentrationsand/or exposures. With increased public interest, different areas and regions are re-sponding in different ways, resulting in a patchwork of air thresholds and permittingrequirements. This issue looks at the changing view of air toxics, and how regulationsand guidance are addressing growing public attention.

Air ToxicsAcross the United States


Cover Story by Teresa Raine


Cover Story by Teresa Raine

How toxic air pollutants are regulated, or even defined, is along and winding road globally that can, and has, varied bycountry, state, or province. Requirements can be a “nuisance”standard with few specifics, a permit requirement with man-agement practices, or a robust regional regulation requiringongoing monitoring and air dispersion modeling to demon-strate compliance with established standards. In recent years,public interest in air toxics in the United States has grown,leading states to refine or revise local regulations. In theseunique times, global interest in the impacts of air quality andrespiratory health are understandability high.

Within the United States, separate from the defined “criteriapollutants—carbon monoxide, nitrogen dioxide, ozone, partic-ulate matter, sulfur dioxide, and lead—a specific portion of airtoxics, or hazardous air pollutants (HAPs), are also regulatedunder the U.S. Clean Air Act (CAA), and a subgroup of 30HAPs are further monitored and regulated as urban air toxics.Federally, HAPs are generally regulated, mitigated, and con-trolled through source and sector specific standards containedin the National Emissions Standards for Hazardous Air Pollu-tants (NESHAP), New Source Performance Standards (NSPS),and for major source of HAPs, through Maximum AchievableControl Technology (MACT) requirements.

Even as these federal regulations continue to be updated andredefined, individual U.S. states, which have additional stricterair toxic requirements, are considering and changing theirviews and regulations for statewide air toxics programs, guid-ance, and regulations. State regulations range from a straight-

forward reference of federal HAP standards, to robust permit-ting programs requiring the tracking and regulation of hun-dreds of additional air toxics, air toxics dispersion modelingand/or monitoring, and state permitting requirements. Thispatchwork of regulations can present a challenge for industrialsources and sectors with operations across the United Stateswhen trying to implement a consistent internal air complianceprogram.

The articles in this month’s issue explore the variations and re-cent developments for state air toxics programs on the Westand East Coasts of the United States. In our first article, authorsGrace Lee, Megan Moreen, Rodrigo Gonzalez-Abraham, andMonica Wright discuss “The Changing View of Air Toxics onthe West Coast of the United States,” looking specifically at thedevelopment and recent updates to the air toxic programs inCalifornia, Washington, and Oregon; each state has a differentregulatory view of toxic air pollutants (TAPS).

In our second article, authors Josh Hemperly, David T.Murtha, Tracey A. Karatas, and Toby Hanna, present a “Sum-mary of Air Toxics Permitting and Health Risk Assessment inNew York and New Jersey.” The authors examine the historyof these two state air toxic programs and recent updates tothe program requirements as public interest in air toxic in theregion grows.

I want to thank the authors for their valuable contributions tothis important topic and invite all of you to read and enjoy thisissue of EM. Stay safe. em

Teresa Raine, Account Director, ERM, Boston, MA, is Chair of the EM Editorial Advisory Committee. E-mail: [email protected].

Experience the ACE 2020 Virtual Conference, now available online!

ACE 2020 GATEWAY TO INNOVATION Air & Waste Management Association’s 113th Annual Conference & Exhibition

Virtual Conference June 30 – July 2, 2020

If you missed the live events, you can still register and access all of the content on demand, available to view any time, anywhere!

Virtual registration includes unlimited on-demand access to the complete technical program, including recordings of over 20 live sessions, hundreds of presentations with slides and audio, video links, poster gallery and audio, and a question and answer archive – all available through June 2021 and able to be viewed at your own pace.

Register now at www.awma.org/ACE2020 to access the content online!

A look at the changing view of air toxics in California, Washington, and Oregon and

how regulations and guidance are addressing growing public attention in these states.

The Changing View ofAir Toxics on the West Coast

of the United Statesby Grace Lee, Megan Moreen, Rodrigo Gonzalez-Abraham, and Monica Wright


Air Toxics on the West Coast by Grace Lee, et al.




In recent years, air quality regulators have seen a shift inpublic perception on air toxics—those gases, aerosols, orparticulates that can potentially result in serious health concerns or damage to the environment under specific concentrations or exposures. With increased public interest,individual areas and regions within the United States are responding differently, resulting in a patchwork of air thresh-olds and permitting requirements. On the state level, publicawareness of air toxics is growing, and the trend across thecountry is toward more state-specific requirements and morepublic disclosure about health risks. In contrast, on the fed-eral level, there have recently been rollbacks and modifica-tions to air toxics regulations, and more may be expected inthe near term. This article provides a brief update on recentand potential modifications to air toxics regulations at thefederal level and takes a closer look at the changing view of air toxics in California, Washington, and Oregon; howregulations and guidance are addressing growing public attention in these states; and the role that the states’ agencies are taking to address this concern.

The State of Air Toxics at the Federal LevelWithin the last few years, the U.S. Environmental ProtectionAgency (EPA) has rolled back many of its prior regulations,including those intended to protect air and water quality and prevent climate change. Some of these proposed ormodified regulations include those governing air toxics.These actions contrast with the perceptions of many in thepublic community, who recognize the public health concernsand risks associated with air toxics and are in favor of stricter

air toxics regulations. It is well established that exposure toair toxics is linked to potential health risks for humans, including cancer, birth defects, and respiratory and nervoussystem disorders.1 Figure 1 shows a map of cancer risk dueto air toxics exposure based on the 2014 National Air Toxics Assessment. Effects of exposure have been shown to be more pronounced among sensitive members of thecommunity, including children and the elderly.

Coronavirus Disease 2019 (COVID-19), an acute respiratoryillness that has spread across the globe in late 2019 andearly 2020, resulting in the declaration of a pandemic, hasintensified public awareness around possible health impactsrelated to air toxic exposure. There has been concern thatexposure to air toxics, in combination with chronic and acutehuman illnesses and diseases such as COVID-19, may leadto more dire health consequences, especially among thosemost susceptible. A recent Harvard study looked at air qual-ity and COVID-19 data at the county level and linked higherlevels of air pollution with higher COVID-19 death rates.2

The study found that the combined health risks of air pollu-tion and COVID-19 are likely to be more worrisome inurban areas and air toxic hotspots. Air toxics tend to posegreater risks in locations that have large populations and ahigher concentration of criteria air pollutants and toxics.COVID-19 also spreads more easily among dense popula-tions. EPA’s Second Integrated Urban Air Toxics Report toCongress, the final of two reports required under the U.S. Clean Air Act (CAA), estimated that more than 13.8million people, mainly in urban locations, were exposed to

Figure 1. 2014 National Air Toxics Assessment Map of Cancer Risk (per million people). Source: U.S. Environmental Protection Agency, 2014; https://gispub.epa.gov/NATA/(accessed June 23, 2020).



concentrations of air toxics and criteria air pollutants that increased cancer risk.3

Air toxics comprise a diverse range of air pollutants, and thedefinition ranges depending on the regulatory regime. Inthe federal regulatory context, 187 hazardous air pollutants(HAPs), a subset of air toxics, are regulated separately fromcriteria air pollutants (i.e., carbon monoxide, lead, nitrogendioxide, ozone, particulate matter, and sulfur dioxide). EPA isrequired to control the 187 HAPs identified in the CAA toprotect public health. EPA has also identified a subset of 30HAPs, known as urban air toxics, that present the greatestthreat to public health in the largest number of urban areas.Under CAA Section 112, EPA is required to regulate HAPsfrom a category of industrial facilities, resulting in source-specific and sector-based standards development such as theNational Emission Standards for Hazardous Air Pollutants (NESHAPS) and Maximum Achievable Control Technology(MACT) requirements; area source, mobile, and residual riskstandards; initiatives such as the Urban Air Toxics Strategy;and air toxics tools such as the National Air Toxics Assess-ment. Additional rules have been created to regulate air tox-ics, including the Mercury and Air Toxics Standards (MATS) in2011, which replaced the Clean Air Mercury Rule. Recently,EPA has updated and has proposed to update air toxics regu-lations with regards to MATS and MACT, respectively.

EPA Revises MATS Justification, but MATS Stays in PlaceOn April 16, 2020, EPA released a rule revising its supple-mental finding for MATS published in 2016. The MATSrule, originally finalized in 2011, was established to limit theallowable amount of mercury and other pollutants from coaland oil-fired power plants. According to EPA data, the rule’simplementation successfully reduced mercury emissions by86% nationwide from 2010 to 2017.4 EPA deemed that it is not “appropriate and necessary” to regulate air toxicsemissions from coal- and oil-fired electric utility steam-gener-ating units (EGUs) under Section 112 of the CAA, becausethe costs of such regulation outweigh the benefits of HAPemission reductions. The MATS rule published in 2011 orig-inally considered the health benefits from the reduction in

particulate matter that would accompany cuts to mercuryemissions. EPA recognized these unquantified HAP benefitsassociated with MATS but concluded “that the identificationof these benefits is not sufficient, in light of the imbalance ofmonetized costs and HAP benefits.” EPA determined thatthe total projected cost of compliance with MATS (US$7.4 toUS$9.6 billion annually) dwarfs the quantified health benefitsof the rule (US$4 to US$6 million annually).5

However, power plants are not allowed to emit more mer-cury to the air than before; coal- and oil-fired EGUs remainon the list of affected source categories for regulation underSection 112 of the CAA, and the MATS rule remains in ef-fect. While this change will not have short-term impacts onemissions, it may set a precedent in subsequent rulemakingfor rolling back air pollution standards that have improvedair quality. Furthermore, this revised supplemental findingundermines the legal foundation for the MATS regulation,and without legal justifications in place, companies wouldhave an avenue to challenge the MATS rule in lawsuits andprevent future implementation of similar regulations, accord-ing to a Reuters report.6

EPA Proposes Reclassification of Major SourcesOn January 25, 2018, EPA issued a guidance memoran-dum, known as the Wehrum Memo, withdrawing the “oncein, always in” policy for classifying major sources of HAPsunder Section 112 of the CAA. Under this guidance, HAPsources previously classified as “major sources” could be re-classified as “area sources” at any time and during NewSource Review, provided the facility limits its potential toemit below major source thresholds.7 “Major sources” aredefined by the CAA as emission points that emit at least 10tons of any particular HAP per year, or more than 25 tons ofany combination of HAPs per year. Major sources are sub-ject to emissions limits based on the MACT, whereas areasources are generally required to eet less stringent emissionslimits based on the generally achievable control technology(GACT). Both MACT and GACT standards are technology-based standards developed to control emissions from indus-trial and commercial sector categories; however, MACTstandards are more stringent. In addition, major sources are

While EPA actively aims to relax federal air toxics regulations, West Coast states such as California have actively fought against thesemodifications and have even added stricter airtoxics regulations at the state level.



also subject to stricter controls and oversight requirements.According to EPA, when fully implemented, the air toxicsMACT program was projected to reduce country-wide airtoxics emissions by about 1.7 million tons annually.8

The proposed rule was published in July 2019, and the public comment period closed in November 2019. If therule is finalized, the longstanding policy requiring majorHAP sources to maintain MACT throughout their operationlifetime (“once in, always in”) would be reversed because ofthe ability to reclassify as an area source.

In April 2018, a few months following the release of theWehrum Memo, the state of California and several environ-mental groups sued to block EPA’s retraction of the “once in, always in” policy, unhappy that the rollback could “invitemajor sources of hazardous air pollutants to game air regulations and avoid important pollution-saving measures.”9

The proposed rule, if passed, would potentially allow someformerly major air toxic polluters to turn off their pollutioncontrol technology, leading to increased air toxics levels,

because they would not be subject to MACT standards if reclassifying as area sources. These cases, known collectivelyas California Communities Against Toxics, et al v. EPA, DocketNo. 18-1085, were dismissed by the D.C. Circuit court inAugust 2019, which decided that the policy was not a finalaction subject to judicial review. In January 2020, Californiaand the environmental groups petitioned for a rehearingafter the proposed rule was published, but the D.C. Circuitdenied the request.10

While EPA actively aims to relax air toxics regulations, as evidenced by its revised MATS justification and proposed reclassification of major sources, West Coast states such asCalifornia have actively fought against these modificationsand have even added stricter air toxics regulations at thestate level.

West Coast States See Changing View of Air ToxicsIn the western United States, California was the first to miti-gate, regulate, and provide guidance related to air pollutants

Figure 2. Portland Moss and Air Quality Study Sample Locations and Cadmium Concentrations.Source: U.S. Department of Agriculture, 2016; https://www.fs.usda.gov/pnw/projects/portland-moss-and-air-quality-study (accessed June 22, 2020).



and air toxics with the introduction of the Toxic Air Contami-nant Identification and Control Act (Assembly Bill [AB] 1807)in 1983.11 Later in 1991, Washington State initiated regula-tions to control toxic air pollutant (TAP) emissions from sta-tionary sources to comply with the 1990 CAA Amendments.More recently, and as a result of public outrage over thehigh concentrations of heavy metals found in moss samplesin 2016 (see Figure 2),12 the Oregon Environmental QualityCommission adopted a health-based air toxics regulatoryprogram in November 2018. The program is known asCleaner Air Oregon (CAO) and is intended to close gaps in the Oregon Department of Environmental Quality’s previous air permitting program (based on federal guidance),which allowed some facilities to operate legally but still emitpollutants that could increase health risks to neighbors.

California, Washington, and Oregon each take different ap-proaches to preventing, mitigating, and managing the healthrisks associated with TAPs. For example, the different stateprograms vary in the number of additional toxics covered byair toxic regulations, with California and Oregon listing asmany as 600 additional toxics over EPA HAPs, and Washing-ton listing over 400 toxics. While some toxics are listed in allthree states, the methodology for determining health impactsof a given pollutant may vary from state to state. This is thecase for diesel particulate matter (DPM), a surrogate fordiesel exhaust, which is listed as a toxic in all three states butlacks consistency in determining health impacts, which givesan artificial impression that DPM toxicity changes as itcrosses the border from one state to the next.

Depending on the project’s location, scope, and size, air toxichealth risk assessments may vary, with some locations onlyrequiring the inclusion of new emission sources, and othersrequiring health risk evaluation from the entire facility,

including existing sources or for an entire region, withscreening criteria (either emission limits or ambient concen-trations) being considered. The lack of consistency betweenlocal and state regulations makes it difficult to track whenand what level of analysis may be required. All three statesalso have a public outreach component, but the extent andpurpose vary with different levels of risk triggering commu-nity meetings and public comment periods. Additional details of the three states’ air toxics programs are discussedbelow.

California State Air Toxics Program With its inception in 1983, California’s Toxic Air Contami-nant Identification and Control Act (AB 1807) has identifiedand managed risk associated with the release of toxic aircontaminants (TAC). Findings from this program, as well aspublic concerns and surveys developed by the congressionalresearch service, led to the development of the Air Toxics"Hot Spots" Information and Assessment Act of 1987 (theHot Spots Act, AB 2588).13 The Hot Spots Act was createdto “ascertain and measure the amounts and types of haz-ardous releases and potentially hazardous releases from spe-cific sources that may be exposing people to those releases.”A timeline of program updates is shown in Figure 3. To address the programmatic requirements of the Hot SpotsAct, the California Air Resources Board has developed theHotspots Analysis and Reporting Program (HARP) andHARP2 software. HARP and HARP2 are accessible to all airquality management districts, facility operators, individuals,and other organizations to provide “statewide consistency,efficiency and cost-effective development” of emission inven-tories, air dispersion modeling, and health risk assessments.Risk assessment methodologies are developed by the Officeof Environmental Health and Hazard Assessment (OEHHA)and incorporated into the Risk Management Guidance for

Figure 3. Evolution of California’s Hot Spots Program (1987–2016). Figure created by Jacobs.



Stationary Sources of Air Toxics. California’s air districts mayuse the guidance document to include the OEHHA’smethodology into their permitting programs.

Although the programmatic aspect of risk assessment in Cal-ifornia is well defined, the variability across the state can alsobe burdensome to regulated facilities that must navigate dif-ferent requirements in different parts of the state. Under theHot Spots Act, each air quality district oversees prioritizingand ranking facilities requiring health risk assessments: “Inestablishing priorities, the districts are to consider the po-tency, toxicity, quantity, and volume of hazardous materialsreleased from the facility, the proximity of the facility to po-tential receptors, and any other factors that the district deter-mines may indicate that the facility may pose a significantrisk.”13

Oregon State Air Toxics ProgramIn November 2018, a risk-based approach to facilities toxicemissions was implemented to overhaul Oregon’s prior tox-ics program.14 Under Oregon’s CAO toxics program, exist-ing facilities in the state have been given a prioritizationscore, with higher-scoring facilities entering the programsooner. Based on the prioritization score and qualitative datafor existing facilities, four prioritization groups were deter-mined. Six out of 20 facilities identified in the first prioritiza-tion group were called into the program in 2019 and arestill in the program’s submittal requirements process.

Facilities in the second and third groups will be called intothe program after the first group’s facilities have completedthe program. Facilities in the fourth group will not be calledinto the program either because they do not have air toxicsemissions or because of facility closure.15

New facilities need to enter the program during the initial airpermitting process. A facility’s score is determined by multi-ple factors such as type and amount of emissions, informa-tion about existing controls, the surrounding community,and other site-specific factors. Once a facility has been calledinto the program, its requirements are to report TAC emis-sions and calculate potential health risks to nearby communi-ties. The facility is required to complete a risk assessment(Level 1, 2, 3, or 4) based upon the permitted emissionssources to evaluate their risk.

These levels are described briefly as follows:

• Level 1 Risk Assessment uses dispersion factors basedon conservative modeling results to estimate a worst-case scenario of possible risk.

• Level 2 Risk Assessment involves using screening toolsthat allow for the use of few site-specific characteristics.

• Level 3 Risk Assessment incorporates dispersion model-ing, which can more effectively capture a facility’s onsitecharacteristics without the overly conservative approachused in a Level 1 or 2 Risk Assessment.

Figure 4. The Hazard Index (HI) level at which air emissions may harm human health (HI > 1),relative to where the Cleaner Air Oregon (CAO) rules set non-cancer benchmark HI values. Figure created by Jacobs.



• Level 4 Risk Assessment is an extremely comprehensivemodel that considers TAC bioavailability and modifyingexposure assumptions. Most facilities will not be re-quired to complete the Level 4 Risk Assessment.

The level of risk assessment used affects the complexity ofanalysis, associated costs, level of public exposure, and time-line for compliance. Once a facility’s risk has been calculated,it is compared with existing facility or new source health riskbenchmarks, or Risk Action Levels (RALs), which determinewhether the facility is in compliance or will need to take additional actions to reduce risk associated with emissions.For facilities comparing non-cancer risk to the TBACT (BestAvailable Control Technology for Toxics) RAL, TACs must beidentified in OAR 340-245-8030 as having a Hazard Index(HI) of 3 or a HI of 5. If the facility emits a mixture of thetwo, a risk determination ratio of 1 must be met for compli-ance (see Figure 4).

Washington State Air Toxics ProgramIn Washington, the Department of Ecology and local airquality agencies monitor air quality and enforce federal,state, and local air pollution laws. In general, a tiered reviewprocess (first, second, and third tier) is used to regulate emis-sions of 432 TAPs for new and modified sources.16 In No-vember 2019, the state amended rulemaking to update itslist of TAPs and source impact thresholds based on bestavailable health effects information. Currently, for new ormodified sources that emit these TAPs, a notice of construc-tion application must be filed prior to their construction.

Sources are subject to review requirements found in Chap-ter 173-460 of the Washington Administrative Code (WAC)unless the estimated emissions before control equipment(worst-case emissions) are less than the applicable de min-imis levels specified in WAC 173-460-150. The section alsolists each TAP’s corresponding acceptable source impact level(ASIL) and small quantity emission rate (SQER) value. If aproject’s potential emissions exceed de minimis levels, a first-tier review is required.

In Washington, for most new projects, only a first-tier review (toxic screening) is needed for permitting. A first-tierreview compares project emissions with the TAP values listed in WAC 173-460-150. The ASIL requirement can be satisfied using either the SQER or dispersion modeling as follows:

• SQER: TAP emission increase, after applying the bestavailable control technology for toxins (t-BACT), is lessthan the SQER listed for that TAP in WAC 173-460-150.

• Dispersion modeling: Dispersion modeling mustdemonstrate that emissions for each TAP emitted by thenew or modified source, after application of t-BACT, donot exceed the ASIL for that TAP as listed in WAC 173-460-150. If concentrations predicted by dispersionscreening models exceed the ASIL, more refined mod-eling or emissions techniques must be used. Refinedmodeling techniques must be approved by the permit-ting authority.

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local communities.17 In Oregon, public outrage over TACemissions has caused mistrust, confusion, and inconsistencythroughout the process, but it has also increased accounta-bility and, in some cases, improved collaboration and coordination among stakeholders. Washington is currentlyreexamining its air toxics approach with exploratory rule-making aimed at updating permitting criteria, emissionthresholds that capture new scientific data, and new sourcecompliance.

The Future of Air Toxics in the United States This article highlights an increased trend in state-driven per-mitting, rules, and policies to address the growing attentionon public health and air toxics. Facilities that must navigateair toxic regulations may struggle to address air toxics re-quirements with the ongoing changes and disconnects be-tween federal and state regulatory frameworks. While thereis no one-size-fits-all approach to addressing air toxics con-cerns, environmental managers from regulated facilities andregulators can reduce risk of public scrutiny and liability byunderstanding the local, regional, and state regulatory envi-ronment, tracking community concerns, and determining ifpublicly available facility air toxics data are accurate andcomplete. em

If first-tier requirements cannot be met, a second-tier reviewthat includes a health impact assessment (HIA) is required.Projects are required to work with the Department of Ecol-ogy for guidance in developing their HIA.

In cases where second-tier reviews are not approved, a third-tier review can be submitted. Third-tier reviews require a riskmanagement analysis and descriptions of the proposal’s en-vironmental benefits. Approval or denial of third-tier reviewsis given by the Department of Ecology director.

Evolution of State Air Toxics ProgramsAs these states have moved to policies that incorporate addi-tional facility transparency, there have been program up-dates and implementation hurdles to overcome. For reasonsassociated with program age and impetus for regulatoryoverhaul, the three states represent different levels of consis-tency, efficiency, and community engagement. Initially, Cali-fornia’s state program had allowed risk assessment andpublic exposure to be better engrained in the air permittingprocess but did not fully address environmental justice issues affecting local communities. Recently, Californiahas enacted new programs like AB-617 to monitor nonve-hicular air pollution, criteria air pollutants, and TACs affecting


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4. Progress Report: Emissions Reductions [Online] U.S. Environmental Protection Agency. Washington, DC, June 2019;https://www3.epa.gov/airmarkets/progress/reports_2017/emissions_reductions_mats.html#figure2 (accessed May 29, 2020).

5. Mercury and Air Toxics Standards for Power Plants: Revised Supplemental Finding and Residual Risk and Technology Review Final Rule [Online] U.S. Environ-mental Protection Agency, Washington, DC, 2020; https://www.epa.gov/sites/production/files/2020-04/documents/fact_sheet_mats_an-rtr_final_rule.pdf (accessed May 29, 2020).

6. Trump administration weakens mercury rule for coal plants [Online]; Reuters, April 16, 2020; https://www.reuters.com/article/us-usa-epa-coal-mercury/trump-administration-expected-to-weaken-mercury-rule-for-coal-plants-idUSKCN21Y1IW (accessed May 29, 2020).

7. Wehrum, W.L. Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act [Online]; Technical Memorandum for Regional AirDivision Directors, U.S. Environmental Protection Agency, Washington, DC, January 2018; https://www.epa.gov/sites/production/files/2018-01/documents/reclassification_of_major_sources_as_area_sources_under_section_112_of_the_clean_air_act.pdf (accessed May 29, 2020).

8. Reducing Emissions of Hazardous Air Pollutants: What is Being Done to Reduce Hazardous Air Pollutants? [Online]; U.S. Environmental Protection Agency,Washington, DC, February 2017; https://www.epa.gov/haps/reducing-emissions-hazardous-air-pollutants#stat (accessed May 29, 2020).

9. Attorney General Becerra Sues EPA Over Illegal Decision to Let Polluters off the Hook [Online]; State of California Department of Justice. Sacramento, Califor-nia, April 10, 2018; https://oag.ca.gov/news/press-releases/attorney-general-becerra-sues-epa-over-illegal-decision-let-polluters-hook (accessed June 22, 2020).

10. Once in Always in Guidance for Major Sources under the Clean Air Act [Online]; Harvard Law School Environmental & Energy Law Program, Cambridge,Massachusetts, February 2, 2018; https://eelp.law. harvard.edu/2018/02/once-in-always-in-guidance-for-major-sources-under-the-clean-air-act/ (accessedJune 22, 2020).

11. AB 1807—Toxics Air Contaminant Identification and Control; C.C.R Cal. Health and Safety Code §44300, Tanner, 1983.12. The Portland Moss and Air Quality Study [Online]; U.S. Department of Agriculture; https://www.fs.usda.gov/pnw/projects/portland-moss-and-air-quality-study

(accessed June 1, 2020).13. AB 2588—The Air Toxics “Hot Spots” Information and Assessment Act; C.C.R Cal. Health and Safety Code §44300 to §44394, Conelly, 1987.14. Oregon Administrative Rules; Cleaner Air Oregon. 2019; Chapter 340-245 OAR. 15. Cleaner Air Oregon Facility Prioritization Results [Online]; State of Oregon Department of Environmental Quality, Portland, Oregon. March 2019;

https://www.oregon.gov/deq/FilterDocs/caofacilityresults.pdf (accessed June 22, 2020).16. Controls for New Sources of Toxic Air Pollutants; Washington Administrative Code, Chapter 173-460 WAC, 2019.17. AB-617—Nonvehicular Air Pollution: Criteria Air Pollutants and Toxic Air Contaminants; C.C.R Cal. Health and Safety Code §40920.6, §42400, §42402,

§39607, §40920.8, §42411, §42705.5, and §44391.2, Garcia, 2017.

Grace Lee is an Environmental Engineer, Megan Moreen and Rodrigo Gonzalez-Abraham are Chemical Process Engineers, andMonica Wright is a Sustainability and Air Quality Technologist, all with Jacobs Engineering Group. E-mail: [email protected].

A comparison of the different policies and practices for air toxic health risk assessments

used by regulatory agencies in New York and New Jersey.

Summary of Air ToxicsPermitting and

Health Risk Assessment inNew York and New Jersey

by Josh Hemperly, David T. Murtha, Tracey A. Karatas, and Toby Hanna


Air Toxics in New York and New Jersey by Josh Hemperly, et al.



As more states adopt air toxics programs, and existingprograms become more complex, the regulated commu-nity must comply with frequently changing requirements. To help air permit applicants better understand the addi-tional permitting effort associated with changes in state guidance, this article will compare and contrast the differentpolicies and practices for air toxic health risk assessmentsused by regulatory agencies in both New York and New Jersey. These states were chosen as both states have a widevariety of industries, have long histories of regulating air toxics, and have been used by other states as examples forstate air toxics regulations.

The 1990 U.S. Clean Air Act Amendments (CAAA) createdregulations to limit the emission of certain air toxics knownto cause cancer and other serious health impacts based onhuman and animal exposure studies, designating them hazardous air pollutants (HAPs).

Health risk assessments determine the increased risk of ill-ness from a specific human exposure to a toxic air pollutantin a four-step process:

1. Hazard identification: describe illnesses caused by a toxic air pollutant based on scientific literature.2. Exposure assessment: estimate the magnitude of the health risk depending on exposure level, duration, and number of people exposed. 3. Dose–response assessment: estimate the

mathematical change in the likelihood of health effects with changes in the levels of exposure to a toxic air pollutant. 4. Health risk characterization: Combine the above assessments to describe the type and size of any increased health risk expected as a result of exposure to a specific air pollutant.

For carcinogens, combining the results of the exposure assessment and the dose–response assessment gives an estimate of the increased lifetime risk of cancer for an individual exposed to the maximum predicted long-termconcentration, which can then be extrapolated to calculaterisk to the overall population. For non-carcinogens, healthbenchmarks are referred to as reference concentrations,which can be short term (e.g., 1 hour or 24 hours) or longterm (e.g., annual) exposure guidelines. Ambient air concentrations that are below these health benchmarks arenot expected to be harmful to human health.

Most U.S. states administer air toxics programs to complywith health standards set by the U.S. Environmental Protection Agency (EPA). Certain states have no additionalrequirements, beyond the federal programs, to complete air dispersion modeling and health risk assessment for airtoxics as part of their routine air permitting process. Forcomparison, Table 1 lists the current status of typical air toxics permitting procedures in the states surrounding New York and New Jersey.

State State Air Toxic Published List of Air Toxics Modeling Regulation or Air Toxics and Demonstration Policy Threshold Required Concentrations for New Sources

New York X X X

New Jersey X X X

Pennsylvania -- -- --

Delaware X X X

Maryland X X X

Virginia X X X

West Virginia -- -- --

Connecticut X -- --

Rhode Island X X X

Massachusetts X X case-by-case

New Hampshire X X X

Vermont X X case-by-case

Maine -- -- --

Table 1. Summary of Air Toxics Programs in the Northeast and Mid-Atlantic States.



New YorkNew York’s air toxics program was formed out of the guid-ance provided by New York State Department of Health(NYSDOH) prior to the founding of New York State Depart-ment of Environmental Conservation (NYSDEC) in 1970.NYSDOH personnel were dealing with air toxics back in the1960s and some of those personnel moved into leadershiproles with the formation of the NYSDEC. New York’s legisla-tion was written broadly enough that it allowed the NYSDECto develop its air toxics program based on that NYSDOHguidance. Initially, the air toxics program under Part 212 wasestablished to regulate the criteria pollutants from regulatedfacilities, and over the years, with the promulgation of thefederal National Emission Standards for Hazardous Air Pollu-tants (NESHAPs) under 40 CFR Part 61, those toxic pollu-tants were added to the list of regulated pollutants. NYSDECcontinued to add substances/chemicals to the list of regulatedpollutants under Part 212 and issued the original draft of “Air Guide-1” in 1991. That draft guidance incorporatedhundreds of criteria and noncriteria pollutants to the list ofregulated air contaminants.

With its history of regulating air toxics, the NYSDEC was approached by a number of other state agencies, initiallythrough the Northeast States for a Consolidated Air UseManagement (NESCAUM) organization, for advice andguidance on how to develop their own state air toxics programs. Each of those states patterned their programsfrom what they learned from New York, with implementingregulations and/or guidance differences between each of the NESCAUM states.

As the 1990 CAAA were implemented, New York incorpo-rated those standards into its air toxics program, where thefederal requirements were more restrictive. In some cases,New York’s requirements were more restrictive than the fed-eral NESHAPs. In these cases, compliance with New York’srequirements would, by default, result in the affected facilitycomplying with the federal requirements.

Air toxics evaluations impact a wide variety of industries inNew York, including chemical manufacturing facilities, petroleum bulk storage/distribution terminals, printing/publishing operations, glass making facilities, pharmaceutical,and nutraceutical companies. The current New York air toxics program requires facility owners to perform an analysis to determine health impacts from inhalation exposures. This analysis requires the use of an air dispersionmodel. The model predicts the maximum 1-hour and annual air concentrations for each toxic air pollutant released. These model-predicted concentrations are thencompared to pollutant specific Annual Guideline Concentra-tions (AGC) and Short-term Guideline Concentrations (SGC)that have been developed by NYSDEC. This process andother factors are then used to determine the degree of airpollution control required. The current 2016 AGC/SGC

tables are located in Appendix A of what was formerly calledAir Guide-1 and is now known as DAR-1: Guidelines for theEvaluation and Control of Ambient Air Contaminants UnderPart 212 of the New York Codes, Rules, and Regulations(NYCRR).1

On June 14, 2015, changes to 6 NYCRR Part 212 becameeffective that included significant changes to the regulationof air toxics. Under the revised regulation, different compli-ance requirements and options are defined for high toxicityair contaminants (HTACs), criteria pollutants and non-criteriapollutants.

HTACs are defined as those chemicals that are likely to becarcinogenic, cause adverse outcomes in humans for reproductive and developmental effects, or meet the definition of persistent and bioaccumulative substance, andhave specific LC50 or LD50 (i.e., lethal dose or concentrationrequired to kill 50% of the population) requirements. In addition to HTACs, there is a class of chemicals designatedmoderate toxicity air contaminants (MTACs), which areknown to cause adverse reproductive and developmental effects in animal species and also must meet specific LC50or LD50 values. Low toxicity air contaminants (LTACs) are defined as those chemicals that might cause irritation orother reversible effects to sensitive subpopulations, andwhich do not meet the criteria for classification as high ormoderate toxicity contaminants.

Implementation of Part 212 RequirementsSince the 2015 promulgation of the updated Part 212requirements, the NYSDEC has adopted a phased approachfor regulated facilities to demonstrate compliance with theserequirements based on: (a) the NYSDEC’s receipt of a “permit action” initiated by the affected facility; or (b) an NYSDEC initiated permit action for an affected facility.

A permit action would include:

• a modification to an existing permit or facility registration; • a permit or air facility registration renewal application for an existing facility; or• an application for a new facility air permit or air facility registration.

Part 212 requires the applicant to precisely identify all aircontaminants emitted from each applicable process emissionsource. A summary of important information that environ-mental managers should consider which are required to beincluded with each registration or permit application are:

1. Submit the yearly actual annual HTAC emissions for an existing facility and the potential to emit (PTE) for a new facility;



2. The emission rate potential (ERP), of each non-HTAC air contaminant emitted at a rate greater than 100 pounds per year facility-wide;3. Identify each air contaminant by its chemical name and number, as defined in the American Chemical Society’s Chemical Abstract Service (CAS) Registry;4. A list and description of all non-exempt or trivial emission sources at the facility;5. A description of all processes and their associated emission sources and products, including a detailed process flow diagram;6. A list of all emission points including stack parameters (e.g., stack height, internal stack diameter, exit temperature, exit velocity, exit flow, distance to the property line, and location coordinates; and7. Any applicable environmental analyses (i.e., Environmental Rating proposal).

In addition, the following analysis may be required:

• Toxic Impact Assessment (TIA) incorporating an AERSCREEN modeling analysis or AERMOD modeling protocol;2

• Best Available Control Technology (BACT) or Toxics Best Available Control Technology (T-BACT) evaluation; or• Volatile Organic Compounds (VOC) or Nitrogen Oxides (NOx) Reasonably Available Control Technology (RACT) evaluation.

NYSDEC believes that within 10 years of the 2015 promul-gation date of the revised Part 212, the majority of the regu-lated facilities statewide will have evaluated their complianceobligations with Part 212.3 This is based on the timing ofcurrent permit lengths since New York State Major Source(Title V) and Air State Facility Permits are issued for a five-year operating period, and Air Facility Registrations (i.e., trueminor sources) are now issued for a 10-year operating pe-riod. The identification of emissions that are subject to themodeling requirements under Part 212 should be consid-ered carefully, the importance of a thorough air emissionsinventory, both from a PTE and actual emissions perspective,should not be minimized. Understanding the distinction of

potential emissions versus actual emissions can help facilitiesmake an informed business decision regarding complianceoptions, permitting strategies, and avoidance with potentiallyunnecessary permit conditions that limit operations.

New JerseyThe New Jersey Department of Environmental Protection(NJDEP) utilizes documented health risk assessment procedures to: (a) evaluate potential air toxics health risks remaining (residual health risk), either from individual sourceoperations or from entire facilities, after applicable pollutioncontrols; and (b) make decisions regarding permitting, control, and/or regulation of air toxics.

NJDEP has been addressing public exposure to air toxicssince 1979. In 1989, routine health risk screening, using a worksheet to conservatively evaluate the health risk fromair toxics sources, became standard during permit review. At the time, the specific air toxics evaluated included 168carcinogens, 133 chemicals with other non-carcinogeniclong-term effects, and 64 with non-carcinogenic short-termeffects. Note that New Jersey has a number of compoundson its air toxics list that are not on the federal HAP list. The health risk screening tool is now applied to all air permit applications with reportable levels of air toxics emissions and is routinely updated by NJDEP, most recentlyin June 2020.

NJDEP’s air toxics program continues to evolve, and on Jan-uary 16, 2018, revisions to NJDEP’s air pollution control re-quirements known as the Resiliency and Air Toxics rule(RATE Rule) were published in the New Jersey Register (50N.J.R. 454(a)). The RATE Rule established significantly lowerreporting thresholds that trigger the health risk assessmentprocess for minor and major air permitting. The changes became effective on February 12, 2018, and were followedlater that year by changes to NJDEP’s health risk assessment and air dispersion modeling guidance.4,5

Starting February 12, 2018, applications for air permits wererequired to be evaluated using new air toxics reportingthresholds for the source operation(s) affected by the new or modified operations. Of 168 air toxics, the reporting

The regulated community in New York andNew Jersey must successfully navigate bothstates’ multi-tiered air toxics programs whencomplying with ever evolving regulations, requiring a high level of knowledge and experience.


hexane, MTBE, toluene, and xylene may also exceed their reporting thresholds.

Health Risk Assessment Procedure in New JerseyOnce emissions become reportable, a health risk assessmentwill be required when submitting applications for new ormodified emission units (major or minor), and when renew-ing Title V operating permits. These health risk assessmentscan be single source, typically for new or modified emissionunits or facility-wide health risk assessments for Title V re-newals. The air toxics emissions from pertinent sourcesshould be analyzed using the air quality modeling method-ologies approved by NJDEP and submitted to the department for review in a modeling protocol.

Health risk assessments are a significant component of theair permitting process in New Jersey. The complexities of airdispersion modeling, sometimes for dozens of stacks, as wellas area sources, and volume sources at one site require itera-tive modeling and negotiation with the NJDEP. There isoften difficulty in matching the permitted emission limits andstack parameters to the modeling, due to the complexity ofthe permits. Sometimes, new limits on operations or emis-sions are necessary. Despite these challenges, it is almost al-ways possible to find a way to achieve acceptable results forthe health risk assessment. However, that usually requires anexperienced team of experts and detailed input from the fa-cility operations and EHS team. Knowing what to expect isimportant while planning new projects.


thresholds decreased (in many cases two to three orders ofmagnitude) for 106 air toxics and increased for 15 air toxics(46 remained unchanged). The overall effect on permittedfacilities was that more air toxics triggering the health risk assessment process and must show acceptable results to obtain air permit approval.

The following emission sources and pollutants are examplesthat would trigger an air toxics impacts review and possibly refined dispersion modeling underNJDEP health risk assessment procedures:

• Natural gas-fired combustion turbines begin to exceed the reporting threshold for formaldehyde at 0.56 MMBtu/hr. • Natural gas-fired boilers begin to exceed the reporting threshold for Cadmium at 9.1 MMBtu/hr.• Oil-fired boilers begin to exceed the reporting threshold for Arsenic at 18 MMBtu/hr.• Emergency natural gas-fired reciprocating internal combustion engines begin to exceed the reporting threshold for formaldehyde at 0.66 MMBtu/hr.• Emergency diesel-fired reciprocating internal combustion engines will exceed the reporting threshold for hourly benzene at 13 MMBtu/hr.• A 120,000-gallon bulk storage tank containing gasoline that emits 1.2 ton/yr VOC will trigger the benzene reporting threshold. Depending on the properties of liquid being stored, ethylbenzene,

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ConclusionThe regulated community in New York and New Jersey mustsuccessfully navigate both states’ multi-tiered air toxics programs when complying with ever evolving regulations, requiring a high level of knowledge and experience. Both states refer to EPA’s air dispersion modeling methodol-ogy for refined health risk assessments to demonstrate compliance with health risk thresholds but differ on how facilities must use various pollutant-specific emissions thresholds and screening tools prior to a dispersion modelinganalysis.

Applicants in both states face increasing pressure to balancethe needs for operational flexibility and aggressive projecttimelines with the need to address health risk in their permitapplications. As a result, applicants must do additional leg-work upfront, including but not limited to: performance ofpreliminary dispersion modeling, development of intricate

operation limitations, and/or proposal of other mitigationstrategies to assure that projects (and facilities in the case of facility-wide evaluations) can demonstrate and acceptablehealth risk. If an intricate permitting strategy is not developed and health risk becomes a factor in the permitapproval process, the applicant risks significant delays to thepermitting process (and the initiation of the project), or evenworse, a permit application denial.

Companies operating in New York and New Jersey shouldbe careful to accurately estimate air toxics emissions whenconsidering changes at their facilities. These additional requirements require specialized expertise, extra lead timeand appropriate funding to ensure that permit applicationsare processed on time and that permit approvals are accurate and as flexible as possible while still demonstratingacceptable health impacts. em

References1. Guidelines for the Evaluation and Control of Ambient Air Contaminants under 6 NYCRR Part 212 Process Operations (Part 212); New York State Department

of Environmental Conservation, Bureau of Air Quality Analysis & Research, 2016; https://www.dec.ny.gov/chemical/106667.html.2. U.S. Environmental Protection Agency. AERMOD Implementation Guide; AERMOD Implementation Workgroup, August 3, 2015.3. Steve DiSantis, NYSDEC, Division of Air Resources, Central Office, Albany, NY. Personal communication, June 2020.4. New Jersey Department of Environmental Protection. Guidance on Preparing an Air Quality Modeling Protocol; NJDEP Technical Manual 1002,

December 2018.5. New Jersey Department of Environmental Protection. Guidance on Preparing a Risk Assessment for Air Contaminant Emissions; NJDEP Technical Manual

1003, December 2018.

Josh Hemperly, David T. Murtha, QEP, Tracey A. Karatas, P.E., and Toby Hanna are all with ERM. E-mail: [email protected].

EPA Turns 50 – Join us in celebrating this special year!

Join the EPA Alumni Association and learn more at EPAalumni.org.

The EPA Alumni Association was formed to provide former employees with a place to reconnect or stay connected to colleagues from the Agency. It is open to federal employees who served one continuous year at EPA or current employees eligible to retire, and currently has over 2000 members.

View our video on Early Implementation of the Clean Air Act of 1970 in California on our website.

What we have done this year:

• Updated our dynamic history of EPA: Half Century of Progress

View the information at EPAalumni.org/HCP.

Our plans for the rest of the year:

• Anniversary panels and gala on December 2, 2020

• Teach-ins

Composting Solutions for RuralMunicipalities in Lebanon:

Low Tech, Low Cost, and Locally Integrated

Waste Management CornerEM is expanding its content coverage of waste management issueswith a special section of waste-themed articles in every issue, calledWaste Management Corner. In this month’s article, Antoine AbouMoussa explores composting solutions in rural Lebanon.

Composting of municipal SSO via passively aerated piles with limited turning, Keserwan District.Photo courtesy of Compost Baladi SAL.


Waste Management Corner by Antoine Abou Moussa

Lebanon is a middle-income West Asian Middle Easterncountry, with a population of approximately 6 million people,of which around one in every six is a refugee.1 The solidwaste management (SWM) infrastructure of the country is, inthe best case, mismanaged and, in the worst case, non-existing, with few exceptions. However, optimized low-techcomposting techniques are enabling rural Lebanese commu-nities to locally treat their source-separated organic wastes(SSO) and transform them into a valuable soil amendment.This article briefly summarizes the characteristics of solid

waste in Lebanon, as well as the status of the current solidwaste management infrastructure, and describes the low-techcomposting techniques being successfully deployed in ruralareas of Lebanon.

Waste Generation RateAs a middle-income country, Lebanon has an estimated dailywaste generation of 0.85 kg/capita in rural areas and 0.95-1.2 kg/capita in urban areas, with a national weighted aver-age of 1.05 kg/capita/day.2 That said, most local waste



management experts working on waste characterization andrecycling campaigns report encountering lower generationrates in rural towns and villages, ranging between 0.5 and0.8 kg/capita/day. It is worth noting that the generation rateof solid waste could reach as low as only 0.3 kg/day/capita ininformal settlements of refugees. In total, Lebanon producesan estimated 2 million metric tons of solid waste per year,around 90% of which is generated by households and commercial establishments, with the remaining 10% beingmostly generated by industrial facilities.2

Waste Characterization and QualityLebanon produces predominantly organic waste, comprisedmostly of food scraps and toilet waste. Such organic wastes,as an official national average, comprise about 53% of house-hold solid waste.3 This number could reach 60–70% in ruralareas, hitting 80% in informal refugee settlements. In weight,organic waste is composed of roughly two-parts food scrapsand one-part toilet waste. In volume, however, the organicwaste portion is almost equally divided between food scrapsand toilet waste, due to a high volume of low-density toiletpaper.

The generation of household yard debris is limited, com-pared to the United States for example, since most housingunits are apartments with no backyards or gardens. The pres-ence of household toilet paper in the solid waste stream issignificantly higher than that of the United States, due prima-rily to the high risk of clogging of the predominantly obsoletetight plumbing pipes that cannot sustain the channeling ofsuch type of waste.

Chemically, the C:N ratio of Lebanon’s household organicwaste is balanced enough to sustain the temperature of acompost pile between 45 and 65 degrees Celsius for morethan two weeks, thus providing enough heat exposure to killpathogens. Lab tests show a C:N ratio of 20 for the house-hold food scraps portion, with a moisture content between60 and 80%.

Physically, the abundance of toilet paper in the organic wastestream is beneficial when it comes to its capacity for absorb-ing the liquid fraction, but detrimental to the overall porosityof the compost mix if no bulking agents are added.

Biologically, the presence of a large volume of toilet waste, aswell as a small portion of raw meat and poultry from house-holds and local butcheries, increases the risk of having FecalColiform, E. coli, Salmonella species, and other infectious microorganisms.

StakeholdersIn Lebanon, the main public stakeholders in solid waste management are:

• 1,000+ municipalities, 70% of which have a population less than 4,000.4

• 400+ towns/villages without municipalities, each governed by the head of its respective district (called a Qadaa or Caza) or governorate (called a Mohafazat). Lebanon has 26 districts and 8 governorates.• 50+ federations of municipalities, encompassing 600+ municipalities.• 5 ministries/governmental offices: Ministry of Environment (MoE), Ministry of Interior and Municipalities (MoIM), Office of the Minister of State for Administrative Reforms (OMSAR) and the Council for Development and Reconstruction (CDR).

Current Waste DisposalPresently, most of the solid waste coming from the maincoastal cities of the country is disposed at a half-dozen, controlled, coastal dumpsites/landfills. “Controlled” meansdisposal at a designated disposal site controlled by a government entity. Informal scavenging (“dump-picking”) is not allowed at controlled dumpsites/landfills. While thesecontrolled dumps/landfills are better managed than simpleopen dumping of waste, they do not meet environmental

In Next Month’s Issue…Zero Emission TransportationAll sectors must decarbonize if the world is to achieve the ambitions ofthe Paris Agreement. The September issue examines the transportationsector’s progress toward zero emission vehicles, vessels, and planes.



recyclables from waste for recovery andalso separate the organic fraction for bi-ological treatment. All of these MRFsand MBT facilities face major problemsrelated to the very low percentage ofrecovered recyclable materials (less than10% of total waste is recovered for re-cycling), limited space to soundly treatthe organic waste fraction, and they areall located in the vicinity of inhabitedareas, creating compatibility issues. Additionally, all these facilities need away to discard of the large amounts ofresidual organic and non-organic wastesthey generate.

Waste disposal at open dumpsites is the norm in most rural locations outsideof Beirut and Mount Lebanon gover-norates, despite numerous attempts inthese areas to run MBT plants of capacities ranging between 10 and 150 metric tons per day. According to anon-governmental organization and anin-country environmental specialist (Dr.Naji Kodeih),5 there are between 941to 1,350 such open dumpsites operat-ing throughout Lebanon, with morethan 150 of these dumps being open-burned at least once a week. Figure 1illustrates the large number of wastedumps operating within Lebanon, andthe variation in their burn frequencies(burns per week).

Composting Status inLebanon

The biggest operating sites in the country for composting oforganic waste, which are located in a few cities and federa-tions of municipalities, have been plagued for decades withlack of financial stability, operational and administrative chal-lenges, and a public resistance due to the generation of foulodors and production of non-salable low-quality compost. Bycontrast, as discussed below, some rural municipalities inLebanon are making progress in successfully implementingpractical techniques for composting organic waste.

Local CompostingGiven that large-scale, urban composting operations inLebanon have been generally unsuccessful, households,commercial establishments and municipalities in rural areashave opted for a different approach. The approach in ruralareas is to implement low-tech, low-cost, and locally inte-grated composting solutions that consider local culture andavailable resources. These rural composting operations are

standards that apply at these locations. Specifically, Lebanon’scontrolled dumps/landfills are still illegal under the BarcelonaConvention for the Protection of the Marine Environmentand the Coastal Region of the Mediterranean, a Conventionto which Lebanon is a contracting party.

Long-term plans for implementing environmentally-conforming solutions are still unclear, especially with the con-tinuous governmental efforts to leverage on the status quocreated by the polluting coastal dumps/landfills in order topromote and adopt the more controlled, yet unpopular, in-cineration technologies for these same cities. It is worth not-ing that there are four, main recycling facilities in coastalcities, specifically Materials Recovery Facilities (MRFs) andMechanical-Biological Treatment facilities (MBT), that each re-ceives hundreds of metric tons of commingled waste per day.MRFs recover recyclable materials from waste via both hand-sorting and mechanical separation. MBT facilities separate

Figure 1. Waste dumpsites and waste burn frequencies inLebanon.3

Climate Change Philosophy in Oklahoma by Ken Senour


undertaken to produce a valuable high-quality compost prod-uct, and/or, to simply treat (biologically stabilize) the organicwaste to reduce the environmental impact of the waste’s finaldisposal. Some specific examples of these rural compostingtechniques are highlighted below, first the composting tech-niques for producing a valuable soil-amendment product,then the techniques for pre-disposal treatment.

Production of Valuable CompostBrief descriptions follow of some of the composting tech-niques most commonly being used in rural Lebanon for producing a valuable compost product. These compostingoperations process food-, garden-, and yard wastes, but donot typically co-compost toilet waste:

• Metal scraps can be “repurposed” to fabricate a simple, low-cost composting unit that a rural household can use for composting food leftovers and yard debris. Similarly, a simple home compost bin can be fabricated from wood or ordered from a local carpenter. These scrap-metal and wooden composting units used at rural homes are illustrated in Figures 2 and 3, respectively.

• At the rural municipality level, community composting is being conducted via small-scale windrow composting operations in which food scraps and occasional garden/ yard debris are co-composted in static, elongated mounds (windrows) to produce a quality compost product for local use. The windrowed material is usually turned with an available front-end loader periodically to maintain aerobic decomposition conditions. Municipal windrow composting in rural Lebanon is illustrated in Figure 4.

• Farms in rural Lebanon have begun to compost their agricultural waste on site, including their crop residue and/or animal manure. The resulting compost is used as a soil amendment. The agricultural waste is typically composted using the turned, open-pile technique, as depicted in Figure 5.

Pre-Disposal Treatment of Organic WasteBecause organic waste disposed in dumps or landfills decom-poses anaerobically, this results in the production of acidicleachate, methane gas, and odorous gas. Acidic leachate canfacilitate the migration of toxic heavy metals from thedump/landfill into surface- and ground water. Methane gascan be explosive and is a potent greenhouse gas. Gases pro-duced when organic waste decomposes anaerobrically cancause odor nuisance. Accordingly, there is value in pre-treat-ing organic waste via composting (biological stabilization)prior to its disposal in dumps or landfills, thus reducing theamount of anaerobic decomposition that takes place subse-quently within the dump/landfill. In addition, for human and

Figure 2. Simple household composter madefrom metal scraps, Chouf District.Photo courtesy of Ehab Abou Fakher.

Figure 3. Simple home compost bin madefrom wood, Keserwan District.Photo courtesy of Compost Baladi SAL.

Figure 4. Farm composting of agriculturalwaste, Aley District.Photo courtesy of Compost Baladi SAL.

.



animal wastes destined for disposal in dumps/landfills, composting pre-treatment of the waste for biological stabilization can aid in pathogen reduction.

Several different composting techniques are being commonlyused in rural areas of Lebanon to pre-treat organic wasteprior to disposal in a dump/landfill. In one method, the municipality’s source-separated organic wastes (SSO) are composted in passively aerated static piles. This techniqueuses aeration ducts and natural air convection to instill sufficient oxygen into the piles of organic waste to ensurethat decompostion takes place aerobically, not anaerobically.This composting technique is illustrated in Figure 6.

Another municipal-level composting method is depicted inFigure 7. This method first entails the use of an on-site shred-der to reduce the volume of the SSO to be composted.

Then, the SSO undergoes composting in stages as it is manually transferred from one basin to the next over a 21-day period. The advantage of successive transfer from basinto basin over the duration of the composting process helps isaerating the piles and keeping the decomposition processaerobic, as well as homogenizing the materials being decomposed in terms of porosity and exposure to the piles’sexothermic heat.

Figure 5. Muncipal small-scale windrow composting, Zahle District.Photo courtesy of Compost Baladi SAL

Figure 6. Composting of municipal SSO usingpassively aerated static piles, Keserwan District.Photo courtesy of Compost Baladi SAL.

Figure 7. Composting of municipal SSO via mechanical shredding and successive inter-basin transfers.Photo courtesy of Embassy of Canada to Lebanon and Ehab Abou Fakher.



Figure 8 illustrates municipal-level composting of SSO using,respectively, open compost piles turned for aeration regularlywith a front-end loader, and passively aerated compost pilesthat need only limited mechanical pile-turning.

SummaryWith limited exceptions such as the successful, rural compost-ing initiatives described in this article, the solid waste man-agement infrastructure in Lebanon is generally mismanaged.In urban areas of Lebanon, waste is ultimately disposed incontrolled dumps/landfills; however, those facilities do not yet

meet standards that apply there for environmental protection.In rural Lebanon, waste management infrastructure is generally nonexistent, and waste is typically disposed in opendumps with open burning. Given the high organic content of the waste in Lebanon, this presents an opportunity to better manage that organic waste fraction via composting.Optimized, practical low-tech composting techniques arenow enabling rural Lebanese communities to locally treattheir source-separated organic wastes and either transformthem into a valuable soil amendment, or biologically stabilizethe waste prior to disposal. em

Figure 8. Open-pile composting of municipal SSO with regular mechanical turning, West Bekaa District.Photo courtesy of Compost Baladi SAL.

References1. Lebanon Crisis Response Plan; United Nations High Commissioner for Refugees, 2019; https://www.unhcr.org/lb/wp-content/uploads/sites/16/2019/04/

LCRP-EN-2019.pdf.2. Country Report on the Solid Waste Management in Lebanon; German Cooperation (GIZ/SWEEP-Net), 2014; http:// http://www.moe.gov.lb/.3. Updated Master Plan for the Closure and Rehabilitation of Uncontrolled Dumpsites Throughout the Country of Lebanon; United Nations Development

Programme and Ministry of Environment of Lebanon, June 2017; https://www.undp.org/content/dam/lebanon/docs/Energy%20and%20Environment/Publications/Updated-Master-Plan-Volume-A_Final-ilovepdf-compressed.pdf.

4. Atallah, S. Can Municipalities Take on the Refugee Crisis?; The Lebanese Center for Policy Studies, February2016; http://lcps-lebanon.org/featuredArticle.php?id=68.

5. Avenue, H.R.W. “As If You’re Inhaling Your Death”; The Health Risks of Burning Waste in Lebanon; Human Rights Watch, New York, December 2017;https://www.hrw.org/report/2017/12/01/if-youre-inhaling-your-death/health-risks-burning-waste-lebanon.

Antoine Abou Moussa is founder/adviser of Compost Baladi SAL in Lebanon and co-founder/CTO of Compost Baladi SAS in Colombia.Abou Moussa is an experienced environmental consultant and trainer with a demonstrated history of working in the environmental servicesecosystem. He earned a Master of Science in Environmental Engineering and a Bachelor of Science in Chemistry. E-mail: [email protected].

Global Disease and Air Qualityin a Changing Climate

Through the lens of the current global pandemic, a look at some of the existingchallenges, such as environmental degradation, decreasing air quality, and climatechange, that continue to put the human population at risk.

by Kim Frauhammer


YP Perspective

2020 has already been a year to remember, defined by thenovel Coronavirus and its far-reaching effects on our healthand economy. This global pandemic has restructured ourlives, while existing global challenges that continue to put thehuman population at risk remain. Environmental degradation,decreasing air quality, and climate change continue to exposethe human population to higher risks of illness and loss ofresources. COVID-19 has provided us with a unique windowinto identifying these underlying risks and highlights the benefits between preserving the future of not only ourhealth, but our environment as well.

Seasonality of the VirusWith how expansive this virus has proven to be, examiningall methods of transport is vital to understanding the future of global diseases. According to the U.S. Global Change Research Program, a set of “vulnerability factors” determinewhether someone is at risk for adverse health outcomes: exposure, sensitivity, and adaptive capacity.1 The climate andenvironment are a part of all three. The virus first emergedand spread rampantly during the Northern Hemisphere Winter and there is scientific evidence to point to why. Humidity is the greatest factor.

Recent research from Harvard University cites that peoplewho live in areas of poor air quality are more likely to diefrom COVID-19.5 The study examined over 3,000 countiesacross the United States with long-term exposure to fine par-ticulate matter (PM2.5) and the virus-related death counts cor-responding to those counties. The study found statisticallysignificant results showing that an increase of 1 µg/m3 ofPM2.5 was associated with an 8% increase in the mortalityrate.

A similar study done in China showed that there was also acompelling link between higher air pollution levels and mor-tality rate of the SARS (“Severe Acute Respiratory Syn-drome”) virus that swept across Asia in 2002.6 The studycites that patients from regions with a high air pollution index(API) had a mortality rate double that of patients from re-gions with low APIs. These studies represent the increasedsensitivity of people to suffer severe impacts from a virus dueto poor air quality.

According to the National Climate Assessment, over 100


YP Perspective

In the midlatitudes of the Northern Hemisphere (broadly be-tween 30 and 60 degrees), the atmosphere cools down as theEarth is tilted farther away from the sun during the winter.This colder air typically contains less moisture than its summercounterpart. This is because water does not evaporate as read-ily in colder air as it does in warmer air.2 As temperature in-creases, so does the energy of water molecules, eventuallybecoming so energetic they evaporate and change from a liq-uid to a gas phase, becoming water vapor in the atmosphere.This phase change does not happen as frequently in the win-ter, leading to drier air.3

Liquid droplets we emit from sneezing, coughing, or evenbreathing can remain in the dry air longer, creating favorableconditions for the spread of viruses like the one that causesCOVID-19. The minute water particles we spray into the airfloat in the dry air of winter for us to breathe.4

Disease and Air QualityUnderstanding the seasonality behind the spread of viruses isonly one environmental aspect determining our exposure.

Figure 1. Human-caused and natural emissions of air pollution.Source: National Climate Assessment.7


YP Perspective

million people in the United States today live in areas wherethe air pollution exceeds health-based air quality standards.7

Two common air pollutants that adversely affect humans areground-level ozone (O3) and particulate matter (PM2.5 andPM10). These impact the respiratory and cardiovascular sys-tems, leading to health complications, shortness of breath,hospital visits, and even premature death. It is estimated thatabout 200,000 Americans die from those air pollution-re-lated causes each year, despite all the pollutants being de-fined as within the U.S. Environmental Protection Agency(EPA) standards.

The State of Air Pollutants TodayO3 and PM primarily originate from emissions from human-related activities such as highway vehicles, stationary fuelcombustion, and industrial processes (see Figure 1).7 Thesepollutants are also extremely sensitive to meteorological factors such as temperature, wind speed, and precipitation.

Natural processes alsoresult in the formation ofthese pollutants. Sea salt,elemental carbon, dust,and smoke are all exam-ples of naturally occur-ring components of PM.It is estimated that wild-fires comprised roughly40% of direct PM2.5

emissions in 2011.7

However, human-relatedactivities, including pre-scribed fires and landmanagement practices,also formed part of this40%.

The U.S. Clean Air Acthas made significantprogress toward cleanerand more breathable airin our country.8 A studyfrom 2009 shows life expectancy across the United States increased by five monthsbetween 2000 and2008 due to reductionsin PM2.5.9 However, allthese pollutants haveshown a slight increasingtrend since 2016 andthere are still many areaswithin the United Stateswhose levels of these

pollutants exceed federal air quality standards, putting citizens that live in these areas at an increased risk for healthcomplications.10

As people stayed home in early 2020 due to COVID-19 andcommuting became walking from the bed to the couch inslippers instead of driving miles in a smog-emitting car, manycited the dramatic improvements in air quality. On April 9,NASA released satellite images revealing significant reduc-tions in air pollution over the major metropolitan areas of theNortheast United States (see Figure 2).11 In India, the nor-mally haze-clogged skies were replaced with magnificentviews of the Himalaya Mountain Range, a sight not seen inyears.12 These achievements show that widespread action ona global scale to improve air quality is possible, even if thecurrent circumstances are not sustainable.

EPA air monitor data from 2015–2019 was compared to

Figure 2. NO2 levels during COVID-19 pandemic.Source: NASA11

2020 data from the same period bycounty during the time of 2020 stay-at-home orders in Colorado (see Fig-ure 3). PM emissions revealed greatcontrast, with one county seeing asmuch as a 40% decrease, while aneighboring county saw a 40% in-crease. O3 was less dramatic. Withfewer cars on the road, data acrossthe state east of the Rockies largelyvaried on a range from negative topositive 5%, with zero change inDenver County. This unique situationof staying at home shows a need forreductions in other aspects of societyto achieve dramatic long-term de-creases in pollutants.

A Changing Climate’s Effecton Air QualityAccording to the National ClimateAssessment, many factors contributeto increased PM and O3 emissions.As the globally averaged tempera-ture increases, we will not see a blanketed effect of this increasethroughout the entire world, rather a quilt of extremes with varioussquares affecting various regions (see Figure 4).

The West and Southwest UnitedStates are two areas that are pro-jected to see higher temperaturesand decreased precipitation due toclimate change.13 This leads to a pro-longed and more severe wildfire sea-son, as well as more frequentdroughts. PM emissions from wild-fires and drought-related dust there-fore increase.14 PM can then travelhundreds of miles in the wind toother parts of the United States, de-creasing air quality. This drier andhotter climate is also expected to re-sult in twice the area of forest burnedin the United States due to wildfires,leading to more smoke-related PM.7

Meteorological conditions continueto influence air quality. O3 is formedthrough photolytic chemical reactionsdriven by the sun, which results in in-creased O3 formation in regions with


YP Perspective

Figure 3. Percent change in Colorado PM2.5 (top) and O3 (bottom)median concentrations by county during stay-at-home order compared to 2015-2019.Source: EPA Air Quality System and AirNow data.

Credit: Holli Williamson and Clement Cros, Spirit Environmental, LLC


YP Perspective

Other viruses such as Lyme disease or malaria, which arevector-borne illnesses carried by ticks and mosquitoes, couldhave the ability to reach regions they never have before.19

Revisiting the quilt analogy, the wet and humid region of thetropics is expected to expand, creating a larger favorable environment for mosquitoes carrying malaria. Similarly, increased precipitation across the northeastern United Stateshas expanded the geographic reach of ticks and Lyme disease.19

What about humidity? Research suggests the more favorable spread of viruses inenvironments with low humidity. Some cite the increasingglobal temperature as an indication that humidity will also increase, suggesting a decrease in the spread of viruses.However, climate models predict that surface temperaturechanges resulting from climate change will be amplified over land when compared to the ocean, and subsequentlylead to relative humidity declining over land while remainingconstant over the ocean.20

A Path ForwardOur Earth is a complex place and we are only beginning to understand the novel coronavirus and its effect on ourhealth, economy, and environment. While it is uncertainwhether the grip COVID-19 has on society will continue to affect us for years to come, it has brought to light the

increased temperature. O3 formation also favors low humid-ity and stagnant air, allowing the O3 to “cook” in the atmos-phere.15 Conversely, O3 and PM can be brought out of theair to the ground by rain and snow.

Persistent weather patterns causing stagnant air over onearea for a prolonged time lead to a piling up of PM or O3

emissions near the ground that leads to negative health im-pacts.16 This is commonly seen in Denver, Colorado (a seri-ous nonattainment area for O3) when a stable air massmoves over the region, causing sinking air to trap these pol-lutants over the city. These stagnant weather patterns arelikely to become more prevalent as our climate changes.

Future of Disease in a Changing ClimateHow else do issues such as air quality and climate change in-fluence the future spread of diseases like COVID-19? Unfor-tunately, the answer is not as clear as the recent Los Angelesskyline. Preliminary research from Italian scientists foundCoronavirus detected on air pollution particles, suggestingviruses could travel further with worsened air quality.17

Climate scientist Katharine Hayhoe from Texas Tech University also cites continued human expansion as one reason zoonotic viruses such as this Coronavirus might become more prevalent.18 As civilization expands and encroaches on wildlife, displaced animals that carry viruseswill be forced into our space, increasing human exposure.

Figure 4. Climate change effects across the United States. Source: National Climate Assessment13


YP Perspective

underlying risks to the human population that we now havethe adaptive capacity to mitigate. It has also revealed that hu-mans can alter behavior when necessary. Telecommuting21 ison the rise, and meat shortages due to the virus have led tomore Americans exploring vegetable-based diets and

sustainable meat alternatives.22 The question remainswhether we will embrace these short-term actions and intertwine them into our lives going forward. The benefits ofdoing so could be significant: a more resilient population andcleaner planet for the next generation. em

YP Perspective is a semi-regular column organized by A&WMA’s Young Professional AdvisoryCouncil (YPAC). YPAC strives to effectively engage professionals within the Association by developingservices and activities to meet the needs of today’s young professionals (YPs). A YP is defined by the Association as being 35 years of age or younger. Each YP is encouraged to get involved with the Association, whether within their local Chapter or Section or within the Association’s four Councils—Education Council, Technical Council, Sections and Chapters Council, and YPAC. YPs interested in getting involved may contact YPAC for more information on current volunteer and leadership opportunities. Call for Submissions: If you have a topic you would like to see YPs discuss in EM, e-mail: Kerry Weichsel.

References1. Balbus, J.; Crimmins, A.R.; Gamble, J.L. Ch. 1: Introduction: Climate Change and Human Health; https://health2016.globalchange.gov/climate-change-and-

human-health (accessed June 3, 2020).2. Physical Properties of Air. NASA. See https://sealevel.jpl.nasa.gov/overview/overviewclimate/overviewclimateair/ (accessed June 3, 2020).3. Frauhammer, K. The millennial scientist; https://themillennialscientist.com/COVID-19/ (accessed June 3, 2020).4. The real reason germs spread in winter. See https://www.bbc.com/future/article/20151016-the-real-reason-germs-spread-in-the-winter (accessed June 3,

2020).5. Wu, X.; Nethery, R.C. Exposure to Air Pollution and COVID-19 Mortality in the United States: A Nationwide Cross-Sectional Study; 2020.6. Cui, Y.; Zhang, Z.-F. Air Pollution and Case Fatality of SARS in the People’s Republic of China: An Ecologic Study; 2003.7. Nolte, C.G.; Dolwick, P.D.; Horowitz, L.W. Fourth National Climate Assessment: Chapter 13: Air Quality; https://nca2018.globalchange.gov/chapter/13/#fn:5

(accessed June 3, 2020).8. Air Quality Trends Show Clean Air Progress. See https://gispub.epa.gov/air/trendsreport/2019/#air_pollution (accessed June 3, 2020).9. Pope III, C.A.; Ezzati, M.; Dockery, D.W. Fine-Particulate Air Pollution and Life Expectancy in the United States; New England Journal of Medicine, 2009.10. Green Book. EPA. See https://www3.epa.gov/airquality/greenbook/ancl.html (accessed June 3, 2020).11. Jacobs, P. Data Shows 30 Percent Drop In Air Pollution Over Northeast U.S.; NASA; https://www.nasa.gov/feature/goddard/2020/drop-in-air-pollution-over-

northeast (accessed June 3, 2020).12. TWC India Edit Team. Himalayan Peek: Thanks to Lockdown, Mighty Himalayas Are Visible from Bihar, Uttar Pradesh. See https://weather.com/en-

IN/india/news/news/2020-05-06-himalayan-peek-lockdown-himalayas-visible-bihar-uttar-pradesh-punjab (accessed June 3, 2020).13. Lindsey, R.; Dahlman, L.A. Climate Change: Global Temperature; NOAA Climate.gov; https://www.climate.gov/news-features/understanding-climate/climate-

change-global-temperature (accessed June 3, 2020).14. Drought and Climate Change. See https://www.c2es.org/content/drought-and-climate-change/(accessed June 3, 2020).15. Burrows, L. The complex relationship between heat and ozone; Havard University Study; https://news.harvard.edu/gazette/story/2016/04/the-complex-relation-

ship-between-heat-and-ozone/ (accessed June 3, 2020).16. Horton, D.E.; Diffenbaugh, N.S. Response of Air Stagnation Frequency to Anthropogenically Enhanced Radiative Forcing; 2012.17. Setti, L. SARS-Cov-2 RNA Found on Particulate Matter of Bergamo in Northern Italy: First Preliminary Evidence; 2020.18. StarTalk: Coronavirus and Climate Change; StarTalk, 2020, 11.19. Beard, C.B.; Eisen, R.J. Ch. 5: Vectorborne Diseases; https://health2016.globalchange.gov/vectorborne-diseases (accessed June 3, 2020).20. Byrne, M.P.; O’Gorman, P.A. Trends in Continental Temperature and Humidity Directly Linked to Ocean Warming. In Proceedings of the National Academy of

Sciences of the United States of America, 2018.21. Guyot, K.; Sawhill, I.V. Telecommuting will likely continue long after the pandemic; https://www.brookings.edu/blog/up-front/2020/04/06/telecommuting-will-

likely-continue-long-after-the-pandemic/ (accessed June 3, 2020).22. King, R. The plant-based diet sees greatest gains yet as meat shortage fears grow; https://fortune.com/2020/05/15/coronavirus-meat-shortage-plant-based-

food-vegan-vegetarian/ accessed June 3, 2020).

Kim Frauhammer is a degreed meteorologist and climate scientist who currently works as an air quality project consultant with SpiritEnvironmental, LLC in Denver, CO. E-mail: [email protected]

Disclaimer: The views expressed in this article are those of the author and are not necessarily those of the author’s employer and/orA&WMA.


Watson

628 Journal of the Air & Waste Management Association

Volume 52 June 2002

ISSN 1047-3289 J. Air & Waste Manage. Assoc. 52:628-713

Copyright 2002 Air & Waste Management Association

CRITICAL REVIEW

ABSTRACTThe 1999 Regional Haze Rule provides a context for this

review of visibility, the science that describes it, and the

use of that science in regulatory guidance. The scientific

basis for the 1999 regulation is adequate. The deciview

metric that tracks progress is an imperfect but objective

measure of what people see near the prevailing visual

range. The definition of natural visibility conditions is

adequate for current planning, but it will need to be re-

fined as visibility improves. Emissions from other coun-

tries will set achievable levels above those produced by

natural sources. Some natural events, notably dust storms

and wildfires, are episodic and cannot be represented by

annual average background values or emission estimates.

Sulfur dioxide (SO2) emission reductions correspond with

lower sulfate (SO4

2–) concentrations and visibility im-

provements in the regions where these have occurred.

Non-road emissions have been growing more rapidly

than emissions from other sources, which have remained

stable or decreased since 1970. Simpler models repre-

senting transport, limiting precursor pollutants, and

gas-to-particle equilibrium should be used to under-

stand where and when emission reductions will be ef-

fective, rather than large complex models that have

insufficient input and validation measurements. Ex-

amples of model-based source attribution show large

differences among estimates from various modeling sys-

tems and with ambient measurements.INTRODUCTIONMajestic views of distant mountains, lush forests, and even

man-made agricultural fields and cities are prime motiva-

tors for visits to U.S. national parks. For outdoor enthusi-

asts who enjoy hiking or skiing in wilderness areas, clear

air complements the awe-inspiring vistas. Urban dwellers

also value good visibility, as evidenced by the high pre-

miums attached to view lots and a conditioned associa-

tion between urban haze and pollution. Citizens and

politicians are often quoted in the press as “seeing” an

excessive brown pall of carbon monoxide (CO) and ozone

(O3) in their cities, even though these are colorless gases

that are visually indistinguishable from clear air. Public

association of visible haze with invisible pollutants reflects

reality, however. The same emitters that cause urban and

non-urban haze also generate adverse health effects,

damage forests and crops, soil buildings and vehicles,

contaminate lakes and streams, and change the earth’s

radiation balance. Visible haze is related to nearly every

other air pollution issue.The U.S. Environmental Protection Agency (EPA)1 has

identified visibility impairment as the best understood of

all environmental effects of air pollution. A long-estab-

lished physical and chemical theory relates the interac-

tion of light with particles and gases in the atmosphere

to removal of light from a sight path. This contrasts with

the effects of particles on health, for which statistical epi-

demiological relationships have been found but no clear

definition of the mechanisms has been established.2,3 On

the other hand, there is still much that is unknown, or

has been learned only recently, about how emissions from

specific sources produce light extinction and how that is

interpreted as good or poor visibility.Natural interactions of light with the atmosphere ac-

count for clear blue skies, rainbows, green flashes, blue

moons, and bright red sunsets that are highly valued or

interesting visual phenomena.4-13 Human observations,

photographs, and measurements show, however, that vis-

ibility is impaired more intensely and more frequently

than desirable in many urban and non-urban areas. Fog

and clouds are not considered part of scenic visibility im-

pairment, although they are important considerations for

highway, marine, and aviation safety. Some visibility im-

pairment is natural, resulting from the earth’s atmosphere;

wind-blown dust; volcanic eruptions; wildfires; plant parts;

biogenic hydrocarbons; sea salt; and nitrogen- and sul-

fur-containing gases released by lightning, land, and

water. Much of the haze, however, results from anthro-

pogenic emissions of particles and invisible gases trans-

formed to particles after emission. These particle

concentrations can be reduced given a sufficient invest-

ment of time and technology.The United States has embarked on a 65-year pro-

gram to return 156 national parks and wilderness areas

(Figure 1) to their natural visibility conditions. This will

be accomplished via a regional haze rule15 that implements

Section 169B of the Clean Air Act (CAA). The regional

Visibility: Science and RegulationJohn G. WatsonDesert Research Institute, Reno, Nevada

This year, we celebrate 50 years of A&WMA’s Annual Critical Review. For half a century, A&WMAhas solicited and published in the Journal of the Air & Waste Management Association (JA&WMA)an Annual Critical Review on a topic of critical importance to the air and waste management fields.Each year, the review author presents the Annual Critical Review at a special session held duringA&WMA’s Annual Conference & Exhibition. Each month in this space, we will take a moment to look back at a singular review of critical significance from the past 50 years.

Back In Time

This month, we spotlight the 32nd Annual A&WMA Critical Review by Dr. John G. Watson, which focused on regional haze and visibility. A Past Chair of the Critical Review Committee, Dr. Watson was well qualified for this review, having (at the time of this review) participated inmore than 50 visibility and aerosol characterization projects,and having published more than 140 peer-reviewed articleson visibility, optics, and related topics, some of which arecited in the review itself.

Dr. Watson noted that the 1999 Regional Haze Rule pro-vided a context for the 2002 review of visibility, the sciencethat described it, and the use of that science in regulatoryguidance. He noted that the scientific basis for the 1999 regulation was adequate; similarly, the definition of naturalvisibility conditions was adequate for current planning butwould need to be refined as visibility improves.

The review examined poor atmospheric visibility and whatcauses it. In her introduction to the review, Dr. Judith Chownoted that the review provided a historical perspective forusing visual and optical methods to monitor and regulatepollution. It traced the development of understanding aboutlight interactions with the earth’s atmosphere and its contam-inants, noting that several of these interactions (e.g., rain-bows, sunsets) are as highly valued as good views of theGrand Canyon. The review explained how the eye and brainsystem interprets what it sees and how the same view is per-ceived differently by different people. Federal guidance forimplementing the 1999 regulation is summarized and ex-amined with respect to its scientific justification and the re-search needed to implement it.

Dr. John Watson is a Research Professor in Atmospheric Science at the Desert Research Institute in Reno, NV. em

‘Those who ignore history are bound to repeat it.’

Past Critical ReviewsA complete list of A&WMA’s past Critical Reviews is available online at http://pubs.awma.org/journal/A&WMA%20Critical%20Reviews.pdf. To read and download any of the past Critical Reviews, log onto JA&WMA Online atwww.tandfonline.com/loi/uawm.

2002 Annual Critical Review: Visibility: Science and Regulationby John G. Watson

Layout and Design: Clay Communications, 1.412.704.7897

EM, a publication of the Air & Waste Management Association, is published monthly with editorial and executive offices at The Koppers Building, 436 Seventh Ave., Ste. 2100, Pittsburgh, PA 15219, USA. ©2020 Air & Waste Management Association(www.awma.org). All rights reserved. Materials may not be reproduced, redistributed, or translated in any form without prior written permission of the Editor. A&WMA assumes no responsibility for statements and opinions advanced by contributors to this publication. Views expressed in editorials are those of the author and do not necessarily represent an official position of theAssociation. A&WMA does not endorse any company, product, or service appearing in third-party advertising.

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