ILLINOIS POLLUTION

CONTROL

BOARD

October 21, 2009

STATE

WNOls

IN THE

MATTER OF:

)

PdIutoa

Control

Board

)

PETITION

OF ROYAL FIBERGLASS

)

POOLS, INC.

FOR AN ADJUSTED

)

AS 09-4

STANDARD FROM

35 ILL. ADM. CODE

)

(Adjusted Standard - Air)

215.301

HEARING OFFICER ORDER

Attached to this order

are the Board’s follow-up questions based on the parties’ responses

to the pre-hearing

questions. The parties may file written responses before hearing,

prepared

to address the questions at hearing.

IS SO ORDERED.

CM<

Carol Webb

Hearing

Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield, Illinois 62794-9274

217/524-8509

webbc@ipcb.state.il.us

AS 09-4

ROYAL FIBERGLASS

POOLS

BOARD

QUESTIONS

FOR PETITIONER

AND

IEPA

These

questions

are directed to

both Royal Fiberglass

Pools and the Illinois

Environmental

Protection

Agency

to be addressed

before or at

hearing.

uestion

19(b) of the

Hearing Officer Order

asked,

“Would

you also please comment

proposing

a condition that

would

require

a re-evaluation

of the adjusted standard

if the ozone

NAAQS

is revised.”

Royal responded

that

“a reevaluation

would be of little value.”

Royal

Resp.

HOO

6-4-09

at 7.

The

Agency responded, “IEPA

believes

that

a condition requiring

re-evaluation

is necessary

in this rulemaking.

. .If

changes are deemed

necessary,

the

Illinois EPA will initiate

rulemaking

before the Board

at that time.”

Ag. Resp. to HOO

6-4-09 at 2.

Would

the Agency please

clarify

if this

comment,

is intended

to suggest that

a condition

should be

included

the adjusted standard

language

requiring

the re-evaluation

of the

adjusted

standard

if there

is a change in

the ozone? Or

was this comment

simply

to clarify

that

a rulemaking is the

usual

course

of action when changes

are deemed

necessary?

Question

21(d)

of the Hearing Officer

Order asked,

“Please comment

on the results of

the

Air Quality Impact

Analysis

the ozone increment

were

added to

the 8-hour background

air

quality reading

of the

highest

measured ozone

concentration

from the past 4 consecutive

years.”

Royal

responded

that Royal

does not have ready

access

the 4-year data and

that the

Scheffe

method “is not mathematically

compatible

with assessments

of eight-hour

average

impacts.”

Royal

Resp.

to HOO 6-4-09 at

Royal characterized

the

air quality impact from

the

adjusted

to be “negligible.”

Royal Resp.

to HOO

6-4-09

at 7. Royal

estimated

the

1-hr average ozone

increment to be 4

ppb.

The

Agency stated

that it

believes

the air quality

impact

to be

“negligible” and (later

in its

response

to 21(d)) that,

“USEPA has not

provided more recent

guidance to

address ozone

impacts on an 8-hour

basis.”

The Board directs the

parties to the

following documents

and

asks for

further clarifications

regarding the air quality

impacts.

USEPA GUIDANCE

USEPA

guidance

regarding the estimation

of the

8-hour

ozone increment

from the 1-

hour increment using

a scaling

factor

of 0.7

(+1-

0.2).

[See USEPA, Support Center

for Regulatory Air Models. Screening Procedures

for

Estimating the Air

Quality Impact ofStationary Sources

- Revised. Research Triangle

Park, North Carolina.

USEPA-454/R-92-019. October 1992

page 15.

http://ww.epa.

gov/oppt/exposure/presentations/efast/usepa 1 992b spforestimagi

of ss.pdf (Attachment 1.)]

[Also

see discussion of Scheffe Method and

the two footnotes on Page 5 of 7 of the

US Department of Agriculture Letter dated 12-22-2003.

http://gc.energy. gov/NEPA/nepa

documents/EIS/eis0342/letter2

.pdf (Attachment 2.)]

OZONE MONITORING

DATA

The ozone concentrations

monitored during 2004-2007 for

the

1-hour and 8-hour

averaging

periods appear

in the Illinois Annual Air

Quality Reports available on

JEPA’s website.

2007:

http://www.epa.state.il.us/air/air-quality-report/2007/air-ciuality-report-

2007.pdf,

2006: http://www.epa.state.il.us/air/air-quality-report/2006/air-guality-report-

2006.pdf,

p.4.8

2005:

http://www.epa.state.il.us/air/air-quality-report/2005/air-guality-report-

•

2005.pdf,p.51

2004: http://www.epa.state,il.us/air/air-guality-report/2004/air-guality-report-

Q4.j2ciLp.50

(See

Attachment

3.)

(a)

In light of the information

above, please comment on the results of the Air

Quality

Impact Analysis if the scaled ozone increment were

added to the 8-hour background

air quality reading

of the

highest measured ozone concentration

from the most

recent 3 years.

(b)

Please comment on how this

value relates to the 75 ppb 8-hour NAAQS.

(c)

Please indicate if the air quality impact

from the adjusted standard would still

considered negligible.

Question

22 of the Hearing Officer Order

asked,

“Since

Hamilton County ozone monitoring

stations

already show exceedences

of the 8-hour ozone standard

of 75 ppb, would you please

comment on including a condition

in the adjusted standard limiting

Royal Pools VOM

emitting operations on ozone

action

days where ambient conditions are

likely to exceed the

ppb 8-hour ozone standard?”

Royal

responded in opposition to such a condition “since it

would be unworkable from

logistical standpoint. It would

require Royal to monitor every

day whether the ambient

conditions are ‘likely to exceed’ the

ozone standard. This raises the question

what

‘likely

exceed’ means. More importantly,

it would require Royal

then

contact its employees

daily basis to inform them whether

to come into work that day.” Royal Resp. HOO 6-4-09

8-9.

The Agency responded

that the JEPA has no objection to such a condition. Ag. Resp. to

HOO 6-4-09 at 2-3.

Again, the

Board

directs the parties

the following

information and asks for

further

comments

on a potential condition in the adjusted standard

limiting Royal Pools VOM

emitting

operations on ozone action days.

AIR QUALITY IMPACT ANALYSIS

Royal’s Air Quality Impact

Analysis

is based on the Scheffe Method: “VOC/NOx

Point

Source

Screening

Tables” by Richard D. Scheffe, September 1988.

http

://ndep.nv.gov/bapc/download,’modellscheffe.pdf

The

Scheffe document states,

“To determine an ozone impact the user is required

apply best estimates

of maximum daily

NMOC emissions rate, and estimated annual mass

emissions

rates ofNMOC and NOx which are

used to

determine

NMOC/NOx ratio for ascribing the applicable column in Table 1 or 2. The

reasons for basing

application on daily maximum NMOC emissions rates

are (1) to avoid underestimates

resulting from discontinuous operations

and (2) the underlying modeling simulations are

based on single day

episodes. The NMOC emissions rates in Tables 1 and 2 are given on an

annual

basis; consequently the user must project daily maximum to annual

emissions rates illustrated

in the example application given below. One

purpose of the technique

to provide

simple,

non-resource intensive

tool; therefore, annual NMOC/NOx emissions ratios are used because

consideration

of daily

fluctuations

would require a screening application

applied

to each day.” P. 5-6.

(a)

Since the Scheffe method bases the ozone increment on the daily maximum

NMOC

emissions rate, would

you

please

comment on the calculation below estimating the

daily impact of the ozone increment of 4

ppb

as represented in the petition?

29.76 tons / year x 2000 lb

ton

(52 weeks

/ year x 5 days / week) =

229 lb

/ day

maximum

OZONE ACTION DAYS

Ozone Action Days (aka: Air

Pollution Action Days) are set forth by the Illinois

Partners for Clean Air. (http://www.cleantheair.org/overview.shtml)

An ozone

action

day is

declared when the Air Quality Index is “unhealthy”

levels of 100

greater.

The

Air Quality Index can

be calculated by going to the Air Quality Index Calculator

http ://www.airnow. gov/index.cfrn?actionaQi

calc.conc_agi_calc.

When ozone

concentration

ppb, the Air Quality

Index

is 100.

IEPA and USEPA

partner with

others on providing

Local Air Quality

Conditions

and

Forecasts on the

website

AirNow.gov.

Besides

current conditions,

the AirNow.gov

website

provides

forecasts

for the next day.

Although air quality

information

for

Jefferson

and Hamilton County

are

not available

on this website,

such information

available

for

the nearby

St. Louis (Metro-east)

area. (http://www.airnow.gov/

Select

State:

Illinois, Select

Region: St. Louis

(Metro-east)).

The AirNow.gov website

also

provides

“EnviroFlash”

for prompt

notification

of forecasted

ozone action

days

through

or cell

phone.

(http

://www.airnow.gov/index.cfin?action=aimow.loca1

state)

(b)

Although

Royal’s emissions

are not considered

in the St.

Louis (Metro-east) area,

the

local

air monitoring

station for Royal in

Hamilton

County

does indicate that

days

occur

where the ozone

concentrations are

above 75 ppb.

This results in an Air

Quality

Index greater than

100.

While Ozone

Action Days are

not

declared

for

Hamilton

or Jefferson

County, would the Agency.

please clarify

if these days typically

coincide

with ozone action

days for the

St. Louis (Metro-east)

area?

(c)

Since

the Agency

has

indicated the IEPA

would have

no objection to including

condition

regarding VOM

limitations

on ozone action

days,

would

the

Agency please

elaborate on how this

might be done?

Does

the Agency recommend

numeric

emission limitation?

so,

should

VOM

emissions

be limited to 229 lb/day

ozone

action days in order

ensure the daily

environmental

impact

of the adjusted

standard

is no

greater than what

was represented

in the petition as

“negligible”?

Does

the

Agency

suggest a different numerical

limit

a different way to

limit

VOM emissions

on ozone

action

days?

To show compliance

with

this

possible condition,

does the Agency

believe

the

VOM limitation

could be

documented simply

through recordkeeping

of Royal’s operations

ozone

action days without

additional air

monitoring?

Is air quality

information

available to Royal in

real time

format

for the

Hamilton

air monitoring station?

so, would

it be possible for

Royal

rely

on such information

to limit its VOM

emissions?

If not,

does the

Agency

recommend that

Royal rely

on forecasts made

for

the St. Louis (Metro-east)

area for

ozone action

days

since

this

is the

closest monitoring

area that provides

forecasts

and

alerts?

Would

the

Agency

recommend

that Royal

observe ozone

actions days as those

days

where the

St.

Louis

(Metro-east)

air monitoring

system measures

an Air

Quality Index

of 100 or greater?

(d)

Would

Royal please

comment

on how it

might comply

with this

possible

condition?

1) In order

to ensure

the

daily environmental

impact

of the

adjusted

standard

no greater

than

what

was

represented

in the

petition as

“negligible”,

would

Royal please

consider

ways to

track

operations

showing

how VOM

emissions

are limited

might be

suggested

by the

Agency

(such

as no

than

229

lb/day) on

ozone

action

days?

Would

Royal please

address

the

steps it

would

take to

determine

when

there will

an ozone

action

day?

Would

Royal please

address

how it would

keep

records

of its operations

(withOut

additional

air

monitoring)

oa ozone

action

days to

enure

compliance

with

this

condition?

CERTIFICATE OF SERVICE

It is

hereby certified that true copies

of the foregoing order were mailed, first

class, on

October 21, 2009,

to each of the persons on the

attached service

list.

It is hereby certified

that a true copy of the

foregoing order was hand delivered to the

following

on October 21, 2009:

John

T. Therriault

Illinois Pollution

Control Board

James

R. Thompson Center

100

Randolph

St., Ste. 11-500

Chicago,

Illinois 60601

CMcr WMr

Carol

Webb

Hearing Officer

Illinois Pollution Control Board

1021

North Grand Avenue East

P.O. Box

19274

Springfield,

Illinois 62794-9274

217/524-8509

webbc@ipcb.state.il.us

AS 2009-004

Charles

Matosian

IEPA

1021

North

Grand

Avenue

East

P.O.

Box 19276

Springfield, IL

62794-9276

AS 2009-004

Brandon

W. Neuschafer

Bryan

Cave,

LLP

One

Metropolitan

Square

211

North

Broadway, Suite

3600

St. Louis, MO

102-2750

AS 2009-004

Dale

A. Guariglia

Bryan Cave, LLP

One

Metropolitan

Square

211

North Broadway,

Suite 3600

St. Louis,

MO 63

102-2750

ATTACHMENT 1

Excerptsfrom:

USEPA,

Support

Center for Regulatory

Air Models.

Screening

Procedures

for

Estimating

the Air Quality Impact

ofStationaiy

Sources

Revised.

Research

Triangle

Park,

North Carolina.

USEPA-4541R-92-019.

October 1992.

http:IIv’ww.epa.gov/oppt/expepesentations/efastIusep

1992b

for estim

agi

of ss.pdf

EPA-454/R-92-O

Screening

Procedures

for

Estimating

the

Air

Quality

Impact

Stationary

Sources,

Revised

U.S.

ENVIRONMENTAL

PROTECTION

AGENCY

Office of

Air and

Radiation

Office

Air Quality Planning

and

Standards

Research Triangle

Park, North

Carolina

27711

October

1992

.5u, account

for

stack

tip

downwash

using

Equation

4.7.

elevated terrain is

be accounted

for, then

reduce the computed

plume height

for

each

wind

speed

by the

maximum terrain

elevation above

stack

base.

For each

wind

speed and stability

considered

in (1), find

the maximum 1-hour

xuIQ

from

Figure 4-2

(rural)

or 4-3

(urban).

Compute the

maximum 1-hour

concentration

for each

case, using

and select

the highest

concentration computed.

For

low-level

sources

with

plume

rise

(he = ha),

find the

maximum 1-hour

XuIQ

from Figure 4-2

(rural case - assume

stability)

or 4-3 (urban case -

assume

stability).

Compute the maximum

1-hour

concentration,

assuming

a lOm wind speed of

rn/s. Adjust the

wind

speed

from lOm to stack

height using

Equation 3.1

and the

appropriate exponent.

Step 5.

Obtain concentration

estimates for

the averaging

times

of concern.

The

maximum

1-hour

concentration

(xi)

is the

highest

the

concentrations

estimated

Step 4, Procedures

(a) - (c). For

averaging

times

greater than

1-hour, the

maximum

concentration

will generally

be less than

the

1-hour

value.

The

following

discussion

describes how

the maximum

1-hour value may be

used to

make

an estimate of

maximum

concentrations for

longer

averaging

times.

The

ratio between a longer-term

maximum

concentration

and a 1-hour

maximum will

depend upon

the

duration

of the

longer averaging time,

source

characteristics,

local

climatology

and

topography,

and the

meteorological

conditions

associated

with

the

1-hour maximum.

Because

of the many ways

in which such

factors

interact,

it is not practical to

categorize all

situations

that

will

typically

result

in any

specified

ratio

between

the

longer-term

and

1-hour

maxima.

Therefore,

ratios

are

presented

here

for a

“general

case”

and

the user

is givensome

flexibility

to adjust

those

ratios

represent

closely

any

particular

point

source

application

where

actual

meteorological data are

used.

obtain

the

estimated

maximum

concentration

for

3-,

8-,

24-hour

annual

averaging

time,

multiply

the

1-hour

maximum

(Xi)

by the

indicated

factor:

Averaging

Time

Multiplying

Factor

hours

0.9

±0.1

hours

0.7

±0.2

hours

0.4

±0.2

Annual

0.08

±0.02)

The

numbers

parentheses

are

recommended

limits

which

one

may

diverge

from

the multiplying

factors

representing

the general

case.

For

example,

aerodynamic

downwash

terrain

is a

problem

at the

facility,

the

emiséion

height

is very

low,

it may

be necessary

increase

the

factors

(within

the limits

specified

in parentheses).

the

other

hand,

the

stack is

relatively

tall

and

there

are

no terrain

downwash

problems,

may

appropriate

decrease

the

factors.

Agreement

should

be reached

with

the

Regional

Office

prior

to modifying

the factors.

The

multiplying

factors

listed

above

are

based

upon

general

experience

with

elevated

point

sources.

The factors

are

only

intended

rough

guide

for

estimating

maximum

concentrations

for

averaging

times

greater

than

one hour.

degree

of conservatism is incorporated

the

factors

provide

reasonable

assurance

that

maximum concentrations

for

3-,

8-, 24-hour

and

annual

values

will

not be

underestimated.

Step

Add the

expected

contribution

from

other

sources

the

concentration

estimated

Step

Concentrations

due

other

sources

can

estimated

from

measured

data,

computing

the

effect of

existing

sources

air

quality

the

area

being

studied.

Procedures

for

estimating

such concentrations

are

given

Section

4.5.5.

this point

the

analysis,

a first

approximation

of maximum

short-tenn

ambient

ATTACHMENT

Department

Agriculture

Letter dated

12-22-2003

(See discussion

of Scheffe

Method and

the

two footnotes on

Page

5 of

http://gc.energy.gov/NEPAlnepadocuments/EIS/eis0342/letter2.pdf

tjnftcd

Slatas

Departotent

Arkutlure

Letter

Perest

P*ctflc

Serice

Northwest

,.O,13os3623

iIiaad,

971083623

333

FIrst

Avenue

Pcrthd,

97104

File

CodL25g0

Responses

Letter

Philip

Sanchez

Superintendent

Uruatilla

Agency

Bureau

Indian

Affairs

P.O.

Box

520

46807

Street

Peudleton,

P7801

DearMr

Sanchez:

Dste:

December

22,2003

The

Air

Resources

portion

the

WANAPADraft

ELS

has

been

reviewed

the

following

comments

aresubmitted

for

your

review

anti

consideration.As

result

potentially

adverse

effects

Class

(areas

and

the

Columbia

River

GorgeNational

Scenic

Area

(CRGNSA)

steadily

increasing

pollutantloadings

the

Columbia

Basinthis

office

hasa

well

established

interest

and

concern

ova’

new

basin

emission

sourcessuch

WANAPA.

did

notreceive

copy

the

draft

document

and

we’renot

aware

its

existenceuntil

late

the

comment

period.

Holiday

schedules

are

also

factor

leading

these

comments

being

somewhat

general

and

cursory

and

perhaps

not

justice

issuesdescribed

below.

Within

50km

radius

theproposed

WANAPA

facilitythere

has

been

substantial

industrial

poinl

sourceemission

growth.

The

most

significant

theBoardmanCoal

Fired

Power

Plant

built

97P

-since

that

time

large

number

smaller

sources

have

been

built

and

number

gas

fired

power

plants

have

recent

permits

butare

not

yetconstructed.

While

the

WANAPA

facility

would

bee

significant

addition

this

mix

sources

its

impact

alone

relatively

small

comparison

the

total

air

pollution

this

area.

Under

NEPA

cumulative

effect

analysis,

particularly

the

power

plant

sources

required.

The

WANAPA

draft

document

does

not

adequatelyrecognize

this

pro-existing

problem-

put

these

issues

perspective

full

cumulative

analysis

needed.

not

discount

the

risk

human

health

from

this

cumulative

effect,

however

land

management

agency,

ourconcenis

arc

focused

the

effect

from

WANAPA

end

the

surrounding

array

misting

and

permitted

sources

cultural

resources,

visibility,

andacid

(sulfur

nitrogen)

deposition

the

Columbia

River

Gorge

National

Scenic

Area

and

the

surrounding

Class

wilderness

and

parks.

This

cumulative

effect

should

analysed

and

disclosed.

The

analysis

provided

the

draft

document

borrowed

heavily

from

the

WANAPA

PSD

permit

application

analysis.

The

analysis

required

under

NEPA

compared

that

normally

provided

for

PSD

quite

different,

PSD

the

analysisfocusesprimarily

the

individual

snurce

effects

with

minimalamount

analysis

the

contribution

effects

Class

areas

from

the

background

sources

background

conditions.

being

single

source

focused

PSI)

analyses

tend

discount

and

minimize

effects

since

the

intent

secure

permit

for

client.

The

intat

under

NEPA

full

disclosure

environmental

effects.

This

NEPA

analysis

reads

PSD

application

and

such

inadequate-

particularly

the

cumulative

effect

perspective

discussed

the

paragraph.

z-i

cumulative

lmoacts

Class

Areas.

Class

areasare

areas

such

National

Parks

and

Wilderness

Areas

that

are

designated

for

special

protectionunder

the

Clean

Air

Act.

Impacts

PM,

visibility,

adrate,

and

sulfate

deposition

Class

areasresulting

from

Wanapa

have

been

evaluated

using

the

CALPUFF

dispersion

modelingsystem

and

its

associated

pre-

and

post-

processing

algosithms.

The

information

included

below

also

avaibble

the

PSI)

application,

filewith

the

USEPA.

Impacts

wereassessed

the

following

Class

areas:

•

Eagle

Cap

Wilderness

Area

•

Goat

Rocks

Wilderness

Area

•

Mount

Adams

Wilderness

Area

•

StrawbcrsyMountain

Wildcrness

Area

•

Mount

HoodWilderness

Area

Columbia

River

Gorgc

(not

technically

Class

area,

but

cvaluatcd

the

Class

inspect

analysis)

Air

quality

impacts

and

the

Class

arms

are

provided

the

Final

EIS

Section

3.5.2.2.

Thy

andwet

deposition

resultsfromWanapa

are

summarized

Tables

and

are

compared

appropriate

depositionsignificanee

thresholds

established

Federal

Land

Manager

guidauce

Acid

deposition

the

Columbia

River

Gorge

particular

interest

the

analysis,

acid

deposition

affects

not

only

natural

resources,

but

also

cultural

rescueces

such

rock

art

and

near

the

Columbia

River

Gorge.

The

results

the

modeling

analysis

demonstrate

that

potentialimpacts

from

Wanapa

would

far

below

the

dcpositionsignificance

thresholds,

including

impact

less

than

percent

the

significance

threshold

she

Columbia

River

Gorge.

2-1

Caring

(or

She

Land

and

ScrvtagPeopk

2-1

Cout’d

Responses

Letter

TsLE

NrnocEN

DEPOS1IION

ANALYSIS

RISuL1s

Maxlnujm

Nitrogen

Locatiei

Maximum

Impact

DepesitlouFlux

Class

Area

(kglha/yr)

(km)

(kin)

Eagle

Cap

(L000228

408.965

201.127

GoatRocks

0.000102

113.990

286.053

RIver

Gorge

0.000247

144.100

197.499

Mount

Adams

0.000173

106239

255.923

Mount

Hood

0.000167

106.373

167.993

Strawierry

MountaIn

0.000124

331.326

68.133

ThaLE

SULRJR

DPosrnON

ANALYSIS

RESULtS

Maxituwn

Sulfur

Location

Maximum

Impact

Deposition

Flux

axis

Area

(kg(balyr)

(kin)

Eagle

Cap

0.000048

408.965

201.127

GoatRocks

O.oooozi

113.990

286.053

River

Gorge

0.000048

144.100

i97.499

Mount

Adams

0.000036

106.239

255.923

Mount

Hood

0.000038

106.373

167.993

SirawherryMountahi

0.000026

321.326

68.133

Visibility

impacts

from

Wanapa

are

summarized

Table

and

compared

the

percent

extinction

criterion

established

Federal

Land

Managerl

guidance.

This

threshold

represents

perceptible

diange

visibility.

VISIBIUTY

ANALYStS

RESUL1S

Responses

Letter

?b,

LocadonofMaxlmune

Maximum

lee

act

Date

Impact

Maximum

lof

Days

ClasslArea

(%)1

(kin)

(ken)

Impact

>5%

Eagle

Cap

0.77%

450.411

149.251

4/14/1998

Goat

Rocks

1.16%

120.832

286.134

—

10/111998

RiverGorge

1.97%

143.958

201494

1(W26/1998

Mount

Adams

2.37%

110.874

255.953

1/4(1999

Mount

Hcod

0.94%

103.322

179.574

1/3(1999

Sfrawi>eny

MounTain

1.16%

328,837

68,519

1/2411999

The

modeled

changes

the

extinction

rate

from

Wanapa

are

less

than

the

percent

threshold

each

Class

area

ali

days

the

year.

Though

the

exllclloei

rate

1mm

Wanapa’s

Impacts

below

(he

appropriate

threshold,

conducted

additional

revIew

assess

the

cumulative

effect

visibility

the

Class

n’eas

from

this

project

and

other

past,

present,

and

.aasonthly

foreseeable

trojects

the

Northwest.

The

reaults

this

analysis

are

presented

below.

tThe

Federal

Land

Managers

include

the

land

managemeni

agendes

under

the

U.S.

Department

the

Interior

(U.S.

Forest

Service,

BUd,

and

National

Pail,

Service).

Several

air

quality

modeling

analyses

have

been

conductedby

the

BonneilIe

Power

AdnuinlsiraUon

(BPA)

assess

the

cumulative

Impacts

power

generation

projects

the

Northwest

and

their

Impacts

Class

areas.

The

BPA’s

Phase

sbdy

examined

the

air

quality

Impacts

proposedcombustion

turbines

BPA’s

servica

area

the

Northwest.

Two

scenarios

were

modeled

this

study:

worst-case

scenario

that

Included

the

Impacts

from

all

facilitIes

(totaling

24.000

generation),

and

second

scenarIo

that

Included

impacts

from

facilitIes

(totalIng

11,000

generation).

Both

analyses

account

for

much

future

power

generation

development

than

cirreatly

expected

the

Northwest.

The

results

the

BPA

study

showed

olatIons

any

National

Ambient

Air

Quality

Standard

for

cdtesia

pollutants

such

SO.

NO5,

and

PMie

The

study

did

however.

Indicate

that

visibility

degradation

was

potential

area

Vah,.i

need

,det’maaI

tad’

the

muksam

rre,Ieed

fefow

tI,i

.xx5an

fo,flIc*,a.

‘Bonneville

Power

Authority,

“Phase

Results

—

Reglonal

AIr

Quality

Modeling

Study,”

August

2001.

Responses

Letter

2-1

Cont’d

Several

air

quality

modeling

analyses

have

been

conducted

the

Bonneville

Power

Admlnis*iation

(BPA)

assess

the

cumulative

impacts

power

generation

projects

inthe

Noth

;r4

their

linpacison

Class

areas.

The

BP’s

Phase

study

examined

the

air

quality

impacts

proposed

combustion

Iuibines

BPA’s

service

area

the

Ncithwest.

Two

scenarios

were

modeled

this

study:

worst-case

scenario

that

included

the

impacts

from

all

facilities

(totaling

.000

generation),

and

second

scenario

that

included

impacts

from

facilIties

(totaling

11,000

generation).

Both

analyses

account

for

much

future

power

generation

development

than

currently

expected

the

Northwest.

The

results

the

BPA

study

showed

violaitore

are’

National

Ambient

Air

Quality

Standard

for

criteria

pollutants

such

SO5,

NO5,

and

PM10

The

study

did,

however.

Indicate

that

visibility

degrathdon

was

potential

area

concern.

Since

the

Phase

study,

additional

studies

regional

visibility

have

been

performed

that

removed

power

development

projects

that

have

since

been

canceled

from

the

list

sources

considered

the

modeling

studies.

recent

study

for

the

Plymouth

Generating

Facility

evaluated

impacts

from

the

following

baseline

source

group

ott

nearby

Class

areas.t

Bonnevlile

Power

Authority,

“Phase

Results

—

Regional

Air

Quality

ModelingStudy,”

August

2001.

2PI,c,uth

GeneratingFacility,

“Contribu(lon

Regional

Haze.”

The

Plymouth

Generating

Facility

study

was

evaluated

iceing

the

same

MM5

meteorological

data

the

Class

area

Impact

analysis

litr

Wanapa.

Additionally,

die

range

dates

for

the

meteorological

data

from

the

two

analyses

viarch

19.

1998

March

16.

1999)

Identical.

For

these

reasons,

the

results

from

these

two

analyses

may

compared

day-by-day

basis.

For

every

date

that

the

Plymouth

Generating

Facility

analysis

resulted

visibility

Impact

greater

than

percent

any

Class

area,

the

impacts

from

Wanapa’s

analysis

for

that

same

data

are

provided

for

comparison

Tables

and

Dates

with

impacts

front

Wanapa

greater

than

0.4

percent

are

bolded

the

tables.

Responses

Letter

Tabt_

Wanapa

Energy

Center

and

Cumulative

VisibilIty

Impacts

Comparison

•

Fredonia

Facility

•

Rat

lidrum

Power

•

Fredcrlckson

Power

Coyote

Springs

Goldendate

Energy

Project

•

Hermiston

Power

Project

Chehalls

Generating

Facility

Goidendale

(The

Cuffs)

•

Big

Hanford

Project

•

Mint

Farm

Generation

•

Wallula

Power

Project

•

Satsop

Project

—

Phase

•

Satsop

CI’

Project

—

Phase

Wanapa

Energy

Center

Plymouth

Generation

‘

Cumulative

Wanapa

Class

lArea

Season

Date

ab,,,(%)

ColumbiaGorgeNatlonslSeenjcAres

Fail

1016/1998

7.99

0.00

‘DolumbiaGorgeNstional

Scenic

Area

Fall

101211l998

5.05

0,00

Columbia

Gorge

National

Scenic

Area

Fail

10130/1998

7.10

t,30

(‘olumbiaGorge

National

Scenic

Area

Fail

11/311993

8,52

0,00

Columbia

Gorge

National

Scenic

Area

Fall

1/3/1998

5.84

0.00

Numbia

Gorge

National

Scenic

Area

Winter

12133/1998

1251

0,00

riumbia

Gorge

National

Scenic

Area

Winter

11311999

8.60

itt

‘cCapWildcmcnsArea

Fall

9)29/1998

5.15

026

AdamsWtlderneasA,’ea

Winter

12/2311998

6.94

1.71

tAdamsWjiderneenArea

Winter

114/1999

5.01

2.37

Hood

Wilderness

Area

Fail

10119/1998

5.29

0.57

Hood

Wilderness

Area

Fall

1113/1998

7,53

0.00

Hood

Wilderness

Area

WittIer

12/22/1998

6.82

0.00

Hood

Wilderness

Area

—

Winter

12/2311998

8.03

0.00

Hood

Wilderness

Area

Winter

1/211999

5.00

0.93

tHoodWildernesnArea

Wittier

1/3/1999

16.70

0.94

‘Tc”OrwndWii,.”as.&

an.Uh.,*s.e

teo.ent.raqea,.a

h..a44te4..,d..

l’able_

Wanapa

Energy

Center

and

Cemubilve

Visibility

tinpacta

Comparison

Winter

Days

with

Oii-FlrlngalFredeala

and

Chehaib

Facilities

Cumulative

Wanapa

Class

Area

Season

Date

—

Mo,,,

1%)

Mo,

(%)

‘umbiaGorgeNationalSeetsicAxea

Cil-FiredWinter

12/17/1998

5,57

0.00

‘umbiaGorge

National

Scenic

Ares

Oil-Fired

Winier

t2/23/l99F

12.51

000

‘serbia

GorgeNational

Scenic

Area

Oil-Fired

Winter

1/3/1999

8.60

1.11

‘serbia

Gorge

National

Scenic

Area

Oil-Fired

Winter

1)16/1999

5.13

0.03

ont

Roclrs

Wilderness

Area

Oil-Fired

Winier

1/3/1999

6,15

0.01

ant

Rocks

Wilderness

Area

Oil-Fired

Winter

1123/1999

7.20

0.00

Mama

Wlidemesu

Area

Oil-Fired

Winter

12/23/1991

6.95

(.7t

Adami

Wilderness

Area

Oil-Fired

Winier

1/1/1999

6.04

0.00

MamiWildernessArea

Oii-FfredWintee

1/411999

5.02

2.37

t.HoodWiidcni*ssArea

Oil-FircdWiriter

12/22/1998

6.82

0.00

Hood

Wilderness

Area

Oil-Fired

Winter

12123/1998

803

0.00

HoodWilderness

Area

Oil-Fired

Winter

1/2/1999

5.76

0.93

t,HoodWildcrrtessArea

Oii-FiredWinter

1/3/1999

16,72

0.94

The

total

number

days

with

extinction

rate

changes

from

Wanepu

greeter

thttn

0.4

percent

end

with

cumulative

impacts

greater

than

5cr

percent

are

uunsmnrizcd

Table

—.

Responses

Letter

2-1

Cou(d

The

total

number

days

with

exUnctlon

rate

changes

from

Wanapa

greater

than

0,4

percent

and

with

cimiulative

Impacts

greater

than

perceat

are

summarized

Table

Tabte

Total

Days

with

WasLapa

Energy

Center

Imparts

>0.4

pcesiI

end

Cumulative

Impacts

percent

Days

with

Wanapa

Energy

Center

Contribution

Days

with

Cumulative

Days

with

Cumulative

Change

Extinction

Change

Exthactlon

ClassI

Area

>5%

>10%

Eagle

Cap

Wilderness

Area

Goat

Rocks

Wilderness

Area

Columbia

Gorge

National

Scenic

Area

Mt.

AdamsWilderness

Area

Hood

Wilderness

Area

Strattier,y

Mowitain

Wilderness

Area

Letter

Continued

From

auitc

long

term

monitoring

the

Columbia

River

Gorge

there

ample

evidence

existing

adverse

effects

visibility

(from

IMPROVE

monitoring),

ecosystem

disturbance

from

lichen

monitoring,

and

cultural

resources.

Additionally

there

ample

evidence

risk

from

higis

ozone

concentrations.

Existing

deposition

rates

the

Gorge

arc

approximately

IO-

kgha/yr

for

both

sulfur

end

nitrogen.

Comparing

these

rates

critical

load

estimate

1-2

kg’ha/yr

evident

that

deposition

rates

are

well

excess

that

needed

maintain

healthy

undisturbed

ecosystem

conditions.

Very

real

concern

exists

about

barns

other

cultural

resources

(such

rock

art)

from

the

acidic

component

ofthis

deposition—

the

federal

agency

with

responsibility

for

the

Columbia

River

Gorge

National

Scenic

area

the

Treaty

Rights

Tribes

have

requested

our

assistance

protecting

these

cultural

resources

from

the

damaging

effects

air

pollution.

winter

the

Gorge

the

primary

outlet

polluted

stagnant

air

draining

out

the

Columbia

Basin.

With

the

proximity

the

river

channel,

which

acts

natural

drainage

channel

inwinter,

substantial

contribution

this

problem

comes

from

thc

industrialized

region

around

Umatilla.

There

significant

body

information

well

documentation

prior

NEPA

documents

detailing

these

concerns.

These

issues

ore

not

recognized

addressed

the

Air

Resources

portion

the

WANAPA

Draft

EJS

document,

Conversely,

summer

there

evidence

high

ozone

levels

the

Eastern

Gorge-.

under

westerly

summertime

flow

this

ozone

background

transported

into

the

basin

and

potentially

made

worse

basin

emission

sources.

Limes

the

prevailing

flows

reverse

summer

and

higher

ozone

concentrations

arc

re-circulated

back

into

the

gorge

and

the

east

slopes

the

adjacent

Cascades

Class

areas.

While

WANAPA

small

incremental

contributor

this

potential

problem

does

contribute

and

such

analysis

and

disclosure

the

issue

should

provided.

talce

the

protection

cultural

resources

the

CRONSA

very

seriously.

This

issue

the

Umatilla

Tribe,

BIA,

and

the

USDA

common

grousd.

hope

you

will

agree

itis

issue

that

deserves

fair

review.

appreciate

this

opportunity

our

concerns

with

you.

Please

include

this

office

further

distributions

inlbrniaiion

pertaining

this

NEPA

review.

Responses

Letter

2-2

analysIs

Increases

ozone

concentrations

resulting

from

Wanapa

emissions

was

conducted

and

avallable

(‘rem

theUSEPA

the

Wanapa

PSD

application.

Though

ozone

not

directly

ernined

from

Wanapa,

increases

ozone

concentrations

may

result

from

pbotochemaai

reactions

Involving

VOC

and

from

the

proposed

facility.

Wlndroses

the

appropriate

meteorological

data

(Uniatilla

Amsy

Depot

and

Walls

WaUs

RegIonal

AIrport)

for

1995

tlsough

1999

were

analyzed

for

the

months

that

are

typically

designated

“ozone

season”

(April-Septemlsei.

The

ndroses

show

that

winds

measured

these

stations

during

the

ozone

season

months

frosts

1995

through

1999

blew

from

the

southwest

approximately

percent

the

lime

(up

percent

for

some

years),

which

than

any

other

direction.

Wlnth

blew

from

thenortheast

less

than

approximately

percent

the

tinte.

Given

the

relatindy

flat

terrain

northeastern

Oregon

and

southeastern

Washington,

not

expected

that

the

distribution

wind

directions

would

change

appreciably

from

the

meteorologIcal

stations

and

the

proposed

site

(approximately

mIles

from

the

Umatilla

Army

Depot

and

approximately

miles

southwest

the

Walla

Walls

NWS

site).

Since

the

proposed

facility

located

the

northeast

the

Columbia

Rhr

Gorge

and

Mount

Hood

Class

arere.

emissions

from

the

proposed

Wanapa

Ener,

Center

can

expected

blow

towards

these

areas

approximately

percent

the

time

during

the

ozone

season.

Ozone

(Os)

impacts

from

the

proposed

Wanapa

Energy

Center

are

enimatod

using

the

Schcffc

Method.l

Based

upon

the

estimated

NO2

and

VOC

emissIons

from

the

proposed

Wanapa

Energy

Center,

the

I-how

ozone

increment

may

estimated.

The

8-hour

ozone

increment

for

the

proposed

facility

estimated

from

the

1-hour

increment

using

scaling

fact

0.7.2

The

results

the

analysisshowed

that

Wanapa

would

bye

maximum

ozone

impacts

0.0119

ppm

(8-hour

average)

and

0.0171

ppm

(1-hour

average).

National

Ambient

Quality

Standards

for

the

hour

average

0.080

ppm

0.120

ppm

forthe

i-how

average.

tThc

Scheffe

Method

screening

procedure,

based

upon

series

applicatIons

the

Reactive

Plume

Model-Il

(RPM-il),

which

calculates

the

i-hour

Increment

due

VOC

and

NOx

point

sources.

Sclseffe.

RIchard

1).,

VOC/M),

Palm.

USEPPt.

Office

Air

Quality

Planning

and

Standards.Research

Triangle

Park,

North

Carolina.

EPA-45012-78-027R.

September

1998.

USEPA.

Support

Center

for

Regulatory

Models.

Sc,mniug

Procethire.r

far

Ecliniating

ihe

Quality

!nguxcr

&aliornry

Soiaw

Revised.

Research

Triangle

Park,

North

Carolina.

USEPA454IR-92-4)19.

a-a

Sincerely,

ROBERT

BACHMAN

Air

ResourceSpecialist

Cc:

BPA

(Bob

Beraud,

Tom

McKinney)

only

October

1992.

Responses

Letter

TOTAL

OZpN

ItPAGT

INCREMENTS

Background

—1

Facility

Ozone

Total

Ozone

NAAQS

Averaging

Increment

Standard

Peilod

(ppm)

8-hour

00119

00646

0.0765

0.0800

1-hour

00170

0.0790

0.0960

0.1200

‘The

Scheffe

Method

soreenjo

procedure,

based

usa,,

series

applications

the

lactiye

Ptrnie

Mde141

(lM

wtich

celcutates

the

1-hour

O[aerent

due

%IOC

end

point

sources.

Scheffe.

Rdeid

0..

VOCNOP&,sI.

USEPk

Off

ice

PJr

OeIfv

Pnnino

end

Slendeids.

Reseaicfi

Thanote

ar1c.

rlh

Oarc,Ina.

EP44I2-78.i27R.

September1998.

EPA.

SuooqI

Center

for

Regulatory

Models.

Soerfno

Pnxodwes

for

Esdmatinc

the

Oualhrlnioact

Stafanarv

Spurr.es

Regsed.

Reseac2i

TdanoIe

Pert.

North

Caroli,a.

USEPA.454iR-92-019.

October1992.

‘VSEPA.

Office

and

RadiaUon.

EPA$

(vLs

Ozone

Ste

dactf

Fact

Sheet.

Reseadi

Tdanglo

Perk.

Notth

Carcana.

July17,

1997.

Letter

Continued

Responses

Letter

-2-

25-

300-foot

gravel

parlting

area

would

established

BPA

along

the

west

side

Ferry

Road.

BPA

would

provide

and

install

parking

curbs

directed

the

District.

controlled

access

point

would

developed

for

overflow

public

parking

the

remaining

open

area.

The

parking

area

would

serve

the

pubic

users

the

adjacent

Corps

Engineers

operated

park

area.

The

four

ferns

outlined

above

would

lncorporated

into

real

estate

purmit

BPA

site-specific

conditions.

Other

than

the

site-specific

conditIons,

the

remaining

terms

the

permit

will

the

standard

Department

the

Army

format.

Bonneville

Power

Administration

wishes

pursue

this

expansion

given

the

conditions

outlined

above,

please

provide

this

office

with

letter

application,

also

need

receive

current

aerial

photograph

the

McNaiy

substation

area

with

the

—

expansion

area

superimposed

the

photo.

you

need

further

information,

please

call

509-527-7324

contact

PauLS.Shampine@usace.army.mtl.

Sincerely,

Paul

Shamplne

Real

Estate

Specialist

Enclosures

KEF1RES/RE

GARLAND/RE

BROWNIOD-1N

SHAMPINE/tp

tM-SM

ATTACHMENT

Excerptsfron:

The

Illinois Annual Air

Quality Reports

2004, 2005, 2006,

2007

Table

2004

OZONE

NUMBER

OF DAYS

HIGHEST

SMftES

GREATER ThAN

(parts

per

million)

1-HOUR

8-HOUR

STATION

ADDRESS

0.12 PPM

0.08

PPM

1ST

2ND

3RD

4TH

1ST

2ND

3RD

4Th

69 METROPOLITAN

QUAD

CiTIES INTERSTATE

(IA

- IL)

ROCK

ISLAND

COUNTY

Rock Island

Rodman

Ave.

0.082

0.070

0.066

0.064

0.076

0.060

0.059

METROPOLITAN

ST.

LOUIS

INTERSTATE

(IL

- MO)

MADISON

COUNTY

Alton

409

MaIn St.

0.096

0.092

0.091

0.090

0.080

0.074

Edwardsville

Poag Road

0.101 0.092

0.085

0.082

0.076

0.075

0.068

Maryville

200W.

DivisIon

0.105

0.103

0.102

0.100

0.082

0.081

0.080

0.078

Wood

River

54 N.

Walcott

0.097

0.096

0.095

0.081

0.080

0.073

RANDOLPH

COUNTY

Houston

Twp

Rds. 150

& 45

0.0082

0.074

0.073

0.069

0.066

0.065

0.064

ST. CLAIR COUNTY

East St.

Louis

13th & Tudor

0.102 0.094

0.092

0.084

0.078

0.076

0.075

0.073

ROCKFORD

- JANESVILLE

BELOIT INTERSTATE

(IL

- WI)

WINNEBAGO

COUNTY

Loves Park

1405

Maple

0.081

0.076

0.072

0.069

0.072

0,070

0.067

0.061

Rockford

1500

Post

0.08

0.079

0.075

0.07 1

0.074

0.073

0.071

0.064

74 SOuThEAST

ILLINOIS

iNTRASTATE

EFFINGHAM

COUNTY

Effingham

Route

South

0.097

0.088

0.078

0.076

0.074

0.073

0.067

HAMILTON

COUNTY

Dale

Route

142

0.085 0.081

0.080

0.076

0.072

0.071

WEST

CENTRAL

ILLINOIS

INTRASTATE

ADAMS COUNTY

Quincy

732

Hampshire

0.078

0.072

0.071

0.070

0.067

0.066

0.064

0.063

JERSEY

COUNTY

Jerseyville

Liberty

St.

0.095

0.093

0.089

0.088

0.077

0.076

0.075

0.073

MACON

COUNTY

Decatur

2200

N. 22nd St.

0.078

0.071

0.069

0.066

0.064

MACOUPIN

COUNTY

Nilwood

Heaton

DuBois

0.087

0.084

0.081

0.079

0.080

0.069

0.068

SANGAMON

COUNTY

Springfield

2875 N.

Dirksen

0.082 0.079

0.078

0.077

0.071

0.066

0.065

0.064

PrImary 1-Hour

Standard

0.12 ppm; 8-Hour

Standard

0.08 ppm

Table

2005

OZONE

NUMBER OF

DAYS

HKHEST SAMPLES

GREATER

(parts per million)

1-HOUR

8-HOUR

STATION

ADDRESS

0.12 f1’M

0.08

PPM

1ST

2ND

3RD

4TH

1ST

2ND

3RD

4TH

METROPOLITAN

QUAD CITIES

iNTERSTATE

(IA - IL)

ROCK

ISLAND

COUNTY

Rod

Island

Rocfman

Ave.

0.095 0.085

0.078

0.072

0.081

0.078

0.071

0.065

METROPOLITAN

ST.

LOUIS

INTERSTATE (IL

- MO)

MADISON

COUNTY

AlLan

4O9MaInSL

0.116

0.110

0.106

0.102

0.096

0.092

0.091

Mayvflle

200W. DivisIon

0.130

0.114

0.111

0.104

0.095

0.092

0.088

WoodRiver

54N.Walcott

0.116

0.109

0.108

0.099

0.093

0.091

0.087

RANDOLPH COUNTY

Houston

Twp Rds.

150 & 45

0.090

0.086

0.082

0.080

0,079

0.078

0,076

0.074

ST.

CLAIR COUNTY

East

St.

Louis

13th

&Tudor

0.132 0.127

0.120

0.104

0.110

0.103

0.101

0.094

73 ROCKFOIU) - JANESVILLE

- BELOIT

INTERSTATE

(IL

Wi)

‘MNNEBAGO

COUNTY

Loves

Park

1405 Maple

0.086

0.083

0.082

0.081

0.079

0,079

0.076

0.075

Rockford

1500

Post

0.089

0.082

0.081

0.080

0.079

0.076

0.075

74 SOUHJEAST

ILLINOIS

INTRASTATE

EFFINGHAM

COUNTY

Efllngham

Route 45 South

0.080

0.078

0.077

0.076

0.075

0.073

0,073

HAMILTON COUNTY

Knight

Prairie

Twp.

Route 14

0.087

0.086

0.085

0.081

0.080

0.077

WEST CENTRAL ILLINOIS

INTRASTATE

ADAMS

COUNTY

QuIncy

732 HampshIre

0.090

0.089

0.085

0.084

0.077

0.076

JERSEY

COUNTY

Jerseyville

LibertySt.

0.108

0.102

0.089

0.087

0.086

MACON

COUNTY

Decatur

2200 N. 22nd St.

0.093

0.092

0.089

0.081

0.080

0.077

0.076

MACOUPIN

COUNTY

Nilwood

Heaton

DuBois

0.097

0.095

0.087

0.086

0.080

0.078

0.077

SANGAMON

COUNTY

Springfield

2875

Dirksen

0.089

0.088

0.087

0.084

0.078

0.077

0.076

0.075

PrImary

S-Hour Standard

0.12 ppm; 8-Hour Standard

0.08 ppm

Table B2

2006

OZONE

NUMBER

OF DAYS

HIGHEST

SAMPLES

GREATER THAN

(parts

per

miIon)

i-HOUR

8-HOUR

STATION

ADDRESS

0.12

PPM

0.08 PPM

1ST

2ND

3RD

4TH

1ST

2ND

3RD

4TH

METROPOLITAN

QUAD

CITIES

INTERSTATE

(IA - IL)

ROCK

ISLAND COUNTY

Rock

Island

Rodman Ave.

0.080

0.078

0.077

0.075

0.074

0.071

0.070

METROPOLITAN

ST. LOUIS

INTERSTATE

(IL

- MO)

MADISON

COUNTY

Alton

409

Main

St.

0.109

0.103

0.101

0.095

0.085

0.080

0.079

Maryville

200W.

Division

0,118

0.104

0.097

0.095

0.089

0.084

0.077

Wood

RIver

Walcott

0.105

0.099

0.098

0.090

0.081

0.080

0.078

0.077

RANDOLPH

COUNTY

Houston

Twp

Rds. 150 &45

0.088

0.087

0.083

0.081

0.077

0.076

0.073

0.072

ST. CLAIR

COUNTY

East St.

Louis

13th

Tudor

0.121

0.111

0.095

0.093

0.098

0.097

0.082

0.077

ROCKFORI)

- JANESVILLE

- BELOIT INTERSTATE

(IL

- WI)

WINNEBAGO

COUNTY

Loves Park

1405

Maple

0.073 0.070

0.069

0.068

0M66

0.066

0.064

0.063

Rockford

1500

Post

0.072 0.071

0.070

0.068

0065

0.064

0.063

SOUTHEAST

ILLINOIS

INTRASTATE

EFFING HAM

COUNTY

Etfingham

Route 45

South

0.085 0.081

0.074

0.071

0.070

0.067

HAM1LTON COUNTY

Knight Prairo

Twp.

Route

0.079

0.074

0.073

0.070

0.068

0.088

0.066

WEST

CENTRAL

ILLINOIS

INTRASTATE

ADAMS COUNTY

Quincy

732

Hampshire

0.084

0.080

0.076

0.073

0.072

0.071

JERSEY COUNTY

lerseyville

Liberty St.

0.096

0.094

0.090

0.085

0.083

0.079

0.077

0.075

MACON

COUNTY

Decatur

2200 N. 22nd

St.

0.088

0.077

0.076

0.079

0.073

0.072

0.071

MACOUPIN

COUNTY

Nitwood

Heaton

& DuBois

0.088

0.085

0.082

0.077

0.073

0.071

0.070

SANGAMON

COUNTY

SpringfIeld

2875

Dirksen

0.084

0.080

0.077

0.074

0.068

0.066

Primary

8-Hour

Standard 0.08

ppm

Table

2007

OZONE

NUMBER

OF DAYS

HIGHEST

SAMPLES

GREATER

ThAN

(parts

per million)

1-HOUR

8-HOUR

STATION

ADDRESS

0.12

PPMO.08

PPM 0.075 PPM

1ST

2ND

3RD

4TH

1ST

2ND

3RD

4Th

METROPOLITAN

QUAD

CITIES

JINTERSTATE

(IA - IL)

ROCK

ISLAND COUNTY

Rock Island

32 Rodman

Ave.

0.090 0.083

0.080

0.077

0.080

0.074

0.072

0.071

METROPOLITAN ST.

LOUIS

INTERSTATE

(IL

- MO)

MADISON

COUNTY

Mon

409

Main

St.

0.120

0.096

0,095

0.092

0.086

0.085

0.083

0.081

Maryville

200W.

DMsion

0.123 0.108

0.104

0.101

0.107

0.094

0.091

0.087

Wood

River

Walcott

0.121

0.114

0.103

0.090

0.089

0.067

0.086

RANDOLPH

COUNTY

Houston

Twp Rds.

150

0.099 0.093

0.093

0.088

0.082

0.081

0.079

ST.

CLAIR COUNTY

EastSt.Louls

131h&Tudor

0.114

0.106

0.093

0.092

0.093

0.081

0.078

0.077

ROCKFORD

- JANESVILLE

- BELOIT

INTERSTATE

(IL - WI)

WINNEBAGO

COUNTY

Loves Park

1405 Maple

0.083 0.080

0.078

0.077

0.075

0.073

Rockford

1500

Post

0.080 0.078

0.078

0.074

0.072

0.071

74 SOUTHEAST ILLINOIS

INTRASTATE

EFFINGHAM

COUNTY

Effingham

Route

South

0.088

0.082

0.081

0.079

0.078

HAMILTON

COUNTY

Knlgiit Prairie

Twp.

Route 14

0.089 0.085

0.084

0.083

0.084

0.080

0.079

0.076

75 WEST CENTRAL

ILLINOIS

INTRASTATE

ADAMS

COUNTY

Quincy

732 Hampshire

0.087

0.080

0.079

0.078

0.082

0.076

0.075

JERSEY COUNTY

Jerseyville

UbertySt.

0,100

0.090

0.088

0.087

0.085

0.077

0.075

MACON

COUNTY

Decatur

2200

22nd St.

0.092

0.084

0.081

0.079

0.078

0.077

MACOUPIN COUNTY

Nilwood

Heaton

DuBois

0.099

0.095

0.089

0.085

0.091

0.075

SANGAMON

COUNTY

Springfield

2875 N.

Dirksen

0.093 0.090

0.079

0.081

0.079

0.075

0.072

PrImary

8-Hour Standard

0.08 ppm

ATTACHMENT

Excerptsfrom:

“VOC I

NOx

Point

Source

Screening Tables”

Richard

D. Scheffe,

USEPA

September,

1988

DISCLAIM

This document

has been

recreated

from

a copy of an original.

Although

every

attempt has

been

made to ensure

exact

duplication

of the

original

document, it

is an electronic re-creation

of the

original

and there may

be errors. it is

recommend

that

the reader obtain

the complete printed

document

from U.S. EPA. Greg

Remer,

Nevada Bureau

of Air Pollution Control,

July 27,

1998.

VOC/NOx

POINT

SOURCE

SCREENING

TABLES

Richard D.

Scheffe

September,

1988

United

States Environmental

Protection

Agency

Office

of Air

Quality

Planning

and Standards

Technical

Support Division

Source

Receptor Analysis

Branch

3.0

SCREENING

TABLES

The

interpretation

definition

“rural”

or “urban”

area

within

the

framework

of this

technique

is intended

rather

broad

and flexible.

The

rationale

for

having

rural

and

urban

tables

stems

from

the

need

account

for

the

coupled

effect

point

source

emissions

and

background chemistry

ozone

formation.

Background

chemistry

the

context

this

procedure

refers

characterization

the

ambient

atmospheric

chemistry

into

which

polnt

source

emits.

The

underlying model

runs

used

develop

the

rural

table

(Table

were

performed

with

spatially

invariant

background

chemistry

representative of.

“clean”

continental

U.S.

areas.

Model

runs

used

to develop

the

urban

table

(Table

are based

background

chemistry

incorporating

daily

temporal

fluctuatlons

of NOx

and

hydrocarbons

asociated with

typical

urban

atmosphere (refer

to Appendix

for

details

regarding

background

chemistry).

Background

chemistry

important

factor

estimating

ozone

formation;

however,

characterization

background

chemistry

perhaps

the

most

difficult

aspect

reactive

plume

modeling

because of data

scarcity

and

the

level

resources

required

measure

or model

(temporally

and

spatially)

the

components

necessary

charcterize

the

ambient atmospheric

along

the

trajectory

point

source

plume.

Recognizing

the

conflicting

needs

using

simple

characterizations

background

chemistries

and

applylng

this

screning

technique

situations

where

sources

are

located

impact

areas

which

can not

simply

categorized,

the

following steps

should

used

choose

appopriate

table:

(1)

the

source

locatlon

and downwind

impact

area can

decribed

as rural

and

where

ozone

exceedances have

never

been

reported,

choose

the

rural

area

table.

(2) If

the

source

location

and downwind

impact

area

are

of urban

characte, choose

the

urban

area

table.

(3)

urban

based

source

potentially

can

impact

a downwind

rural

area,

a rural

based

source

can

potentially

impact

downwind

urban

area,

use the

highest

value

obtained

from

applying

both

tables.

The

VOC

point

source

screninq

tables

(Tables

1 and

provided ozone

increments

a function

NMOC

(nonmethane

organic

carbon)

mass

emissions

rates

and

NNOC/NOx

emissions

ratios.

determine

ozone

impact

the

user

is required

apply

best

estimates

maximum

daily

NMOC

emissions

rate,

and

estimated

annual

mass

emissions

rates

NMOC

and NOx

which

are

used

determine

NMOC/NOx

ratio

for

ascribing

the

applicable

column

Table

1 or

The

reasons

for

basing

application

daily

maximum

NMOC

emissions

rates

are

(1>

avoid

underestimates

resulting

from

discontinuous

operations

and

(2)

the

underlying

modeling

simulations

are

based

single

day

episodes.

The

NMOC

emissions

rates

Tables

and

are

given

on an

annual

basis;

consequently

the

user

must

project

daily

maximum

annual

emissions

rates

illustrated

the example

application

given

below. One

purpose

the technique

provide

simple,

non-resource

intensive

tool;

therefore,

annual

NMOC/NOx emissions

ratios

are used

because consideration

daily

fluctuations

would

require

screening

application applied

each

day.

Parameters describing

background

chemistry,

episodic

meteorology,

and source

emissions

speciation

affect actual

ozone

impact

produced

point

source.

However,

as a screening

methodology

the

application

should

be simple,

robust and

yield

conservative

(high

ozone)

values. Thus,

only NMOC

and

Nox

emissions

rates are

required as

input

Tables

and 2.

Rural

Example Application

A manufacturing

company

intends

to construct

a facility in

an isolated

rural

location

where ozone exceedances

have never

been

observed.

The

pollution control

agency

requires that the

company

submit

an analysis

showing

that

operation of the

proposed

facility

will not

result

in an ozone increment

greater than X ppm

in order to permit

operation.

The

estimated

daily maximum

NNOC

emissions

rate is

9000

lbs/day.

The

annual estimated

emissions

rates

for

NMOC

and

NOx are

1000

tons/yr and

80 tons/yr,

respectively.

The

company’s

strategy

is to provide a

screening

analysis

using

the

rural

area

table

to prove future

compliance.

If the

screening

result

exceeds

X ppm,

the company

will initiate

detailed

modeling

analysis

requiring characterization

source

emissions

speciation,

ambient

chemistry,

and episodic

meteorology.