Oklahoma department of environmental quality



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G-P modeled fugitive sources using the VOLUME source type. The VOLUME source type applies two dimensions and a square base to represent the emission source. In cases where the model cannot approximate a fugitive emission source as a single square base model source, G-P divided the emission source into multiple identical sources. G-P divided the emission rate equally among the model sources. Table D-10 presents the fugitive emission source parameters for VOLUME sources.




Table D-10

Roads

Railcar Unload

Coal Stacker

Coal Crusher

Coal Grizzly

Bunker Transfer

Model ID

Various

RCUN

STKER

CRUSHER

GRIZZLY

BNKXF

Source ht (m)

7.3

5.0

1.0

11.4

3.0

1.0

Release Ht (m)

3.7

2.5

14.6

5.7

1.5

31.4

Surface Based or Elevated

Surface

Surface

Elevated

Surface

Surface

Elevated

Side Length (m)

14.1

7.5

14.1

11.8

3.5

1.0

Initial Lateral dim. (Σy) (m)

6.6

3.5

6.6

5.5

1.6

0.5

Source ht (m)

7.3

5.0

1.0

11.4

3.0

1.0

Initial Vertical dim (Σz) (m)

3.4

1.2

0.2

2.7

0.7

0.2

“Volume Source Inputs” in the EPA’s User’s Guide for the Industrial Source Complex (ISC3) Dispersion Models Volume I - User Instructions (EPA-454/B-95-003a)
Receptor Locations

All analyses will use screening and refined Cartesian receptor grids. The receptors are spaced at 25-m intervals along the fenceline, at 100-m intervals within 3 km of the Mill, and at 500-m intervals beyond 7.5 km of the Mill. G-P inspected the analysis results to determine if predicted impacts at the edges of the most coarse receptor grid were decreasing. The analysis was supplemented with additional refined receptor sets if the receptor spacing at the maximum impact location was more than 100 m. The analysis modeled all areas, including our property outside the fence, as ambient air. G-P compiled the terrain and source elevations using USGS Digital Elevation Model 7.5-minute series data. G-P used the AERMAP program to interpolate the raw USGS DEM data into the uniform receptor grids. The raw datasets were prepared by the USGS with a resolution of 30 m for the 7.5-minute data. G-P inspected the resultant grid files for accuracy. G-P used the fine resolution dataset (i.e., 7.5 minute series) to extract terrain data.


D.2.7 NAAQS MODELING ANALYSIS

Purpose and Methodology

As discussed in the result section, preliminary modeling of the proposed project indicated a significant impact (i.e., maximum impact at or above the PSD significance levels) for NO2, SO2, and PM10. Therefore, PSD review requires G-P to perform a full air quality analysis to demonstrate compliance with the NAAQS. The NAAQS impact analysis predicts the maximum ambient air concentration due to 1) all Mill sources emitting at maximum potential emission rates, 2) off-site sources at maximum permitted rates, and 3) natural and background sources. The total of these concentrations must be less than the NAAQS. Table D-11 summarizes the NAAQS.


Table D-11

Pollutant

Averaging Time

NAAQS (μg/m3)

Form of Standard

PM10

24-hour

150

High-sixth-highest for 5 years




Annual

50

Annual Mean

NO2

Annual

100

Annual Mean

SO2

3-hour

1,300

High-second-highest for each year




24-hour

365

High-second-highest for each year




Annual

80

Annual Mean


Background Concentrations

Background concentrations are necessary to determine total ambient air quality impacts to demonstrate compliance with the NAAQS. “Background concentrations” are defined as concentrations due to sources other than those specifically included in the modeling analysis. For example, background concentration would account for other small point sources not included in the modeling, fugitive emission sources, and natural background sources (e.g., mobile sources).


ODEQ recommended conservative values for background concentrations considering monitor locations, their proximity to the Muskogee Mill, data quality, and how recent the data was collected. Table D-12 presents the background concentrations in micrograms per cubic meter (μg/m3) used for the analyses.


Table D-12 Pollutant

Monitor and Data Description

Averaging Period

Background Concentration

(ppm)

(μg/m3)

SO2

Muskogee – 2004 High Second High for 3-hour and 24-hour; 2004 Annual mean

3-hr

0.061

159.8

24-hr

0.016

41.9

Annual

0.0026

6.8

NO2

Tulsa - 2004 Annual Mean

Annual

0.0054

10.2

PM10

Muskogee – 2002-2004 High Fourth High and 2004 Annual mean

24-hr

--

72

Annual

--

23.2


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