Oklahoma department of environmental quality

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.

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.

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.

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).

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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