A Facility’s Perspective into a Modeled PSD Increment Violation
Midwest Environmental Compliance Conference – MECC 2019
In 2005, dispersion modeling was conducted in Nebraska Bluff Road Landfill as part of the construction permitting process for the Lincoln Electric System Salt Valley Generating Station. The modeling results identified a Prevention of Significant Deterioration (PSD) increment violation at the Bluff Road Landfill resulting from activities associated with landfill operations. The model results predicted an increment violation for particulate matter less than 10 microns (PM10) at the landfill boundary, specifically for the short term 24-hour standard for PM10.
This SCS Engineers’ presentation by Tia Jeter, focuses on the experience of Bluff Road Landfill and the City of Lincoln, as the entities responded to the modeled violation, and provides highlights of the process required to ultimately resolve the increment violation and bring the facility into modeled compliance with the increment.
Resolving the modeled increment violation required coordination with multiple entities, including the local air permitting authority, the Lincoln Lancaster County Health Department (LLCHD), the Nebraska Department of Environmental Quality (NDEQ) and US EPA Region 7. To resolve the violation, facility emission processes, operational limitations, emission controls, model setup, and the compliance boundary was evaluated and revised numerous times. Initial modeling efforts conducted as part of the response utilized the Industrial Source Complex 3 Short Term (ISC3ST) model, which was the EPA-approved dispersion model at the outset of the project. Due to the prolonged timeline of the project, the final compliance modeling scenario submitted to the regulatory agency was completed using AERMOD which is now the EPA-approved dispersion model.
Along the path to compliance there were multiple challenges, including negotiations on emission point modeling methods, clarification on the definition of ambient air as it relates to leased property, the requirement to create federally enforceable compliance requirements, the slow response and feedback from the regulatory authority (ies), and the bureaucratic “hold-up” of other facility projects until resolution of the violation was attained.
Tia’s presentation will provide an overview of the road to compliance for the Bluff Road Landfill from the beginning of the project to the resolution of the increment violation. Her presentation provides an insight into what other facilities may experience in the future as compliance with the National Ambient Air Quality Standards and PSD increment for PM10 and particulate matter less than 2.5 microns (PM2.5) becomes increasingly more scrutinized. Learn more about Tia Jeter.