Federal authorities (as well as the media) have singled out power plants as potential targets for terrorist activities and like many firms, you may be searching for responsible but reasonable steps you can take to help safeguard your facility, your employees, and your surrounding community. We can help with several of these.
Do you have an old emergency response plan (ERP) gathering dust on a shelf. Are you now in the process of updating it? If you haven't started yet, get going. If your facility was not required to prepare an ERP, you may want to consider developing one now. We can assist you to make sure all necessary emergency steps are correct - particularly with regard to avoiding an unplanned release of chemicals.
Do you have evacuation routes planned? Practiced? Evaluated? We can assist you with this critical procedure. Different events may dictate different procedures.
Have you always thought your SARA Title III, Tier II filings were just a pain? Your local emergency responders rely on that information to be accurate and up to date. Is it current, or have you just duplicated previous year's filings every year? We can help ensure the accuracy of that information, including your site diagrams.
Have your staff received HazCom training? Or Hazardous Materials Awareness Level Training if you have hazardous materials on-site? We can provide that training so your employees recognize what to do and when to do it.
Do you have the proper personal protective equipment (PPE) on site for emergency situations? Have all appropriate staff received the required training in order to use that equipment properly? We can provide training to ensure the safe and correct use of PPE.
How Can You Get Started? Have you looked at your facility with the scrutiny of an outsider's eye to identify possible vulnerable areas regarding machinery, chemicals, equipment, and procedures? An unbiased perspective is key to ensuring that all priority systems are failsafe. We can perform a third party audit of your facility to address these concerns and make appropriate recommendations.
You can request information or a quote by emailing us at
info@erl.com
Making It Clear - New Visibility Impact Requirements May Affect Your Project
In a July 2001 letter ERL wrote the following:
I recently returned from a vacation in California, where I visited Kings Canyon National Park. While not one of our nation's most well-known national parks, Kings Canyon is nonetheless a national treasure, with soaring mountains, an untamed river, abundant wildlife, and spectacular vistas at nearly every turn. Unfortunately though, on the days that I was there, the vistas were not so spectacular - because they were obscured by a shroud of smog and haze.
Apparently, I am not alone in the discovery of this unwelcome phenomenon that is affecting most of our national parks and wilderness areas. The Federal Land Managers (FLMs), those individuals charged with the management and protection of the national parks and other federal Class I areas, have also noticed that the vistas are not quite as scenic as they used to be. Therefore, some regulatory changes are being implemented to prevent further degradation of visibility and to ultimately restore visibility in national parks to pristine conditions. Many of these changes affect the permitting of new power plant projects and other major emissions sources. The result is that power plant developers are facing some new hurdles that make it more difficult to obtain environmental permit approvals. Here are a few examples to consider:
It used to be that if your project site was located more than 100 kilometers from a Class I area, potential visibility impacts were considered to be negligible and no visibility impact evaluation was required. Not any more. Now, expect that visibility impacts from your project will have to be evaluated if your site will be within 200 kilometers of the border of a Class I area. And, there may be cases where an even greater distance (up to 300 kilometers) will have to be evaluated. At 300 kilometers, about the only way to avoid a visibility impact study will be to locate your project in the middle of Iowa.
Visibility impacts could previously be evaluated using simple screening techniques. Not any more. Now, for distances more than 50 kilometers, the FLMs recommend the use of the CALPUFF model. CALPUFF is a sophisticated, state-of-the-art model that requires significantly more modeling expertise and resources to use. In addition, if modeling results indicate that a new source will exceed certain visibility impact thresholds, a cumulative source impact analysis that includes other regional sources may be required.
The visibility reference levels established to determine whether a new source would have adverse visibility impacts used to be based on annual average actual visibility conditions. Not any more. Now, the FLMs are recommending that the reference levels be based on "natural conditions", i.e., conditions absent the effect of man-made air pollution. This has lowered the threshold at which a new source is determined to cause visibility impairment, making it more difficult for permits to be obtained.
Only time will tell if these actions will help to restore visibility in Kings Canyon National Park to pristine conditions. In the meantime, they will have a major effect on the construction of new power plants. Stay tuned for more information in future letters.
"The times they are a-changin"
In an April 2001 letter ERL wrote the following:
I'm sure Bob Dylan did not have Prevention of Significant Deterioration (PSD) impact analyses in mind when he wrote that song, but it nevertheless aptly summarizes the current state of affairs in the world of air quality dispersion modeling. The Industrial Source Complex (ISC) model, long the workhorse for most regulatory air modeling applications, will soon be out. AERMOD and CALPUFF, the new kids on the block, will soon be in. They will become the preferred models for most regulatory modeling analyses.
The introduction of new dispersion models and corresponding changes to regulatory modeling guidance is generally a very slow and deliberate process. After all, the ISC model has been around in various versions since the 1970's. However, according to Joseph Tikvart, Source Receptor Analysis Branch Chief at the U.S. Environmental Protection Agency, final regulations designating the AERMOD and CALPUFF modeling systems as preferred modeling techniques are expected to be promulgated by Fall 2001. Speaking at the Air and Waste Management Association's recent Guideline on Air Quality Models Conference in Newport, Rhode Island, Mr. Tikvart also stated that full implementation of the new models and modeling guidance is expected by Fall 2002. At that time, the ISC model will become obsolete and regulatory air dispersion modeling will enter a new frontier with the next generation of more sophisticated dispersion models.
So, what are the implications of these changes to obtaining a PSD permit or other air permit for your project? The answer is…..it depends. Evaluation studies conducted for the new models indicate that, under certain circumstances, the new models predict much smaller ambient impacts than the old models. That kind of result could make it significantly easier to permit your project and could enable cost savings by making a shorter stack and/or less expensive emission controls feasible. However, in other cases, especially if stack emissions will be subject to aerodynamic building downwash, the new models may predict substantially higher impacts. About the only thing you will be able to count on is that the modeling analyses that will have to be performed for your project will take more time and cost more money. To obtain the better model accuracy and more realistic results offered by AERMOD and CALPUFF, more resources (i.e., people and time) will be needed to collect modeling data and to set up and execute model runs. And, it will also take longer to get the results out of the computer. Model runs that used to take less than one hour with ISC may take hours or even days with AERMOD or CALPUFF.
In future letters, ERL will be providing you with periodic updates on the status of these important changes.
