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State/Military Environmental Issues Working Group. Fall Meeting October 2006. Water Resources Subcommittee. Water Resources Subcommittee. Co-Chairs: Jeff Manning, DENR DWQ Lynn Vaughan, Fort Bragg
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State/Military Environmental Issues Working Group Fall Meeting October 2006
Water Resources Subcommittee Co-Chairs: Jeff Manning, DENR DWQ Lynn Vaughan, Fort Bragg Mission: Mutual understanding and troubleshooting through constructive exchange of information on all water- related issues affecting military installations in NC.
Water Resources Subcommittee • Goals: • Address any DENR water program issue • Stormwater • Water supply • Wastewater • Foster collaboration/long-term plans • Issue Update: • Universal Stormwater Management Plan
Sustainability/Pollution Prevention/Environmental Management Systems (SPPEMS) Subcommittee
SPPEMS Subcommittee SPPEMS is a partnership to benchmark current pollution prevention activities, establish emissions reduction goals, and share accomplishments across all DoD facilities in North Carolina.
SPPEMS Subcommittee Goals: • Promote and implement pollution prevention as the preferred environmental alternative • Meet and exceed compliance requirements • Reduce demand on state and installation resources • Reduce generation of pollutants • Institutionalize the pollution prevention ethic • Meeting requirements of Executive Order 13148 “Greening the Government Through Leadership in Environmental Management” • Sustaining the mission and environment
SPPEMS Subcommittee 2005-2006 Focus: • Sustainable installations • P2 awareness, practices, technologies • EMS continual improvement
SPPEMS Subcommittee Major Issues Discussed this Past Year: • BRAC Sustainability Issues • Contracting Procedures for Federal Facilities Environmental Projects • EMS Management Review • HAZMAT Pharmacy Operations • Sustainability Education Development and Implementation
Special Use Airspace Subcommittee Mission • Share information on issues affecting Special Use Airspace • Work together to mitigate or resolve aviation issues to mutual satisfaction • Foster cooperation and maintain open environmental dialogue
Special Use Airspace Subcommittee • Issues of Note: • NC Military Support Act Program • - Sustain funding line • Windmills & MTR Encroachment • - Cooperative involvement needed • Pilot Safety & Education – DOT Air Safety Office • - High value customer; stay the course • Radar Partnership - ATC Service for coastal NC • - Leverage mutual advantages
V189 Manteo Non-Radar Area Kinston Billy Mitchell New Bern Ocracoke Cherry Point Morehead Wilmington 45NM 55NM Radar Partnership
V189 Plymouth Manteo Radar Partnership . 55NM 45NM Kinston Billy Mitchell New Bern Ocracoke Cherry Point Morehead Wilmington 45NM 55NM Leveraging Mutual Advantage
UST Subcommittee The UST Subcommittee discusses any UST issues of concern and provides an opportunity for the DoD installations to be aware of any future rule or policy changes.
UST Subcommittee Committee Updates: • UST Section Guidelines (still under revision) • Landfarming Rule 15A NCAC 2T (Waste not discharged to surface waters) – final Sept 1; available on OAH’s website
UST Subcommittee Issue for Discussion: • Underground Storage Tanks Deed Restriction
Clean Air Act Subcommittee • Originally called the Title V Subcommittee • Later expanded focus of committee • Concentrates primarily on stationary sources, but also discusses mobile source issues
Clean Air Act Subcommittee Issues for Discussion: • Comfort Heat Boilers • Vehicle Inspection and Maintenance • Smoke Management Plan for Forestry Burning
Why A Mandatory Smoke Management Program is Needed Laura Boothe Attainment Planning Branch Chief Division of Air Quality October 20, 2006
DAQ’s Position on Forest Management Burns • Recognize and support the need to reduce forest underbrush & litter to prevent larger wild fires in the future. • Recognize and support the need to maintain specific habitats • Recognize that prescribe burns helps protect natural resources as well as public welfare • Want to prevent exceedances of National Ambient Air Quality Standards (NAAQS)
EPA’s Policy on Wildland & Prescribed Fires • Interim policy came out in 1998 • Outlines Smoke Management Program requirements • States must certify they have a Smoke Management Program in place • EPA must approve the certification
Smoke Management Program Elements • Authorization to Burn • Encourage Consideration of Alternatives to Minimize Air Pollutant Emissions • Burn Plan Requirements • Actions to minimize fire emissions • Evaluation of smoke dispersion • Public notification & exposure reduction procedures • Air quality monitoring • Public Education & Awareness • Surveillance & Enforcement • Program Evaluation • Optional Air Quality Protection
North Carolina’s Smoke Management Program • DAQ certified current DFR program • EPA denied our certification • Voluntary program • Missing key elements • DAQ is working with DFR to develop a Smoke Management Program that EPA will approve
Why an EPA Approved SMP is Important • If smoke from a managed fire impacts a PM2.5 monitor, the State cannot flag the monitoring sample as a fire event. • Flagged data can be excluded in the calculation of the annual average and from the daily values. • Note that an effective SMP should prevent smoke impacts at monitors in populated areas • Elevated PM2.5 levels on a regular basis can impact the annual average. • Exceedances of the daily standard can lead to a violation of the PM2.5 standards.
What Happens if Violations Occur? • Areas can be designated as nonattainment • Nonattainment designation requires: • New Source Review • Transportation Conformity • General Conformity • This may impact ability to burn • Control measures and rules necessary to attain the standard
PM2.5 NAAQS • New standard signed by EPA Administrator on September 21, 2006 • Annual standard remains at 15 μg/m3 • 3 year average • Daily standard lowered to 35 μg/m3 • 98th percentile averaged over 3 years • Designations will occur in late 2009 • Most likely based on 2007-2009 data
Daily PM2.5 Standard • For monitors that sample everyday • Use the 8th highest value for each year • For monitors that sample every 3 days • Use the 3rd highest value for each year
Effects of Forest Fires 11/3/2000
PM2.5: ~ 72 mg/m3 PM2.5: ~ 7 mg/m3 “Pilot Cam” November 3, 2000: Forest fire smoke covers the area. November 5, 2000: Cold front moves through. Both pictures taken around 4:15 PM.
Conclusions • A Smoke Management Program that EPA will approve as certifiable is necessary. • Having such a program will allow DAQ to flag samples impacted by managed burns. • Results in managed burns having less impact on nonattainment designations
Contact Information • Laura Boothe • Laura.Boothe@ncmail.net • (919) 733-1488
Evolvement of NC’s Smoke Management Program “Potential Impacts to NC’s Strategic Partners” Prepared by: NC Division of Forest Resources / FEWG
Objectives / Sequence • Review some of the impacts of the NC’s smoke management program to certified burners / Strategic Partners • Review the background or reasons for these new developments
Impact to certified burners & Strategic Partners • increase in opportunities to initiate prescribed fires • increase a closer review of atmospheric conditions for burning • facilitate better assessment of smoke impacts on downwind Smoke Sensitive Areas (SSAs) • SSAs viewed as “old” SSAs or as “new” SSAs for visibility and PM. • responsibility to enter burn information into an “real time electronic database” • Participate in mandatory program of choice • two systems (Ventilation Index and Atmospheric Dispersion) • both are enhanced and advance the management of smoke and the use of fire across NC’s natural landscape
In 2004 the SMP project was initiated: • Fire Danger Working Group –submits • “DENR NCDFR Action Plan for Strategic Direction 5 Improving NC’s Air Quality” • Fire Danger evolves to: • “ Fire Environment Work Group & Strategic Partners” • FEWG is tasked with reviewing the Division’s smoke management program and to improve opportunities for prescribed fire.
Fire Environment Fire Behavior Smoke Management Fire Weather Fire Danger Fire Effects Fire Use Weather Station Network Fire Research
USA Air-sheds • Ventilation Index data shows the greatest risks to air quality and visibility are in the southeastern United States, where marginal to poor ventilation conditions prevail most of the year. • This region also has the most complex as it has the highest SSA concentrations.
NCDFR SMP Objective • In 1974 it was stated, “ to minimize particulate concentrations and smoke in smoke sensitive areas resulting from prescribed burning activities by defining those days and volumes of vegetative debris that may be burned”
After “32 years”- is there a need for an evolutionary change within the NC - SMP? • Protect public & forest health? • Provide for visibility & safety? • Minimize smoke impact into designated smoke sensitive areas? • Maximize burning opportunities? • Maintain air quality by identifying acceptable burning weather. • Track forestry emissions - TSP? • prescribe burning & wildfire • Coordinate with other NC state agencies & programs?
What are the pressures that we are dealing with today & into the future that necessitate change? • A) NCDFR is committed to prescribed fire, SM project is directed to increase opportunities. • Prescribed fire is why the Southern Forests have developed. Fire is indigenous to their development & health. Exclusion will mean species change. • B) EPA Rule Making Pressures • Exceptional Events • NAAQS • C) Air Quality • Ozone • Particulate Matter • D) Wildland Urban Interface • E Class I Areas & Regional Haze
“elevating our game” in the current system • standards of accuracy ? verification of accuracy • update procedure • spot forecasts • Night time winds forecast period • Mixing height standardization / weighted averaging ? District SMP Refreshers • review training content Prescribe Burn Boss ? S-290 / 390