August 2016 Metrics Report
In terms of air quality, Nebraska is privileged and is in attainment with all federally established National Ambient Air Quality Standards. This provides Nebraskans with healthy air to breathe and our businesses an opportunity to operate without being subject to inflexible regulatory provisions common in areas of the country with compromised air quality. The above graph shows those areas of the country that experience days with air quality rated as “unhealthy” by EPA. This rating is based on particulate matter and ozone. It is notable that Nebraska is not included; however, as the chart on the next page indicates, continued vigilance with regard to our Air Quality is appropriate.
The above graph depicts Nebraska’s compliance with the National Ambient Air Quality Standards for fine particulates and ozone. While Nebraska is within the standards, there is not a great cushion, particularly with the ozone standard. It is important that NDEQ and the regulated community pay close attention to our monitoring results and if necessary take action to maintain compliance. Many entities in the Omaha Metro area have already initiated such action; the Metropolitan Area Planning Agency is leading this effort.
Emerging Issues/Risks: NDEQ staff is monitoring operations at the Waste Connections landfill near David City. Abnormally high temperatures from the landfilled area indicate a subsurface heating event. If critical temperatures are reached, damage could occur to the landfill’s leachate collection system, gas collection system and liner. If conditions worsen and a fire develops, this will be extremely problematic, as landfill fires are very difficult to extinguish. NDEQ is working with Waste Connections to determine the best approach to this situation. The Waste Connections landfill receives waste from a large geographic area; any disruption of the landfill’s ability to receive waste could result in municipalities needing to find alternate sites for the disposal of their waste.
Accomplishments: NDEQ, Green Plains Inc., UNL and the Ethanol Board partnered to present NDEQ’s first webinar. Erica Montefusco, Director of Environment, Health and Safety for Green Plains, presented the Green Plains perspective on the pros and cons of being a major source versus a minor source for purposes of the Air Quality program. Many sources request emission limits just below the threshold for the major source category; this results in those facilities being subject to strict operational requirements to ensure the facility remains a minor source. Ms. Montefusco explained major sources, while subject to emission fees, have greater flexibility in their operations. She suggested those desiring to remain minor sources take a close look at the pros and cons of each classification. Her message will likely resonate more with the ethanol industry than would have been the case had NDEQ staff presented the information.
NDEQ announced an innovative arrangement with the ethanol industry whereby expensive volatile organic compound (VOC) testing requirements are reduced for ethanol plants that install Continuous Emission Monitors (CEMs). CEMs offer an opportunity to better manage plant operations and improve compliance with applicable regulations. Testing requirements pose significant resource demands and are expensive and disruptive of facilities’ normal operations. The CEM arrangement offers both NDEQ and the regulated community the opportunity to save resources and provide additional assurances that compliance is attained on a continuing basis.
Misc. Items of Note: The Environmental Quality Council met August 30th and approved revisions to Title 119 Rules and Regulations Pertaining to the Issuance of Permits Under the National Pollutant Discharge Elimination System (NPDES). The revisions allow NDEQ to consider the need to raise user fees, the ability of ratepayers to pay increased fees, and the potential growth or decline of the associated municipality when making permit decisions.