PJ1) Air Permitting
Industry: Electric Power Generation
Client: Real Energy, Inc.
Prime Contractor: BlueScape
Gas Engine Siting and Air Permitting for Multiple Air Districts in California.
Teamed with business associates Resource Catalysts and Environmental Compliance
Solutions to assist with Phase I installation of engines at 13 sites located in
three California air districts. The client is a distributed generation company
that sites, manages, and operates small, clean natural gas-fired, internal
combustion engines in corporate and municipal office buildings; these engines
can be used to reduce electricity costs during peak cost periods (peak shaving)
and provide energy for heating and cooling (cogeneration). Team assessed
potential air permitting hurdles in both the South Coast and San Diego County
air basins. Conformed to an extremely aggressive schedule that included kickoff
meetings with key agency staff, compilation of equipment and emissions data for
air permit applications, and completion of air dispersion modeling and health
risk assessment work. Though difficulties arose in resolving issues with health
risk impacts and periodic monitoring conditions, agency approval was granted to
begin construction under an expedited schedule. Draft air permits were
received, permit conditions were reviewed and changes were negotiated to allow
operational flexibility. At the conclusion of the Phase I permitting project,
air permitting manuals were developed to train Real Energy staff on air
permitting in four California air districts. Under Phase II, BlueScape is
currently assisting Real Energy with air permit applications for three projects
in metropolitan San Francisco.
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PJ2) Air Permitting
Industry: Fiberglass Manufacturing
Client: Johns Manville International, Inc.
Prime Contractor: BlueScape
PSD Air Permit; Submittal to Georgia EPD. Managed and completed modeling study
to support a PSD application submittal for a fiberglass manufacturing facility
located near Atlanta, Georgia. Facility proposed to add sodium nitrate to raw
batch materials to reduce odor-causing emissions of hydrogen sulfide from a
melting furnace. Process required a PSD Air Permit for NO2 emissions. Estimated
process emissions of criteria pollutants, assessed compliance with NAAQS and
increment thresholds for NO2, and completed other required PSD analyses,
including a visibility screening analysis.
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PJ3) Air Permitting
Industry: Federal Facilities: Electric Power Generation
Client: EDS Corporation
Prime Contractor: Rancho Santa Fe Technology
Air Permits for Five 1MW Emergency Backup Engines: SPAWARS Project in San
Diego, California. Prepared air permit applications under a very aggressive
schedule. Prime contractor hired to develop a computer help desk / command
center at Commerce Point in San Diego as part of the U.S. Naval global military
intranet system called "SPAWARS." Critical to the project was installation of
five 1 MW diesel-fired engines to provide backup power to the command center.
Targeted an installation period during summer of 2001, a period during which
the potential for power blackouts was high. Hurdles to overcome were the
aggressive timeline and a changing San Diego APCD health risk policy for
diesel-fired engines. Responded quickly to resolve issues with APCD permitting
staff. Application efforts were successful; EDS received air permits for
construction within a reasonable timeframe.
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PJ4) Air Permitting
Industry: Fiberglass Manufacturing
Client: Johns Manville International, Inc.
Prime Contractor: BlueScape
PSD Air Permit; Submittal to Ohio EPA. Client planned shut down of fiberglass
manufacturing plant in California, and transfer of two manufacturing lines to
plant in Ohio. Required completion and submittal of major PSD application to
the Ohio Environmental Protection Agency (OEPA) for PM10 emissions increases.
Main tasks included submittal of a modeling protocol and development of a PSD
application (emissions calculations, application forms, NAAQS air quality
impact modeling review, rule review and BACT assessment). Worked closely with
plant staff to develop the complete BACT chapter and assess health risks from
formaldehyde emissions under state regulations. A major project challenge was
the NAAQS dispersion modeling study. Many large regional PM10 sources existed
within 50 km of the JM plant. Worked extensively with JM and OEPA staff to
develop a regional PM10 emissions inventory, and to screen out sources from the
NAAQS impact analysis. JM staff also proposed stack changes to OEPA that
mitigated plant-related PM10 impacts. PSD application submitted to OEPA was
reviewed and approved within about four months.
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PJ5) Air Permitting
Industry: Electric Power Generation
Client: RAMCO, Inc.
Prime Contractor: Resource Catalysts
CEC Siting Application: Expedited Peaker Turbine Approval in Southern
California. Coordinated with several other subcontractors to pull together over
15 separate documents to develop and submit a CEC application. Client's
original project configuration included the installation of two peaker turbine
facilities, each one to be sited in Chula Vista and Escondido, California.
Scope changed to include the installation of an additional peaker turbine
facility on the Chula Vista property (CVII), and licensing of the second
turbine under the 21-day California Energy Commission (CEC) licensing process.
Submitted fifty copies of application document to CEC. Attended public hearings
and workshops for proposed facility. Although RAMCO ultimately stopped the
project for contractual reasons, the project had received approval by CEC to
begin construction.
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PJ6) Air Dispersion Modeling
Industry: Municipality; Wastewater Processing
Client: San Diego Metropolitan Wastewater District (SDMWD)
Prime Contractor: Montgomery Watson
Odor Modeling Study and Health Risk Assessment for Wet Weather Storage Facility
in San Diego, California. Completed dispersion modeling study using the ISCST3
model to assess potential odor impacts and health risks. The San Diego MWD
planned construction of a Wet Weather Storage Facility (WWSF), consisting of
two 7 million gallon underground storage tanks, to handle future peak
wastewater flows during storm events. Required analysis of potential nuisance
odors and health risk impacts as compared to thresholds established by the San
Diego APCD under Rule 1200 for surrounding businesses. Developed engineering
design data, such as stack height, air flows, and scrubber control efficiency
that would be required to meet City's odor design standards of 5 odor units
(OU). Used conservative modeling and exposure assumptions, to show that odor
impacts and health risks from the Wet Weather Storage Facility would meet
design requirements.
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PJ7) Air Dispersion Modeling
Industry: Petroleum Industry
Client: THUMS, Inc.
Prime Contractor: Environmental Compliance Solutions
Modeling and Health Risk Assessment (HRA): New 44 MW Simple-Cycle Turbine in
Long Beach, California. Owner of natural gas and petroleum production fields,
planned to site a 44 MW simple-cycle turbine facility in Long Beach harbor to
provide onsite electricity for well pumping. Needed modeling and HRA to show
that operation was in compliance with South Coast Air District Rules 1303 and
1401. Modeled impacts from criteria pollutants (NOx, PM10, etc.), ammonia slip,
and air toxics found at three candidate site locations. Examined the effect of
different stack heights, and the effect of building downwash on air quality
impacts. For each candidate site, determined a stack configuration that would
result in compliance with the district rules.
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PJ8) Air Dispersion Modeling
Industry: Federal Facilities; Munitions Disposal
Client: U.S. EPA
Prime Contractor: Booz-Allen & Hamilton
Third-Party Modeling Review; Instantaneous and Short-Term Releases from
Multiple Federal Munitions Disposal Facilities. Federal munitions disposal
facilities located in West Virginia, Indiana and Pennsylvania proposed
munitions disposal that involved open burning techniques. Health risk
assessments were performed by the facilities following the USEPA Human Health
Risk Assessment Procedures (HHRAP) guidance document. Models proposed for use
included OBODM, ISCST3, INPUFF, and TRPUF. Resulting documentation required
third-party review by an independent source. The review focused primarily on
the appropriateness of modeling input data assumptions, including emissions,
source release parameters, and meteorological data. Comments were provided to
Booz-Allen, and submitted along with other comments to USEPA and state air
pollution agency staff.
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PJ9) Air Dispersion Modeling
Industry: Metal Can ManufacturingClient: Confidential
Prime Contractor: Kleinfelder, Inc.
Stack Increase Study. Major beverage can manufacturing facility experienced
possible entrainment of sulfuric acid emissions released from three stacks into
building ventilation intakes, resulting in poor product finish quality for some
can batches. Customers required plan of action to alleviate problem. Made
visual observations at site and confirmed strong likelihood of a potential
problem during strong northeast winds. Used ISCST3 model and ASHRAE ventilation
guidance to estimate level of stack height increases required to avoid intake
contamination. Study recommendations were used to begin reconstruction of
stacks.
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PJ10) Health Risk & Exposure Assessment
Industry: Metal Plating and Finishing
Client: EME, Inc.
Prime Contractor: BlueScape
Air Emissions and Health Risk Refinements in California. Client operates a
metals finishing process with a chromic anodizer and several paint booths using
paints containing chromium. An existing AB2588 health risk assessment stated
that cancer risks in the community were considered significant (greater than 10
in one million). Refined air emissions and health risk impact calculations were
needed. At client's request, hired source-testing firm to obtain actual
hexavalent chromium emission data from the chromic anodizing process,
accounting for HEPA controls. Recalculated hexavalent chromium emissions from
the paint booths to account for multistage HEPA filters. Assisted facility in
re-submittal of health risk isopleth information to the South Coast AQMD. EME,
Inc. was able to show that health risks in the community caused by the
hexavalent chromium emissions had dropped by more than a factor of 100. AB2588
program fees were thus reduced by about $10,000 per year.
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PJ11) Health Risk & Exposure Assessment
Industry: Electric Power Generation
Client: Nuevo Energy, Inc.
Prime Contractor: MF Strange & Associates
Health Risk Assessment for Peaker Facility: Thirteen 2 MW Dual-fueled Engines
in Santa Barbara, California. Independent oil exploration company wanted to
site a peaking electrical power facility in Santa Barbara County. The facility
would consist of thirteen dual-fueled engines, firing diesel fuel and natural
gas. Completed a health risk assessment, utilizing VOC and PM reductions
assumed for the control system. Showed that, given the rather remote location,
health risk at the nearest receptor locations (houses, workers, etc.) would not
be significant.
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PJ12) Health Risk & Exposure Assessment
Industry: Precious Metal Reclamation
Client: Confidential
Prime Contractor: BlueScape
Health Risk Assessment for Hazardous Waste Incinerator in Southern California.
A client owns a precious metal reclamation facility located in Southern
California. The facility receives spent palletized petroleum catalyst and mixed
wastes from petroleum refineries. Platinum and other precious metals are
recovered from the waste using an incineration process. To permit a new rotary
incinerator, the Department of Toxic Substances Control (DTSC) required the
facility to estimate potential health risks from benzene in the waste stream.
Since benzene in the waste stream was unknown, BlueScape back-calculated health
risks assuming a relatively high feedstock component. From the results of the
health risk assessment, client was able to permit a maximum feedstock
throughput and waste benzene concentration that would allow ample operational
flexibility.
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PJ13) Health Risk & Exposure Assessment
Industry: Metal Part Coatings
Client: Life Paint Corporation
Prime Contractor: AQC Environmental Engineers
AB2588 Health Risk Assessment Life Paint Corporation in Southern California.
The South Coast Air Quality Management District required client to submit an
AB2588 health risk assessment for hexavalent chromium emissions from a paint
mixer. On client's behalf, performed required health risk assessment
incorporating proposed dust controls and developed source configuration
refinements to show that off-site health risks would not be significant.
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PJ14) Health Risk & Exposure Assessment
Industry: Petroleum Industry
Client: Equilon Refinery
Prime Contractor: Environmental Audit, Inc.
AB2588 Health Risk Assessment; Gasoline Reformulation Project, Southern
California. Revised an existing health risk assessment to account for changes
in source emissions due to gasoline reformulation with MTBE. Submitted to the
South Coast Air Quality Management District as part of an environmental impact
analysis. Due to expected agency staff scrutiny, BlueScape modified modeling
source configurations to more accurately reflect emissions releases, then used
the ISCST3 and ACE2588 models to complete the health risk assessment. Health
risks at nearby receptors were calculated to be below significance thresholds.
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PJ15) Litigation Support
Industry: Metal Plating and Finishing
Client: Confidential
Prime Contractor: BlueScape
Proposition 65 Litigation; Perchloroethylene Emissions. Prepared a Proposition
65 health risk assessment for a confidential metal polishing and plating
facility that uses perchloroethylene in a vapor degreasing operation. A
citizen's group (plaintiff) contended that the facility failed to warn off-site
receptors of perchloroethylene exposures above the no significant risk level
(NSRL), including a school, residences, and commercial locations. Used refined
analysis methods to show that, given very conservative exposure assumptions
that overstate actual risk, exposure values above the NSRL were confined to
commercial locations very near the emissions source. Case did not go to trial,
and the client settled with the plaintiff.
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PJ16) Litigation Support
Industry: Metal Parts Manufacturing
Client: Confidential
Prime Contractor: BlueScape
Proposition 65 Litigation; Perchloroethylene Emissions. Client sells seating
equipment to the aerospace industry and is currently being sued by a citizen's
group under Proposition 65 for perchloroethylene emissions. Although the
facility provided clear and reasonable warnings to the community in the local
newspaper, the plaintiff contends that the warnings were not adequately
provided to the exposed community. The plaintiff's health risk assessment shows
impacts above the NSRL at many nearby residential locations. Working with the
client and another consultant, BlueScape identified emissions and modeling
refinements that can be reasonably made to limit the extent of risk isopleth.
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PJ17) Litigation Support
Industry: Building Materials Manufacturing
Client: Confidential
Prime Contractor: BlueScape
Proposition 65 Litigation; Formaldehyde Emissions in Southern California. A
confidential building materials manufacturer in Southern California was
notified by a citizen's group that formaldehyde emissions led to community
exposures above the no significant risk level (NSRL). Met with the citizen's
group counsel and presented a community exposure assessment, which showed that
cancer risks due to formaldehyde emissions from the facility were insignificant
at all offsite locations. Given this fact, and the fact that the facility
planned to shutdown within the next year, the citizen's group pursued no
further legal action.
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PJ18) Air Emissions Inventories
Industry: Fiberglass Manufacturing
Client: Johns Manville International, Inc.
Prime Contractor: BlueScape
AB2588 Emissions Inventory. A fiberglass manufacturing facility in Northern
California was required to update its original AB2588 emissions report. Several
new source tests had been completed to develop more accurate emissions data.
Used the source test data and information sources from other plants and
completed a comprehensive air toxics inventory that was submitted to the Air
Pollution Control District using FATES. Based upon the emissions inventory, the
facility was not required by the APCD to complete an AB2588 health risk
assessment.
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PJ19) Air Emissions Inventories
Industry: Fiberglass Manufacturing
Client: Johns Manville International, Inc.
Prime Contractor: BlueScape
Annual Emissions Fee Report, Southern California. Assisted fiberglass company
in Southern California with response to SCAQMD's request for revised Rule 301
emissions inventories for the period 1994-1997 and completed the 1997-1998
report and 2000-2001 reports. A full air compliance audit initiated the project
to verify permit status and emissions source inclusion. Emission factors were
updated to reflect recent source tests and a Title V emissions inventory.
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PJ20) Air Emissions Inventories
Industry: Building Materials Manufacturing
Client: Confidential
Prime Contractor: BlueScape
Banking of Emissions in the South Coast Air Quality Management District.
Completed Emission Reduction Credit (ERC) applications for manufacturing
company located in the South Coast Air Basin. Submitted 15 applications to
SCAQMD in 2001, with emission reductions estimated to have a potential market
value of $20 million. Will also be assisting the client through the process of
justifying the emission reductions, including hard copy documentation of
operations, source test emission factors used and determination of operating
days.
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PJ21) Clean Air Regulatory Analyses & Compliance Audits
Industry: Automobile Manufacturing
Client: General Motors Corporation
Prime Contractor: Golden Environmental
Air Quality Compliance Audit, Flint, Michigan. Completed the air quality
portion of an environmental audit for the General Motors "Buick City" facility
in Flint, Michigan. The audit covered auxiliary operations, such as maintenance
areas and electrical power generation facilities. Worked with GM staff to
resolve and close out issues pertaining to recent minor source and PSD permit
application submittals and air emissions inventory submittals.
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PJ22) Clean Air Regulatory Analyses & Compliance Audits
Industry: Dental Material Processing
Client: Argen Corporation
Prime Contractor: BlueScape
Air Emissions Investigation and Compliance Review. A facility that reclaims and
recycles metal alloys from dental bridge grindings was concerned about
potential air emissions from a melting operation. Assisted the client by
observing the melting operation and associated stack emissions. MSDS sheets and
other records were reviewed to determine if any toxic metal alloys would be
emitted into the outside air. Concluded that air emissions would not cause
odors or visible smoke that would bother commercial neighbors. As a minor
operation, the facility would likely be exempted from air quality rules as
regulations.
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PJ23) Clean Air Regulatory Analyses & Compliance Audits
Industry: Electric Power Generation
Client: Confidential
Prime Contractor: BlueScape
Proposition 65 Audit and AB2588 Health Risk Assessment Revisions for Six
Facilities in California. Completed Proposition 65 due diligence audits for six
facilities located in the San Francisco Bay Area and San Joaquin Valley. The
company generates power by firing petroleum coke in fluidized bed combustors; a
Prop 65 audit was required to identify the potential exposures for on-site
workers and contractors, customers and the community through air, water, waste
and co-product exposure routes. Processed results of a source test completed by
Avogadro Group to complete air toxic emissions calculations. Completed
community exposure assessments using the SCREEN3 dispersion model. Recommended
that community Prop 65 warnings did not need to be completed. Other
recommendations were provided regarding gate and on-site notification
procedures. Used the new air toxic emissions data from source testing to revise
the AB2588 health risk assessments for five facilities.
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PJ24) Air Quality Impacts; Environmental Impact Reports
Industry: Municipality
Client: Los Angeles World Airports
Prime Contractor: CDM & ECS
Air Dispersion Modeling Review; LAX Expansion in Los Angeles, California. The
Master Plan environmental impact report for the proposed Los Angeles
International Airport expansion involved substantial dispersion modeling to
predict air quality impacts from both stationary and construction sources.
Reviewed air dispersion modeling impacts from construction sources and
recommend potential analysis refinements. The analysis, which discovered
several needed corrections and possible technical refinements, was completed to
prepare CDM staff to respond on behalf of Los Angeles World Airports to
comments in public workshops.
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PJ25) Air Quality Impacts; Environmental Impact Reports
Industry: Municipality
Client: City of Antioch
Prime Contractor: BlueScape
Review of Air and Other Environmental Impacts: Large Power Generation Facility
in Antioch, California. Retained by the City of Antioch, an Intervener, to
review the California Energy Commission's (CEC) Preliminary Staff Assessment
for the Pittsburg District Energy Facility. City of Antioch was concerned that
the proposed power plant might adversely impact environmental and community
resources within the Antioch area. Worked as a team with Resource Catalysts and
Rothrock Consulting to educate and represent Antioch in the CEC licensing
process. The team developed written testimony regarding potential impacts to
air quality, water quality, and infrastructure. Attended workshops and hearings
to obtain information and present City of Anitoch's concerns to CEC staff.
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PJ26) Air Quality Impacts; Environmental Impact Reports
Industry: Metal Processing
Client: California Steel Industries
Prime Contractor: ECS
Air Quality Impact Study; 500 MMBtu/hr Reheat Furnace in California. Completed
an air quality impact analysis to support an environmental impact report for
installation of a new, large Reheat Furnace #5. The work involved estimating
maximum potential criteria pollutant emissions, and completing an air toxics
health risk assessment. The air emissions study accounted for Reheat Furnace #5
emissions, removal of an old reheat furnace, and emissions increases from
debottlenecked sources. The health risk assessment accounted for cumulative
impacts from several sources near Reheat Furnace #5. The air quality impact
study determined that NOx and PM10 emissions increases would be CEQA
significant, and health risk impacts would not be significant.
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PJ27) Air Quality Impacts; Environmental Impact Reports
Industry: Electric Power Generation
Client: PG&E Dispersed Generating Company, LLC
Prime Contractor: Resource Catalysts
Public Hearings in City of Escondido; Air Quality Impacts, Southern California.
Represented air quality impacts before the public in workshops and hearings.
PG&E DG sought City of Escondido approval for a 49 MW peaker power plant. The
cityÕs regulations required an environmental impact report for daily emissions
over stringent thresholds. Although PG&E DG and the Escondido Planning
Commission staff agreed that the EIR thresholds did not apply to the project,
the project received strenuous opposition from public members and City Council
staff. Explained that air quality impacts would not exceed health risk
thresholds if the project were allowed to proceed. The project won narrow
approval in City Council review and was commissioned in early 2002.
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PJ28) Business & Risk Management Plans for Chemical Storage &
Release
Industry: Electric Power Generation
Client: Intergen N.A.: Wildflower Energy LP
Prime Contractor: Resource Catalysts
Risk Management Plan and Business Plan for Aqua Ammonia Storage: Peaker Turbine
Facility in Otay Mesa, California. Completed a CalARP Risk Management Plan
(RMP) and Hazardous Materials Business Plan for storage of aqua ammonia at the
proposed Wildflower Energy Larkspur Power Generation facility in Otay Mesa.
Because the project was under a 21-day licensing process before the California
Energy Commission, the time schedule for work completion was very tight. Under
CalARP Program 2 requirements, BlueScape managed completion of the hazard
review, an off-site consequence analysis, and submittal of the RMP and business
plan documents. The plans were reviewed and approved by the County of San Diego
Department of Environmental Health Hazardous Materials Division.
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PJ29) Business & Risk Management Plans for Chemical Storage &
Release
Industry: Ammonia Storage and Refrigeration
Client: Hill Brothers Chemicals & Modern Ice and Cold Storage
Prime Contractor: DENALI, Inc.
Accidental Release Modeling; Anhydrous and Aqua Ammonia Storage. Completed
Program 2 CalARP (RMP) modeling studies for a chemical company that stores and
redistributes for sale anhydrous and aqueous ammonia, and a food cold storage
facility. For each facility, assessed the worst-case and alternative release
scenarios for each process utilizing ammonia, then calculated the source term
(ammonia release rates) for each process. The worst-case and alternative case
impacts were determined using the DEGADIS model and USEPA guidance.
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PJ30) Business & Risk Management Plans for Chemical Storage &
Release
Industry: Public Agency
Client: Modesto Irrigation District
Prime Contractor: DENALI, Inc.
Accidental Release Modeling; Acrolein Storage. The Modesto County Irrigation
District needed to assess the potential offsite consequence due to a worst-case
spill of acrolein from a storage facility. Used the AFTOX model to estimate the
offsite distance to the acrolein endpoint. Assumed that a worst-case spill of
all acrolein stored will be contained within an underground sump of determined
depth to reduce the extent of modeled impacts. Using the modeling refinement,
only a Program 1 Risk Management Plan was required, with minimal planning
requirements.
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PJ31) GHG inventory for a municipal solid waste landfill
Industry: Public Agency
Client:
Prime Contractor:
BlueScape prepared what we believe to be the first GHG inventory in California
for a landfill. We quantified direct emissions from collection activities,
landfill gas combustion and fugitive (uncaptured) landfill gas. Indirect
emissions from electrical generation were quantified based on utility records.
Total greenhouse gas emissions were quantified in terms of equivalent tons of
carbon dioxide. With methane having 21 times the global warming potency of
carbon dioxide, BlueScape was able to demonstrate that by capturing and
controlling methane via the landfill gas collection system, landfill operations
have a net benefit in reducing atmospheric impacts of GHG. Further, the two
landfill gas to energy electric generating facilities provided renewable energy
while reducing GHG emissions.
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