Derivation of exemption formulas for air quality regulatory applications

Abstract

The regulatory agencies and the industries have the responsibility for assessing the environmental impact from the release of air pollutants, and for protecting environment and public health. The simple exemption formula is often used as a criterion for the purpose of screening air pollutants. That is, the exemption formula is used for air quality review and to determine whether a facility applying for and described in a new, modified, or revised air quality plan is exempted from further air quality review. The Bureau of Ocean Energy Management’s (BOEM) air quality regulations are used to regulate air emissions and air pollutants released from the oil and gas facilities in the Gulf of Mexico. If a facility is not exempt after completing the air quality review, a refined air quality modeling will be required to regulate the air pollutants. However, at present, the scientific basis for BOEM’s exemption formula is not available to the author. Therefore, the purpose of this paper is to provide the theoretical framework and justification for the use of BOEM’s exemption formula. In this paper, several exemption formulas have been derived from the Gaussian and non-Gaussian dispersion models; the Gaussian dispersion model is a special case of non-Gaussian dispersion model. The dispersion parameters obtained from the tracer experiments in the Gulf of Mexico are used in the dispersion models. In this paper, the dispersion parameters used in the dispersion models are also derived from the Monin-Obukhov similarity theory. In particular, it has been shown that the total amount of emissions from the facility for each air pollutant calculated using BOEM’s exemption formula is conservative.

Implications: The operation of offshore oil and gas facilities under BOEM’s jurisdiction is required to comply with the BOEM’s regulations. BOEM’s air quality regulations are used to regulate air emissions and air pollutants released from the oil and gas facilities in the Gulf of Mexico. The exemption formulas have been used by BOEM and other regulatory agencies as a screening tool to regulate air emissions emitted from the oil and gas and other industries. Because of the BOEM’s regulatory responsibility, it is important to establish the scientific basis and provide the justification for the exemption formulas. The methodology developed here could also be adopted and used by other regulatory agencies.

Acknowledgment

The author thanks and appreciates the anonymous reviewers for their comments and suggestions on the manuscript, which resulted in substantial improvement of the paper.

Additional information

Notes on contributors

C.H. Huang

C.H. Huang is a certified consulting meterorologist in the Physical/Chemical Sciences Section at the Bureau of Ocean Energy Management, Gulf of Mexico OCS Region, the Department of the Interior, New Orleans, LA.