North Hebgen Multiple Resource Projecta123.g.akamai.net/7/123/11558/abc123/forestservic... · derived from any public assistance program, or protected genetic information in employment

North Hebgen Multiple Resource Project

Air Quality Report

Prepared by: Thomas Dzomba (R1 Assistant Director Air Quality and Smoke Management)

Jill McMurray (Air Quality Specialist)

for: Hebgen Lake Ranger District

Custer Gallatin National Forest

07/07/2015

The U.S. Department of Agriculture (USDA) prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual's income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all programs and/or employment activities.)

Air Quality Resource Report North Hebgen Multiple Resource Project

i

Contents Introduction ................................................................................................................................. 1

Issue ......................................................................................................................................... 1 Resource Indicators and Measures .......................................................................................... 1

Regulatory Framework ............................................................................................................... 2 Federal Clean Air Act .............................................................................................................. 2 Gallatin Forest Plan ................................................................................................................. 4

Methodology ............................................................................................................................... 4 Affected Environment ................................................................................................................. 7

Existing Condition ................................................................................................................... 7 Environmental Consequences ..................................................................................................... 9

Alternative 1 – No Action ....................................................................................................... 9 Alternatives 2, 3, and 4 – Proposed Actions .......................................................................... 10 Conclusion ............................................................................................................................. 12 Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans and Other Disclosures .................................................................................................................. 12 Acronyms .............................................................................................................................. 13

References Cited ....................................................................................................................... 14

Tables

Table 1: Resource indicators and measures for assessing effects.................................................... 1 Table 2 Modeling Scenarios and Source Area Descriptions .......................................................... 6 Table 3 SIS Model Assumptions by Burn Type .............................................................................. 7 Table 4 Sensitive Receptors within 50 Miles of the Project Area ................................................... 7 Table 5 SIS Model PM2.5 Results for North Hebgen Burn Scenarios ........................................... 10

Figures

Figure 1: North Hebgen Project Location ...................................................................................... 5 Figure 2: Location of Sensitive Receptors Relative to the Project Area ........................................ 8 Figure 3: 2009-2014 Wind Rose Data from Hebgen Lake RAWS for September-November ...... 9

Air Quality Resource Report North Hebgen Multiple resource Project

1

Introduction Smoke impacts to air quality have been identified as an analysis issue for the North Hebgen Project. There is concern that project related prescribed burning activities could potentially create unhealthy levels of particulate matter (PM) from smoke affecting adjacent landowners and recreating public. Smoke could also potentially cause reductions in visibility in nearby Class I airsheds.

PM of the size class<2.5 microns (PM2.5) are a health concern because they can be inhaled into the deepest parts of the lungs and enter the bloodstream. PM2.5 can cause tissue damage, emphysema, bronchitis, and exasperate cardiovascular conditions especially for sensitive groups; children, elderly, and individuals with pre-existing respiratory diseases. PM is a criteria pollutant regulated by the Environmental Protection Agency (EPA) under the Clean Air Act’s (CAA) National Ambient Air Quality Standards (NAAQS).

The focus of this analysis is to estimate potential smoke impacts to sensitive receptors located within 50 miles of the project area.

Issue

There is concern that smoke from prescribed burning could potentially cause unhealthy air quality conditions for people living or recreating in the area.

Resource Indicators and Measures

Indicator: PM2.5 concentrations due to smoke from prescribed burning were estimated through dispersion modeling and used as an indicator to assess smoke impacts on air quality and public health. This indicator was used to ensure prescribed fires are meeting the national ambient air quality standards (NAAQS) which require the concentration of PM2.5 not to exceed 35 µg/m3 in a 24 hour period. This includes PM from project actions, baseline background conditions, and other emission releasing activities. Concentration of PM 2.5 from prescribed burns was modeled using the Smoke Impact Spreadsheet (SIS) using inputs from the First Order Fire Effects Model (FOFEM) for broadcast burning and the CONSUME Model for pile burns.

Table 1: Resource indicators and measures for assessing effects Resource Element Resource Indicator Measure

Used to

address: P/N, or key issue?

Source

Air Quality Smoke concentration 24 hr PM 2.5> 35 µg/m3

Yes National Ambient Air Quality Standards (NAAQS) within the Clean Air Act (CAA)


2

Regulatory Framework

Federal Clean Air Act The 1963 Clean Air Act (CAA) (www.epa.gov/air/caa/title1.html), as amended in1970, 1977, and 1990 (42 U.S.C. §7401 et seq.) provides the foundation for protections of clean air on federal lands. The 1977 Clean Air Act amendments direct Federal Land Managers (FLMs) to “preserve, protect, and enhance the air quality” in 156 mandatory Class I national parks and wilderness areas (42 U.S.C. 7470 et seq.). Class I areas are wilderness areas that were designated before August 7, 1977 and are larger than 5,000 acres). All other land managed by the FLMs are designated Class II. Under the CAA the Federal Agencies including the Forest Service are held responsible to protect air quality related values (AQRVs) in Class I areas. The North Hebgen Project Area lies within Class II federal lands. The nearest Class I area is Yellowstone National Park, which is adjacent to some units that are part of the proposed action.

National Ambient Air Quality Standards-40 CFR part 50 Under the CAA, National Ambient Air Quality Standards (NAAQS) were established (40 CFR part 50). NAAQS identified 6 criteria pollutants and established standards for each that must be met by state and federal agencies, and private industry. Criteria pollutants include carbon monoxide, lead, nitrogen dioxide, ozone, particulate pollution (PM2.5 and PM10), and sulfur dioxide. For the North Hebgen Project the primary concern is with 24-hr PM2.5 emissions from prescribed fire. The primary PM2.5 standard requires concentrations of PM2.5

not to exceed a 24-hr average of 35 µg/m3 (micrograms per cubic meter). Average annual PM2.5 concentrations are not to exceed 12 µg/m3.

Conformity Determinations The general conformity provisions of the CAA (Section 176(c)) prohibit federal agencies from taking any action within a non-attainment area that causes or contributes to a new or existing violation of the standards or delays the attainment of a standard. All of Gallatin County including The North Hebgen Project area is in attainment. One smoke management impact zone exists in Airshed 8A around Big Sky (Impact zone “BS”); this zone would not be impacted by smoke produced from implementation of the North Hebgen Project.

Regional Haze Rule- 40 CFR Part 51. Haze is created when sunlight hits and is either absorbed or scattered by air pollution particles. EPA’s 1980 visibility rules (40 CFR 51.301-307) were developed to protect mandatory Class I areas from human-caused impairments reasonably attributable to a single or small group of sources. In 1988 EPA and other agencies began monitoring visibility in Class I areas. The 1999 Regional Haze Rule (40 CFR 51.308-309) called for states to establish goals to improve visibility in mandatory Class I areas and to develop long-term strategies to reduce the emissions of air pollutants that cause visibility impairment. The regional haze regulations apply to all states, including those states that do not have any Class I areas. The Regional Haze regulations require states to demonstrate reasonable progress for improving visibility in each Class I area over a 60-year period (to 2064), during which visibility should be returned to natural conditions. The North Hebgen project is a Class II Airshed, but two Class I airsheds are within 50 miles of the project area. Red Rock Lakes is

http://www.epa.gov/air/caa/title1.html


3

located approximately 22 miles west of the project area, while Yellowstone National Park adjacent to some units in the project area. (http://deq.mt.gov/airmonitoring/citguide/understanding.mcpx).

The Interim Air Quality Policy on Wildland and Prescribed Fires (U.S. EPA 1998) On May 15, 1998, the EPA issued the Interim Air Quality Policy of Wildland and Prescribed Fire to address impacts to public health and welfare (EPA 1998). The goal of the Interim Policy is to allow fire to function in an ecological role to help maintain healthy ecosystems while balancing the need to protect public health and welfare from the impacts of fire-related air pollution emissions. The Interim Policy is interim only because it does not yet address agricultural burning or regional haze (EPA 1998). The Interim Policy suggests that air quality and visibility impact evaluations of fire activities on Federal lands should consider several different items during planning (EPA 1998). In a project level NEPA document, it is appropriate to consider and address to the extent practical, a description of applicable regulations, plans, or policies, identification of sensitive areas (receptors), and the potential for smoke intrusions in those sensitive areas. Other important disclosure items include applicable smoke management techniques, participation in a basic smoke management program, and potential for emission reductions. Ambient air quality and visibility monitoring (for Class I areas) are typically done collaboratively with the states. Impacts to regional and sub-regional air are addressed operationally through a coordinated smoke management program. The EPA urges states to develop, implement and certify smoke management programs that meet the recommended requirements of the Interim Policy. If a “certified” program is in place and smoke exceeds the particulate standard, it may not be considered a violation by EPA. The State of Montana operates an EPA-certified smoke management program.

The Wilderness Act

The Wilderness Act of 1964 mandates that wilderness areas be managed to protect and restore as necessary the natural wilderness conditions (16 U.S.C. 1131-1136).

State Level Direction and Regulations State Implementation Plans

Each State is required under the CAA to have a State Implementation Plan (SIP) which identifies how the State would maintain or attain NAAQS (Section 110(h)(1)). The Montana SIP was approved by EPA and promulgated through the Montana Clean Air Act and implementing regulations to provide specific guidance on maintenance of air quality, including restrictions on open burning (ARM 16.8.1300). The Montana Department of Environmental Quality (MTDEQ) has the regulatory authority to implement and enforce Air Quality in Montana. The Custer Gallatin National Forest would cooperate with the MTDEQ Air Quality Bureau and meet the requirements of the Montana SIP.

Montana Code Annotated – Title 75. Environmental Protection

http://deq.mt.gov/airmonitoring/citguide/understanding.mcpx


4

The Clean Air Act of Montana, Chapter 2 Air Quality provide state regulatory requirement outlines intent, limitations, and powers associated to the regulatory agency within the State of Montana.

Administrative Rules of Montana (ARM) Title 17, Chapter 8, Subchapter 6

This rule covers the general provisions of open burning including, definitions, restrictions on non-burnable material, and major/minor burner requirements.

Smoke Management

The Forest Service is considered a major open burner in the state of Montana (any entity that emits more than 500 tons of carbon monoxide or 50 tons of any other regulated pollutant per calendar year), and conducts prescribed burning under the provisions of an annual open burning permit issued by MTDEQ (http://deq.mt.gov/AirQuality/OpenBurn/2015/USDAForestService.pdf).

The Forest Service is a member of the MT/ID Airshed Group (www.smokemu.org) and prescribed burning associated with the North Hebgen project would follow the guidelines established in the MT/ID Airshed Group’s Operating Guide (http://smokemu.org/docs/2010%20Operations%20Guide.pdf). Planned permitted burns would be submitted to the Smoke Monitoring Unit (SMU) in Missoula, MT. For each burn planned, the type of burn, the number of acres to burn, location and elevation of each site would be provided to the SMU. The MT/ID Airshed Group Smoke Program Coordinator would use the burn information, along with meteorological forecasts, to recommend burn restrictions for airsheds with planned burning. The SMU issues daily burn recommendations for airsheds, elevations, or impact zones on the MT/ID Airshed Group Website.

All prescribed fires implemented within the North Hebgen Project would comply with these regulatory policies and statutes.

Gallatin Forest Plan The Gallatin National Forest Land and Resource Management Plan (Forest Plan) provides standards and guidelines for meeting and maintaining state and national air quality standards and protecting air quality related values on National Forest System lands.

• The Forest will cooperate with the Montana Air Quality Bureau (now MTDEQ) to meet SIPs and Montana Smoke Management Plan will be met.

• Prescribed fire objectives for smoke management will be met within the constraints established by the MT/ID Airshed Group’s Memorandum of Understanding.

Methodology Spatial and Temporal Bounds of Analysis

Spatial Bounds: Figure 1 depicts the North Hebgen Project Area. The air quality modeling analysis performed for this project assessed potential smoke impacts up to 50 miles from potential burn locations within the project area. Cumulative effects associated with proposed activities are assessed throughout the air quality modeling domain. Based on the air modeling results, direct and indirect effects are more realistically limited to areas within one mile of any burn location.

http://deq.mt.gov/AirQuality/OpenBurn/2015/USDAForestService.pdf

http://www.smokemu.org/

http://smokemu.org/docs/2010%20Operations%20Guide.pdf


5

Temporal Bounds: Smoke associated with pile burning is expected to occur at various intervals throughout the life of the project. For this analysis, time periods associated with proposed treatments and subsequent effects would be limited to the duration of proposed treatments. Air quality effects from burning activities are anticipated to dissipate within 24 hours.

Figure 1: Map Showing the Project Area


6

Methods:

Potential air quality impacts from the North Hebgen project were determined using the Smoke Impact Spreadsheet (SIS) model (Air Sciences, 2004). The SIS model predicts ambient PM2.5 concentrations from burning activities for up to 50 miles downwind of the burn. Emissions data is obtained from the CONSUME 2.1 model for pile burns. A simplified version of the CALPUFF model is used to determine downwind PM2.5 concentrations. Model Assumptions

For model purposes, the North Hebgen project was broken into five distinct areas. These areas were identified due to either elevation, mixture of species, and/or type of burning. The areas are as follows:

Horse Butte: Units on Horse Butte Peninsula, in the southern half of the project area.

Rainbow-Cougar-Duck: Units east of Rainbow Point, north of Madison Arm, and south of Duck Creek and Cougar Creek, in the southern half of the project area.

Red Canyon: Units in the Red Canyon Area in the northern half of the project area.

Whit’s Lower Tepee: Units in the Whit’s Lake Area and the lower portion of the Tepee Creek Fuel Break Area, in the northern half of the project area.

Upper Tepee: Units in the upper portion of the Tepee Creek Fuel Break Area, in the northern half of the project area.

The combination of different areas and the type of pile burning to be performed resulted in a total of eight different modeling scenarios as listed in Table 2:

Table 2 Modeling Scenarios and Source Area Descriptions

Scenario # Source Area Burn Type Primary Species -

% Secondary Species -

% 1. Horse Butte Landings Douglas Fir – 70% Lodgepole Pine –

30% 2. Hand Piles

3. Rainbow Cougar Duck Landings Lodgepole Pine – 100% --

4. Red Canyon Landings Douglas Fir – 90% Lodgepole Pine – 10%

5. Whit’s Lake Area Landings Douglas Fir – 80% Lodgepole Pine – 20%

6. Upper Tepee Landings Lodgepole Pine – 60% Subalpine Fir – 50%

7. Upper Tepee Landings Lodgepole Pine – 50% Subalpine Fir – 50%

The Following Burn Types are Common to all Units

8. Rainbow Cougar Duck

Red Canyon Whit’s Lake Area

Upper Tepee Horse Butte

Hand Piles Lodgepole Pine – 100% --

9. Grapple Piles Lodgepole Pine – 100% --


7

Table 3 lists SIS model assumptions for each burn type modeled:

Table 3 SIS Model Assumptions by Burn Type

Pile Burns

Pile Type Pile Size (w h l)

Packing Ratio

%

# burned

/day

Min. btwn Starts

10 ft. Wind Speed

Burn Date

Avg. Temp.a

Mixing Height

(ft. agl)b

Stability Class

Landings 50w20h75l 20 5 30 8 mph Nov 35 3600 Unstable Grapple 10w8h10l 20 50 10 8 mph Nov 35 3600 Unstable

Hand 10w8h10l 20 100 5 8 mph Nov 35 3600 Unstable a Temperature data averaged from data measured at the Hebgen Lake RAWS station (http://www.raws.dri.edu/cgi-bin/rawMAIN.pl?mtMHEB) b Mixing Height estimated using the Ventilation Climate Information System (http://smoke.airfire.org/vcis/#/)

Incomplete and Unavailable Information

The information required for the air quality analysis is complete.

Affected Environment

Existing Condition The North Hebgen Project lies in the southern part of Airshed 8A which shares the same borders with Gallatin County. Currently Airshed 8A is in attainment of all NAAQS. One smoke management impact zone exists in Airshed 8A around Big Sky (Impact zone “BS”).

Background 24-hour PM2.5 concentrations are estimated to be 3 µg/m3. This number was determined by averaging 2010 – 2014 annual average PM2.5 values at the West Yellowstone monitoring site operated by MTDEQ (Site ID 30-031-0017; data obtained from the EPA Air Quality System (AQS) database).

The nearest Class I airshed is Yellowstone National Park whose boundary is adjacent to the nearest treatment area. Red Rock Lakes National Wildlife Refuge is a Class I airshed located approximately 22 air miles west of the project area.

Table 4 lists the sensitive receptors (excluding nearby residences) within 50 miles of the project area. Relative location of sensitive receptors is also shown in Figure 2.

Table 4 Sensitive Receptors within 50 Miles of the Project Area

Receptor Type Approx. Distance (miles)1 Direction

Yellowstone NP Class I Airshed Adjacent E Lee Metcalf Wilderness (FS) Class II Airshed Adjacent N

West Yellowstone, MT City 4 S Big Sky Impact Zone 13 NNW

Red Rock Lakes NWR Class I Airshed 22 WSW Gardiner, MT City 24 NE Cameron, MT City 24 NW Island Park, ID City 24 SW Emigrant, MT City 35 NE

Lee Metcalf Wilderness (BLM) Class II Airshed 38 NNW

http://www.raws.dri.edu/cgi-bin/rawMAIN.pl?mtMHEB

http://smoke.airfire.org/vcis/#/


8

Receptor Type Approx. Distance (miles)1 Direction

Pray, MT Town 38 NE Virginia City, MT City 38 NW Warm River, ID City 44 SSW

Gallatin Gateway, MT Town 44 N Ennis, MT City 45 NNW Norris, MT City 46 NW Alder, MT City 46 NW Ashton, ID City 49 SW

McCallister, MT Town 50 NW 1 Distance represents closest distance from the project boundary to the sensitive receptor boundary.

Figure 2: Location of Sensitive Receptors Relative to the Project Area

Figure 2: Location of Sensitive Receptors Relative to the Project Area


9

Figure 3 depicts 2009 – 2014 wind rose data for September – November from the Hebgen Lake Remote Automated Weather Station (RAWS). It is anticipated that pile burning activities would occur during this time frame. The wind rose data indicates that winds predominately occur from the SW during this time of year. Thus, of the sensitive receptors listed in the Table 4, Yellowstone NP, Gardiner MT, Emigrant, MT, and Pray MT are likely receptors in the path of smoke generated by project burning. However, given the distance that Gardiner, Emigrant, and Pray are away from the project area, it is unlikely that they would be impacted by smoke from this project.

Figure 3: 2009-2014 Wind Rose Data from Hebgen Lake RAWS for September-November

Hebgen Lake RAWS Daytime Wind Rose Hebgen Lake RAWS Nighttime Wind Rose

Resource Indicator or Measure

Existing sources of emissions include smoke from residential wood burning stoves, snowmobile emissions, vehicle emissions, private and agency prescribed burns, limited construction, and smoke from wildland fires. The primary air quality indicator for this project is ensuring that cumulative emissions from existing sources and pile burning associated with this project do not exceed the 24-hour NAAQS of 35 µg/m3.

Environmental Consequences

Alternative 1 – No Action The No Action alternative means that the anticipated fuels treatments (and associated prescribed burning) proposed in the North Hebgen project would not take place.

Direct and Indirect Effects

Alternative 1- no action would, in the short-term, have less negative direct effects to air quality than other alternatives since no treatments would take place. However, the no treatments action of Alternative 1 does not manage for fuel loading in the project area. Over time, vegetative growth will continue to follow


10

successional pathways, increasing fuel loads and increasing the potential of large wildfires. The indirect effects of fuel loading leading to a wildfire would in most cases, have greater impact to air quality than in other alternatives.

Cumulative Effects

Alternative 1-no action, would not contribute to short-term negative cumulative effects to air quality since no treatments would take place. The indirect effects of fuel loading leading to a large wildland fire would in most cases, have greater negative cumulative impact to air quality than other alternatives.

Alternatives 2, 3, and 4 – Proposed Actions Air quality modeling for this project is not based on the specific treatment scenarios presented in each action alternative, but rather type of pile and number of each type that could be burned in a single day, as described in Table 3. Therefore, the air quality modeling analysis presented is valid for any of the action alternatives.

Under the proposed action alternatives, fuels reduction, wildlife habitat improvement, and other treatments would take place as part of the North Hebgen project. These activities would generate landing piles, grapple piles, and hand piles that would be burned as part of this project. Pile burning activities would most likely to take place in the November (fall to late fall) timeframe.

Direct and Indirect Effects

The action alternatives would have a direct, short term impact on air quality in the project area. Pile burns could produce smoke that, in a worst case scenario, could settle in low lying areas during evening hours after ignition. Smoke could also cause nuisance conditions such as short term reduced visibility along highways, smell, or haze.

Table 5 lists the modeled PM2.5 concentrations (in µg/m3) for each modeled scenario, at specific downwind distances from the burn location (background concentrations not included).

Table 5 SIS Model PM2.5 Results for North Hebgen Burn Scenarios

Scenario # Source Area Burn Type

Total PM2.5

Emissions (Tons)

PM2.5 Concentration (µg/m3) – Distance Downwind from Source

(mi) 0.1 0.5 1 2 5 10

1. Horse Butte Landings 3.2 67 23 8.1 4.9 2.7 1.5 2. Horse Butte Hand Piles 0.7 74 13 5.0 2.1 0.97 0.42 3. Rainbow Cougar Duck Landings 2.8 59 20 7.2 4.3 2.4 1.3 4. Red Canyon Landings 3.3 69 23 8.4 5.1 2.7 1.5 5. Whit’s Lake Area Landings 3.2 68 23 8.3 5.0 2.7 1.5

6. Upper Tepee

Landings (50-50) 2.8 59 20 7.1 4.3 2.3 1.3

7. Landings (60-40) 2.8 59 20 7.2 4.3 2.3 1.3

8. Rainbow Cougar Duck Red Canyon

Whit’s Lake Area Upper Tepee

Hand Piles 0.6 65 15 6.3 2.9 1.2 0.42

9. Grapple Piles 0.3 32 7.5 3.1 1.4 0.56 0.21


11


Total PM2.5

Emissions (Tons)


(mi) 0.1 0.5 1 2 5 10


Total PM2.5

Emissions (Tons)


(mi) 15 20 25 30 40 50

1. Horse Butte Landings 3.2 0.99 0.75 0.61 0.53 0.48 0.47 2. Horse Butte Hand Piles 0.7 0.28 0.20 0.15 0.12 0.08 0.06 3. Rainbow Cougar Duck Landings 2.8 0.87 0.66 0.53 0.46 0.41 0.41 4. Red Canyon Landings 3.3 1.0 0.77 0.63 0.54 0.49 0.48 5. Whit’s Lake Area Landings 3.2 1.0 0.76 0.62 0.54 0.48 0.47

6. Upper Tepee

Landings (50-50) 2.8 0.86 0.65 0.53 0.45 0.40 0.41

7. Landings (60-40) 2.8 0.87 0.65 0.53 0.45 0.41 0.41

8. Rainbow Cougar Duck Red Canyon

Whit’s Lake Area Upper Tepee

Hand Piles 0.6 0.26 0.18 0.13 0.10 0.07 0.05

9. Grapple Piles 0.3 0.13 0.09 0.06 0.05 0.03 0.02

The model results predict that, even incorporating a background concentration of 3 µg/m3, PM2.5 concentrations fall below the NAAQS within 0.5 miles of any pile burning activity. The greatest potential impact would be to residents near burn locations.

Alternative 2 proposes the largest amount of acres treated (5895) as opposed to Alternative 3 (4831 acres) and Alternative 4 (5346 acres). Thus it is conceivable that more pile burning will take place under Alternatives 2 and 4 as opposed to Alternative 3. Increased pile burning would mean that there would be more days where pile burning would take place; however, the number of piles burned on any given day would still be limited by the number of piles for each pile type given in Table 3.

When units are burned, Best Available Control Technologies (BACT) would be used in accordance with Montana ARM Unit 17, Chapter 8, Subchapter 6. This includes burning under good dispersion conditions, use of emission reduction techniques as necessary, and limiting the amount of burning done at one time as necessary. Burns conducted during the fall burning season would be burned when recommended by the MT/ID Airshed Group. While pile burning is planned for the November timeframe, there is a possibility that burning could occur during the winter months. In such cases, burning would take place after direct coordination with MTDEQ.

Cumulative Effects

Air resources are somewhat unique in that the past impacts to air quality are not usually evident or cumulative. The North Hebgen Project emissions would be cumulative only with those local emission sources described in the Affected Environment Section occurring at the time of burning. The greatest potential for cumulative effects would be from pile burn smoke mixing with residential wood smoke. These potential impacts would be localized in nature, and can be mitigated by burning under favorable dispersion conditions or reducing the number of piles burned on a given day. Other emission sources are


12

likely to add little or no additional impacts beyond the direct and indirect effects from burning activities associated with this project.

Conclusion The SIS model was used to assess potential smoke impacts from pile burning activities associated with the North Hebgen Project. Model results predict that no significant impacts to human health are anticipated from burning activities associates with this project. PM2.5 concentrations would fall below the 35 µg/m3 24-hour NAAQS within 0.5 miles of the burn location for all pile burning activities anticipated for this project. Short term impacts would likely be to residents living near burn locations and nuisance impacts such as reduced visibility across highways. There is potential for smoke to intrude into Yellowstone National Park but significant visibility impacts are not expected due to the short-term duration of any smoke intrusions. Other sensitive receptors within 50 miles of a burn are not likely to be impacted by smoke.

The greatest potential for cumulative effects would be smoke from pile burning mixing with residential wood smoke. Any impacts due to these potential cumulative impacts would likely be localized in nature and insignificant.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans and Other Disclosures The Forest Plan specifies that

• The Forest will cooperate with the Montana Air Quality Bureau (now MTDEQ) to meet SIPs and Montana Smoke Management Plan will be met.

• Prescribed fire objectives for smoke management will be met within the constraints established by the MT/ID Airshed Group’s Memorandum of Understanding.

The EPA has delegated CAA compliance authority to the state of Montana, under the auspices of MTDEQ. Thus, compliance with state environmental laws and regulations also satisfies compliance with the federal CAA.

Any burning associated with this project would be conducted in accordance with the Forest Service Open Burning Permit from MTDEQ, and in compliance with Montana open burning regulations. This includes the use of BACT to minimize potential smoke impacts. Burning conducted during the fall burning season would be coordinated through the MT/ID Airshed Group, which makes go/no go recommendations based on forecasted meteorology and air quality conditions, along with consideration for any additional major open burning occurring near the area. The MT/ID Airshed Group coordinates burning activities during the fall burning season directly with MTDEQ. Should burns need to be conducted during the winter burn season, burning would be coordinated directly with MTDEQ. These measures are incorporated in all action alternatives and would ensure compliance with the Forest Plan, the CAA, and the Administrative Rules of Montana as they pertain to air quality and open burning.

/s/ Thomas Dzomba, Air Quality Specialist July 7, 2015 … Name and title Date


13

Acronyms

AQRV-Air Quality Related Values

AQS – EPA Air Quality System Database

BACT – Best Available Control Technology

CAA- Clean Air Act

EPA- Environmental Protection Agency

FLM-Federal Land Manager

FOFEM- First Order Fire Effects Model

MTDEQ- Montana Department of Environmental Quality

NAAQS- National Ambient Air Quality Standards

PM2.5 – Particulate Matter less than 2.5 microns

PSD – Prevention of Significant Deterioration

SIP – State Implementation Plan

SIS – Smoke Impact Spreadsheet

SMU – MT/ID Airshed Group Smoke Monitoring Unit


14

References Cited

Administrative Rules of Montana, Title 17, Chapter 8, Air Quality, ARM 17.8.

Anderson, H.E, Aids to Determining Fuel Models For Estimating Fire Behavior, US Forest Service General Technical Report INT-122, April 1982,

CAA 42 U.S.C. 7401. The Clean Air Act of December 17, 1963, 88-206, as amended.

Montana Idaho Airshed Group, Operating Guide, 2010.

Western Regional Climate Center, Hebgen Lake Remote Automated Weather System, http://www.raws.dri.edu/cgi-bin/rawMAIN.pl?mtMHEB

United States Environmental Protection Agency, Interim Air Quality Policy for Wildland and Prescribed Fires, 63 FR 27957, May 21, 1998.

United States Environmental Protection Agency, Regional Haze Regulations, Final Rule, 40 CFR 51 35714, July 1, 1999

United States Forest Service, Pacific Northwest Research Station, AirFire Research Team, Ventilation Climate Information System, (http://smoke.airfire.org/vcis/#/)

http://www.raws.dri.edu/cgi-bin/rawMAIN.pl?mtMHEB

http://smoke.airfire.org/vcis/#/

Documents

North Hebgen Multiple Resource Projecta123.g.akamai.net/7/123/11558/abc123/forestservic... · derived from any public assistance program, or protected genetic information in employment