The Undertaking Is Calling… A surprising potential minor source story Brandy Toft Air Quality Specialist Leech Lake Band of Ojibwe National Tribal Forum 2014

The Frantic Call…  Cranes!  Moon suits!!  Crematory!!!  INSTALLING NOW!!!  Why don’t you know?!?!?  What are YOU going to do???

Fire Hall Garage B and G Club District Offices OffceOffce Day Care Residences Library Health Div

“THE UNDERTAKER IS IN…” It’s not everyday that you get this call…

Chatting with the Undertaker  Applied for City permits  Unit from “residential area”  Puzzled but Cooperative  Will do what needs to be done…

Call MPCA Who has Crematory information? Call Laura Call who Laura directed me to – R5 Call R5 again Scratch head… Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 Scratch head again…

PTE Calculations Many questions:  Fuel Source?  Throughputs…?  Operational times?  Location?  Are these right?

To Be or Not to Be a Minor Source??? Manufacture PTE #’s  SO  NOx  VOC/TOC  Lead  PM & PM  CO0.936  Hg??? EPA Minor Thresholds  SO210  NOx10  VOC 5  Lead0.1  PM & PM10 10 & 5  CO10  HAPs (Hg)*10 * 10 tons of HAPs or combo of 25 tons total

Minnesota Pollution Control Agency  No MPCA Permit required  Health Department License  subpart 3 MN Administrative Rules 1.Smoke and Odor (nuisance) 2.Require no mercury controls 3.No greater than 20% opacity 4.Maintain 1200 degree flue gas temperature, 1600 degrees inside chamber

MPCA and EPA Guidance “ Good Engineering Practices” GEP – 1980’s Minimum – (downwash plume concerns) 1.5 x building height = stack height 1.5 x 12 ft = 18 ft Optimum 2.5 x building height = stack height 2.5 x 12 ft = 30 ft Compromised to a 24 foot stack in 4 foot sections Taller the stack = lessen the ground level impacts

Concerns for surrounding buildings Fire Hall Garage B and G Club District Offices OffceOffce Day Care Residences Library Health Div 130’ 203’ Going with 24ft stack from top of burner

Still Questions  Waiting for guidance from EPA retired!%#  MPCA and U of Mn study on dental algams – 3yr  Chemotherapy and other drugs – accounted for?  PTE does include natural gas as fuel source Nox levels higher?  No one is quite sure on any aspect… touchy political subject

What you can do…  Even when there is not a direct regulation use other regulations to enforce  e.g. nuisance, opacity  Find “Good Practices”  Work with other regulatory agencies  Find and use information outlets  Keep a positive relationship with source

Open doors and make connections… Brandy Toft Air Quality Specialist llojibwe.org 14