3 Individual Submissions

5.2.1

Criteria for non-criteria air pollutants should be derived traceably from toxicological data:

• WHO Guidelines

• US EPA Reference Concentrations (IRIS)

• California Office of Environmental Health Hazard Assessment Reference Exposure Levels.

Agreed.

Significant rewrite of section 5.

Questions inclusion of Washington acceptable source impact levels. These are supposed to be the same as IRIS reference concentrations (annual average) but use a different time average (24-hour average).

Agreed.

Washington ASIL recommendations removed.

Should include hazard quotient/hazard index approach – for multiple pollutants.

Noted.

No action.

5.2.1

Should cross-reference to 8.5.2 (or bring 1 in 10,000 acceptable risk into 5.2.1.

Agreed.

Done.

Attached report on “Comparative Health Risks from General Population Exposures to Hazardous Air Pollutants” by S Stevenson and B Mills, Ministry of Health. Examines the likelihood of adverse health effects in pop as a result of exposure to hazardous substances – reviewing local and international literature. Focus on long term exposure of majority of population. This includes likely levels of some pollutants. Suggests the GPG could refer to it (although MoH may need to add to website first).

Noted.

No action.

p.57

Should consider ingestion of pollutants in depositing dust (pollutant concentrations can be much higher in depositing dust than soil accumulation).

Noted.

Overtaken by removal of health risk assessment section.

8.4.2

Ref to GPG for atmospheric dispersion modelling on NOx / NO2 assessments. Ozone Limiting Method (not clear for practitioners).

GPG industry opportunity to update description of NO2.

Suggest brief description in 8.4.2 and new appendix.

Attached unpublished report which attempts to simplify process – this report could be reduced for GPG.

Much appreciated.

A new section on NOx conversion has been added as an Appendix. This includes some new analysis, relevant mainly to Auckland and other major urban centres that might experience NOx issues.

Appreciates the efforts of MfE guidance.

Noted.

Figure 1.1

Should add GPG for dust (2001) and odour (2004).

Agree.

Figures 1.1 and 1.2 amended.

Figure 1.2

Remove “Odour Management under the RMA” (Superseded by “Odour GPG”).

Agree.

Figures 1.1 and 1.2 amended.

Table 6.1

Sensitivity similar to odour table in Odour GPG – however these ratings are not similarly applicable to human health or ecosystems

Suggested deletions where disagree (in table attached).

Agree.

Table 6.1 clarified, rural residential upgraded to ‘medium to high’ sensitivity.

Figure 7.1

Missing link from assessment of PM10 in airshed back to assessment of other contaminants.

Agree – incorporate.

Done.

Overall comments

Useful overview of regional council process.

Need guidance on ground level concentrations for comparing dispersion modelling results with ambient air quality guidelines and standards ie, ARC tiered approach “Assessing Discharges of Contaminants to Air”.

Need guidance on SO2 regarding GPG on dispersion modelling, i.e. compare 99.9% of NES on 350 or 570 µg/m3 value?

Noted.

Noted.

Agreed, to address.

Whilst clear guidance on ‘acceptable levels’ when comparing model outputs with criteria would be helpful, it would not be applicable for PM10. There is further, always an exception to disprove the rule. This is not considered doable in a national guidance document attempting to cover all eventualities.

Section 8.45 added to provide guidance on comparison of modelling values with NES.

General

Support guide and nationally consistent approach.

Concern that local authorities may not pay attention to it given their inconsistent approach to defining airsheds and consent processing.

Expressed concerns over NES in current form.

Noted.

No action.

Specific

Guide would be improved with more examples and Holcim could assist with this.

Offer appreciated, however, considered that smaller sites less useful than a larger case study. No appropriate example available at time of writing.

No action.

3.1

Recommended change: “Air discharge consent applications can be complex” to “Air discharge consent applications can range from relatively simple to complex”.

This sentence intends to note that majority of assessment of environmental effects for air quality is actually quite complex.

Clarified original text.

3.1.1

Strongly support recommendation for pre-application meeting.

Noted.

Highlighted in the new “Recommendations”.

Figure 4.2

Figure indicates that the tiers relate to type of consent required, but not always true in practice. Recommend delete row “type of consent”.

Agreed, to amend.

Done.

5.1.1

Offset guidance concerning/confusing. If on / below path to compliance, need to offset change in concentrations. This may be hasher than requirements for above path to compliance.

Recommend: if on / below path, offsets only required where concentrations push levels above path.

Noted.

This section specifically refers only to airsheds that breach the PM10 standard. It is acknowledged that this area is still evolving and difficult to address.

Section 5
Air quality criteria

Concern over remarks at workshop about EPA Victoria air quality criteria.

The 1999–2002 review of ambient air quality guidelines adopted a risk assessment approach for hazardous risk pollutants. Provided an example report prepared in 2000 – An Assessment of Dioxin and PCB Emissions to Air from Steel Making at Pacific Steel, Otahuhu.

Noted.

Noted.

No action.

Concern over support for Texas Commission effects screening levels; these primarily relate to occupational exposure.

Attached a copy of Ethics, Threshold Limit Values and Community Air Pollution Exposures by Jim Tarr.

Section 5 now references California and US EPA criteria (including unit risk factors for carcinogens).

Noted.

No action.