5. "NRM Plan," 14; R.G. Flocchini et al., "Characterization of Particles in the Arid West," Atmospheric Environment 15:10/11 (1981), 2017-2030; R.G. Flocchini, "A Synoptic Scale Fine Particle Monitoring Network in the Western U.S.," unpublished MS, ca. 1980 (THRO-L), unpaginated.
6. Angelo and Anderson, Western North Dakota Air Quality Study, 12, 27, and 33; Robert T. Angelo and Kurt W. Anderson, The Chemistry of Atmospheric Precipitation in North Dakota: A Preliminary Report With Comments on The Ambient Air Quality and Meteorological Characteristics of Western North Dakota in 1981 (Bismarck: NDSDH, 1982), 86, 88. TSP have exceeded the legal limits in a couple of instances, but only under extraordinary conditions such as a prolonged east wind or after the eruption of the Mount St. Helens volcano in May 1980. See Flocchini et al., 2020-2021.
10. Ibid., 32; Clifford Wetmore, "Lichens and Air Quality in Theodore Roosevelt National Park," unpublished MS, 1983 (THRO-A); L.P. Gough, J.L. Peard, R.C. Severson, L.L. Jackson, B.F. Arbogast, J.M. Motooka, S.W. Snow, E.E. Engleman, and J.P. Bennett, "Baseline Elemental Composition of Selected Plants and Soils, and Assessment of Airborne Element Contamination, Theodore Roosevelt National Park, North Dakota," USGS OpenFile Report 85251, 1985 (THRO-A); John P. Christiano (Chief, NPS Air Quality Division) to Harvey Wickware (Supt., THRO), memorandum, 16 December 1985 (THRO-A), 2-3.
13. Ibid., 6. See also 40 CFR (a)(13)(i) (14)(i). For a valuable explanation of the background and effect of the Clean Air Act Amendments of 1977 on the parks, refer to Robert Maynard, "The Clean Air Act Amendments and the National Parklands, " University of Michigan Journal of Law Reform 11:2 (Winter 1978), 290-316, and esp. 295 (for baselines).
14. Martin R. Shock, The Selection of a Complete Modeling Procedure for the Simulation of Mesoscale Ground Level Air Quality Considerations (Bismarck: NDSDH, 1981), 6. North Dakota was one of the first states to adopt PSD regulations (in January 1976). In May 1977, EPA delegated PSD enforcement responsibility to the state; see Final West-Central North Dakota Regional Environmental Impact Study on Energy Development (N.p., BLM and State of North Dakota, 1978), 12. See also Maynard, 296.
16. Air Pollution Control Regulations of the State of North Dakota (ND Administrative Code), Article 33-15, Chapter 33-15-15, paragraphs 4-6 (pp. 13-14); Final West-Central North Dakota EIS, 17. For a full discussion, see Maynard, 306-307.
17. Final West-Central North Dakota EIS, 21-23; Air Quality Effects Analysis and Permit Application of Western Natural Gas Processors, Ltd., Natural Gas Processing and Sulfur Recovery Plant, Billings County, North Dakota (Bismarck: NDSDH, 1979), 48.
21. The six projects for which variances were originally sought: Basin Electric Power Cooperative's 500 megawatt addition (AVS #3) to its Antelope Valley electric generating plant; Warren Petroleum's expansion of its Little Knife natural gas processing plant; Nokota's coal-to-methanol plant; a 500 megawatt generating station of Minnesota Power and Light; and gas processing plants of Amoco and Phillips Petroleum. See NPS Air and Water Quality Division's "Technical Review of Six PSD Permit Applications Potentially Affecting Theodore Roosevelt National Park and Lostwood National Wildlife Refuge," unpublished MS, 17 June 1982 (THRO-A), Table 2 (contained in unpaginated appendix).
24. Maynard, 303-305; and Richard A. Dobbins, Atmospheric Motion and Air Pollution (New York: John Wiley & Sons, 1979), 219-249, esp. 243. Shock (p. 4) writes: "The choice of input data, particularly the wind field, is a critical aspect of the air quality modeling process."
28. Ibid., 58; Maynard, 305; Air Quality Effects Analysis of Basin Electric Power Cooperative Antelope Valley Station Unit 3, Mercer County, North Dakota (Bismarck: Division of Environmental Engineering, NDSDH, 1982), 144-145. See also "State Coordinator's Monthly Report," 4 March 1980.
30. In a later study, the state admitted to the "post-processing of hourly output . . . in order to remove calm wind bias from calculated 3-hour and 24-hour concentrations. . . .", See Air Quality Effects Analysis of Cities Service Company Lignite Gas Plant, Burke County, North Dakota (Bismarck: Division of Environmental Engineering, NDSDH, 1983), 38.
32. Ibid., 173. This TSP format is also used in the Air Quality Effects Analysis and Permit Application of Amoco Production Company, Whitetail Gas Processing Plant, Billings County, North Dakota (Bismarck: Division of Environmental Engineering, NDSDH, 1982), and Air Quality Effects Analysis of Warren Petroleum Natural Gas Processing Plant (Expansion), Billings County, North Dakota (Division of Environmental Engineering, NDSDH, 1982).
33. "Technical Review," 1. For significance levels, see 40 CFR (b)(23)(i) and 40 CFR (i)(8)(i), and Air Quality Effects Analysis and Permit Application of Koch Hydrocarbon Company Gas Processing and Sulfur Recovery Plant, McKenzie County, North Dakota (Bismarck: Division of Environmental Engineering, NDSDH, 1980), 59.
41. "Response to Public Comments on the Federal Land Manager's Determination of No Adverse Impact on Theodore Roosevelt National Park and Lostwood National Wildlife Refuge Under Section 165(d)(2)(c)(iii) of the Clean Air Act," unpublished MS, September 1982 (THRO-A), passim.; Duane Sebastian (Chairperson, Dakota Resource Council) to Gene Christianson (Division of Environmental Engineering, NDSDH), 5 June 1982 (THRO-A).
42. "Supplemental Information to the July 1982 Technical Review of Six PSD Permit Applications Potentially Affecting Theodore Roosevelt National Park and the Wilderness Portion of Lostwood National Wildlife Refuge," unpublished MS, August 1982 (THRO-A), 1, 7. The state believed the high sulfur dioxide figures were a temporary increase caused by flaring from a new oil field.
43. "Theodore Roosevelt National Park and Lostwood National Wildlife Refuge; Final Certification of No Adverse Impact," Federal Register 47 FR 41480 (20 September 1982). The certification was made effective as of 15 September 1982. See also Greg Turosak, "Park Service OKs Energy Projects," Bismarck Tribune, 20 September 1982.
46. Fort Union Coal Regional Environmental Impact Statement; Air Quality Information Supplemental to the Fort Union Coal Region Draft Environmental Impact Statement (Billings: MT State Office, BLM, 1982), 5-11-S-35; Dan Gorham, "Roosevelt Park Air Threatened," High Country News, 13 May 1983.
49. "State Coordinator's Monthly Report," 30 March 1983; NDSDH, "Final Report: Sulfur Dioxide Emission Inventory for Sources Near the Theodore Roosevelt National Park (draft)," unpublished MS, February 1983 (THRO A), 19.
Last Updated: 15-Jan-2004