Today we submitted comments on the Alabama Department of Environmental Management’s (ADEM) Annual Ambient Air Monitoring Plan for 2017.
Mobile Baykeeper’s primary focus in commenting on the 2017 Ambient Air Monitoring Plan is safeguarding the health of citizens living in Coastal Alabama. We believe the protection of human health should be the most important factor driving decisions about ambient air monitoring.
To protect the citizens living, working, and visiting Mobile, it is important to ensure that the Ambient Air Monitoring Plan not only meets the requirements at the federal level but also adequately addresses issues specific to the Mobile Area.
Our comments are summarized below and a full copy is available for download at the bottom of the page.
1. We need a PM10 monitor for the Mobile Area.
We have significant concerns with the absence of a PM10 monitor in the Mobile area. A PM10 monitor measures a critical pollutant called particulate matter. PM10 is a specific type of particulate matter with a diameter between 2.5 and 10 micrometers (μm). It primarily comes from road and agricultural dust, construction sites, and certain industrial activities. Particulates are often considered one of the most dangerous forms of air pollution due to their ability to get into the deepest parts of the lungs.
It is well established that increased risk of death and numerous other health issues are strongly associated with particulate matter. To understand the health effects particulate matter is having on citizens of the Mobile area we must adequately monitor particulate matter. If we do not have this information the community the does not have the tools to take sufficient measures to protect public health.
Mobile previously had a PM10 monitor at the WKRG office in West Mobile. The monitor showed low concentrations and ADEM determined it was not necessary based on the monitoring results and relevant regulations.
- However, WKRG is approximately 10 miles from major sources of particulate matter at the Theodore Industrial Canal and approximately 4 miles and 5 miles from sources at the Port of Mobile and Port of Chickasaw respectively. While historical particulate matter data at the monitor was generally in the low concentration range it seems clear to Mobile Baykeeper that the WKRG monitoring location was inappropriately located and did not adequately characterize concentrations of particulate matter in the Mobile area.
2. Mobile County has several areas that would be considered hot spots for particulate matter emissions.
These "hot spots" include the Port of Mobile, Theodore Industrial Canal, and Port of Chickasaw.
- At the Port of Mobile, there are many significant sources of particulate matter including grit blasting of ships, coal handling facilities, and pulp and paper plants. In an area of less than 1,400 acres around the Port of Mobile there are 280 tons of PM10 emitted annually.
- At the Theodore Industrial Canal there are a multitude of point sources that generate a large amount of particulate matter including Holcim’s cement manufacturing plant, Alabama Power’s cogeneration plant, Millard Maritime's bulk fertlizer and salt drying facility, and the Evonik plant. In an area of less than 2500 acres surrounding the industrial canal there are nearly 200 tons of PM10 emitted annually.
- Finally, in an area of approximately 800 acres near the Port of Chickasaw there are more than 180 tons of PM10 emitted annually.
All of these sources are also located near significant residential populations that are likely affected by these PM10 emissions.
Particulate matter is extremely harmful to human health.
It has been shown to reduce life spans by years and cause numerous problems with public health. While historical monitoring data and arbitrary population guidelines give the option of not monitoring PM10 in the Mobile area, the health of citizens of Alabama should be the top priority influencing the plan. Therefore, we strongly encourage ADEM to install a PM10 monitor to understand issues with air quality.