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2. STUDY AREA CHARACTERISTICS guidance, true natural minor sources (the WPCF) are exempted from meeting these additional compliance requirements because both their actual and PTE emissions are below major source triggers for criteria pollutants and HAPs. The most likely issues that could create compliance-related actions concern nuisance issues. Other activities at the WPCF that may impact air quality include fugitive dust blowing offsite, or visible emissions from the internal combustion engines or other combustion sources. However, WPCF staff have been proactive in implementing favorable air quality activities and have been mitigating these factors with actions such as conducting odor evaluations and planning; implementing proper boiler, flare, and internal combustion engine maintenance programs; watering dirt roads and construction sites; and dealing with public concerns in an effective and timely manner. Table 2.2.8-1 presents the results of the emissions estimates. TABLE 2.2.8-1 Estimated Emissions from the WPCF MWMC Facilities Plan, Eugene-Springfield Pollutant PTE (tpy) Actual (tpy) CO 86.1 57.8 NOx 89.9 55.2 SOx 7.1 5.7 PM-lO 1.0 0.3 Total VOCs 23.9 16.5 Total HAPs 8.4 6.0 It should be noted that 65 percent of the residents in the vicinity of the WPCF rate the WPCF as a good or excellent neighbor, according to results of the Wastewater Facilities Good Neighbor Survey performed by the Oregon Survey Research Laboratory at the University of Oregon as part of the master planning effort. Furthermore, an additional 16 percent rate the WPCF as a fair neighbor. The overall good-neighbor rating of the WPCF considers the residents' attitudes about the facility's appearance, odors, traffic, noise, and use of chemicals. Process Hazards Analysis of Chlorine and Sulfur Dioxide Systems A comprehensive process hazards analysis (PHA) evaluation was performed at the WPCF in August 1996. The PHA is a requirement for regulated substances as stipulated by the Occupational Safety and Health Administration (OSHA) and the Oregon Process Safety Management (PSM) program. More than 100 "what if" scenarios were evaluated, including determining the scenario's consequences and existing protections, and developing and implementing recommendations for improvements, new procedures and policies, and additional maintenance or monitoring of key process and safety equipment to address each scenario, when needed. The PHAs and release scenarios in the PSM manual adequately cover all regulated substance usage, storage, and handling scenarios to meet PSM requirements. MWMC_2.0_REV23. DOC 2-27