What is the difference between plume height and fugitive height? Surely a plume is different from a fugitive?
This is unfortunately due to a confusing use of terminology by both DEQ and EPA. In this context the plume height is the same as the fugitive height, which is the height above grade that fugitives are released from. This could be the top of a storage tank or the top of a mineral pile. For leaks from pipework or loading operations the fugitive height is typically three feet.
