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New Source Review Modeling & Impacts Evaluation

New Source Review Modeling & Impacts Evaluation. Dan Jamieson Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2014. By What Authority?. TCEQ receives its authority from: Texas Health and Safety Code, Chapter 382 - Clean Air Act (TCAA)

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New Source Review Modeling & Impacts Evaluation

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  1. New Source Review Modeling & Impacts Evaluation Dan Jamieson Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2014

  2. By What Authority? • TCEQ receives its authority from: • Texas Health and Safety Code, Chapter 382 - Clean Air Act (TCAA) • Federal Clean Air Act (FCAA) • New minor sources or modifications shall comply with 30 TAC §116.111 • New major sources or major modifications in an attainment or unclassifiable area shall comply with 30 TAC §116.160 Texas Health & Safety Code Clean Air Act

  3. Who Requires Modeling? Who Requires Modeling? • Permit Reviewer is lead contact • Permit Reviewer determines which air contaminants and review types need to be included in the air quality analysis (AQA) • Review Type are: • NAAQS • PSD Increments • State Property Line • Health Effects • Each review type has a specific set of associated air contaminants • Some air contaminants are associated with more than one review type Air Contaminant Data Air Quality Demonstration Analysis

  4. Air Quality Demonstrations NAAQS • SO2 • CO • PM10 PSD Increment • SO2 • PM10 Property Line • SO2 • H2S Health Effects • Benzene PSD Increment • SO2 • PM10 PSD Increment • SO2 • PM10 • Property Line • SO2 • H2S • Health Effects • Benzene Property Line • SO2 • H2S PSD Increment • SO2 • PM10 • Property Line • SO2 • H2S • Health Effects • Benzene Health Effects • Benzene PSD Increment • SO2 • PM10 • Property Line • SO2 • H2S • Health Effects • Benzene

  5. ModelingProtocol • If project is major by itself or a major modification, a protocol is required • For all criteria pollutants with an increase • Must be sent to EPA Region 6 for review • May include protocol for state-only requirements • Items to include in protocol are listed in protocol checklist • Consider all the items in the protocol check list before you start on your protocol document Before you start, have a plan.

  6. Modeling ProtocolBe Complete to Be Correct • Provide full documentation and details to reduce review time and mitigate potential issues • Protocol document should resemble AQA without modeling results Final product?Not exactly... Final product? Not exactly...

  7. ModelingProtocolExample (Background) Station information? Time period? Monitored values? How will it be used? Justification?

  8. Pre-modeling Meeting • If the project is at a minor site or is a minor modification at a major site, a protocol is not required, but recommended • Provide a modeling summary two days prior to the pre-modeling meeting to give ADMT time to review and prepare • Modeling summary includes same items as in protocol No Brainstorming Sessions

  9. Pre-modeling Meeting Tips • Provide full documentation and details to reduce review time and mitigate potential issues • Meeting could be for pre-protocol preparation • Meetings are typically conference calls Present your assumptions. Show your calculations. Let’s resolve any issues. Do your research. Check your references.

  10. Pre-modeling MeetingExample (Source Types)

  11. Pre-modeling Meeting (cont) A good plan results in… • Pre-modeling meeting and/or protocol increases your chances of a successful project … a good final product!

  12. The Air Quality Analysis • The AQA is an addendum of the air permit application • A stand-alone document Include all information in support of the project. • Describe any deviations or changes from protocol or meeting summary

  13. Air Quality Analysis Tips • Include a complete listing of all electronic files • Summarize results demonstrating compliance • Reiterate everything from the protocol and/or pre-modeling meeting • Document any deviations from the protocol and/or pre-modeling meeting Present all information in a straightforward and organized fashion. • Provide as much documentation I would have never thought to look here!

  14. Avoiding Deficiencies On time, under budget...and beyond! • Deficiencies slow down the process and delay permit issuance • Lack of sufficient information • Incorrect interpretations When is the deficiency cycle ever going to end…

  15. Updates in Modeling Latest model program versions: • AERMOD version 13350 • AERMET version 13350 Updated processed meteorological input files from TCEQ (December 2013) Status of modeling guidelines

  16. Questions?

  17. Contact Information • Dan Jamieson • Air Dispersion Modeling Team • (512) 239-4342 • daniel.jamieson@tceq.texas.gov • Daniel Menendez • Team Leader – Air Dispersion Modeling Team • (512) 239-1537 • daniel.menendez@tceq.texas.gov

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