New Source Review Modeling & Impacts Evaluation

1. New Source Review Modeling & Impacts Evaluation Dianne Anderson Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2013

2. Authority for Requesting Air Quality Impacts Evaluation • Texas Clean Air Act • Federal Clean Air Act • 30 Texas Administrative Code Chapter 116 • PSD review - §116.160 • Minor NSR - §116.111

3. Who Requests Modeling? • TCEQ Permit Reviewer • Serves as lead contact in the permit application process • Determines which pollutants & review types need to be included in an AQA

4. General Process: Once Modeling is Requested • Pre-Modeling Meeting • Modeling Protocol • AQA

5. Pre-Modeling Meetings • What is a pre-modeling meeting? • What do we need for a pre-modeling meeting? • What should the pre-modeling summary include?

6. Pre-Modeling Meetings • Meeting held between permit reviewer, ADMT staff, & applicant • Provide a modeling summary two days prior to the meeting

7. Pre-Modeling Meetings • Summary should resemble the AQA without the results • Provide full documentation & details to reduce review time & catch potential issues

8. Modeling Protocols • When do you provide a modeling protocol? • What should be included in the modeling protocol? • What is the process for a modeling protocol?

9. Modeling Protocols • Provide protocol if project triggers a PSD review • Protocol should resemble the AQA without the results

10. Modeling Protocols • Provide full documentation & details to reduce review time & catch potential issues • Protocol will include additional information: pre-application analysis, increment, & additional impacts analysis

11. Modeling Protocols • Submit protocol to both TCEQ & EPA Region 6 • ADMT reviews & provides formal comments

12. Air Quality Analysis • When do you provide an AQA? • What should be included in the AQA? • What is the process for an AQA?

13. Air Quality Analysis • Submit after a pre-modeling meeting has been conducted and/or modeling protocol has been reviewed • Must clearly document all supporting discussion or justification to support the project will be in compliance

14. Air Quality Analysis • ADMT Review  Additional Information or Deficiencies  Formal Audit Memo

15. What to Provide in Reports • Project Identification Information • Project Overview • Type of Permit Review • Constituents Evaluating • Plot Plan & Area Map

16. What to Provide in Reports • Air Quality Monitoring Data • Modeling Emissions Inventory • Stack Parameter Justification • Scaling Factors • Models Proposed & Modeling Techniques

17. What to Provide in Reports • Selection of Dispersion Options • Building Wake Effects (Downwash) • Receptor Grid • Meteorological Data • Modeling Results • Digital Information

18. Common Deficiencies Ambient Background Information Example: The AQA makes reference to background concentrations being used in the analysis. However, the only thing included in the report is a table with background concentrations. What other information is missing?

19. Common Deficiencies(Solution) Ambient Background Information • The AQA needs basic information: • Monitor name (name and/or AQS number) • Monitor location • Years included in data • Metric used (i.e., highest value from past 3 years)

20. Common Deficiencies(Solution) Ambient Background Information • The AQA needs a discussion to show the monitoring data are conservative or representative: • Proximity to the project site • Type &amount of emission sources around monitor vs. project site • Topographic &land-use comparison • Location relative to predominant wind direction

21. Common Deficiencies Intermittent Sources Example: My emergency engine will operate no more than 500 hours per year; therefore it is intermittent. What other information is missing?

22. Common Deficiencies(Solution) Intermittent Sources • AQA needs to include discussion on proposed operation: • How many times will it operate in a year? • What is the duration of each operating event? • Any operating limitations?

23. Common Deficiencies Source Characterization Example: Piping exists throughout the entire facility. Emissions vent out through openings in the piping. One fugitive area source was modeled to encompass emissions associated with the piping. The release height is 10 feet, half the height of the piping. The dimensions of the area source are 2000 meters by 1000 meters. What other information is missing?

24. Common Deficiencies(Solution) Source Characterization • The AQA needs to include: • Source dimensions justification • Size to averaging time appropriateness • Does the activity occur at multiple locations throughout the site? • Release height justification

25. Common Deficiencies Plot Plan What other information is missing?

26. Common Deficiencies(Solution) Plot Plan • The plot plan needs to include: • Clearly labeled modeled sources (including fugitive) & downwash structures • Property lines clearly marked • Independent of the model input

27. Common Deficiencies(Solution)

28. Updates In Modeling • New AERMOD Version: 12345 • New meteorological datasets • New years of data • More surface stations

29. Updates In Modeling • New PM2.5 Information • Annual NAAQS: 12 µg/m3 • Minor Source Baseline dates are being set • The SILs & SMC have been vacated per a recent court case

30. Updates in Modeling • New Source Inventory: APAD • Process to obtain source retrieval is essentially the same • Data are continuing to be loaded into APAD • What will need to be provided if using APAD?

31. Updates in Modeling • New Air Quality Guidelines • Supersedes the previous 1999 AQMG • Includes new standards (PM2.5, 1-hr SO2, & 1-hr NO2)

32. Updates in Modeling • New ADMT Webpage • New guidelines • Presentations • Links to EPA guidance • Easier to use & find modeling information

33. Questions?

34. Thank You! Air Permits Division 512-239-1250