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Dispersion Modeling Procedures Update

Dispersion Modeling Procedures Update. Robert Opiela, Technical Specialist Technical Program Support Section TCEQ, Air Permits Division Austin, Texas September 29, 2008. Introduction. The Role of Dispersion Modeling in the Air Quality Permitting Process How to Make the Process Better

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Dispersion Modeling Procedures Update

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  1. Dispersion Modeling Procedures Update Robert Opiela, Technical Specialist Technical Program Support Section TCEQ, Air Permits Division Austin, Texas September 29, 2008

  2. Introduction • The Role of Dispersion Modeling in the Air Quality Permitting Process • How to Make the Process Better • How to Expedite the Review Process

  3. Air Quality Permitting Process • Analogous to Building Permit Process • Building codes apply to all structures • Storage sheds or high-rise office buildings • Information required to be submitted • Blue prints, diagrams, etc. • Additional analysis, if applicable • Case-by-case review

  4. Air Quality Permitting Process • MERA is the Express Lane • Not for every project • Must be simple enough • Has to fit into the box • Just applies to air toxics • Does not apply to NAAQS or state property line

  5. Air Quality Permitting Process • Case-By-Case Review • More requirements • NAAQS, Increment, state property line, etc. • More analysis • Air Quality Analysis (AQA) • May include dispersion modeling

  6. Air Quality Permitting Process • Where May Dispersion Modeling Fit In? • MERA • Steps 5, 8, 11 • Case-by-case • NAAQS, Increment demonstrations • State property line standard demonstrations • Health effects demonstrations

  7. How to Make a Better Analysis • What is an Air Quality Analysis (AQA)? • Demonstration the project would not: • Cause or contribute to a NAAQS or Increment violation • Exceed a state property line standard • Adversely impact human health and welfare • Technical justifications of demonstration

  8. How to Make a Better Analysis • What Should an AQA Include? • Explanation of methodology • Dispersion modeling, maybe/maybe not • Technical justification of all claims with supporting documentation

  9. How to Make a Better Analysis • Why Care About AQA Content? • It is a REQUIREMENT • Missing or hard to find information leads to delays • Burden is on the applicant

  10. How to Make a Better Analysis • For Dispersion Modeling, Include: • Explanation of methodology • Technical justification of all input selections and supporting documentation • All modeling input and output files • Description of input and output files

  11. How to Make a Better Analysis • Why Care About Modeling Analysis? • Missing or hard to find information will delay permit issuance • Continued information deficiencies can lead to application being voided

  12. How to Expedite Review • If Performing Refined Modeling: • Use Modeling Input Data Templates • Standardizes data exchange between agency staff and applicant

  13. How to Expedite Review • Why Were Templates Developed? • Limited agency resources • Fewer staff to review projects • Less experienced staff to review projects • More projects • More complicated projects • Allows review to be automated

  14. How to Expedite Review • What if Templates Aren’t Used? • Review time may increase significantly • Permit issuance may be delayed

  15. How to Expedite Review • How to Use Input Data Templates: • Read instructions thoroughly • Follow instructions carefully • Do not alter in any way • Pay attention to validation criteria

  16. How to Expedite Review • Things to Know About Templates: • What is a Scenario? • Change in source parameter for a unique source • What is a Review Type? • Health Effects Project Only, Health Effects Site-wide, State Property Line Project Only, State Property Line Site-wide, State NAAQS AOI, State NAAQS, PSD AOI, PSD NAAQS, PSD Increment

  17. How to Expedite Review • Hints to Expedite Review Process • Thoughtful use of “CONFIDENTIAL” • No customizations • Provide clear explanations • Concise, informative AQA reports

  18. In Summary • An Air Quality Analysis (AQA) is part of the permitting process; MERA is a screening tool • A complete and thorough AQA will speed up the review process; dispersion modeling may be included • Using Input Data Templates will expedite review; consider other hints, too

  19. Questions

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