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New Source Review Modeling and Impacts Evaluation

New Source Review Modeling and Impacts Evaluation. Dan Schultz Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2012. Authority for Requesting Air Quality Impacts Evaluation. Minor source NSR TCAA, Title 30 TAC Chapter 116 Major source NSR – PSD

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New Source Review Modeling and Impacts Evaluation

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  1. New Source Review Modeling and Impacts Evaluation Dan Schultz Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2012

  2. Authority for Requesting Air Quality Impacts Evaluation • Minor source NSR • TCAA, Title 30 TAC Chapter 116 • Major source NSR – PSD • Federal Clean Air Act

  3. Requirements for Modeling • Determines which pollutants to model • Determines review type • Sends modeling letter - 45 Days Permit Reviewer

  4. Pre-Modeling Meeting Goals • Discuss project with staff • Identify areas of concern early in the process • Eliminate problems later in the review cycle and reduce review time

  5. Pre-Modeling Meeting • Contacts the permit reviewer to request a pre-modeling meeting • Prepares modeling summary Applicant Permit Reviewer • Schedules the pre-modeling meeting

  6. Pre-Modeling Meeting & PSD • Not required for a PSD project • PSD air quality analysis protocol is submitted to EPA Region 6 and TCEQ • ADMT reviews protocol and responds with written comments

  7. Modeling Summary • Project information, applicant name, regulated entity number, nearest city, county, contact information • Project overview – what is being modeled and why?

  8. Modeling Summary • Review types – state property line, NAAQS, health effects • Monitoring data • Proposed model: AERMOD, ISC-PRIME, AERSCREEN, SCREEN3

  9. Modeling Summary • Emission rates – must be pre-approved by permit reviewer • Source characterization – point source, area source, or volume source • Source parameters

  10. Modeling Summary • Operating scenarios and scalars • Plot plan with emission point locations and downwash structure locations • Building heights

  11. Modeling Summary • Dispersion options – SCREEN3 and ISC-PRIME Rural or Urban? • Surface roughness - AERMOD • Meteorological data choice – surface and upper air files

  12. Modeling Summary • Receptor grid design • Specialized modeling techniques • Include results in modeling report • Document your work

  13. On the way to a pre-modeling meeting, the applicant feverishly prepares a modeling summary on the laptop computer as the car careens along I-35. Don’t do this!

  14. Do This! • Provide modeling summary to the permit reviewer no later than two business days prior to meeting • Let staff get familiar with the project and adequately prepare for the meeting • Decide if a teleconference or in-person meeting at TCEQ is preferred

  15. Pre-Modeling Meeting • Parties discuss the project • Be prepared - ask questions • Agree upon timelines for the project

  16. After the MeetingThe Modeling Report • Prepares modeling report • Sends modeling report to the permit reviewer Applicant

  17. Modeling Audit Process • Sends request to the ADMT • Works with ADMT staff to conduct an audit of the air quality analysis Permit Reviewer

  18. Modeling Audit Process • Reviews the methodology and assumptions used in the model • Reviews all model inputs and results and compares them to the report ADMT Staff

  19. Modeling Audit Process • Contacts the applicant to resolve deficiencies • Details audit comments in a memo to the permit reviewer • Labels the project acceptable or not acceptable ADMT Staff

  20. Modeling Audit Process • Acceptable - the permit reviewer prepares a Request for Comments and sends to Toxicology for applicable health effects related reviews • Not acceptable - the project needs more work and is remanded back to the applicant

  21. Common Deficiencies Emission rates reported are not the same as what are in the model Parameters reported are not the same as what are in the model No flare worksheet showing how the effective diameter was calculated

  22. More Common Deficiencies No plot plan • Plot plan does not indicate the source and building locations - these should be clearly labeled No independent list of building heights

  23. More Common Deficiencies No modeling results included in the report • The modeling results reported are different than the results in the model output file • Use of the health-based ESL instead of the odor-based ESL

  24. Example Plot Plan

  25. Example Plot Plan

  26. Solutions Quality control can eliminate many of these types of problems Check model inputs before running the model

  27. Determining Air Quality Impacts • State property line standard • NAAQS • Health effects review

  28. State Property Line Standard • Pollutants • Hydrogen sulfide • Sulfuric acid • Sulfur dioxide • Model new and increased emissions • Compare results to 2% of the standard

  29. State Property Line Standard • Site-wide modeling • All sources with allowable emission rates • Compare results to the standard • Harris/Galveston Counties and Jefferson/Orange Counties have a lower SO2 standard

  30. State Property Line Standard Hydrogen sulfide • One standard for residential, recreational, business, or commercial receptors • Another standard for undeveloped receptors

  31. NAAQS Review • Apply to new and increased criteria pollutants: Carbon monoxide Lead Particulate matter (PM10 & PM2.5) Nitrogen dioxide Sulfur dioxide Ozone

  32. NAAQS Review • Compare to the Significant Impact Level (SIL) • No established SILs for lead or ozone

  33. NAAQS Review • Model all on-property and off-property sources with allowable emission rates • Include background concentration • Compare modeling results to the NAAQS

  34. Health Effects Review • Apply to new and increased emissions for contaminants with an ESL • Review averaging periods • Compare results to applicable threshold levels • Follow MERA guidance

  35. Health Effects Review Site-wide modeling results are reviewed following a tiered process The predicted concentration is less than the ESL at all off-property receptors.

  36. Health Effects Review The predicted concentration is less than 2X ESL at industrial receptors and less than the ESL at non-industrial receptors.

  37. Health Effects Review The predicted concentration and frequencies of exceedance at the GLCmax and GLCni are subject to a case-by-case review by the Toxicology Division.

  38. Health Effects Review • Prepares a Request for Comments (RFC) form • Summarizes health effects results • Sends results to Toxicology Division for review Permit Reviewer

  39. Revised Air Quality Modeling Guideline Draft version soon available for public comment

  40. PM2.5 Increment • Trigger date: October 20, 2011 • PSD permit applications received after the trigger date will need to address PM2.5 increment

  41. PM2.5 Increments 9 μg/m3(24-hr) 4 μg/m3(annual)

  42. PM2.5 IncrementBaseline Dates • Major source: October 20, 2010 • Minor source: date established when the first PSD permit application is received after October 20, 2011

  43. New Meteorological Data Sets for TX Counties • Use of AERMINUTE data • Allows hourly averages of wind speed and direction

  44. Questions

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