MPCA s Modeling Process

Transcription

1 aq-ppt5-15 MPCA s Modeling Process How to successfully navigate from protocol submittal to report approval Steve Irwin - MPCA

2 Overview Facility decides to modify or create new source Pre-protocol meeting (optional but encouraged) Facility/consultants prepare modeling protocol forms and submit along with supporting documents Agency receives and begins tracking preapplication process Copies sent to modeling and permitting supervisors Supervisors assign review to air modeler and permit engineer Modeler and permit engineer review documentation Modeler or permit engineer send notice of approval Facility/consultants complete modeling report noting changes Facility/consultants submit modeling report to MPCA If still in compliance, and no other issues, modeling report approved

3 Permit Requirements If modeling is being done as part of a permit requirement, contact the permit compliance coordinator and follow the instructions in your permit. The process may differ from previous slide.

4 Step 1 Non-Standard Practices/Clarifications Set up a pre-protocol meeting AirModeling.pca@state.mn.us Actuals vs. Potentials for nearby sources Beta Options Other Models How to characterize intermittent generators Clarification on a new working practice Characterization of sources Questions for permitting

5 MPCA Modeling Guidance

6 Step 2 Complete Modeling Protocol Forms

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11 Sections and Common Problems Files to accompany protocol Make sure all the necessary files are included Make sure files are labeled correctly

12 Section A Purpose for Air Dispersion Modeling Why modeling is being conducted Project Description PSD considerations Type of analysis (SIL, NAAQS etc.) Common Problems Errors on the trigger for modeling Inaccurate descriptions of what s changing

13 Section B EPA Pre-Processors and Post-Processors Info on Elevation data Info on Building data Info on Meteorological data EPA Pre/Post-Processors No Common Problems Keep up the good work!

14 Section C Model Selection and Options What pollutants are being modeled? Rural vs. Urban, Elevated vs. Flat etc. Alternative Models or Methods NO 2 Conversion Selection Common Problems Not selecting all the required pollutants Not updating model versions

15 Section D Emission Source Characterizations and Parameters Types of sources to be modeled Fugitive Sources Intermittent Emissions Alternative operating scenarios Common Problems Not listing fugitive sources Not listing intermittent emission sources No information on operations of intermittent sources

16 Section E Paved Roads Fugitive Dust Information on fugitive dust, traffic and parking. Determination of whether roads will need to be modeled No Common Problems Keep up the good work!

17 Section F Receptors Type of Receptor Grid Grid dimensions Grid Spacing Common Problem Fenceline location for NAAQS vs. MAAQS

18 Section G Meteorological Data Surface Station Upper Air Station AERMET version Justification for selections Common Problem Not including sufficient justification for met station selection.

19 Section H SIL Analysis and Results Preliminary modeled impacts vs. SILs No Common Problems Keep up the good work!

20 Section I Background Values List of pollutants that require background analysis. Method for determining background. Background data source Form of the background value Common Problems Leaving the form of the background value blank. Insufficient justification for monitor selection.

21 Nearby Sources Section J Pollutants that require nearby sources Method for determining nearby sources Method of modeling nearby sources No Common Problems Keep up the good work!

22 Section K Pollutant-based Considerations Secondary formation of PM 2.5 NO 2 in-stack and equilibrium ratios Info on ozone data Common Problem Insufficient justification for representative ozone monitor selection.

23 AQDM - 02

24 AQDM - 02 Helpful Tips: 1) Leave the equations in the spreadsheet so MPCA permit engineers can see how the numbers were derived. 2) The standard AQDM-02 form is required for a modeling review, however additional sheets can be added. 3) No PDFs of spreadsheets or locked spreadsheets can be accepted. Always submit an electronic copy. 4) Include justification for emission factors. 5) Highlight source parameters that have changed.

25 Step 3 Submit a modeling protocol For a permit application: Submit two paper copies of the Air Quality Dispersion Modeling protocol form (AQDM-01), the Air Quality Dispersion Modeling protocol spreadsheet (AQDM-02) and any accompanying files to the permit document coordinator MPCA, Air Quality Permit Document Coordinator, IND/AQPD 520 Lafayette Road St. Paul, MN In addition, strongly encourage submitting electronic copies of the forms and accompanying files to: AirModeling.pca@state.mn.us

26 Communication

27 Step 4 Protocol Approval If Guidance is followed or non-standard approaches have gone through proper channels Forms are filled out correctly No changes from EPA Modeler and permit engineer understand and agree with all modeling inputs You will receive an AQDM-05 and an AQDM-04 notifying you of approved status.

28 Step 5 Submit Modeling Report

29 Modeling Report AQDM-06 Only submit report after protocol forms have been approved. Report must be submitted with your permit application, in the same medium as your permit application. Main purposes: 1) Document any changes since the protocol approval. 2) Report modeling results.

30 Modeling Report What Ifs Final runs differ from the protocol form. Discuss with your modeler Document changes on the report form Re-submit files with changes and AQDM-02 As long as still in compliance, it s okay

31 Modeling Report What Ifs Modeling isn t working out for the project MPCA will work with the company to come up with solutions based on scientific and technically defensible methods within the regulatory framework. Sometimes won t model compliance without additional controls or adjustments to construction.

32 Modeling Report What Ifs Final as-built design differs from modeled/permitted design If changes happen before construction, may need to re-model and re-permit. EBD may be an option for this case. Possibly an amendment If source constructed changes that were not modeled/permitted, then it may become an enforcement issue.

33 Permit Amendments The modeling process is the same for a permit amendment. Submit modeling protocol first, after that s approved, submit the report with the amendment application. Modeling report must be approved before an amendment is issued.

34 Modeling Permit Conditions Hours of operation Hourly emission rates Fuels used Best practices Extend stacks Fugitive dust plans

35 Step 6 Modeling Report Approved If changes, clearly document and discuss with modeler. Once report is approved, modeling process is complete.

36 Tempo The process of submittals will change in early Fall Content of submittals/forms will remain largely the same. Questions on this presentation?

37 Questions Asked: Who do you contact for a pre-protocol meeting? Send an to: AirModeling.pca@state.mn.us Slide 14: Are there exceptions to using the most recent model version? If a model update comes out during the protocol or report phases, there may be situations where updates will not affect modeled concentrations. MPCA modeling staff will review these situations on a case-by-case basis to determine whether an update is necessary or not. Slide 17: General confusion over what fenceline to model for NAAQS vs. MAAQS : NAAQS compliance is determined at the fenceline MAAQS compliance is determined at the property boundary