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338               20. Air Pollution Modeling and Prediction

        E. Utilization of Models
          For the air quality manager to place model estimates in the proper per-
        spective to aid in making decisions, it is becoming increasingly important
        to place error bounds about model estimates. In order to do this effectively/
        a history of model performance under circumstances similar to those of
        common model use must be established for the various models. It is antici-
        pated that performance standards will eventually be set for models.


        F. Modeling to Meet Regulatory Requirements
          In the United States if the anticipated air pollution impact is sufficiently
        large, modeling has been a requirement for new sources in order to obtain
        a permit to construct. The modeling is conducted following guidance issued
        by the U.S. Environmental Protection Agency (56, 57). The meeting of
        all requirements is examined on a pollutant-by-pollutant basis. Using the
        assumptions of a design that will meet all emission requirements, the impact
        of the new source, which includes all new sources and changes to existing
        sources at this facility, is modeled to determine pollutant impact. This is
        usually done using a screening-type model such as SCREEN (58). The
        impacts are compared to the modeling significance levels for this pollutant
        for various averaging times. These levels are generally about 1/50 of the
        National Air Quality Standards. If the impact is less than the significance
        level, the permit can usually be obtained without additional modeling. If
        the impact is larger than the significance level, a radius is defined which
        is the greatest distance to the point at which the impact falls to the signifi-
        cance level. Using this radius, a circle is defined which is the area of
        significance for this new facility. All sources (not only this facility, but all
        others) emitting this pollutant are modeled to compare anticipated impact
        with the National Ambient Air Quality Standards and with the Prevention
        of Significant Deterioration increments.
          The implementation of the Clean Air Act Amendments of 1990 (CAAA90)
        will require not only permitting for new sources but also permits for existing
        facilities. There is also a requirement for reexamination of these permits at
        intervals not longer than 5 years. The permit programs are set up and
        administered by the states under the review and guidance of EPA. These
        programs include the collection of permit fees sufficient to support the
        program. Implementation of CAAA90 will require the application of Maxi-
        mum Achievable Control Technology (MACT) on an industry-by-industry
        basis as specified by EPA. Following the use of MACT, a calculation will
        be made of the residual risk due to the remaining pollutant emissions.
        This will be accomplished using air quality dispersion modeling that is
        interpreted using risk factors derived from health information with the
        inclusion of appropriate safety factors.
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