Texas Natural Resource Conservation Commission
        Austin                       Texas
                     Interoffice

From:  Bruce Broberg, P.E., Chief Data Analysis Section
To:  Jim Gise, Director Air Quality Data Analysis
Date:  April 23, 1985, Updated August 29, 1994
Subject:  Evaluation of Ambient Monitoring for PSD Permits

The ambient monitoring requirements for PSD permits can be
rather complicated.  Monitoring does not have to be submitted
in all cases.  In some instances, data from a monitor that is
nearby may be used.  For other cases, monitoring must be
conducted at the site of the proposed facility.  The latter
requirement can cause delays in permits.  However, if
monitoring is not submitted, there is a risk of locating a
facility in an area where the National Ambient Air Quality
Standard is being exceeded.  Both of these scenarios have
happened in the recent past.

I propose the Quality Assurance Section, Monitoring Operations
Division take over the review for the ambient monitoring
requirements for PSD permits.  We have the expertise in monitor
siting, data analysis and knowledge of the monitoring data
available throughout the state.  By taking over this function, a
more thorough and consistent evaluation of PSD monitoring
requirements may be conducted.

I have discussed this proposal with Lawrence Pewitt, P.E.  He
agreed it would be advantageous for the Quality Assurance Section,
Monitoring Operations Division to evaluate the Monitoring Section
of the PSD permits.