Modeling Guidance

Overcoming Technical Challenges and Demonstrating Compliance With Air Quality

Standards

Dom Ruggeri, P.E.Air Permits Division

Texas Commission on Environmental QualityAdvanced Air Permitting Seminar 2012

Presentation Topics

Modeling challenges

You want me to model?

Take-home points!

Modeling ChallengesWhy Now?

Primary standards changed: Ozone – level Lead – level, averaging time, form NO2 – level, averaging time, form SO2 – level, averaging time, form PM2.5 – precursors, condensables

Modeling Challenges What’s Ahead?

Secondary standards may change: NO2, SO2 - deposition-based standard? PM2.5 - visibility-based standard? Ozone - seasonal standard?

Modeling Challenges Summary

No implementation rules Petitions Interim and outdated guidance Court decisions Consistency (major, minor source)

You Want Me to Model?Why?

The answer depends on the project:

Must always evaluate emissions impact Model new and modified facilities Model site-wide if project not de minimis

Justify use of representative data to evaluate impacts

You Want Me to Model?(Cont)

Key modeling factors to remember:

Permits under review may be affected by new standards or designations

Past conditions, controls, and rates may not be appropriate for new standards

You Want Me to Model?How?

Anticipate the modeling chokepoint When do you need the permit issued?

Meet with us early to discuss Modeling protocol Required technical justification

Discuss “test” results with staff Consider limits for planned MSS and non-project facilities in the permit

Take-Home Points

The permitting process has changed – more changes likely

New standards create technical challenges for you and us

Help us help you Talk to us early -- and often!

Contact Information

Dom Ruggeri (512) 239-1508 dom.ruggeri@tceq.texas.gov

Daniel Menendez Team Leader - Air Dispersion

Modeling Team (512) 239-1537 daniel.menendez@tceq.texas.gov