Dom Ruggeri, P.E. Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2012 Modeling Guidance Overcoming Technical Challenges and Demonstrating Compliance With Air Quality Standards
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Modeling Challenges Summary • No implementation rules • Petitions • Interim and outdated guidance • Court decisions • Consistency (major, minor source)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 • firstname.lastname@example.org • Daniel Menendez • Team Leader - Air Dispersion Modeling Team • (512) 239-1537 • email@example.com