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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? - PowerPoint PPT Presentation
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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No implementation rules Petitions Interim and outdated guidance Court decisions Consistency (major, minor source)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
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