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Dom Ruggeri, P.E. Air Permits Division Texas Commission on Environmental Quality

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?

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Dom Ruggeri, P.E. Air Permits Division Texas Commission on Environmental Quality

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  1. 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

  2. Presentation Topics • Modeling challenges • You want me to model? • Take-home points!

  3. 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

  4. Modeling Challenges What’s Ahead? Secondary standards may change: • NO2, SO2 - deposition-based standard? • PM2.5 - visibility-based standard? • Ozone - seasonal standard?

  5. Modeling Challenges Summary • No implementation rules • Petitions • Interim and outdated guidance • Court decisions • Consistency (major, minor source)

  6. 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

  7. 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

  8. 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

  9. 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!

  10. 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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