Matthew Kovar Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2015

By What Authority? TCEQ receives its authority from: Texas Health and Safety Code, Chapter Clean Air Act (TCAA) Federal Clean Air Act (FCAA) New minor sources or modifications shall comply with 30 TAC § New major sources or major modifications in an attainment or unclassifiable area shall comply with 30 TAC § Federal Clean Air Act Texas Health & Safety Code

Air Quality Demonstration Permit Reviewer determines which air contaminants and review types need to be included in the air quality analysis (AQA) Review types are: NAAQS PSD increments State property line Health effects Each review type has a specific set of associated air contaminants Some air contaminants are associated with more than one review type Air Contaminant Data Air Quality Demonstration Analysis Permit Reviewer Requests Modeling

Air Quality Demonstrations NAAQS: SO 2 NO 2 CO PSD Increment: SO 2 NO 2 Property Line: SO 2 H 2 SO 4 Health Effects: Styrene NAAQS  SO 2  NO 2  CO PSD Increment  SO 2  NO 2 Property Line  SO 2  H 2 SO 4 Health Effects  Styrene

Modeling Protocol If project is major by itself or a major modification, a protocol is required for all criteria pollutants with an increase: Must be sent to EPA Region 6 for review May include protocol for state-only requirements Items to include in protocol are listed in protocol checklist Consider all the items in the protocol check list before you start on your protocol document Before you start, have a plan.

Modeling Protocol- Be Complete to Be Correct Provide full documentation and details to reduce review time and mitigate potential issues Protocol document should resemble AQA without modeling results I wasn’t expecting this!

Modeling Protocol- Background Info. Needed Station information Time period Monitored values How will it be used? Justification

Pre-modeling Meeting If the project is at a minor site or is a minor modification at a major site, a protocol is not required, but recommended Provide a modeling summary two days prior to the pre- modeling meeting to give ADMT time to review and prepare Modeling summary includes same items as in protocol Not a Brainstorming Session

Pre-modeling Meeting- Tips Provide full documentation and details to reduce review time and mitigate potential issues Meeting could be for pre-protocol preparation Meetings are typically conference calls

Pre-modeling Meeting- Source Type Examples Power Plants Loading Racks

Air Quality Analysis Pre-modeling meeting and/or protocol increases your chances of a successful project SUCCESS AHEAD! A good plan results in a successful air quality analysis.

Air Quality Analysis- What Is It? An addendum to the air permit application A stand-alone document Includes all information in support of the project Describes any deviations or changes from protocol or meeting summary Modeling Approach Justification & Supporting Documentation Modeling Results

Air Quality Analysis- Be Straightforward & Organized Include a complete listing of all electronic files Summarize results demonstrating compliance Reiterate everything from the protocol and/or pre-modeling meeting Document any deviations from the protocol and/or pre-modeling meeting Present all information in a straightforward and organized fashion Provide as much documentation as possible I would have never thought to look here!

Avoiding Deficiencies Deficiencies slow down the process and delay permit issuance Lack of sufficient information Incorrect interpretations Check for inconsistencies between model inputs and air quality analysis.

Avoiding Deficiencies Deficiencies slow down the process and delay permit issuance Lack of sufficient information Incorrect interpretations Address all comments from meetings.

Monitor Selection Example

Project Site Location

Selected Monitor

Representative Monitor

Inappropriate Fugitive Source Characterization

Appropriate Fugitive Source Characterization

Updates in Modeling AERMOD - Ambient Ratio Method 2 (ARM2) Must consider several factors to use ARM2: Tier 1 NO x modeling results In-stack NO 2 /NO x ratio of source Ozone background concentrations

Questions?

Contact Information Matthew Kovar Air Dispersion Modeling Team (512) Daniel Menendez Team Leader – Air Dispersion Modeling Team (512)