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On October 1, 2015, the Environmental Protection Agency (EPA) revised the National Ambient Air Quality Standard (NAAQS) for ground-level ozone from 75 parts per billion (ppb) to 70 ppb.  As a result of this rulemaking, states are required to recommend EPA with attainment and nonattainment area designations by October 1, 2016, which will be based on the design value (dv) calculated from monitoring data between 2014 and 2016.  Based on the latest available ozone monitoring data from 2013 through 2015, the TCEQ's Air Quality Division (AQD) is considering recommending that counties with regulatory ozone monitors measuring above the 2015 ozone NAAQS of 70 ppb be designated nonattainment.  Based on preliminary 2015 ozone monitoring design values, the following counties are recommended to be designated as nonattainment counties under the 2015 ozone NAAQS:

  • Bexar County (78 ppb),
  • Hood County (73 ppb), and
  • El Paso County (71 ppb).

Areas currently designated as nonattainment for the 2008 ozone standard would be recommended as nonattainment areas for the 2015 ozone standard.  All other counties in Texas with regulatory monitors with ozone design values below the 2015 ozone NAAQS would be recommended to be designated attainment including:  Bell, Brewster, Cameron, Gregg, Harrison, Hidalgo, Hunt, Jefferson, McLennan, Navarro, Nueces, Orange, Polk, Randall, Smith, Travis, Victoria, and Webb.  All other counties not having a regulatory ozone monitor would be recommended to have a designation of unclassifiable/attainment consistent with historical EPA designation practices.

The TCEQ's AQD is soliciting public comments on potential area designations and boundaries under the 2015 ozone NAAQS for consideration in developing state designation recommendations due to the EPA by October 1, 2016.  The public comment period opened on March 15, 2016 and will close on April 15, 2016.  The commission is scheduled to consider staff's recommendation at its August 3, 2016 meeting.  If approved by the commission, the recommendation will be submitted to the Governor's office for consideration.

With potential addition of Bexar, Hood, and El Paso Counties to be designated as nonattainment, the requirements associated with a moderate non-attainment area will apply to sources located in these counties.  These requirements include, but are not limited to, lower thresholds for emissions inventory reporting, nonattainment new source review for new construction and modifications, and state regulatory requirements for emissions of Nitrogen Oxides (NOx) and Volatile Organic Compound (VOC).

At this stage, Trinity can assist the industrial facilities located in the affected counties to analyze the monitoring data, review the modeling data from TCEQ and conduct ozone analysis using photochemical models such as Comprehensive Air Quality Model with Extensions (CAMx) to simulate the actual high-ozone episodes which prevailed in the effected region.  The results of these modeling analyses can be used to recommend the extent of the nonattainment area to TCEQ and then to support development of the State Implementation Plan (SIP) by TCEQ to achieve attainment for the area using different control strategies.

Additional information on TCEQ's recommendations and reference documents are available here.

To determine how these changes might affect your facility and future compliance, call Trinity Consultants at (972) 661-8100 to speak with a permitting specialist.