Annual Operation Report Workshop

1. Annual Operation Report Workshop January 13, 2009 Tampa, Florida

2. Major Changes to AOR Form & Instructions • Add pollutants: PM2.5, CPM, NH3, TBAC • Expand summer season data requirements to the entire state • Lower hazardous air pollutant (HAP) reporting thresholds • Change HAP reporting frequency to every 3 years • Include the emissions computation and reporting requirements in Rule 62-210.370 • Change due date for 2008 AOR to May 1, 2009 • Add report contact

3. Some Specific Issues • Ozone season reporting • Hazardous air pollutant reporting • Condensible emissions reporting • Fugitive emissions reporting • Emissions calculation hierarchy • AOR submission due date

4. Ozone Season Reporting • Applies statewide (new) • Only for VOC or NOx emitting units • Summer Season (June 1 – August 31) • Average or typical work day (lbs/day) value (only report VOC and NOx)

5. Hazardous Air Pollutants (HAPS) • Threshold change (new) – 1000 lbs actual/SCC • Applies to all HAPs at major facilities (i.e., total HAPs emissions >25 tpy PTE) • Applies to individual HAPs with emissions >10 tpy PTE). • Reporting every 3 years; 2008, 2011, etc. • Any HAP for which a permit limit is imposed must be reported every year, even if below 1000 lbs

6. Condensible PM Emissions Reporting • New requirement • Threshold – 5 tpy, reported annually • Reported only if information is available to estimate emissions • However, because data is limited, and questions remain on the accuracy of test methods, for the 2008 reporting year only report if you are confident in the data, or if you have a permit limit. • In fact, if CPM is subject to a permit limit, it must be reported (even if below 5 tpy) • Do not list CPM as a pollutant if no data can be reported.

7. Fugitive Emissions • Must report if: • Associated with a permitted emissions unit and SCC for which all emissions are fugitive and are quantifiable (landfill, cooling pond, etc.) • Associated with a permitted facility for which an “emissions unit” has been established by the permitting authority to represent facility-wide fugitive emissions (e.g., equipment leaks, maintenance painting) • Associated with a controlled process using a collection system for which some emissions are not captured and for which the permitting authority has established a separate reporting emissions unit for this purpose.

8. Fugitive Emissions (cont.) • Fugitive PM emissions from vehicular movement or wind erosion need not be reported unless required by permit.

9. Emissions Methods Hierarchy • CEMS • Materials balance • Emission factor- site specific (stack test) • Emission factor- directly applicable from published source (e.g., AP-42) • Emission factor- similar, but different process from published source (e.g., AP-42) • Emissions factor- other • 1A • 2 • 3A • 3B • 4 • 5 Method Emissions Method Code

10. AOR Due Date • For 2008 AOR due to May 1, 2009 • For 2009, and thereafter, due by April 1of following year • Issue: Title V permit specifies March 1 due date, thus, if submitted after this date, would technically be out of compliance. • Resolution: Will resolve by guidance or Statement of Compliance form change.

11. Questions? Tom Rogers Florida DEP (850) 921-9554 tom.rogers@dep.state.fl.us