Emissions Inventory SeminarCriteria Air Pollutants (EIS)Toxic Air Pollutants (TEDI)
Organization Department of Environmental Quality Office of Environmental Assessment Air Quality Assessment Division EIS/TEDI/TRI Environmental Manager - Linda Brown Staff - EIS Jackie Surles Rashaunda Johnson Tiffini Brumfield Brett DeDual TEDI Shelita Smith Cedric Mellion TRI Nicholas LaCroix Rashaunda Johnson
Criteria Pollutant Emissions Inventory Reporting for 2004 Contacts: Jackie Surles Jackie.Surles@la.gov (225) 219-3486 • Rashaunda Johnson • Rashaunda.Johnson@la.gov • (225) 219-3504 • Brett DeDual • Brett.Dedual@la.gov • (225) 219-3537 • Tiffini Brumfield • Tiffini.Brumfield@la.gov • (225) 219-3500 • Fax: 225-219-3240
2004 Reporting Criteria Review • Ozone Non-attainment Parishes: Ascension, E. Baton Rouge, Iberville, Livingston, W. Baton Rouge • Ozone Adjoining Parishes: Assumption, E.Feliciana, Iberia, Pointe Coupee, St. Helena, St. James, St. John the Baptist, St. Martin, Tangipahoa, W.Feliciana
2004 Reporting Criteria ReviewStill in Effect for 2004! • Attainment Parish with Activated Contingency Measures in Maintenance Plan: Calcasieu Non-attainment Parish threshold applies • Parishes adjoining Calcasieu: Beauregard, Cameron, Jefferson Davis Adjoining Parish threshold applies (Potpourri Notice 0102Pot1; Feb20, 2001)
2004 EIS Applicability Review • Attainment Parishes: A facility must report if it emits or has the potential to emit 100 TPY or more of any criteria pollutant. • Non-attainment Parishes: A facility must report if it emits or has the potential to emit 10 TPY or more of VOC, 25 TPY or more of NOx, and/or 100 TPY or more of any other criteria pollutant. • Adjoining Parishes:A facility must report if it emits or has the potential to emit 50 TPY or more of VOC and/or 100 TPY or more of any other criteria pollutant. (LAC 33:III.919.A)
2004 EIS Applicability Review Facilities that meet any of these criteria must also report an EIS: • Potential or actual emissions of 5 tpy of lead • A major source of hazardous air pollutants in Federal Clean Air Act Section 112(a)(1) or of toxic air pollutants in LAC 33:III.Chapter 51 • A Title V Operating Permit (40 CFR Part 70) • A SOGA permit in a non-attainment or adjoining parish (LAC 33:III.919.A)
2004 EIS Applicability Review Standard Oil & Gas Permits • Facilities that operate under a Standard Oil & Gas Permit (SOGA) and are located in an ozone non-attainment parish or an adjoining parish must report EIS data. The SOGA permit allows emissions above the reporting thresholds for these parishes. • Note: This includes the 4-parish Calcasieu area (LAC 33:III.919.A)
What is Reportable • There are no exemptions once the rule applies to you. • All emissions within the facility must be included in the inventory even... • Insignificant Sources such as maintenance & small equipment (LAC 33:III.501.B.5 Table A) • Start-ups & Shut-downs, Upsets & Accidental Releases, Fugitives (equipment leaks), General Condition XVII & Flash Gas emissions
Requirements • A Certification Statement is required from all facilities that meet the reporting threshold. • An electronic data file is required unless there has not been a significant change in emissions. (LAC 33:III.919.B.2)
Significant Change Defined as the lesser of the following: • 5% increase or decrease in facility total potential/actual emissions • 50 tpy increase or decrease in facility total potential/actual emissions • 10 tpy increase or decrease in potential/actual emissions from a single emissions point • Termination of operations at the facility (LAC 33:III.919.B.2)
Requirements • Please include a Cover Letter • Company/Facility Name • Emissions Inventory ID # • Agency Interest ID # • Contact Name and Phone Number • Regulatory due date = March 31, 2005 • Must be postmarked or in-house
Requirements • Use the file we will provide to prepare the 2004 submittal. • Check EIS 2000 (version 2.0) • Name for year 2004 data – 8 digit EI #.04d xxxxxxxx.04d • Use the 2004 LDEQ Certification Statement.
Certification Statement • Certifies only 2004 Criteria Pollutant Emissions Inventory • Signed by a “responsible company official” as per LAC 33:III.502.A or a designee • Add Agency Interest ID # • Complete Side 2 • HRVOC emissions for selected parishes • Active permit numbers • Emission factor changes
Side 1 NH3 and PM2.5 - required under LAC 33.III.919
Side 2 Active Air Permit Numbers Emission Factor Changes HRVOC Emissions for Specific Parishes
What’s New for Reporting Year 2004 • Toluene & Xylene – new for HRVOC Reporting • Emergency Rule – difference in emission factors
LAC 33:III.919 Revision • Final Rule – December 20, 2003 • Major revisions were made to the rule primarily to clarify the language and to codify reporting requirements that were already policy. • Rule now correlates with the Federal CERR (i.e. PM2.5 and NH3 reporting) http://www.deq.louisiana.gov/planning/regs/addition/index.htm
HRVOC Reporting • Under the authority of LAC 33:III.919.B.4, emissions of highly reactive volatile organic compounds (HRVOC) must be included in the 2004 emissions inventory if the facility is located in one of the following 12 parishes: Ascension, East Baton Rouge, East Feliciana, Iberville, Livingston, Pointe Coupee, St. Charles, St. Helena, St. James, St. John the Baptist, West Baton Rouge, West Feliciana • Note: this list is NOT the same as the non-attainment and adjoining parish lists
HRVOC Reporting • The specific compounds that must be added and their SAROAD codes are: 1,3-butadiene 43218 Butenes, isomers 43213 Ethylene 43203 Propylene 43205 Toluene 45202* Xylenes, isomers 45102* • Emissions must be added to the electronic data file as well as the Certification Statement. • Note: only 16 pollutants per NEDS point • *New for 2004
PM10, PM2.5 & TSP • All facilities must report particulate emissions as PM10 AND PM2.5. We will not accept TSP data. • The NAAQS was changed in 1988 from TSP to a standard for Particulate Matter of 10 microns or less - PM10. • The NAAQS for PM2.5 was issued in July 1997.
PM10, PM2.5 & TSP • Check the code in the electronic data file. Particulate emissions must be recorded under the SAROAD codes for PM10 & PM2.5. • Delete the code for TSP (Card 13D & 23D) and add the code for PM10 & PM2.5 (Card 13A & 23A). • SAROAD pollutant codes: • TSP = 11101 (DELETE) • PM10 = 81102 • PM2.5 = 81104
PM10, PM2.5 & TSP References: • EPA’s PM 2.5 Inventory Resources Center: http://www.epa.gov/ttn/chief/eiip/pm25inventory/ • EPA’s PM Calculator: http://www.epa.gov/ttn/chief/software/pmcalc/index.html
Ammonia • All facilities should report ammonia emissions in the electronic data file and on the Certification Statement, even if it is reported in the TEDI. • Ammonia reported in the EIS should match that reported in the TEDI. • SAROAD code = 42604
Data accuracy is vital!What you can do to improve data quality • Do not delete NEDS points (No 11Ds). • Check your SCCs and SICs to make sure they are correct, not just valid. • Double check your facility UTM coordinates, Physical and Mailing Addresses and Contact information. • Please reference the Coding Manual and Forms, Submittal Tips and Expanded Examples. • Data files with too many errors will be sent back for corrections
What you can do to improve data qualityHighlights from the Tips Sheet • Calculation of Emissions – As per LAC 33:III.919.C, if continuous emissions monitoring system (CEMS) or other stack test data are available, they must be used to calculate the emissions. In lieu of test data, emissions shall be calculated using the best available information. • Card 23 – Columns for Pollutant Codes must not be zero-filled - If a program is used that automatically adds zeros to columns 49-53, delete them before submitting the file. • Only 16 Pollutants – The EIS data structure does not allow more than 16 pollutants to be reported per NEDS point. • Action Codes – Use capital letters. • Card 11 Throughput – If the point did not operate at all for the year, fill columns 52-64 with 2525252500052. • Changing SCC Codes – Use 23D and 23A. Do NOT use a 23C. Check the sequence numbers.
What you can do to improve data quality Record VOC emissions correctly. Total VOC = Toxic + Non Toxic
VOC Reminder • Total Volatile Organic Compounds (VOCs) include all compounds that are toxic VOCs and nontoxic VOCs. • In the electronic file, the total VOC must be recorded under the SAROAD code 43104, even if the toxic VOCs are speciated. • Carbon Disulfide and Carbonyl Sulfide are classified as VOCs under the EPA definition. (40 CFR 51.100 and LAC 33:III.2117)
Complete Data • Complete all sections of the Certification Statement, including toxic VOC and pollutants for which there are zero emissions. • First time reporters & adding new points: • Submit complete card decks in the electronic file. Cards 11, 12, 13, 14, 21, 22 & 23 are required. • Format the cards completely and correctly. • Please see the Coding Manual and Forms, Submittal Tips and Expanded Examples.
What you can do to improve data quality • If your facility is an Air Toxics facility, in general, you should report to both TEDI and EIS. • Please be sure that the TEDI and EIS submittals correspond. • You can submit the TEDI with the EIS.
EIS and TEDI • The emission point IDs (NEDS points) between EIS and TEDI must represent the same physical emission point in both inventories. • The toxic VOC reported on the EI Certification Statement should equal (within rounding error) the toxic VOC total reported to TEDI.
Optional Reporting • Greenhouse Gases • SAROAD Codes: • Carbon dioxide = 42102 • Methane = 43201 • Crosswalk of Permit Point ID to EI/TEDI NEDS Point ID
Submitting the Data • 2004 inventory- due on March 31, 2005 • Save updated file with extension .04d • Change of ownerships: • Multiple CS’s acceptable • Only one electronic data file • Electronic data can be mailed or e-mailed. • Certification Statements with original signature must be mailed or delivered to:
Address all USPS Mail to: LDEQ/OEA/AQAD – 6th Floor Emissions Inventory Unit P. O. Box 4314 Baton Rouge, LA 70821-4314
Resources • EPA Chief - offers a variety of software and other resources useful in calculating the inventory www.epa.gov/ttn/chief/index.html • LDEQ - http://www.deq.louisiana.gov/ • EIU – http://www.deq.louisiana.gov/evaluation/eis/index.htm
QUESTIONS & ANSWERS