Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 1 Point Source Emissions...

Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015•

Point Source Emissions Inventories

Air Quality Division Susan Wampler May 5-6, 2015• •

2015 Environmental Trade Fair and Conference


Point Source Emissions Inventory (EI) Overview

30 Texas Administrative Code (TAC) Section (§) 101.10

Applicability: Does the site need to submit an EI? Types of EIs Reporting responsibility Reporting options Reporting requirements 2014 Guidance clarifications and reminders 2014 EI publications EI process/timeline overview Trends and Data


30 TAC §101.10 (a) applicability

(b) types of inventories

(c) calculations

(d) certifying statements

(e) reporting requirements

(f) enforcement


Major stationary source defined under 30 TAC §116.12 (relating to Nonattainment and Prevention of Significant Deterioration definitions)– The rule defines potential to emit (PTE) thresholds.– The major source threshold can change based on the

attainment status and classification of the county.

Need to know:– PTE and actual emissions thresholds for regulated

pollutants– PTE and actual emissions thresholds for hazardous air

pollutants (HAP)– Site location and attainment status and classification of

the county

ApplicabilityDoes the site need to submit an EI?


Applicability (cont.)Does the site need to submit an EI?

Any site in ozone nonattainment areas that emits:− > 10 tons per year (tpy) of volatile organic

compounds (VOC); − > 25 tpy of nitrogen oxides (NOx); or − > 100 tpy of any contaminant subject to National

Ambient Air Quality Standards.

Any site that emits or has the PTE 100 tpy or more of any contaminant.

except for green house gases (GHGs)


Applicability (cont.)Does the site need to submit an EI?

Any site that emits or has the PTE HAPs as defined in Federal Clean Air Act, Section 112(a)(1):− 10 tpy single; or − 25 tpy aggregate.

Any source of emissions subject to special inventories under 30 TAC §101.10(b)(3)

Designations for 2014 special inventories will be discussed under “types of EIs”


Applicability (cont.)

Summary of Reporting Requirements in Tons per Year (tpy) for 30 TAC §101.10

Note: For ozone nonattainment areas, the more stringent or severe classification (where applicable) between the 1997 and 2008 ozone standards is used to determine reporting requirements for ozone precursor potential emissions.

County

Volatile Organic Compounds

(VOC)

Nitrogen Oxides

(NOx)Other

Individual HAPs

Aggregate HAPs

Actual PTE Actual PTE Actual PTE Actual PTE Actual PTE

Brazoria, Chambers, Fort Bend, Galveston, Harris,

Liberty, Montgomery, Waller

SEVERE/OZONE

10 25 25 25 100 100 10 10 25 25

Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant,

SERIOUS/OZONE

10 50 25 50 100 100 10 10 25 25

Wise MODERATE/OZONE

10 100 25 100 100 100 10 10 25 25

All Other Counties 100 100 100 100 100 100 10 10 25 25


Applicability (cont.)

Summary

1) What is the attainment status and classification of the county where my site is located?

2) What are my site’s actual emissions for regulated pollutants and HAPs (single and aggregate)?

3) What is my site’s PTE for regulated pollutants and HAPs (single and aggregate)?


In March 2014, Texas Commission on Environmental Quality (TCEQ) adopted rulemaking to implement House Bill 788 of the 83rd Legislative Session.

On June 23, 2014, the Supreme Court of the United States issued an opinion in Utility Air Regulatory Group v. Environmental Protection Agency (EPA) et al. that affects GHG permitting.

GHG Update


Sites cannot be classified as major sources solely due to GHG emissions levels.

GHG emissions are NOT required to be reported in the EI. There are no changes to EI reporting requirements.

There are no changes to emissions fee assessments.

GHG Update (cont.)


Austin Fun Fact #1

Author O. Henry lived in Austin from 1884 – 1895 before moving to Houston to write full time for the Houston Post.

His most well known writing is the Christmas short story called “The Gift of the Magi.”

His house is located at 409 East 5th street, one block north of the convention center. The house currently serves as the O. Henry Museum.

The O. Henry Pun-Off is a spoken word competition held every May to celebrate word play in the form of puns.


Types of EIs

Initial

Annual– full update– insignificant change

Special– ozone precursors– Lead (Pb)


Types of EIs (cont.) Initial EI

Applies to a site that has never submitted an inventory

Must be received by the TCEQ by March 31 of the calendar year immediately following the reporting year

Can submit using the Web-EI system


Types of EIs (cont.)Annual EI Update

Annual update required each year reporting criteria are met– Updating an EI: Chapter 6, EI Guidelines– EI Checklist: page xiv, 2014 EI Guidelines

Due March 31 of the calendar year immediately following the reporting year, unless otherwise notified in writing by the TCEQ.


Types of EIs (cont.)Insignificant Change Notification Letter

A letter can be submitted if changes in emissions for each pollutant do not exceed 5% or 5 tpy, whichever is greater, from the last reported EI.− The 5% or 5 tpy criteria are based upon 2014 emissions

compared to the most recently submitted EI entered into the STARS database.

− The changes can be either increases or decreases.− The emissions from the last submitted EI are copied to

current year.− Sample letter provided in 2014 Emissions Inventory

Guidelines, Appendix B.− If a letter is submitted several years in a row, the EI may

need to be updated if the OVERALL change exceeds 5% or 5 tpy from last submitted EI.


Types of EIs (cont.)Insignificant Change Notification Letter (cont.)

2010 2011 2012 2013 2014

2% increase > Emissions total




Emissions total

Rollover? Yes Rollover? Yes Rollover? No Rollover? Yes

2010 emissions entered in STARS

2010 emissions copied to 2011


6% increase from 2010 emissions in STARS so 2013 totals must be entered


Example of how a rollover request submitted several years in a row is evaluated:


Types of EIs (cont.)Insignificant Change Notification Letter (cont.)

In addition to the Insignificant Change Notification Letter, the following must be provided:– Account and EI contact information; – Criteria emissions totals and site quantifiable event

totals; – Signature of legally responsible party; – Updates to emission events and/or scheduled

maintenance, startup, and shutdown activities (EE/SMSS).

• If site experienced no EE, then the EE certification statement must be signed.

• If site experienced EE, then provide EE updates on the applicable paths emissions pages of the EI.


Types of EIs (cont.)Special EI: Pb

Special Inventory requirement only applies to regulated entities (RE) that are notified in writing of the special inventory.

RE that receive a written request from the TCEQ must respond to the letter, even if the site does not meet reporting thresholds.

Actual/PTE emissions thresholds for Pb special EI:– Any regulated entity that emits ≥ 0.5 tpy of Pb

emissions during normal operations; or– Any regulated entity that has the PTE ≥ 5 tpy of Pb.

Applicable to all counties in Texas


Types of EIs(cont.) Special EI: Ozone Precursors

Special Inventory requirement only applies to RE that are notified in writing of the special inventory.

RE that receive a written request from the TCEQ must respond to the letter, even if the site does not meet reporting thresholds.

Actual emissions reporting thresholds for ozone precursors are:– 10 tpy of VOC; or– 25 tpy of NOX, during normal operations; and– Located in one of the counties on the next slide


Bastrop Bexar Caldwell Comal El Paso

Gregg Guadalupe Hardin Harrison Hays

Henderson Hood Jefferson McLennan Nueces

Orange Rusk San Patricio Smith Travis

Upshur Victoria Williamson Wilson

Special Inventory Counties

CountyCLASSIFICATION/

POLLUTANT

VOC NOx OtherIndividual

HAPAggregated

HAPActual Potential Actual Potential Actual Potential Actual Potential Actual Potential

SPECIAL INVENTORY REPORTING

THRESHOLDS FOR OZONE PRECURSORS

10

100

25

100

100

100

10

10

25

25


Moderate

Serious

Severe

Special for ozone precursors


Inapplicability Notifications

If you receive a notification letter from the TCEQ but the site does not meet any of the reporting thresholds in 30 TAC §101.10 or special inventory requirements, a certifying letter is acceptable in place of a full EI update.

The sample letter provided in the 2014 EI Guidelines, Appendix B, is recommended. – No option currently to submit through the Web– A similarly worded letter can be provided


Austin Fun Fact #2

Congress Avenue Bridge is home to the largest urban bat population in the US from March through November.

Each spring, mostly female, pregnant Mexican free-tailed bats migrate from central Mexico.

Approximately 1.5 million bats live under the bridge and eat 10,000 to 20,000 pounds of insects each night.


Reporting Responsibility

Who is Responsible for Reporting the EI?

The owner or operator of the site at the time the inventory is due is responsible for reporting the EI.

The due date for sites that reported an EI the previous year is March 31 unless otherwise directed in writing by the TCEQ.

The due date for sites that did not report an EI the previous year but are applicable to reporting requirements is March 31.


Reporting Options

Web-EI: two options– Web entry method: analogous to updating paper

Called "manual entry,“ “web entry” or "emissions inventory questionnaire (EIQ) entry" method

– Electronic file upload/submission Now fully integrated into Web-based system Called "text file upload" or "delta file" method

PaperBeginning with the 2015 reporting cycle (due March 31, 2016), paper EIs will no longer be accepted.


Reporting Options (cont.)Web-EI

Web entry method: analogous to updating paper– Users enter data to State of Texas Environmental

Electronic Reporting System work area using Graphical User Interface windows

– User can log in and out while maintaining a “work-in-process” in the work area

– Users submit completed data when ready– Called manual entry, web entry or EIQ method

Electronic file upload/submission− Now fully integrated into Web-based system− Called text file upload or delta file method


Reporting Requirements

What Sources to Include in the EI

Represent sources individually if the source:

– is listed in any TCEQ enforceable document such as a permit, regulation, or commission order;

or– emitted 1 tpy or more of any

regulated pollutant; or

– emitted 0.1 tpy or more of toxics or HAPs;

or– emitted 2 pounds (lbs) or

more per year of Mercury (Hg) and/or Pb.


Reporting Requirements (cont.)

What Sources to Include in the EIMay represent sources as collective sources if the sources:

– are not listed individually in any TCEQ enforceable document such as a permit, regulation, or commission order;

– emitted < 1 tpy or more of any regulated pollutant; and

– emitted < 0.1 tpy or more of toxics or HAPs.



Report any Regulated Air Contaminant

Criteria pollutants: NOx, carbon monoxide, sulfur dioxide (SO2), VOC, Pb, PM10, PM2.5

– PM10 : particulate matter 10 microns in diameter and less

– PM2.5 : particulate matter 2.5 microns in diameter and less

HAPs identified in Federal Clean Air Act, §112(b) Other regulated air contaminants subject to rules,

regulations, permits, orders of the commission, or court orders; for example – particulate matter (PM)

Once a site meets applicability, all regulated contaminants must be reported.



Summary of Speciation Criteria

Counties What to speciate When to speciate

All counties

Pb, Hg Path level emissions ≥ 0.001 tpy

HAPs and Toxics Path level emissions ≥ 0.1 tpy

TSP, PM10 • Speciate particulate classes• Known constituents should be

speciated

Chemical Mixtures When constituents are known

Nonattainmentcounties

HRVOC Path level emissions ≥ 0.1 tpy

East of 100º longitude; andEl Paso

Total VOC 90% speciation required when path level emissions ≥ 5 tpy

West of 100º longitude

Total VOC 90% speciation required when path level emissions ≥ 25 tpy


Reporting Requirements (cont.) General Hierarchy of Determination Methods D: Continuous Emissions Monitoring System—Must

be used if present and properly operated H: Highly reactive volatile organic compounds (HRVOC)

monitoring system F: Predictive emissions monitoring system M: Measured or stack test data Q: Portable analyzer test data V: Vendor-supplied emissions factors A: AP-42 and other U.S. Environmental Protection Agency

approved factors B: Material balance S: Scientifically calculated E: Estimated O: Other


Guidance Clarifications and Reminders (cont.)EI Guidance Updates

Chapters 1 and 2– Guidance for sites that are permitted but not built– Guidance on submitting confidential information

electronically Chapter 4

Changed the denominator in the equation to determine ozone season pounds per day (ppd) emissions rates from ‘Operation Days’ to simply ‘153 days’ to obtain the ppd emission rate for the entire ozone season.

Appendix A, Technical Supplement 4: "Flares"The EPA is potentially updating certain AP-42, Chapter 13.5 emissions factors for flares; do not use the proposed flare factors for EI purposes.


Guidance Clarifications and Reminders (cont.)EI Guidance Updates (cont.)

Technical Supplement 6: Aboveground Liquid Storage Tanks

– Clarified data required for determining emissions using chemical mixtures

– Streamlined guidance on produced water tanks, heated tanks, and tanks receiving hot products

– New guidance for potential breathing losses from heated, insulated tanks

– Clarified data required for tanks storing heavy fuel oils and related products

– New guidance for the ozone season emissions calculations using the American Petroleum Institute's Exploration and Production Tank program and how to adjust emissions accordingly


Sample Calculation Templates Common source types

– glycol dehydration– internal combustion engines– marine vessel loading operations– railcar and truck loading operations– storage tanks

Sample calculation templates are located on the Point Source Emissions Inventory Web page:

http://www.tceq.texas.gov/airquality/point-source-ei/psei.html..for common sources are available on the Point

http://home.tceq.state.tx.us/internal/ceo/presentations/guidance.shtml

http://home.tceq.state.tx.us/internal/ceo/presentations/guidance.shtml


2014 EI Guidance Documents

EI guidelines book (RG-360/14) provides:– step-by-step instructions for completing an EI;– yearly updates with current reporting requirements; and– technical supplements for common emissions sources.

EI forms and instructions – blank forms in enterable PDF format – document includes instructions and example forms

Web-based EI Reporting Instructions

All documents available at: www.tceq.texas.gov/goto/ieasCall TCEQ publications for your one free hard copy of the 2014 EI Guidelines: (512) 239-0028.


EI Process/Timeline Overview

** or as directed in writing by the TCEQ

Calendar Year Data is Transmitted

to EPA

Ongoing TCEQ Review of Submitted Data

EI (All types) Due March 31** Contaminant Summary Reports

Mailed to Sites as Reviews are Completed


Trends and Data

Air Quality Division March 2015


Trends and Data (cont.)

Air Quality Division March 2015


Trends and Data (cont.)


Questions?

Susan Wampler−[email protected]−512-239-1463

EI Helpline−Mon-Fri, 8am - 5pm−512-239-1773

Point Source Emissions Inventory webpage: www.tceq.texas.gov/goto/ieas

Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 1 Point Source Emissions...

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