Emissions Inventory Seminar Criteria Air Pollutants (EIS) Toxic Air Pollutants (TEDI)

Emissions Inventory Seminar

Criteria Air Pollutants (EIS)

Toxic Air Pollutants (TEDI)

LouisianaLouisiana

Department ofDepartment of

EnvironmentalEnvironmental

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OrganizationDepartment of Environmental QualityOffice of Environmental Assessment

Air Quality Assessment DivisionEIS/TEDI/TRI

Environmental Manager - Linda Brown

Staff - EIS Jackie Surles

Rashaunda JohnsonTiffini BrumfieldBrett DeDual

TEDI Shelita SmithCedric Mellion

TRI Nicholas LaCroixRashaunda Johnson

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Jackie [email protected]

(225) 219-3486

Rashaunda [email protected]

(225) 219-3504

Brett [email protected]

(225) 219-3537

Tiffini [email protected]

(225) 219-3500

Fax: 225-219-3240

Criteria Pollutant Emissions Inventory Reporting for 2004

Contacts:

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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

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2004 Reporting Criteria Review

Still 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)

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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)

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2004 EIS Applicability ReviewFacilities 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)

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2004 EIS Applicability ReviewStandard 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)

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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

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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)

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Significant Change

Defined as the lesser of the following:o 5% increase or decrease in facility total

potential/actual emissions

o 50 tpy increase or decrease in facility total potential/actual emissions

o 10 tpy increase or decrease in potential/actual emissions from a single emissions point

o Termination of operations at the facility

(LAC 33:III.919.B.2)

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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

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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.

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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

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Side 1

NH3 and PM2.5 - required under LAC 33.III.919

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Side 2Active Air Permit Numbers

HRVOC Emissions for Specific Parishes

Emission Factor Changes

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What’s New for Reporting Year 2004

Toluene & Xylene – new for HRVOC Reporting

Emergency Rule – difference in emission factors

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LAC 33:III.919 Revision

o Final Rule – December 20, 2003o Major revisions were made to the

rule primarily to clarify the language and to codify reporting requirements that were already policy.

o Rule now correlates with the Federal CERR (i.e. PM2.5 and NH3 reporting)

http://www.deq.louisiana.gov/planning/regs/addition/index.htm

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HRVOC Reportingo 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

o Note: this list is NOT the same as the non-attainment and adjoining parish lists

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HRVOC Reporting• The specific compounds that must be

added and their SAROAD codes are:1,3-butadiene 43218Butenes, isomers 43213Ethylene 43203

Propylene 43205Toluene 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

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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.

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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

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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

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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

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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

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What you can do to improve data quality

Highlights 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.

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Record VOC emissions correctly.

Total VOC = Toxic + Non Toxic

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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)

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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.

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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.

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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.

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Optional Reporting

Greenhouse Gases SAROAD Codes:

• Carbon dioxide = 42102• Methane = 43201

Crosswalk of Permit Point ID to EI/TEDI NEDS Point ID

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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:

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Address all USPS Mail to:

LDEQ/OEA/AQAD – 6th FloorEmissions Inventory Unit

P. O. Box 4314Baton Rouge, LA 70821-

4314

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Resources

EPA Chief - offers a variety of software and other resources useful in calculating the inventorywww.epa.gov/ttn/chief/index.html

LDEQ - http://www.deq.louisiana.gov/

EIU – http://www.deq.louisiana.gov/evaluation/eis/index.htm

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QUESTIONS

&

ANSWERS

Emissions Inventory Seminar Criteria Air Pollutants (EIS) Toxic Air Pollutants (TEDI)

Documents

Transcript of Emissions Inventory Seminar Criteria Air Pollutants (EIS) Toxic Air Pollutants (TEDI)