Transcript Document

Emissions Inventory
Seminar
Criteria Air Pollutants
(EIS)
Toxic Air Pollutants
(TEDI)
Organization
Department of Environmental Quality
Office of Environmental Assessment
Air Quality Assessment Division
EIS/TEDI/TRI
Louisiana
Environmental Manager - Linda Brown
Department of
Staff Environmental
EIS
Quality
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:
Louisiana
Department of
Environmental
Quality
Jackie Surles
[email protected]
(225) 219-3486
Rashaunda Johnson
[email protected]
(225) 219-3504
Brett DeDual
[email protected]
(225) 219-3537
Tiffini Brumfield
[email protected]
(225) 219-3500
Fax: 225-219-3240
2004 Reporting Criteria Review
 Ozone Non-attainment Parishes:
Louisiana
Ascension, E. Baton Rouge, Iberville,
Livingston, W. Baton Rouge
Department of
Environmental
Quality
 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 Review
Still in Effect for 2004!
 Attainment Parish with Activated
Department of
Contingency Measures in
Maintenance Plan:
Calcasieu
Environmental
Non-attainment Parish threshold applies
Louisiana
Quality
 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.
Louisiana
Department of
Environmental
Quality
 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:
Louisiana
Department of
•
•
Environmental
Quality
•
•
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
•
Louisiana
Department of
Environmental
Quality
•
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
Louisiana
Department of
Environmental
rule applies to you.
 All emissions within the facility must
be included in the inventory even...

Quality

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
Louisiana
Department of
Environmental
Quality
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
Louisiana
Department of
Defined as the lesser of the following:
o 5% increase or decrease in facility total
potential/actual emissions
o
Environmental
Quality
o
o
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
Louisiana
Department of
Environmental
Quality




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.
Louisiana
Department of
 Check EIS 2000 (version 2.0)
Environmental
Quality
 Name for year 2004 data – 8 digit EI #.04d
xxxxxxxx.04d
 Use the 2004 LDEQ Certification Statement.
Certification Statement
 Certifies only 2004 Criteria Pollutant
Louisiana
Department of
Environmental
Quality
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
Louisiana
Department of
Environmental
Quality
NH3 and
PM2.5 required
under LAC
33.III.919
Side 2
Active Air Permit
Numbers
Emission Factor
Changes
Louisiana
Department of
Environmental
Quality
HRVOC
Emissions for
Specific
Parishes
What’s New for
Reporting Year 2004
Louisiana
Department of
Environmental
Quality
 Toluene & Xylene – new for
HRVOC Reporting
 Emergency Rule – difference in
emission factors
LAC 33:III.919 Revision
o
Louisiana
o
Department of
Environmental
Quality
o
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
o
Louisiana
Department of
Environmental
Quality
o
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 nonattainment and adjoining parish lists
HRVOC Reporting
•
The specific compounds that must be
added and their SAROAD codes are:
1,3-butadiene
Butenes, isomers
Ethylene
Propylene
Toluene
Xylenes, isomers
Louisiana
Department of
Environmental
Quality
•
•
•
43218
43213
43203
43205
45202*
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
Louisiana
Department of
Environmental
Quality
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.
Louisiana
Department of
Environmental
Quality
 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
Louisiana
Department of
Environmental
Quality
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
Louisiana
Department of
emissions in the electronic data file
and on the Certification Statement,
even if it is reported in the TEDI.
Environmental
Quality
 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
Louisiana
Department of
Environmental
Quality
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 quality
Highlights from the Tips Sheet

Louisiana
Department of
Environmental
Quality

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


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
Louisiana
Record VOC emissions
correctly.
Department of
Environmental
Quality
Total VOC = Toxic + Non Toxic
VOC Reminder
 Total Volatile Organic Compounds
(VOCs) include all compounds that are
toxic VOCs and nontoxic VOCs.
Louisiana
Department of
Environmental
Quality
 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
Louisiana
Department of
Environmental
Quality
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,
Louisiana
Department of
in general, you should report to both
TEDI and EIS.
Environmental
Quality
 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
Louisiana
Department of
Environmental
Quality
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
Louisiana
Department of
Environmental
Quality

SAROAD Codes:
• Carbon dioxide = 42102
• Methane = 43201
 Crosswalk of Permit Point ID to
EI/TEDI NEDS Point ID
Submitting the Data
Louisiana
Department of
Environmental
Quality
 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:
Louisiana
Department of
Environmental
Quality
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
Louisiana
Department of
Environmental
Quality
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
Louisiana
Department of
&
Environmental
Quality
ANSWERS