Transcript Annual Operation Report Workshop

January 13, 2009
Tampa, Florida
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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
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Ozone season reporting
Hazardous air pollutant reporting
Condensible emissions reporting
Fugitive emissions reporting
Emissions calculation hierarchy
AOR submission due date
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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)
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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.
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Any HAP for which a permit limit is imposed
must be reported every year, even if below
1000 lbs
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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.
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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.
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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.
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Fugitive PM emissions from vehicular
movement or wind erosion need not be
reported unless required by permit.
Method
1.
2.
3.
4.
5.
6.
Emissions Method
Code
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
3.
1A
2
3A
4.
3B
5.
4
6.
5
1.
2.
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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.
Tom Rogers
Florida DEP
(850) 921-9554
[email protected]