Emissions Inventory Seminar Criteria Air Pollutants EIS Toxic

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 Department of Environmental Manager - Linda Brown Staff Environmental EIS Quality Jackie Surles Rashaunda Johnson Tiffini Brumfield Brett De. Dual TEDI Shelita Smith Cedric Mellion TRI Nicholas La. Croix Rashaunda Johnson

Criteria Pollutant Emissions Inventory Reporting for 2004 Contacts: Louisiana Department of Environmental Quality Jackie Surles Jackie. Surles@la. gov (225) 219 -3486 Rashaunda Johnson Rashaunda. Johnson@la. gov (225) 219 -3504 Brett De. Dual 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: Louisiana Department of Environmental Quality 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 Review Still in Effect for 2004! § Attainment Parish with Activated Louisiana Department of Environmental Quality Contingency Measures in Maintenance Plan: Calcasieu Non-attainment Parish threshold applies § Parishes adjoining Calcasieu: Beauregard, Cameron, Jefferson Davis Adjoining Parish threshold applies (Potpourri Notice 0102 Pot 1; Feb 20, 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 required Louisiana Department of Environmental Quality 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 Environmental Quality Defined as the lesser of the following: o 5% increase or decrease in facility total potential/actual emissions o 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 Environmental Quality § Check EIS 2000 (version 2. 0) § Name for year 2004 data – 8 digit EI #. 04 d xxxx. 04 d § 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 NH 3 and PM 2. 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. PM 2. 5 and NH 3 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 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

PM 10, PM 2. 5 & TSP § All facilities must report particulate Louisiana Department of Environmental Quality emissions as PM 10 AND PM 2. 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 - PM 10. § The NAAQS for PM 2. 5 was issued in July 1997.

PM 10, PM 2. 5 & TSP § Check the code in the electronic data file. Particulate emissions must be recorded under the SAROAD codes for PM 10 & PM 2. 5. Louisiana Department of Environmental Quality § Delete the code for TSP (Card 13 D & 23 D) and add the code for PM 10 & PM 2. 5 (Card 13 A & 23 A). § SAROAD pollutant codes: TSP = 11101 (DELETE) • PM 10 = 81102 • PM 2. 5 = 81104 •

PM 10, PM 2. 5 & TSP Louisiana Department of Environmental Quality References: § EPA’s PM 2. 5 Inventory Resources Center: http: //www. epa. gov/ttn/chief/eiip/pm 25 inventory/ § 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 Louisiana Department of Environmental Quality § Do not delete NEDS points (No 11 Ds). § 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 quality Highlights from the Tips Sheet § Louisiana Department of Environmental Quality § § § 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 252500052. Changing SCC Codes – Use 23 D and 23 A. Do NOT use a 23 C. Check the sequence numbers.

What you can do to improve data quality Record VOC emissions correctly. Louisiana 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 Environmental Quality 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 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. 04 d § 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 – 6 th 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