Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 1
Point Source Emissions Inventories
Air Quality Division Susan Wampler May 5-6, 2015• •
2015 Environmental Trade Fair and Conference
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 2
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 3
30 TAC §101.10 (a) applicability
(b) types of inventories
(c) calculations
(d) certifying statements
(e) reporting requirements
(f) enforcement
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 4
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?
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 5
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)
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 6
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”
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 7
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 8
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)?
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 9
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 10
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.)
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 11
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 12
Types of EIs
Initial
Annual– full update– insignificant change
Special– ozone precursors– Lead (Pb)
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 13
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 14
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 15
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 16
Types of EIs (cont.)Insignificant Change Notification Letter (cont.)
2010 2011 2012 2013 2014
2% increase > Emissions total
2% increase > Emissions total
2% increase > Emissions total
2% increase > Emissions total
Emissions total
Rollover? Yes Rollover? Yes Rollover? No Rollover? Yes
2010 emissions entered in STARS
2010 emissions copied to 2011
2010 emissions copied to 2012
6% increase from 2010 emissions in STARS so 2013 totals must be entered
2013 emissions copied to 2014
Example of how a rollover request submitted several years in a row is evaluated:
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 17
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 18
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 19
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 20
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 21
Moderate
Serious
Severe
Special for ozone precursors
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 22
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 23
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 24
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 25
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 26
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 27
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 28
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 29
Reporting Requirements (cont.)
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 30
Reporting Requirements (cont.)
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 31
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 32
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 33
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 34
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 35
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.
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 36
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
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 37
Trends and Data
Air Quality Division March 2015
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 38
Trends and Data (cont.)
Air Quality Division March 2015
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 39
Trends and Data (cont.)
Air Quality Division March 2015
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 40
Trends and Data (cont.)
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 41
Trends and Data (cont.)
Air Quality Division • Emissions Inventories, SAW: May 5-6, 2015• Page 42
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