Data Collection & Evaluation Seminar

Toxic Air Pollutants (TEDI)

Criteria Air Pollutants (EI)

Air Quality Assessment Division Organizational Chart

Jack ie H ebe rE S S ta ff

C lara W o o d sA d m in A ss is tan t 3

R ashaun da Jo hn so nE nv . S cien tis t

T iffin i G o sseran dE nv . S cien tis t

B rett D eD u a lE nv . S c ien tis t

C ed ric M ellio nE n v . S c ien tis t

N ich o las L aC ro ixE nv . S c ien tis t

S he lita W illiam sE S S up erv iso r

Jenn ifer M o u to nE nv . S c ien tis t M anage r

Contacts• Tiffini Gosserand

(225) 219-3500• Jackie Heber

(225) 219-3486• Rashaunda Johnson

(225) 219-3504• Nicholas LaCroix

(225) 219-3501

• Cedric Mellion(225) 219-3499

• Shelita Williams(225) 219-3503

• Fax:(225) 219-3240

• Email:EI-TEDI-TRI@la.gov

Address all postal mail to:

Department of Environmental QualityOffice of Environmental

Assessment/Air Quality Assessment Division

Data Collection & Evaluation GroupPO Box 4314

Baton Rouge, LA 70821-4314

Address all delivery mail to:

Department of Environmental QualityOffice of Environmental

Assessment/Air Quality Assessment Division

Data Collection & Evaluation Group602 N. 5th Street

Baton Rouge, LA 70802

New Email Address

EI-TEDI-TRI@la.gov

• Used for questions, comments, etc.• If sending EI & TEDI data files and/or

crosswalks by email, send them to this address only.

• Do not email them to individual staff.• Do not email the Certification

Statements.

Web Page Addresses

Emissions Inventory: http://www.deq.louisiana.gov/portal/Default.aspx?tabid=109

Toxic Emissions Data Inventory: http://www.deq.louisiana.gov/portal/tabid/114/Default.aspx

(A work in progress)

Emissions Inventory Enhancement Project

• DEQ Staff have completed the technical portion of the Request for Proposal (RFP)

• Should be out of state contract review and “on the street” in late February– Delays due to agency budget constraints

• Work should begin in late spring• Implementation Timing – goal is for 2006 data• More user friendly & better data quality and

availability

Emissions Inventory Enhancement Project

• Web based submittal– Work on-line or remotely and submit

info– Electronic certification

• Enhanced data validation that is linked to certification

• Integration of information• Permitted emissions, EI, TEDI, SSM and

variances

Extensions to the EI & TEDI reporting deadlines

• EI due March 31, 2006• TEDI due July 1, 2006• There will be no extensions granted

to these deadlines• Submittals received after will be

considered late and subject to enforcement action

EI and TEDI• There are approximately 1,171 reporters to EI and

approximately 282 reporters to TEDI

• The emission point IDs (NEDS points) between EI and TEDI must represent the same physical emission point in both inventories.

• Crosswalks must be submitted when changes to emission points occur.

• The toxic VOC reported on the EI Certification Statement should equal (within rounding error) the toxic VOC total reported to TEDI. (Not all TEDI chemicals are VOCs).

Chapter 51 & 919 Applicability

• If a facility meets the reporting requirements of 919 and 5107 it is the facility’s responsibility to submit a report to the department.

• If an EI or TEDI ID is not assigned to the facility, it does not mean you are not required to report.

• You have to request the ID.

Methyl Ethyl Ketone

• EPA delisted MEK as a TAP in the Clean Air Act on December 13, 2005.

• MEK is being reviewed for delisting as a TAP in LAC 33:III.Chapter 51.

• MEK must still be reported in the TEDI for the 2005 reporting year.

Data Requests• All data requests must go through Public

Records. Do not contact individual staff for data requests.

• Public Records web site:http://www.deq.louisiana.gov/portal/tabid/2231/Default.aspx

• Use the Public Requests form – fax or mail to:Custodian of Records Department of Environmental QualityP.O. Box 4303Baton Rouge, LA 70821-4303Fax: (225) 219-3175

• Online request form at:https://www.deq.louisiana.gov/prr/RequestForm.aspx

Hurricanes Katrina & Rita• EI and TEDI submittals are still required, even if the

facility no longer exists due to the hurricanes.• If the facility will not be rebuilt or will be rebuilt at a

different location, request, in writing, to be released from reporting after reporting year 2005.

• If the facility will be rebuilt at the same location with the existing AI # and Permit #, continue to use the same EI and TEDI IDs.

• If the facility will be rebuilt at a different location, a new AI #, permit #, EI ID, and TEDI ID will be issued.

• If records are lost as a result of the hurricanes, then….

Questions

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Comments

TEDI Applicability Review

• The owner or operator of any stationary source which was a major source but which has achieved minor source status through reduction of emissions and reduction of potential to emit.

• 10 tons/yr of any TAP listed in LAC 33:III.5112 or 25 tons/yr of any combination of TAPs.

(LAC 33:III.5101.A)

Requirements

• A Certification Statement is required from all facilities.

• Data File – can be emailed! • Discharge Report• Crosswalk• Cover Letter• Regulatory due date = July 1, 2006

Certification Statement

• All annual emissions reports and revisions to any emissions report shall include a certification statement that is signed by a “responsible company official” as per LAC 33:III.5107.

Certification Statement

• Complete all sections of the certification statement. (new version)

• Original signatures only. No faxed, stamped, copied, or electronic signatures.

• Name, number, and email address of the facility’s contact person.

Data File

• If sending by email, send them to EI-TEDI-TRI@la.gov

• If you mail a diskette, label the diskette: Facility Name, TEDI ID, AI #, and Reporting Year

Discharge Report

All discharges to the atmosphere of a TAP must be reported to the department in the annual emissions report and where otherwise specified in the applicable subchapters.

(LAC 33:III.5107.B5)

Discharge Report

• Identity of the source• Date and time of the discharge• Approximate total loss during the

discharge

Crosswalk

• Must be submitted when changes to emission points occur.

• Permit Point ID to EI/TEDI NEDS Point ID

• Can be an EXCEL or Word document. (hardcopy)

• Can be emailed to EI-TEDI-TRI@la.gov

Cover Letter

• Company/Facility Name• TEDI ID #• Agency Interest #• Invoice Mailing Address• Facility Contact Name and Number

Common Errorsto Avoid

• Invalid CAS numbers• Line duplications• More/Less than 53 characters on a

line• Invalid julian date/reporting year• Unsigned certification statement• Invalid SIC codes

Resources

• Standard Industrial Codes (SIC)

http://www.census.gov/epcd/www/naics.html

• Source Classification Codes (SCC)http://www.epa.gov/ttn/chief/codes/

• Reference Submittal Handouts

Questions

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Answers

2005 EI Reporting Criteria Review

• 1-hour ozone standard has been replaced by the 8-hour ozone standard

• Parishes designated as nonattainment or adjoining have not changed

Ozone Nonattainment Parishes: Ascension E. Baton RougeIbervilleLivingstonW. Baton Rouge

Ozone Adjoining Parishes: Assumption St. MartinE. Feliciana TangipahoaIberia W. FelicianaPointe CoupeeSt. HelenaSt. JamesSt. John the Baptist

2005 EI Reporting Criteria Review

Still in Effect for 2005!• Attainment Parish with Activated Contingency

Measures in Maintenance Plan: Calcasieu

Non-attainment Parish threshold applies

• Parishes adjoining Calcasieu: BeauregardCameronJefferson Davis

Adjoining Parish threshold applies

(Potpourri Notice 0102Pot1; Feb20, 2001)

2005 EI Applicability ReviewEmits or Potential to Emit

Attainment Parishes:• Any criteria pollutant > 100 TPY

Adjoining Parishes: • VOC > 50 TPY• All others > 100 TPY

Non-attainment Parishes:• VOC > 10 TPY • NOx > 25 TPY • All others > 100 TPY

(LAC 33:III.919.A)

2005 EI Applicability Review

Facilities that meet any of these criteria must also report an EI:

• 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) regardless of emissions

• A SOGA permit in a non-attainment or adjoining parish(LAC 33:III.919.A)

2005 EI Applicability Review

Standard Oil & Gas Permits

• Facilities that operate under a Standard Oil & Gas Air Permit (SOGA) and are located in an ozone non-attainment parish or an adjoining parish must report EI 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)

Potential to Emit (PTE)• Potential to emit includes all potential

emissions, not just permitted emissions.

• PTE includes:– 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

What is Reportable to EI• 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

• If a facility is constructed but not operating, an EI is still required.

• If a facility is permitted but not constructed, submit the certification statement with all zeros and a data file is not required until there are constructed emission points.

What is Reportable to EICriteria Pollutant SAROADAmmonia (NH3) 42604

Carbon Monoxide (CO) 42101

Lead (Pb) 12128

Nitrogen Oxides (NOx) 42602

Particulate Matter 10 (PM10)

81102

Particulate Matter 2.5 (PM2.5)

81104

Sulfur Dioxide (SO2) 42401

Total Volatile Organic Compounds (VOC)

43104

HRVOCs Pollutants:

SAROAD

Butenes, isomers

43218

Ethylene 43203

Propylene 43205

Requirements for 2005 EI• An original Certification Statement and a

duplicate 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)

• Original Signature – no faxed, stamped, copied or electronic signatures or certification statements

Requirements for 2005 EI• Please include a Cover Letter

• Company/Facility Name• Emissions Inventory ID #• Agency Interest ID #• EI Contact Name, Phone Number, and email address

• Regulatory due date = March 31, 2006• Must be postmarked or in-house

• Change of ownerships: • Multiple CS’s acceptable• Only one electronic data file (owner as of December

31, 2005 is responsible for the data file)

Requirements for 2005 EI

• Use the file we will provide to prepare the 2005 submittal.

• Run ALL files through Check EIS 2000 (version 2.0)

• Name for year 2005 data – 8 digit EI #.05dxxxxxxxx.05d

• Use the 2005 LDEQ Certification Statement.

2005 EI Certification Statement

• Do NOT use a previous version of the certification statement and change the years. Each version of the CS is different.

• Certifies only 2005 Criteria Pollutant Emissions Inventory• Original signature by a “responsible company official” as

per LAC 33:III.502.A or a designee• Add Agency Interest ID # & TEDI ID (if applicable)• Facility contact name and email address (this can not be a

consultant) – Person responsible for preparing and submitting the annual EI

• Complete Side 2• HRVOC emissions for selected parishes• Active permit numbers• Emission factor changes

What’s New for EIReporting Year 2005

• An original certification statement and a duplicate is required.

• No extensions will be granted to the reporting deadline.

• New email address for emailing data files (not for certification statements)

EI-TEDI-TRI@la.gov

• 1,3-butadiene, toluene, and xylenes – removed from HRVOC reporting

• LAC 33:III.501 & 919 Revisions

• If emission factors check box is checked, a copy of the certification statement does not need to be sent to Permits and Compliance.

LAC 33:III.919 Revision

• AQ255 Final Rule – February 20, 2006• Changes language from 1-hour ozone standard to

8-hour ozone standard• Lists the applicable parishes for each reporting

threshold• Requires an original and a duplicate certification

statement to be submitted

http://www.deq.louisiana.gov/portal/Default.aspx?tabid=2218

LAC 33:III.919 Revision• Clarifies calculation methods to be used:

– Continuous emissions monitoring systems (CEMS) or approved stack testing shall be used for reporting of emissions...

– In the absence of CEMS or stack test data, emissions shall be calculated using methods found in the most recent edition of, as of December 31 of the current reporting year, AP-42, calculations published in engineering journals, and/or EPA or department-approved estimation methodologies.

• For example, when calculating 2005 emissions, use CEMS or stack test data, then the most recent version, as of December 31, 2005, of AP-42, engineering journals, and/or EPA or LDEQ approved methodologies.

Emissions FactorsLAC 33:III.501 revision

• Emergency Rule AQ240E4, effective December 23, 2005. Good for 120 days or until proposed rule is promulgated.

• Proposed rule, AQ 240, has been issued to finalize this emergency rule.

• Emissions increases due solely to a change in AP-42 emission factors do not constitute violations of the air permit. Changes in emission factors other than AP-42 factors will be evaluated on a case-by-case basis.

• Check box on certification statement if this applies.

HRVOC Reporting• Under the authority of LAC 33:III.919.B.4, emissions of

highly reactive volatile organic compounds (HRVOC) must be included in the 2005 emissions inventory if the facility is located in one of the following 12 parishes:

Ascension St. CharlesE. Baton Rouge St. HelenaE. Feliciana St. JamesIberville St. John the

BaptistLivingston W. Baton RougePointe Coupee W. Feliciana

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

• If HRVOCs are not included on the certification statement, the submittal will be considered incomplete and subject to enforcement action.

HRVOC Reporting

• The specific compounds that must be added and their SAROAD codes are:

Butenes, isomers 43213Ethylene 43203 Propylene 43205

• 1,3-butadiene, toluene, and xylenes were removed for 2005.

• Emissions must be added to the electronic data file as well as the Certification Statement.

• Note: only 16 pollutants per NEDS point

Release from EI Reporting

• Release request must be in writing on company letterhead.

• If a facility is shutdown, the permit is rescinded, or if PTE is lowered below the threshold, facility is not released immediately. Additional reporting may be required before release can be granted.

• Examples: – if a facility was shutdown or permit rescinded in mid-

2005, the facility still has to report to EI for 2005 and possibly for 2006 or until emissions shown in EI are all zeros.

– If a permit is modified to show PTE below reporting thresholds in 2005, the facility still has to report until emissions shown in EI are below reporting thresholds.

VOC Reminders

• 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)

VOC Reminders• Not all TEDI chemicals are VOCs. i.e., ammonia,

beryllium, chlorine, etc.

• When calculating toxic VOCs for your EI, do not use the sum of your TEDI chemicals. Remove the emissions from the TEDI chemicals that are not VOCs. The list of non-VOC TEDI chemicals:

http://www.deq.louisiana.gov/portal/default.aspx?tabid=1757

• If you report to TEDI, the sum of TEDI VOCs are subtracted from the EI Total VOC on the certification statement for invoicing. This ensures we do not invoice you twice for the same emissions.

What you can do to improve data quality

Record VOC emissions correctly.

Total VOC = Toxic + Non Toxic

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 01, 02, 03, 04, 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.

Data accuracy is vital!What you can do to improve data quality

•Do not delete NEDS points (No 11Ds).

• If we see card 11D, we will delete the entire card from the data file and the delete will not take place.

19084010699990536501 11D

Data accuracy is vital!What you can do to improve data quality

• When a NEDS point is no longer operating, do not delete the NEDS (Card 11D):– zero the throughput - Card 11 cols. 52-64 = 2525252500052– zero all of the emissions - Card 13 cols. 26-62– change the estimation code to 7 - Card 13 col. 64– insert appropriate comment on Card 30

192880106999905365010011311 708732311 2525252500052 11C 19288010699990536501003000405000000500000010000 12C 1928801069999053650143104 00000000000000 7 13C 19288010699990536501O 001 500 HP NATURAL GAS-FIRED COMP ENG 14C192880106999905365013100020300 0000000 00000F 21C1928801069999053650131000203002C500 HP COMPRESSOR ENGINE 22C192880106999905365013100020300F 43104 23C1928801069999053650100001LCOMP DID NOT OPERATE IN 1997 30A1928801069999053650100001RCOMP WAS REMOVED IN FEBRUARY 1997 30A1928801069999053650100002LCOMP IN POINT 25 REPLACED THIS ONE. 30A

Data accuracy is vital!What you can do to improve data quality

• Card 11 Throughput – If the point did not operate at all for the year, fill columns 52-64 with 2525252500052.

• Card 11 Throughput – The sum of the weighted percent should be no more than 100%. The coding manual says 95-105% is acceptable, however, when we convert the data to NIF for submittal to EPA, any thing greater than 100% is invalid.

19156010699990536512 1311 787032746 252525250005200000000 11C

19156010699990536512 1311 787032746 252525252475200000000 11C

Data accuracy is vital!What you can do to improve data quality

• Card 11 Operating Rates – Hours < 24, days < 7, and weeks < 52.

• When multiplying, the total should be no more than 8736.

• Example: If the point operates 60 hours a year:

Incorrect:19156010699990536512 1311 787032746 252525250116000000000 11C

60 weeks a year is not a valid entry.

A Correct Option:19156010699990536512 1311 787032746 252525251010600000000 11C

Data accuracy is vital!What you can do to improve data quality

• Double check your facility UTM coordinates, Physical and Mailing Addresses and Contact information.

• If facility is in zone 16, but are using horizontal coordinates for zone 15, make sure the zone on card 01 is 15.

• Make sure coordinates are valid for LA.• Do NOT use 214.9 as the horizontal coordinate for

anything, including compressor shutdowns.

• If a NEDS point is not a point source, i.e., fugitives, then a center point can be used for the coordinates.

19156010699990536516 1311 214932556 252525250005200000000 11C

Data accuracy is vital!What you can do to improve data quality

• Do not use an estimation code of 3 in column 64 of card 13. Some commercially designed EIS software programs use 3 in column 64. Change the 3 to a valid code such as 5.

Incorrect:1928801069999053650142602 00000000000000 3 13C

Correct:1928801069999053650142602 00000000000000 5 13C

Data accuracy is vital!What you can do to improve data quality

• If you have 16 pollutants and want to add additional pollutants, you must delete the unwanted pollutants in RY 2005, and then add the additional pollutants in RY 2006.

• The system will not allow card 13D and 13A in the same reporting year when all 16 pollutants have been used.

• Advice:• Do not report more than what is required. However, methane

(43201) and carbon dioxide (42102) are always welcome.

• If you speciate total VOCs (43104) in the data file by individual pollutant, those speciated emissions should still be included in the total VOC emissions (43104).• It is not necessary to report your TEDI chemicals in your EI.

Data accuracy is vital!What you can do to improve data quality

• Check your SCCs and SICs to make sure they are correct, not just valid.

• Point source SCC – Be sure you are using an SCC for point sources, not area sources.

• SIC 0000 on card 11 is not acceptable:

• 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.

190200106999905365010000000 686833059 001724242473400000000 11C

190200106999905365013060010400F 42101 00000 23C

• Changing SCC Codes – Use 21D and 21A. Do NOT use 21C, 22C, 23C, 24C, and 25C to change SCC. Check the sequence numbers.

190840106999905365AA2020160100 21D190840106999905365AA2020020100 F 21A190840106999905365AA2020020100 NATURAL GAS TURBINE 22A190840106999905365AA2020020100F 43104 23A

Data accuracy is vital!What you can do to improve data quality

Data accuracy is vital!What you can do to improve data quality

• Deleting SCC Codes – Use 21D and remove cards 22, 23, 24, and 25 completely. Do NOT use a 22D, 23D, 24D, and 25D.

Incorrect:190840106999905365AA3100020300 21D190840106999905365AA3100020300 22D190840106999905365AA3100020300 23D190840106999905365AA3100020300 24D190840106999905365AA3100020300 25D

Correct:190840106999905365AA3100020300 21D

What you can do to improve data quality

• If your facility is an Air Toxics facility, in general, you should report to both TEDI and EI.

• Please be sure that the TEDI and EI submittals correspond.

• You can submit the TEDI CS and data file with the EI.

• Action Codes – Use capital letters.• Data files with too many errors will be sent back

for corrections• Crosswalk of Permit Point ID to EI/TEDI NEDS

Point IDs

Reminders• 2005 inventory - due on March 31, 2006• Save updated file with extension .05d• Change of ownerships:

• Multiple CS’s acceptable• Only one electronic data file

• Electronic data can be mailed or e-mailed to EI-TEDI-TRI@la.gov.

• Certification Statements (an original and duplicate) with original signature must be mailed or delivered to the department.

• Run all files through Check EIS before sending them.

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/portal/tabid/36/Default.aspx

• Emissions Inventory – http://www.deq.louisiana.gov/portal/tabid/109/Default.aspx

• Valid Source Classification Codes (SCC):http://www.epa.gov/ttn/chief/codes/

QUESTIONS

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ANSWERS