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LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
OrganizationDepartment of Environmental QualityOffice of Environmental Assessment
Air Quality Assessment DivisionEIS/TEDI/TRI
Environmental Manager - Linda Brown
Staff - EIS Jackie Surles
Rashaunda JohnsonTiffini BrumfieldBrett DeDual
TEDI Shelita SmithCedric Mellion
TRI Nicholas LaCroixRashaunda Johnson
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Jackie [email protected]
(225) 219-3486
Rashaunda [email protected]
(225) 219-3504
Brett [email protected]
(225) 219-3537
Tiffini [email protected]
(225) 219-3500
Fax: 225-219-3240
Criteria Pollutant Emissions Inventory Reporting for 2004
Contacts:
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
2004 Reporting Criteria Review
Ozone Non-attainment Parishes: 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
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
2004 Reporting Criteria Review
Still in Effect for 2004!
Attainment Parish with Activated Contingency Measures in Maintenance Plan: Calcasieu
Non-attainment Parish threshold applies
Parishes adjoining Calcasieu: Beauregard, Cameron, Jefferson Davis
Adjoining Parish threshold applies
(Potpourri Notice 0102Pot1; Feb20, 2001)
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
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.
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)
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
2004 EIS Applicability ReviewFacilities that meet any of these
criteria must also report an EIS:
• 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)
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
2004 EIS Applicability ReviewStandard Oil & Gas Permits
• 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)
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
What is Reportable 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
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Requirements
A Certification Statement 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)
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Significant Change
Defined as the lesser of the following:o 5% increase or decrease in facility total
potential/actual emissions
o 50 tpy increase or decrease in facility total potential/actual emissions
o 10 tpy increase or decrease in potential/actual emissions from a single emissions point
o Termination of operations at the facility
(LAC 33:III.919.B.2)
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Requirements
Please include a Cover Letter 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
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Requirements Use the file we will provide to prepare
the 2004 submittal.
Check EIS 2000 (version 2.0)
Name for year 2004 data – 8 digit EI #.04d
xxxxxxxx.04d
Use the 2004 LDEQ Certification Statement.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Certification Statement Certifies only 2004 Criteria
Pollutant 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
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Side 1
NH3 and PM2.5 - required under LAC 33.III.919
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Side 2Active Air Permit Numbers
HRVOC Emissions for Specific Parishes
Emission Factor Changes
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
What’s New for Reporting Year 2004
Toluene & Xylene – new for HRVOC Reporting
Emergency Rule – difference in emission factors
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LAC 33:III.919 Revision
o Final Rule – December 20, 2003o Major revisions were made to the
rule primarily to clarify the language and to codify reporting requirements that were already policy.
o Rule now correlates with the Federal CERR (i.e. PM2.5 and NH3 reporting)
http://www.deq.louisiana.gov/planning/regs/addition/index.htm
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
HRVOC Reportingo 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
o Note: this list is NOT the same as the non-attainment and adjoining parish lists
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
HRVOC Reporting• The specific compounds that must be
added and their SAROAD codes are:1,3-butadiene 43218Butenes, isomers 43213Ethylene 43203
Propylene 43205Toluene 45202*Xylenes, isomers 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
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
PM10, PM2.5 & TSP All facilities must report particulate
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.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
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.
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
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
PM10, PM2.5 & TSP
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
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Ammonia
All facilities should report ammonia emissions in the electronic data file and on the Certification Statement, even if it is reported in the TEDI.
Ammonia reported in the EIS should match that reported in the TEDI.
SAROAD code = 42604
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
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 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
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
What you can do to improve data quality
Highlights from the Tips Sheet
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.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
What you can do to improve data quality
Record VOC emissions correctly.
Total VOC = Toxic + Non Toxic
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
VOC Reminder 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)
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
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 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.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
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 EIS.
Please be sure that the TEDI and EIS submittals correspond.
You can submit the TEDI with the EIS.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
EIS and TEDI
The emission point IDs (NEDS 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.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Optional Reporting
Greenhouse Gases SAROAD Codes:
• Carbon dioxide = 42102• Methane = 43201
Crosswalk of Permit Point ID to EI/TEDI NEDS Point ID
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Submitting the Data 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:
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Address all USPS Mail to:
LDEQ/OEA/AQAD – 6th FloorEmissions Inventory Unit
P. O. Box 4314Baton Rouge, LA 70821-
4314
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
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/
EIU – http://www.deq.louisiana.gov/evaluation/eis/index.htm