Data Collection & Evaluation Seminar Toxic Air Pollutants (TEDI) Criteria Air Pollutants (EI)

1. Data Collection & Evaluation SeminarToxic Air Pollutants (TEDI)Criteria Air Pollutants (EI)

2. Air Quality Assessment Division Organizational Chart

3. 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 Contacts

4. Address all postal mail to: Department of Environmental Quality Office of Environmental Assessment/Air Quality Assessment Division Data Collection & Evaluation Group PO Box 4314 Baton Rouge, LA 70821-4314

5. Address all delivery mail to: Department of Environmental Quality Office of Environmental Assessment/Air Quality Assessment Division Data Collection & Evaluation Group 602 N. 5th Street Baton Rouge, LA 70802

6. 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.

7. 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)

8. 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

9. 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

10. 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

11. 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).

12. 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.

13. 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.

14. 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

15. 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….

16. Questions&Comments

17. 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)

18. 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

19. 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.

20. 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.

21. 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

22. 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)

23. Discharge Report • Identity of the source • Date and time of the discharge • Approximate total loss during the discharge

24. 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

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

26. 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

27. 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

28. Questions&Answers

29. 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 Rouge • Iberville • Livingston • W. Baton Rouge Ozone Adjoining Parishes: Assumption St. Martin E. Feliciana Tangipahoa Iberia W. Feliciana Pointe Coupee St. Helena St. James St. John the Baptist

30. 2005 EI Reporting Criteria ReviewStill in Effect for 2005! • 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)

31. 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)

32. 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)

33. 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)

34. 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

35. 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.

36. What is Reportable to EI

37. Requirements for 2005 EI • An originalCertification 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

38. 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)

39. 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 #.05d xxxxxxxx.05d • Use the 2005 LDEQ Certification Statement.

40. 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

41. 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.

42. 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

43. 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.

44. 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.

45. 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. Charles E. Baton Rouge St. Helena E. Feliciana St. James Iberville St. John the Baptist Livingston W. Baton Rouge Pointe 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.

46. HRVOC Reporting • The specific compounds that must be added and their SAROAD codes are: Butenes, isomers 43213 Ethylene 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

47. 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.

48. 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)

49. 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. VOC Reminders

50. What you can do to improve data quality Record VOC emissions correctly. Total VOC = Toxic + Non Toxic