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Overview of Point Source Emissions Inventory Process. 2014 Environmental Trade Fair and Conference. Air Quality Division . Julia Segura May 6-7, 2014. Point Source Emissions Inventory (EI): Overview. 30 Texas Administrative Code (TAC) Section (§) 101.10 Applicability

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overview of point source emissions inventory process

Overview of Point Source Emissions Inventory Process

2014 Environmental Trade Fair and Conference

Air Quality Division

Julia Segura May 6-7, 2014

point source emissions inventory ei overview
Point Source Emissions Inventory (EI): Overview
  • 30 Texas Administrative Code (TAC) Section (§) 101.10
  • Applicability
  • Types of EIs
  • Submission responsibility
  • Reporting options
  • Reporting requirements
  • 2013 Guidance clarifications and reminders
  • 2013 EI publications
  • EI process/timeline overview
101 10
§101.10

§101.10 Organization

  • (a) applicability
  • (b) types of inventories
  • (c) calculations
  • (d) certifying statements
  • (e) reporting requirements
  • (f) enforcement
101 10 cont
§101.10 (cont.)

A few examples of industry types subject to EI reporting:

  • refineries;
  • chemical plants;
  • electric utility plants;
  • cement production; and
  • oil and gas production sites.
applicability do you need to submit an ei
ApplicabilityDo you need to submit an EI?
  • Major stationary source defined under 30 TAC §116.12, Nonattainment and Prevention of Significant Deterioration definitions
    • Rule defines potential to emit (PTE) thresholds for major sources.
    • Major source definition can change based on attainment status of county.
  • Need to know:
    • PTE and actual emissions thresholds for regulated pollutants
    • PTE and actual emissions thresholds for hazardous air pollutants (HAPs)
    • Site location and attainment status of county
applicability cont recent nonattainment designation
Applicability (cont.)Recent Nonattainment Designation
  • Effective July 20, 2012, Wise County was designated moderate ozone nonattainment.
    • Updated reporting requirements for actual emissions of volatile organic compounds (VOC) and nitrogen oxides (NOx).
    • 10 tons per year (tpy) actual VOC
    • 25 tpy actual NOx
  • Reporting requirements for PTE, HAPs, and other regulated pollutants remain the same.
    • 100 tpy PTE VOC or NOx
    • 100 tpy PTE or actual regulated pollutants
    • 10 tpy PTE or actual individual HAP
    • 25 tpy PTE or actual aggregate HAPs
applicability cont summary
Applicability (cont.) Summary
  • What is the attainment status of the county where my site is located?
  • What are my site’s actual emissions for regulated pollutants and HAPs (single and aggregate)?
  • What is my site’s PTE for regulated pollutants and HAPs (single and aggregate)?
applicability cont greenhouse gas ghg update
Applicability (cont.)Greenhouse Gas (GHG) Update
  • Implement House Bill 788 of the 83rd Legislative Session.
  • Rule changes to §101.10 and §101.27 were adopted.
  • Incorporate GHG as a pollutant under prevention of significant deterioration and New Source Review (NSR).
  • Stationary sources submit an EI if they are major for NSR.
  • Stationary sources are subject to emissions fees if they are major for Title V.
applicability cont ghg update cont
Applicability (cont.) GHG Update (cont.)
  • EI reporting changes under 30 TAC §101.10
    • Sources that become major due to GHG would report:
      • Criteria pollutants;
      • HAPs; and
      • Regulated pollutants.
    • GHG reporting is not required.
  • Emissions fees change under 30 TAC §101.27
    • No fee on GHG.
    • GHG excluded as a “regulated pollutant” for emissions fee assessment purposes.
    • New Title V sources (because of GHG) would pay on all other regulated pollutants.
types of point source inventories
Types of Point Source Inventories
  • Initial
  • Annual
    • full update
    • inapplicability notification
    • insignificant change
  • Special
    • ozone precursors
    • Lead (Pb)
types of point source inventories cont initial ei
Types of Point Source Inventories (cont.)Initial EI
  • Applies to a site that has never submitted an inventory
  • Data collected using standardized forms
  • 2013 Emissions Inventory Guidelines (RG-360/13)
    • Chapter 2: Creating an Initial EI
    • Chapter 5: Example Initial EI
    • Must be received by the Texas Commission on Environmental Quality (TCEQ) by March 31 of the calendar year immediately following the reporting year
types of point source inventories cont annual ei update
Types of Point Source Inventories(cont.)Annual EI Update
  • Annual update required each year reporting criteria are met
  • Updating an EI: Chapter 6, EI Guidelines
  • EI Checklist: page xiv, 2013 EI Guidelines
  • Due March 31 of the calendar year immediately following the reporting year unless otherwise notified in writing by the TCEQ
annual ei update cont inapplicability notification letter
Annual EI Update (cont.)Inapplicability Notification Letter
  • 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 instead of a full EI update is acceptable.
  • The sample letter provided in the 2013 EI Guidelines, Appendix B is recommended.
    • No option currently to submit through the Web
    • Similarly worded letter can be provided
  • Letter provides two options:
    • Remain on the mailing list; or
    • Removal from the mailing list.
annual ei update cont inapplicability notification letter cont
Annual EI Update (cont.)Inapplicability Notification Letter (cont.)

To be removed from the mailing list, the following are required:

  • Last emissions in the State of Texas Air Reporting System (STARS) database cannot exceed the applicability requirements.

Must submit a current updated EI and sample calculations before the site can be removed

  • May have to void the site’s Title V permit to demonstrate that the PTE levels are below reporting requirements

If EI reporting requirements are met at any time during the calendar year, an updated EI must be submitted.

Example: Title V permit was voided in June 2013; therefore, a 2013 EI must be submitted.

Sample Letter- Appendix B of 2013 EI Guidelines

annual ei update cont insignificant change notification letter
Annual EI Update (cont.) Insignificant Change Notification Letter

Can be submitted if changes in emissions for each pollutant do not exceed 5% or 5 tpy, whichever is greater

  • Changes can be either increases or decreases.
  • 2013 emissions compared to last reported emissions in the STARS database.
  • If an insignificant change 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.
  • Emissions from the previous reporting year are copied to current year.
  • Sample letter provided in 2013 EI Guidelines, Appendix B

Sample Letter- Appendix B of 2013 EI Guidelines

annual ei update cont insignificant change notification letter1
Annual EI Update (cont.) Insignificant Change Notification Letter

In addition to the Insignificant Change Notification Letter the following must be provided:

  • Account Information and EI Contact Information on page 2 of the EI;
  • Criteria Emissions Totals and Site Quantifiable Event Totals on page 3 of the EI;
  • Signed Legally Responsible Party on page 4 of the EI; and
  • Updates to emission events and/or scheduled maintenance, startup, and shutdown activities (EE/SMSS).
    • If site experienced no EE, then the EE certification statement on page 4 of the EI must be signed.
    • If site experienced EE, then provide EE updates on the applicable paths emissions pages of the EI.
types of emissions inventories cont 2013 special ei for sources that emit pb
Types of Emissions Inventories (cont.)2013 Special EI for Sources that Emit Pb
  • Applicable to all counties in Texas
  • Regulated entities that receive a written request from the TCEQ to submit an EI must respond.
  • Actual/PTE thresholds for Pbspecial EI:
    • Any regulated entity that emits ≥ 0.5 tpy of Pbemissions during normal operations; or
    • Any regulated entity that has the PTE 5 tpy or more of Pb emissions.
types of emissions inventories cont 2013 special inventory counties for ozone precursor emissions
Types of Emissions Inventories (cont.) 2013 Special Inventory Counties for Ozone Precursor Emissions
  • McLennan County was added to list of special EI counties for ozone precursors beginning with the 2012 reporting year.
  • Special inventory actual emissions reporting thresholds for ozone precursors are:
    • 10 tons per year of VOC; or
    • 25 tons per year of NOX.
  • Submit an EI if:
    • site meets special EI reporting thresholds; and
    • site is formally notified in writing by the TCEQ.
  • Respond to letter even if site does not meet reporting thresholds.
submission responsibility who is responsible for submitting the ei
Submission ResponsibilityWho is Responsible for Submitting the EI?
  • The owner or operator of the site at the time the inventory is due is responsible for submitting the EI.
  • Due date for sites that submitted an EI the previous year is March 31, 2014 unless otherwise directed in writing by the TCEQ.
  • Due date for sites that did not submit an EI the previous year but are applicable to reporting requirements is March 31, 2014.
reporting options
Reporting Options

Three options for submitting an EI

  • Paper
  • Electronic text file format submitted over the Web (delta file method)
  • Online Web-entry
reporting options cont
Reporting Options (cont.)

Option 1: The TCEQ still accepts paper submittals.

  • Printable EI reports are generated through the Central Registry’s Public Query tool.
  • Instructions for Obtaining a Printable Copy of the EI:

www.tceq.texas.gov/goto/eiqprint

  • Paper EIs are no longer mailed to regulated entities.
  • Standardized add forms can be used to add new equipment to an existing EI or to submit an initial EI.
  • Standardized forms are available at: www.tceq.texas.gov/goto/ieas.
reporting o ptions cont
Reporting Options (cont.)
    • Option 2: Submission of current electronic text file format over the Web
    • State of Texas Environmental Electronic Reporting System (STEERS) login/protections
    • Client feedback on format issues
    • Quicker data upload into the STARS database
  • Option 3: Data entry of EI information over the Web
    • Users load data to STEERS work area using Graphical User Interface windows
      • emissions
      • select process parameters
    • User can log in and out while maintaining a work-in-process in the work area
    • Users submit completed data when ready
reporting requirements what sources to include in the ei
Reporting RequirementsWhat 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;
  • emitted 1 tpy or more of any regulated pollutant; and
  • emitted 0.1 tpy or more of toxics or HAPs.
  • Mercury (Hg) and Pb exception: emitted 2 pounds (lbs) or more per year.
reporting requirements cont what sources to include in the ei
Reporting Requirements (cont.)What Sources to Include in the EI

May represent sources as collective sources if:

  • the sources are not listed 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.
  • Hg and Pb exception: emitted less than 2 lbs per year.
reporting requirements cont report any regulated air contaminant
Reporting Requirements (cont.)Report any Regulated Air Contaminant
  • Criteria pollutants: NOx, carbon monoxide, sulfur dioxide, 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 - total suspended particulates (TSP)
  • Once a site meets applicability, all regulated contaminants must be reported.
reporting requirements cont general hierarchy of determination methods
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
guidance clarifications and reminders determining emissions from amine units
Guidance Clarifications and RemindersDetermining Emissions from Amine Units

Remove acid gases, carbon dioxide (CO2) and hydrogen sulfide, from natural gas streams using an alkanolamine compound (typically)

  • Amine contacts the wet gas to remove acid gases, but also absorbs VOC and HAPs
  • Including benzene, toluene, ethylbenzene, xylene, and n-hexane
determining emissions from amine units cont
Determining Emissions from Amine Units (cont.)

Appendix A: regarding amine units in CO2 service:

  • Most preferred determination methods for amine units in CO2service vented to atmosphere:
    • current and accurate simulation methods; or
    • stack sampling should be used to determine emissions.
  • Least preferred determination methods for amine units in CO2service vented to atmosphere:

Recent research indicates that AMINECalc underestimates VOC emissions from amine units.

Clarification

calculating emissions from heated and hot product tanks
Calculating Emissions From Heated and Hot Product Tanks
  • Heated tank

Designed for and does store hot product above ambient temperature

  • Hot product tank

Unheated tank that receives hot product above ambient temperature

  • In either case, EPA TANKS 4.09D cannot accurately determine emissions.

Use AP-42, Chapter 7 to determine emissions

Reminder

determining ozone season emissions for storage tanks
Determining Ozone Season Emissions for Storage Tanks
  • Emissions during ozone season are higher due to elevated ambient temperatures resulting in higher vapor pressures.
  • EPA TANKS 4.09D cannot be used to determine ozone season emissions because it uses annual average liquid temperatures.
  • Use AP-42, Chapter 7 equations to determine emissions.
  • E&P TANK can be used to determine ozone season emissions for upstream oil and gas storage tanks.
sample calculation templates
Sample Calculation Templates

Common source types

  • glycol dehydration
  • internal combustion engines
  • marine vessel loading operations
  • railcar and truck loading operations
  • storage tanks

New

2013 ei publications
2013 EI Publications
  • EI guidelines book (RG-360/13) 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/ieas

Call TCEQ publications for your one free hard copy of the 2013 EI Guidelines: (512) 239-0028.

ei process timeline overview
EI Process/Timeline Overview
  • Calendar Year Data is Transmitted to EPA

** or as directed in writing by the TCEQ

questions
Questions?

Julia Segura

Julia.segura@tceq.texas.gov

512-239-2936

EI Helpline

  • Mon-Fri, 8am - 5pm
  • 512-239-1773

Point Source Emissions Inventory webpage:

http://www.tceq.texas.gov/airquality/point-source ei/psei.html