Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 1 Point Source Emissions Inventories Air Quality Division Susan Wampler May 3, Environmental Trade Fair and Conference

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 2 Point Source Emissions Inventory (EI) Overview  30 Texas Administrative Code (TAC) Section (§)  Applicability: Does the site need to submit an EI?  Types of EIs  Aspects of Reporting – responsibility – options – requirements  EI resources  EI process/timeline overview  Trends and Data

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 3 30 TAC §  (a) applicability  (b) types of inventories  (c) calculations  (d) certifying statements  (e) reporting requirements  (f) enforcement

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 4 Major stationary source defined under 30 TAC § (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. Applicability Does the site need to submit an EI?

Air Quality Division Emissions Inventories SAW: May 3, 2016 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 (NO x ); 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 (GHG)

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 6 Applicability (cont.) Does the site need to submit an EI?  Any site that emits or has the PTE Hazardous Air Pollutants (HAP) 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 2015 special inventories will be discussed under “types of EIs.”

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 7 Applicability (cont.) Summary of Reporting Requirements in Tons per Year (tpy) for 30 TAC § 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 (NO x ) Other Individual HAPs Aggregate HAPs ActualPTEActualPTEActualPTEActualPTEActualPTE Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, Waller SEVERE/OZONE Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, SERIOUS/OZONE Wise MODERATE/OZONE All Other Counties

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 8 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)? Applicability (cont.) Summary

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 9 Types of EIs  Initial  Annual – full update – insignificant change – inapplicability notifications  Special – ozone precursors – Lead (Pb)

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 10 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 2015 emissions compared to the most recently submitted EI entered into the 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 2015 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 3, 2016 Page 11 Types of EIs (cont.) Special EIs  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.  Lead (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 3, 2016 Page 12 Types of EIs (cont.) Special EIs  Ozone Precursors Special EI applies to a regulated entity that emits: – 10 tpy of VOC or – 25 tpy of NOx – located in one of these 24 counties:

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 13 Moderate Serious Severe Special for ozone precursors

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 14 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 § or special inventory requirements, a certifying letter is acceptable in place of a full EI update.  The sample letter provided in the 2015 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 3, 2016 Page 15 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.  March 31 due date – For sites that reported an EI the previous year, unless otherwise directed in writing by the TCEQ – For sites that did not report an EI the previous year but are applicable to reporting requirements

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 16 Reporting Options  Web reporting is required starting with the 2015 reporting year  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

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 17 Reporting Requirements  Which sources to include – Individual – Collective – Details listed on page 24 of the 2015 EI Guidelines  Which contaminants to report – Criteria pollutants – HAPs, Toxics – Regulated air contaminants subject to rules, regulations, permits, order of the commission, or court orders (except for contaminants that are regulated only because they are classified as a green house gas) – Once a site meets applicability, all regulated contaminants must be reported.  Determination Methods

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 18 Reporting Requirements (cont.) Summary of Speciation Criteria CountiesWhat to speciateWhen to speciate All counties Pb, HgPath level emissions ≥ tpy HAPs and ToxicsPath level emissions ≥ 0.1 tpy TSP, PM 10 Speciate particulate classes Known constituents should be speciated Chemical MixturesWhen constituents are known Nonattainment counties Highly Reactive Volatile Organic Compounds (HRVOC) Path level emissions ≥ 0.1 tpy East of 100º longitude; and El Paso Total VOC90% speciation required when path level emissions ≥ 5 tpy West of 100º longitude Total VOC90% speciation required when path level emissions ≥ 25 tpy

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 19 Sample Calculation Templates  Common source types – glycol dehydration – internal combustion engines – marine vessel loading operations – railcar and truck loading operations – storage tanks  The templates are located on the Point Source Emissions Inventory Web page: source-ei/psei.htmlhttp:// source-ei/psei.html.. for common sources are available on the Point

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 20 EI Guidance Documents  EI guidelines book 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: Call TCEQ publications for your one free hard copy of the EI Guidelines: (512)

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 21 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 3, 2016 Page 22 Trends and Data (cont.)

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 23 Trends and Data Air Quality Division February 2016

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 24 Trends and Data (cont.)

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 25 Trends and Data (cont.) Air Quality Division February 2016

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 26 Contact Information  Susan Wampler −  EI Helpline −Mon-Fri, 8am - 5pm −  Point Source Emissions Inventory webpage :

Air Quality Division Emissions Inventories SAW: May 3, 2016 Page 27 Questions