1 SUBCHAPTER 21 EMISSION STATEMENTS Rule Revisions and Program Update

2 Contents §Objectives of the Rule Revisions §CY2003 Reporting Requirements §Whats New in RADIUS Ver. 2.9

3 Objectives of Rule Revisions §Update Original Rule Language l Update Rule to reflect current NJDEP policy and procedures l Add PM 2.5 and ammonia to applicability (100 tpy) l Require mandatory RADIUS electronic submittal l Incorporate new electronic submittal due date - May 15 l Add NAICS code field

4 Objectives of Rule Revisions §Incorporate Expanded Reporting Requirements l Ozone Season Reporting (tons/season) l PM 2.5 and Precursors (ammonia) l Greenhouse Gases (CO 2 and methane) l 36 Toxic Air Pollutants (TAPs)

5 New Rule Proposal §Published in NJ Register - February 4, 2002 §Public hearing - March 8, 2002 §Public comment period ends March 9, 2002 §Final Rule signed - January 21, 2003 §Final Rule in NJ Register - February 18, 2003 §New Rule text available on NJDEP website

6 CY 2003 Reporting Requirements §Must file electronically unless a hardship waiver is approved in advance §Facilities must use RADIUS Ver. 2.9 §Must Include NAICS and SIC code l §Ozone seasonal amount reported for 5/1/03 - 9/30/03 in units of tons/season

7 CY 2003 Reporting Requirements Minor (Non-Title V) facilities - same pollutants as before (CO, NOx, and VOC) Major (Title V) facilities PM2.5 and NH3 at source level, in addition to what was required before (CO, NOx, Pb, PM10, SO2, TSP, and VOC) CO2, CH4, and 36 TAPs (if applicable) at facility-wide level

8 Ozone Season Reporting §Existing lb/day reporting for peak ozone season - (6/1 through 8/31) §Add tons per season reporting for ozone season - (5/1 through 9/30) §Required by USEPA Consolidated Emission Reporting Rule. §All ES sources must report ozone season data.

9 Toxic Air Pollutant Reporting §List of 36 Toxic Air Pollutants (TAPs) §Report facility-wide emissions §Major facilities starting with CY2003 data §Minor facilities starting with CY2005 data §Sub 8 reporting threshold applied to whole facility l E.g. if PTE is < Sub 8 lb/yr threshold - Dont report.

10 NJDEPs List of Toxic Air Pollutants

11 Reporting Thresholds for TAPs §Report total emissions of a specific TAP if the facilitys PTE for that TAP is greater than the reporting (not SOTA) threshold contained in Table B of Appendix 1 of Subchapter 8.

12 Approach for 2003 Reporting §Use the Save as Another Year function to update your 2002 electronic submittal to use as the basis for the 2003 Emission Statement. §The created 2003 ES will include the new data fields (empty)

13 Important Dates §Non-Applicability Requests due February 1, 2004 §Hardship Request for paper submittal due March 1, 2004 §Paper submittals due April 15, 2004 (only with written approval of hardship) §RADIUS submittals due May 15, 2004

14 Emission Statement Web Page §Web Page: l Submittal Dates l Guidance Document and other forms l General Info l Listserv Instructions l Contact Information l FAQs (updated) l Useful links (USEPA, NAICS, etc.)

15 Contents of a Notification of Non-Applicability (7: ): §The NJDEP Facility ID Number §The plant contact and telephone number, §The name and telephone number of the Responsible Official, §The maximum contaminant emissions allowed under current air permits, §The maximum contaminants that can be emitted at design capacity for all unpermitted ( grandfathered, insignificant ) sources, §The maximum contaminants that can be emitted as fugitive emissions, and §If the facility has voluntarily applied for or obtained a Title V Operating Permit. §A statement as to future applicability of Subchapter 21

16 Emission Statement Contacts NJDEP - Office of Air Quality Management Bureau of Air Quality Planning P O 418 Trenton, NJ Helpline: (609) General: (609) Fax: (609)

17 Whats New in RADIUS 2.9 §Ozone Season for 5/1/03 - 9/30/03 (tons/season) §Additional air contaminant names §1000 tons/year for CO2 §lbs/year for TAPs

18 Rules for RADIUS Reporting §Emission Statement should mirror permit(s). §Title V facilities have to use their BOP PI #. §Do not use the Batch Print Details button. §Treat Stack and Fugitive emissions separate §Control devices that burn fuel have to be reported as a piece of equipment.

19 Rules for RADIUS Reporting §Combustion sources can only be combined with other combustion sources burning the same fuel type. §Auto-Calculate does not calculate emission for the entire Ozone Season (5/1/03- 9/30/03). §Submit function does not send the file to the Department.

20 Rules for RADIUS Reporting §Only NOx is required for the entire Ozone Season (5/1/03-9/30/03). §If you get an error during upgrade, contact the Department. DO NOT run the upgrade again. §Need to import Upgrade.000 before running Radius29.exe. §PM10 and PM2.5 includes both filterables and condensables.

21 Common Issues for Reasonableness Letters in 2002 ES Use of proper AP42 emission factors, especially for combustion sources. Not reporting PM10 when TSP is reported. E, PT, or CD listed but missing from the EU/BP Inventory. Emission factor units that are dissimilar with the process data units.

22 Common Issues for Reasonableness Letters in 2002 ES Do not use SCC codes that begin with lettered prefixes. Provide Source Details and Control Operations Details as required. Report fuel usage on the process screen instead of production quantity. Report operating time as total hours/year, total days/year and total weeks/year.

23 Common Issues for Reasonableness Letters in 2002 ES Facilities properly designated as a "Major" or "Minor". Correct Facility ID (APEDS vs PI). Emission Statement must mirror permit(s). Report any accidental spills, or emissions from malfunctions as fugitive emissions.

24 Questions???