1. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 1 Point Source Emissions Inventories Air Quality DivisionSusan Wampler May 5-6, 2015 2015 Environmental Trade Fair and Conference

2. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 2 Point Source Emissions Inventory (EI) Overview  30 Texas Administrative Code (TAC) Section (§) 101.10  Applicability: Does the site need to submit an EI?  Types of EIs  Reporting responsibility  Reporting options  Reporting requirements  2014 Guidance clarifications and reminders  2014 EI publications  EI process/timeline overview  Trends and Data

3. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 3 30 TAC §101.10  (a) applicability  (b) types of inventories  (c) calculations  (d) certifying statements  (e) reporting requirements  (f) enforcement

4. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 4  Major stationary source defined under 30 TAC §116.12 (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.  Need to know: – PTE and actual emissions thresholds for regulated pollutants – PTE and actual emissions thresholds for hazardous air pollutants (HAP) – Site location and attainment status and classification of the county Applicability Does the site need to submit an EI?

5. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 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 (GHGs)

6. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 6 Applicability (cont.) Does the site need to submit an EI?  Any site that emits or has the PTE HAPs 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 2014 special inventories will be discussed under “types of EIs”

7. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 7 Applicability (cont.) Summary of Reporting Requirements in Tons per Year (tpy) for 30 TAC §101.10 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 1025 100 10 25 Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, SERIOUS/OZONE 10502550100 10 25 Wise MODERATE/OZONE 1010025100 10 25 All Other Counties 100 10 25

8. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 8 Applicability (cont.) Summary 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)?

9. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 9  In March 2014, Texas Commission on Environmental Quality (TCEQ) adopted rulemaking to implement House Bill 788 of the 83 rd Legislative Session.  On June 23, 2014, the Supreme Court of the United States issued an opinion in Utility Air Regulatory Group v. Environmental Protection Agency (EPA) et al. that affects GHG permitting. GHG Update

10. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 10  Sites cannot be classified as major sources solely due to GHG emissions levels.  GHG emissions are NOT required to be reported in the EI. There are no changes to EI reporting requirements.  There are no changes to emissions fee assessments. GHG Update (cont.)

11. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 11 Austin Fun Fact #1  Author O. Henry lived in Austin from 1884 – 1895 before moving to Houston to write full time for the Houston Post.  His most well known writing is the Christmas short story called “The Gift of the Magi.”  His house is located at 409 East 5 th street, one block north of the convention center. The house currently serves as the O. Henry Museum.  The O. Henry Pun-Off is a spoken word competition held every May to celebrate word play in the form of puns.

12. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 12 Types of EIs  Initial  Annual – full update – insignificant change  Special – ozone precursors – Lead (Pb)

13. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 13 Types of EIs (cont.) Initial EI  Applies to a site that has never submitted an inventory  Must be received by the TCEQ by March 31 of the calendar year immediately following the reporting year  Can submit using the Web-EI system

14. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 14 Types of EIs (cont.) Annual EI Update  Annual update required each year reporting criteria are met – Updating an EI: Chapter 6, EI Guidelines – EI Checklist: page xiv, 2014 EI Guidelines  Due March 31 of the calendar year immediately following the reporting year, unless otherwise notified in writing by the TCEQ.

15. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 15 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 2014 emissions compared to the most recently submitted EI entered into the STARS 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 2014 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.

16. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 16 Types of EIs (cont.) Insignificant Change Notification Letter (cont.) 20102011201220132014 2% increase > Emissions total 2% increase > Emissions total 2% increase > Emissions total 2% increase > Emissions total Rollover? Yes Rollover? NoRollover? Yes 2010 emissions entered in STARS 2010 emissions copied to 2011 2010 emissions copied to 2012 6% increase from 2010 emissions in STARS so 2013 totals must be entered 2013 emissions copied to 2014 Example of how a rollover request submitted several years in a row is evaluated:

17. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 17 Types of EIs (cont.) Insignificant Change Notification Letter (cont.) In addition to the Insignificant Change Notification Letter, the following must be provided: – Account and EI contact information; – Criteria emissions totals and site quantifiable event totals; – Signature of legally responsible party; – Updates to emission events and/or scheduled maintenance, startup, and shutdown activities (EE/SMSS). If site experienced no EE, then the EE certification statement must be signed. If site experienced EE, then provide EE updates on the applicable paths emissions pages of the EI.

18. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 18 Types of EIs (cont.) Special EI: Pb  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.  Actual/PTE emissions thresholds for 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

19. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 19 Types of EIs(cont.) Special EI: Ozone Precursors  Special Inventory requirement only applies to 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.  Actual emissions reporting thresholds for ozone precursors are: – 10 tpy of VOC; or – 25 tpy of NO X, during normal operations; and – Located in one of the counties on the next slide

20. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 20 BastropBexarCaldwellComalEl Paso GreggGuadalupeHardinHarrisonHays HendersonHoodJeffersonMcLennanNueces OrangeRuskSan PatricioSmithTravis UpshurVictoriaWilliamsonWilson Special Inventory Counties County CLASSIFICATION/ POLLUTANT VOCNO x Other Individual HAP Aggregated HAP ActualPotentialActualPotentialActualPotentialActualPotentialActualPotential SPECIAL INVENTORY REPORTING THRESHOLDS FOR OZONE PRECURSORS 10 100 25 100 100 100 10 10 25 25

21. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 21 Moderate Serious Severe Special for ozone precursors

22. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 22 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 §101.10 or special inventory requirements, a certifying letter is acceptable in place of a full EI update.  The sample letter provided in the 2014 EI Guidelines, Appendix B, is recommended. – No option currently to submit through the Web – A similarly worded letter can be provided

23. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 23 Austin Fun Fact #2  Congress Avenue Bridge is home to the largest urban bat population in the US from March through November.  Each spring, mostly female, pregnant Mexican free-tailed bats migrate from central Mexico.  Approximately 1.5 million bats live under the bridge and eat 10,000 to 20,000 pounds of insects each night.

24. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 24 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.  The due date for sites that reported an EI the previous year is March 31 unless otherwise directed in writing by the TCEQ.  The due date for sites that did not report an EI the previous year but are applicable to reporting requirements is March 31.

25. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 25 Reporting Options  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  Paper Beginning with the 2015 reporting cycle (due March 31, 2016), paper EIs will no longer be accepted.

26. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 26 Reporting Options (cont.) Web-EI  Web entry method: analogous to updating paper – Users enter data to State of Texas Environmental Electronic Reporting System work area using Graphical User Interface windows – User can log in and out while maintaining a “work-in-process” in the work area – Users submit completed data when ready – Called manual entry, web entry or EIQ method  Electronic file upload/submission −Now fully integrated into Web-based system −Called text file upload or delta file method

27. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 27 Reporting Requirements What 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; or – emitted 1 tpy or more of any regulated pollutant; or – emitted 0.1 tpy or more of toxics or HAPs; or – emitted 2 pounds (lbs) or more per year of Mercury (Hg) and/or Pb.

28. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 28 Reporting Requirements (cont.) What Sources to Include in the EI May represent sources as collective sources if the sources: – are not listed individually 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.

29. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 29 Reporting Requirements (cont.) Report any Regulated Air Contaminant  Criteria pollutants: NO x, carbon monoxide, sulfur dioxide (SO 2 ), VOC, Pb, PM 10, PM 2.5 – PM 10 : particulate matter 10 microns in diameter and less – PM 2.5 : 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 – particulate matter (PM)  Once a site meets applicability, all regulated contaminants must be reported.

30. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 30 Reporting Requirements (cont.) Summary of Speciation Criteria CountiesWhat to speciateWhen to speciate All counties Pb, HgPath level emissions ≥ 0.001 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 HRVOCPath 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

31. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 31 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

32. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 32 Guidance Clarifications and Reminders (cont.) EI Guidance Updates  Chapters 1 and 2 – Guidance for sites that are permitted but not built – Guidance on submitting confidential information electronically  Chapter 4 Changed the denominator in the equation to determine ozone season pounds per day (ppd) emissions rates from ‘Operation Days’ to simply ‘153 days’ to obtain the ppd emission rate for the entire ozone season.  Appendix A, Technical Supplement 4: "Flares" The EPA is potentially updating certain AP-42, Chapter 13.5 emissions factors for flares; do not use the proposed flare factors for EI purposes.

33. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 33 Guidance Clarifications and Reminders (cont.) EI Guidance Updates (cont.) Technical Supplement 6: Aboveground Liquid Storage Tanks – Clarified data required for determining emissions using chemical mixtures – Streamlined guidance on produced water tanks, heated tanks, and tanks receiving hot products – New guidance for potential breathing losses from heated, insulated tanks – Clarified data required for tanks storing heavy fuel oils and related products – New guidance for the ozone season emissions calculations using the American Petroleum Institute's Exploration and Production Tank program and how to adjust emissions accordingly

34. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 34 Sample Calculation Templates  Common source types – glycol dehydration – internal combustion engines – marine vessel loading operations – railcar and truck loading operations – storage tanks  Sample calculation templates are located on the Point Source Emissions Inventory Web page: http://www.tceq.texas.gov/airquality/point- source-ei/psei.htmlhttp://www.tceq.texas.gov/airquality/point- source-ei/psei.html.. for common sources are available on the Point

35. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 35 2014 EI Guidance Documents  EI guidelines book (RG-360/14) 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 2014 EI Guidelines: (512) 239-0028.

36. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 36 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

37. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 37 Trends and Data Air Quality Division March 2015

38. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 38 Trends and Data (cont.) Air Quality Division March 2015

39. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 39 Trends and Data (cont.) Air Quality Division March 2015

40. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 40 Trends and Data (cont.)

41. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 41 Trends and Data (cont.)

42. Air Quality Division Emissions Inventories, SAW: May 5-6, 2015 Page 42 Questions?  Susan Wampler −Susan.wampler@tceq.texas.gov −512-239-1463  EI Helpline −Mon-Fri, 8am - 5pm −512-239-1773  Point Source Emissions Inventory webpage : www.tceq.texas.gov/goto/ieas