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

2. Air Quality Assessment Division Organizational Chart

3. Contacts 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

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. 5 th 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 Quality P.O. Box 4303 Baton Rouge, LA 70821-4303 Fax: (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 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 Errors to 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/na ics.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: AssumptionSt. Martin E. FelicianaTangipahoa IberiaW. Feliciana Pointe Coupee St. Helena St. James St. John the Baptist

30. 2005 EI Reporting Criteria Review Still 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 Review Emits 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 Criteria PollutantSAROAD Ammonia (NH3)42604 Carbon Monoxide (CO)42101 Lead (Pb)12128 Nitrogen Oxides (NOx)42602 Particulate Matter 10 (PM10) 81102 Particulate Matter 2.5 (PM2.5) 81104 Sulfur Dioxide (SO2)42401 Total Volatile Organic Compounds (VOC) 43104 HRVOCs Pollutants: SAROAD Butenes, isomers 43218 Ethylene43203 Propylene43205

37. Requirements for 2005 EI An original Certification 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 EI Reporting 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 Factors LAC 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: AscensionSt. Charles E. Baton RougeSt. Helena E. FelicianaSt. James IbervilleSt. John the Baptist LivingstonW. Baton Rouge Pointe CoupeeW. 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, isomers43213 Ethylene43203 Propylene43205 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. VOC Reminders 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.

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

51. Complete Data Complete all sections of the Certification Statement, including toxic VOC and pollutants for which there are zero emissions. First time reporters & adding new points: Submit complete card decks in the electronic file. Cards 01, 02, 03, 04, 11, 12, 13, 14, 21, 22 & 23 are required. Format the cards completely and correctly. Please see the Coding Manual and Forms, Submittal Tips and Expanded Examples.

52. Data accuracy is vital! What you can do to improve data quality Do not delete NEDS points (No 11Ds). If we see card 11D, we will delete the entire card from the data file and the delete will not take place. 19084010699990536501 11D

53. Data accuracy is vital! What you can do to improve data quality When a NEDS point is no longer operating, do not delete the NEDS (Card 11D): –zero the throughput - Card 11 cols. 52-64 = 2525252500052 –zero all of the emissions - Card 13 cols. 26-62 –change the estimation code to 7 - Card 13 col. 64 –insert appropriate comment on Card 30 192880106999905365010011311 708732311 2525252500052 11C 19288010699990536501003000405000000500000010000 12C 1928801069999053650143104 00000000000000 7 13C 19288010699990536501O 001 500 HP NATURAL GAS-FIRED COMP ENG 14C 192880106999905365013100020300 0000000 00000F 21C 1928801069999053650131000203002C500 HP COMPRESSOR ENGINE 22C 192880106999905365013100020300F 43104 23C 1928801069999053650100001LCOMP DID NOT OPERATE IN 1997 30A 1928801069999053650100001RCOMP WAS REMOVED IN FEBRUARY 1997 30A 1928801069999053650100002LCOMP IN POINT 25 REPLACED THIS ONE. 30A

54. Data accuracy is vital! What you can do to improve data quality Card 11 Throughput – If the point did not operate at all for the year, fill columns 52-64 with 2525252500052. Card 11 Throughput – The sum of the weighted percent should be no more than 100%. The coding manual says 95-105% is acceptable, however, when we convert the data to NIF for submittal to EPA, any thing greater than 100% is invalid. 19156010699990536512 1311 787032746 252525250005200000000 11C 19156010699990536512 1311 787032746 252525252475200000000 11C

55. Data accuracy is vital! What you can do to improve data quality Card 11 Operating Rates – Hours < 24, days < 7, and weeks < 52. When multiplying, the total should be no more than 8736. Example:If the point operates 60 hours a year: Incorrect: 19156010699990536512 1311 787032746 252525250116000000000 11C 60 weeks a year is not a valid entry. A Correct Option: 19156010699990536512 1311 787032746 252525251010600000000 11C

56. Data accuracy is vital! What you can do to improve data quality Double check your facility UTM coordinates, Physical and Mailing Addresses and Contact information. If facility is in zone 16, but are using horizontal coordinates for zone 15, make sure the zone on card 01 is 15. Make sure coordinates are valid for LA. Do NOT use 214.9 as the horizontal coordinate for anything, including compressor shutdowns. If a NEDS point is not a point source, i.e., fugitives, then a center point can be used for the coordinates. 19156010699990536516 1311 214932556 252525250005200000000 11C

57. Data accuracy is vital! What you can do to improve data quality Do not use an estimation code of 3 in column 64 of card 13. Some commercially designed EIS software programs use 3 in column 64. Change the 3 to a valid code such as 5. Incorrect: 1928801069999053650142602 00000000000000 3 13C Correct: 1928801069999053650142602 00000000000000 5 13C

58. Data accuracy is vital! What you can do to improve data quality If you have 16 pollutants and want to add additional pollutants, you must delete the unwanted pollutants in RY 2005, and then add the additional pollutants in RY 2006. The system will not allow card 13D and 13A in the same reporting year when all 16 pollutants have been used. Advice: Do not report more than what is required. However, methane (43201) and carbon dioxide (42102) are always welcome. If you speciate total VOCs (43104) in the data file by individual pollutant, those speciated emissions should still be included in the total VOC emissions (43104). It is not necessary to report your TEDI chemicals in your EI.

59. Data accuracy is vital! What you can do to improve data quality Check your SCCs and SICs to make sure they are correct, not just valid. Point source SCC – Be sure you are using an SCC for point sources, not area sources. SIC 0000 on card 11 is not acceptable: Card 23 – Columns for pollutant codes must not be zero-filled - If a program is used that automatically adds zeros to columns 49-53, delete them before submitting the file. 190200106999905365010000000 686833059 001724242473400000000 11C 190200106999905365013060010400F 42101 00000 23C

60. Changing SCC Codes – Use 21D and 21A. Do NOT use 21C, 22C, 23C, 24C, and 25C to change SCC. Check the sequence numbers. 190840106999905365AA2020160100 21D 190840106999905365AA2020020100 F 21A 190840106999905365AA2020020100 NATURAL GAS TURBINE 22A 190840106999905365AA2020020100F 43104 23A Data accuracy is vital! What you can do to improve data quality

61. Deleting SCC Codes – Use 21D and remove cards 22, 23, 24, and 25 completely. Do NOT use a 22D, 23D, 24D, and 25D. Incorrect: 190840106999905365AA3100020300 21D 190840106999905365AA3100020300 22D 190840106999905365AA3100020300 23D 190840106999905365AA3100020300 24D 190840106999905365AA3100020300 25D Correct: 190840106999905365AA3100020300 21D

62. What you can do to improve data quality If your facility is an Air Toxics facility, in general, you should report to both TEDI and EI. Please be sure that the TEDI and EI submittals correspond. You can submit the TEDI CS and data file with the EI. Action Codes – Use capital letters. Data files with too many errors will be sent back for corrections Crosswalk of Permit Point ID to EI/TEDI NEDS Point IDs

63. Reminders 2005 inventory - due on March 31, 2006 Save updated file with extension.05d Change of ownerships: Multiple CS’s acceptable Only one electronic data file Electronic data can be mailed or e-mailed to EI-TEDI-TRI@la.govEI-TEDI-TRI@la.gov. Certification Statements (an original and duplicate) with original signature must be mailed or delivered to the department. Run all files through Check EIS before sending them.

64. Resources EPA Chief - offers a variety of software and other resources useful in calculating the inventory www.epa.gov/ttn/chief/index.html LDEQ – http://www.deq.louisiana.gov/portal/tabid/36/Default.aspx Emissions Inventory – http://www.deq.louisiana.gov/portal/tabid/109/Default.aspx Valid Source Classification Codes (SCC): http://www.epa.gov/ttn/chief/codes/

65. QUESTIONS & ANSWERS