1. Control of Emissions of Sulfur Dioxide – LAC 33:III.Chapter 15 Dustin Duhon Air Permits Division Louisiana Department of Environmental Quality March 23, 2007

2. Purpose for Revision More clearly defines monitoring, recordkeeping, and reporting requirements Establishes new criteria by which a source may be determined to be exempt Clearly defines when initial and additional compliance tests should be performed

3. Applicability Sulfuric acid plants Sulfur recovery plants Each single point source that emits or has the potential to emit ≥ 5 tons per year of SO 2 – SO 2 emissions < 5 tons per year → LAC 33:III.Chapter 15 does not apply

4. If the source is subject to Chapter 15, what limitations apply? For sources other than sulfuric acid plants and sulfur recovery plants – SO 2 emissions ≤ 2,000 parts per million by volume (ppmv) – If SO 2 emissions < 250 tons per year, LDEQ may exempt source from 2,000 ppmv limit This provision exists in both the current and the proposed regulation.

5. When must a Continuous Emissions Monitoring System (CEMS) be installed? Per §1511.A of the proposed rule, CEMS is required if “ … subject to the sulfur dioxide emission limitations of this Chapter …”. – Current rule says “… subject to the provisions of this Chapter …”. – Source can apply for alternative to CEMS

6. When must a CEMS not be installed? Per §1511.D of the proposed rule, LDEQ shall not require CEMS for – Flares – Sources with potential to emit of < 100 tons per year – Sources identified in 40 CFR 51, App. P – Sources subject to 40 CFR 75 First three items are present in current rule

7. If the SO2 emission limitation doesn’t apply, what is required to show compliance? Per §1513.C of the proposed rule, source not subject to emission limitations shall: – “…record and retain at the site sufficient data to show annual potential sulfur dioxide emissions from the emissions unit.” – That’s it. Per §1513.A of the current and proposed rule, this data shall be recorded and retained at the site for at least two (2) years.

8. Summary LAC 33:III.Chapter 15 does not apply to sources at sugar mills that emit or have the potential to emit < 5 tons per year [LAC 33:III.1502.A.3] Sources at sugar mills that emit ≥ 5 tons per year but < 250 tons per year may be exempted from 2,000 ppmv limit. Sources at sugar mills that are exempted from 2,000 ppmv limit must maintain calculations to show potential annual SO 2 emissions.

9. Summary (cont.) Sources at sugar mills that are not exempted from the 2,000 ppmv and emit greater than 100 tons per year of SO 2 require an SO 2 CEMS or must apply for alternative compliance. – Due to the characteristically low levels of sulfur associated with natural gas and bagasse, a source with this level of emissions is extremely unlikely. The pending revisions to LAC 33:III.Chapter 15 do not impact in any way the sources which require an SO 2 CEMS.