Tennessee’s Move to Online Emissions Inventory Submittal

The Tennessee Division of Air Pollution Control (APC) Emissions Inventory Team has recently finalized the switch to an internet-based system for air emissions inventory reporting, referred to as the State/Local Emissions Inventory System (SLEIS). Starting with the 2019 emissions inventory report, due June 1, 2020, the reporting process will be done within the new online system. Note that electric generating units, as defined in subpart (9)(d)2(i) of Rule 1200-03-26- .02, do not have their emissions inventory reports due until July 1. SLEIS has been under development by APC for some time, with a pilot project occurring in the Fall of 2018 for select facilities. The pilot process is now complete, and APC has decided to move forward with implementing the SLEIS to all facilities who are required to submit annual emissions inventory reports in Tennessee. The previous way of filling out the Microsoft Excel-based form, also known as the Emissions Database Layout (EDL), and submitting via email to APC will no longer be accepted for the 2019 emissions inventories.

An initial step for facilities that are required to submit an air emissions inventory is the requirement to register their facility and users (e.g., company and consultants) in the SLEIS, preparing the air emissions inventory. In order to register your facility, you must fill out the facility registration form located on APC’s emissions inventory reporting website. There are also instructions on the same page that provide more detail about each section and what information to include for facility personnel as well as registering consultants to assist in the completion of the air emissions inventory. Once the registration form has been completed, the next step is to get the hardcopy notarized by a Notary Public, and then mail the physical copy to the APC at the address provided on the registration form. Your facility must complete and mail the registration form no later than December 31, 2019. APC will be hosting WebEx meetings during the start of 2020 to train facilities on how to access and work with SLEIS.

If you have any questions about SLEIS, feel free to reach out to me at 678.460.0324 x202 or aniketas@all4inc.com.

PADEP’s CSMM Rev. 8 Frequently Asked Questions Document Updated! (Part 2)

The Pennsylvania Department of Environmental Protection’s (PADEP’s or Department’s) Continuous Emissions Monitoring (CEM) Section within the Division of Air Quality released an updated Frequently Asked Questions (FAQs) document to support Continuous Source Monitoring Manual Revision No. 8 (CSMM Rev. 8) on October 8, 2019. The updated document provides a reference point for certain gray areas within CSMM Rev. 8 and continuous monitoring in the Commonwealth of Pennsylvania. This article is the second in our series that detail PADEP’s most recent responses to questions related to CSMM Rev. 8, which discusses PADEP’s response to the question “How is a 3-hour average, rolling by one hour calculated?” If you’re curious about what PADEP has to say about the application of diluent caps, our first article in this series, PADEP’s CSMM Rev. 8 Frequently Asked Questions Document Updated! covers that topic.

Let’s get to it – what does PADEP have to say about 3-hour rolling averages? The Department states that a 3-hour rolling average is considered valid if it contains at least two valid hourly averages. Now you may be wondering what constitutes a valid hourly average. Well, except for opacity, temperature, and carbon monoxide (CO) data, an hourly average is determined to be valid if there is at least one valid data reading obtained in each 15-minute quadrant of the clock hour during which the process is operating. For hours in which preventative maintenance or quality assurance activities took place, a valid hourly average can be calculated if there are at least two valid readings in the hour separated by a minimum of 15 minutes. For opacity, temperature, and CO, a valid hourly average can be calculated if the hour contains at least 75% of the segments of the hour corresponding to the minimum required cycle time (for measurement) during which the process was operating. PADEP provides an example of this validation on page 27 of their FAQs document.

Now that we’re clear on what constitutes an hourly average, let’s get back to how to calculate a 3-hour rolling average. A 3-hour rolling average can be calculated if it contains at least two valid hourly averages. Additionally, process down hours, invalid hours, and exempt hours are excluded from the 3-hour average calculation. Note that hours for which data substitution has been utilized will not be included in the 3-hour average when determining compliance with a 3-hour rolling average emission standard. The table below provides examples of how the Department calculates the 3-hour rolling average, under common operating scenarios.

Hour Operating Status Concentration Calculated Value
00 Starting-up

Exempt

6 PPM None.  No data available from hour 22 or 23 from previous day.  Do not include hour 00.
01 Starting-up

Exempt

5 PPM None.  No data from hour 23 from previous day.  Don’t include hour 00 and 01.
02 Process on

Normal Operation

3 PPM None.  Only have 1 hour for consideration (hour 02).
03 Process on

Normal Operation

3 PPM 3 PPM.  Average of hour 02 and 03, do not include hour 01.
04 Invalid (blank) 3 PPM.  Average of hour 02 and 03, do not include hour 04.
05 Process on

Normal Operation

3 PPM 3 PPM. Average of hour 03 and 05, do not include hour 04.
06 Shutting down

Exempt

5 PPM None.  Only have 1 hour for consideration (hour 05).
07 Process Down (blank) None.  Only have 1 hour for consideration (hour 05).
08 Starting-up

Exempt

6 PPM None.  No data for consideration.
09 Process on

Normal Operation

3 PPM None.  Only have 1 hour for consideration (hour 09).
10 Process on

Normal Operation

3 PPM 3 PPM.  Average of hour 09 and 10, do not include hour 08.
11 Process on

Normal Operation

3 PPM 3 PPM.  Average of hour 09, 10, and 11.

As the table above details, PADEP uses a clock hour methodology when calculating 3-hour averages.  This is done in PADEP’s Continuous Emission Monitoring Data Processing System (CEMDPS) using hourly emissions data collected by the CEMS and submitted by the facility.   If you have any questions about calculating averages, or any other general CMS questions, please reach out to me at (610) 933-5246 x116, or at kfritz@all4inc.com.  Lastly, don’t forget to keep an eye out for our next article that goes over PADEP’s response to questions around Phase II testing during the operational test period.

How Does the Texas Mass Emission Cap and Trade (MECT) Program Affect Houston?

This is the second blog in a series where I will discuss Texas Emissions Banking and Trading (EBT) programs specifically in the Houston-Galveston-Brazoria (HGB) region. In this edition, I will explain the purpose and requirements of the mandatory Mass Emissions Cap and Trade (MECT) program. The MECT program is a market-based cap and trade program whose requirements began on January 1, 2000.

The MECT program implements an annual nitrogen oxide (NOX) emissions cap for major sources and for minor sources which have an uncontrolled design capacity to emit 10 tons per year (tpy) or more of NOX in the HGB region. The purpose of the MECT program is to help the HGB region reach the National Ambient Air Quality Standards (NAAQS) for ozone. The Texas Commission on Environmental Quality (TCEQ) limits NOX emissions by allocating NOX allowances to each facility based on their emissions history and by multiplying by an emission factor. On September 23, 2019, the HGB region was designated as Serious Nonattainment status for the 2008 ozone standard. Because of this designation change, any facility that emits greater than 50 tpy (previously the limit was 100 tpy) of the ozone precursor pollutants, Volatile Organic Compounds (VOC) or NOX, are now considered major sources and are affected by the MECT program.

Affected facilities must report their NOX emissions electronically through the State of Texas Environmental Electronic Reporting System (STEERS) no later than March 31st following the most recent control period. Control periods run from January 1st to December 31st of each year, allowing facilities a few months to submit their NOX emissions report. Facilities may use NOX emission reductions generated under the Texas Emissions Reduction Plan (TERP) in lieu of allowance by following the regulations at 30 Texas Administrative Code (TAC) §101.357. If the reported value is above the facility’s NOX allowances, the deficit plus a 10% penalty on the deficit value will be applied to the next control period. For example, if a facility has 100 tons of NOX allowances for a reporting period in which they report 110 tons of NOX emissions, the facility will have a penalty of 11 tons of NOX applied to their account in the following control period.

Whenever a facility recognizes they have a deficit (i.e., when emissions are higher than allowances), the facility must purchase additional allowances to cover the remaining balance. For facilities that have surplus allowances, they may either trade them to another facility or emissions broker, or they may be banked as vintage allowances for use in the next control period. Facilities may use these surplus allowances for strategic growth in the following control period or sell them to other facilities that have an allowance deficit.

It is critical to the growth and operation of facilities in the HGB region to use their MECT allowances strategically to their fullest potential. These strategies range from saving excess allowances for future growth projects, to selling surplus allowances for a profit, evaluating the installation of air pollution control/implementing emissions reduction measures to avoid the need to purchase as many allowances.

Stay tuned for an upcoming edition of ALL4’s 4 The Record where I will discuss more in depth about the Highly Reactive Volatile Organic Compound Emissions Cap and Trade (HECT) program, which affects major sources in the HGB region. If you missed the first blog in this series, Did you know there are 5 emissions trading programs in Texas?!, which gives a broad overlook of the different EBT programs in the HGB region. If you have any questions regarding this blog, please reach out to me at thenson@all4inc.com or 281-937-7553 x308.

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