CAERS Update for Georgia: HAP Emissions Reporting

The United States Environmental Protection Agency (U.S. EPA) and Georgia Environmental Protection Division (GEPD) hosted a “HAPs Reporting in CAERS Training” webinar on Tuesday, April 20^th to provide Georgia facilities the opportunity to learn more about reporting hazardous air pollutant (HAP) emissions in the Combined Air Emissions Reporting System (CAERS).  ALL4 attended the training and is here to fill you in on what you may have missed!

First and foremost, facilities are NOT required to report HAP emissions for calendar year (CY) 2020 annual emissions inventories, with the exception of lead (Pb).  However, reporting of HAP emissions is strongly encouraged for a few reasons:

1. Georgia is currently one of few states that does not require some type of HAP emissions reporting as part of their annual emissions inventory reporting requirements.  GEPD is asking facilities to voluntarily report their HAP emissions data so that they don’t have to make this a mandatory requirement in the near future.
2. By reporting HAP emissions in CAERS, users can take full advantage of the platform’s comprehensive reporting abilities.  When users report HAP emissions in CAERS, the user can not only use CAERS data quality check features from year to year, but can also import the CAERS HAP emissions directly into Sections 5.1 and 5.2 (Fugitive or Non-Point Source Emissions and Stack or Point Source Emissions, respectively) of the Toxic Release Inventory (TRI) Form R’s via TRI-MEweb.  As a result, users can complete an automated data validation check via CAERS and do not have to double-enter HAP emissions data into both systems, which is one of the main goals of the CAERS platform.
3. Without the presence of accurate and recent HAP emissions data from annual emissions inventories, GEPD must use HAP augmentation software to evaluate the state’s HAP emissions profile.  The HAP augmentation software may not be an accurate representation of your facility’s HAP emissions profile in both type of HAPs and quantity of emissions.  In addition, the facility and/or state’s emissions profile can be used in GEPD’s rulemaking process to determine the emissions limits that need to be established.  Inaccurate data during the rulemaking process may result in overly burdensome emissions standards or work practice standards for facilities.

While reporting of HAPs is a facility-to-facility decision unless otherwise required, it may make sense for facilities to report a subset of their HAP emissions.  One consideration for the subset of reported HAP emissions could be any HAP that is also reported in a facility’s annual TRI Form R’s.  Reporting a subset of emissions would allow Georgia to have accurate emissions profiles for your facility’s significant HAP and also allow users to utilize the expanded reporting capabilities of CAERS.  However, the decision to report HAP should be on a facility-specific case-by-case basis.  ALL4 recommends that each facility have the appropriate conversations prior to reporting any HAP emissions in CAERS.

As for how to report HAP emissions in CAERS, the process is similar to other regulated pollutants within the CAERS platform.  Therefore, adding the HAP emissions data into your annual emissions inventory is a simple process to follow.  Users can open an individual emissions unit process, select to add more reportable pollutants, and then use the search box to select a pollutant using the Chemical Abstracts Service (CAS) number or pollutant name.  Depending on how your facility quantifies emissions of the HAP, you can choose the best calculation method for your facility such as, an emissions factor from AP-42, a site-specific or other trade group emissions factor, site-specific stack test data, or continuous monitoring system data.

If you have any questions about reporting HAP emissions in CAERS (or even any type of emissions reporting within CAERS), please reach out to Stacy Arner at sarner@all4inc.com or Andrew Kelley at akelley@all4inc.com with any questions you may have!  In addition, GEPD will be hosting multiple live, virtual help sessions for reporting in CAERS for anyone that is interested or needs additional assistance.