Considerations for Emissions Inventory Reporting in Louisiana

Facilities emitting criteria pollutants and toxic air pollutants (TAP) in Louisiana may be required by the Louisiana Department of Environmental Quality (LDEQ) to submit an annual emissions inventory (EI) using the Department’s web-based Emissions Reporting and Inventory Center (ERIC). The EI data submitted through ERIC is used by LDEQ for a variety of planning, regulatory, and reporting purposes. In addition to the electronic ERIC report, facilities are required to submit a certification statement signed by the responsible official. Emissions inventory submissions in ERIC and the signed certification are due by April 30 each year. This article highlights some things to consider while preparing your annual EI in ERIC to ensure a smooth submittal process.

Verify and Update Facility Information

Most report information can be revised within the template spreadsheet that will be uploaded to ERIC. However, there are some facility details that must be revised prior to submitting the report. These include:

• EI facility contact
• EI billing party
• Facility mailing address or phone number
• Front gate coordinates
• Ownership dates
• North American Industry Classification System (NAICS) or Standard Industrial Classification (SIC) code

Facilities can request revision to these parameters by completing the Facility Update Request Form on the LDEQ website. These updates are passed through to the ERIC platform. This year, LDEQ has indicated that these requests must be submitted before 4:00 PM on Friday April 28, 2023 or they will not be processed prior to the deadline. This information needs to be updated and correct for a complete submission.

Review Emissions Factors

LDEQ requires facilities update emissions factors each year as revised factors are published, even if those factor changes have not been used as part of recent permitting (LAC 33.III.919.G). Facilities should review factors published in AP-42 or by a trade association each year to ensure that emissions are reported correctly in the EI. It is possible that a factor change may result in reported emissions greater than permitted limits; however, LDEQ has indicated that emissions above permitted limits as a result of emissions factor changes alone are not considered a violation (LAC 33.III.501.C.12). Also make sure to apply emissions factors changes to your Toxic Release Inventory (TRI) air emissions to be consistent with what is reported in the EI.

Report the Correct Chemicals in the Correct Format

Emissions inventories in Louisiana cover criteria air pollutants as well as TAP. If an emissions source emits less than 0.005 tons of a pollutant in a year, the pollutant does not need to be reported. For chemicals that require reporting, LDEQ provides guidance for the number of significant figures that must be reported for criteria pollutants and TAP based on the maximum emissions rate and the chemical being reported. Data from facility emissions tracking workbooks may need to be manipulated to satisfy these standards when preparing a bulk upload spreadsheet for ERIC.

Prepare Certification and Potential Notifications

Although the ERIC report is submitted electronically, the certification statement still requires a wet signature. Be sure to coordinate with your facility’s responsible official because both the certification statement and the electronic submission must be completed by April 30 to be considered an on-time submittal. In addition, if there have been changes to emissions factors or estimation methods since the issuance of your Title V Operating Permit which result in a significant change in emissions, a notification should be included as part of the Title V Annual certification per LAC 33:III.501.C.13. You may also consider a permit modification to incorporate any newly published factors.

ALL4 has experience using ERIC and preparing permit applications in Louisiana. If you have questions or need help preparing your facility’s ERIC submittal or follow up permitting, please reach out to your ALL4 project manager or contact info@all4inc.com.