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TCEQ Reporting Season is Almost Upon Us: Are You Ready to Prepare your Facility Emissions Inventory?

Posted: December 12th, 2016

Authors: Frank D. 

As the 2016 calendar year winds down to a close, it’s time to start thinking about and planning for the submission of your facility’s Emissions Inventory (EI) to the Texas Commission on Environmental Quality (TCEQ).  As you may be aware, an EI submission is due on March 31 of the calendar year immediately after the reporting year.  This EI blog, forecasted in my November 8, 2016 blog, will highlight general information about an EI, new additions to EI reporting over the past year, and other information that may be helpful when preparing your EI. 

What is an Emissions Inventory?  Let’s Review the Basics

Before we dive into the details of an EI, let’s first review the basics.  Federal and state law requires the State of Texas to develop annual EIs to meet state implementation plan (SIP) requirements.  To create a state-wide EI, TCEQ requires facilities that satisfy the criteria outlined in 30 TAC §101.10(a) to submit an EI that consists of actual emissions of volatile organic compounds (VOC), nitrogen oxides (NOX), carbon monoxide (CO), sulfur dioxide (SO2), lead (Pb), particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM10), particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM2.5), emissions of all hazardous air pollutant (HAPs), or other contaminant requested by TCEQ.

Using the collected facility EIs, TCEQ is able to then gather state-wide emissions data to supply information to the United States Environmental Protection Agency (U.S. EPA), to plan pollution control programs, and to analyze emissions trends, to name a few.  In order to facilitate the collection of this emissions data, TCEQ has developed the State of Texas Environmental Electronic Reporting System (STEERS) Air Emissions Inventory Reporting (AEIR) with two reporting options: the Web-EI system with the Emission Inventory Questionnaire (EIQ) and the text file upload system.  Facilities that meet the requirements of 30 TAC §101.10(a) are required to submit their emissions data using the STEERS online platform.  For first time submissions of any criteria pollutant or HAP that have not been identified in a previous inventory, an initial emissions inventory (IEI) is required.  If a facility has previously submitted an EI and that facility continues to meet the requirements of 30 TAC §101.109(a), an annual emissions inventory update (AEIU) is required.  Just remember, beginning with the 2015 reporting year, the online STEERS-AEIR is the required reporting method for all EIs.  Caution: In case you have not heard, paper copies are no longer accepted by TCEQ.  Another important topic to keep in mind this reporting season is to make sure your facility demonstrates consistency across all platforms of reporting.  For example, make sure your toxic release inventory (TRI) emissions matches what you are reporting to TCEQ on your EI.  If your TRI emissions do not match what you reported to the state, you can expect a call from your regulator.

Getting Started for Your Online Submission

If you are new to submitting an EI online, the following steps must be taken to ensure that TCEQ receives the required information by March 31.

  1. Set up a STEERS account and select your appropriate reference number (RN).
    1. Before starting an IEI, contact the State of Texas Air Reporting System (STARS) to make sure necessary data for EI processing is complete.  This can be done by calling the EI Helpline for assistance at (512) 239 – 1773.
  2. Assign a person with a “signature authority” that will be the responsible official for the STEERS submissions.
  3. Select the data entry method that you will be using (i.e., EIQ entry, or file upload).
  4. Attach supporting documentation to your STEERS submission.
  5. Submit data from STEERS.

What is TCEQ Looking for in a Complete EI?

Before data is to be submitted in STEERS, be sure to understand what information TCEQ is looking for to determine a complete EI.  The items below identify the information TCEQ is expecting:

  1. A complete and updated EI.
  2. A signed certification statement.
  3. Sample calculations representative of current processes.
    • Be sure to include calculations that show determination of actual annual emissions.
    • Provide enough data so that the determinations can be reproduced.
    • Do not just include generic sample calculations.
  4. If stack test data is being used to quantify emissions, provide a summary of the test results.
  5. If a continuous emissions monitoring system (CEMS) is being used to determine emissions, provide a summary of the most recent relative accuracy test audit (RATA).
  6. Material throughput forms; and
  7. Fugitive data forms (if applicable).

Remember, confidential information is not to be submitted through STEERS; rather confidential information is to be submitted in hard copy, or submitted on a burned CD or DVD.

What has Changed Since Last Year?

Effective July 28, 2016, specific clarifications and changes were made to 30 TAC §101.10.  Some changes include the shortening of the applicable distance for off shore facilities, and the change of the EI reporting threshold for Pb to align with the U.S. EPA Annual Emissions Reporting Rule.  Another change includes the addition of a requirement for a facility that is obliged to submit an EI and that has had no emissions events during the reporting period.  These facilities are now required to include a certifying statement that describes the fact that no emissions events have taken place during the reporting period.  A more detailed summary of the changes can be found here.  Be sure to scan over the changes to ensure they do not impact the submission of your EI.  

Extra, Extra: TCEQ is Holding an EI Workshop in Late January

Save the date: on Wednesday, January 25, 2017, TCEQ will be hosting its annual EI Workshop in Austin, TX.  Registration for the event can be found here.  During this workshop, TCEQ will focus on providing a step-by-step tutorial on submitting an EI using the EIQ entry method and providing guidance on the Web-EI file uploading process (e.g., file specifications, troubleshooting, etc.).  ALL4 plans to be in attendance so please be on the lookout for one of our smiling faces if you happen to join this workshop.

Does the upcoming March 31, 2017 EI reporting deadline have you feeling stressed?  Don’t fret. ALL4 has been staying well-informed on EIs and is available to assist in any EI-related matter you may have.  From the preparation of a facility EI, to providing technical review/quality assurance (QA) on an EI, from administratively updating an EI, to submitting an EI through STEERS, ALL4 has you covered.  Feel free to reach out to me at fdougherty@all4inc.com if you have any additional questions or require support in completing your EI.


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