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Texas SIP Emission Inventory Revisions for Sites in Bexar County

Posted: June 13th, 2019

Authors: Frank D. 

In case you have not been following, the U.S. Environmental Protection Agency (U.S. EPA) designated Bexar County (San Antonio area) as nonattainment for the 2015 eight-hour ozone National Ambient Air Quality Standard (NAAQS). This designation was effective on September 24, 2018. Sources located in nonattainment areas must have SIP emissions in order to generate and create emission reduction credits (ERC). SIP emissions represent the actual emissions from a given facility in a designated nonattainment area during the state implementation plan (SIP) emissions year. SIP emissions cannot exceed applicable state, local, or federal requirements. Therefore, the Texas Commission on Environmental Quality (TCEQ) is preparing an emission inventory (EI) state implementation plan (SIP) revision for three ozone nonattainment areas, including Bexar County. The SIP emissions year for Bexar County will be 2017. Because Bexar County has been newly designated as nonattainment, TCEQ is allowing facilities in Bexar County to review reported 2017 emissions data and to submit valid revisions to their 2017 calendar year EIs. Revisions to the 2017 EIs are required to be submitted to TCEQ no later than July 31, 2019 and must be certified and submitted via hardcopy paper forms. Once TCEQ approves the received information, the EI SIP revision will be adopted for emissions credit generation.

Why is This Important?

The air quality permitting implications for major stationary sources of the ozone precursors nitrogen oxides (NOX) and volatile organic compounds (VOC) located in ozone nonattainment areas can be daunting. Under certain circumstances, ERCs are required as emissions offsets to facilitate facility changes that are major modifications under the TCEQ nonattainment new source review (NNSR) regulations. ERCs can be generated by over-controlling actual emissions or by reducing actual emissions though shutdown or limitations on operations and emissions. ERCs must be surplus, permanent, quantifiable, and federally enforceable. ERCs can be sold to other facilities located within the same nonattainment area if not needed at the facility where they originated. Because ERCs are based on reported emissions, it is important that emissions reported by facilities be as accurate as possible.

Things to Keep In Mind

The request from TCEQ only applies to valid revisions for the 2017 emissions year and does not represent an opportunity for amnesty for emissions inventories that may have been required at the time but were not submitted. The sites that would have submitted EIs for the 2017 emissions would have either been a major source or would have been notified by a TCEQ special inventory request. As mentioned above, the revised EIs are required to be submitted hardcopy and are NOT to be submitted through the State of Texas Environmental Electronic Reporting System (STEERS). Documentation, such as sample calculations, appropriate signatures, etc. are also required. If revisions contain confidential information, the site is responsible for designating that information as such.

What is Next?

This is an opportunity for facilities in Bexar County to double check and revise, as appropriate, reported emissions for 2017. Reported 2017 emissions could be the basis to generate valuable ERCs. It is therefore important that a site review its 2017 EI to confirm its accuracy, especially if emissions were inadvertently under reported. If a 2017 EI revision is submitted, the site must also be aware of other reports or documents that may be impacted as a result of the revisions. For example, the air emissions fees would differ and may also need to be revisited. Because TCEQ has allowed this opportunity to reexamine 2017 EI data, it is certainly worth-while for facilities in Bexar County to take another look at their previously submitted data before the deadline.

Need Help?

If you need assistance reviewing or submitting revisions to your 2017 EI, feel free to reach out to me, Frank Dougherty at fdougherty@all4inc.com, 281-937-7553 x302.

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