TCEQ’s Emissions Inventory Updates – January 2018

While Houston Rodeo season is almost upon us, the Texas Commission on Environmental Quality (TCEQ) reporting season is now in full swing.  As such, ALL4 is once again preparing for the April 2, 2018 annual emissions inventory (AEI) reporting deadline by attending the January 24, 2018 TCEQ Emissions Inventory (EI) Workshop held in Austin, TX.  No, that’s not a typo: this year’s EI submission deadline is in April because March 31st falls on a Saturday this year.  If this is news to you, or if you would like to learn more about how ALL4 continues to stay informed on updates that TCEQ shares at its training sessions, please read on.

At this year’s event, ALL4 focused on strengthening our relationships with the TCEQ trainers, EI Technical Specialists, and Air Quality Team Leads by meeting with them after each session to ask a few clarifying questions and to re-introduce ourselves from years past.  If you were unable to attend this year, don’t worry: 1) the session agenda can be found on TCEQ’s website and 2) ALL4 has also distilled some important information from the sessions as summarized below:

• Hardcopy submissions of AEIs are no longer accepted unless special permission is given; however, inapplicability EI letters can be submitted via hard copy.
• Responsible Officials (ROs) and Duly Authorized Representatives (DARs) are required to sign and certify a Facility’s EI through the State of Texas Environmental Electronic Reporting System (STEERS).  Make sure these Facility contacts have a STEERS account with proper access well before the EI due date.
• The TCEQ 2017 Emissions Inventory Guidelines found here document (updated January 2018) is now available and includes a few new clarifications and additions.  The changes this year primarily include administrative updates and technical supplement additions.  For example, the EI reporting requirements map has been moved from the PDF onto a web platform and a coal-fired boiler section has been added to the Technical Supplement Appendix.
• Bell County was added to the ozone precursors counties list in 2016.  Applicable facilities in ozone precursor counties may be subject to a special emissions inventories request from TCEQ.
• One facility identification number (FIN) can have multiple emission point numbers (EPNs).
• TCEQ compares EI data with other historically submitted information to determine consistency.
• Ozone season emissions must be provided on a pounds per day (ppd) basis and those calculations must use a denominator of 153 days.
• TCEQ defines the nitrogen oxides (NO_X) molecular weight as 46.01 lb/lb-mole.
• TCEQ does not allow Facilities to utilize a permit limit as a source of an emissions factor.
• TCEQ strongly discourages using U.S. EPA’s TANKS 4.09d software for quantifying storage tanks fugitive emissions.  AP-42, Chapter 7 equations are preferred.

This list of watchouts covers a lot of ground, but there are always more questions to consider.  If you find yourself having trouble answering some of the questions below, you may want to consider calling ALL4 to help assist you in your EI or Air Emissions Fees:

• Do the filterable and condensable portions of particulate matter (PM) need to be reported separately in the EI?
• What is the best software program to view and edit my Facility’s extract file?
• Do emissions events that occurred during Hurricane Harvey need to be included in this year’s EI?
• What is TCEQ’s guidance if a county is split by the 100° longitude line?
• If a Facility is idle, do the Air Emissions Fees or Inspection Fees apply to that Facility?
• For continuous emissions monitoring systems (CEMS), how does TCEQ expect emissions to be accounted for during monitor downtime events?
• Does TCEQ expect opacity excess emissions events to be reported on a mass basis?  If so, what is TCEQ’s preferred method of doing so?
• If a Facility has components exempt from equipment leak fugitive emissions monitoring requirements, are emissions from those components included in the EI?
• What is TCEQ’s preference on representing permitted maintenance, startup and shutdown (MSS) emissions within the EI structure?

Alternatively, if the person who typically completes your Facility’s EI retired last year, you are performing your Facility’s EI for the first time in the state of Texas, or you were unable to attend this year’s TCEQ training session, ALL4 has you covered.  Feel free to reach out to Kristin Gordon at kgordon@all4inc.com, 281-937-7553×301 or me, Frank Dougherty at fdougherty@all4inc.com, 281-937-7553×302 if you have any additional questions or require support in completing your EI.