240 likes | 411 Views
SUBCHAPTER 21. EMISSION STATEMENTS Rule Revisions and Program Update. Contents. Objectives of the Rule Revisions CY2003 Reporting Requirements What’s New in RADIUS Ver. 2.9. Objectives of Rule Revisions . Update Original Rule Language
E N D
SUBCHAPTER 21 EMISSION STATEMENTS Rule Revisions and Program Update
Contents • Objectives of the Rule Revisions • CY2003 Reporting Requirements • What’s New in RADIUS Ver. 2.9
Objectives of Rule Revisions • Update Original Rule Language • Update Rule to reflect current NJDEP policy and procedures • Add PM2.5 and ammonia to applicability (100 tpy) • Require mandatory RADIUS electronic submittal • Incorporate new electronic submittal due date - May 15 • Add NAICS code field
Objectives of Rule Revisions • Incorporate Expanded Reporting Requirements • Ozone Season Reporting (tons/season) • PM 2.5 and Precursors (ammonia) • Greenhouse Gases (CO2 and methane) • 36 Toxic Air Pollutants (TAPs)
New Rule Proposal • Published in NJ Register - February 4, 2002 • Public hearing - March 8, 2002 • Public comment period ends March 9, 2002 • Final Rule signed - January 21, 2003 • Final Rule in NJ Register - February 18, 2003 • New Rule text available on NJDEP website http://www.nj.gov/dep/aqm/
CY 2003 Reporting Requirements • Must file electronically unless a “hardship waiver” is approved in advance • Facilities must use RADIUS Ver. 2.9 • Must Include NAICS and SIC code • www.census.gov/epcd/www/naics.html • Ozone seasonal amount reported for 5/1/03 - 9/30/03 in units of tons/season
CY 2003 Reporting Requirements • Minor (Non-Title V) facilities - same pollutants as before (CO, NOx, and VOC) • Major (Title V) facilities • PM2.5 and NH3 at source level, in addition to what was required before (CO, NOx, Pb, PM10, SO2, TSP, and VOC) • CO2, CH4, and 36 TAPs (if applicable) at facility-wide level
Ozone Season Reporting • Existing lb/day reporting for “peak ozone season” - (6/1 through 8/31) • Add tons per season reporting for “ozone season” - (5/1 through 9/30) • Required by USEPA Consolidated Emission Reporting Rule. • All ES sources must report ozone season data.
Toxic Air PollutantReporting • List of 36 Toxic Air Pollutants (TAPs) • Report facility-wide emissions • Major facilities starting with CY2003 data • Minor facilities starting with CY2005 data • Sub 8 reporting threshold applied to whole facility • E.g. if PTE is < Sub 8 lb/yr threshold - Don’t report.
Reporting Thresholds for TAPs • Report total emissions of a specific TAP if the facility’s PTE for that TAP is greater than the reporting (not SOTA) threshold contained in Table B of Appendix 1 of Subchapter 8.
Approach for 2003 Reporting • Use the “Save as Another Year” function to update your 2002 electronic submittal to use as the basis for the 2003 Emission Statement. • The created 2003 ES will include the new data fields (empty)
Important Dates • Non-Applicability Requests due February 1, 2004 • Hardship Request for paper submittal due March 1, 2004 • Paper submittals due April 15, 2004 (only with written approval of hardship) • RADIUS submittals due May 15, 2004
Emission Statement Web Page • Web Page: www.nj.gov/dep/baqp • Submittal Dates • Guidance Document and other forms • General Info • Listserv Instructions • Contact Information • FAQ’s (updated) • Useful links (USEPA, NAICS, etc.)
Contents of a “Notification of Non-Applicability” (7:27-21.9): • The NJDEP Facility ID Number • The plant contact and telephone number, • The name and telephone number of the Responsible Official, • The maximum contaminant emissions allowed under current air permits, • The maximum contaminants that can be emitted at design capacity for all unpermitted (grandfathered, insignificant) sources, • The maximum contaminants that can be emitted as fugitive emissions, and • If the facility has voluntarily applied for or obtained a Title V Operating Permit. • A statement as to future applicability of Subchapter 21
Emission Statement Contacts NJDEP - Office of Air Quality Management Bureau of Air Quality Planning P O 418 Trenton, NJ 08625-0418 EMIS_STATEMENT@dep.state.nj.us Helpline: (609) 984-5483 General: (609) 292-6722 Fax: (609) 984-6533
What’s New in RADIUS 2.9 • Ozone Season for 5/1/03 - 9/30/03 (tons/season) • Additional air contaminant names • “1000 tons/year” for CO2 • “lbs/year” for TAPs
“Rules” for RADIUS Reporting • Emission Statement should mirror permit(s). • Title V facilities have to use their BOP PI #. • Do not use the “Batch Print Details” button. • Treat Stack and Fugitive emissions separate • Control devices that burn fuel have to be reported as a piece of equipment.
“Rules” for RADIUS Reporting • Combustion sources can only be combined with other combustion sources burning the same fuel type. • Auto-Calculate does not calculate emission for the entire Ozone Season (5/1/03-9/30/03). • Submit function does not send the file to the Department.
“Rules” for RADIUS Reporting • Only NOx is required for the entire Ozone Season (5/1/03-9/30/03). • If you get an error during upgrade, contact the Department. DO NOT run the upgrade again. • Need to import Upgrade.000 before running Radius29.exe. • PM10 and PM2.5 includes both filterables and condensables.
Common Issues for Reasonableness Letters in 2002 ES • Use of proper AP42 emission factors, especially for combustion sources. • Not reporting PM10 when TSP is reported. • E, PT, or CD listed but missing from the EU/BP Inventory. • Emission factor units that are dissimilar with the process data units.
Common Issues for Reasonableness Letters in 2002 ES • Do not use SCC codes that begin with lettered prefixes. • Provide Source Details and Control Operations Details as required. • Report fuel usage on the process screen instead of production quantity. • Report operating time as total hours/year, total days/year and total weeks/year.
Common Issues for Reasonableness Letters in 2002 ES • Facilities properly designated as a "Major" or "Minor". • Correct Facility ID (APEDS vs PI). • Emission Statement must mirror permit(s). • Report any accidental spills, or emissions from malfunctions as fugitive emissions.