SUBCHAPTER 21
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Transcript of SUBCHAPTER 21
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SUBCHAPTER 21
EMISSION STATEMENTSRule Revisions and Program Update
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Contents
Objectives of the Rule RevisionsCY2003 Reporting RequirementsWhat’s New in RADIUS Ver. 2.9
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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
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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)
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New Rule Proposal
Published in NJ Register - February 4, 2002 Public hearing - March 8, 2002Public comment period ends March 9, 2002Final Rule signed - January 21, 2003Final Rule in NJ Register - February 18, 2003New Rule text available on NJDEP website
http://www.nj.gov/dep/aqm/
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CY 2003 Reporting Requirements
Must file electronically unless a “hardship waiver” is approved in advance
Facilities must use RADIUS Ver. 2.9Must Include NAICS and SIC code
www.census.gov/epcd/www/naics.htmlOzone seasonal amount reported for 5/1/03 -
9/30/03 in units of tons/season
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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
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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.
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Toxic Air Pollutant Reporting
List of 36 Toxic Air Pollutants (TAPs) Report facility-wide emissionsMajor facilities starting with CY2003 dataMinor facilities starting with CY2005 dataSub 8 reporting threshold applied to whole facility
E.g. if PTE is < Sub 8 lb/yr threshold - Don’t report.
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NJDEP’s List of Toxic Air PollutantsChemical Sub. 17 NATA HAP
1 Acetaldehyde X X2 Acrolein X X3 Acrylonitrile X X4 Arsenic and compounds X X5 Benzene X X X6 Beryllium and compounds X X7 1,3-Butadiene X X8 Cadmium and compounds X X9 Carbon tetrachloride X X X
10 Chloroform X X X11 Chromium and compounds X X12 1,3-Dichloropropene X X13 1,4-Dioxane X X14 Dioxins X X15 Ethylene dibromide X X X16 Ethylene dichloride X X X17 Ethyleneimine X X18 Ethylene oxide X X192021
FormaldehydeHexachlorobenzeneHydrazine
XXX
XXX
22 Hydrochloric acid X23 Manganese and compounds X X24 Mercury and compounds X X25 Methylene chloride X X X26 Nickel and compounds X X27 Polychlorinated biphenyls (PCBs) X X28 Polycyclic organic matter X X29 Propylene dichloride X X30 Quinoline X X31 1,1,2,2-Tetrachloroethane X X X32 Tetrachloroethylene X X X33 1,1,1-Trichloroethane X X34 1,1,2-Trichloroethane X X35 Trichloroethylene X X X36 Vinyl chloride X X
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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.
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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)
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Important Dates
Non-Applicability Requests due February 1, 2004Hardship Request for paper submittal due March
1, 2004Paper submittals due April 15, 2004 (only with
written approval of hardship)RADIUS submittals due May 15, 2004
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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.)
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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
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Emission Statement Contacts
NJDEP - Office of Air Quality ManagementBureau of Air Quality Planning
P O 418Trenton, NJ 08625-0418
Helpline: (609) 984-5483General: (609) 292-6722
Fax: (609) 984-6533
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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
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“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 separateControl devices that burn fuel have to be
reported as a piece of equipment.
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“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.
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“Rules” for RADIUS ReportingOnly 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.
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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.
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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.
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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.
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Questions???