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SUBCHAPTER 21

EMISSION STATEMENTS

Rule 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.html

Ozone 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 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

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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 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.

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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???