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Article # 0053
REPORTING OF AN AIR EMISSION EVENT IN THE STATE OF
A facility that
releases pollutants into the air in the state of
The specific definition for emissions event and reportable emissions event from Texas Administrative Code of Regulations is as follows:
Emissions event - Any upset event or unscheduled maintenance, startup, or shutdown activity, from a common cause that results in unauthorized emissions of air contaminants from one or more emissions points at a regulated entity.
Reportable emissions event - Any emissions event that in any 24-hour period, results in an unauthorized emission from any emissions point equal to or in excess of the reportable quantity as defined in this section.
manager at the site must use information collected by process and
staff that work in the field to assess the “event” to determine if it
evaluation as a potential “emissions event” and to quantify the
necessary to determine if the emissions exceeded a reportable quantity
for the specific contaminant (e.g., benzene) or mixture of contaminants
gasoline) released. Companies
to design their own communication and examination processes as long as
system in place will result in meeting the State regulatory
evaluating and reporting events. The
The type of information on a field level incident or emissions event form might include the following:
Additional information that might be included if known (if this information is not transmitted the manager would collect as part of his investigation and report):
The environmental manager would use the above information to quickly estimate the chemical species (e.g., benzene) and mass (in pounds) of air pollutant released to determine if the release was above reportable quantity (RQ) and thus requires reporting to the regulatory agency(s).
Determining if the Air Emission Release is a Reportable Quantity (RQ)
Once the release has been identified (specific chemical or chemical mixture) and the environmental professional has correctly estimated the mass of air emissions released, then it is necessary to determine if the release is above the chemical’s or chemical mixtures RQ to see if the release is a reportable emissions event and thus should be relayed to the environmental agency(s). If the mass of the release is less the RQ it still requires estimation and documentation. The amount of emissions should be also be included in the next Annual Emissions nventory along with normal operation emissions.
The determination of
whether the release is above its RQ may be the most complicated task
the definition of a chemical’s RQ is long and complicated by the fact
that it crosses
both federal and state (and possibly local) definitions. That is, some chemicals
may be “reportable”
under state regulations, but not reportable under federal regulations
versa. Also, the
magnitude of the RQ in
pounds may differ for the same chemical between the federal, state and
state regulatory agency
Procedure for Assessing and Reporting an Emissions Event in the State of Texas
Question: When do I need to use this guidance document?
Answer: Every time recordkeeping or other evidence indicates that your facility may have either:
1. Emitted pollutants for which you do not have authorization (via an air permit, for example)
2. Caused emissions exceeding authorized levels (emissions greater than emission rates shown in the Maximum Allowable Emission Rates Table of your permit, for example). Unscheduled break-downs in emission control equipment and spills are two examples of circumstances that may cause an emissions event.
Question - What am I required to do?
Answer – Follow this step-by-step procedure to determine any records or reports that you may need to create.
Step 1: Determine if the emissions event is reportable. This must be done within 24 hours of discovery of the event. If the event is reportable, the initial notification must also be filed within 24 hours.
Step 1.A: Estimate the quantity of emissions of each chemical involved in the event. If possible, use calculation techniques previously utilized for the same facility in permit applications, PBR applications or Emissions Inventory submittals. Common process knowledge, past engineering analysis or test results are good sources of data. If the release is of a mixture of chemicals and the relative amount of each chemical cannot be determined, use the total amount of the mixture as the amount of emissions for each chemical.
Step 1.B: Determine the reporting threshold for each chemical emitted. The threshold for a chemical is the lowest one that appears in the three following lists. If the chemical does not appear on any of these lists, the threshold quantity is 100 lb.
Chemical RQ (lbs)
butanes (any isomer) 5,000
butenes (any isomer,
except 1,3-butadiene) 5,000(1)
carbon monoxide 5,000
decanes (any isomer) 5,000
hexanes (any isomer) 5,000
Isopropyl alcohol 5,000
mineral spirits 5,000
nitrogen dioxide 100(3)
nitrogen oxide 100(2)
octanes (any isomer) 5,000
pentanes (any isomer) 5,000
Notes to above table:
(1) The RQ in the Houston/Galveston (HGA) and Beaumont/Port Arthur (BPA) ozone nonattainment areas is 100 lbs.
(2) Use instead of the RQ provided in 40 CFR §302, Table 302.4, the column "final RQ"
(3) Used instead of the RQ listed in 40 CFR §302, Table 302.4, the column "final RQ" or listed in 40 CFR §355, Appendix A, the column "Reportable Quantity";
Step 2: Do emissions of any chemical from the emissions event equal or exceed the lowest of the thresholds?
Yes. The emissions event is reportable. Go to Step 3.
No. The emissions event is not reportable but you must create the required records. Go to Step 4.
Step 3: You must file the Notification for Reportable Emissions Events within 24 hours. You can create your own reporting form that includes the information required to report under 30 TAC 101 or check the agency website for a reporting form template. E-mail or fax the completed form to the appropriate Texas Commission of Environmental Quality (TCEQ) regional office. If there are any other local air pollution control agencies in your city or county, you must also send a copy to that office. Note that the TCEQ now requires use of their on-line STEERS system for submitting reportable emission event reports. An e-mail or fax is considered an alternative to STEERS. Go to Step 4.
Step 4: Create a Final Record of the Emissions Event. The final record must be created within two weeks of the emissions event and the record must be kept on site for at least five years. If you have a reportable event and the information on the Final Record is different than that submitted in the 24-hour notification, then you should submit a revised Notification for Reportable Emissions Events Form to the TCEQ regional office and any applicable local air pollution control agency.
L. Bullard, P.E. is an Engineering Partner of Bullard
Environmental Consulting, Inc. He has over 20 years experience in
engineering, compliance, and permitting. Jack has a Bachelors of
in Chemical Engineering from the
Jack L. Bullard, P.E. No. 83547
Final Edition Completed December 2010
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