Annual Operation Report Workshop

January 13, 2009Tampa, Florida

Add pollutants: PM2.5, CPM, NH3, TBAC Expand summer season data requirements to

the entire state Lower hazardous air pollutant (HAP) reporting

thresholds Change HAP reporting frequency to every 3

years Include the emissions computation and

reporting requirements in Rule 62-210.370 Change due date for 2008 AOR to May 1, 2009 Add report contact

Ozone season reporting Hazardous air pollutant reporting Condensible emissions reporting Fugitive emissions reporting Emissions calculation hierarchy AOR submission due date

Applies statewide (new) Only for VOC or NOx emitting units Summer Season (June 1 – August 31) Average or typical work day (lbs/day) value

(only report VOC and NOx)

Threshold change (new) – 1000 lbs actual/SCC◦ Applies to all HAPs at major facilities (i.e., total

HAPs emissions >25 tpy PTE)◦ Applies to individual HAPs with emissions >10 tpy

PTE).◦ Reporting every 3 years; 2008, 2011, etc.

Any HAP for which a permit limit is imposed must be reported every year, even if below 1000 lbs

New requirement Threshold – 5 tpy, reported annually Reported only if information is available to

estimate emissions However, because data is limited, and questions

remain on the accuracy of test methods, for the 2008 reporting year only report if you are confident in the data, or if you have a permit limit.

In fact, if CPM is subject to a permit limit, it must be reported (even if below 5 tpy)

Do not list CPM as a pollutant if no data can be reported.

Must report if: ◦ Associated with a permitted emissions unit and SCC

for which all emissions are fugitive and are quantifiable (landfill, cooling pond, etc.)

◦ Associated with a permitted facility for which an “emissions unit” has been established by the permitting authority to represent facility-wide fugitive emissions (e.g., equipment leaks, maintenance painting)

◦ Associated with a controlled process using a collection system for which some emissions are not captured and for which the permitting authority has established a separate reporting emissions unit for this purpose.

Fugitive PM emissions from vehicular movement or wind erosion need not be reported unless required by permit.

MethodEmissions Method Code

1. CEMS2. Materials balance3. Emission factor- site specific (stack

test)4. Emission factor- directly applicable

from published source (e.g., AP-42)5. Emission factor- similar, but

different process from published source (e.g., AP-42)

6. Emissions factor- other

1. 1A2. 23. 3A

4. 3B

5. 4

6. 5

For 2008 AOR due to May 1, 2009 For 2009, and thereafter, due by April 1of

following year Issue: Title V permit specifies March 1 due

date, thus, if submitted after this date, would technically be out of compliance.

Resolution: Will resolve by guidance or Statement of Compliance form change.

Tom RogersFlorida DEP

(850) 921-9554tom.rogers@dep.state.fl.us