inventory needs and legal requirements martin johnson emission inventory workshop air resources...

Inventory Needs and Legal Requirements

Martin Johnson

Emission Inventory WorkshopAir Resources Board

March 13, 2006

Air Resources Board

Emission Inventory Workshop Spring 2006

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Presentation Outline

Who Uses the Inventory? How is the Inventory Used? Agency Responsibilities Legal Requirements Reporting Guidelines and

Requirements ARB Audit Program

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Inventory Users

Local air districts ARB and other state agencies USEPA Industry Consultants Academics Environmental Groups Public

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Inventory Applications

Emission Trend Studies State Implementation Plans (SIPs) Control Measure Development Regional Air Quality Modeling Neighborhood Level Studies (EJ)

Cumulative Risk Analyses Public Information Requests

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Upcoming Inventory Priorities

8-Hour Ozone SIPs – Districts with Nonattainment Designation Preliminary modeling inventories completed Dec-2005 Completing planning projections now SIPs due to EPA June 2007

PM2.5 SIPs - SC, SJV Preliminary modeling inventories completed Dec-2005 Completing planning projections now A few external adjustments anticipated SIPs due to EPA April 2008

Regional Haze SIPs Western Regional Air Partnership (WRAP) Draft 2018 Milestone Projections completed Nov 2005 2064 attainment SIPs due to EPA Dec 2007

Statewide Risk Modeling - all districts Fall 2006 (Tentative)

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Agency Responsibilities for Inventory Development

Local Air Districts Point sources Some areawide source categories

ARB On-road vehicles (EMFAC) Off-road and other mobile (OFFROAD) Some areawide source categories

■ Transition Categories■ Statewide methodology for Ships for Goods

Movement Areawide source categories by agency available at:

www.arb.ca.gov/ei/areasrc/lstareasrccats903.pdf

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Legal Requirements

State Health and Safety Code California Clean Air Act AB 2588 “Hot Spots” Act ARB Environmental Justice Policies Federal Clean Air Act Amendments Federal Consolidated Emissions Reporting

Rule (CERR) Air Emissions Reporting Requirements

(AERR)

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State Health and Safety Code

ARB has responsibility for development of State Implementation Plans (Section 39602)

ARB must inventory all sources of air pollution and use local agency data to fullest extent possible (Section 39607(b))

Districts have power to require facility operators to provide emission inventory data (Section 40701(g))

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California Clean Air Act

Adopted in 1987 Requires all areas of the State to attain state

standards as soon as possible (all feasible measures)

Limited to criteria pollutants Authorizes ARB to require districts to impose

fees on sources > 250 TPY of any nonattainment pollutant

Authorizes ARB to impose fees on consumer product and architectural coating manufacturers that sell a product in California resulting in emissions > 250 TPY of VOC

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AB 2588 “Hot Spots” Act

Passed in 1987 Limited to toxics pollutants Objective is to reduce toxics risk from

individual facilities Includes public notification process Quadrennial reporting schedule Fee schedule adopted to support program Risk-based program (i.e. not emission-

based)

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ARB Environmental Justice Policies

Adopted in 2001 In response to SB 115, EJ must be

considered in development, adoption, implementation, and enforcement of environmental laws and regulations

ARB must assess, consider, and reduce cumulative emissions, exposures, and health risks

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Federal Clean Air Act Amendments

Passed in 1990 Limited to criteria pollutants Affects states with nonattainment

areas Requires submittal of

comprehensive, accurate, and current emission inventories as revisions to SIPs

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Federal Consolidated Emissions Reporting Rule

CERR adopted in 2002 Limited to criteria pollutants Large point sources must report annually

(threshold varies) All other sources must report every three

years 2002 inventory submitted June 1, 2004 2005 inventory to be submitted June 1,

2007

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Air Emissions Reporting Requirements

Replaces CERR Rule to be phased in by 2011 Accelerated reporting schedule to

EPA e.g. 2010 data would be due on

June 30, 2011 Until 2011, EPA plans on scaling back

the requirements under the CERR

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Reporting Guidelines and Requirements

ARB CEIDARS Reporting Guidelines AB 2588 Reporting Requirements

www.arb.ca.gov/ab2588/2588guid.htm#current

USEPA CERR www.epa.gov/ttn/chief/cerr/index.htm

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ARB CEIDARS Reporting Guidelines

Guidelines, not legal requirements Published every year Criteria and toxics pollutants Basis for annual submittals to

CEIDARS database

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Point Source Criteria Reporting

All New or Closed Point Sources Every year

Point Sources > 10 TPY Every year

Point Sources < 10 TPY Every 3rd year (2005 base year next)

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Point Source Toxics Reporting

Report high-risk facilities annually Risk 1 in a million; or 10 TPY of any single HAP; or 25 TPY of any combination of HAPS

Report AB2588 facilities annually Needed for toxics inventory, HARP,

Community Health, CHAPIS, NEI

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Criteria for Facility Updates

Missing and incorrect data emissions, codes, spatial

Change in criteria emissions 5% or 10 TPY change

Change in toxics emissions 10% change in process rate

Addition or removal of device or process since last year

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Area Source Updates

Districts requested to update 1/3 of their area sources annually

Recognize resource intensive ARB on-line clearinghouse of district

methodologies www.arb.ca.gov/ei/areasrc/index0.htm

Encourage all districts to submit methodologies to assist others

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Reporting Methods

Prefer electronic submittals Batch HARP CEIDARS Web Forms

QA report tools are available on the web for districts to help correct errors

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Merged Criteria and Toxics

ARB still in the process of merging criteria and toxics databases

Districts requested to submit merged data

ARB willing to assist with mergers

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Important District Deadlines

November 1, 2006 Submit point and area source updates

for 2005 inventory year Feb 15 – Apr 30, 2007

QA Review Period for 2005 inventory June 1, 2007

Final 2005 inventory frozen and provided to NEI

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District Audit Program ARB staff audit all aspects of district

programshttp://www.arb.ca.gov/audits/audits.htm Includes AB 2588 and emission inventory Based on CEIDARS reporting guidelines All districts audited Audit frequency function of nonattainment

status Results published in report provided to ARB

and district upper management

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Summary

Improved air quality is top public priority

SIPs and other control programs need complete and current inventories

District and ARB partnership critical Some legal mandates require district

cooperation and assistance

inventory needs and legal requirements martin johnson emission inventory workshop air resources...

Documents

inventory needs

sources of air pollution

state standards

toxics risk

agency available

local agency data

statewide risk modeling

milestone projections