Inventory Needs and Legal Requirements

1
Inventory Needs and Legal Requirements

• Martin Johnson
• Emission Inventory WorkshopAir Resources Board
• March 13, 2006

2
Presentation Outline

• Who Uses the Inventory?
• How is the Inventory Used?
• Agency Responsibilities
• Legal Requirements
• Reporting Guidelines and Requirements
• ARB Audit Program

3
Inventory Users

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

4
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

5
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)

6
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

7
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)

8
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))

9
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

10
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)

11
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

12
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

13
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

14
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

15
Reporting Guidelines and Requirements

• ARB CEIDARS Reporting Guidelines
• AB 2588 Reporting Requirements
• www.arb.ca.gov/ab2588/2588guid.htmcurrent
• USEPA CERR
• www.epa.gov/ttn/chief/cerr/index.html

16
ARB CEIDARS Reporting Guidelines

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

17
Point Source Criteria Reporting

• All New or Closed Point Sources
• Every year
• Point Sources 10 TPY
• Every year
• Point Sources
• Every 3rd year (2005 base year next)

18
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

19
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

20
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

21
Reporting Methods

• Prefer electronic submittals
• Batch
• HARP
• CEIDARS Web Forms
• QA report tools are available on the web for
  districts to help correct errors

22
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

23
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

24
District Audit Program

• ARB staff audit all aspects of district programs
• http//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

25
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