Facilities located within Jefferson County who are required to report emissions to the LMAPCD need to know that the District has changed forms and approaches for the annual emissions inventory. A complete emissions inventory must be submitted by April 15th for the previous calendar year of operations. This summary highlights the revisions to emissions inventory forms and several other important changes.

  • The District is recommending that sources revise particulate matter emission factors from natural gas combustion for boilers and other combustion sources as shown in the table below. The new values will result in less actual emissions reported by the source for natural gas combustion.
Pollutant New Value Old Value
TSP 0.84 lb/MMCF 7.6 lb/MMCF
PM condensable 0.32 lb/MMCF 5.7 lb/MMCF
PM10 filterable 0.20 lb/MMCF 1.9 lb/MMCF
PM2.5 filterable 0.11 lb/MMCF 1.9 lb/MMCF

 

      • Forms E91T and E92T require specific information to characterize release points and control measures. The District is requesting that changes from year-to-year are to be clearly labeled on the forms.
      • The District has also recommended that facilities begin tracking n-propyl bromide (CAS #106-94-5) because EPA is proposing to add this chemical to the list of hazardous air pollutants contained in Section 112(b)(1) of the Clean Air Act. Keep in mind this is not required at this time.

Facilities have two options for their emissions inventory submissions: Reporting Option 1 requires individual forms, or Reporting Option 2 which calls for a processes spreadsheet.

Option 1 requires separate MS Excel workbooks for each form type. Forms include E10T, E90, E91T, E92T, E99, E20, E43, E44, E45, E54, and E55. Individual workbooks will include separate tabs for each fuel type, material usage, or emission source.

Option 2 requires preparation of a separate MS Excel workbook for each process, which would include separate tabs for forms E20, E43, E44, E45, E54, E55, and E90.

We suggest that local facilities review the instructions in Form E01, “General reporting instructions” as a first step for preparation of an emissions inventory. All emissions inventory forms including the revised forms are posted on the District’s website: http://louisvilleky.gov/government/air-pollution-control-district/emissions-inventory-forms

Please contact Smith Management Group (502) 587-6482, if you would like more information or need assistance with air permitting or environmental compliance strategies for sources located in Jefferson County, Kentucky.