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July 11, 2013
Proposal would lower lead reporting threshold

A revision lowering the lead emissions threshold that triggers reporting of a stationary source as an individual point rather than as part of a county-aggregate nonpoint source is included in a proposed package of amendments to the 2008 air emissions reporting requirements (AERR) rule by the EPA.  The proposed actions would affect states and local governments that are required to report certain air emissions or emissions-related data, which the EPA uses to build its national air emissions inventory.

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Some of the proposed changes are intended to reduce redundant or unnecessary reporting while others would align requirements with the implementation of electronic reporting.  The EPA says that, in general, the proposed amendments would reduce the reporting burden.

Proposed actions

The following specific changes are proposed:

  • Lead source threshold.  The current 5-tons-per-year (tpy) level that triggers point source reporting would be lowered to 0.50 tpy.  As with other required pollutants, the threshold determination for lead is based on potential to emit, although the emissions reported are actual.  The proposed AERR threshold for reporting lead would match the threshold in the revised ambient air monitoring requirements.  The EPA says that only about 30 additional facilities nationwide would need to be reported as point sources due to the proposed change since most sources emitting lead beyond the 0.50-tpy threshold are already reported as point sources due to their emissions of other criteria air pollutants.
  • Wildfires.  The requirement that states report emissions from wildfires and prescribed fires would be eliminated.  The EPA says it already provides nationwide estimates for wildfires and prescribed fires using information it has.
  • Emissions model inputs.  The proposal would replace the current requirement for states to report emissions for on-road and nonroad sources with a requirement that they report the input parameters that the EPA can use in its models to generate emissions values.  Reporting these emissions would become voluntary for states.  However, California and tribal agencies would continue to report emissions rather than model inputs because the EPA models are not applicable to California, and the county-specific inputs required by the emission inventory system (EIS) for these models are not applicable to tribal areas.
  • Daily and seasonal emissions.  The proposal would delete all the daily and seasonal emissions reporting requirements from the AERR and replace them with statements that the states can choose to meet the underlying requirements through reporting that is occurring under the NOx SIP Call rule, the Ozone NAAQS implementation rule, and the CO NAAQS implementation rule.
  • Consistency.  The following changes are proposed to simplify reporting and provide consistency between the AERR and the EIS:
    • Tables 1, 2a, 2b, and 2c in Appendix A of the AERR would be revised to clarify which sources must be reported and when.
    • Table 2a would be revised by adding new operating statuses to the AERR; specifically, facility site status, release point status, and unit stats, along with the year any of these three items change from operating to some other status.
    • Five new emissions elements would be added to Table 2b—shape identifiers, emissions type, reporting period type, emissions operating type, and emissions calculation method.
    • Data element names would be revised and usage conventions for four data elements related to emissions control devices for point source facility inventory items would be clarified. 
    • Some terms in point source facility inventory Table 2a would be revised to promote clarity and consistency with the EIS data system names.
  • Burden reduction.  Proposed changes would reduce reporting requirements applicable to exit gas velocity/flow rate and stack location. 

EPA’s proposed revisions to emissions inventory reporting requirements were published in the June 20, 2013, FR.

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