DNR to Require PM 2.5 and Ammonia Emissions to be Reported for Minor and Title V Air Sources

December 12, 2006

Beginning with the 2006 emission year, DNR will require both Title V facilities and Minor Source facilities to report PM 2.5 and ammonia emissions on their annual emissions inventories. Starting January 1, 2007, the DNR will also begin requiring PM 2.5 and ammonia to be included in all new Title V Operating Permit Applications and Renewal Applications.

Q. Why am I being required to report PM 2.5 and ammonia emissions now?

A. The Consolidated Emission Reporting Rule (CERR) required that DNR report ammonia and PM-2.5 emissions to the National Emissions Inventory (NEI) starting with the 2002 emission year. Because facilities previously did not report ammonia and PM 2.5 emissions on their annual inventories, DNR staff were forced to calculate the ammonia and PM 2.5 emissions after the inventory data was pulled from SPARS. For emission year 2002, more than 15,000 Title V emission points were run through EPA's PM Calculator, which contained the only emission factors available at that time. This was very time consuming, and because of time constraints, the DNR has been calculating and reporting only Title V ammonia emissions from ammonia nitrate production and cement manufacturing to EPA. Potential emissions calculations are being required so that the DNR may evaluate the air pollution situation in the state for future planning activities.

Ammonia emissions are important to air quality analyses because ammonia is involved in the formation of sulfate and nitrate, which are precursors for PM 2.5. Only primary ammonia needs to be reported. Primary ammonia means it is in the same chemical form as when it was emitted into the atmosphere. Secondary ammonia, such as ammonium sulfate and ammonium nitrate, is formed by chemical reactions in the atmosphere.

Requiring PM 2.5 and ammonia to be reported on the annual emission inventory benefits both the DNR and industry for the following reasons:

• It will be more cost-effective for both the DNR and industry than mailing out a separate PM 2.5 and ammonia inventory questionnaires.
• It will save DNR staff time when compiling the NEI submittal.
• Facilities will be responsible for calculating and reporting their own emissions.
• Facilities will certify the accuracy of their PM 2.5 and Ammonia emissions.
• The data will be entered into and stored in SPARS, where everyone can access it.

Q. How do I calculate PM 2.5 and ammonia emissions?

A. The preferred method to calculate PM 2.5 and ammonia emissions is EPA's Factor Information Retrieval (FIRE) Data System. The most current version of the database is FIRE 6.25. EPA has also developed a new Internet version of the database called WebFIRE. It is available at: www.epa.gov/ttn/chief/efpac/index.html. Nearly all ammonia emission factors and more than 600 emission factors for PM 2.5 are now included in FIRE. Unfortunately, EPA is no longer supporting the PM Calculator due to inaccuracies, so if you can not find a PM 2.5 emission factor in FIRE. Particle distributions for selected sources can be found in AP-42, Appendices B.1 and B.2. The PM 2.5 emissions may be calculated by applying a particle distribution factor to the PM emissions. The particle distribution should be used only as a last resort. EPA prefers the use of FIRE.

Q. How do I report PM 2.5 and ammonia emissions on my Title V Operating Permit Application, Title V Emissions Inventory, and/or Minor Source Emissions Inventory?

A. Both the paper and SPARS electronic forms have been modified to allow for PM 2.5 and ammonia reporting. The paper forms are available at www.iowacleanair.com/.

Q. Do Title V facilities have to pay fees on PM 2.5 and ammonia emissions?

A. No. The PM 2.5 emissions are a subset of PM 10 emissions, which the Title V facilities already pay fees on, and ammonia does not meet the definition of "regulated air pollutant (for fee calculation)" in 567 IAC 22.100 because it is regulated only under 112(r).

Additional information can be found in this fact sheet.

For more information, contact Marnie Stein with the DNR at (515) 281-8468 or Marnie.Stein@dnr.iowa.gov.