Frequently Asked Questions

Do I have to file?

If you have, or are required to have, a State of Illinois air pollution operating permit, you are required to file an Annual Emissions Report. This requirement is contained in 35 Ill. Adm. Code Part 254.

When do I have to file?

Annual Emissions Reports are due by May 1. Emissions reported must reflect the previous calendar year.

What if I fail to file or I file late?

Failure to file a complete Annual Emissions Report by the required deadline is a violation of 35 Ill. Adm. Code 201.302(a) and is subject to the penalties prescribed in Section 42 of the Illinois Environmental Protection Act. The Illinois EPA intends to ensure compliance with this reporting requirement through careful review of noncomplying sources. Furthermore, the United States Environmental Protection Agency is requiring the Illinois EPA to provide quarterly reports of all noncomplying sources in ozone nonattainment areas continuing each quarter until there is full compliance.

How do I begin?

Around February 1 of each year, the Illinois EPA will send to you the forms necessary to be completed for the Annual Emissions Report. To complete the report, you should have available items such as: your permit, records maintained throughout the year, emission calculation references (AP-42, FIRE, etc.) and, if necessary, your permit application.

Use your permit to identify each emission unit that is permitted. In many cases, your permit will specify, or at least give a clue, how to calculate emissions. Use the data you’ve collected throughout the year and the calculation methods and references to calculate emissions.

What if I do not receive my forms by February 1?

Failure to receive the Annual Emissions Report forms does not relieve you of the obligation to file a timely report. Contact EPA.AERQuestions@illinois.gov

How do I contact the Illinois EPA?

E-mail EPA.AERQuestions@illinois.gov

Where do I send the completed report?

After the Annual Emissions Report has been completed and signed, mail it to the address below:

Illinois EPA
 

Bureau of Air
 

Air Quality Planning Section (#39)
 

1021 North Grand Avenue East
 

P.O. Box 19276
 

Springfield, IL 62794-9276
 

ATTN: Annual Emissions Report

I need additional help. What should I do?

Persons knowledgeable about the Annual Emissions Report can be reached at EPA.AERQuestions@illinois.gov. Please include your facility identification number in your email. Additional contact information can be found on the main AER page. During busy periods, you may not be able to receive help immediately. A staff member will get back to you as soon as possible. Remember, this may be a while during peak periods. There are only limited staff available. Be patient.

Are any extensions available?

No. The rule is quite specific. Annual Emissions Reports are due by May 1 of each year.

Where does the data that was sent to me come from?

Data on the Annual Emissions Report comes from the Bureau’s emission inventory database (ICEMAN). ICEMAN is the Bureau’s enterprise data system which in addition to emission inventory data, also includes data on fee payments, permit tracking and inspections. Data specific to Annual Emissions Reporting comes from permit applications, previous Annual Emissions Reports and source inspections.

Does everyone complete the same type of report?

No. There are two types of reports. The “short” report requires the source to report emissions for the source as a whole. The “long” report includes the short report and additionally requires a source to report emissions at the emission unit level.

What makes me qualify for the long report?

Sources that are required to complete the long report include:

• all CAAPP (Title V) sources
• sources whose total allowable emissions are >= 25 tons/year
• sources who are in an ozone nonattainment area whose potential NOx or VOM emissions >= 25 tons/year

When determining what type of report the source receives, the Illinois EPA also looks at the values reported for the previous year. Therefore, if you reported total emissions >= 25 tons/year in the previous year and the database shows emissions < 25 tons/year, you will receive, and be required to file, a long report.

What makes me qualify for the short report?

If you do not meet one of the requirements for submitting a long report, then you fall into the short report category. Sources that have been issued lifetime permits often fall into this category.

Can I receive the long report even though I only need to file the short report?

Yes. The complete report can be provided upon request. Contact the Illinois EPA. A request for the Detailed Annual Emissions Report does not oblige a source to provide additional detailed information if not required by the provisions of the rule.

What counties/areas make up the ozone nonattainment areas?

• Cook County
• DuPage County
• Grundy County - Aux Sable and Goose Lake Townships only
• Kane County
• Kendall County - Oswego Township only
• Lake County
• Madison County
• McHenry County
• Monroe County
• St. Clair County
• Will County

How is potential to emit calculated?

Potential emissions are calculated by taking the maximum emission rate (lb/hr) times 8760 (hours/year) times the number of identical points and dividing by 2000 (lb/ton). For example, an emission unit that is capable of emitting 10 lb/hr (after control) of VOM would have potential emissions of 43.8 tons/year (10 x 8760 x 1 / 2000).

Emission units that have a Federally Enforceable Permit Special Condition have their potential emissions calculated by taking the allowable emission rate (lb/hr) times the allowable amount of hours of operation times the number of identical sources and dividing by 2000 (lb/ton). For example, an emission unit that is capable of emitting 10 lbs/hr of VOM, but has a Permit Special Condition limiting VOM emissions to 2.5 lb/hr and 4000 hours of operation per year would have potential emissions of 5.0 tons/year (2.5 x 4000 x 1 / 2000).

The potential emissions for the source are calculated by summing the potential emissions of all emission units.

As time goes on, the definition of potential to emit is becoming more and more nebulous. The above should be used as a guide.

What emissions must be reported?

All sources must report annual emissions for regulated pollutants. This includes criteria pollutants and HAPs. For sources that emit HAPs, a HAP is to be reported only if there is a specific regulation (NESHAP or MACT) that applies to the source. For example, if your source is subject to the MACT for halogenated solvent cleaning. Emissions of the HAPs used in that solvent cleaning must be reported. Please note: Your permit may require you to report emissions of HAPs.

Criteria Pollutants:

• CO - Carbon Monoxide
• LEAD - Lead
• NH3 - Ammonia
• NOX - Nitrogen Oxides
• PART - Particulate Matter
• PM10 - Particulate Matter < 10 microns
• PM2.5 - Particulate Matter < 2.5 microns
• SO2 - Sulfur Dioxide
• VOM - Volatile Organic Material

Hazardous Air Pollutants (HAPs)

• Individual HAPs Regulated at your source by NESHAP, MACT or other regulations.

The report you sent me does not include some of my emission units. What should I do?

You can download forms here. Note: If you are adding an emission unit that is not currently covered by a permit, please contact the Permit Section to determine if a permit is needed.

Must I report fugitive emissions?

Yes. Fugitive VOM emissions from permitted emission units must be reported by all facilities. Fugitive VOM emission sources include valves, pumps, seals, flanges, leaks, and solvent clean-up operations. Annual source totals of fugitive Particulate and PM10 emissions must also be reported by facilities involved in mining operations (SIC groups 10 - 14), manufacturing operations (SIC groups 20 - 39), and electrical generating operations (SIC group 491) AND which are located in the following counties and townships:

• Cook - All townships
• DuPage - Addison, Winfield and York townships
• Lake - Shields, Waukegan and Warren townships
  LaSalle - LaSalle and Utica townships
• Macon - Decatur and Hickory Point townships
• Madison - Alton, Chouteau, Collinsville, Edwardsville, Fort Russell, Godfrey, Granite City, Nameoki, Venice, Wood and River townships
• Peoria - Richwoods, Limestone, Hollis and Peoria townships and City of Peoria
• Rock Island - Blackhawk, Coal Valley, Hampton, Moline, South Moline, Rock Island and South Rock
• St. Clair - Canteen, Caseyville, Centerville, St. Clair, Stites, Stookey, Sugar Loaf and Millstadt townships
• Tazewell - Fondulac, Pekin, Cincinnati, Groveland and Washington townships
• Will - DuPage, Plainfield, Lockport, Channahon, Peotone, Florence and Joliet townships

The types of particulate and PM10 fugitive emissions that must be reported include, but are not limited to emissions from storage piles, loading and unloading operations and traffic areas.

The source-wide totals of fugitive VOM, PART, and PM10 emissions must be identified and reported on the ANNUAL SOURCE EMISSIONS page. The total VOM, PART, and PM10 emission values are to include both the fugitive and non-fugitive values. For example, if a source had 95 tons per year of non-fugitive PART emissions and 20 tons per year of fugitive emissions, 115 tons per year of PART emissions would be reported on the ANNUAL. A value of 20 tons per year would also be identified as fugitive PART emissions.

Is there any other information that must be reported?

Title V (CAAAP) permits, Federally Enforceable State Operating Permits (FESOPs), and Operating permits commonly contain conditions specifying additional data or certification requirements that must be provided with the Annual Emissions Report. For example, issued Title V permits require annual compliance certifications to be completed and filed with the Annual Emissions Report. You should review your permit before completing the Annual Emissions Report to insure you are providing all the necessary information.

I am reporting emissions greater than the allowable value indicated on the report you sent me. Will there be a problem?

In general, reporting emissions greater than your allowable is a violation of your permit. However, there are a few cases where this is not a violation.

• Our inventory is not up-to-date
• Emission factors have changed since the permit was last issued
• There are no limits for some emission units at your source. For example, small gas-fired boilers do not have limits on the amount of CO or NOx they can emit. In this case, the "allowable" is the amount you emit (see how allowables are calculated). So if you are using more natural gas than what was indicated in your permit application (and your gas usage was not limited in the permit), you will be reporting emissions greater than your allowable, but that is no violation.

In all cases, we first check to see who is in error before a notice of violation is sent.

Why doesn't my AER data agree with my permit/Title V application?

If the AER data do not agree with your permit or application, please e-mail the Agency at EPA.AERQuestions@illinois.gov with the specific problems and Agency staff will investigate.

When should I contact the Permit Section?

You should contact the Permit Section for any of the following reasons:

• You have a question about your allowable or estimated emissions.
• To add an emission unit that is not permitted.
• To delete an emission unit that has been permanently shut down or dismantled.
• The facility has closed or ownership has changed.
• If you feel a permit is no longer needed or equipment is exempt from permit requirements.

How can I contact the Permit Section?

The Permit Section mailing address and telephone number is listed below:

Illinois EPA

Bureau of Air

Permit Section (#11)

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

Telephone: 217-782-2113

It is possible that your permit has a contact name. Please review your permit to find this name. If you do not have a contact, your call will be forwarded to one of the permit analysts assigned to answer phone calls that day.

How are allowable emissions calculated?

Allowable emissions can be set by many methods. The two most common are by regulation or by permit condition.

In general, allowable emissions are calculated by taking the allowable emission rates for each emission unit in pounds/hour multiplied by the allowable hours of operation divided by 2000 pounds/ton. The values for all emission units are then summed to obtain the plant total.

If the emission unit does not have a restriction on the number of hours it can operate, the maximum hours of operation indicated in your permit application are used.

If there is no limitation on your emissions (NOx emissions from small gas-fired boilers for example), your maximum emission rate is substituted for allowable.

How do I change my allowable emissions?

You must contact the Permit Section in writing to change your permit. In your request, state what changes are necessary.

If you think the allowable emissions are an Agency error, contact a person from the Emission Inventory Unit.

The report you sent me says I have an expired permit. What should I do?

You need to contact the Permit Section to get the permit reinstated. If the equipment covered by that permit is no longer in operation or no longer needs to be permitted, please inform the Permit Section so we can correct our records. In this way, you will avoid us sending you a notice that the permit is expired.

The report you sent me says my permit is denied or rejected. What should I do?

Find the denial or rejection letter from the Agency and find out why the permit was denied or rejected. If that project has not been put into operation, you are probably ok. However, in any case, it is advisable to contact the Permit Section to see how you can rectify the situation.

I have a permit that has equipment that doesn't exist any more. What should I do?

Contact the Permit Section in writing to have that permit withdrawn or to have that equipment in the permit removed from the permit. Please be clear on what is to be done with the permit. We do not want to accidentally withdraw the entire permit when all you wanted to do was remove one piece of equipment out of ten.

How do I request confidentiality?

Certain information requested in the Annual Emissions Report forms may be claimed as trade secret, privileged information, or confidential only if the information does not represent "emissions data" as described in 40 CFR 56.7042 (1991) (also see Emissions Data under DEFINITIONS in Appendix B). All claims of trade secret must comply with 2 Ill. Adm. Code 1827.201, Procedures for Claiming and Determining Trade Secrets. A claim of trade secret for data contained in an Annual Emissions Report applies only to that report and must accompany the report. Any information which is claimed as a trade secret in the Annual Emissions Report which also appears in other documents submitted to the Illinois EPA (such as permit applications), must be claimed under separate letter. A separate, edited version of the Annual Emissions Report, omitting the confidential information, must be submitted to the Illinois EPA to provide a version of the report which may be inspected by the public.

How accurate must I make my report?

The data in your Annual Emissions Report must represent the best information available to you and must be certified as true and accurate to the best of your knowledge.

What about electronic reporting?

While the rule does allow for electronic submittal, the Agency has not pursued it at this time. We would also prefer that you do not send spreadsheets on diskette to us. Our records management rules do not allow for the storage of these items. If a diskette is submitted, it is virtually impossible for us to tell whether the data was changed in transit (or even if it was changed after receipt). Submitting your Annual Emissions Report on paper will help both you and the Agency. The screens we use to enter the data are set up to mimic the forms we send you. Submitting a spreadsheet which does not conform to our screens and that needs a magnifying glass to read is not a productive use of electronic submittal.

For the future, we are keeping an eye on the development of electronic signatures for the State. Once this method is finalized, we can begin to think about using the Internet to receive Annual Emissions Report data.