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Environmental Roadmapping Initiative -- Shipbuilding and Ship Repair

Baseline Environmental Performance Measures for the Shipbuilding and Ship Repair Industry

Prepared August 2001 by John Sheridan, NCMS, (734) 995-4963, johns@ncms.org 

Data, Part One: VOC Emissions

Federal Programs on VOC Emissions

Shipyards may be major sources of hazardous air pollutants, which include volatile organic compounds[3]. Such emissions are governed under the Clean Air Act, Titles III and Title V. Title III directs the EPA to set emissions standards based on technological feasibility for 189 toxic air pollutants. Title V requires EPA to establish a permit program for major sources of air pollution. The EPA regulations that respond to this law are in 40CFR part 70.

Summary and Assessment of State VOC data

Basis for performance measures

All states follow the EPA Clean Air Act reporting, which has been available since 1991. The Clean Air Act addresses only major sources.

Outliers

The Connecticut Air Toxics Control Regulation deserves special mention. In 1986, Connecticut adopted the most comprehensive regulation, at the time, in the United States to control toxic air pollutants. This regulation established emission limits for 850 chemicals based on national occupational health standards. Compliance with these limitations is verified through engineering calculations, periodic testing and inspections conducted by the Department's enforcement staff. Following the passage of the 1990 Clean Air Act Amendments, with its MACT requirements, the Department decided to retain the existing state regulation for control of air toxics as well as to implement the required federal MACT program.

State Data Available on VOC Emissions

The following paragraphs provide information on the status of the selected state VOC emission programs. States are presented in alphabetical order. Information about significant state databases is presented in a table. Other states are covered in narrative format.  

Alabama Florida Mississippi Virginia
California Louisiana Oregon Washington
Connecticut Maine Texas  

 

Alabama[4]

 

Are there state data?

Yes, but only one shipyard in Alabama (Atlantic Marine) has a Title V permit. The state does maintain a database with that information, but suggested that the yard would have even more detailed data. 

For what years is data available?

Title V data since about 1991.

Data for both small and large facilities?

No. Reporting of emissions from smaller facilities is not required. Thus, no data exist.

Data easily aggregated to SIC?

Yes. Only one shipyard reports.

Are data in similar units?

Yes, in accordance with EPA Title V requirements.

California

The state of California is in an unusual situation when compared with other states. The California EPA division that handles VOC is the Air Resources Board (ARB), The ARB does not have authority to issue permits directly to stationary sources of air pollution. Primary responsibility for permitting all sources, except vehicular sources, rests with the local and regional air pollution control authorities known as Air Pollution Control Districts (APCD) or Air Quality Management Districts (AQMD), which are also called air districts. The following map shows the Air District Boundaries. This map can be used to access the County and Air Basin pages to view emissions data. However, when viewed, the publicly available data did not list VOC emissions. We were not able to find data on VOC emissions in public California web searches.

Connecticut

 

Are there state data?

Yes, most likely. In addition to their own state law (see below), Connecticut has a complete Title V implementation plan in accordance with EPA regulations. They also have a Environmental and Geographic Information Center that maintains information on hazards, and provides technical assistance and makes information available through a geographic information system (GIS). No further description of the system was available online.

For what years is data available?

Title V data since about 1991. Other data earlier.

Data for both small and large facilities?

Likely no.

Data easily aggregated to SIC?

Likely yes. The data is self-reported by the shipyard.

Are data in similar units?

Yes, in accordance with EPA Title V requirements.

Connecticut’s management of toxic air pollutants is described here. It features a number of unusual aspects worthy of mention.  

Connecticut Air Toxics Control Regulation: In 1986, Connecticut adopted the most comprehensive regulation, at the time, in the United States to control toxic air pollutants. This regulation established emission limits for 850 chemicals based on national occupational health standards. Compliance with these limitations is verified through engineering calculations, periodic testing and inspections conducted by the Department's enforcement staff.

Following the passage of the 1990 Clean Air Act Amendments, with its MACT requirements, the Department decided to retain the existing state regulation for control of air toxics as well as to implement the required federal MACT program. The driving forces behind this decision include:

Toxic Air Study in Connecticut: In 1998, the Department initiated a three-year research and monitoring effort to characterize levels of toxic air pollutants from locations throughout the state. The goal of this study is to gain a better understanding of ambient air levels of toxic chemicals so that effective strategies can be developed for mitigation. Connecticut's study will measure ambient levels of toxic air pollutants, such as carbonyls (i.e. formaldehyde), volatile organic compounds (i.e. benzene), polycyclic aromatic hydrocarbons (i.e. benzopyrene) and metals (i.e. nickel).

Air Toxics Inventory: To enhance the existing emission inventory effort for criteria air pollutants, the Department is planning to compile an air toxics inventory. This new effort will provide summary information on Title V sources and their emissions, evaluate emission trends and provide a basis for program development efforts. Forty priority hazardous air pollutants have been identified for inclusion in the air toxics inventory.

Florida[5]

 

Are there state data?

Yes. Florida DEP requires that each permitted facility self-report data every year, and maintains a database of such data. Their program is largely consistent with the Clean Air Act, with no significant additions.

For what years is data available?

Since about 1991

Data for both small and large facilities?

No. Data is kept for major sources, and some minor sources that meet special criteria.

Data easily aggregated to SIC?

Yes. The data is self-reported by the shipyard. The information is also provided in a format consistent with the EPA Source Classification Code (SCC) system.

Are data in similar units?

The reporting format and data fields are identified in an Annual Operations Report[6]. Record keeping requirements and units are specified in Reasonably Available Control Technology (RACT) Volatile Organic Compounds Florida rules. Units appear consistent with EPA federal reporting guidelines.

 

Louisiana

 

Are there state data?

Yes. See Louisiana Toxic Air Pollutant Facts for details and history.

Louisiana is one of the most heavily industrialized states in the nation. As mandated by the law, the Louisiana DEQ developed and promulgated the Comprehensive Toxic Air Pollutant Emission Control regulation, one of the most stringent state air toxics rules in the country.

The state list of regulated chemicals includes the federal toxic air pollutants and adds others that are of particular concern in Louisiana, such as ammonia and hydrogen sulfide. Louisiana's current toxic air pollutant control program covers over 200 pollutants, and tracks toxic air emissions from over 250 industrial facilities.

Under this program, facilities must report annual emission totals to DEQ's Toxic Emission Data Inventory (TEDI). This data is available through DEQ's in-house data system called TEMPO (Tools for Environmental Management and Protection Organizations).

For what years is data available?

TEDI data is available back to 1991.

Data for both small and large facilities?

Unknown, likely no.. 

Data easily aggregated to SIC?

Yes. The data is self-reported by the shipyard.

Are data in similar units?

Toxics Emissions Data Inventory (TEDI) reporting guidelines are here. Units appear consistent with EPA federal reporting guidelines.

 

Maine

 

Are there state data?

Yes. Maine requires that each permitted facility self-report data every year, and maintains a database of such data. Detailed "facility" reports are submitted annually in accordance with the requirements of the Clean Air Act Amendments of 1990 and Chapter 137 of Maine regulations.

For what years is data available?

 

Data for both small and large facilities?

No. For reporting purposes, the threshold limit is 25 tons per year.

Data easily aggregated to SIC?

Yes. The data is self-reported by industry.

Are data in similar units?

Point Source Emission Inventories are generated by a software product called i-Steps™ Infinity, which handles information on various industrial processes, fuel consumption, control equipment, and facility emissions for six criteria pollutants (of which VOC is one). The Complete Set of Requirements, Definitions, and Emission Statement Contents may be found in their entirety in Maine Law, Chapter 137, Sections 2-4.

 

Mississippi

The Mississippi Department of Environmental Quality, Office of Pollution Control, Air Division implements and enforces the EPA Clean Air Act and other appropriate laws. All the data from these inventories is fed into the EPA database. There was no data maintained locally.

Oregon[7]

 

Are there state data?

Oregon does collect VOC data and perform emission estimates.  Oregon DEQ regulates approximately 130 major sources of air emissions through the Oregon Title V Operating Permit program. Non-major sources may be regulated through the Air Contaminant Discharge Permit program. When a company is issued a permit, one of the requirements is to report production information relevant to compliance or emission estimation.  This production information is used to estimate VOC emissions along with the other criteria pollutants. 

For what years is data available?

Oregon has VOC data back to 1980. Older data may not be as complete as recent data.

Data for both small and large facilities?

Oregon collects data for both large and small sources, but Oregon is only required to report larger sources to EPA. 

Data easily aggregated to SIC?

Yes. The data is self-reported by the shipyard.

Are data in similar units?

Likely, yes. The Oregon Administrative Rules, Division 200 specify reporting requirements. Reference documents used in this Division include the Department Source Sampling Manual and the Department Continuous Monitoring Manual. (Both not available online.) 

Texas

 

Are there state data?

Yes. The Texas Natural Resources Conservation Commission enforces an annual point source emissions inventory survey of chemical plants, refineries, electric utility plants and other industrial sites that meet the reporting criteria in the TNRCC emissions inventory rule (30 TAC §101.10), and maintains a database of such data.

For what years is data available?

Data was available on the web site back to 1994.

Data for both small and large facilities?

No. The TNRCC collects information about air pollutants emitted from industrial point sources in Texas that is stored in our Point Source Database (PSDB). Of the 50,000 plants tracked in the database, only those plants whose emission rates exceed the reporting applicability levels found in (30 Texas Administrative Code 101.10) are tracked. Currently, there are more than 3,000 industrial point sources being tracked that include summary information with about 1,850 updating emissions annually.

Data easily aggregated to SIC?

Yes. Reports are available for the 3,000 plants and are available in portable document format (PDF). Supporting data about the reporting process, forms, requirements are available here.

Are data in similar units?

The TNRCC Requires an initial emissions inventory and an annual emissions inventory update.

Virginia

The Virginia Department of Environmental Quality implements and enforces the EPA Clean Air Act and other appropriate laws. They have an air permitting program for point sources. DEQ periodically compiles an inventory of criteria pollutant air emissions from point, area, mobile, and biogenic sources in the state. Point source emissions are inventoried annually. All the data from these inventories is fed into the EPA database. Thus, although the inventory and record keeping is quite complete, no state data is kept that is different than the federally available data. Virginia Annual Point Source Criteria Pollutant Emissions reports for previous years are available here.

Washington[8]

 

Are there state data?

Yes. Washington has substantial reporting and data on VOC emissions by industry, but their programs are managed by the local air pollution agencies. The Washington database of such data is called Washington Emissions Data.

For what years is data available?

Since 1977, with better data more recent

Data for both small and large facilities?

Not at the state level. The local agencies send data on the larger sources to the state, but keep data on the smaller sources regionally. It is possible that some regional data may be in paper files.

Data easily aggregated to SIC?

Yes. The data is self-reported by industry.

Are data in similar units?

Likely, yes. The state offers an Emissions Inventory form that reports criteria pollutants in standard SIC and SCC terminology. Local agencies may have their own systems that deviate from the state system.