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PBR Emission Inventory Requirements


In response to requests from industry during the development of the new Oil and Natural Gas Permit by Rule (PBR), the emission inventory reporting requirements in OAC 252:100-5 for minor source facilities registered under a PBR were amended. Such facilities with less than 5 tons of any regulated pollutant now have to submit an emissions inventory every six rather than five years, and larger PBR facilities with over 5 tons of any regulated pollutant now have to report every three years instead of annually. This schedule is aligned with National Emissions Inventory (NEI) triennial years when emissions from all sources are fully inventoried. Thus the overall reporting burden for these small but cumulatively important facilities has been reduced with data collection efforts focused on the most important years for air quality planning and policy decisions.

The current rule, which came into effect on 9/10/2013, is available here. The following explains the change in reporting requirements:

PBR facilities are now required to submit, at a minimum, an annual emission inventory for the 2014 operating year or the first calendar year in which the facility is registered under a PBR, if registered after December 31, 2014. After the initial emission inventory submittal, PBR facilities will be required to submit an annual emission inventory on the following schedule:

  • For PBR facilities with actual emissions greater than 5 tons per year of any regulated air pollutant, an emission inventory is required for every NEI Three-Year Cycle Inventory year (defined in 40 CFR Section 51.30(b)).

  • For PBR facilities with actual emissions of 5 tons or less per year of any regulated air pollutant, an emission inventory is required for every second NEI Three-Year Cycle Inventory year (defined in 40 CFR Section 51.30(b)) beginning in 2020.

PBR facilities may elect to also submit an emission inventory for non-NEI reporting years. This option may be advantageous for facilities that have a significant emissions decrease between NEI reporting years.

Emissions Threshold Determination
Actual emission amounts should be determined for PBR facilities every NEI Three-Year Cycle Inventory year. If an increase or decrease in facility emissions results in a change of reporting schedule, it will be the facility's responsibility to ensure reporting deadlines are met.

Annual Operating Fees
PBR facilities will be assessed an annual operating fee each year which will be based on the most recent emission inventory submission.

PBR Permit Conversions
Facilities converting from an Individual or General Permit to a PBR in any year may still have to submit an emission inventory for that calendar year if the permit change was due to the removal of permitted equipment.

If your company has any questions, including whether an inventory needs to be submitted, please e-mail the Emissions Inventory Section or call us at (405) 702-4100.

Last Updated: June 17, 2015


PBR Emission Inventory Requirements

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