Introduction to Emissions Inventory
Carrie Schroeder Emissions Inventory Manager
Emissions Inventory Workshop January 23, 2019 & January 30, 2019 Norman, OK Tulsa, OK Contact Information
• Program Manager: Carrie Schroeder [email protected] • Emissions Inventory Section Staff: Michelle Horn [email protected] Brent Wilkins [email protected] Michael Ketcham [email protected] Shelby Willeby [email protected] Grant Loney [email protected]
http://www.deq.state.ok.us/aqdnew/emissions/index.htm
Emissions Inventory Presentations
• Introduction – Carrie Schroeder • Emissions Inventory (EI) Basics – Shelby Willeby • EI Updates – Carrie Schroeder • Break • Emission Calculations – Grant Loney • Common Mistakes – Michael Ketcham • Break • Live Redbud Demonstration – Joshua Kalfas • Q&A – staff Introduction Presentation Objectives
• Housekeeping • What is an emissions inventory? • Who is required to file an inventory? • When is the emissions inventory due? • Invoicing, Ownership, and Responsible Officials Housekeeping
• Emergency Exits
• Restrooms
• Coffee & Tea!
• Please put cell phones on silent • If you have a question, ask! o Follow up with us if you have a specific question about a rule or facility What is an Emissions Inventory? What Is An Emissions Inventory?
• A report of actual emissions of regulated pollutants during the previous year
• Provides a description to DEQ of your facility and its operations Uses of Inventory Data • The emissions inventory is used to… 1) Model interstate transport of ozone and PM-2.5 precursors 2) Inform modeling work for major construction permits 3) Predict health impacts and identify local hotspots 4) Confirm the success of current rules and evaluate the need for new rules 5) Satisfy national reporting requirements 6) Document compliance 7) Calculate fees
Emission Trends
*Chart reflects emissions from facilities that reported for all of these years Emission Trends
*Chart reflects emissions from facilities that reported for all of these years Who is Required to File an Emissions Inventory? Required to File an Inventory
• The owner or operator of any facility that is a source of Regulated Air Pollutants (RAP)
• “Special Inventories” upon request by AQD Director
• Permit Exempt & De Minimis facilities are not required to file an inventory
De Minimis Facility Permit Exempt Facility Site Specific Questions
Remember Air Quality Rules Always Apply http://www.deq.state.ok.us/mainlinks/deqrules.htm • The Annual Reporting Cycle The Emission Inventory Annual Reporting Cycle
2018 2019 2020 EI Section submits Redbud 30-Day Extension EI Section 2017 Point passwords, inventories received SLEIS Testing Submission data and TADs dispatched and Deadline for Nonpoint Implementation 2018 NEI data data to Invoices NEI Annual based on Workshops 2017 data sent out
Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar
Redbud upload TAD preparation Main QC work on 2018 data
Companies notified Bulk of 2018 RO changes updated inventories received SLEIS Deployment SLEIS Configuration and Implementation Important Dates
• Redbud passwords dispatched on January 2
• Emission Inventories due April 1
• Deadline with approved 30 day extension - May 1
• Invoices mailed July 1
• Operating Fees due July 31
Emission Inventory Amendments EI Amendments
• An EI amendment may be submitted due to an inspection/enforcement action, a companies’ internal audit, or an audit by the EI section.
• Redbud o Use a Turn Around Document/Hardcopy o Mark up the changes in red ink o Responsible Official must sign last page o Cover letter summarizing changes o Mail OR scan and email to EI Section
EI Amendments
• If the amendment (or any correspondence to EI) is due to an enforcement case, please include the DEQ Inspector’s name in your correspondence with EI so that EI staff can let the inspector know documents have been received!
Invoicing and Annual Operating Fees Invoicing • Two years in arrears • 2017 inventories submitted by April 1, 2018 - billed in 2019 • 2018 inventories submitted by April 1, 2019 - billed in 2020 • This allows the Emission Inventory Section ample time for quality control
• The Title V operating fee was set at $32.30 per ton in 2008, and it is adjusted yearly based on the change in the annual Consumer Price Index • The 2019 Title V fee is $39.17 per ton • The minor source fee is fixed at $25.12 per ton
Invoicing Continued
• Pollutants can not be double billed • We split your reported Total VOC into HAP and non-HAP VOC for billing • Only bill for PM-10. (PM-2.5 is a subset of PM-10)
• When calculating PBR annual operating fees, the last reported inventory emission amounts are used. Invoice
• Invoices sent out July 1st
• Vital to have correct Responsible Official information
• A 100-882 must be signed and submitted to designate a Responsible Official
• Mail, email or fax to DEQ EI Section
#100-882 Designation of Responsible Official
http://www.deq.state. ok.us/AQDnew/resou rces/aqforms.htm Main Facility Contact
• A Main Facility Contact (MFC) is not required. Inventory questions regarding invoicing, calculations, etc. are initially presented to the MFC • An MFC can be designated by emailing the EI section with the name, title, address, phone number, and email of the person [email protected]
Ownership & Annual Operating Fee Liability
• Change of ownership – New owners assume liability for payment of the annual operating fees based on emission reported in years of operation prior to transfer of ownership (However purchase contracts can shift the liability to the previous owner)
• To change the ownership of a facility a Form 100-883 must be submitted Change of Ownership
Responsibilities of the:
• Transferor (Seller) “The transferor shall notify the DEQ using a prescribed form no later than 30 days following the change in ownership.” • Transferee (Purchaser) “The transfer of ownership of a stationary source or a facility is an administrative amendment that shall subject the new owner or operator to existing permit conditions &/or compliance schedules.”
#100-883 Administrative Change Notification (Transfer of Ownership) Resources & Help
• Sometimes the workshop is just a starter • You can e-mail or call us • You are welcome to come into our office • Schedule a time if you need one-on- one help • Bring your laptop, spreadsheets & other pertinent information • www.deq.state.ok.us/aqdnew/emissions /EIcontact.htm
General Contact Information • Emission inventory email: [email protected]
• Air Quality front desk: 405-702-4100 Questions on air emission inventory, compliance & enforcement, permitting, rules
Emissions Inventory Basics
Shelby Willeby
36 What is an Emissions Inventory?
• Detailed estimation of the amounts of regulated air pollutants released into the atmosphere.
o Provides enough information to show: • Where and when emissions occurred • What processes produced emissions • Calculation methods for determining emissions
37 Structure of an Emissions Inventory • Emissions Inventories have a nested structure where each element is “nested” within the previous element. • Elements: o Company • Facility o Emission Unit • Process o Pollutants • Ex) A process occurs at an emission unit, so data for the process is nested within the data for the emission unit.
38 39 Submitting an Emission Inventory – Turn-Around Document (TAD)
40 Note on First Inventories
• If a facility is submitting an Emissions Inventory for the first time, Redbud will have no information populated for emission units, processes, or emissions
o See Permit or Permit Application for a list of emission units and information about them. *This might not have all units though*
• After the first inventory, most data are copied forward to next year. o Key exceptions: Annual process rates, annual hours of operation, annual emissions.
41 Company and Facility Data
• Largely unchanged from year to year, with a few things to watch out for. o Make sure the appropriate Responsible Official (RO) has been designated, and is on file with the DEQ • Form #100-882 is used for Responsible Official Changes o Make sure all change of ownership paperwork has been submitted to the DEQ before preparing Emissions Inventories. • New owner assumes responsibility for reporting, fees, compliance, unless specifically written into the purchase agreement. • Form #100-883 is used for ownership changes 42 Company Home Page
43 Responsible Official
Form 100 -882 Designation of Responsible Official
http://www.deq.state.ok.us/aq dnew/resources/aqforms.htm #EmissionsInv
44 Company Home Page
45 Facility Homepage
46 Facility Contact Page
A Main Facility Contact can be designated by emailing the EI section with the name, title, address, phone number, and email of the person [email protected]
47 Facility Homepage
48 Emission Unit & Release Point
49 Emission Units
• Physical object or group of objects that produces emissions.
• Many types o Engines, storage tanks, stock piles, paint booths, etc.
• Each emission unit has one or more release points o Stack or fugitive
• Report operating status for both the emission unit and the release point
50 Release Points
For Fugitives: Height above grade (ft.) Area (sq. ft.)
For Stacks: Height above grade (ft.) Diameter (ft.) Gas exit temperature (degrees Fahrenheit) Flow rate (actual cubic ft. per min.) Gas exit velocity (ft. per sec.) 51 Emission Unit & Release Point
Emission Unit Info: name, emission unit type, operating status Release Point Info: name, operating status, stack or fugitive parameters 52 Process, Emissions, and Control Devices
53 Process
• Activity at an emission unit that produces emissions. • Associated with a specific Source Classification Code (SCC) o Can be found on EPA’s website. o Also in Redbud • Harder to determine which code to use
https://ofmpub.epa.gov/sccsearch/
54 Process
• Multiple processes at one emission unit o Different process materials • Ex) Engine burns natural gas or diesel o Storage tanks • Working, breathing, flashing losses • If emissions for an individual fixed-roof tank or a group of fixed-roof tanks that share a common header and have actual emissions less than or equal to 6 tons per year, a combination SCC for working, breathing, and flashing losses can be used
55 Process
• Other Required Information: o Process Material o Process Rates o Hours of operation o Design capacity (if applicable) • The maximum output a machine, tool, or other component can achieve under ideal conditions with unlimited resources. (Horsepower, MMBTU/HR, Megawatts)
o Fuel data (if applicable) • The heat content of fuel (MMBtu/MMSCF, MMBtu/ton, MMBtu/1000 gallons).
56 Process
Process Info: throughput material and rate, SCC, seasonal fractions, process material and rate, hours of operation, design capacity, fuel heat content
57 Process, Emissions, and Control Devices
58 Emissions
• Necessary Information: o What pollutants to report
o Calculation Method
o Control Information
o Actual emissions
o Permit limit or rule limit (if applicable)
o Excess emissions (if applicable)
59 Pollutants • Where to find pollutants to report? o In Permit
o List of Regulated Air Pollutants • http://www.deq.state.ok.us/aqdnew/emissions/OklahomaE missionsInventoryRAPreportingList.htm
o EPA WebFIRE database • https://cfpub.epa.gov/webfire/
o Manufacturer data 60 WebFIRE
• Most Comprehensive list of pollutants and emission factors
• Will I report 42 pollutants? o Probably not • Duplicate Factors • Factors with Control • Reporting Threshold
61 Actual Emissions • Actual Emissions = Total amount of pollutant that is actually emitted. o Amount of actual annual emissions of the pollutant, after application of air pollution control equipment, reported in tons per year. The actual emissions for a plant, emission unit, or process—measured or calculated—that represents a calendar year. This total shall include emissions from fugitives, upsets, startups, shutdowns, malfunctions, blowdowns, and excess emissions. The actual emissions field will allow emissions to three decimal places.
62 Excess Emissions
• Any emissions that are in excess of a permit or other such limit (this can also include malfunctions and maintenance activities). The excess may be over an hourly limit, and although it may not be enough to cause total emissions of that pollutant to exceed an annual limit, any excess amount must be entered in the total excess emissions field.
• Any excess emission amounts that are formally reported to the Compliance and Enforcement Section of the AQD (as required by OAC 252:100-9) must be included in both the actual emissions field and the total excess emissions field.
63 Permit Limit
• The total amount of any regulated air pollutant which is subject to an emissions limiting standard, either by rule or permit condition contained in an enforceable permit.
• Permit limits can be found in the Specific Conditions section of an air quality permit
• Estimated emissions listed in the permit memorandum are not permit limits and should not be listed in the permit/rule limit field in Redbud.
64 Reporting Threshold
• Actual Emissions of 0.1 tons per year o Includes insignificant and trivial activities • Key Exceptions that must report 0.001 tons per year or more are: o Lead, mercury & chromium o Any HAP at a facility that is also reported to the TRI o Any HAP from glycol dehydration still vents o Any HAP from large storage tanks (>500 BBL) o Other situations where deemed necessary
65 Record Keeping
• Records need to be kept for the last 5 years. This includes records for insignificant and trivial activities at the facility
• If we discover errors in an emission inventory, we can request up to 5 years of corrections.
66 Grouping Emission Units
• Some small sources of emissions should be logically grouped into one source o An individual emission unit may not have emissions above the reporting threshold but a group of that emission unit type might
• How to Report Grouped Emission Units o Include number of units being grouped in name o Fugitive release point includes total area of all units and the average height. o Process rates, operating hours, design capacity, should be reported as an average. o Actual emissions determined by actual process rates of each unit not an average rate
67 Other Calculation Methods
• Modeling software • Formulas • CEMS
• Mass balance calculations o Like above or use Emission Factor if only one factor
68 Other Calculation Methods
Portable Electrochemical Analyzer (PEA) Tests
o PEA Tests are performed quarterly or semi- annually for oil and gas facilities with general permits.
o PEA tests generally only test NOx and CO. If VOC is also tested at each PEA test for that inventory period , VOC emissions can be calculate using PEA testing for that inventory year.
o Utilize a weighted average to calculated the emissions. Apply the quarterly emission factor to hours for the previous quarter. Then add the results of the four quarters together.
o Do not average the quarterly emission factors together and multiply by the total hours of operation
o http://www.deq.state.ok.us/aqdnew/permitting/AdviceDocument s.htm
69
Control Information
• Control Device/ Scenario: The control system, abatement equipment, or approach applied to reduce emissions of the pollutant.
• Capture Efficiency: The percentage of air emission that is directed to the control equipment
• Control Efficiency: The amount of actual air emissions prevented from being emitted by the control scenario. The actual efficiency should reflect maintenance degradation
70 71 Emissions
Emission Info: Pollutants, Calculation Method, Emission Factor and Units, Control Device, Capture Efficiency, Control efficiency, Actual emissions, Excess Emissions, Permit Rule Limit 72 73 Emission Inventory Guidance and Updates
Carrie Schroeder Emissions Inventory Manager
Emissions Inventory Workshop January 23, 2019 & January 30, 2019 Norman, OK Tulsa, OK Update Presentation Objectives
• Permit by Rule Reporting • SLEIS • Oil and Gas Facility Categories
Permit by Rule (PBR) Reporting
Inventory Reporting
• Facilities under individual minor source/major source permits and General Permits must report an inventory every year • Facilities under Permit by Rule are on a reduced reporting frequency o When PBR facilities do report, it is an annual inventory like everyone else. It is NOT a multi-year inventory.
Permit by Rule Facilities
• New facilities registered under a PBR must submit an inventory for the first year that they are registered
• Thereafter PBR facilities must submit: • > 5 Ton/year of any Regulated Air Pollutant (RAP) – every National Emission Inventory (NEI) three-year cycle (next is 2020, 2023) • ≤ 5 Ton/year of any RAP – every second NEI three-year cycle (next is 2020, 2026) PBR Reporting Schedule
Facility A: Facility registered under PBR in 2018 10 Tons of NOx reported for 2018 8 Tons of NOx emitted in 2020 – All facilities report regardless of amount of emissions emitted
PBR Permit issued: 2020 NEI: All PBR Facilities report 2/1/2018
2017 2018 2019 2020 2021 2022 2023
2023 NEI: PBR Facility must Facilities With report initial Emissions > 5TPY inventory
PBR Reporting Schedule
Facility B: 10 Tons of VOC reported for 2015 4.5 Tons of VOC emitted in 2017 – Did Not Report Report again for 2020 – All facilities report
2017 NEI: Determine 2020 NEI: All PBR Permit: issued reporting PBR 2026 NEI: All 1/1/2015 schedule Facilities PBR Facilities
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 Transitioning to a new Permit Mid -Year General Permit PBR • For inventory purposes, considered to have a general permit for the year and will need to submit an inventory • Facility will not be required to submit an inventory the following year as a PBR, unless it is a triennial reporting year (2020, 2023, etc.) • Contact EI to determine on a case-by-case basis if the facility can be considered PBR during the transition year PBR General Permit • Considered to have a general permit for the year and will need to submit an inventory 2018 Permit by Rule
• PBRs that have already submitted their initial inventory will not be loaded into Redbud for 2018 reporting unless requested by the company
SLEIS Updates Emissions Inventory Reporting System
DEQ developed the current Redbud reporting tool in- house.
It was first implemented in 2005.
DEQ has recently purchased SLEIS (State and Local Emissions Inventory System) from Windsor Solutions to replace Redbud. Emissions Inventory Reporting System Why SLEIS?
• SLEIS is currently used by several other states • SLEIS will include cross-browser compatibility • SLEIS has the ability to accept emissions data through spreadsheet upload • Companies can submit inventory amendments though SLEIS • SLEIS provides a streamlined process for DEQ to use in submitting data to the EPA.
Emissions Inventory Reporting System What’s next? Going forward: • Configuration, migration and customizations are estimated to be completed in the late spring of 2019
• Customization requested:
Ability to submit all or a subset of a company’s facilities - SLEIS “out of the box” requires each facility to be submitted individually Ability to download spreadsheets for all or a subset of a company’s facilities - SLEIS “out of the box” only has the spreadsheet download/upload function for one facility at a time
• After customizations are in place, DEQ must test the software
Emissions Inventory Reporting System
When will industry report using SLEIS?
• Deployment of SLEIS will only be possible when customization and testing are complete.
• If we implement the customizations in 2019, and testing goes smoothly, SLEIS will be used for the 2019 reporting season. Emissions Inventory Reporting System What kind of training will there be?
• We plan to offer training during our normal annual workshops Sites include Norman and Tulsa, Oklahoma Normally offered in late January/early February. We anticipate this to still be the case.
Emissions Inventory Reporting System Want training now?
• Iowa Department of Natural Resources has developed training videos you may view for an introduction to SLEIS http://www.iowadnr.gov/Environmental- Protection/Air-Quality/eAirServices/eAirServices- Online-Training Please remember we will have customizations and different data sets so our system will differ some Oil and Gas Facility Categories
Types of Oil and Gas Facilities
• O&NG – Well Site • Production Tank Battery/Central Distribution Point • Produced Water Injection • NG – Gathering Compressor Station • NG – Treatment Without Compression • NG Plant – NGL Extraction and/or Fractionation • NG – Transmission Compressor Station • NG – Storage Facility • Oil – Pipeline Breakout Facility/Truck Station • Oil – Tank Farm • Oil/NGL/Refined Petroleum – Pipeline Pump Station • Oil Refinery • Refined Petroleum – Product Terminal • Oil/NG/NGL – Other
Oil and Gas Facilities
• Emissions from the oil and gas sector constitutes a greater percentage of air emissions in Oklahoma than any other sector.
• It is critical to have the best possible data concerning facilities and emissions in this sector.
• The DEQ’s annual point source inventory is a more accurate representation of facility emissions than estimates provided by the area tool.
• Beginning with the 2019 inventory submitted in SLEIS, please classify each of your oil and gas facilities. The facility category will not be required to be completed in the 2018 inventory.
I will now confront your most
challenging questions!
Emissions Calculations Grant Loney Introduction
• Q: What is an Air Emissions Inventory
• A: It is a report describing a facility. It provides detailed information about equipment and activities that release emissions, the processes that occur at these equipment, and quantities of emissions. Outline
• Overview and General Equation • Calculation of CO, NOx, and Benzene from an Emergency Engine • Calculation of Total VOC and Formaldehyde from a Compressor Engine • Calculation of PM-10 and PM-2.5 from Grain Receiving • Calculation of PM-10 and PM-2.5 from a Limestone Conveyor • Calculation of PM-10 and Hexavalent Chromium from Shielded Metal Arc Welding • Calculation of VOC and Xylenes from a Paint Booth
General Equation
푨 × 퐄퐅 = 푬
A is Activity Rate EF is Emission Factor E is calculated Emission
All three have units! Overview of General Equation
푨 × 푬푭 = 푬 A is Activity Rate
Activity Rate refers to the amount of the activity that occurs in a given year that is associated with emissions. Examples include: • Million standard cubic feet of gas burned by an engine • Vehicle miles travelled on a dirt road • Barrels of hydrocarbon in a storage tank • Gallons of paint used in a spray booth • Tons of rock crushed • And many more…
Overview of General Equation
푨 × 푬푭 = 푬 EF is Emission Factor
Calculation Methods • Continuous Emission Monitoring System Use the most accurate (CEMS) Emission Factor • EPA RM Stack Test available to you! • Similar Unit EPA RM Stack Test • Manufacture Test Data • Process Simulation Software Relative Accuracy Relative • Mass Balance • AP-42 or other EPA Documents Overview of General Equation
퐀 × 퐄퐅 = 퐄 E is for Calculated Emissions
• Calculated Emissions will always be reported in units of tons.
• The correct Emission Factor and a little bit of unit analysis will help you get from the units of the Activity Rate to tons. Emergency Engine
• Activity Information: • Source Classification Code: 20200102 • Process Material: Diesel Fuel • Process Rate: 500 gallons • Annual Hours of Operation: 50 • Design Capacity (if applicable): 400 hp • Fuel Data (if applicable): 140 MMbtu/1,000 gal • Control Scenario (if applicable): none Emergency Engine
• Relevant Emission Factors • Carbon Monoxide (CO):1.3E2 Lb per 1000 gallons=130 pounds/1,000 gal • Nitrogen Oxides (NOx): 6.04E2 Lb per 1000 gallons=604 pounds/1,000 gal • Benzene: 9.33E-4 Lb per Million BTUs=0.000933 pounds/MMBTU
https://cfpub.epa.gov/webfire/index.cfm?action=fire.SearchEmissionFactors Emergency Engine
Carbon Monoxide Calculation
Process Rate Emission Factor Convert to tons (i.e. throughput)
500 gallons 130 pounds 1 ton 0.0325 tons 1,000 gallons 2,000 pounds Emergency Engine
• NOx Calculation
500 gallons 604 pounds 1 ton 0.151 tons 1,000 gallons 2,000 pounds Emergency Engine • Benzene Calculation
Fuel Data (i.e. fuel heat content)
500 gallons 140 MMBTU 0.000933 pounds 1 ton 0.000033 tons 1,000 gallons 1 MMBTU 2,000 pounds Total VOC from Compressor Engine Activity Information • SCC: 20200254 • Process Material: Natural Gas • Annual Process Rate: 115 MMscf • Annual Hours of Operation: 8,760 • Design Capacity: 1,380 hp • Fuel Data: 1,020 MMBtu/MMscf • Control Scenario: Oxidation Catalyst (100% capture, 50% control)
Total VOC-Potential EF Problems • Emission factor for Total VOC obtained from a Stack Test using Method 25A • Methods 18 and 25A are known to not detect formaldehyde, which is a VOC. Because of this you must add a formaldehyde emission factor to the factor generated by the stack test when calculating Total VOC. • Total VOC factor from Stack Test: 0.15 grams/horsepower-hour • Formaldehyde factor from Manufacturer data: 0.44 g/hp-hr
Don’t forget to apply Control Scenario! Apply Control Scenario
• Formaldehyde factor from Manufacturer data: 0.44 g/hp-hr • Control Scenario: 100% capture, 50% control • Formaldehyde factor with control: 0.44 g/hp-hr x (1-(100% x 50%))=0.22 g/hp-hr
• Combined Factor to be used for calculations: 0.15+0.22=0.37 g/hp-hr
Total VOC from Compressor Engine
1380 hp 8,760 hours 0.37 grams 1 ton 4.93 tons Total VOC 1 hp-hr 907,185 grams
*Remember, as with all VOC HAPs, formaldehyde should be reported individually, AND as part of Total VOC
1380 hp 8,760 hours 0.22 grams 1 ton 2.932 tons formaldehyde 1 hp-hr 907,185 grams PM from Grain Receiving
Activity Information • SCC: 30500552 • Process Material: Grain • Annual Process Rate: 260,816 tons • Hours of Operation: 932 • Control Scenario: Baghouse
Emission Factors and Control Equipment
PM-10: 0.0078 lbs/ton PM-2.5: 0.0013 lbs/ton
Control Device: Baghouse Capture Efficiency: 100% Control Efficiency: 90% PM from Grain Receiving
260,816 tons 0.0078 pounds 1 ton 1.017 tons PM-10 1 ton 2,000 pounds
260,816 tons 0.0013 pounds 1 ton 0.1695 tons PM-2.5 1 ton 2,000 pounds
We’re not done yet! Don’t forget to apply the Control Scenario! Apply Control Scenario Uncontrolled PM-10 Emissions = 1.017 tons Uncontrolled PM-2.5 Emission = 0.1695 tons Control Scenario: 100% Capture; 90% Control
Reportable PM-10 Emissions: 1.017 * (1-(100%*90%)) = 1.017*0.1 = 0.102 tons Reportable PM-2.5 Emissions: 0.1695 * (1-(100%*90%)) = 0.1695*0.1 = 0.017 tons PM from Limestone Conveyor
Activity Information • SCC: 30510105 • Process Material: Limestone • Annual Process Rate: 21,045,219 tons • Hours of Operation: 6,782 • Control Scenario: Dust Suppression Relevant Emission Factor
• PM-10: 0.000046 pounds per ton • PM-2.5: 0.000013 pounds per ton • From AP-42 11.19 • Both of these are Controlled Factors.
Do I need to apply my Control Scenario? PM from Limestone Conveyor
21,045,219 tons 0.000046 pounds 1 ton 0.484 tons PM-10 1 ton 2,000 pounds
21,045,219 tons 0.000013 pounds 1 ton 0.137 tons PM-2.5 1 ton 2,000 pounds Notes About PM
PM-2.5 is a subset of PM-10. This means: 1. PM-10 will ALWAYS be greater than or equal to PM-2.5 2. If PM-2.5 is reported, PM-10 MUST also be reported.
PM-10
PM- 2.5 PM-10 and Chromium (VI) from Welding Activity Information • SCC: 30905120 • Process Material: Shielded Metal Arc Welding Electrode E316 • Annual Process Rate: 27,000 pounds • Hours of Operation: 1820 • Control Scenario: Uncontrolled
Relevant Emission Factors
• PM-10: 10 lbs/1,000 lbs
• Chromium (VI): 0.332 lbs/1,000 lbs
• Factors from AP-42 12.19
PM-10 and Chromium from SMAW Welding
27,000 pounds 10 pounds 1 ton 0.135 tons PM-10 1,000 pounds 2,000 pounds
27,000 pounds 0.332 pounds 1 ton 0.004 tons Chromium VI 1,000 pounds 2,000 pounds
Based only on the reporting threshold, which of these two emissions am I required to report? Total VOC and Xylenes from Paint Booth
• Activity Information: • Source Classification Code: 40200101 • Process Material: ZINC CLAD Epoxy Primer • Process Rate: 800 gallons • Hours Process Occurred: 2,080 • Control Scenario (if applicable): none
VOC and Xylenes from Paint Booth
800 gallons 4.73 pounds 1 ton 1.892 tons Total VOC 1 gallon 2,000 pounds
800 gallons 7.85 pounds 0.12 pounds 1 ton 0.377 tons Xylenes 1 gallon 1 pound 2,000 pounds
Product Weight Percent Xylenes *N/A-Formula, Software, or CEMS
• Used when a single emission factor is not used to calculate emissions • Emission Factor must be reported as zero • Examples of when to use: • When this emission unit has a CEMS • Software packages that require multiple variables to be entered • Ex) TANKS, GRI-GLYCalc, ProMax, etc. • When multiple emission factors are used • Ex) multiple paints with different VOC content in the same paint booth • When a complex formula is used to calculate emissions
Helpful Documents and Links
• DEQ Permitting Advice Documents http://www.deq.state.ok.us/aqdnew/permitting/AdviceDocuments.htm
• EPA WebFIRE https://cfpub.epa.gov/webfire/
• EPA SCC Search https://ofmpub.epa.gov/sccwebservices/sccsearch/
• Your Permit/Permit Application Questions?
• Ask now or contact us at: • [email protected] -common inbox for Emissions Inventory Section
• (405) 702-4100 –Air Quality Front Desk QUALITY CONTROL AND TOP MISTAKES
MICHAEL KETCHAM ENVIRONMENTAL PROGRAMS SPECIALIST, AQD
EMISSIONS INVENTORY WORKSHOP JANUARY 23, 2019: NORMAN, OK JANUARY 30, 2019: TULSA, OK
129 QC GOAL
Our goal is to be able to provide the most accurate data to EPA
• Generally we should be able to replicate your emissions with the information provided.
• The most accurate information available at the time of submittal should be used.
130 OVERVIEW
• Cannot Replicate Emission Calculation • Total VOC less than sum of individual Hazardous Air Pollutants (HAPs) • Control Devices • Inconsistencies • Guidance
131
EMISSION CALCULATION ISSUES
132 CANNOT REPLICATE CALCULATION DUE TO UNITS
For most emission units, the throughput units and emission factor units should match.
• MMBTU – MMSCF • Fuel heat content should be provided for conversion • Due to the similar abbreviations it’s easy to choose the wrong unit • Horsepower-Hours • Provide design capacity • Horsepower-hours should not be used as a throughput unit.
133
Throughput & emission factor units do not match.
134 SIGNIFICANT CHANGE IN EMISSIONS FROM PREVIOUS REPORTING YEAR
• Often, we see emissions at an emission unit increase or decrease significantly without any significant changes in throughput or operating time • Excess Emission should be reported in the Emission Inventory • We email companies to verify that the emissions are accurate and if so to explain the change in emissions • Often typos are encountered in this check • Providing a detailed emission unit note helps us validate these situations! 135 “DEQ APPROVED METHOD”
• DEQ Approved Method should only be selected if no other calculation method is applicable • Inappropriately selecting “DEQ Approved method” creates instances where it is difficult to replicate the emission calculation • An emission unit note or calculation method reference should be added to instances where “DEQ Approved Method” is chosen • Remember, you have to get DEQ approval before selecting DEQ Approved Method! 136 TOTAL VOC & HAPS
137 HAPS AND VOC
• Volatile Organic Compounds (VOCs) are organic compounds that contain carbon and react in the presence of sunlight with NOx to form ozone
• Hazardous Air Pollutants (HAPs) are a compound that has been included on EPA’s list of 187 pollutants that can have a detrimental effect on humans and the environment. • Many HAPs are also VOCs • Both HAPs and Total VOC must be reported • You will not be double billed
138 HAPS AND VOC (CONT.)
• Total VOC amount should be greater than or equal to the total of the individual HAPs • BTEX pollutants are HAPs and VOCs • BTEX = Benzene, Toluene, Ethylbenzene, & Xylenes
139 FORMALDEHYDE EMISSIONS AT NSPS JJJJ ENGINES
• JJJJ emission factors can cause issues with calculating both Formaldehyde & Total VOC emissions.
• Many manufacturer’s emission factors are developed using EPA Test Method 25A • Method 25A is used to demonstrate JJJJ compliance • The method poorly detects formaldehyde • Formaldehyde emission factor often not provided by manufacture
140 FORMALDEHYDE EMISSIONS AT NSPS JJJJ ENGINES
• Possible Solution • Add the formaldehyde AP-42 emission factor to the Total VOC emission factor to create a larger Total VOC emission amount. • When using an AP-42 factor for Formaldehyde, make sure that HAPs are less than or equal to Total VOC!
141 MANUFACTURE DATA WITH FORMALDEHYDE EMISSION FACTOR PROVIDED
Manufacture data without formaldehyde emission factor provided
142 TOTAL VOC EMISSIONS AT NSPS JJJJ ENGINES
• Some engines subject to EPA NSPS give limits in g/kW-hr hydrocarbons. • Example: NSPS, Subpart JJJJ establishes requirements for manufacturers that are based on new nonroad spark ignition (SI) engine rules in 40 CFR part 90 or 1054 • These emission factors combine NOx & Total VOC • Please use separate factors for NOx & Total VOC • If there is no manufacture’s factor for Total VOC, use an AP-42 factor. 143 • Calculation Method Refernece note indicates that a combined NOx/HC factor has been used. • Creates a problem because Formaldehyde (subset of Total VOC) is now greater than Total VOC.
144 INCONSISTENT REPORTING
145 REPORTING CONTROL DEVICES
• 100% control efficiency in combination with 100% capture efficiency should not be selected when emissions are also reported • If both are reported as 100% there would be no emissions • One or both must be less than 100% • Ensure that control equipment and efficiencies apply to the pollutant on which they are reported. • Fabric filters and baghouses control PM. • Catalytic converters control CO, VOCs, and/or NOx. • Catalytic oxidizers control CO and VOCs. • Leave an emission unit note for special circumstances.
146 CONTROLS
Control Efficiencies • Does your emission factor include the control efficiency? • Don’t underestimate emissions!
147 INCONSISTENT STATUS The Operating Status for the emission unit and emission release point should match.
148 INCONSISTENT STATUS
If an emission unit is Operating… • annual process rate and annual operating hours cannot be “0.”
If an emission unit is Temporarily/Permanently Shutdown… • annual process rate, annual operating hours, and annual emissions must all be “0.”
If the equipment ran more than 0 hours at any point in the year status must be Operating!!
149 REPORTING THE SAME THROUGHPUT, ANNUAL HOURS, AND EMISSIONS AS THE PREVIOUS YEAR
• For most emission units the throughput, annual hours, and emissions should vary from year to year. • Emissions may be quite similar but not exact
• Some emission units like emergency engines that are tested on a regular schedule may have the same values 150
REPORTING GUIDANCE
151 REPORTING GUIDANCE
• Produced Water Tank emissions
• Reporting Downtime for CEMS
• How to Group Emission Units
• New Facility & Collocated Facility Equipment
152 PRODUCED WATER TANK EMISSIONS
• Permits may not reference produced water tanks • If emissions are greater than 0.1 tons, the produced water emissions must be reported • To calculate produced water emissions: • The volume of produced water can be entered into the TANKS program as if it was condensate/crude oil. • One percent of the resultant value can be utilized as the produced water emissions.
153 REPORTING DOWNTIME FOR CONTINUOUS EMISSIONS MONITORING SYSTEMS (CEMS)
• Downtime must be accounted for! • For most electric generating facilities, the appropriate methodology to account for downtime is found in 40 CFR Part 75. • For non-electric generating and low mass emitting electric generating facilities please contact the EI Section for assistance. • Generally an average of emission before and after the downtime event could be utilized to account for downtime emissions 154 GROUPING EMISSION UNITS
• Some small sources of emissions should be logically grouped into one source • An individual emission unit may not have emissions above the reporting threshold but a group of that emission unit type might
155 GROUPING EMISSION UNITS
• How to Report Grouped Emission Units • Include number of units being grouped in name • Fugitive release point includes total area of all units and the average height. • Process rates, operating hours, design capacity, should be reported as an average. • Actual emissions determined by actual process rates of each unit, not an average rate
156 NEW FACILITY & COLLOCATED FACILITY EQUIPMENT
• Create a new emission unit for all new equipment, including like-for-like engine swaps. • Emission units from a collocated facility are not transferred to the new facility, therefore new emission units should be created. • This allows a historical record of equipment.
157 YOUR INVENTORY IS IMPORTANT!
Why?
• Missing or incorrect release point data leads to errors in geographical location of emissions and impacts photochemical modeling and health risk assessments.
• Missing or incorrect hours and season fractions lead to errors in temporal distribution of emissions.
• Errors in SCCs and SICs impact control strategy development and attainment plans.
• Missing or incorrect control equipment data impacts rule development.
• Good data leads to effective air quality regulation! 158 QUESTIONS??
BREAK TIME!!
159