Transcript Using Your Permit to Create anEmissions Inventory

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Submit by Mail
Completed
Emission
Inventory
Submitted to
DEQ
Submit Electronically
Hardcopy
TAD
Air Permit
Data
Redbud
Webfire &
AP-42 Data
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Operation &
Production
Information
Other Data
Sources
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I.
II.
III .
IV.
V.
VI.
VII.
VIII.
IX.
FACILITY DESCRIPTION
PROCESS DESCRIPTION
EQUIPMENT
AIR EMISSIONS
INSIGNIFICANT ACTIVITIES
OKLAHOMA AIR POLLUTION CONTROL
RULES
FEDERAL REGULATIONS
COMPLIANCE
SUMMARY
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 Permit writer includes initial application data
 Emission calculations and referenced sources
 Normally lists the acceptable Emission Factors
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
Emission Units
 Stack or Fugitive Release Point
 Emission Processes
• Fuel Combustion Data
 Pollutants
• Emission Factors
• Controls
• Emission Limits
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Every emission unit must have:
 At least one emission release point
 At least one process
 If active, one or more pollutants
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–this emission unit operated all or part of the
calendar year (active at anytime during the year)
–this emission unit did not operate at
all during the calendar year, but may restart at sometime in the
future (no emissions during the calendar year).
–select this status if an emission
unit has been removed, removed from service, or is
permanently shutdown (no emissions during the
calendar year).
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Stack
Fugitive
Height above
ground level
Pipe work
Storage Tank
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Minerals
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From Permit:
In Redbud:
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 Description of each process or activity at an
emission unit
 This description is assigned by the SCC
 A single emission unit may have two or
more processes
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Combustion Processes Only
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From Specific Conditions:
From Permit Memorandum:
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 Sulfur %: Mass percentage of the sulfur
content in the process fuel
 Ash %: Mass percentage of the ash
content in the process fuel
 For natural gas in Oklahoma report
sulfur and ash percentages as zero
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
ANY EQUIPMENT that can utilize different
Process Material (coal, wood, natural gas)

CONDENSATE TANKS: if over 5 tons of
emissions – separate breathing, working and
flashing losses. Under 5 tons of emissions,
losses can be combined using SCC
40400311.
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• Pollutant
• Methods of calculation
• Emission factor & units (numerator &
denominator)
• Control equipment
• Permit/Rule limits
• Amount of actual emissions
• Excess emissions
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 Air pollutants for which an ambient air
quality standard has been set
 Based on health and/or environmental
criteria
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Criteria Air Pollutants
Carbon monoxide (CO) Nitrogen oxides (NOx)
Sulfur dioxide (SO2)
Lead (Pb)
Particulate matter (PM) Ozone (O3)
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Defined in OAC 252:100 Appendix P
• Criteria Pollutants
• Hazardous Air Pollutants (HAPs)
• Oklahoma Toxics (Appendix O)
• Other pollutants regulated in OAC 252:100
For more information:
http://www.deq.state.ok.us/aqdnew/emissions/
OklahomaRegulatedAirPollutants.htm
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Two Categories - Dependent on Particle Size
PM-10 and PM-2.5
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PM-10 – all particulate matter with an
aerodynamic diameter equal to or less
than 10 micrometers
PM-2.5 – all particulate matter with an
aerodynamic diameter equal to or less
than 2.5 micrometers
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Amt
PM-10
10
0
Amt
PM-2.5
0
2.5
10
Size (microns)
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 (d)
Method of calculation. The best
available data at the time the emission
inventory is or should have been prepared
shall be used to determine emissions
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An emission factor is a representative value that attempts
to relate the quantity of a pollutant released to the
atmosphere with an activity or process rate associated with
the release of that pollutant.
Emissions = Process Rate x EF
These factors are usually expressed as the weight of
pollutant divided by a unit weight, volume,
distance, or duration of the activity emitting the
pollutant.
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
Storage Tanks - TANKS

Landfills - LANDGEM, a gas emissions model

Tank Flashing - Vasquez-Beggs equation

Glycol Dehydrator Reboiler - GRI-GLYCalc
These are models
with formulas using multiple variables.
There is no single emission factor.
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For the situations on the previous slide and for
complex mass balance calculations enter:
0 * N/A - Formula, Software or CEMS
* N/A - Formula, Software or CEMS
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Paint usage calculation:
In Redbud:
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
Stack testing plus 25% safety factor

AP-42, 7/98, Sec. 1.4 plus 25% safety
factor

Baghouse manufacturer guarantee plus
safety factor
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 AP
42, Fifth Edition
Compilation of Air Pollutant Emission Factors,
Volume 1: Stationary Point and Area Sources
http://www.epa.gov/ttn/chief/ap42/index.html
 WebFIRE
http://cfpub.epa.gov/webfire/index.cfm
 Stack
Testing
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
The percentage of air emissions that
are directed to the control equipment
If emissions escape prior to the
control device, these should be
accounted for in the total actual
emissions amount.
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Actual amount (%) of air emissions
prevented from being emitted by a
control approach
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Report combustion
emissions at a separate
emission unit
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Allowed Emissions (tpy): 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 or
potential to emit, or for grandfathered sources,
emission limits based on maximum design capacity
and considering all applicable rules.
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What should be reported?
All Actual Emissions
not
Permit limits
or
Potential to Emit Values
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Yes, Report the following:
 Quantifiable emissions that are in
excess of a permit or other such limit
• Should include total mass reported under
Subchapter 9 of Oklahoma Air Rules
 However, ALL actual emissions must
be reported in the total emissions field
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Total actual emissions
of 8.465 tons includes
0.124 tons of excess
emissions
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0.124 tons represents
total mass of all hourly
limit exceedances in the
reporting year
The annual limit of
11.74 tons has not been
exceeded
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Look to your PERMIT
to CREATE or REVIEW
your emissions inventory
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The permit memorandum is not the
final word for Emission Inventories
The permit may list some processes as:
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If a process emits pounds or more of a
regulated air pollutant (≥ 0.001 tons)…
…please report these emissions
Trace (<0.001 TPY):
You can use the Trace check box to
indicate annual emissions have been
calculated but are less than
0.001 Tons (2 lbs)
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Your permit is a great resource for
emissions inventory reporting, however, it
may not include all the required
information.
REPORT regulated
pollutants
over 2 pounds
from each process
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Even if permit
considers the process
insignificant
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