Transcript www.deq.state.ok.us

Frequent
Errors
by Carrie Schroeder
Areas of Discussion
1. Facility Status Changes
2. Substituting or Removing Equipment
3. Source Classification Codes
4. Hours as Process Rate
5. Units
6. Inconsistent Reporting
7. Fuel Heat Content
8. Controls
9. Emission Factors
10. Hazardous Air Pollutants (HAPs)
11. Redbud Submissions
12. Signed Documents
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#1
Facility Status Changes
• If you have had no activity, change status to Closed
or Idle.
• Enter a facility note!!!
• If you have existing emission units, you will need to
change them to Idle.
• We will reset Facility Status to Active for the next
year so we can get a yearly status verification.
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#2
Equipment
Substitutions
• Create a new emission unit for any new or substitute
equipment.
• Update the old emission unit’s status.
• Inspectors will compare Serial #s with permit serial
#s.
• Your emission inventory is a history of all equipment
at your facilities.
• Permanently Shutdown equipment will be removed
from Redbud for the next reporting year.
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#2
Removed Equipment
• If equipment had no emissions in the year and has
been removed, simply change status to
Permanently Shutdown.
• Permanently Shutdown equipment will be removed
from Redbud for the next reporting year.
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#3
Codes
Source Classification
(SCC)
• The SCC describes an emission process or activity.
• Avoid xxxxxx99 Miscellaneous processes.
• Watch for Industrial versus
Commercial/Institutional.
• Refinery vs. Nonrefinery SCCs
• Only use 20200252-3-4 for Industrial natural gas
burning engines.
2 - Internal Combustion Engines
02 - Internal Combustion Engines, Industrial
002 - Internal Combustion Engines, Industrial, Natural Gas
54 - Internal Combustion Engines, Industrial, Natural Gas, 4-cycle Lean Burn
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#4
Hours as Process Rate
• We find hours per year entered as a process rate.
• Process rate is a measurable quantity that relates to the
emissions of an air pollution source.
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#4
Hours as Process Rate
• Actual Annual (activity) should be expressed as fuel combusted,
raw material processed or product manufactured or handled.
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#5
Units
• Double check that the units in Redbud are
still accurate.
• Check:
– process rate units
– emission factor units
• We can’t replicate your emissions if the units
are incorrect.
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#6
Inconsistent Reporting
• Emissions reported but have 0 for process rate
and/or 0 for annual hours.
OR
• Process rate reported and/or annual hours reported
but emissions are 0 and trace boxes are not
checked.
• We expect:
– If the emission unit is
rate AND >0 hours AND >0 emissions.
then, >0 process
– If the emission unit is
or
then, 0 process rate AND 0 hours AND 0 emissions.
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#7
Fuel Heat Content
• When burning well or landfill gas report the true
mmbtu per mmscf.
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#8
Control
Efficiencies
• Does your emission factor include the Control
Efficiency?
• Then don’t forget to check the box!
• Also add your control equipment type and efficiencies.
• If factor includes efficiencies, do not double count by
including the efficiency again in emission calculations.
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#8
Control Equipment
• Listing controls and efficiencies that do not apply to
that pollutant.
o Fabric filters and baghouses only control PM
o Catalytic converters control CO, VOCs and/or NOx
o Catalytic oxidizers control CO and VOCs
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#9
Emission Factors
• Where did they come from?
• How old are they?
• If you changed it in your spreadsheet, make sure to
change it in Redbud
• Document where you got the emission factor
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#9 Emission Factors - Methods
Approximate Ranking of Reliability:
Continuous Emissions Monitoring Data (CEMS)
EPA RM Stack Test
Similar Unit EPA RM Test
Mass Balance
Manufacture Test Data
TANKS, GRI-GLYCalc, Vasquez-Beggs
Fire Data Factors
AP42, EPA Documents
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#10
Hazardous Air Pollutants
(HAPs)
• Are they also VOCs?
• Speciate your HAPs out of your VOCs.
• Report remaining VOCs as
• Don’t double count.
• We often see this error on compressor engines.
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#11
Redbud Submissions
• If you have made a submission and then change
data, you have to resubmit.
• You can make as many submissions as you want up
to the reporting deadline; the final submission is the
keeper.
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#12
Signed Documents
• What needs an original signature?
– Hardcopy emissions inventory (certification page)
– Amended emissions inventory (certification page)
– Responsible Official change letter/form #100-882
• Delivered by mail or in person.
• Faxed/Emailed document can not be accepted in
lieu of the signed original.
• Redbud submissions do not require a signed
certification. Our password system serves as an
official electronic signature.
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Why Your Inventory Is Important
• 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 SCC and SIC impact control strategy
development and attainment plans.
• Missing or incorrect control equipment data impacts
rule development.
• Good data leads to effective air quality regulation.
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Any Questions?
If you have questions, call us
and/or
make an appointment to visit us for
assistance.
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