Using Your Permit to Create an Emissions Inventory
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Transcript of Using Your Permit to Create an Emissions Inventory
Using Your Permit to Create an
Emissions Inventory
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Emission Inventory Data Flow
Air Permit Data
Webfire & AP-42 Data
Operation & ProductionInformation
Other Data Sources
Completed Emission Inventory
Submitted to DEQ
Redbud Hardcopy
TAD
Submit by Mail Submit Electronically
First Stop -Your Air Permit
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I . FACILITY DESCRIPTION II. PROCESS DESCRIPTIONIII . EQUIPMENTIV. AIR EMISSIONSV. INSIGNIFICANT ACTIVITIESVI. OKLAHOMA AIR POLLUTION CONTROL
RULESVII. FEDERAL REGULATIONSVIII. COMPLIANCEIX. SUMMARY
Permit Memorandum Sections
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Permit writer includes initial application data
Emission calculations and referenced sources
Normally lists the acceptable Emission Factors
Your Permit Memorandum
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Specific Conditions
Types of EmissionInventory Data
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Emissions Inventory Data Structure Emission
Units Stack or Fugitive
Release Point Emission Processes
• Fuel Combustion Data Pollutants
• Emission Factors • Controls• Emission Limits
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Emission Unit
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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Specific Conditions Section
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Emission Unit StatusOperating–this emission unit operated all or part of the calendar year (active at anytime during the year)
Temporarily Shutdown–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).
Permanently Shutdown–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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Emission Release Point Information
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Types of Emissions Release Points
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Stack Fugitive
Height above ground level
Storage Tank
Pipe work
Minerals
For an Emission Release Point
Report Stack or Fugitive Data
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One or the OtherNot Both
Sometimes listed in the Permit
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Fugitive Release PointsFrom Permit:
In Redbud:
Emission Process Information
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Emission Process Information
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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
Fuel Combustion Data
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Combustion Processes Only
Design Capacity
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From Specific Conditions:
From Permit Memorandum:
Fuel Heat Content
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Other Fuel Data
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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Multiple ProcessesWithin an Emission Unit
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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Multiple Processes
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Emissions Information
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Emissions Information
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• Pollutant• Methods of calculation• Emission factor & units (numerator &
denominator)• Control equipment • Permit/Rule limits• Amount of actual emissions• Excess emissions
Criteria Air Pollutants
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Air pollutants for which an ambient air quality standard has been set
Based on health and/or environmental criteria
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
Regulated Air Pollutants
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Particulate Matter
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Two Categories - Dependent on Particle Size
PM-10 and PM-2.5
Particulate Matter
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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
TWO POLLUTANTS to REPORT
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Size (microns)
Amt PM-2.5
2.5 10
Amt PM-10
100
0
252:100-5-2.1. Emission inventory
(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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Emission Factors
What is an Emission Factor?
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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.
Sometimes it is as easy as this…
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Emission Factors are often in your permit
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Is an Emission Factor Needed? 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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No Specific 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
No Specific Emission Factor
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Paint usage calculation:
In Redbud:
Emission Factors with Safety FactorShould Not Be Used
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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Additional EF Sources
AP 42, Fifth EditionCompilation 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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Controls
Controls
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Capture Efficiency % The percentage of air emissions that
are directed to the control equipment
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If emissions escape prior to the control device, these should be accounted for in the total actual emissions amount.
Control Efficiency %
Actual amount (%) of air emissions prevented from being emitted by a control approach
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A Control Device as anEmission Unit
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Report combustion emissions at a separate emission unit
Permit Limits
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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.
Permit Emission Limits
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EmissionsWhat should be reported?
All Actual Emissions not Permit limits or Potential to Emit Values
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Excess Emissions
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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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Do excess emissions need to be included?
Excess Emissions
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Total actual emissions of 8.465 tons includes 0.124 tons of excess emissions
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
Summary ……
Look to your PERMITto CREATE or REVIEWyour emissions inventory
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The permit memorandum is not the final word for Emission Inventories
The permit may list some processes as:
But Beware !
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InsignificantDe Minimis
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Insignificant for Permitting
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Insignificant for permitting, but not for Emission Reporting
But Beware !
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If a process emits 2 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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Remember…
REPORT regulated pollutants
over 2 pounds from each process
Even if permitconsiders the process
insignificant
Your permit is a great resource for emissions inventory reporting, however, it
may not include all the required information.
Call us for help with your inventory
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General Inquiries (405) 702- 4100
Mark Gibbs (405) 702- 4179
Michelle Horn (405) 702- 4176
Justin Milton (405) 702- 4210
Carrie Schroeder (405) 702- 4214
Questions
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