General Issues & Reporting Guidance

Transcription

1 General Issues & Reporting Guidance Emissions Inventory Workshop 2015

2 Topics to Discuss Reporting Total VOC plus HAPs What Facilities Have to Report Lower Reporting Cut-Off Guidance Pneumatic Devices Control Classification Changes API Well Number Redbud Improvements General Reporting Issues Emissions Inventory Workshop

3 Reporting VOC Emissions Inventory Workshop

4 Important Change for Reporting VOC in 2014 Gone from reporting Speciated HAPs plus VOC (non-hap) to Total VOC (including HAPs) plus Speciated HAPs Should reduce errors and confusion Consistency with most published emission factors Oklahoma Clean Air Act does not allow doublebilling for pollutants in multiple categories Invoices will charge for VOC (non-hap) and HAPs Emissions Inventory Workshop

5 What Facilities Have to Report for 2014? Emissions Inventory Workshop

6 More Facilities to be Inventoried RY ,533 Facilities 5% 1% 3% 10% 4% 10% 10% 54% RY ,941 Facilities 3% 5% 2% 1% 1% 2% 13% 2% 5% 69% 6

7 Who is Required to File an Inventory? The owner or operator of any facility that is a source of Regulated Air Pollutants Facilities that have or should have an Air Permit Facilities operating prior to receiving their operating permit Permit by Rule: All facilities for 2014 Every 3 or 6 years thereafter Special Inventories upon request by the AQD Director Emissions Inventory Workshop

8 Who is Not Required to File an Inventory? De Minimis Facilities Permit Exempt Facilities Except when the facility status changed during the year due to equipment removal Facilities subject to OOOO for flowback only Let us know if you believe a facility should be removed from Redbud Emissions Inventory Workshop

9 Permit by Rule (PBR) Facilities All PBR facilities that were registered by 12/31/2014 must submit an inventory for 2014 New PBR facilities must submit an inventory for the first year that they are registered Thereafter PBR facilities must submit: > 5 Ton/year of any RAP every NEI three-year cycle (next due in 2017) 5 Ton/year of any RAP every second NEI three-year cycle (next due in 2020) Emissions Inventory Workshop

10 Permit by Rule (PBR) Facilities PBR facilities will be first invoiced for Annual Operating Fees in 2016 based on CY 2014 emissions Annual Operating Fees will be based on the most recently reported annual inventory thereafter PBR facilities may submit a more recent inventory if production has decreased Emissions Inventory Workshop

11 Lower Emission Amount Reporting Guidance Emissions Inventory Workshop

12 Lower Emission Amount Reporting Guidance There is no lower reporting limit in SC-5 AQD provides reporting guidance that is prudent & practical Our current guidance is that emissions of 0.1 tons or greater of any regulated air pollutant at a process must be reported There are certain key exceptions Emissions Inventory Workshop

13 Lower Emission Amount Reporting Guidance Emissions must still be reported at tons or greater per process for: Lead, mercury & hexavalent chromium Any HAP at a facility that is also reported to the TRI Any HAP from glycol dehydration still vents Any HAP from large storage tanks (>500 BBL) Other situations where deemed necessary Emissions Inventory Workshop

14 Lower Emission Amount Reporting Guidance You can still continue to report down to tons per process if you choose to The Trace Checkbox is still available for <0.001 tons if you wish to use this Contact us to discuss removing unnecessary pollutants that may still be in your inventory Emissions Inventory Workshop

15 Removal of Unnecessary Emission Records For 2014 reporting, many HAP, PM & SOx records have been removed from major external & internal combustion processes Where emission amounts would be less than 0.1 TPY in normal operation Based on design capacity & installed controls Emissions Inventory Workshop

16 Pneumatic Devices Emissions Inventory Workshop

17 Pneumatic Devices Pneumatic devices were previously identified as potentially significant sources at Oil & Gas production facilities DEQ had considered requiring these devices to be reported individually for 2014 Focus of considerable research & discussion in the last year Emissions Inventory Workshop

18 Pneumatic Devices OIPA, GPA & major operators conducted surveys & provided DEQ with detailed data This has significantly expanded our understanding of the characteristics & distributions of these devices Consequently, DEQ will not be requiring pneumatic controllers to be reported as part of annual inventories from production or midstream facilities at this time Emissions Inventory Workshop

19 Changes to Control Classifications Emissions Inventory Workshop

20 Control Classifications EPA has made substantial changes to the list of valid control devices & practices 85 selections retired & 8 new control types added We have replaced invalid selections Please verify that any new assignments in your inventory are correct Emissions Inventory Workshop

21 Control Classifications Thermal Oxidizer changed to: Recuperative Thermal Oxidizer or Regenerative Thermal Oxidizer Fabric Filter Temperature Dependent Fabric Filter High Temp > 250 F Fabric Filter Medium Temp 180 F<T<250 F Fabric Filter Low Temp < 180 F All Changed to Fabric Filter/Baghouse Please contact us if you can t find an appropriate valid selection to describe your control Emissions Inventory Workshop

22 API Well Numbers Emissions Inventory Workshop

23 API Well Numbers API Well Numbers are needed for oil & gas wellhead facilities Crucial for accurately apportioning point & area emissions in the 2014 National Emissions Inventory (NEI) We have added numbers where already reported to DEQ (e.g., from OOOO notifications & PBR applications) Please use the Redbud Facility Memo field to enter or revise API Well Numbers Emissions Inventory Workshop

24 Redbud Improvements Emissions Inventory Workshop

25 Redbud Improvements No changes to structure, layout or validation TAD generation now much faster Can now print a Final Submission TAD for an individual facility New Logout Feature Emissions Inventory Workshop

26 General Reporting Issues Emissions Inventory Workshop

27 Owner/Operator Responsibilities The owner or operator of any facility that is a source of regulated air pollutants shall submit a complete annual emission inventory through DEQ s electronic reporting system or in another manner acceptable by the Division. This means the current owner/operator has to file the complete 2014 annual inventory by April 1, 2015 Emissions Inventory Workshop

28 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. Emissions Inventory Workshop

29 Change of Ownership What this means for the new owner: Responsibilities transfer unless explicitly stated in contract or sale agreement New owner is responsible for providing the complete year s inventory - Even if sale took place within the reporting year Emissions Inventory Workshop

30 Changing Facility Information Form # Emissions Inventory Workshop

31 Changing a Responsible Official Form # Emissions Inventory Workshop

32 Changing a Main Facility Contact Inventory questions are initially presented to the Main Facility Contact Changes can be made by ing the EI section with the name, title, address & contact information. A form is not necessarily required. Updates can also be submitted though the Redbud facility memo field Emissions Inventory Workshop

33 Operating Statuses Emissions Inventory Workshop

34 Facility Status If inactive last year, has been preset to Active for the new Reporting Year Facility operating status must be verified yearly If the facility was active at any time, status is Active for that Reporting Year Emissions Inventory Workshop

35 Facility Status Not yet built Status E.g., permit applied for in 2014 but construction has not yet started Add a brief facility note if necessary Exempt or De Minimis facilities must be removed completely from Redbud Please contact us to do so Emissions Inventory Workshop

36 Emission Unit Status Operating & Temporarily Shutdown: Remains in your inventory next year Permanently Shutdown: Drops out from your inventory next year Example: Emission unit operated through June 2013 then physically removed from the facility in September 2013 Status for 2013 Operating Status for 2014 Permanently Shutdown Status for 2015 Not in inventory Emissions Inventory Workshop

37 Emission Unit Status Report only what was at the facility during the Reporting Year Should be there for all or at least part of the calendar year Don t leave removed emission units as idle, change unit status to permanently shutdown Don t add emission units to your inventory before they have been installed Emissions Inventory Workshop

38 Replacement Equipment Don t change the existing unit Create a new emission unit Report data for original & replacement equipment separately Include notes explaining the situation at both units Report original equipment as permanently shutdown the next year. It will then drop out of the inventory in the second year. Emissions Inventory Workshop

39 Ensure Data is Consistent If Emission Unit Status = Active Operating Hours should be > 0 Process Rates should be > 0 At least some emissions would normally be reported Emissions Inventory Workshop

40 Storage Tank Emissions Emissions released from the bottom of a tank that has no throughput must be reported Tank would be reported as Active Tanks linked together can be reported as a single emission unit Combined SCC (working + breathing + flashing) may be used for condensate tanks with < 6 ton per year total VOC emissions Create new process if changing to SCC Don t change the SCC at an existing process. Emissions Inventory Workshop

41 Inventory Corrections During the reporting season, corrections to the current reporting year are accomplished by making changes in Redbud & resubmitting Last submission overwrites any earlier ones Redbud submissions do not need a signature Corrections after the reporting season can not be entered in Redbud You can still download your Turnaround Document (TAD) at any time Corrections should be marked up in your TAD on a hardcopy of Emissions Inventory Workshop

42 Certifying Corrections Corrections must be certified by the Responsible Official with an original signature & mailed to our office There is a signature page at the end of the Redbud TAD that can be used in these circumstances Emissions Inventory Workshop

43 Redbud Browser Compatibility Redbud is best used with Internet Explorer To correct compatibility problems with IE 10 or IE 11: Select Tools in your Menu Bar, then select compatibility view Add ok.gov to the compatibility view settings More info on Redbud login page Emissions Inventory Workshop

44 Direct Electronic Reporting We have been developing a process for companies with large numbers of similar facilities to directly export from their databases to Redbud Avoids errors when doing data entry in Redbud Not necessarily easy requires significant technical expertise Managing record ID s & referential integrity is crucial We hope to expand this option to companies with large complex facilities in the next few years Emissions Inventory Workshop

45 Last Words 2014 will be an important reporting year Triennial NEI year, likely base year for nonattainment planning Data quality will be vital for developing effective control strategies Get 2014 into the best possible shape now Comprehensive 2014 inventory of Oil & Gas area and point sources will be critical Emissions Inventory Workshop

46 Questions? General Inquiries (405) Mark Gibbs (405) Michelle Horn (405) Joshua Kalfas (405) Cecelia Kleman (405) Chris Laley (405) Cody Lathrop (405) Carrie Schroeder (405) Emissions Inventory Workshop

47 Thanks for Coming Today Please complete the feedback form before you leave Emissions Inventory Workshop