Introduction to Emissions Inventory

Introduction to Emissions Inventory 1 Carrie Schroeder Emissions Inventory Manager Emissions Inventory Workshop January 23, 2018 & January 31, 2018 Norman, OK Tulsa, OK

Contact Information Program Manager: Carrie Schroeder Carrie.Schroeder@deq.ok.gov Emissions Inventory Section Staff: Michelle Horn Michelle.Horn@deq.ok.gov Joshua Kalfas Joshua.Kalfas@deq.ok.gov Roxanne Bueckers Roxanne.Bueckers@deq.ok.gov Shelby Willeby Shelby.Willeby@deq.ok.gov Grant Loney Grant.Loney@deq.ok.gov http://www.deq.state.ok.us/aqdnew/emissions/index.htm 2

Emission Inventory Presentations Introduction Carrie Schroeder Emission Inventory (EI) Basics Grant Loney EI Updates Carrie Schroeder Break Permitting Phil Martin/Lee Warden Emission Calculations Roxanne Bueckers EI Quality Control and Top Mistakes Shelby Willeby Break Live Redbud Demonstration Joshua Kalfas Q&A - staff 3

4 Introduction Presentation Objectives Housekeeping What is an emission inventory? Who is required to file an inventory? When is the emission inventory due? Invoicing, Ownership, and Responsible Officials

5 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 Emission Inventory? 6

7 What Is An Emission Inventory? A report of actual emissions of regulated pollutants during the previous year Provides a description to DEQ of your facility and its operations

8 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

Who is Required to File an Emission Inventory? 9

10 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

The Annual Reporting Cycle 11

12 The Emission Inventory Annual Reporting Cycle 2017 2018 2019 Redbud passwords, TADs dispatched Annual Workshops 30-Day Extension inventories received Invoices based on 2016 data sent out Late invoices sent out EI Section Submission Deadline for 2017 NEI data Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Redbud upload TAD preparation Companies notified RO changes updated Bulk of 2017 inventories received Main QC work on 2017 data EI Section submits 2017 Point and nonpoint data to NEI

13 Important Dates Redbud opens January 1 st Emission Inventories due April 1 st Deadline with approved 30 day extension May 1 st Invoices mailed July 1 st Operating Fees due July 31 st

Invoicing and Annual Operating Fees 14

15 Invoicing Two years in arrears 2016 inventories submitted by April 1, 2017 - billed in 2018 2017 inventories submitted by April 1, 2018 - billed in 2019 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 2018 Title V fee is $38.14 per ton The minor source fee is fixed at $25.12 per ton Pollutants can not be double billed Billed only for Total VOC although the invoice will list HAP and VOC (non- HAP) amounts Will only bill for PM-10. (PM-2.5 is a subset of PM-10)

Invoice Invoices sent out July 1 st 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 ODEQ EI Section 16

17 #100-882 Designation of Responsible Official http://www.deq.state.ok.us/aqdnew /resources/aqforms.htm

18 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 aei@deq.ok.gov

19 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

20 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.

21 #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-onone help Bring your laptop, spreadsheets & other pertinent information www.deq.state.ok.us/aqdnew/emissions /EIcontact.htm 22

23 General Contact Information Emission inventory email: aei@deq.ok.gov Air Quality front desk: 405-702-4100 Questions on air emission inventory, compliance & enforcement, permitting, rules

24 Emissions Inventory Basics Grant Loney

25 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

26 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.

28 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 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. o Facility Operating Status

29 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

30 Note on First Inventories If a facility is submitting an Emissions Inventory for the first time, Redbud will be blank. o See Permit or Permit Application for a list of emission units and information about them. After the first inventory, most data are copied forward to next year. o Key exceptions: Annual process rates, annual hours of operation, annual emissions.

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.) 31

32 Grouping Emission Units Logically similar emission units that produce small amounts of emissions can be grouped and reported as a single emission unit. o Ex) Multiple emergency generators with low annual hours of operation o Mind the reporting threshold (covered later) o See the General Instructions document on DEQ website for more info.

33 Process Activity at an emission unit that produces emissions. Associated with a specific Source Classification Code (SCC) o o Can be found on EPA s website. Also in Redbud Harder to determine which code to use https://ofmpub.epa.gov/sccsearch/

34 Process Other Required Information: o Process Material o Process Rates o Hours of operation o Design capacity (if applicable) o Fuel data (if applicable)

Process 35

36 Process Multiple processes at one emission unit o Different process materials Ex) Engine burns natural gas or gasoline o Storage tanks Working, breathing, flashing losses

37 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)

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 38

39 WebFIRE Most Comprehensive list of pollutants and emission factors Will I report 42 pollutants? o Probably not Duplicate Factors Factors with Control Reporting Threshold

40 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 & hexavalent 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 Grouped emission units

41 Other Calculation Methods Modeling software Formulas CEMS Mass balance calculations o Like above or use Emission Factor

42 Control Information Reported at the Pollutant level 3 Main pieces of information o Control Device o Capture Efficiency o Control Efficiency When should this box be checked?

43 Actual Emissions Actual Emissions=Total amount of pollutant that is actually emitted. o Includes Normal Operations; Startup, Shutdown, and Malfunction (SSM); and Excess Emissions Excess Emissions should be reported if hourly limits are exceeded, even if yearly limits are not.

Emission Inventory Guidance and Updates 45 Carrie Schroeder Emissions Inventory Manager Emissions Inventory Workshop January 23, 2018 & January 31, 2018 Norman, OK Tulsa, OK

46 Update Presentation Objectives Permit by Rule Reporting Legal Clarification in business practices Amendments Redbud and Code Changes National Emissions Inventory (NEI) Emissions Inventory Website

Permit by Rule (PBR) Reporting 47

48 PBR 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.

49 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 (2017, 2020, 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

50 Permit by Rule Facilities 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 National Emission Inventory (NEI) three-year cycle (next is 2017) 5 Ton/year of any RAP every second NEI three-year cycle (next is 2020)

2017 Permit by Rule Regulated Pollutants < 5 TPY All PBRs have been loaded into Redbud Facilities at or below 5 TPY (for all regulated pollutants) for CY 2017 may elect the 2020 schedule. Facility should choose Not Yet Built/Idle/Closed over the 2020 option, if one of those statuses applies. When the reporter selects facility status PBR-Schedule B (2020) in Redbud, a popup box will appear in which the reporter is agreeing to the following: I certify under OAC 252:100-5-2.1(a)(2)(B) that this facility is not required to report until 2020. The emission units and associated records will not need to be updated. 51

52 PBR Reporting Schedule Facility A: 10 Tons of NOx reported for 2015 12 Tons of NOx reported for 2017 - currently reporting Report again in 3 years Etc. PBR Permit issued: 1/1/2015 2020 NEI: All PBR Facilities 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2017 NEI: PBR Facilities with emissions > 5 TPY 2023 NEI: PBR Facilities With Emissions > 5TPY

53 PBR Reporting Schedule Facility B: 4.5 Tons of VOC reported in 2015 However, for 2017, will need to calculate and determine if on 2020 schedule PBR Permit: issued 1/1/2015 2017 NEI: Determine reporting schedule 2020 NEI: All PBR Facilities 2026 NEI: All PBR Facilities 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026

54 PBR-Schedule B (2020) Option

55 PBR Annual Operating Fees Oil & Gas PBR facilities were first invoiced in 2016 based on CY 2014 emissions Annual Operating Fees will be based on the most recently reported annual inventory thereafter

Legal Clarifications Leap Years Report actual hours even when emissions may be slightly over limits no excess emissions are required to be reported. Form 100-882, Designation of Responsible Official can be scanned and emailed. An original copy is not required. Inventories with confidential data must be submitted by hardcopy (paper submission) confidential & redacted version. 56

Emission Inventory Amendments 57

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 58

59 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!

Redbud Updates 60

Future of Redbud ODEQ is reviewing web-based reporting tools in search of a possible replacement for Redbud. A new system may be available for reporting inventories to the ODEQ in 2019 or 2020. Information on the conversion and training will be forthcoming after selection. 61

62 Redbud Compatibility Internet Explorer (IE) is the only browser that fully supports Redbud. Compatibility views should be set to off. Instructions to revert Microsoft Edge to IE 11 can be found on the Redbud login page.

63 Notes in Redbud Notes exist to communicate specific items from DEQ to a company or from a company to DEQ. Facility notes are most common and appear on the facility page Emission Unit notes appear on the emission unit page. These may discuss: The emission unit The release point The related processes Any singular emission record related to the emission unit All notes from DEQ should be reviewed and addressed as required

64 Notes in Redbud O&G facilities with a wellhead must report the US/API well number via the Facility Note to DEQ Any facility with a retired NAICS must report the appropriate NAICS code from the current code set

Redbud Code Changes 1. North American Industry Classification System (NAICS) 2. Source Classification Code (SCC) 3. Unit Type Codes - A description that uniquely identifies the emission unit chosen from the Unit Type table A comprehensive listing of all code changes can be accessed at https://www.epa.gov/air-emissionsinventories/2017-national-emissions-inventory-neidocumentation. 65

66 NAICS Code Changes EPA is retiring several NAICS codes. NAICS codes have been updated where EPA has provided a map from retired codes to new codes and a note has been left in Redbud for facilities to review the change. One code 211111 (Crude Petroleum and Natural Gas Extraction) does not have a single replacement! o Companies will need to select new NAICS codes 211120 (Crude Petroleum Extraction) or 211130 (Natural Gas Extraction) to replace 211111 in Redbud Companies may reach out for assistance with updating the NAICS codes.

NAICS Code Changes 67

68 SCC Code Changes EPA is retiring several SCC codes. The EI Section is waiting for EPA to confirm that all changes have been incorporated and we know the exact code set. Depending on the timing of EPA s guidance, EI may be able to update SCC codes in Redbud where EPA has provided a map from retired codes. Further guidance will be forthcoming.

69 Unit Type Code Changes New Unit Type codes fall under these sectors: o o o o o o o Plywood and Composite Wood Products Process Publicly-Owned Treatment Works Nutritional Yeast Off-site Waste and Recovery Operations Portland Cement Wool Fiberglass Pulp and Paper EI Section is waiting for EPA to confirm all changes. Guidance will be forthcoming.

70 National Emissions Inventory (NEI) Prepared at least every three years by the U.S. EPA based primarily upon emissions estimates and emissions model inputs provided by State, Local and Tribal (SLT) air agencies, and supplemented by data developed by the EPA. 2017 is a triennial year! A comprehensive and detailed estimate of annual total air emissions of both criteria air pollutants (CAPs) and hazardous air pollutants (HAPs) from all air emissions sources. ODEQ will be applying additional QC during and after data collection to help ensure the most accurate data is submitted.

Website Changes (EI page) 71

www.deq.state.ok.us/aqdnew/emissions 72

73 EI Website Improvements Frequently Asked Questions (FAQ): General Instructions and Redbud Help Document Information has been reviewed and updated, and a link to EPA s new SCC searchable database is provided.

74 Now to Permitting, but first Emissions Inventory Permitting Air Quality Division

Break Time 75

Annual EI Workshop Phil Martin/Lee Warden Permitting Manager 76

Cancelling Permits E-Permitting VOC loading guidance 77

A permit may be cancelled when a facility permanently ceases operation or when either DEQ or the facility representatives determine that the facility qualifies for "permit exempt" or "de minimis" status as defined in OAC 252:100-7. A facility representative may self-determine the facility's eligibility to claim either status and request DEQ cancel the permit. A cancellation request should be made in writing and address the following: Provide reason for cancellation (closure, permit exempt, de minimis) Reference the permit number Provide facility and company name Provide date when facility ceased operations or became eligible for "permit exempt" or "de minimis" status Where the facility has ceased operations, please indicate if emitting equipment has been removed or remains in place. Call 405-702-4100 and ask to speak with permitting staff for additional guidance. 78

Data entered in the system is transferred to TEAM (the air quality facility management database) TEAM is used to pre-fill information for existing facilities You can use a previous application as a template for a new facility Responsible Official (RO) and preparer can interact with the permit writer through the system with all communications visible to the RO You can pay in person, by check or with e-check and credit cards 80

An RO may delegate authority for the e-permitting system An RO designated or delegated for permitting purposes does not change the RO that has been or will be established for inventory purposes. 81

Permit by Rule (PBR) Oil and Natural Gas Facilities Volatile Organic Compounds (VOC) Storage and Loading Facilities Grain Elevators Emergency Engines Title V Renewal Applications (under testing) 82

Filling Clean Truck (Animation) Clean Truck includes: + V 1 New truck Clean truck Truck previously hauling nonvolatile cargo. V A + V 1 L 1 L 1 84

V A Emptying Truck (Animation) V 1 + V A L 1 Through transportation and time, vapors will evolve from liquid to bring the system into equilibrium. L 1 85

Vapor Saturation V of Empty Truck 1 + V A L (Animation) 1 Vapors entrained in V 1 + V A residual liquid (clingage) will evolve to bring the system into equilibrium. Dependent on temperature and time. 86

Filling Empty Truck (Animation) + V 2 V 1 + V 2 L 2 L 2 87

Stratification of Emissions (Animation) L 88

Equation 1 of AP-42 (6/08), Section 5.2: LL LL = 12.46 SSSSSS TT Where: L L = Loading Loss, pounds per 1,000 gallons of liquid loaded; S = Saturation factor; P = True Vapor Pressure (TVP) of liquid loaded; M = Molecular weight of vapors emitted; T = Temperature of bulk liquid loaded; and 12.46 = Conversion factor which incorporates the ideal gas constant and a conversion to put L L in terms of lb/1,000 gallons. Estimates emissions with a probable error of ±30%. 89

New Facilities (operating < 6 months): Representative data may be used Applicant should justify use of representative data Facilities Currently Operating (operating > 6 months): General assumptions: Trucks are in dedicated normal service Vapor composition is similar to storage tank working and breathing losses 90

Facilities Currently Operating (cont d): Obtaining values for P, M, and T Calculated based on: Methodologies from AP-42 (11/06), Section 7.1, using representative data; Process simulation software and representative lab analysis; or Representative data provided in AP-42 (11/06), Section 7.1. Collected from: Representative or site-specific sample analyses, and Representative or site-specific data. 91

Emissions Reductions (cont d): Reduced VOC content: Any applicant may exclude the non-voc components from the vapor molecular weight calculation ONLY if using site-specific data to calculate the speciated breakdown of the loading loss vapors. Otherwise, the applicant may comply with the following: 92

Emissions Reductions (cont d): Reduced VOC content (cont d): Wellhead facilities: Crude oil and condensate: May use an emission factor = * L L x 85%. So long as L L 2.0 lb/1,000 gallons. All other petroleum liquids: Shall use an emission factor = L L x 100%. All other facilities: Shall use an emission factor = L L x 100% 93

Produced water: Use same calculation methodology used to calculate condensate and crude oil loaded May assume the L L factor to be greater than or equal to 1% of the calculated condensate or crude oil L L factor. 94

Additional Considerations: Samples (representative or site-specific): Not older than three (3) years old. Sample from a wellhead site: The facility shall be sampled after the last time the well was fractured or refractured. Provide justification for use of representative samples. Process simulation software must conform with software user guide, must submit detailed program generated output report(s). 95

Vapor Balancing Routed to Storage Tank Vapor Control Routed to Combustion Device Vapor Recovery Routed to Process/Sales DEQ/AP-42 Default Collection Efficiency of 70% Unless Trucks and Collection System are Leak Tested Subject to annual leak testing requirements 96

Controls may be relied upon for reporting emissions without a federally enforceable limit Controls may not be relied upon to determine applicability for PBR. Relying on FEL - Must request limits for GP-OGF/Individual Permits Loading Facilities with throughput > 952 BPD or 40,000 gallons per day May use GP-OGF to obtain FEL but only for drilling or production facilities prior to lease custody transfer Must use Individual construction or operating permit to establish FELs for non-production facilities and those facilities after lease custody transfer. Subject to OAC 252:100-37-16 Federally Enforceable Limits will also include: Requirements for hookup procedures training & posting of signs Requirements for system equipped with fittings that they make vaportight connections 97

Vapors displaced from tank truck during loading are routed back to storage vessel being unloaded Most common type of control Storage Tank needs to be equipped with a vapor pressurevacuum vent valve Collected emissions are assigned to the storage tank 98

Three separate emission release points Tank Truck- DEQ/AP-42 default collection efficiency (1-70%) = 30% Storage Tank Capture/Control System Collected emissions assigned to the Storage Tank Correction for saturation factor (K N = 1) Storage Tank (Solely related to truck loading) [70% * (1- Control Device Capture Efficiency)] = (70% * 2%) = 1.4% Uncombusted storage tank emissions at Control (Solely related to truck loading) [70% * (Control Device Capture Efficiency) * (1-Control Efficiency)] = (70% * 98% * 2%) 1.4% 99

Uncontrolled Loading Emissions (1-70%) = 30% Controlled Loading Emissions [70% * (1- Control Efficiency)] (70% * 2%) = 1.4% 100

Uncontrolled Loading Emissions (1-70%) = 30% Controlled Loading Emissions [70% * (1-Control Efficiency)] Control efficiency can be assumed to be 100% (when operating) Emissions are taken in to account in fugitive calculations 101

102

Emissions Calculations Roxanne Bueckers Environmental Programs Specialist, AQD Emissions Inventory Workshop January 23, 2018: Norman, OK January 31, 2018: Tulsa, OK 103

INTRODUCTION An air emissions inventory is a report describing a facility. It lists the equipment and processes that cause the release of pollutants into the atmosphere. It also lists the quantity of these emissions. Before quantifying emissions it is important to know what is being emitted (i.e., pollutant) and where the emission comes from (i.e., process). 104

AGENDA Overview of general equation Calculation examples 1. CO from industrial boiler (AP-42) 2. NO x from internal combustion engine (WebFIRE) 3. NO x from compressor engine (manufacturer test data) 4. Total VOC from compressor engine (EPA reference method stack test and manufacturer test data) 5. Methanol (HAP) from compressor engine (AP-42) Resources from Permitting Section Reminders 105

GENERAL EQUATION A EF = E A is Activity (or process) Rate EF is Emission Factor, as determined by calculation method E is Emissions Estimate All three have physical dimensions (i.e., units). 106

GENERAL EQUATION A EF = E A is Activity Rate EF is Emission Factor E is Emissions Estimate Again, before quantifying emissions it is important to know what is being emitted (i.e., pollutant) and where the emission comes from (i.e., process). Where should I go? 107

GENERAL EQUATION A EF = E A is Activity Rate EF is Emission Factor E is Emissions Estimate Review the following to find the processes and pollutants at your facility. Operating permit Previous emissions inventories Permit application Comprehensive process flow diagrams Manufacturer/supplier details Site maps 108

GENERAL EQUATION A EF = E A is Activity Rate The annual amount of process material used, produced, or existed. In addition to this value, you must also report the following: Source Classification Code (SCC) Process material Annual hours the process operated/occurred Design capacity and fuel data (if a combustion process) Reportable pollutants Control scenario Permit or rule limit Excess emissions 109

GENERAL EQUATION A EF = E EF is Emission Factor A representative value that attempts to relate the quantity of a pollutant released to the atmosphere with an activity associated with the release of that pollutant. 110

GENERAL EQUATION A EF = E EF is Emission Factor Calculation Methods Relative Accuracy Continuous Emission Monitoring System (CEMS) EPA RM Stack Test Similar Unit EPA RM Stack Test Manufacturer Test Data Process Simulation Software Mass Balance Web Factor Information Retrieval System (WebFIRE) AP-42 or other EPA Documents 111

CALCULATION EXAMPLE 1: CO from industrial boiler Calculating uncontrolled carbon monoxide emissions from a 63 MMBtu/hr natural gasfired boiler AP-42, Section 1.4, Table 1.4-1 https://www.epa.gov/air-emissions-factors-andquantification/ap-42-compilation-air-emission-factors 112

CALCULATION EXAMPLE 1: CO from industrial boiler What do I need before I calculate? SCC: 10200602 Process Material: natural gas Annual Process Rate: 495.662 MMscf Annual Hours: 8,025 Design Capacity: 63 MMBtu/hr Fuel Data: 1,020 MMBtu/MMscf Reportable Pollutants: CO and others Control Scenario: none 113

CALCULATION EXAMPLE 1: CO from industrial boiler 114

CALCULATION EXAMPLE 1: CO from industrial boiler 115

CALCULATION EXAMPLE 1: CO from industrial boiler 116

CALCULATION EXAMPLE 1: CO from industrial boiler A EF = E A is Activity Rate EF is Emission Factor E is Emissions Estimate 495.662 MMscf 1 year 84 lbs 1 MMscf 1 ton 2,000 lbs = 2222.888888 tttttttt 11 yyyyyyyy 117

CALCULATION EXAMPLE 2: NO x from internal combustion engine Calculating uncontrolled nitrogen oxide emissions from a 400 hp diesel-fired internal combustion engine WebFIRE https://cfpub.epa.gov/webfire/ 118

CALCULATION EXAMPLE 2: NO x from internal combustion engine What do I need before I calculate? SCC: 20200102 Process Material: diesel Annual Process Rate: 500 gal Annual Hours: 50 Design Capacity: 400 hp Fuel Data: 137 MMBtu/1000 gal Reportable Pollutants: NO x and others Control Scenario: none 119

CALCULATION EXAMPLE 2: NO x from internal combustion engine 120

CALCULATION EXAMPLE 2: NO x from internal combustion engine 121

CALCULATION EXAMPLE 2: NO x from internal combustion engine 122

CALCULATION EXAMPLE 2: NO x from internal combustion engine 123

CALCULATION EXAMPLE 2: NO x from internal combustion engine A EF = E A is Activity Rate EF is Emission Factor E is Emissions Estimate 6.040E2 500 gal 1 year 604 lbs 1000 gal 1 ton 2,000 lbs = 00.111111 tttttttt 11 yyyyyyyy 124

CALCULATION EXAMPLE 3: NO x from compressor engine Calculating controlled nitrogen oxide emissions from a 1,380 hp natural gas-fired compressor engine Manufacturer Test Data 125

CALCULATION EXAMPLE 3: NO x from compressor engine Notes about control scenarios A control system, abatement equipment, or an approach applied to reduce emissions of a pollutant. Two parts: capture efficiency and control efficiency 126

CALCULATION EXAMPLE 3: NO x from compressor engine Notes about control scenarios Capture Efficiency The percentage of air emissions that are directed to the control equipment or an estimate of that portion of an affected emissions stream that is collected and routed to the control measure. Any emissions not being captured due to control device downtime should be accounted for in the total actual emissions. The capture efficiency should be lowered for that year and the downtime should be explained in the emission unit notes field in Redbud. Excess emissions should be reported if applicable. 127

CALCULATION EXAMPLE 3: NO x from compressor engine Notes about control scenarios Control Efficiency The percentage of actual air emissions prevented from being emitted by the control scenario. Ensure the control efficiency accurately reflects the condition of the device. 128

CALCULATION EXAMPLE 3: NO x from compressor engine What do I need before I calculate? SCC: 20200254 Process Material: natural gas Annual Process Rate: 63.185 MMscf Annual Hours: 7,296 Design Capacity: 1,380 hp Fuel Data: 1,020 MMBtu/MMscf Reportable Pollutants: NO x and others Control Scenario: SCR 129

CALCULATION EXAMPLE 3: NO x from compressor engine 130

CALCULATION EXAMPLE 3: NO x from compressor engine 131

CALCULATION EXAMPLE 3: NO x from compressor engine A EF = E A is Activity Rate EF is Emission Factor E is Emissions Estimate 7,296 hrs 1 year 0.5 g 1 hphr 1,380 hp 1 1 lb 453.592 g 1 ton 2,000 lbs = 55.555555 tttttttt 11 yyyyyyyy 132

CALCULATION EXAMPLE 3: NO x from compressor engine Don t forget to apply the control scenario! Selective Catalytic Reduction 90% Capture 95% Control 133

CALCULATION EXAMPLE 3: NO x from compressor engine A EF [1-(ER/100)] = E ER is Overall Emissions Reduction Efficiency 7,296 hrs 1 year 0.5 g 1 hphr 1,380 hp 1 1 lb 453.592 g 1 ton 2,000 lbs = 55.555555 tttttttt 11 yyyyyyyy 5.549 tons 10% = 00. 555555 tttttttt (uuuuuuuuuuuuuuuuuuuu eeeeeeeeeeeeeeeeee) 134

CALCULATION EXAMPLE 3: NO x from compressor engine A EF [1-(ER/100)] = E ER is Overall Emissions Reduction Efficiency 4.994 tons 1 95 100 = 00. 2222 tttttttt (cccccccccccccccccccc eeeeeeeeeeeeeeeeee) 0.555 tons + 0.25 tons = 00. 888888 tttttttt (eeeeeeeeeeeeeeeeee tttttttttt eeeeeeeeeeeeeeeeee wwwwwwww cccccccccccccc ssssssssssssssss) 135

CALCULATION EXAMPLE 4: Total VOC from compressor engine Calculating controlled total VOC emissions from a 1,380 hp natural gas-fired compressor engine EPA Reference Method Stack Test Method 18/25A: Gas Chromatography/Flame Ionization Detection Manufacturer Test Data 136

CALCULATION EXAMPLE 4: Total VOC from compressor engine 137

CALCULATION EXAMPLE 4: Total VOC from compressor engine 138

CALCULATION EXAMPLE 4: Total VOC from compressor engine Stack test methods may not account for all reportable pollutants. 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. Don t forget to apply the control scenario! Oxidation Catalyst 100% Capture 80% Control 139

CALCULATION EXAMPLE 4: Total VOC from compressor engine 140

CALCULATION EXAMPLE 4: Total VOC from compressor engine 141

CALCULATION EXAMPLE 4: Total VOC from compressor engine What do I need before I calculate? SCC: 20200254 Process Material: natural gas Annual Process Rate: 107.47 MMscf Annual Hours: 8,760 Design Capacity: 1,380 hp Fuel Data: 1,020 MMBtu/MMscf Reportable Pollutants: total VOC and others Control Scenario: oxidation catalyst 142

CALCULATION EXAMPLE 4: Total VOC from compressor engine A EF = E A is Activity Rate EF is Emission Factor E is Emissions Estimate EF = 0.17 g hphr + (20% of 0.44 g hphr) = 00. 2222 gg hhhhhhhh VOC Factor from Stack Test CH 2 O Factor from Manufacturer Test Data Total VOC Factor 143

CALCULATION EXAMPLE 4: Total VOC from compressor engine A EF = E A is Activity Rate EF is Emission Factor E is Emissions Estimate 8,760 hrs 1 year 0.26 g 1 hphr 1,380 hp 1 1 lb 453.592 g 1 ton 2,000 lbs = 33.444444 tttttttt 11 yyyyyyyy * Total VOC must be equal to or greater than sum of HAPs! 144

CALCULATION EXAMPLE 5: Methanol from compressor engine Calculating uncontrolled methanol emissions from a 1,380 hp natural gas-fired compressor engine AP-42, Section 3.2, Table 3.2-2 https://www.epa.gov/air-emissions-factors-andquantification/ap-42-compilation-air-emission-factors 145

CALCULATION EXAMPLE 5: Methanol from compressor engine What do I need before I calculate? SCC: 20200254 Process Material: natural gas Annual Process Rate: 107.47 MMscf Annual Hours: 8,760 Design Capacity: 1,360 hp Fuel Data: 1,020 MMBtu/MMscf Reportable Pollutants: CH 3 OH and others Control Scenario: none 146

CALCULATION EXAMPLE 5: Methanol from compressor engine 147

CALCULATION EXAMPLE 5: Methanol from compressor engine A EF = E A is Activity Rate EF is Emission Factor E is Emissions Estimate 2.50 E-03 107.47 MMscf 1 year 0.0025 lbs 1 MMBtu 1,020 MMBtu 1 MMscf 1 ton 2,000 lbs = 00.111111 tttttttt 11 yyyyyyyy 148

RESOURCES FROM PERMITTING http://www.deq.state.ok.us/aqdnew/permitting/advicedocuments.htm Permit Application Advice Documents Asphalt Plant Advice Compressor Station Advice Permit Application Guide for Facilities with Coating/Painting Operations Rock Crusher Advice Storage Tank Advice Other Guidance & Permitting Advice Resources Calculation of Flashing Losses/VOC Emissions from Hydrocarbon Storage Tanks Estimating Condensate and Crude Oil Loading Losses from Tank Trucks Potential to Emit Guidance 149

RESOURCES FROM PERMITTING http://www.deq.state.ok.us/aqdnew/permitting/advicedocuments.htm Review permit and/or permit application Review site-specific general permit forms Calculation of Flashing Losses/VOC Emissions from Hydrocarbon Storage Tanks Updated in response to NSPS Subpart OOOO Usage restrictions on certain estimation methods Estimating Condensate and Crude Oil Loading Losses from Tank Trucks Developed to standardize calculation of Total VOC emission factor due to varying amounts of methane and ethane AP-42, Section 5.2, Equation 1 150

REMINDERS A facility s potential to emit (PTE) does not equal a facility s actual emissions. Apply current guidance. OAC 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. Report gap-filled CEMS data. Supporting documentation must be maintained. EI staff can provide more example calculations for other industries (e.g., coating operations, asphalt/rock crushing operations, air curtain incinerators, etc.). When in doubt, contact us. We are here to help! aei@deq.ok.gov or (405) 702-4100 151

Quality Control and Top Mistakes Shelby Willeby Environmental Programs Specialist, AQD Emissions Inventory Workshop January 23, 2018: Norman, OK January 31, 2018: Tulsa, OK 152

QC Goal Our goal is to be able to provide the most accurate data to EPA o Generally we should be able to replicate your emissions with the information provided. o The most accurate information available at the time of submittal should be used. o Emission factors/stack test factors should be updated. o The correct calculation method should be selected. o The throughput and emission factor units should be complementary o Emission unit and facility notes should be added when appropriate. 153

Overview Cannot Replicate Emission Calculation Total VOC less than sum of individual Hazardous Air Pollutants(HAPs) Control Devices Inconsistencies Guidance 154

Cannot Replicate Emission Calculation 155

2016 QC issue Hits No Reported Emissions But Both Annual Process Rate and Hours of Operation Reported 1788 Calculated Emissons Do Not Match Reported Emissions 1039 Emission Factor Units Of Pounds Per Hour 967 Total VOC is less than the sum of Speciated VOCs 507 100% Primary Control Efficiencies But Emissions Reported 332 Emissions decreased by over 1 ton and more than 30% from previous year to current year, but Annual Rate & Hours only changed by +/- 10%. 325 Same annual process rate, hours of operation and emissions reported for previous year and current year. 299 Emission Factor Required For This Methodology 296 Nonrefineries using refinery SCCs 295 Emission Factor Units Required For This Methodology 291 Emissions increased by over 1 ton and greater than 30% from previous year to current year, but Annual Rate & Hours only changed by +/- 10%. 289 Controlled CA/EA pollutant inconsistent with Secondary Control Equipment 281 Controlled CA/EA pollutant inconsistent with Primary Control Equipment 262 Facility, Emission Unit, and/or Release Point statuses are inconsistent. 198 156

Cannot Replicate Calculation Due to Units For most emission units, the throughput units and emission factor units should match. MMBTU MMSCF o Fuel heat content should be provided for conversion o Due to the similar abbreviations it s easy to choose the wrong unit Horsepower-Hours o Provide design capacity o Prefer MMBTU as the throughput o Only use horsepower-hours as the throughput unit if all pollutants emission factors are in horsepower-hours 157

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Significant Change in emissions from previous reporting year Often, we see emissions at a unit increase or decrease significantly without any significant changes in throughput or operating time o 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 o Often typos are encountered in this check Providing detailed emission unit notes helps for valid situations! 160

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! 162

Total VOC & HAPs 163

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 A Hazardous Air Pollutant (HAP) is a compound that has been included on EPA s list of 187 chemicals that can have a detrimental effect on humans and the environment. o Many HAPs are also VOCs o Both HAPs and Total VOC must be reported o You will not be double billed For Oil and Gas Facilities the Total VOC amount should be greater than the total of the individual HAPs o BTEX pollutants are HAPs and VOCs 165

Formaldehyde Emissions at JJJJ Engines Many manufacturer s emission factors are developed using EPA Test Method 25A o Method 25A is used to demonstrate JJJJ compliance o The method poorly detects formaldehyde o Formaldehyde emission factor often not provided by manufacture Possible Solutions o Add the formaldehyde emissions calculated with the AP- 42 emission factor to the Total VOC to create a larger Total VOC 166

Manufacture data with formaldehyde emission factor provided Manufacture data without formaldehyde emission factor provided 167

Control Devices 168

Reporting Control Devices 100% control efficiency in combination with 100% capture efficiency should not be selected when emissions are also reported 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. 170

Controls Control Efficiencies Does your emission factor include the control efficiency? Don t underestimate emissions! 171

Inconsistent Reporting 172

Inconsistent Reporting The operating Status for the emission unit and emission release point should match. 174

Inconsistent Reporting 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. 175

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. o 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 176

Reporting Guidance Blowdown Emissions Produced Water Tank emissions Reporting Downtime for CEMS How to Group Emission Units. 177

Reporting Blowdown Emissions Blowdowns are the intentional venting of pressurized gases from equipment, like compressors or piping systems, often due to maintenance. The number of blowdowns that occur at a facility in a calendar year should be: o Tracked o Reported under its associated emission unit (not under fugitives) Utilize SCC 30600402 (Industrial Processes, Petroleum Industry, Blowdown Systems, Blowdown System w/o Controls) Utilize SCC 30600401 if you have a vapor recovery system with flaring If a blowdown SCC doesn t exist for your industry, report emissions under the normal process at the emission unit. Use 0 NA/NA for factor. Include a note detailing the blowdown emissions and normal operations at the unit. 178

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: o The volume of produced water can be entered into Tanks as if it was condensate/crude oil. o One percent of the resultant value can be utilized as the produced water emissions. 179

Reporting Downtime for Continuous Emissions Monitoring Systems (CEMS) Downtime must be accounted for! o For most electric generating facilities, the appropriate methodology to account for downtime is found in Part 75. o 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 180

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 181