Frequent Errors

1. FrequentErrors by Carrie Schroeder

2. Areas of Discussion Facility Status Changes Substituting or Removing Equipment Source Classification Codes Hours as Process Rate Units Inconsistent Reporting Fuel Heat Content Controls Emission Factors Hazardous Air Pollutants (HAPs) Redbud Submissions Signed Documents

3. #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 Activefor the next year so we can get a yearly status verification.

4. #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.

5. #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.

6. #3 Source Classification Codes (SCC) 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 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.

7. #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.

8. #4 Hours as Process Rate Actual Annual (activity) should be expressed as fuel combusted, raw material processed or product manufactured or handled.

9. #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.

10. #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 then, >0 process rate AND >0 hours AND >0 emissions. • If the emission unit is or then, 0 process rate AND 0 hours AND 0 emissions.

11. #7 Fuel Heat Content When burning well or landfill gas report the true mmbtu per mmscf.

12. #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.

13. #8 Control Equipment • Listing controls and efficiencies that do not apply to that pollutant. • Fabric filters and baghouses only control PM • Catalytic converters control CO, VOCs and/or NOx • Catalytic oxidizers control CO and VOCs

14. #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

15. #9 Emission Factors - Methods Most reliable Least reliable 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

16. #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.

17. #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.

18. #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.

19. 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.

20. If you have questions, call us • and/or • make an appointment to visit us for assistance. Any Questions?