What is an Emissions Inventory?

1. What is an Emissions Inventory? By Carrie Schroeder

2. “Cheat Sheet” Index Card

3. Air Quality 101 Why do you have to report an emissions inventory?

4. Air Quality 101 Summary of the Clean Air Act 42 U.S.C. §7401 et seq. (1970) The Clean Air Act (CAA) is the comprehensive federal law that regulates air emissions from stationary and mobile sources. Among other things, this law authorizes EPA to establish National Ambient Air Quality Standards (NAAQS) to protect public health and public welfare and to regulate emissions of hazardous air pollutants. One of the goals of the Act was to set and achieve NAAQS in every state by 1975 in order to address the public health and welfare risks posed by certain widespread air pollutants. The setting of these pollutant standards was coupled with directing the states to develop state implementation plans (SIPs), applicable to appropriate industrial sources in the state, in order to achieve these standards. The Act was amended in 1977 and 1990 primarily to set new goals (dates) for achieving attainment of NAAQS since many areas of the country had failed to meet the deadlines.

5. Air Quality 101 • Our SIP includes the Oklahoma Air Quality Rules • OAC 252:100-5-2.1. Emission inventory (a) Requirement to file an emission inventory. 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. (1) General requirements. The inventory shall cover operations during a calendar year and shall be submitted on or before April 1 of the following year. Upon receiving a written demonstration of good cause the Director may grant an extension for submittal beyond the April 1 deadline. (2) Permit by rule. The owner or operator of a facility registered under a permit by rule in Subchapter 7, Part 9, shall submit, at a minimum, an annual emission inventory for the 2014 reporting year or the calendar year in which the facility is registered, if the facility is registered after December 31, 2014, and thereafter according to the following schedule: (A) For a registered facility with actual emissions greater than 5 tons per year of any regulated air pollutant, an annual emission inventory for that facility shall be submitted every National Emissions Inventory (NEI) Three-Year Cycle Inventory year, as defined in 40 CFR Section 51.30(b). (B) For a registered facility with actual emissions of 5 tons per year or less of any regulated air pollutant, an annual emission inventory for that facility shall be submitted every second National Emissions Inventory (NEI) Three-Year Cycle Inventory year, as defined in 40 CFR Section 51.30(b), beginning with the 2020 NEI reporting year. (3) Permit exempt facilities and de minimis facilities. The owners or operators of permit exempt facilities or de minimis facilities, as these terms are defined in OAC 252:100-7-1.1, are not required to submit an annual emission inventory. (4) Special inventories. Upon request by the Director, the owner or operator of a facility that emits or has the potential to emit any regulated air pollutant shall file an emission inventory with the Division. The Director is authorized to request this inventory when emission related data is necessary for program planning or compliance with State or Federalrules, regulations, standards, or requirements.

7. What is an Emissions Inventory • A report describing what’s going on at the facility • Lists equipment/activities and describes the processes in which emissions are released

8. Layout of an Inventory • Company– University of Oklahoma Health Sciences Center • Facility(s) – OKC Campus Services • Emission unit(s) with release point(s)– Boiler No. 4 & Boiler No. 4 Stack • Process(es) – Source Classification Code 10300602 = External Combustion Boilers, Commercial/Institutional, Natural Gas, 10-100 million Btu/hr • Emission(s) – CO, NOx, PM-10, PM-2.5, SOx, non-HAP VOC, Benzene, Formaldehyde, Hexane, Toluene

9. Company Page Facility Page Emission Unit Page Process & Emission Page

10. Emission Units

11. Emission Units What is an emission unit? Any part of a facility that releases emissions

12. Emission Units • What emission units should I report? • If it’s in your permit then it should be in your inventory

13. Emission Units continued • What emission units should I report? • “Insignificant activities” (Appendix I of our Rules) and “Trivial Activities” (Appendix J of our Rules) may need to be reported Call us to find out for your situation!

14. Release Points

15. Release Points What is a release point? The point or area at which the emissions are released into the environment Common types are fugitive, vertical stack, horizontal stack

16. Release Points Stacks Fugitives Pipe work Minerals Storage Tank

17. Processes

18. Processes • What information will I need? • Source Classification Code • Process Material • Process Rate • Hours the process ran • Design capacity (if applicable) • Fuel data (if applicable)

19. Processes – Source Classification Code • Describes the process in which pollutants are emitted • You can find the full excel spreadsheet list of SCCs as well as the smaller table just showing the first 3 digits of the SCCs on our website: • http://www.deq.state.ok.us/aqdnew/emissions/TurnAroundDocs.htm • http://www.deq.state.ok.us/aqdnew/emissions/Point%20Source%20Categories%20SCC_v2004b.pdf

21. Processes – Material, Rate, Hours

22. Emissions

23. Emissions • What information will I need? • What pollutants to report • Method for calculating the emission amounts (emission factor) • Control efficiency and capture efficiency (if applicable) • Permit or rule limit (if applicable) • Excess emissions (if applicable)

24. Emissions • Report Regulated Air Pollutants (RAPs) – pollutants regulated by statute, rule, regulation or permit http://www.deq.state.ok.us/aqdnew/emissions/OklahomaRegulatedAirPollutants.htm • Not sure what pollutants come from your process? • Look at your permit • Contact the manufacturer, ask your supplier • Try entering your SCC into EPA’s WebFIRE database http://cfpub.epa.gov/webfire/index.cfm?action=fire.SearchEmissionFactors • "Actual emissions" means the total amount of any regulated air pollutant actually emitted from a given facility during a particular calendar year, determined using methods contained in 252:100-5-2.1(d).

25. Emissions – Calculation 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 WebFIRE Data Factors AP-42, other EPA Documents

26. Emissions – Emission Factor • What emission factor (EF) should be reported? • If your calculation method uses a single factor, enter that EF • If your method uses a complex formula or model, list the factor as 0 and the units as *NA/*NA • Some methods that may use a model or complex equations: • Storage Tanks – TANKS, Vasquez-Beggs equation • Glycol Dehydrator Reboiler - GRI-GLYCalc • Mass Balance • EPA documents with formulas

27. Emissions – Emission Factor For the situations on the previous slide and for complex mass balance calculations enter: * N/A - Formula, Software or CEMS 0 * N/A - Formula, Software or CEMS

28. Resources for Emission Factors WebFIRE –http://cfpub.epa.gov/webfire/index.cfm AP-42 - http://www.epa.gov/ttn/chief/ap42/index.html TANKS - http://www.epa.gov/ttnchie1/software/tanks Vasquez-Beggs - www.deq.state.ok.us/aqdnew/resources/Calculations11.xls

29. 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 Emissions – Particulate Matter Amt 0 10 Size (microns)

30. Emissions – Particulate Matter

31. Calculated Emissions What should be reported? AllActual Emissions not Permit limits or Potential to Emit Values (PTE)

32. Emissions - Controls Control equipment is reported at the pollutant level

33. Emissions – Controls Control Scenario – control system, abatement equipment or approach applied to reduce emissions of the pollutant Capture Efficiency – the percentage of air emissions that is 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, when the capture or collection system is operating as designed Control Efficiency – the percentage of actual air emissions prevented from being emitted by the control scenario. The actual efficiency should reflect control equipment downtime and maintenance degradation

34. Emissions – Permit/Rule Limit If you have a limit, list it Otherwise, leave it as 0

35. Do excess emissions need to be included? • 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

36. 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.

37. Questions? General Inquiries(405) 702- 4100 aei@deq.ok.gov Mark Gibbs (405) 702- 4179 Cooper Garbe (405) 702- 4178 Cody Lathrop (405) 702- 4212 Michelle Horn (405) 702- 4176 Justin Milton (405) 702- 4210 Carrie Schroeder(405) 702- 4214