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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