EMISSIONS EVENTS

Joe Janecka – Central Office Susan Thompson – Region 1 Amarillo

Presentation Outline

Two Parts:

(1) What you do and

(2) What we do

What You Do

Regulatory knowledge, process or plant knowledge,

Reporting: Reportable Quantities (RQ)

Reporting: STEERS Reporting: Affirmative Defense

Reg Knowledge

Emissions events is an upset or unscheduled maintenance, start-up, or shutdown.

Regulated Entity must report an emission event meeting an RQ within 24 hours of the discovery of the event.

Reg Knowledge

A Regulated Entity: All regulated units, facilities, equipment, structures, or sources at one street address or location that are owned or operated by the same person. The term includes any property under common ownership or control identified in a permit or used in conjunction with the regulated activity at the same street address or location. Owners or operators of pipelines, gathering lines, and flowlines under common ownership or control in a particular county may be treated as a single regulated entity for purposes of assessment and regulation of emissions events.

Process/Plant Knowledge

What is contained in or flowing through your systems that may be emitted during an emissions event.

Why? So you can quickly determine RQ

Emission Points and their respective “allowables.”

Why? So you can determine unauthorized quantity

Reporting: RQ

Refer to definition (88) in section 101.1 of 30 TAC Chapter 101. It will be the lowest of: 40 Code of Federal Regulations (CFR)

Part 302, Table 302.4 40 CFR Part 355, Appendix A (III) individual contaminants listed in the

definition RQ = 100 pounds when the

contaminant cannot be found in the three references above

Reporting: RQ

§101.1(88)(B) describes RQ for mixtures

§101.1(88)(C) describes “OPACITY” as the only RQ for boilers and combustion turbines with narrow fuel specs. The RQ for opacity is 15% above the standard or limit at the emission point.

Reporting: RQ

§101.1(88)(D) describes RQ can be a ground level concentration for sources with CEMs and an approved “conditions and screening model.” This is rare. I have not seen this approach… usually this type of assessment would take much longer than the initial 24 hour reporting period to determine.

Case Examples: RQs

Ammonia (gaseous) Gasoline (spill) Produced (unprocessed) natural gas

Case Examples: RQs

§ 302.4 40 CFR Ch. I (7–1–04 Edition)TABLE 302.4—LIST OF HAZARDOUS SUBSTANCES AND REPORTABLE QUANTITIES—Continued[Note: All Comments/Notes Are Located at the End of This Table] 

Hazardous substance

CASRN Statutory Codedagger

RCRA waste No Final RQ pounds (Kg)

 

 

 

 

Ammonia

 

 

 

 

7664–41–7

 

 

 

 

1

   

 

 

 

100 (45.4)

Case Examples: RQs

Gasoline: 4% by volume Benzene 200 gal spill reported under 30 TAC

Chapter 327, §327.3 Estimated 50% volatilized

Case Examples: RQs

100 gallons evaporated at .04 Benzene, 6.15 lb/gal

24.6 lbs Benzene Same formula gasoline to reach RQ

Benzene?100 lbs/6.15 = 16.3 gal/.04 = about 408 gallons (evaporated)

Case Examples: RQs

Natural gas - RQ definition (88)(B)(iv): 5000 lbs excluding carbon dioxide,

water, nitrogen, methane, ethane, noble gases, hydrogen, and oxygen or air emissions from crude oil, (usually sweet gas) or

100 lbs hydrogen sulfide and mercaptans (sour gas)

Reporting: STEERS

Electronic reporting through STEERS required except: Small businesses (may fax, but STEERS

is encouraged) When STEERS is down for any reason (at

the agency) When reported under the Spill Rules (30

TAC Chapter 327)

Reporting: STEERS

Set-up account and STEERS Participation Agreement

The SPA, and the STEERS account, and the reporting is a personally certified process

Rules for “probationary” account Initial 24 hour report can be done

through probationary account. Final report requires a fully activated account with a completed SPA

Reporting: STEERS

Initial report, best information you have, within 24 hours of your discovery of the event.

As 24th hour approaches, RQ not met but emissions are still on-going and you are not sure, many people report out of abundance of caution

Why? Because a timely report is needed for affirmative defense.

Reporting: Affirmative Defense A demonstration by the regulated

entity for defense against enforcement

Reports must be timely The event must not be deemed

“excessive” RE must provide information

addressing eleven factors listed in 30 TAC Chapter 101, §101.222(b)

Reporting: Affirmative Defense Enter your information supporting

the eleven demonstration criteria in the STEERS reporting form in the field labeled:

“Basis Used to Determine Quantities and Any Additional Information Necessary to Evaluate the Event:”

STEERS reporting help

STEERS AEME technical contact:Joe Janecka, 512-239-1353, Joseph.janecka@tceq.texas.gov

STEERS helpline: 512-239-6925

STEERS Help at:https://www3.tceq.texas.gov/steers/help/main.html