Oklahoma Department of Environmental Quality

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• Oklahoma Department of Environmental Quality
• Emissions Inventory
• John Munro

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Emissions Inventory Staff

• RAY BISHOP
• 405-702-4218 ray.bishop_at_deq.state.ok.us
• MARK GIBBS
• 405-702-4214 mark.gibbs_at_deq.state.ok.us
• STEVE HOPKINS
• 405-702-4172 steve.hopkins_at_deq.state.ok.us
• JOHN MUNRO
• 405-702-4216 john.munro_at_deq.state.ok.us
• CRYSTAL K. STEARNS
• 405-702-4170 crystal.stearns_at_deq.state.ok.us

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This Afternoons Schedule

• Changes for the 2006 Reporting Year Important
  Issues - John Munro
• Reporting Excess Emissions in Annual Emissions
  Inventories - Crystal K. Stearns
• Data Quality Control Common Errors
• Mark Gibbs
• Questions Answers

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Where Can I Get Help?

• The Emissions Inventory Website
• http//www.deq.state.ok.us/AQDnew/emissions
• or via
• www.deq.state.ok.us

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SCC SCOUT - Software Program for Determining
SCCs(Source Classification Codes)

• http//www.deq.state.la.us/portal/default.aspx?tab
  id1760

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The Emissions Inventory Web Site
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CHIEF www.epa.gov/ttn/chief\

• Emissions Inventories
• Emissions Factors
• Software
• Basic Information and FAQs

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Whats New for Reporting Year 2007

• Reporting deadline is now prior April 1
• We will accept submissions up to COB on Monday,
  April 2, 2007
• Extensions beyond that date MAY be granted by
  the AQD Director if good cause is shown in writing

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Recent Rule Changes

• Requirement to automatically provide an
  explanation for a 30 change in emissions has
  been re-written
• The Department may require the owner or operator
  to provide an explanation for the change
  (Supporting Documentation)

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Recent Rule Changes

• Both recent changes to Subchapter 5 of OAC
  252100 are due to formally come into effect in
  June 2007
• But will be reporting policy for 2006 emission
  inventories

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Initial Inventory Submittalsfor New
Facilities(REDBUD Users)

• If a facility does not show up on the facility
  page in the Facility to Edit window,
• Contact us so we can add the facility to REDBUD
  

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Initial InventoriesNew Facilities(REDBUD Users)
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Initial Inventory Submittalsfor New
Facilities(REDBUD Users)

• In the two previous REDBUD versions, inventories
  for a new facility had to be submitted by
  hardcopy
• REDBUD is set up so that new points can be
  added, by the user, including to a facility where
  there are no points at all

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Facility with No Points
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Change of Ownership

• Responsibilities of the
• Transferor (Seller)
• It shall be the responsibility of the transferor
  to notify the Department in writing within ten
  (10) days of the change in ownership.
• Transferee (Purchaser)
• The transfer of ownership of a stationary source
  or a facility shall subject the new owner or
  operator to existing permit conditions and/or
  compliance schedules.

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Change of Ownership

• What this means for the new owner
• Responsibilities transfer unless explicitly
  stated in contract or sale agreement.
• New owner is responsible for providing the
  complete years inventory
• Even if sale took place within the reporting year

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CompanyResponsible Official (RO)

• Definition
• Procedure for changing the RO

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DefinitionOAC252100-1-3
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Notifying the DEQ of a Change of Responsible
Official

• We need letter on company letterhead
• Must include Signature, Name, Title
• Must be from a Senior Company Official as
  defined in OAC 252100-1-3
• Can designate themselves or another qualifying
  person as the RO

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Report RegulatedAir Pollutants Only

• Regulated air pollutant (defined in OAC
  252100-5-1.1. Definitions)
• Any pollutant listed in Appendix P of OAC 252100
• Any other substance for which an air emission
  limitation or equipment standard is set by permit

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Reporting Criteria

• The number of "Regulated air pollutants" in
  Oklahoma has been substantially consolidated in
  recent years
• Subchapter 41 now superseded by Subchapter 42
• Now just 21 State Toxics, all except Ammonia
  (NH3) are also HAPS
• Greatly simplifies reporting
• Appendix P of OAC 252100
• Brings pollutants regulated by statute and rule
  into one place
• Formally becomes part of rules in June 2007

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http//www.deq.state.ok.us/AQDnew/council_mtgs/jul
06/jul06rules.htm
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Reporting Criteria Review

• Be Aware of synonyms and/or proprietary names
• e.g., tetrachloroethylene
• Synonyms PERC , Perchloroethylene, Perclene,
  Tetrochloroethane

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Reporting Criteria Review

• Watch out for consolidation of individual
  compounds into their HAP compound group
• e.g., diethylene glycol is part of the HAP
  compound group of Glycol Ethers
• Would be reported , within that group

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Report RegulatedAir Pollutants Only

• Permit-limited pollutants should be reported
• This would include TSP and old SC-41 toxics
• Redbud set up to show most known occurrences,
  where applicable

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Understanding PollutantReporting Categories

• Many pollutant groups overlap.
• A compound can be both a HAP and a VOC (Volatile
  Organic Compound an ozone precursor)
• AVOID DOUBLE COUNTING and therefore DOUBLE
  BILLING!

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Reporting VOCs

• Volatile Organic Compounds (VOCs) include all
  compounds that nontoxic and non-HAP VOCs.

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How to Report VOC Emissions Correctly

• Total VOC minus (Toxics HAPS)
• equals
• Reportable VOCs
• or
• Volatile Organics (non-HAP)

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Reporting Particulate Matter

• All facilities must report particulate
  emissions, usually in two separate size
  fractions
• PM-Coarse (Particulate Matter between 2.5 and
  10 microns only)
• AND
• PM-Fine (Particulate Matter lt2.5 microns)

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Correctly Reporting PM

• Most natural gas combustion processes, produce
  particulate matter that is less than 2.5
  micrometers (microns).
• In these situations only PM-Fine should be
  reported

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PMfrom Natural Gas Combustion

• FIRE factor listings for PM-10 and PM-25 from a
  typical natural gas compressor engine

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Permit Limits for PM fromNatural Gas Combustion

• Many permits may refer only to PM-10
• This is obviously correct because its all less
  then 10 microns
• BUT
• It is also all less than 2.5 microns as well

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Correctly Reporting PM Avoid Double Counting

• PM-10 minus PM-2.5
• Equals
• PM-Coarse
• (Particulate Matter between 2.5 and 10 microns
  only)

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