FrequentErrors

by Carrie Schroeder

Areas of Discussion1. Facility Status Changes2. Substituting or Removing Equipment3. Source Classification Codes4. Hours as Process Rate5. Units6. Inconsistent Reporting7. Fuel Heat Content8. Controls9. Emission Factors10.Hazardous Air Pollutants (HAPs)11.Redbud Submissions12.Signed Documents

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#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 Active for the next

year so we can get a yearly status verification.

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#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.

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#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.

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#3 Source Classification Codes (SCC)

•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.

02 - Internal Combustion Engines, Industrial

2 - Internal Combustion Engines

002 - Internal Combustion Engines, Industrial, Natural Gas

54 - Internal Combustion Engines, Industrial, Natural Gas, 4-cycle Lean Burn

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#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.

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#4 Hours as Process Rate

•Actual Annual (activity) should be expressed as fuel combusted, raw material processed or product manufactured or handled.

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•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.

#5 Units

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• 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.

#6 Inconsistent Reporting

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#7 Fuel Heat Content

• When burning well or landfill gas report the true mmbtu per mmscf.

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#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.

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•Listing controls and efficiencies that do not apply to that pollutant.o Fabric filters and baghouses only control PMo Catalytic converters control CO, VOCs and/or NOxo Catalytic oxidizers control CO and VOCs

#8 Control Equipment

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•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

#9 Emission Factors

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Approximate Ranking of Reliability:Continuous Emissions Monitoring Data (CEMS)EPA RM Stack TestSimilar Unit EPA RM TestMass BalanceManufacture Test DataTANKS, GRI-GLYCalc, Vasquez-BeggsFire Data FactorsAP42, EPA Documents

#9 Emission Factors - Methods

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•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.

#10 Hazardous Air Pollutants

(HAPs)

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#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.

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#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.

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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.

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Any Questions?If you have questions, call us

and/or

make an appointment to visit us for assistance.

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