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Emissions Events Joe Janecka, P.E. – Central Office Jon Williams– Region 6 El Paso.

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Presentation on theme: "Emissions Events Joe Janecka, P.E. – Central Office Jon Williams– Region 6 El Paso."— Presentation transcript:

1 Emissions Events Joe Janecka, P.E. – Central Office Jon Williams– Region 6 El Paso

2 Presentation Outline Two Parts: Two Parts: What you do and What you do and What we do What we do

3 What You Do Regulatory knowledge, process or plant knowledge Regulatory knowledge, process or plant knowledge Reporting: Reportable Quantities (RQ) Reporting: Reportable Quantities (RQ) Reporting: STEERS Reporting: STEERS Reporting: Affirmative Defense Reporting: Affirmative Defense

4 Regulatory Knowledge Emissions events is an upset or unscheduled maintenance, start-up, or shutdown. 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. Regulated Entity must report an emission event meeting an RQ within 24 hours of the discovery of the event.

5 Regulatory 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 flow lines 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. 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 flow lines 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.

6 Process/Plant Knowledge What is contained in or flowing through your systems that may be emitted during an emissions event. What is contained in or flowing through your systems that may be emitted during an emissions event. Why? So you can quickly determine RQ Why? So you can quickly determine RQ Emission Points and their respective allowables. Emission Points and their respective allowables. Why? So you can determine unauthorized quantity Why? So you can determine unauthorized quantity

7 Reporting: RQ Refer to definition (88) in section 101.1 of 30 TAC Chapter 101. It will be the lowest of: 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 Code of Federal Regulations (CFR) Part 302, Table 302.4 40 CFR Part 355, Appendix A 40 CFR Part 355, Appendix A (III) individual contaminants listed in the definition (III) individual contaminants listed in the definition

8 Reporting: RQ RQ = 100 pounds when the contaminant cannot be found elsewhere in definition 30 TAC §101.1(88) for RQ RQ = 100 pounds when the contaminant cannot be found elsewhere in definition 30 TAC §101.1(88) for RQ

9 Reporting: RQ 30 TAC §101.1(88)(B) describes RQ for mixtures 30 TAC §101.1(88)(B) describes RQ for mixtures 30 TAC §101.1(88)(C) describesOPACITY 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. 30 TAC §101.1(88)(C) describesOPACITY 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.

10 Reporting: RQ 30 TAC §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. 30 TAC §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.

11 Case Examples: RQs Ammonia (gaseous) Ammonia (gaseous) Gasoline (spill) Gasoline (spill) Produced (unprocessed) natural gas Produced (unprocessed) natural gas

12 Case Examples: RQs § 302.4 40 CFR Ch. I (7–1–11 Edition) TABLE 302.4LIST OF HAZARDOUS SUBSTANCES AND REPORTABLE QUANTITIES Hazardous substance CASRN Statutory CodeRCRA waste NoFinal RQ pounds (Kg) Ammonia 7664–41–7 1 100 (45.4)

13 Case Examples: RQs Gasoline: 4% by volume Benzene Gasoline: 4% by volume Benzene 200 gal spill reported under 30 TAC §327.3 200 gal spill reported under 30 TAC §327.3 Estimated 50% volatilized Estimated 50% volatilized

14 Case Examples: RQs 100 gallons evaporated at.04 Benzene, 6.15 lb/gal 100 gallons evaporated at.04 Benzene, 6.15 lb/gal 24.6 lbs Benzene 24.6 lbs Benzene Same formula gasoline to reach RQ Benzene? Same formula gasoline to reach RQ Benzene? 100 lbs/6.15 = 16.3 gal/.04 = about 408 gallons (evaporated)

15 Case Examples: RQs Natural gas - RQ definition 101.1 (88)(B)(iv): Natural gas - RQ definition 101.1 (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 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) 100 lbs hydrogen sulfide and mercaptans (sour gas)

16 Reporting: STEERS STEERS: State of Texas Environmental Electronic Reporting System STEERS: State of Texas Environmental Electronic Reporting System Emissions Events: use Air Emissions and Maintenance Events (AEME) module in STEERS Emissions Events: use Air Emissions and Maintenance Events (AEME) module in STEERS

17 Reporting: STEERS Set-up an account and STEERS Participation Agreement (SPA) Set-up an account and STEERS Participation Agreement (SPA) The SPA, and the STEERS account, and the reporting is a personally certified process The SPA, and the STEERS account, and the reporting is a personally certified process

18 Reporting: STEERS Rules for probationary account 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 Initial 24 hour report can be done through probationary account. Final report requires a fully activated account with a completed SPA STEERS Helpline can assist you with your account STEERS Helpline can assist you with your account

19 Reporting: STEERS Initial report, best information you have, within 24 hours of your discovery of the event. Initial report, best information you have, within 24 hours of your discovery of the event. As 24 th hour approaches, RQ not met but emissions are still on-going and you are not sure, many people report out of abundance of caution As 24 th 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. Why? Because a timely report is needed for affirmative defense.

20 Reporting: STEERS Electronic reporting through STEERS required except: Electronic reporting through STEERS required except: Small businesses (may fax, but STEERS is encouraged) Small businesses (may fax, but STEERS is encouraged) When STEERS is down for any reason (at the agency) When STEERS is down for any reason (at the agency) When reported under the Spill Rules (30 TAC Chapter 327) When reported under the Spill Rules (30 TAC Chapter 327)

21 Reporting: STEERS When faxing an emissions event report: When faxing an emissions event report: Use Form 10360, follow instructions Use Form 10360, follow instructions Form can be found at: Form can be found at: http://www.tceq.texas.gov/field/cefoumform s.html http://www.tceq.texas.gov/field/cefoumform s.html Recommend downloading and printing the form and instructions – having it available when your computer or internet connection fails. Recommend downloading and printing the form and instructions – having it available when your computer or internet connection fails.

22 Reporting: Affirmative Defense A demonstration by the regulated entity for defense against enforcement A demonstration by the regulated entity for defense against enforcement Reports must be timely Reports must be timely The event must not be deemed excessive The event must not be deemed excessive RE must provide information addressing eleven factors listed in 30 TAC §101.222(b) RE must provide information addressing eleven factors listed in 30 TAC §101.222(b)

23 Reporting: Affirmative Defense Enter your information supporting the eleven demonstration criteria in the STEERS AEME reporting form in the field labeled: Enter your information supporting the eleven demonstration criteria in the STEERS AEME reporting form in the field labeled: Basis Used to Determine Quantities and Any Additional Information Necessary to Evaluate the Event:

24 STEERS reporting help STEERS helpline: 512-239-6925 STEERS Help at: https://www3.tceq.texas.gov/steers/help/main.html


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