SAFAA EL-ORABY DAPC-CO-EIS FACILITY PROFILE REVIEW IN AIR SERVICES

DAPC Air Program Workshop December 6, 2011

Introduction 11/2010 DAPC – CO began outreach program to TV facilities to obtain the most accurate and complete facility profiles possible. 90 profiles reviewed and 66 facilities contacted. Profile and emissions data are sent to US EPA The profile is used in key calculations for emissions reporting and the information is used for air quality planning purposes. Correct profile information is important in terms of accurately representing the emissions at the facility.

Air Services is designed to reflect the operations at the facility as represented by the airflow from each source process to the ambient air, as permitted The facility profile may contain an EU which does not exist at the facility. Such EUs should be invalidated or permanently shutdown. Profile facility contacts are not updated as roles or people change. This must be maintained so the proper person can be contacted as needed. The following topics are included in this help page: View or Update Current Owner/Contact Information Start Date and End Date Create a New Contact Person Assign Contact Type Change/Assign Ownership GENERAL ISSUES

Correct Profile Tree Configurations for Significant Units. Basic Configurations Emissions Unit Control Equipment Emissions Process Egress Point 1a 1b

Questionable Profile Tree Configurations for Significant Emissions Units The tree contains the proper EU, CE, and EP but may be configured incorrectly such that it does not reflect true conditions or order at the facility which will in turn affect air flow representation. If configurations appear suspect, follow-up with the facility to determine their validity and if needed, assist with the reconfiguration of the tree. Accurate facility profile configuration is essential for proper auto- calculations of emissions.

Questionable Configurations Parallel Control Equipment An EU with one process and 2 CE in parallel (i.e., 50% of process flow goes to each control device) Controls in parallel are usually of the same type where multiple controls are needed to capture and treat the air flow such as coating lines w/multiple fabric filters Revise process names to exclude “TEMP” used during data migration from STARShip

Questionable Configurations Missing EP? This configuration may be correct as it stands or it may be missing another EP be it a stack or fugitive

Questionable Configurations Numerous EPs If the EPs are Stacks and the company carefully identified all of them in the facility tree, the tree should not be changed.

Questionable Configurations Numerous CE This configuration contains too many controls for one process. It is highly unlikely that this process has so many controls in parallel as well as in series

Questionable Configurations It is unlikely that all the CEs and EPs belong to one process while the other is not controlled or linked to a stack.

CONTROL EQUIPMENT Incomplete CE data in the profile Specific Equipment Type Information Section The Answer Place has an excel spreadsheet link in: Air Services Facility Profile QA checks Which allows the Air Services user to know what is required when so that the user can determine the best time to enter data that may be required at some point of interaction with the system.

CONTROL EQUIPMENT An incomplete PM panel in the pollutants controlled section. This section must include PM10-fil which is a criteria pollutant and possibly PM2.5- fil if from burning fuels. (Similarly for the FER.) Question the 100% Efficiency

CONTROL EQUIPMENT This is a complete PM Panel for EIS Generally % Efficiency drops as particle size decreases. Wet ESP, only PM10 drops

CONTROL EQUIPMENT Missing control efficiencies (No Reduction), or a very low value such as 9% Pollutants identified as being controlled in the profile are not reported in the FER FER must be reviewed for consistency with profile. QA checks do not always detect discrepancies

CONTROL EQUIPMENT Pollutants NOT being controlled by CE are NOT to be included in the Pollutants controlled section. Filter/Baghouse

EGRESS POINT Incorrect EP release type selected Fugitive -Volume: vertical openings such as windows, doors or roof vents Fugitive – Area: For irregular surfaces such as storage piles, roadway, or a worksite Egress Point data is missing such as Base elevation, Release height, Fence line distance, building dimensions, lat/long, or stack detail. Can guesstimate fence line distance by walking it.

EGRESS POINT Release Heights lower than Building Height This data may be correct due to differing roof levels, side of building, on the ground, or inside the building. Or it may be incorrect due to erroneous measurements. Request confirmation from the facility

EGRESS POINT Missing fugitive EP if CE’s capture efficiency is below 100%. Or Conversely having Fug EP when Cap % is 100. Whichever option the facility chooses, the FER must be in sync with the profile. Fugitive emissions must be reported if cap % is less than 100% Answer Place topic: Air Services Facility Profile and Processes with Less Than 100 Percent Capture Efficiency

PROCESS Two processes for an EU cannot be identified with one SCC. A coating line with an oven requires 2 SCC, one for the process and one for the oven fuel. EIS requires individual processes to be recognized in the profile tree and in the report with separate SCC and emissions Cannot combine emissions from separate processes in the FER. Generally, emissions from fuel combustion should be reported separately from process emissions with some limited exceptions. If unable to separate emissions such as with cement kilns or asphalt operations can report combined emissions.

PROCESS EUs should not be missing a process in the profile as T005 shows. Although their emissions are not being reported, an SCC must be selected for an operating EU to have a complete profile. Incorrect SCC used or too general of a description when a more specific description is available Once an EU is installed, the facility must provide all three dates shown below.

PROCESS Incorrect SCC used or too general of a description when a more specific SCC description is available. Use cascading levels to select most suitable SCC or search by keyword to view all possible suitable SCC’s available. All ‘Z’ EUs should be renamed per the draft engineering guide.

Emissions Reporting FER pollutants are: SO2, NOx, OC, Lead, PM-FIL Excluding VOC emissions for fear of double counting OC emissions or paying double. Air Services is designed to NOT double count these emissions EIS Pollutants are: NOx, VOC, SO2, Lead, OC, CO, NH3, PM- CON, PM-FIL, PM 10 -FIL and PM 25 -FIL VOC,PM2.5-fil, and PM10-fil are not always reported. Must report all EIS pollutants if one pollutants triggers reporting even if under 1 ton.

EMISSIONS REPORT Incomplete reporting of emissions because small amounts have been rounded up to zero rather than report Each emissions field can take 6 figures or use exponential (E) as used when reporting HAPs. No emissions should be rounded to zero. Reporting combined emissions even with separate processes identified in the profile. Each process must have its own emissions reported without being referred to another process. Therefore no process should report zero emissions

FEE EMISSIONS REPORT Calculations are NOT being attached to the FER. Explanations provided are not useful and do not contain calculations. Numerous EUs with zero emissions clutter the FER tree. Use the exclusion button to exclude EUs from FER that do not have reportable emissions

FEE EMISSIONS REPORT Selecting an improper “Method Used” to calculate emissions such as stack testing when there is no stack. Answer Place Topic: Calculating emissions for emissions reporting - using the best method Incomplete reporting of pollutant per the SCC. WebFIRE: Not all inclusive web/index.cfm?action=fir e.main web/index.cfm?action=fir e.main Permit, other NAICS sources

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