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Emissions Events
Joe Janecka, P.E. – Central Office
Jon Williams– Region 6 El Paso
Presentation Outline
Two Parts:
What you do and
What we do
What You Do
Regulatory knowledge, process or plant knowledge
Reporting: Reportable Quantities (RQ) Reporting: STEERS Reporting: Affirmative Defense
Regulatory 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.
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.
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 302.440 CFR Part 355, Appendix A (III) individual contaminants listed in the
definition
Reporting: RQ
RQ = 100 pounds when the contaminant cannot be found elsewhere in definition 30 TAC §101.1(88) for RQ
Reporting: RQ
30 TAC §101.1(88)(B) describes RQ for mixtures
30 TAC §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
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.
Case Examples: RQs
Ammonia (gaseous) Gasoline (spill) Produced (unprocessed) natural gas
Case Examples: RQs
§ 302.4 40 CFR Ch. I (7–1–11 Edition)TABLE 302.4—LIST OF HAZARDOUS SUBSTANCES AND REPORTABLE QUANTITIES
Hazardous substance
CASRN Statutory Code 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
§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 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
100 lbs hydrogen sulfide and mercaptans (sour gas)
Reporting: STEERS
STEERS: State of Texas Environmental Electronic Reporting System
Emissions Events: use Air Emissions and Maintenance Events (AEME) module in STEERS
Reporting: STEERS
Set-up an account and STEERS Participation Agreement (SPA)
The SPA, and the STEERS account, and the reporting is a personally certified process
Reporting: STEERS
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
STEERS Helpline can assist you with your account
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: 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
When faxing an emissions event report:Use Form 10360, follow instructionsForm can be found at:
http://www.tceq.texas.gov/field/cefoumforms.htmlRecommend downloading and printing
the form and instructions – having it available when your computer or internet connection fails.
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 §101.222(b)
Reporting: Affirmative Defense
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:”
STEERS reporting help
STEERS helpline: 512-239-6925
STEERS Help at:https://www3.tceq.texas.gov/steers/help/main.html