General Issues & Reporting Guidance Emissions Inventory Workshop 2014 1

General IssuesGeneral Issues&&

Reporting GuidanceReporting Guidance

Emissions Inventory Workshop 2014 1

Topics to DiscussTopics to Discuss Recent Rule ChangesRecent Rule Changes

Lower Reporting Guidance Lower Reporting Guidance ChangeChange

Pneumatic DevicesPneumatic Devices

Typical Reporting IssuesTypical Reporting Issues

The Invoicing ProcessThe Invoicing Process


Changes to Subchapter 5Changes to Subchapter 5

OAC 252:100-5OAC 252:100-5

Registration, Emission Inventory Registration, Emission Inventory and Annual Operating Feesand Annual Operating Fees


SC-5 Rule ChangesSC-5 Rule Changes Became effective September 10, 2013Became effective September 10, 2013

Minor rule clarifications:Minor rule clarifications: Eliminated requirement to report “physical state Eliminated requirement to report “physical state

of contaminant” and “moisture content of the of contaminant” and “moisture content of the gas stream”gas stream”

Updated reporting method to emphasize Updated reporting method to emphasize electronic reportingelectronic reporting

Permit number now not requiredPermit number now not required

Confidentiality of proprietary information – Confidentiality of proprietary information – corrected reference to the Oklahoma Statutecorrected reference to the Oklahoma Statute


SC-5 Rule ChangesSC-5 Rule ChangesInventories for Permit by Rule (PBR) Inventories for Permit by Rule (PBR) Facilities – New reporting scheduleFacilities – New reporting schedule

PBR facilities must submit inventory for 2014 or PBR facilities must submit inventory for 2014 or the first calendar year registered under a PBR (if the first calendar year registered under a PBR (if registered after 12/31/2014)registered after 12/31/2014)

After the initial inventory submittal:After the initial inventory submittal: PBR facility > 5 Ton/year of any RAP – every NEI PBR facility > 5 Ton/year of any RAP – every NEI

three year cyclethree year cycle

PBR facility ≤ 5 Ton/year of any RAP – every PBR facility ≤ 5 Ton/year of any RAP – every second NEI three year cyclesecond NEI three year cycle

PBR facilities may elect to also submit an PBR facilities may elect to also submit an emissions inventory for non-NEI reporting years emissions inventory for non-NEI reporting years


SC-5 Rule ChangesSC-5 Rule Changes

What this means for Permit by Rule What this means for Permit by Rule (PBR) facilities for 2013 Reporting:(PBR) facilities for 2013 Reporting:

If a facility applied for a PBR in 2013 then an If a facility applied for a PBR in 2013 then an inventory will NOT be due provided the facility inventory will NOT be due provided the facility would have qualified for a PBR throughout all of would have qualified for a PBR throughout all of 20132013

If there was an equipment change or a decline in If there was an equipment change or a decline in production the facility may still need to report for production the facility may still need to report for 20132013


Lower Emission AmountLower Emission Amount

Reporting GuidanceReporting Guidance


Lower Emission AmountLower Emission AmountReporting GuidanceReporting Guidance

There is no lower reporting limit in SC-5There is no lower reporting limit in SC-5

AQD provides reporting guidance that is “prudent AQD provides reporting guidance that is “prudent and practical”and practical”

For 2010, 2011 and 2012 reporting years guidance For 2010, 2011 and 2012 reporting years guidance was that emissions of 0.001 tons or greater of any was that emissions of 0.001 tons or greater of any regulated air pollutant must be reported from each regulated air pollutant must be reported from each processprocess

Recent data analysis and a review of program Recent data analysis and a review of program needs has allowed us to revise this guidanceneeds has allowed us to revise this guidance



For the 2013 Reporting Year our guidance will be For the 2013 Reporting Year our guidance will be emissions of 0.1 tons or greater of any regulated emissions of 0.1 tons or greater of any regulated air pollutant at a process must be reportedair pollutant at a process must be reported

Key exceptions must still be reported at 0.001 tons Key exceptions must still be reported at 0.001 tons or greater per process:or greater per process:

Lead, mercury & hexavalent chromiumLead, mercury & hexavalent chromium

Any HAP at a TRI facilityAny HAP at a TRI facility

Any HAP from glycol dehydration still ventsAny HAP from glycol dehydration still vents

Any HAP from large storage tanks (>500 BBL)Any HAP from large storage tanks (>500 BBL)

Other situations where deemed necessaryOther situations where deemed necessary



You can still continue to report to 0.001 tons You can still continue to report to 0.001 tons per process if you choose toper process if you choose to

Trace Checkbox is available for <0.001 tons Trace Checkbox is available for <0.001 tons if you wish to use thisif you wish to use this

Contact us to remove unnecessary pollutantsContact us to remove unnecessary pollutants




Area Oil & Gas Emissions Area Oil & Gas Emissions ToolTool


Source Category VOC (TPY)

Artificial Lift 87

Associated Gas 1,295

Condensate Tanks 20,944

Crude Oil Tanks 25,825

Dehydrators 5,829

Drill Rigs 162

Fugitives 11,206

Gas-Actuated Pumps 15,932

Heaters 577

Hydraulic Fracturing 16

Lateral/Gathering Compressors 511

Liquids Unloading 20,658

Loading Emissions 4,823

Mud Degassing 11,094

Pneumatic Devices 86,614

Produced Water 0

Well Completions 1,917 - Natural Gas well completions

334

Wellhead Compressor Engines 1,044

Total 208,533

Area Oil & Gas Emissions Area Oil & Gas Emissions ToolTool

More information:More information:

CenSARA StudyCenSARA Study

www.deq.state.ok.us/AQDnew/emissions/OilandGasAreaEmissions

EPA National Oil & Gas Emissions Estimation EPA National Oil & Gas Emissions Estimation ToolToolwww.epa.gov/ttn/chief/net/2011inventory.html


Pneumatic DevicesPneumatic Devices Pneumatic Devices account for over 40% of all Pneumatic Devices account for over 40% of all

VOC emissions from wellhead facilitiesVOC emissions from wellhead facilities

Poorly characterized source that is present at Poorly characterized source that is present at many types of Oil & Gas production, processing many types of Oil & Gas production, processing and transmission facilitiesand transmission facilities

Need to start collecting more data to improve Need to start collecting more data to improve both point and area inventoriesboth point and area inventories

2014 will be an important reporting year2014 will be an important reporting year Optional to report for 2013, required for 2014Optional to report for 2013, required for 2014

Work with companies this year to constrain Work with companies this year to constrain uncertainties in counts and bleed ratesuncertainties in counts and bleed rates



Specific SCC’s are now available in Redbud, Specific SCC’s are now available in Redbud, depending on:depending on:One of three device types (matches Subpart W One of three device types (matches Subpart W GHG reporting):GHG reporting):

Low Bleed (≤ 6 scf/hr)Low Bleed (≤ 6 scf/hr) High Bleed (> 6 scf/hr)High Bleed (> 6 scf/hr) IntermittentIntermittent

One of four sectors:One of four sectors: Gas Production Gas Production (SIC 1311)(SIC 1311) Oil Production Oil Production (SIC 1311)(SIC 1311) Gas Processing Gas Processing (SIC 1321)(SIC 1321) Gas TransmissionGas Transmission (SIC 4922)(SIC 4922)



General ReportingGeneral ReportingIssuesIssues


Change of OwnershipChange of Ownership


Responsibilities of the:

Transferor (Seller)“The transferor shall notify the DEQ using a prescribed form

no later than 30 days following the change in ownership.”

Transferee (Purchaser)“The transfer of ownership of a stationary source or a

facility is an administrative amendment that shall subject the new owner or operator to existing permit conditions and/or compliance schedules.”

Change of OwnershipChange 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 year’s inventory

- Even if sale took place within the reporting year

Changing Facility Changing Facility

InformationInformationForm #100-883Form #100-883


Changing a Responsible Changing a Responsible

OfficialOfficialForm #100-882Form #100-882


Status of Inactive FacilitiesStatus of Inactive Facilities

Reset to Active for New Reporting Reset to Active for New Reporting YearYear

Status Must be Verified YearlyStatus Must be Verified Yearly

If Active at any time, status is If Active at any time, status is Active for that reporting year Active for that reporting year


Facility StatusFacility Status New Classification – “Not yet built”New Classification – “Not yet built”

E.g., permit applied for in 2013 but E.g., permit applied for in 2013 but construction has not yet startedconstruction has not yet started

Add a brief facility note if necessaryAdd a brief facility note if necessary

Exempt or De Minimis facilities must Exempt or De Minimis facilities must be removed completely from Redbudbe removed completely from Redbud

Contact us to do soContact us to do so


Emission Unit and Stack Emission Unit and Stack StatusStatus

OperatingOperating – operated all or part of – operated all or part of the calendar year the calendar year

Temporarily ShutdownTemporarily Shutdown – did not – did not

operate at all during the calendar operate at all during the calendar year, but may restart at sometime in year, but may restart at sometime in the futurethe future

Permanently ShutdownPermanently Shutdown – has been – has been physically removed or is physically removed or is permanently shutdownpermanently shutdown


Emission Unit and Stack Emission Unit and Stack StatusStatus

Operating and Temporarily Shutdown:Operating and Temporarily Shutdown:Remains in your inventoryRemains in your inventory

Permanently Shutdown: Permanently Shutdown: Drops from your inventory the next yearDrops from your inventory the next year

Example: Emission unit operated through June 2013 then physically Example: Emission unit operated through June 2013 then physically removed from the facility in September 2013removed from the facility in September 2013

Status for 2013 – OperatingStatus for 2013 – Operating

Status for 2014 – Permanently ShutdownStatus for 2014 – Permanently Shutdown

Status for 2015 – Not in inventoryStatus for 2015 – Not in inventory


Replacement Replacement EquipmentEquipment

Create a new emission unitCreate a new emission unit

Report data for original and replacement Report data for original and replacement equipment separatelyequipment separately

Preferably include notes explaining the Preferably include notes explaining the situation at both unitssituation at both units

Report original equipment as permanently Report original equipment as permanently shutdown the next year. It will then drop shutdown the next year. It will then drop out of the inventory in the second year.out of the inventory in the second year.


Ensure Data is ConsistentEnsure Data is Consistent

If Emission Unit Status = ActiveIf Emission Unit Status = Active

Operating Hours > 0Operating Hours > 0

Process Rates > 0Process Rates > 0

Emissions > 0Emissions > 0


Storage Tank EmissionsStorage Tank Emissions Emissions released from the bottom of a tank Emissions released from the bottom of a tank

that has no throughput must be reportedthat has no throughput must be reported Tank would be reported as ActiveTank would be reported as Active

Tanks linked together can be reported as a Tanks linked together can be reported as a single emission unitsingle emission unit

Combined SCC 40400311 (working + breathing Combined SCC 40400311 (working + breathing + flashing) may be used for condensate tanks + flashing) may be used for condensate tanks with < 6 ton per year total VOC emissions.with < 6 ton per year total VOC emissions.


Calculating Condensate Tank Calculating Condensate Tank EmissionsEmissions

TANKS Version 4.09D: TANKS Version 4.09D: Estimates VOC and HAP emissions from fixed- and floating-roof storage Estimates VOC and HAP emissions from fixed- and floating-roof storage

tanks. Used for calculating working and breathing loss emissions.tanks. Used for calculating working and breathing loss emissions.www.epa.gov/ttnchie1/software/tanks

Vasquez Beggs equation: Vasquez Beggs equation: Used for calculating flashing lossesUsed for calculating flashing losseswww.deq.state.ok.us/aqdnew/resources/Calculations11.xls

RVP 10:RVP 10: Is the closest default to condensate for the TANKS programIs the closest default to condensate for the TANKS program

Report Working, Breathing and Flashing lossesReport Working, Breathing and Flashing losses


Common Stack ReportingCommon Stack Reporting If you have all tank emissions going to a flare, create an If you have all tank emissions going to a flare, create an

emission unit for the tank emissions with a flare as the emission unit for the tank emissions with a flare as the control and another emission unit for the flare itself to control and another emission unit for the flare itself to show the combustion emissionsshow the combustion emissions

BOTH units will list the same common stackBOTH units will list the same common stack

If you have all emissions going to a thermal oxidizer, If you have all emissions going to a thermal oxidizer, create an emission unit for the process emissions with a create an emission unit for the process emissions with a thermal oxidizer as the control and another emission unit thermal oxidizer as the control and another emission unit for the thermal oxidizer to show the combustion for the thermal oxidizer to show the combustion emissionsemissions

BOTH units will list the same common stackBOTH units will list the same common stack


Emissions Inventory Workshop 2014

Common Stack – Flare as ControlCommon Stack – Flare as Control

31

Common Stack – Flare Common Stack – Flare CombustionCombustion


Inventory CorrectionsInventory Corrections During the reporting season, corrections to the current During the reporting season, corrections to the current

reporting year are accomplished by making changes in Redbud reporting year are accomplished by making changes in Redbud and resubmittingand resubmitting

Last submission overwrites any earlier onesLast submission overwrites any earlier ones

Corrections after the reporting season can not be entered in Corrections after the reporting season can not be entered in RedbudRedbud

Corrections should be marked up in Corrections should be marked up in RedRed on a hardcopy of the on a hardcopy of the Turnaround Document (TAD) from the appropriate yearTurnaround Document (TAD) from the appropriate year

Corrections must be certified by the Responsible Official with an Corrections must be certified by the Responsible Official with an original signature and mailed to our officeoriginal signature and mailed to our office

Redbud TAD has a signature page that can be used in these Redbud TAD has a signature page that can be used in these circumstancescircumstances


34Emissions Inventory Workshop 2014

Certifying CorrectionsCertifying Corrections Submissions made through Redbud during the Submissions made through Redbud during the

reporting season do not need a hardcopy signaturereporting season do not need a hardcopy signature

The statement below is on all Redbud TAD’s in case The statement below is on all Redbud TAD’s in case it is needed for later hardcopy correctionsit is needed for later hardcopy corrections

Redbud Browser Redbud Browser CompatibilityCompatibility

Redbud is best used with Internet Explorer 5.5 or higherRedbud is best used with Internet Explorer 5.5 or higher

To correct compatibility problems with Internet 10 and 11:To correct compatibility problems with Internet 10 and 11: Select Tools in your Menu Bar, then select compatibility viewSelect Tools in your Menu Bar, then select compatibility view Add state.ok.us to the compatibility viewAdd state.ok.us to the compatibility view


Air Quality Operating FeeAir Quality Operating Fee

Invoicing ProcessInvoicing Process


Annual Operating Fee Annual Operating Fee InvoicesInvoices

Invoices are mailed on July 1, normally Invoices are mailed on July 1, normally addressed to the Responsible Officialaddressed to the Responsible Official

Emissions are billed 2 years in arrearsEmissions are billed 2 years in arrears CY 2014 Operating fees will be based on CY 2012 emissions CY 2014 Operating fees will be based on CY 2012 emissions

Payment due 30 days after billingPayment due 30 days after billing

Companies with <5 Tons total are not Companies with <5 Tons total are not invoicedinvoiced


Annual Operating Fee Annual Operating Fee InvoicesInvoices

PBR facilities will be assessed an annual operating PBR facilities will be assessed an annual operating fee each year based on the most recent emissions fee each year based on the most recent emissions inventory submission.inventory submission.

The current facility owner is responsible for The current facility owner is responsible for invoiced fees regardless of facility ownership invoiced fees regardless of facility ownership during the year in which emissions were released.during the year in which emissions were released.

Title V fees are adjusted yearly based on the CPI. Title V fees are adjusted yearly based on the CPI. The 2014 Title V fees will be $36.33 per ton.The 2014 Title V fees will be $36.33 per ton.

Non-Title V fees are fixed at $25.12 per ton.Non-Title V fees are fixed at $25.12 per ton.


Heads Up!Heads Up! 2014 will be an important reporting year2014 will be an important reporting year

Triennial NEI year, likely base year for non-attainment planningTriennial NEI year, likely base year for non-attainment planning

Data quality will be vital for developing effective control Data quality will be vital for developing effective control strategiesstrategies

Get 2013 in best possible shape nowGet 2013 in best possible shape now Comprehensive 2014 inventory of Oil & Gas area and point Comprehensive 2014 inventory of Oil & Gas area and point

sources will be criticalsources will be critical

All PBR facilities will have to report for 2014All PBR facilities will have to report for 2014

We are developing processes for companies with large We are developing processes for companies with large numbers of similar facilities to directly export from their numbers of similar facilities to directly export from their databases to Redbuddatabases to Redbud

Avoids needing to do data entry in RedbudAvoids needing to do data entry in Redbud Not necessarily easy – requires significant technical expertise Not necessarily easy – requires significant technical expertise


Important Proposed ChangeImportant Proposed Changefor Reporting VOC in 2014for Reporting VOC in 2014

Go from reportingGo from reportingSpeciated HAPs plus VOC (non-HAP)Speciated HAPs plus VOC (non-HAP)

totoTotal VOC plus HAPsTotal VOC plus HAPs

Should reduce errors and confusionShould reduce errors and confusion

Consistency with most published emission factorsConsistency with most published emission factors

Oklahoma Clean Air Act does not allow double billing for Oklahoma Clean Air Act does not allow double billing for pollutants that are in multiple categoriespollutants that are in multiple categories

Invoices will continue to charge for HAPs and VOC (non-HAP)Invoices will continue to charge for HAPs and VOC (non-HAP)

Allow industry sufficient lead time to prepare for this Allow industry sufficient lead time to prepare for this changechange


Questions?Questions?

41Emissions Inventory Workshop 2014

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Documents

General Issues & Reporting Guidance Emissions Inventory Workshop 2014 1