Pennsylvania Environmental Reporting ARIPPA January 2006 Meeting January 30, 2007 Altoona, PA Carole Hamner trinityconsultants.com.

Pennsylvania Environmental Reporting

ARIPPA January 2006 MeetingJanuary 30, 2007

Altoona, PACarole Hamner

trinityconsultants.com

Introductions

Trinity ConsultantsTrinity ConsultantsFrederick, MD Carole Hamner

Managing Consultant5320 Spectrum Drive, Suite C

Frederick, MD 21703(240) 379-7490

Objectives

Gain an understanding of various federal and state environmental reporting obligations for facilities located in Pennsylvania

Integrate topics with real-world examples

Have a practical reference text for future reporting activities

Pennsylvania Reporting – Agenda(1 of 2)(1 of 2)

Introduction & Agency Overview Tier II Reporting Residual Waste Reporting Hazardous Waste Reporting Annual Emissions Statements

Pennsylvania Environmental Pennsylvania Environmental ReportingReporting

Agency Overview

PaDEP

Pennsylvania Department of Environmental Protection (PaDEP)(PaDEP) Main Office

Rachel Carson State Office Building in Harrisburg

Secretary of PaDEP, Kathleen McGinty Six Regional Offices

Responsible for Directing Environmental Programs in Region

PaDEP Bureaus Air Management Water Management

Bureau of Water Standards and Facility Regulation

Bureau of Watershed Management Bureau of Waterways Engineering Water Planning Office

Waste Management

Region 1Southeast Regional Office2 East Main StreetNorristown, PA 19401(484) 250-5920(484) 250-5921 faxCounties: Bucks, Chester, Delaware, Montgomery, Philadelphia

Region 2Northeast Regional Office2 Public SquareWilkesbarre, PA 18711-0790(570) 826-2435(570) 826-2357 faxCounties: Carbon, Lackawanna, Lehigh, Luzerne, Monroe, Northampton, Schuylkill, Susquehanna, Wayne, Wyoming

Region 3South Central Regional Office909 Elmerton AvenueHarrisburg, PA 17110-8200(717) 705-4702

(717) 705-4710 fax Counties: Adams, Bedford, Berks, Blair, Cumberland, Dauphin, Franklin, Fulton, Huntingdon, Juniata, Lancaster, Lebanon, Mifflin, Perry, York

Region 4North Central Regional Office208 West Third StreetWilliamsport, PA 17701 (570) 327-3648, (570) 327-3565 faxCounties: Bradford, Cameron, Centre, Clearfield, Clinton, Columbia, Lycoming, Montour, Northumberland, Potter, Snyder, Sullivan, Tioga, Union

Region 5Southwest Regional Office400 Waterfront DrivePittsburgh, PA 15222-4745(412) 442-4161(412) 442-4194 faxCounties: Allegheny, Armstrong, Beaver, Cambria, Fayette, Greene, Indiana, Somerset, Washington, Westmoreland

Region 6Northwest Regional Office230 Chestnut StreetMeadville, PA 16335-3481(814) 332-6940(814) 332-6125 fax Counties: Butler, Clarion,Crawford, Elk, Erie, Forest, Jefferson, Lawrence, Mckean, Mercer, Venango, Warren

DEP RegionalOffices

Pennsylvania’s Environmental Regulations (1 of 2)(1 of 2)

Title 25 Environmental Protection Part I. Department of

Environmental Protection Part II. State Board for Certification

of Sewage Treatment Plant and Waterworks Operators

Part VII. PA Infrastructure Investment Authority

Part VIII. UST Indemnification Board Part IX. Environmental Hearing

Board

Pennsylvania’s Environmental Regulations (2 of 2)(2 of 2)

Title 25 Environmental Protection Part I. Department of Environmental

Protection Subpart A. Preliminary Provisions Subpart C. Protection of Natural Resources

Article I. Land Resources Article II. Water Resources Article III. Air Resources

Subpart D. Environmental Health and Safety

Allegheny County Health Department (ACHD)

Air Pollution Control regulations contained in the Allegheny Health Department Rules and Regulations, Article XXI Air Pollution Control

ACHD is responsible for enforcement of Article XXI as well as State and Federal regulations controlling air pollution

ACHD Article XXI Regulations (1 of 2)(1 of 2)

Part A. General Part B. Permits Generally Part C. Operating Permits

Subpart 1 – All Major and Minor Permits Subpart 2 – Additional Requirements for Major Permits Subpart 3 – Additional Requirements Generally Subpart 4 – Operating Permit Fees Subpart 5 – Acid Deposition Control

Part D. Pollutant Emission Standards Part E. Source Emission & Operating Standards

Subpart 1 – VOC Sources Subpart 2 – Slag, Coke, and Miscellaneous Sulfur

Sources Subpart 3 – Incineration and Combustion Sources

ACHD Article XXI Regulations (2 of 2)(2 of 2)

Part E. Source Emission & Operating Standards (cont.) Subpart 4 – Miscellaneous Fugitive Sources Subpart 5 – Open Burning and Abrasive Blasting

Sources Subpart 6 – Asbestos Sources Subpart 7 – Miscellaneous VOC Sources Subpart 8 – {Reserved} Subpart 9 – Transportation Related Sources Subpart 10 – NOx Sources

Part F. Air Pollution Episodes Part G. Methods Part H. Reporting, Testing, & Monitoring Part I. Enforcement

Environmental Regulations Links

Pennsylvania: http://www.pacode.com/secure/data/025/025toc.html

Federal:

http://www.epa.gov/epahome/cfr40.htm ACHD:

http://www.achd.net/airqual/pubs/pdf/polctrl.pdf

Chapter 2

TIER II REPORTING

Tier II Report Who?

Facilities that have on site at any one time: 10,000 lb or more hazardous substance Greater than the threshold quantity of an

extremely hazardous substance What?

Tier II Report – Hazardous materials inventory When?

March 1 every year

Due Dates Annual ReportAnnual Report

Due March 1March 1 Initial ReportInitial Report

Within 5 days of exceeding threshold for hazardous substance or extremely hazardous substance (EHS)

Send reports to: Local Fire Department Local Emergency Planning Committee Department of Labor & Industry Bureau of PENNSAFE PO Box 68571 Harrisburg, PA 17106-8571 Telephone (717) 783-2071

Where to Send Report

Filing Fee

Fees: $10 per chemical per year Must be included with Initial Initial and Annual Annual

ReportsReports

Where to Obtain Forms

Web site for form: http://www.dli.state.pa.us/landi/cwp/view.asp?a=144&Q=65642

Hazardous Substance(1 of 3)(1 of 3)

Review MSDS (Regulatory Information Section) Regulated under

EPCRA Sections 302, 311, 312 and/or 313EPCRA Sections 302, 311, 312 and/or 313

Included in one or more hazard categories(acute, chronic, fire, pressure, reactivity)(acute, chronic, fire, pressure, reactivity)

Regulated under“OSHA HCS” “OSHA HCS” oror “29 CFR 1910.1200” “29 CFR 1910.1200”

MSDS – Control and NFPA Fire

Diamond

Protective Measures HMIS Hazard

RatingsOne or more of the ratings is 2 or moreEvery category has a hazard rating of 0

Reportable

Exempt

Otherwise, call the Otherwise, call the DSHSDSHS

Hazardous Substance(3 of 3)(3 of 3)

Gasoline and Diesel Fuel

Each reportable as one substanceone substance with its own CASCAS

Different grades may be consolidated/reported as “Gasoline”“Gasoline” or “Diesel Fuel”“Diesel Fuel”

Minimum quantities for reporting Gasoline 1,585 gallons Diesel Fuel 1,400 gallons

Lead Acid Batteries Total weight of all batteries > 10,000 lb> 10,000 lb

Report as Lead Acid BatteriesLead Acid Batteries (Common Name)

List Chemicals and Include CAS numbers for Sulfuric acid Lead

Total weight of pure sulfuric acid > 500 lb> 500 lb Report in separate chemical description Report in separate chemical description

blockblock

Sulfuric Acid Wt. = Battery Wt. * Electrolyte % * Sulfuric Acid Sulfuric Acid Wt. = Battery Wt. * Electrolyte % * Sulfuric Acid Content %Content %

Sulfuric Acid Wt. = Battery Wt. * 0.18 Sulfuric Acid Wt. = Battery Wt. * 0.18 (estimation method)(estimation method)

Lead Acid Battery - Example

A warehouse has several batteries with the following properties:

Total Battery Weight 12,000 lbs

% Electrolyte in Batteries 40% % Sulfuric Acid in Electrolyte 20%

What should be reported on the Tier Two?

Total Weight of All Batteries1 > 10,000 > 10,000 lbslbs Report Lead Acid BatteriesLead Acid Batteries

Calculate Total Weight of Sulfuric Acid Sulfuric Acid Wt. = Battery Wt. * Electrolyte % * Sulfuric Acid Sulfuric Acid Wt. = Battery Wt. * Electrolyte % * Sulfuric Acid

Content %Content % 960 lb = 12,000 lb * 40% * 20%960 lb = 12,000 lb * 40% * 20%

Total Weight of Sulfuric Acid > 500 lbs> 500 lbs Report Sulfuric AcidSulfuric Acid

Lead Acid Battery - Example

1Exceptions: Consumer Products, including vehicle batteries if purchased from manufacturer who sells same product to public.

Chapter 3

RESIDUAL WASTE Source Reduction Strategy and Source Reduction Strategy and

Biennial ReportBiennial Report

PA Source Reduction Strategy

Unique to Pennsylvania, requires two separate reports: Source Reduction Strategy (Form

25R) Biennial report

Applies to Residual Waste and Hazardous Waste

Residual Waste Streams Non hazardous:

Waste oil Scrap metal Baghouse filters, baghouse dust Industrial packaging materials Sludge Waste filters, packing materials, screens,

etc. from the industrial process Ash Waste equipment

Streams Not Considered Residual Waste

Sanitary sewage Process wastewater discharged to

POTW Uncontaminated non-contact

cooling water Office, restroom, lunchroom wastes Construction debris/waste

Source Reduction Strategy Who?

Large quantity generators of residual waste Generate > 2200 lb residual or hazardous

waste in any one month in a calendar year What?

Source reduction strategy When?

Keep on site, update every five years and when there are changes that affect waste status

Residual Waste Definition Summary

Residual waste is non hazardous industrial waste

Includes waste material produced by industrial, mining and agricultural operations

Excludes Certain coal mining wastes General municipal solid waste

(office/cafeteria waste)

Source Reduction Definition

The reduction or elimination of quantity or toxicity of waste through operational changes Process modifications Feedstock substitutions Shipping and packing modifications Housekeeping/management practices Machinery efficiency Recycling within process

Does not include dewatering, compaction, waste reclamation or the use or reuse of waste

Develop Source Reduction Strategy For Each Waste Stream:

ID source Generation Rate

Reduction Options

Properties-Chemical analysis

Management Techniques

Evaluation of options

Hazards Management Costs

Explanation of choices

Download from PA DEP web site:http://www.depweb.state.pa.us/landrecwaste/cwp/view.asp?a=1239&Q=462717&landrecwasteNav=%7C

Recordkeeping for Source Reduction Strategy

Signed by company responsible officer Maintained on site/available to DEP Update every 5 years or when there is

a significant change in waste streams Submit Source Reduction Strategy to

the solid waste management facility or DEP on request

Keep records of residual wastes generated for five years

Frequently Asked QuestionsQ: Do I need to include waste oil generated

and burned on site in the Source Reduction Strategy?

A: Yes. Waste oil is a residual waste, and must be included

Q: Do I need to include recycled uncontaminated pallets, scrap metal and waste packaging materials in the Source Reduction Strategy?

A: Yes. These are residual wastes, and must be included in the Strategy*

*Although these do no need to be included in the Biennial Report

Residual Waste Biennial Report Who?

Generate > 2200 lb residual or hazardous waste in any one month in a calendar year and

> 13 tons residual waste in any one year What?

Biennial report When?

March 1 every odd-numbered year

Residual Waste Biennial Report Due March 1 each odd-numbered year Description of generator’s efforts to

implement the Source Reduction Strategy

Only applicable if generate > 13 tons residual waste in one year Do not count recycle scrap metal,

uncontaminated pallets, corrugated paper

Form 330-GM

Fill in a separate 330-GM form for each residual waste stream

For waste streams less than one ton per year generated, do not complete form List the these small waste streams

on a blank sheet of paper at the end of the report

Example (1 of 8)

ABC Inc, a laminate manufacturing facility, generated the following waste in 2006 Used oil – 5 tons (3 tons burned on site) Scrap metal – 15 tons (non contaminated,

recycled) Ash – 10 tons (to landfill) Waste phenolic resin (hazardous waste) – 24

tons Sanderdust – 19 tons, non hazardous waste (9

to landfill and 10 burned on site) Empty raw material containers – 0.5 tons Cleaning liquid – 0.9 tons

Reporting Wastes (2 of 8)

Report the following wastes on Biennial Report: Used oil – 5 tons (3 tons burned on site) Ash – 10 tons (to landfill) Sanderdust – 19 tons (9 to landfill and 10 burned

on site) Do NOT report the following wastes on

Biennial Report:x Scrap metal – exempt; non contaminated,

recycledx Waste phenolic resin - hazardous wastex Empty raw material containers – less than 1 ton,

list at end of reportx Cleaning liquid – less than 1 ton, list at end of

report

Example – Form 330 for Used Oil (3 of 8)

ABC Inc. EPA ID Number

ABC Inc.

5 0 9 3 2 5 2 1

NAICS number forlaminate manufacturingis 325211

Residual WasteCode for waste oil

Oil has noconstituents that were entered on the facilityForm R (do not check)

Waste oil from equipment and vehiclemaintenance

D 1 2 3 4 5 6 7 8 9

Example – Form 330 for Used Oil (4 of 8)

ON S I T E

Burned on site

3

2

L

L

09

Code for recycler/reuser

Clean Harbors

PAD 9 8 7 2 7 9 7 7

Clean Harbor’s EPA ID number

09

Burned on site in facility oil burner

Boiler is not exclusively used for disposal of waste, so not “captive”

Example – Form 330 for Waste Ash (5 of 8)

ABC Inc. EPA ID Number

ABC Inc.

0 0 7 3 2 5 2 1

NAICS Number forlaminate manufacturingis 325211

Residual WasteCode for “other” ash

Waste has chromiumthat was entered on the facility Form R

Ash from boilerX

D 1 2 3 4 5 6 7 8 9

Example – Form 330 for Ash (6 of 8)

2 4 8 5 2 1

Landfill site ID

1 0 S 05

Jones County Landfill

Landfill not on site, so not “captive”

Code for landfill

Example – Form 330 for Sanderdust (7 of 8)

ABC Inc. EPA ID Number

ABC Inc

4 0 7 3 2 5 2 1

NAICS Number forlaminate manufacturingis 325211

Residual WasteCode for nonhalogenatedplastics

Sanderdust has formaldehyde and phenol that were entered on the facilityForm R

Sanderdust (from sanding laminate)X

D 1 2 3 4 5 6 7 8 9

Example – Form 330 for Sanderdust (8 of 8)

2 4 8 5 2 1

Landfill site ID

9 S

Landfill is not on site, so not “captive”

05

Jones County Landfill

ON S I T E S 07

Burned on site in facility boiler

Boiler is not exclusively used for disposal of waste, so not “captive”

Code for landfill

Code for recycler/reuser

1 0

Waste Facility Codes

Residual Waste Biennial Report Form

Generator's Residual Waste Biennial Report Form 2560-FM-BLRWM330GM for 2004 (Form 330)

Download from PA DEP website http://www.depweb.state.pa.us/

landrecwaste/cwp/view.asp?A=1239&Q=486286

Chapter 4

HAZARDOUS WASTE REPORT

PA Hazardous Waste Regulations

Title 25 Environmental Protection

Subpart D Environmental, Health and Safety

Article VII Hazardous Waste Management

Biennial Hazardous Report

Who? Large quantity generators of hazardous waste Applies if the facility was a large quantity

generator during at least one month the previous year

What?Biennial Hazardous Waste Report

When?March 1 every even-numbered year

Annual Hazardous Report

Who? Large quantity generators of hazardous waste Applies if the facility sent all hazardous waste

to a foreign country the previous year, per 40 CFR 262.56

What?Annual Hazardous Waste Report

When?March 1 every even-numbered year

Large Quantity Generator

Generates per month ≥1,000 kg/month hazardous waste

>1 kg/month of acute hazardous waste>100 kg/month of acute spill residue or soil Part 262 and §261.5(e)

Has on site at any one time ≥6,000 kg hazardous waste at any

one time

Generator Status Change

If generator status has changed, and facility is no longer required to report must inform DEP of change: Fill out the RCRA Subtitle C Site

Identification Form (this is one of the forms in the hazardous waste report)

Mark the box for Subsequent Notification of Regulated Waste Activity in Item 1 - Reason for Submittal

Submit form to DEP

Generator Status Change Form

Definition of Hazardous Waste Waste that has properties that make it

dangerous or potentially harmful to human health or the environment

Exhibits at least one of four characteristics: Ignitability Corrosivity Reactivity Toxicity

Or, it appears on one of the four hazardous wastes lists (F, K, P or U)

Ignitable Hazardous Wastes Liquids with flash point less than 140oF

Examples of ignitable hazardous wastes Waste petroleum distillates Spent solvents

Spontaneously combustible solid or liquid Ignites without external source of heat Example: Combustible rags impregnated with

oils or solvents EPA Hazardous Waste Number - D001 40 CFR 261.21

Corrosive Waste Liquid waste with pH < to 2, or > 12.5 Capable of corroding metal EPA Hazardous Waste Number –

D002 40 CFR 261.22

Reactive Waste Unstable; readily undergoes violent change

w/o detonating Reacts violently with water Generates toxic gases, vapors or fumes when

mixed with water Capable of detonation or explosive reaction if

it is heated under confinement Forbidden explosive as defined in regulations EPA Hazardous Waste Number - D003 40 CFR 261.23

Toxic Wastes Harmful or fatal when ingested or absorbed Contaminated liquid may leach from waste

and pollute environment Toxicity Characteristic Leaching Procedure

(TCLP) - EPA Method 1311 If concentration exceeds threshold in regulation,

waste is toxic EPA Hazardous Waste Numbers

D004 to D043 40 CFR 261.24

F-List Wastes Non-specific source wastes from common

manufacturing and industrial processes Examples:

F003, F004 and F005 - Non halogenated spent solvents Spent solvents, wipes

F006 - Wastewater treatment sludge from electroplating operations (lists exceptions) Acid filters from lead plating process Filter cake from filter press

40 CFR 261.31

K-List Wastes Source-specific wastes from specific industries Examples:

Wastewater treatment sludge from chrome green pigment production

Distillation bottoms from production of acetaldehyde from ethylene

Solvent, caustic or water washes and sludge from cleaning equipment used in formulation of ink from pigments, driers, soaps, and stabilizers containing chromium and lead

Emission control dust/sludge from secondary lead smelting

40 CFR 261.32

P- and U-List Wastes Specific unused commercial chemical

and pharmaceutical products Off-specification Past shelf-life Container residues Spill residues

Any of these listed wastes mixed with another waste

40 CFR 261.33

Exclusions Materials which are not solid waste

Not waste Not defined as solid waste

Not solid waste Domestic sewage Used oil which will be recycled and not mixed with

hazardous waste (>1000 ppm halogenated solvents) Scrap metal for recycling Shredded circuit boards for recycling Vehicle batteries for recycling Universal waste Several specific industry wastes

This table provides a summary of requirements for each class of hazardous waste generator: Conditionally Exempt Small Quantity Generators (CESQGs), Small Quantity Generators (SQGs), and Large Quantity Generators (LQGs).

  CESQGs SQGs LQGs

Quantity Limits

≤100 kg/month≤1 kg/month of acute ≤100 kg/month acute spill residue/ soil §§261.5(a) and (e)

Between 100 - 1,000 kg/month§261.34(d)

≥1,000 kg/month>1 kg/month of acute hazardous waste>100 kg/month of acute spill residue or soil Part 262 and §261.5(e)

EPA ID # Not required §261.5 Required §262.12 Required §262.12

On-Site Accumulation Quantity

≤1,000 kg ≤1 kg acute≤100 kg of acute spill residue or soil §§261.5(f)(2) and (g)(2)

≤6,000 kg§262.34(d)(1)

No limit

Accumulation Time Limits

None§261.5

≤180 days or ≤270 days (if > 200 miles)§§262.34(d)(2) and (3)

≤90 days§262.34(a)

Storage Requirements

None§261.5

Basic requirements with technical standards for tanks or containers§§262.34(d)(2) and (3)

Full compliance for management of tanks, containers, drip pads, or containment buildings§262.34(a)

Waste Sent To:State approved or RCRA permitted/interim status facility§§261.5(f)(3) and (g)(3)

RCRA permitted/interim status facility §262.20(b)

RCRA permitted/interim status facility§262.20(b)

Manifest Not required §261.5 Required §262.2 Required §262.2

Biennial Report Not required §261.5 Not required §262.44 Required §262.41

Training Not required §261.5 Basic required §262.34(d)(5)(iii) Required §262.34(a)(4)

Contingency Plan

Not required §261.5 Basic plan §262.34(d)(5)(i) Full plan §262.34(a)(4)

Emergency Procedures

Not required §261.5 Required §262.34(d)(5)(iv) Full plan required §262.34(a)(4)

DOT Transport Requirements

Yes(if required by DOT)

Yes§§262.30-262.33

Yes§§262.30-262.33 See Table in handout

Generator Summary Chart

Hazardous Waste Biennial Report

Use EPA Form 8700-13A Differences between the PA and

federal reporting requirements: PA requires that overseas shipments

of hazardous waste be included in the report

PA does not require form OI

EPA Form 8700-13A (1of 3)

EPA Form 8700-13A (2 of 3)

EPA Form 8700-13A (3 of 3)

Waste solventD 0 0 1 F 0 0 2

Contains > 1% methylene chlorideIgnitable

Pennsylvania followsFederal codes

0 1

Code for dipping, spray washing. Describes how the waste was generated

Leave blank unless you enteredG25 for “Source Code.”

2 0 2

Concentrated halogenated solvent

3 1 4 0. 61

If UOM is volume, enter density

2005 Hazardous Waste Report

For 2005 hazardous waste report (due March 1, 2006) DEP did not send out instruction

booklets Sent out letter with reference to web

sites and telephone number for assistance Phone number: 717-783-9258

Electronic Filing American Resource Management

(ARM) – provides web form Web site:

http://www.arminc.net/ARM_easitrak2k5.asp

You will need to enter your site EPA ID number and create a password Keep the password with your files,

since you will need to use it when you file again in two years

Hazardous Waste Biennial Reporting – Paper Copies

PA uses the federal form 8700-13A/B which can be downloaded at http://www.epa.gov/epaoswer/hazwaste/data/br05/forms.htm

Note the one on file expires 10/31/07 – must check for updated version before next filing

Chapter 5

ANNUAL EMISSIONS STATEMENTS (AES)

Why is it Important? Summary of actualactual air emissions into air

shed Compliance with NAAQS

Demonstration of progress towards attainment

Federal permitting Prevention of Significant Deterioration (PSD)

Nonattainment New Source Review (NNSR)

Agency revenue stream ($/ton emissions ($/ton emissions

fee)fee)

Required under 25 PA Code §135.21 Site-wide actual/potentialactual/potential emissions

Any Pollutant > 100 tpy

Single HAP > 10 tpy oror Multiple HAPs > 25

tpy

Classified as Major SourceMajor Source in a

nonattainment1 area

In nonattainment1 or near nonattainment

areas with actualactual emissions > 10 tpy VOC

oror > 25 tpy NOx

Does it Apply to Me?

1 Based on the eight-hour ozone standard

Due Date : March 1st (March 15th for ACHD) (Extensions may be requested)(Extensions may be requested)

File electronically using I-Steps (AMS and

ACHD facilities)

File electronically using AES*Online or

AES*XML (other PA facilities) Paper filing still allowed using PaDEP forms

http://www.dep.state.pa.us/dep/deputate/airwaste/aq/emission/emission_inventory.htm

When is it Due?

What Do I Have to Do?

Calculate actual emissions from all sources Point sources and fugitive sources Include vehicles and roadways Include emissions from accidental releases

Enter data into I-Steps, AES*Online, AES*XML, or paper forms provided by PaDEP

Make sure data matches information submitted in TRI report

Calculate Emissions?(1 of 3)(1 of 3)

Measurement methods Continuous emission monitoring (CEM)(CEM) Parametric emissions monitoring (PEM)(PEM) Fugitive emissions monitoring (LDAR)(LDAR) Source testing Periodic monitoring Instrument measurements

Estimation methods Emissions factors

U.S. EPA published factors (AP-42, FIRE, etc.)(AP-42, FIRE, etc.) Industry or vendor developed factors

Engineering calculations/Mass balance

Predictive U.S EPA models TANKS ((www.epa.gov/ttn/chief/software/tanks/index.html) WATER9 ((

www.epa.gov/ttn/chief/software/water/index.html)

Calculate Emissions?(2 of 3)(2 of 3)

Calculation methods: Continuous Emissions Monitoring (CEM) system

data Predictive Emissions Monitoring (PEM) system data Measured data (stack sampling data) Vendor supplied emissions factors AP-42, other EPA, or PaDEP approved factors Material balance Scientific calculation Estimation Other

Calculate Emissions?(3 of 3)(3 of 3)

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Pre

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nce

Cooling Tower Particulates(1 of 2)(1 of 2)

Operating parameters Induced Draft Cooling Tower Circulation Rate 8,000 gpm 2006 Hours of Operation 8,200 hours

U.S. EPA Emission Factor AP-42, Section 13 – Miscellaneous Miscellaneous

SourcesSources Subsection 13.4 – Wet Cooling TowersWet Cooling Towers PM10 Emission Factor – 0.019 lb/1,000 gal

Cooling Tower Particulates(2 of 2)(2 of 2)

PM10 Emissions

(8,000 gal/min) x (60 min/hr) x (0.019 lb/1,000 gal) = 9.12 lb/hr9.12 lb/hr

(9.12 lb/hr) x (8,200 hr/yr) = 37.39 tpy37.39 tpy

What about PM and PMWhat about PM and PM2.52.5 emissions? emissions?

Speciating HAP Emissions

Any facility that emits any HAP in an amount ≥ 0.1 tons ≥ 0.1 tons must speciate and report individual HAP emissions

Particulate Matter

PM

PM2.5

PM10

Example PM

Emissions from a facility Total PM 10 tpy10 tpy

Phosphorous (PM10) 7.57.5 tpy Zinc (PM10) 1.61.6 tpy Total PM2.5 0.50.5 tpy

TTotal Speciatedotal Speciated9.6 tpy9.6 tpy

= 0.4 = 0.4 tpytpy

(Assume PM = PM(Assume PM = PM1010))

Ozone Season Emissions

June 1 – August 31 (92 days)June 1 – August 31 (92 days)

Use actualactual number of days operated

Report emissions in pounds per pounds per day (ppd)day (ppd)

Useful Resources (1 of 2)(1 of 2)

U.S. EPA CHIEF – Clearing House for Inventories and Emission Factors

((www.epa.gov/ttn/chief))

U.S. AP-42 ((www.epa.gov/ttn/chief/ap42/index.html))

FIRE – Factor Information Retrieval Data System((www.epa.gov/ttn/chief/software/fire/index.html))

Protocol for Equipment Leak Emission Estimates((http://www.epa.gov/ttn/chief/efdocs/equiplks.pdfhttp://www.epa.gov/ttn/chief/efdocs/equiplks.pdf))

Emissions Calculation Models((www.epa.gov/ttn/catc/products.html#software)

TANKS ((www.epa.gov/ttn/chief/software/tanks/index.html)

WATER9 (www.epa.gov/ttn/chief/software/water)(www.epa.gov/ttn/chief/software/water)

PMCalc (www.epa.gov/ttn/chief/software/pmcalc/index.html)(www.epa.gov/ttn/chief/software/pmcalc/index.html)

Useful Resources (2 of 2)(2 of 2)