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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)
Ord
er o
f P
refe
ren
ceO
rder
of
Pre
fere
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)