Joe Janecka, P.E. – Central Office Jon Williams– Region 6 El Paso Emissions Events Joe Janecka, P.E. – Central Office Jon Williams– Region 6 El Paso Describe to the audience that Jon and I are co-presenting, one at time. I am covering some basics and Jon will follow with the investigator’s perspective. Also explain that I have transferred to the Air Permits Division. Any follow-up for questions after the trade fair should be taken to the regional office with jurisdiction. Also, point out Rick or Annette in the audience.

Presentation Outline Two Parts: What you do and What we do Joe Janecka speaks to (1) Jon Williams addresses (2) And there is overlap

Regulatory knowledge, process or plant knowledge What You Do Regulatory knowledge, process or plant knowledge Reporting: Reportable Quantities (RQ) Reporting: STEERS Reporting: Affirmative Defense What Joe covers Tips and suggestions along the way

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. Emissions events are when things go wrong! Emphasis on 24 hours of the discovery of the event, not when the reportable quantity is determined to be met.

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. Let the audience read… don’t need to cover this definition unless there is a question from the audience

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 Explaining the need for the person who will report emissions events to be familiar with certain aspects of the plant’s operations.

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 302.4 40 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

30 TAC §101.1(88)(B) describes RQ for mixtures 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. (88) B outlines the calculation methods for mixture RQ based on mixture content knowledge, etc. (88) C reduces reporting requirements to simply opacity for these situation.

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. As explained in this slide, this is likely a rare determination for RQ. I have not seen it. The lowest RQ will likely be the specific amounts in other parts of the definition.

Produced (unprocessed) natural gas Case Examples: RQs Ammonia (gaseous) Gasoline (spill) Produced (unprocessed) natural gas Let me step through three common examples of determining RQ.

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) From one of the federal rule tables (referred to in the definition (88) of Chapter 101)

Gasoline: 4% by volume Benzene Case Examples: RQs Gasoline: 4% by volume Benzene 200 gal spill reported under 30 TAC §327.3 Estimated 50% volatilized Verify assumptions and calculations

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)

Natural gas - RQ definition 101.1 (88)(B)(iv): 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) Useful to have field gas analysis

Reporting: STEERS STEERS: State of Texas Environmental Electronic Reporting System Emissions Events: use Air Emissions and Maintenance Events (AEME) module in STEERS

Set-up an account and STEERS Participation Agreement (SPA) 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 I am not the STEERS data person. I will give you contact information for STEERS account help at the end of this presentation.

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

Why? Because a timely report is needed for affirmative defense. 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. Many owner/operators report out of abundance of caution when not sure an RQ will be met or exceeded in a 24-hour period.

Electronic reporting through STEERS required except: 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) The use of STEERS is encouraged except (obviously) when the program is unavailable.

When faxing an emissions event report: Reporting: STEERS When faxing an emissions event report: Use Form 10360, follow instructions Form can be found at: http://www.tceq.texas.gov/field/cefoumforms.html Recommend 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) All reportable emissions events are investigated. The investigator may ask questions regarding affirmative defense claims where it is not clear.

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 Any issues you may have with STEERS logging-in or data entry: contact the STEERS helpline listed on this slide.