1. 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.

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

3. 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

4. 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.

5. 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

6. 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.

7. Reporting: RQ
Refer to definition (88) in section 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

8. Reporting: RQ
RQ = 100 pounds when the contaminant cannot be found elsewhere in definition 30 TAC §101.1(88) for RQ

9. 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.

10. 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.

11. 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.

12. Case Examples: RQs
§ 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)

13. 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

14. 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)

15. Natural gas - RQ definition 101.1 (88)(B)(iv):
Case Examples: RQs
Natural gas - RQ definition (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

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

17. 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.

18. 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

19. 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.

20. 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.

21. When faxing an emissions event report:
Reporting: STEERS
When faxing an emissions event report:
Use Form 10360, follow instructions
Form can be found at:
Recommend downloading and printing the form and instructions – having it available when your computer or internet connection fails.

22. 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 § (b)
All reportable emissions events are investigated. The investigator may ask questions regarding affirmative defense claims where it is not clear.

23. 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:”

24. STEERS reporting help STEERS helpline: 512-239-6925 STEERS Help at:
Any issues you may have with STEERS logging-in or data entry: contact the STEERS helpline listed on this slide.