Emissions Events

1. Emissions Events Joe Janecka, P.E. – Central Office Jon Williams– Region 6 El Paso

2. Presentation Outline • Two Parts: • What you do and • What we do

3. What You Do • Regulatory knowledge, process or plant knowledge • Reporting: Reportable Quantities (RQ) • Reporting: STEERS • Reporting: Affirmative Defense

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.

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.

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

7. 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

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

9. 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.

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.

11. Case Examples: RQs • Ammonia (gaseous) • Gasoline (spill) • Produced (unprocessed) natural gas

12. Case Examples: RQs

13. Case Examples: RQs • Gasoline: 4% by volume Benzene • 200 gal spill reported under 30 TAC §327.3 • Estimated 50% volatilized

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. 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)

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

17. 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

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. 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.

20. 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)

21. 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.

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 §101.222(b)

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: https://www3.tceq.texas.gov/steers/help/main.html