|March, 2006, Vol 9, No 1|
AP-42 EMISSION FACTOR UPDATES
Currently, EPA lists two sections as under review. AP-42 Section 11.12-Concrete Batching was opened for review in November; comments are requested by February 17, 2006. For AP-42 Section 12.5.1-Steel Minimills, the comment period was scheduled to close on March 31, 2005. Find more AP-42 information on EPA’s TTN-CHIEF Bulletin Board at http://www.epa.gov/ttn/chief/ap42/index.html.
The Air Quality Advisory Council held its first meeting of 2006 on January 18 at DEQ headquarters in Oklahoma City. The agenda for the meeting included hearings on Chapter 100 New Source Review (NSR) reform and Best Available Retrofit Technology (BART), both of which were carried forward from the October Council meeting.
Customary business for the Council’s first meeting of the year began with the election of officers. The Council voted to retain Sharon Myers as chair and elected David Branecky as vice-chair for the coming calendar year. Ms. Myers represents general industry on the Council. Mr. Branecky represents the electric utilities industry.
Scott Thomas and Dr. Joyce Sheedy presented proposed changes that include moving several definitions from Subchapter 8 to Subchapter 1 and revisions to NSR in Parts 1, 7 and 9 of Subchapter 8. Dr. Sheedy responded to questions regarding amendments made to the draft rule since the October Council meeting. The Council voted to recommend adoption of the OAC 252:100-1 definitions and the proposed NSR rules (OAC 252:100-8) to the Environmental Quality Board (EQB) at its February meeting.
The Council also voted to send to the February EQB the addition of a new Part 11 to OAC 252:100-8 that incorporates by reference the federal BART requirements which will become part of the Regional Haze State Implementation Plan.
The next Council meeting will be held in Tulsa on April 19, 2006 at the OSU Tulsa Campus located at 700 North Greenwood.
A request was received at the Oklahoma City meeting for one-on-one time following the formal presentations to go step-by-step through the reporting process. It was determined this was especially beneficial for first time users of the system. This request was incorporated into the Tulsa workshop.
These questions and comments, along with all others received from meeting attendees, were recorded and will be incorporated into the Frequently Asked Questions posted on the Emission Inventory Website at: http://www.deq.state.ok.us/AQDnew/emissions/index.htm. Many additional documents found on the website are the result of suggestions received at previous workshops. All presentation materials, instructions, forms and staff contact information are available and may be downloaded for future reference. “Emission Inventory 101” is a guidance document currently under development for persons new to the emissions inventory reporting process. It will be available later this year.
It is time once again for DEQ certified Lead-based Paint (LBP) contractors and firms to renew their certification. The 2005-2006 certification year will end March 31, 2006. To renew a LBP certification, contractors must submit a complete LBP renewal application, including documentation of refresher training and fees to DEQ by March 31, 2006. Refresher training has already begun and will continue through March 2006.
DEQ has two accredited LBP training providers: Metro Technology Centers and the University of Oklahoma-Institute for Environmental Management. You may obtain accredited LBP training from either training provider. Contact the following individuals for course schedules and price information:
A change has been made to the Quarterly Reports. Beginning April 2006, DEQ will request the physical address of each property listed on the report(s). The Quarterly Report forms can be obtained from our website at http://www.deq.state.ok.us/AQDnew/resources/aqforms.htm.
All DEQ employees are invited to attend Green Team brown bag lunch discussions, which include topics such as: Oklahoma Nature Conservancy, Green Holidays Idea Exchange, The Zero Energy House, Where do DEQ Recycled Materials Go, Commuter’s Choice Program, and Composting 101.
Future plans involve an energy audit of the DEQ main building by OU students enrolled in a LEED (Leadership in Energy and Environmental Design) class, research into the best method of CD disposal, and promotion of “green” purchasing policies.
Additionally, the Green Team initiated DEQ’s application to join EPA’s Green Power Partnership by pledging to procure an amount of renewable energy proportional to the DEQ’s annual electricity use. At this time, the DEQ purchases the largest percentage of wind energy allowed by the local vendor.
As a reminder of the broad efforts of the Green Team, the Keep Oklahoma Beautiful award is being placed on display for several weeks in the reception area of each DEQ Division. The real award, however, has been the positive reception of eco-initiatives and agency-wide involvement in environmental stewardship.
Air Toxic Monitoring: The Tulsa monitoring project is underway. The Air Quality Division is collecting VOC and Carbonyl samples at 3 sites in Tulsa. Data will be posted to the webpage as it becomes available. For more information on this project contact Randy Ward at 405-702-4164 or email email@example.com
MACT updates: EPA has completed all of the scheduled MACTs, but lawsuits on several MACT standards have resulted in re-opening and reconsiderations of several standards. Air Quality will track these developments and provide updates as they are resolved. More information regarding MACT standards is available on the EPA Air Toxics Webpage at http://www.epa.gov/ttn/atw/mactfnl.html or the EPA rules site at http://www.epa.gov/ttn/oarpg.
HAP List: Information on the status of HAP delisting is available at http://www.epa.gov/ttn/atw/pollutants/atwsmod.html EPA is also considering proposals to add hydrogen sulfide and diesel particulates to the HAP list, but no official proposal has been promulgated.
1999 NATA: The 1999 National-Scale Air Toxics Assessment (NATA) was released by EPA on February 22, 2006. This is an update and follow-up to the 1996 NATA. See the 1999 NATA at http://www.epa.gov/ttn/atw/nata1999
When reciprocating compressors are taken off-line, natural gas (principally methane, ethane, and some VOC) can leak from a number of sources with the amount depending on the system pressurization. In a depressurized system, emissions result from the “blowdown,” or venting of the high-pressure gas left within the compressor and from continued leakage of unit isolation valves. In a fully pressurized system, gas can leak from the closed blowdown valve and the compressor rod packings.
The EPA, working in cooperation with the natural gas industry under the National Gas STAR Partners program, has identified several simple operational changes that can reduce gas emissions when taking compressors off-line. These methods can reduce pollution from methane (which has ten times the greenhouse effect as carbon dioxide) and save valuable fuel.
Option 1 is to simply keep the compressor pressurized when taken off-line for operational reasons, i.e. when no maintenance work is required or other safety reasons do not dictate depressurization. This can reduce emissions by about 225 Mscf/year for a fuel savings of $2,250 /year (assuming $10/Mscf) for a typical base loaded compressor (assumed off-line 500 hours per year) and reduce emissions by about 1,800 Mscf/year for a fuel savings of $18,000/year for a typical peak loaded compressor (assumed off-line 4,000 hours per year).
Option 2 is to install a connection to the fuel gas system and leave the compressor pressurized at the fuel gas system pressure (typically 100 to 150 psig). This recovers most of the “blowdown” gas and reduces leakage from the blowdown valve (to atmosphere) and reduces leakage from rod packings. This option requires that enough other combustion equipment is operating to burn the blowdown and leakage from the shutdown compressor (typically about 1.4 Mscf/hr). Cost savings are about $2,900/year for a typical base loaded compressor and $23,000/year for a typical peak loaded compressor. Costs to connect the blowdown line to the fuel system range from $1,000 to $2,000. Maintenance personnel will need to remember to isolate the blowdown valve to the fuel system when working on the compressor.
Option 3 is to leave the compressor fully pressurized (Option 1) and install automatically operated static seals on the compressor rods. A static seal is installed on each rod shaft outside the conventional packing. An automatic controller activates when the compressor is shutdown to wedge a tight seal around the shaft. The controller deactivates the seals on startup. Leakage occurs only from the blowdown valve. Cost savings are about $3,000/year for a typical base loaded compressor and about $24,000/year for a typical peak loaded compressor. Costs are about $500 per rod plus $1,000 for the controller or about $3,000 for a four rod compressor. This option does not reduce emissions much when used with Option 2 as leakage has already been reduced substantially with the compressor at fuel system pressure.
One large company used Option 2 on 577 compressor units (about 3,000 compressor cylinders) and saved 1.58 billion cubic feet per year. Each facility is a bit different, but an operator can easily estimate blowdown losses and leakage losses and then do a cost analysis to determine a project payback time. With natural gas prices at record levels, it also makes sense to do an annual inspection and maintenance on compressor blowdown valves and to investigate other options that can save fuel and reduce air pollution at the same time. For more specific information on the options discussed here and on other innovative methods to reduce emissions and save fuel, go to http://www.epa.gov/gasstar.
The Department of Environmental Quality is again offering training for Visible Emissions Evaluation. The Spring 2006 courses are provided by the Air Quality Division in conjunction with CenSARA and are presented by Eastern Technical Associates (ETA). Training will occur in Oklahoma City on March 28, 29, 30 and Tulsa on April 25, 26, 27. Field certifications and a classroom lecture will be offered at both locations. Applicants who have not attended smoke school previously are required to attend the classroom lecture. Lecture attendance is encouraged for all applicants who have not attended a lecture in the past year. These courses will meet EPA Method 9, and Method 22 training requirements. Individuals qualifying at the field certification will be certified to make visible emission readings.
The Oklahoma City classroom lecture will take place on March 28 at Metrotech Springlake Campus’ Business Conference Center Big Dipper Room at 1900 Springlake Drive. The Field certification will take place March 29 and 30 at the North Parking Lot of the State Fair Grounds (north of Space Needle). Attendees should enter the fairgrounds from May Avenue at gate 25 on Neosho Avenue.
The Tulsa classroom lecture is scheduled for April 25 at the Holiday Inn Select at
Registration for all classes will begin at 8:00 AM.
Maps for both locations are available at the ETA website:
Applicants should contact Jeff Dye firstname.lastname@example.org. or (405) 702-4118.
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