General Topics

We are now Permit Exempt under the recent rule change. Do we still have to submit an emissions inventory?

All facilities that have a permit must submit an Emissions Inventory. Only when a permit is formally rescinded by DEQ is the requirement to submit an inventory removed.

If our facility is now Permit Exempt how do we get our existing permit rescinded?

You will need to send a letter to the permits section of the Air Quality Division at DEQ.

This is the name given to DEQ Form #100-730 which DEQ requires be used when completing an annual emissions inventory.

A Turn Around Document contains the annual emissions inventory for a particular facility, as well as other relevant information such as the facility location and address, ownership details, operating hours and process rates, etc. Certification by the Responsible Official for the facility that the information is "true, accurate, and complete," followed by submission of this form to DEQ constitutes fulfillment of the legal requirements for reporting emissions inventories.

Do I have to use the reporting form provided by DEQ or may I report emissions on my company’s spreadsheets?

The Oklahoma Air Pollution Control Rules in OAC 252:100-5-2.1(a) state, “The owner or operator of any facility that is a source of air emissions shall submit a complete emission inventory annually on forms obtained from the Division”. Therefore, any forms other than those available from the Department are not acceptable for reporting.

Why do I have to fill in all the blanks on the emission inventory form?

All the data requested is of vital importance to some aspect of the Air Quality Program. There are some questions that may not pertain to your facility and in those situations you may enter “NA” or “not applicable”. One example of this would be the “Dunn and Bradstreet Number”. If your facility or company does not have such a number you may enter “not applicable” in this field.

How do I get blank copies of the Turn Around Document forms?

These are available on our website on the Turn Around Documents: Instructions & Help page. If you are completing an emissions inventory for the first time you are strongly advised to read the general Emissions Inventory Instructions as they will assist you in determining what data is required.

How do we change a company or facility name?

You must notify DEQ in writing about such a change.

Change Notification Form #100-883

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Note: If a facility is sold, it is the legal responsibility of the seller to notify DEQ within 30 days of the sale.

Who is an RO? Who can sign the Turnaround Document?

A full definition of who is responsible for the emissions inventory from a facility owned by a company or other such entity is given in OAC 252:100-1-3. Typically, for a corporation this would be a senior officer, such as the president, secretary, or treasurer. It may also be a vice-president who is in charge of a principal business function. For partnerships, it will be a partner; for sole proprietorships, the owner; and for public bodies, an elected official or senior executive officer.

Does the Responsible Official have to physically sign the final submission when using Redbud?

No. Under Oklahoma Statute (12A O.S. sec. 15-101 et seq.) compliance with the conditions on the Redbud Agreement page, which a user must always agree to when logging onto Redbud, results in a legally binding electronic signature.

How do we change the designated RO for our company?

Complete DEQ Form #100-882 and mail this to DEQ.

What if the Emissions Inventory Contact is different from the Responsible Official at our company? Where can I enter their contact details in Redbud?

These details can be entered using the Facility Contact button on the Facility Page.

We have an emission unit that was dismantled and removed during the reporting year. Should this not be removed completely from our inventory for this reporting year?

If the emission unit did not operate at all and was physically removed or permanently disconnected from service during the reporting year then it should be listed as Removed. We retain information on such points for historical purposes, but for the next reporting year they will not appear on a hardcopy Turn Around Document or in Redbud.

We are a major source and we have only just realized that we have a large number of small gas-fired heaters that produce emissions for which we have not accounted for previously. How should we handle this?

It is possible that although each unit is de minimis on its own, when grouped together as one source, the total emissions need to be reported. However, such situations need to be handled on a case-by-case basis. Please contact us so we can evaluate your operations and your specific circumstances.

What is the definition of Grade?

Grade is the level at which the ground surface meets the base of a stack or the base of a structure that emits fugitives. In the latter case, this could be the ground level at the base of a storage tank or the base of a storage pile of minerals.

Do we enter an instantaneous maximum flow rate or an average flow rate from a stack?

This information is collected for air pollution modeling purposes and therefore the maximum flow rate is required. In the case of a batch process, it would be the highest rate, usually at the start of the batch, rather than a time average.

What is the fugitive height?

This is the height above grade that fugitives are released from. It could be the top of a storage tank or the top of a mineral pile. For leaks from pipework or loading operations the fugitive height is typically three feet.

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How do we treat Flashing Losses from hydrocarbon storage tanks?

There are three processes involved when considering VOC emissions from hydrocarbon storage tanks: working, breathing and flashing losses. Each of these processes should normally be entered separately, with different SCC codes. Working and breathing losses have their own SSC codes and EPA added a new SCC for flashing losses in 2007 (40400300 - Petroleum Liquids Storage (Non-Refinery), Fixed Roof Tank, Flashing Losses). Working, breathing and flashing losses from condensate tanks maybe grouped into the all inclusive code of 40400311- Condensate, working+breathing+flashing losses if combined emissions are less than 5.0 tpy.

For more information about Flashing losses from hydrocarbon storage tanks, please see the DEQ factsheet: Calculation of Flashing Losses/VOC Emissions from Hydrocarbon Storage Tanks.

What if I use two different fuels at an emission unit (e.g., a boiler that can burn both natural gas and oil)?

Emissions must be reported separately for each process. In this case, there would be two different processes for this emission unit, with potentially different pollutants and emission factors and amounts.

If we enter an hourly process rate, will Redbud automatically fill out the annual rate?

No. Each field must be entered separately. The hourly rate for the process in question is the maximum hourly rate that occurred at anytime during the year. The daily rate of operation is the typical rate for days when the emission unit is in operation. However, the annual rate must be the actual total amount processed during the year.

What if the process material is not in the pull-down list of these materials in Redbud?

Find another process material that best fits your circumstances. Please contact the Emissions Inventory Section if you need any help.

For which pollutants must I report emissions?

Emissions of any Regulated Air Pollutants (RAPs) must be reported for every facility for which an inventory is due. This page on our web site discusses which pollutants must be reported in an Oklahoma Emissions Inventory.

What is the smallest amount of emissions that we have to report?

A lower cut-off or minimum amount of emissions of an individual pollutant that should be reported is not defined by rule. Emissions of each regulated pollutant should be reported in tons to three decimal places.  The trace checkbox should be used to indicate that emissions of a regulated pollutant have been estimated to be less than 0.001 tons (2 lbs) per year. A pollutant need not be reported at an individual process at all if the Potential to Emit (PTE) of that pollutant at that process is less than 0.001 tons (2 lbs).

We want to use a new method for calculating emissions. What do we need to do?

You should first check if this method falls under any of the permissible methods – contact the Emissions Inventory Section for help if necessary. Otherwise, a new method must be pre-approved by the DEQ before submitting your annual inventory. Write to the Emissions Inventory section providing as much detail and as many references as possible for the new method.

What do we do about entering an emission factor if we use TANKS or GLY-CALC?

Providing emission factors enables us to check and verify your calculations. In the case of specific models like these with many input variables, there may not be a unique emission factor for each particular set of conditions. Enter zero (0) in the emission factor field and for the numerator and denominator select N/A - Formula, Software or CEMS from the dropdown menu.

Why is control equipment listed at the pollutant level? Why not at the emission release point level?

Most control equipment reduces emissions of one or some - but not all - of the pollutants produced by a particular process at an emission unit. In many cases, emissions of other pollutants are not reduced by the particular control equipment or control approach, and so these emissions should not be incorrectly reported as being controlled.

If a controlled emission factor is used to calculate air emissions, is a control efficiency percentage also entered?

Yes - if it is available. A "Controlled" emission factor incorporates control equipment efficiencies for emissions of a particular pollutant from a particular process. Providing the control efficiency, as well as the control equipment, allows us to cross-check that the correct factor has been used and that the calculated emissions are correct. However, in some cases, such as where the factor is an Manufacturer's Guarantee that already includes the effect of a control, this field can be left as zero.
Note: Actual emissions, including quantifiable excess emissions, should only be adjusted by the control efficiency percentage if an “Uncontrolled” emission factor is used to quantify emissions. Remember, use the “best available data” at the time the inventory is prepared to report all actual annual emissions.

How do I report Particulate Matter?

Report both PM-10 and PM-2.5, the amounts of particulate matter with an aerodynamic diameter of less than 10 and 2.5 microns, respectively. For fee calculation, only PM-10 will be counted. Do not subtract your PM-2.5 from your PM-10. PM-2.5 is a subset of PM-10. PM-2.5 can be less than or equal to, but never greater than, PM-10. If no PM-2.5 emission factor is available report only PM-10.

In the Actual Emissions field I am trying to enter a number of .0004 Tons. This number is too small as the field only accepts 3 digits which leaves 0.000 in the cell. Should I note this somewhere or just leave it as 0?

Leave the Actual Emissions field as 0 and use the "Trace (<0.001 TPY)" check box for emissions that have been calculated to be less than 0.001 tpy (2.0 lbs).

Do we still need to report a reason if there is a 30% increase or decrease in emissions?

No. This rule was changed effective June 15, 2007. The requirement to provide this information is not automatic, but the Department may require the owner or operator to provide an explanation for the difference.

How is Opacity reported?

If possible, opacity should be calculated and reported as a mass quantity (in terms of tons), using the best available data and methods. Opacity cannot be reported in terms of percent. If opacity is limited by permit and that limit is exceeded, it should be reported as an excess emission as well as part of the annual emissions in the emission inventory.

How can I estimate emissions from tank roof landing losses?

Landing losses occur from floating-roof tanks whenever the tank is drained to a level where its roof rests on its deck legs (or other supports). Vapors that occupy the space below the roof are emitted upon refilling the tank (filling losses). Emissions also occur while the roof rests on the supports (standing idle losses).

Total landing loss emissions are therefore the sum of the daily standing idle losses and the filling losses over the entire period that the roof remained landed. Landing losses must be determined each time a tank’s floating roof is landed.

The emissions determination method detailed in API TR 2567, Evaporative Loss from Storage Tank Floating Roof Landings, or its equivalent, is the preferred method for determining landing loss emissions. This publication is available from API.

What if I do not have any kind of emission limit for a particular pollutant from a particular emission unit? What do I enter in the Permit/Rule Limit (aka Allowed) Field for that pollutant?

You will need to convert the limit to the relevant limit in tons per year and enter that figure. For instance, in a paint booth operation, there may be a limit of 1000 gallons of paint per year. It will then be the company’s responsibility to determine the correct amount of VOC’s that would be released when using this paint. If the paint contains 9.5 lbs of VOC’s per gallon, and this paint is sprayed with a control efficiency of 90%, the maximum permissible yearly emissions of VOC’s would be:

1000 gallons x 9.5 lbs/gallon x 0.1 = 950 lbs = 0.475 tons/yr

Some of the flaring events at our refinery do not exceed permit limits. Do they need to be reported in the Excess emissions amount field?

No, providing the flare event did not exceed any permit or other such limit. These limits may be per hour, as well as per year.

Note: The amount of emissions from such events, other than regular operations that do not exceed permit operations, must still be entered in the Total emissions field.

Do excess emissions from start ups and shut downs need to be included?

Yes. Any emissions that are in excess of a permit or other such limit (this can also include malfunctions and maintenance activities) must be included. The excess may be over an hourly limit, and although it may not be enough to cause total emissions of that pollutant to exceed an annual limit, any excess amount must be entered in the excess field.

Note: Any emission amounts that are reported in Excess Emission Reports to the Compliance Section of the DEQ Air Quality Division, as part of the requirements of OAC 252:100-9, must be included in both the Total tons/yr field and the Excess tons/yr field.

Do we need to complete the Facility summary of pollutants on the hardcopy certification page?

We need the pollutant data for each process at each point, and the listing seen on these documents is a facility summary that is easily derived from the individual point data in our database. Completion of this page is therefore optional.

Does the Responsible Official have to physically sign the final submission when using Redbud?

No. Under Oklahoma Statute (12A O.S. sec. 15-101 et seq.), compliance with the conditions on the Redbud Attestation (Agreement) page, which a user must always agree to when logging onto Redbud, results in a legally binding electronic signature.

What if I am completing an inventory on Redbud and want to do the final submission?

You can do this, providing you have been authorized to do so by the Responsible Official.

Can someone else other than the Responsible Official also receive the Final Submission Confirmation Email?

Yes. Enter the Additional Contact's details on the Responsible Official page in Redbud. This person will be sent a copy of the confirmation email when it is sent to the RO but otherwise this information will not be stored or used elsewhere.

When does the Final Submission need to be made by?

The rules were changed effective June 15, 2007 to state that the inventory is due prior to April 1 of the following year.

How do we get access to Redbud?

Each company Responsible Official (RO) is issued their own ID and password, which can be used by one or more authorized company personnel, to access information for that company’s facilities only.

Can more than one person in our company use Redbud?

Yes. The login and password information applies to your company. Any company employee who is duly authorized by the company RO can enter information, even at the same time.

We didn’t receive a password for Redbud. Why?

At the beginning of the year, an e-mail containing the new Redbud password is sent to the Responsible Official (RO) at all companies that had previously submitted emission inventories using Redbud.

If your company did not receive this announcement, it is probably because the Air Quality Division's files do not contain a current e-mail address for your Company’s RO. Alternatively, it is possible that the Company RO received the email but did not forward it to the personnel that compile that company’s emission inventory.

If your RO did not receive the email, or if you have subsequently decided to submit electronically instead of the Hardcopy or PDF options, then please e-mail the Emissions Inventory Section or call us at (405) 702-4100.

Please note that Redbud access information can only be sent to the Company RO, who may then decide to give this information to any duly authorized company employee or representative.

What if I want to look at our Company information in Redbud, but not change anything?

Simply do not press any update buttons on any of the Redbud pages.

What if I make some updates during a Redbud session but realize that they are wrong? Can I cancel those changes?

No. As soon as the page (which can be facility, emission unit, process or pollutant information) is updated by a user, the Redbud server immediately writes the new information over any existing information. You would need to correct the errors, and then update the relevant page again.

Does Redbud calculate my emissions? Does it check if I have made an error?

No. It is the responsibility of the reporting company or entity to make the emissions calculations using an approved method. Redbud is a means of collecting information for our database.

How do I delete a pollutant record in Redbud?

A pollutant record cannot be directly deleted by a Redbud user. Complete the Redbud Deletion Request form and email it to us. We will then check and process the request.

How do I print out my emissions inventory from Redbud? Can I still get a hardcopy Turn Around document?

The Turn Around Document in PDF format is available after Final Submission. This can be printed or saved immediately or else accessed later including after the submission deadline.

Where does the Responsible Official sign the Certification page in Redbud?

The Responsible Official (RO) does not need to physically sign anything, providing the conditions on the Attestation (Agreement) page for using an electronic signature are met.

If so desired, a hardcopy Turn Around Document can still be printed off, signed by the RO and sent to DEQ. A company employee designated by the RO can make the Final Submission, but remember: the electronic signature is that of the RO and they are the person responsible!

Can you correct an inventory in Redbud after you have made a Final Submission?

Yes. Corrections can be made at any time prior to April 1 of the year following the reporting year in question. After this date, unless you have been granted an extension by DEQ, you will be able to logon to Redbud but you will then have Read-Only privileges. You will still be able to view your data and print your Turn Around Documents. Corrections will then have be emailed or submitted by hard copy depending on their magnitude.