Instructions for DEQ Form #100-730
I. GENERAL REPORTING GUIDANCE
A. Inventory Reporting Requirements
The Air Quality Division (AQD) of the Oklahoma Department of Environmental Quality (DEQ) requests emission inventories and supporting documentation required by the federal Clean Air Act, in conjunction with Sections 2-5-105(9) and 2-5-112.B.11 of the Oklahoma Clean Air Act, Oklahoma Statutes Title 27A, and OAC 252:100-5 (Subchapter 5).
Subchapter 5 requires potential sources of air contaminants to register with the AQD, file an emissions inventory, and pay annual operating fees. The owners or operators of permit exempt facilities or de minimis facilities, as these terms are defined in OAC 252:100-7-1.1, are not required to submit an annual emission inventory.
All facilities that have a permit must submit an emissions inventory.
B. Report Regulated Pollutants Only
Report the amount of actual emissions of all regulated air pollutants, including quantifiable emissions from startups, shutdowns, and malfunctions (SSMs) or excess emissions. The following questions should be asked in the order shown to determine the correct reporting category for an emission. A pollutant should be reported if a pollutant question is answered with a ‘yes'.
Is the emission...
If the emission does not fall into any of the above categories,
C. Inventory Submission Tools
Emission inventories may be submitted using Redbud, the preferred method of reporting, or by completing DEQ Form 100-730 hard copy Turn-Around Documents (TADs).
D. Inventory Due Date
All content, necessary information, and requested data must be submitted on or before April 1. Upon receiving a written demonstration of good cause, the director of the AQD may grant an extension for submittal beyond the April 1 deadline.
E. Permit By Rule Reporting Schedule
The owner or operator of a facility newly registered under a permit by rule (PBR), as in OAC 252:100-7-9, shall submit an initial emissions inventory. After the initial emission inventory submittal, PBR facilities will be required to submit an annual emission inventory on the following schedule:
F. Deleting Records
A company can make a deletion request by completing DEQ Form 100-730(B) in Redbud or emailing the Emission Inventory Section with a request.
Use these instructions to complete an annual inventory
II. COMPANY INFORMATION
A. Company Name
The name of the legal entity or company that currently owns or operates the facility.
B. Facility Name
A unique facility name, facility location, or facility designation. The facility is the location where activities resulting in air emissions occur or have occurred.
C. Company Mailing Address
The business address to which mail is delivered, which can be distinct from the company's physical address.
D. Responsible Official (RO)
The name, phone, fax, and email address of the individual responsible for the company. A Responsible Official is defined in OAC 252:100-1-3. To change an RO, complete DEQ Form 100-882 (.pdf) with signature, and then email, fax, or mail the completed form to the address listed on the form.
E. Change in Ownership or Company/Facility Name
The owner or operator of any facility that is required to submit an emissions inventory shall notify DEQ in writing no later than 30 days following any transfer of ownership using DEQ Form 100-883 (.pdf).
III. FACILITY INFORMATION
A. Facility Physical Address
The physical address of the facility. A PO Box or rural delivery route number is unacceptable.
B. Facility Status
The operational status of the facility (selections listed below) during the reporting year. A company can change a facility's operating status, but by doing so the company is certifying the accuracy of the new status. Per OAC 252:100-7.1.1, annual emissions inventories do not need to be submitted for permit exempt or de minimis facilities. If a facility should be updated to permit exempt or de minimis in our records, please notify our office in writing (email, fax, or letter). In these cases, an inventory may be required for the part of the year in which the facility held a permit, prior to the exempt or de minimis classification.
The North American Industry Classification System. Enter the primary NAICS for overall facility operations. See http://www.census.gov/epcd/www/naics.html for valid NAICS values and conversion tables from NAICS to SIC and from SIC to NAICS.
The Standard Industrial Classification code for the facility. This can be determined at http://www.osha.gov/pls/imis/sicsearch.html.
E. TRI FID
The unique ID that is assigned to the facility in the U.S. Environmental Protection Agency (EPA) Toxic Release Inventory (TRI) data system. Contact our office if you believe the incorrect TRI ID is linked to your facility.
F. Facility Permits
All of the active permits issued for this facility.
G. Memo from DEQ/Memo from Facility
Use this memo field to explain entries or to address other issues in the inventory, where more information might be necessary. Also, please review any new notes from DEQ.
H. Facility Location
I. Main Facility Contact (MFC)
The name, phone, fax, and email address of the main contact for the facility. This will be our first point of contact should we have any questions regarding the facility's inventory.
To change an MFC, submit the new contact information (name, title, email, mailing address, and telephone number) to email@example.com.
IV. EMISSION UNIT INFORMATION
A. Sequence Number
A number assigned by the AQD for each particular emission unit so that companies can easily reference an emission unit at a facility. When reporting new emission units via hard copy, use the next available sequence number. In Redbud the sequence number will increment automatically when a new emission unit is added.
B. Emission Unit Name
The current name of the emission unit. Every emission unit must have an emission release point, at least one process, and if active, one or more pollutants (when equal or greater than the reporting threshold), which may also include control equipment information.
C. Notes from ODEQ/Notes from facility
Use this area to address issues relating to this emission unit and its associated emission release points, processes, and emissions. Examples include describing a drastic change in emissions from the previous year, emissions calculations using formulas, grouped emission units, etc.
D. Emission Unit Type
A description that uniquely identifies the emission unit chosen from the Unit Type table. Examples include but are not limited to boilers, engines, tanks, spray booths, fugitive sources, and crushers.
E. Emission Unit Status
The operational status of the emission unit.
F. Location of the Emission Unit
Enter valid GPS data only during initial creation of emission units. This information cannot change for existing emission units in Redbud.
G. Additional Emission Unit Guidance
V. EMISSION RELEASE POINT INFORMATION
A. Stack/Emission Release Point Name
Describes the area from which emissions are released into the environment via a stack or fugitive release. A release point can define the area over which fugitive emissions occur. Names should be similar to the emission unit name for easy recognition. When a facility has multiple emission units that go to a common release point, the release point for each emission unit should be the same name with the word "common" in it.
B. Stack/Emission Release Point Type
A description that uniquely identifies the release point: Fugitive, Vertical, Horizontal, Goose Neck, Vertical with Rain Cap, or Downward-Facing Vent.
C. Stack/Emission Release Point Status
The operational status of the stack/emission release point. If an emission unit is reported as temporarily shut down, the release point status should match the current emission unit status. It is possible for an emission unit, with multiple stacks, to be operational and some of the stacks reported as shut down.
D. Release Point Parameters
VI. EMISSION PROCESS INFORMATION
A. Process Description
A description of each process or activity at a particular emission unit (this description is assigned by the Source Classification Code). A single emission unit may have two or more processes (and so Source Classification Codes) if more than one material is used. For example, a single boiler will have two SCCs if it burns both fuel oil and natural gas.
B. Source Classification Code (SCC)
The EPA SCC for the process. The SCC describes an emissions process or activity. It is important to stay within a specific industry group. For assistance in selecting an appropriate SCC, access EPA's SCC searchable database: https://ofmpub.epa.gov/sccsearch/
There are certain facility operations that may be represented more accurately by the creation of multiple emissions processes at one emission unit. Examples include:
C. Confidential Business Information
Indication of confidentiality of process information. Emissions data that may be held as confidential is certain information, which if made public, would divulge methods or processes entitled to protection as trade secrets. Companies with confidential data must submit their company emission inventory by hard copy (TAD forms) and will not be able to utilize Redbud. Confidential information must be severable and "CONFIDENTIAL" should be marked on every applicable page. A "PUBLIC" copy of the report should also be provided with all of the confidential information removed. The Department shall hold and keep as confidential any information declared by the provider to be a trade secret and may only release such information upon authorization by the person providing such information.
D. Process Material
The substance from which the pollutants were created by each process. Depending on the type of source category, material may refer to the type of fuel combusted, raw material processed, product manufactured, or material handled. A table of the material descriptions to be used can be found here. If you can't find the exact material, select another material that best fits your process or contact the Emission Inventory Section for assistance.
E. Material Input/Output
F. Process Rates
The hourly, daily, and annual process or activity rate measured by the process rate units, which are typically defined by the process SCC.
The rate is a measurable factor or parameter that relates directly or indirectly to the emissions of an air pollution source. Activity information is typically the value that is multiplied by an emission factor to generate an emissions amount that should be expressed as tons per year (TPY). Note that this is the rate of the process that produces emissions and is not necessarily the amount of throughput of material passed through a piece of equipment. For example, for a compressor engine that is burning natural gas, the process rate would refer to the amount of natural gas burned by the engine, not the amount of gas compressed by the engine-driven compressor.
For tanks with no throughput activity: If the tank has product stored, the tank will remain active and the storage capacity of the tank or the actual amount stored should be entered as the throughput. The tank will still be emitting breathing losses even though there isn't any throughput.
G. Process Rate Units
The units of measure used to quantify the rate of the activity that produces air emissions.
H. Design Capacity (Report only if unit is a boiler, turbine, or internal combustion engine.)
The design capacity of the process equipment operating at 100% of the designed rate. For a boiler, design capacity is based on the reported maximum continuous steam flow. Report the design capacity for a boiler as MMBtu/hr (million British thermal units per hour). For a turbine report the design capacity as horsepower (hp) or megawatts (MW). For an internal combustion engine report the design capacity as hp.
I. Fuel Heat Content
The heat content of a fuel in million British thermal units (MMBtu) per the standard unit of measure for that type of fuel, that is:
J. % Sulfur
The percentage of sulfur, by weight, in the process fuel. The value must be between 0.01% and 10%, inclusive.
K. % Ash
The percentage of ash, by weight, in the process fuel. The value must be between 0.01% and 20%, inclusive.
L. Hours Per Day
The typical hours per day that the emitting process operates during the inventory period. This must be a number between 0 and 24 (inclusive).
M. Days Per Week
The typical days per week that the emitting process operates during the inventory period. This must be a number between 0 and 7 (inclusive).
N. Weeks Per Year
The typical weeks per year that the emitting process operates during the inventory period. This must be a number between 0 and 52 (inclusive).
O. Actual Hours Per Year
This represents the total actual hours the process operated during the calendar year for which the emissions inventory is being submitted. For leap years, actual hours per year must be a number between 0 and 8784 (inclusive). For all other years, this must be a number between 0 and 8760 (inclusive).
If during leap years, actual hours per year and/or actual emissions are over a permit limit, leave a note in the emission unit's memo field. Do not report excess emissions if the sole cause of the overage is due to the extra 24 hours of operation.
P. Seasonal Fractions
The fraction of the total operation that occurs in each season. This expresses the part of the actual annual activity information based on the four seasons. Seasonal fractions should be reported as decimals. For example, if 40% of production took place in summer, "0.40" should be entered for the summer season. Total seasonal operations should equal 100% or 1.0.
VII. EMISSIONS INFORMATION
A. Pollutant Description
The name of the substance, compound, or compound group of which emissions are produced.
The Chemical Abstract Services registration number for the pollutant (if applicable).
C. Calculation Method
The approved method used for computing or measuring emissions.
If you want to change the method of calculation, verify the method falls under any of the permissible methods. Otherwise, a new method must be pre-approved by the DEQ before submitting your annual inventory. Contact the Emissions Inventory Section for assistance. Details and references to support the new method may be requested.
D. Emission Factor
The ratio relating emissions of a specific pollutant to an activity or material process rate. The numeric value of this field is dependent upon the calculation method and the emission factor's numerator and denominator units. A pollutant-specific emission factor is typically expressed as pounds (lbs) per process rate units. If uncontrolled emission factors are reported here, reduce the resulting amount of emissions by the actual capture and control efficiencies of the control scenario.
Providing emission factors enables us to check and verify your calculations. In the case of specific models like E&P TANKS or GRI-GLYCalc 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."
E. Method/Factor includes Control Efficiency?
Check this box if the emission factor includes the control efficiency, meaning the factor is a Controlled Factor.
F. Factor Numerator Units
This is usually pounds but can be another unit, such as grams, where the emission factor is in grams per horsepower-hour (g/hp-hr).
G. Factor Denominator Units
These units are usually the same as the process rate units. For example, for a natural gas boiler the process rate is measured in million standard cubic feet (MMscf); the emission factor numerator unit would be pounds and the denominator unit would be million standard cubic feet (i.e., lbs/MMscf).
For calculation methods where there may not be one single emission factor used to compute the actual emissions (e.g., E&P TANKS, GRI-GLYCalc, CEMS), enter zero (0) in the emission factor field and for the numerator and denominator select "N/A - Formula, Software, or CEMS."
H. Trace (<0.001 TPY)
The trace checkbox can be used to indicate that emissions of a regulated pollutant have been estimated to be less than 0.001 tons. For emissions estimated to be greater than 0.001 tons but less than the reporting threshold of 0.1 tons (for most situations), a company can either report the quantified amount or report "0." The trace checkbox should only be used if emissions are below 0.001 tons.
I. Actual Emissions (Tons)
Amount of actual annual emissions of the pollutant, after application of air pollution control equipment, reported in tons per year. The actual emissions for a plant, emission unit, or process—measured or calculated—that represents a calendar year. This total shall include emissions from fugitives, upsets, startups, shutdowns, malfunctions, and excess emissions. The actual emissions field will allow emissions to three decimal places.
The specific source or material containing the method of calculation and factor. When using "AP-42 Factors" as a calculation method, record the table number (e.g., "Table 1.4-1"). When using "Permit Factors," insert the permit number unless the permit reference is AP-42. It is preferred to site the original source of the factor. When using "FIRE Data Factors," list the appropriate AP-42 section, table, or EPA document. Other references may include EPRI, RMA, UEF, etc. Other calculation methods may not have a reference, so leaving the field null in this case is acceptable.
K. Excess Emissions (Tons)
The amount of annual excess emissions as defined by OAC 252:100-1-3. This amount shall be included in the total amount of actual emissions.
Flaring events that do not exceed permit limits do not need to be reported as excess emissions. These limits may be per hour, as well as per year.
The amount of emissions from such events must still be entered in the actual emissions field.
Any emissions that are in excess of a permit or other such limit (this can also include malfunctions and maintenance activities) must be included in your excess emissions total. 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 total excess emissions field.
Any excess emission amounts that are formally reported to the Compliance and Enforcement Section of the AQD (as required by OAC 252:100-9) must be included in both the actual emissions field and the total excess emissions field.
L. Permit/Rule Limit (TPY)
The total amount of any regulated air pollutant which is subject to an emissions limiting standard, either by rule or permit condition contained in an enforceable permit.
When a facility's permit does not specifically set an emission limit for a particular pollutant from a particular emission unit (facility-wide limits only), enter zero (0) in this field to designate no specific emissions limit for the pollutant at that unit.
M. Capture Efficiency (%)
The percentage of air emission that is directed to the control equipment, or an estimate of that portion of an affected emissions stream that is collected and routed to the control measures, when the capture or collection system is operating as designed.
N. Control Scenarios (Primary and Secondary)
The control system, abatement equipment, or approach applied to reduce emissions of the pollutant.
O. Control Efficiencies (%) (Primary and Secondary)
The amount of actual air emissions prevented from being emitted by the control scenario. The actual efficiency should reflect maintenance degradation. Control efficiencies should be reported as a percentage.
P. Additional Emission Guidance
VIII. CERTIFICATION PAGE
A. Facility Summary
Hard copy reporters should total their emissions by pollutant and report those totals on a summary page. Blank summary pages can be found here.
B. Certification by Company Responsible Official (RO)
The emissions inventory shall contain a certification by a company's RO (as defined in OAC 252:100-1-3) of the truth, accuracy, and completeness of the document, as required by OAC 252:100-5-2.1(f). This certification shall be signed by an RO and shall contain the following language:
"I certify, based on information and belief formed after reasonable inquiry,