1. finance
2. accounting and auditing

General Issues
&
Reporting Guidance
Emissions Inventory Workshop 2014
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Topics to Discuss
 Recent Rule Changes
 Lower Reporting Guidance
Change
 Pneumatic Devices
 Typical Reporting Issues
 The Invoicing Process
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Changes to Subchapter 5
OAC 252:100-5
Registration, Emission Inventory and
Annual Operating Fees
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SC-5 Rule Changes
 Became effective September 10, 2013
 Minor rule clarifications:




Eliminated requirement to report “physical
state of contaminant” and “moisture content
of the gas stream”
Updated reporting method to emphasize
electronic reporting
Permit number now not required
Confidentiality of proprietary information –
corrected reference to the Oklahoma Statute
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SC-5 Rule Changes
Inventories for Permit by Rule (PBR)
Facilities – New reporting schedule

PBR facilities must submit inventory for 2014
or the first calendar year registered under a
PBR (if registered after 12/31/2014)

After the initial inventory submittal:



PBR facility > 5 Ton/year of any RAP – every NEI
three year cycle
PBR facility ≤ 5 Ton/year of any RAP – every
second NEI three year cycle
PBR facilities may elect to also submit an
emissions inventory for non-NEI reporting years
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SC-5 Rule Changes
 What this means for Permit by Rule
(PBR) facilities for 2013 Reporting:


If a facility applied for a PBR in 2013 then an
inventory will NOT be due provided the
facility would have qualified for a PBR
throughout all of 2013
If there was an equipment change or a
decline in production the facility may still
need to report for 2013
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Lower Emission Amount
Reporting Guidance
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Lower Emission Amount
Reporting Guidance
 There is no lower reporting limit in SC-5
 AQD provides reporting guidance that is “prudent
and practical”
 For 2010, 2011 and 2012 reporting years guidance
was that emissions of 0.001 tons or greater of any
regulated air pollutant must be reported from each
process
 Recent data analysis and a review of program
needs has allowed us to revise this guidance
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Lower Emission Amount
Reporting Guidance
 For the 2013 Reporting Year our guidance will be
emissions of 0.1 tons or greater of any regulated
air pollutant at a process must be reported
 Key exceptions must still be reported at 0.001 tons
or greater per process:

Lead, mercury & hexavalent chromium

Any HAP at a TRI facility

Any HAP from glycol dehydration still vents

Any HAP from large storage tanks (>500 BBL)

Other situations where deemed necessary
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Lower Emission Amount
Reporting Guidance
 You can still continue to report to 0.001 tons
per process if you choose to
 Trace Checkbox is available for <0.001 tons
if you wish to use this
 Contact us to remove unnecessary pollutants
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Pneumatic Devices
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Area Oil & Gas Emissions Tool
Source Category
VOC (TPY)
Artificial Lift
Associated Gas
87
1,295
Condensate Tanks
20,944
Crude Oil Tanks
25,825
Dehydrators
5,829
Drill Rigs
162
Fugitives
11,206
Gas-Actuated Pumps
15,932
Heaters
577
Hydraulic Fracturing
Lateral/Gathering Compressors
Liquids Unloading
Loading Emissions
16
511
20,658
4,823
Mud Degassing
11,094
Pneumatic Devices
86,614
Produced Water
Well Completions
- Natural Gas well completions
Wellhead Compressor Engines
Total
0
1,917
334
1,044
208,533
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Area Oil & Gas Emissions Tool
More information:
CenSARA Study
www.deq.state.ok.us/AQDnew/emissions/OilandGas
AreaEmissions
EPA National Oil & Gas Emissions Estimation
Tool
www.epa.gov/ttn/chief/net/2011inventory.html
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Pneumatic Devices

Pneumatic Devices account for over 40% of all
VOC emissions from wellhead facilities

Poorly characterized source that is present at
many types of Oil & Gas production, processing
and transmission facilities

Need to start collecting more data to improve
both point and area inventories



2014 will be an important reporting year
Optional to report for 2013, required for 2014
Work with companies this year to constrain
uncertainties in counts and bleed rates
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Pneumatic Devices
Specific SCC’s are now available in Redbud,
depending on:
 One of three device types (matches Subpart W
GHG reporting):



Low Bleed (≤ 6 scf/hr)
High Bleed (> 6 scf/hr)
Intermittent
 One of four sectors:




Gas Production
Oil Production
Gas Processing
Gas Transmission
(SIC
(SIC
(SIC
(SIC
1311)
1311)
1321)
4922)
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General Reporting
Issues
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Change of Ownership
Responsibilities of the:
 Transferor (Seller)
“The transferor shall notify the DEQ using a
prescribed form no later than 30 days following the
change in ownership.”
 Transferee (Purchaser)
“The transfer of ownership of a stationary source or a
facility is an administrative amendment that shall
subject the new owner or operator to existing permit
conditions and/or compliance schedules.”
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Change of Ownership
 What this means for the new owner:

Responsibilities transfer unless explicitly
stated in contract or sale agreement.

New owner is responsible for providing the
complete year’s inventory
- Even if sale took place within the reporting year
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Changing Facility Information
Form #100-883
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Changing a Responsible Official
Form #100-882
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Status of Inactive Facilities
 Reset to Active for New Reporting
Year
 Status Must be Verified Yearly
 If Active at any time, status is
Active for that reporting year
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Facility Status
 New Classification – “Not yet built”

E.g., permit applied for in 2013 but
construction has not yet started
 Add a brief facility note if necessary
 Exempt or De Minimis facilities must
be removed completely from Redbud

Contact us to do so
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Emission Unit and Stack Status
 Operating – operated all or part of the
calendar year
 Temporarily Shutdown – did not operate
at all during the calendar year, but may
restart at sometime in the future
 Permanently Shutdown – has been
physically removed or is permanently
shutdown
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Emission Unit and Stack Status
Operating and Temporarily Shutdown:
Remains in your inventory
Permanently Shutdown:
Drops from your inventory the next year
 Example: Emission unit operated through June 2013 then
physically removed from the facility in September 2013
Status for 2013 – Operating
Status for 2014 – Permanently Shutdown
Status for 2015 – Not in inventory
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Replacement Equipment

Create a new emission unit

Report data for original and replacement
equipment separately

Preferably include notes explaining the
situation at both units

Report original equipment as permanently
shutdown the next year. It will then drop
out of the inventory in the second year.
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Ensure Data is Consistent
If Emission Unit Status = Active
Operating Hours > 0
Process Rates > 0
Emissions > 0
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Storage Tank Emissions
 Emissions released from the bottom of a tank
that has no throughput must be reported

Tank would be reported as Active
 Tanks linked together can be reported as a
single emission unit
 Combined SCC 40400311 (working + breathing
+ flashing) may be used for condensate tanks
with < 6 ton per year total VOC emissions.
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Calculating Condensate Tank
Emissions
 TANKS Version 4.09D:
Estimates VOC and HAP emissions from fixed- and floating-roof
storage tanks. Used for calculating working and breathing loss
emissions.
www.epa.gov/ttnchie1/software/tanks
 Vasquez Beggs equation:
Used for calculating flashing losses
www.deq.state.ok.us/aqdnew/resources/Calculations11.xls
 RVP 10:
Is the closest default to condensate for the TANKS program
 Report Working, Breathing and Flashing losses
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Common Stack Reporting
 If you have all tank emissions going to a flare, create an
emission unit for the tank emissions with a flare as the
control and another emission unit for the flare itself to
show the combustion emissions

BOTH units will list the same common stack
 If you have all emissions going to a thermal oxidizer,
create an emission unit for the process emissions with a
thermal oxidizer as the control and another emission unit
for the thermal oxidizer to show the combustion
emissions

BOTH units will list the same common stack
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Common Stack – Flare as Control
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Common Stack – Flare Combustion
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Inventory Corrections
 During the reporting season, corrections to the current
reporting year are accomplished by making changes in Redbud
and resubmitting

Last submission overwrites any earlier ones
 Corrections after the reporting season can not be entered in
Redbud
 Corrections should be marked up in Red on a hardcopy of the
Turnaround Document (TAD) from the appropriate year
 Corrections must be certified by the Responsible Official with an
original signature and mailed to our office

Redbud TAD has a signature page that can be used in these
circumstances
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Certifying Corrections
 Submissions made through Redbud during the
reporting season do not need a hardcopy signature
 The statement below is on all Redbud TAD’s in case
it is needed for later hardcopy corrections
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Redbud Browser Compatibility
 Redbud is best used with Internet Explorer 5.5 or higher
 To correct compatibility problems with Internet 10 and 11:

Select Tools in your Menu Bar, then select compatibility view

Add state.ok.us to the compatibility view
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Air Quality Operating Fee
Invoicing Process
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Annual Operating Fee Invoices
 Invoices are mailed on July 1, normally
addressed to the Responsible Official
 Emissions are billed 2 years in arrears

CY 2014 Operating fees will be based on CY 2012 emissions
 Payment due 30 days after billing
 Companies with <5 Tons total are not
invoiced
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Annual Operating Fee Invoices
 PBR facilities will be assessed an annual operating
fee each year based on the most recent emissions
inventory submission.
 The current facility owner is responsible for
invoiced fees regardless of facility ownership
during the year in which emissions were released.
 Title V fees are adjusted yearly based on the CPI.
The 2014 Title V fees will be $36.33 per ton.
 Non-Title V fees are fixed at $25.12 per ton.
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Heads Up!
 2014 will be an important reporting year

Triennial NEI year, likely base year for non-attainment planning
 Data quality will be vital for developing effective control
strategies


Get 2013 in best possible shape now
Comprehensive 2014 inventory of Oil & Gas area and point
sources will be critical
 All PBR facilities will have to report for 2014
 We are developing processes for companies with large
numbers of similar facilities to directly export from their
databases to Redbud

Avoids needing to do data entry in Redbud

Not necessarily easy – requires significant technical expertise
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Important Proposed Change
for Reporting VOC in 2014
 Go from reporting
Speciated HAPs plus VOC (non-HAP)
to
Total VOC plus HAPs
 Should reduce errors and confusion
 Consistency with most published emission factors
 Oklahoma Clean Air Act does not allow double billing for
pollutants that are in multiple categories

Invoices will continue to charge for HAPs and VOC (non-HAP)
 Allow industry sufficient lead time to prepare for this
change
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Questions?
www.deq.state.ok.us/AQDnew/emissions
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Thanks for Coming Today
 Please complete the feedback form before you leave
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