Data Quality Control

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Data Quality ControlCommon ErrorsMark Gibbs
Reporting 2006Emissions Inventories
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Presentation Outline

• Validation at time of data entry
• Error Checking and Analysis after submission
• Error Correction Process
• Most common (and easily
• avoidable) errors

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Data Validation

• Validation procedures continue to tighten-up
• Key fields are validated at time of entry
• You must still indicate if a field is N/A
• If a field is not completed
• You will be unable to save data in Redbud and do
  a Final Submit
• Detailed checks and analyses after submission

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Complete All Data Fields

• Substantially incorrect submissions will be
  returned to you
• Else you will be contacted by the Emissions
  Inventory Section staff corrections can be made
  via email
• Save time get it right the first time!

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Update with 2006 Data

• Dont enter last years data,turn that around
  and send it back to us!
• Most processes do not operate
• for exactly the same number of hours,
• with the same annual rate, and
• produce the same amounts of emissions
• from year to year.

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Update with 2006 Data

• Key fields deliberately zero-ed out
• Annual Process Rate
• Annual Hours of Operation
• Emission Amounts
• Excess Emission Amounts
• All these fields need to updated with ACTUAL data
  for 2006

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The Emissions Inventory Data Hierarchy
Company gt Facility gt Point gt Process gt
Emission
Company Facility Facility Point Point Pro
cess Process Emission Emission
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Facility Address

• Must be a physical location
• 1600 Pennsylvania Avenue
• 0.5 MI W of Springlake DR and MLK AVE
• 1 MI S of SH-33 and Co Road 234
• Not
• Near Cushing
• PO Box 123

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Facility Operational Status

• Five Options
• 1. Active
• 2. Idle
• 3. Closed
• 4. Exempt
• 5. De Minimis

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Closed Facilities

• Closed Status
• Applies only if facility has been permanently
  shut down
• Annual Emission Inventories are not required
• DEQ must have confirmation in writing
• Note If the facility operated at any time during
  the calendar year
• its status will not be changed to Closed
• until the following year

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Exempt De MinimisFacilities

• As defined in OAC 252100-7-1.1
• Emissions Inventories are not required for these
  facilities.
• Note A facility with an existing permit cannot
  simply be declared Permit Exempt
• The permit must be cancelled
• by DEQ

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Do you need to submit?

• If we have not sent you a form or your facility
  is not in Redbud
• The onus is still on you to ensure you are
  compliant
• Contact us if a facility
• has recently opened,
• is not now permit exempt,
• etc,
• and we will load the relevant
• data into Redbud

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Facility Data

• NAICS Code
• TRI Facility ID
• Dun Bradstreet Number
• This information is required
• We continue to tighten-up data completeness
• So expect these fields to be checked!

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Incorrect SIC / NAICS andSCC Assignments

• Create errors in
• Categorization
• Reconciliation
• Assignment of control and growth profiles
• Which impacts
• Photochemical modeling
• Control strategy development
• Effective and efficient application of
• regulatory measures
• Success of Attainment Plans

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Point Name

• Use as precise a name as possible
• Should be able to distinguish from any other
  Emission Point by name only
• Include any permit name or reference
• e.g., EUG-3
• Include any internal reference number
• e.g., Tank 3210

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Facility Point LocationData

• Needed for
• Cross-referencing regulatory databases
• Geographical location of emissions
• Ultimately need GPS data to an accuracy of 1
  meter for
• The facility (Main Gate)
• Each emission point

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Stack Data Errors

• Entering both fugitive and stack dimensions
• Improved logic in Redbud
• Clearer Hardcopy forms
• Stack data not in correct units
• Flow Rate is in acfm
• actual cubic feet per minute
• Gas Exit Velocity is in fps
• feet per second

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Missing Stack Data Fields

• Example
• One or more of Stack Height, Diameter, Flow Rate
  or Temperature missing
• Creates errors in
• Calculation of effective plume height
• Determining pollutant dispersion

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Missing Stack Data Fields

• Which impacts
• Photochemical modeling
• Ozone studies
• Model validation
• Health risk assessments
• Solution
• Provide all stack physical
• parameters

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SCC Source Classification Code

• Avoid General or miscellaneous classifications
• SCCs ending xxxxxx99
• Be as specific as possible
• e.g., Compressor Engines 20200202 is not
  acceptable should be
• 20200252 2-cycle Lean Burn
• 20200253 4-cycle Rich Burn, etc.
• Make sure the SCC is valid for
• process and facility

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SCC for Flashing Losses

• New SCC available for reporting flashing losses
  only from hydrocarbon storage tanks
• 40400300 Fixed Roof Tank Flashing Loss
• Do not need to use 40400311 (Breathing Working
  Flashing) for condensate flashing losses only
• There should be three separate
• processes with own SCC and
• emission amounts

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Process Data Errors

• Operating Rates - hourly, daily annual
• Different definitions but same units
• Maximum Hourly Rate
• Typical Daily Rate
• Actual Annual Rate
• Rates are not in the proper units
• Does not match actual throughput
• Prefer units to be consistent with emission
  factor numerator units

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Missing / Incorrect Temporal Data

• Example Fields
• Hours/day, days/week, weeks/year, seasonal
  operating fractions
• Creates errors in
• Temporal distribution of emissions

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Missing / Incorrect Temporal Data

• Which Impacts
• Seasonal planning inventories
• Photochemical modeling
• e.g., modeling an extreme summer ozone event
• Weekday/ weekend studies
• Solution
• provide as accurate as possible
• temporal data for each process

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Typically Under-ReportedPollutants

• Fugitive Dust
• Ammonia (NH3)

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Lower Reporting Limits

• No legally defined lower cut-off for individual
  emissions
• intent is to be cautious and practical
• Report individual pollutant emissions if facility
  total of that pollutant exceeds 0.1 Tons (200
  lbs)
• Redbud accepts data down to
• 0.001 Tons (2 lbs)

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Fugitive Dust

• Unpaved roads
• Agricultural tilling
• Construction
• Windblown dust, Fly ash

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Ammonia (NH3)

• Where applicable, all facilities should report
  ammonia
• Ammonia (NH3) emissions are often
  under-represented
• important contributor to the formation of
  secondary fine Particulate Matter (PM)

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Sources of NH3 Emissions

• Emissions from industrial processes
• Refrigeration losses
• Combustion sources
• Fertilizer production
• Petroleum refining
• Pulp and paper production

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Best Available Data Method

• Emissions shall be calculated using the best
  available information
• DEQ Approved Methods only
• Portable Emissions Analyzer results are NOT
  acceptable
• List the most specific category
• Must be able to demonstrate
• Prior Approval from DEQ

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Emission Factor Errors

• Missing emission factor and units
• Throughput units are inconsistent with emission
  factor units
• e.g., rate is in MMSCF but emission factor is
  lbs/MMBTU
• Value of emission factor does not match emission
  factor units
• All these issues will affect replication
  calculations

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Control Devices

• Not reported
• Incorrect descriptions used
• Control efficiencies not reported
• Effect of controls not included in reported
  emissions
• Multiple Controls not reported or handled
  correctly

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Missing / Incorrect Control Equipment data

• Not completed correctly
• Primary and secondary control device fields
• Control efficiency field
• Creates errors in
• Identifying controlled vs. uncontrolled emissions
• Identifying control equipment used

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Missing / Incorrect Control Equipment data

• Which can impact
• Control strategy planning
• Rule development
• Solution
• Provide correct control device information
• and/or
• control efficiency for each controlled pollutant

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Emissions Calculation Errors

• Math errors
• Control efficiencies not handled correctly
• Using wrong units when doing conversions
• Be careful to report your emissions in Tons not
  pounds per year
• - Could be a very expensive mistake!

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How to Calculate Emissions Correctly

• The general equation for emissions estimation is
• E A x EF
• Where
• E emissions
• A activity rate
• EF emission factor
• For controlled emissions this becomes
• E A x EF x (1-ER/100)
• Where
• ER overall emission reduction efficiency,

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How to ReportEmissions Correctly

• Calculated / Measured Emissions
• Excess Emissions
• ACTUAL Total Emissions in
• Tons per Year (TPY)

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Resources Help

• The Emissions Inventory Website

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Resources Help

• www.deq.state.ok.us/AQDnew/emissions
• Rules
• Redbud Online Help
• Turn Around Documents
• Instructions Help
• General Instructions
• Tables
• Useful Links

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Resources Help

• www.deq.state.ok.us/AQDnew/emissions
• Emissions Inventory FAQs
• Workshop Presentations Training Materials
• How to Contact Us!

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EPAs CHIEF Web Site

• Clearing House for Inventories Emissions
  Factors
• www.epa.gov/ttn/chief

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www.epa.gov/ttn/chief
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www.epa.gov/ttn/chief

• Published National Emissions Inventories
• Emissions Factors
• Software
• Basic Information and General Training

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Questions?

• Also dont forget the
• feedback form!