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General
Kansas Emissions Inventory Submittal System
Class I
Class II
Who must submit an emissions inventory
report?
All facilities that are required to apply for a Class I or Class
II operating permit must submit an annual emissions inventory.
See K.A.R. 28-19-517
(Class I inventory requirements) and
K.A.R. 28-19-546 (Class
II inventory requirement).
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Do I need to submit an emissions inventory
form if I didn't operate in the previous calendar year?
Yes. If your facility did not operate in
the previous calendar year and you want to keep your operating
permit active, you must submit the inventory form to us. Indicate
on the form that the facility did not operate and there are
no emissions to report.
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Do I need to submit an emissions inventory
form if my facility shut down its operations in the previous calendar
year?
If your facility shut down its operations
and you wish to deactivate your operating permit, you must notify
us in writing. If your facility operated for a portion of the
previous calendar year, you must submit an emissions inventory
covering the portion of the year you operated.
What if some of the information pertaining
to my facility is confidential?
Send us two copies of your inventory form--a
masked copy with the confidential data blanked out and a copy
that includes the confidential information. We will keep the
copy with confidential information locked in our confidential
files.
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How many copies of the completed inventory
form should I submit?
If you are not submitting confidential information,
submit one copy of your inventory form.
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Is the web submittal mandatory?
No
How do I get signed up?
Contact Will Stone, (785) 296-6427.
Who is eligible?
All Class I facilities.
If I sign up for the web can I submit on paper instead?
Signing up for the web system does not obligate you to use it. At any time you may submit the paper forms.
If I submit using the web system, should I also submit the Emission Inventory paper forms?
If you have submitted using the web then the only paper that you need to submit is the "Final Report" PDF from the Reports tab or the email.
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What pollutants must be reported?
Criteria pollutant emissions that must be reported include oxides of nitrogen (NOx), particulate matter with diameters of 10 micrometers or less (PM10), volatile organic compounds (VOCs), sulfur dioxide (SO2), carbon monoxide (CO), particulate matter with a diameter of 2.5 micrometers or less (PM2.5) and ammonia (NH3) emissions. Condensable PM (PM-CON) where emission factors or other emissions estimation methods are available must also be reported. The hazardous air pollutants listed in K.A.R. 28-19-201(a) must be reported as well.
For HAPS, emissions that are 500 pounds or more per
year from any emissions unit should be reported. Emissions that
are less than 500 pounds per year from any emissions unit do
not need to be reported, unless the total emissions from similar
units at the stationary source equal or exceed 2,000 pounds
per year. An exception to this is for facilities that are major for HAP’s with emissions of the following pollutants, those pollutants have no de minimus. These HAPs are:
1,3 – Butadiene Arsenic and arsenic compounds Benzene Chromium and chromium compounds Coke oven emissions Dioxins Lead and lead compounds Mercury and mercury compounds Nickel and nickel compounds Vinyl chloride
Other HAPs must be reported if the emissions
are more than 500 pounds per year from any emissions unit.
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Am I required to report fugitive emissions
at my facility?
Only those sources that are listed as a
federally designated fugitive source must report fugitive emissions.
These federally designated fugitive sources are listed in K.A.R.
28-19-200 as:
(dd) "Federally designated fugitive emissions source" means any of the following:
(1) coal cleaning plants, with thermal dryers;
(2) kraft pulp mills;
(3) portland cement plants;
(4) primary zinc smelters;
(5) iron and steel mills;
(6) primary aluminum ore reduction plants;
(7) primary copper smelters;
(8) municipal incinerators capable of charging more than 250 tons of refuse per day;
(9) hydrofluoric, sulfuric, or nitric acid plants;
(10) petroleum refineries;
(11) lime plants;
(12) phosphate rock processing plants;
(13) coke oven batteries;
(14) sulfur recovery plants;
(15) carbon black plants that use a furnace process;
(16) primary lead smelters;
(17) fuel conversion plants;
(18) sintering plants;
(19) secondary metal production plants;
(20) chemical process plants;
(21) fossil-fuel boilers, or a combination thereof, totaling more than 250 million British thermal units per hour heat input;
(22) petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels;
(23) taconite ore processing plants;
(24) glass fiber processing plants;
(25) charcoal production plants;
(26) fossil fuel-fired steam electric plants of more than 250 million British thermal units per hour heat input; or
(27) any other stationary source categories regulated by a standard promulgated as of August 7, 1980,under 42 U.S.C. §7411, (new source performance standards), or 42 U.S.C. §7412, (hazardous air pollutants), of the federal clean air act, but only with respect to those air pollutants that have been regulated for that category.
Records usually required for qualitative
assessments include: time and date assessment occurred, whether
emissions appeared normal, a description of the emission point
from which any unusual emissions emanated, steps taken to correct
any abnormal emissions, and the name of the person conducting
the assessment, and any other information required by the permit.
Which compounds are considered VOC's?
Volatile organic compounds include any compound
of carbon, excluding carbon monoxide, carbon dioxide, carbonic
acid, metallic carbides or carbonates, and ammonium carbonate,
that participates in atmospheric photochemical reactions. The
list of compounds that KDHE has designated as having negligible
photochemical reactivity are at K.A.R. 28-19-201(b). Emissions
of the compounds listed at
K.A.R. 28-19-201(b)
do not have to be reported as a VOC, although some of these
compounds are HAPs.
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What compounds are considered
glycol ethers?
Through the Toxic Release Inventory (TRI)
program, EPA has provided guidance on what compounds are included
in the glycol ethers category. This guidance document is available
in .pdf format at
http://www.epa.gov/ttnatw01/glycol2000.pdf.
Chemicals listed in this document should be reported as glycol
ethers.
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What should facilities that operate 24 hours
per day/7 days per week enter as their "typical start time" (on
worksheet 1)?
Enter 12:00 a.m. or midnight.
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What should peaking plants enter for typical
start time, hours/day, and days/week (on worksheet 1)?
If these types of records are kept at your
facility, determine the average start time, hours/day, and days/week
based on your operations during the peaking period, which will
generally be during the hottest months of the year. If you don't
have this information, please provide your best estimate based
on your knowledge of your process.
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How should facilities report emissions due
to malfunctions or upsets?
K.A.R. 28-19-210(f)(1) specifies that all
emissions during startup, shut down, control equipment malfunctions
or by-passes or other periods of greater than normal emissions
should be calculated as if the emissions unit was being operated
without air emission control equipment unless a more accurate
manner of calculating actual emissions is demonstrated by the
owner or operator and approved by the department. These emissions
should be reported on the inventory forms along with the facility's
other actual emissions for the calendar year. Please assign
a unique point ID number and fill out a separate worksheet 1
(air emissions source operating information) for malfunctions
or upsets. The emissions for this point should then be reported
on one of the emissions calculation worksheets (worksheets 3,
5, 6, 9 or 10). If you use worksheet 3 or 9 (the emission factor
method forms for criteria and HAP emissions) to report these
emissions, you may enter "Upset" for the emission factor origin
if needed.
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Which emission factor should I use if different
factors are listed for VOC (volatile organic compounds), TOC (total
organic compounds) and non-methane TOC?
Use the emission factor for VOC.
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Should stack height be measured from the
ground or the top of the building?
Kansas air regulations define "stack height"
as the distance from the ground-level elevation at the base
of the stack to the elevation of the stack outlet. (See K.A.R.
28-19-18b(c).)
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If my facility doesn't operate all four quarters,
why do the seasonal throughput percentages have to sum to 100% (on
worksheet 1)?
The sum of the seasonal throughput percentages
represents the total amount of time you operated during the
calendar year, not the percentage of your capacity that you
operated. The sum of the percentages should always equal 100%.
For example, if you burned 90 million cubic feet of natural
gas from June-August, 10 million cubic feet of natural gas from
September- November and no natural gas during the other quarters,
you would enter 0% for December-February, 0% for March-May,
90% for June-August and 10% for September-November.
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Do I need to complete every emissions calculation
worksheet in the inventory packet?
No. The worksheets cover a variety of methods
for calculating emissions, including mass balance, fuels analysis,
and emissions factor approaches. You only need to complete the
worksheets that are pertinent to your equipment or processes.
If you prefer to use some other methodology to estimate your
emissions, please attach documentation of your work.
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Am I allowed to use a method of estimating
emissions that is not included as one of the worksheets in the inventory
packet?
You should calculate your actual emissions
using the method that will yield the most accurate results for
your particular process or equipment. The worksheets that are
included in the inventory packet cover the most widely used
methodologies for calculating actual emissions, including mass
balance, fuels analysis, and emissions factor approaches. If
some other method is more appropriate for your facility (e.g.,
using an emissions model such as TANKS or LandGEM), you should
use that approach rather than one of the worksheets. Simply
attach documentation of the methodology you used, along with
your calculations and assumptions, to your inventory form.
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Are there activities that are exempt from
the emissions inventory?
There are many activities that have the
potential to produce minor emissions that are not required to
be reported. Examples of activities that are exempt follow,
but are not limited to:
1). Plant upkeep and maintenance: painting,
welding, plumbing, roof tarring, paving parking lots, clerical
activities, maintenance shop activities, cleaning, etc.
2). Finishing operations: hand held equipment
for buffing, polishing, cutting, drilling, sawing, grinding,
turning or machining wood or plastic.
3) Residential activities: not including fuel
burning equipment with a capacity of 500,000 Btu/hr or greater
or incinerators.
4). Health care activities: activities and equipment
directly associated with the diagnosis, care and treament of
patients in medical or veterinary facilities.
Miscellaneous: other activities meeting the
de minimus FAQ below.
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Is there guidance on the acceptable accuracy
of stack parameters?
We have not established a formal standard
for accuracy due to the wide variety of types, locations and
applications for the equipment in question. We request that
actual measurements be conducted for information such as stack
height and diameter if facility plans are not available due
to the age of the emissions unit. For taller, inaccessible stacks,
this may involve using an inclinometer and a rangefinder. Information
such as flow rate and temperature can be taken from design plans,
old stack tests, or estimated based on process knowledge. We
do not expect facilities to conduct stack tests to obtain this
information.
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Do emissions from light duty vehicles such
as security vehicles need to be included in the calculation of fugitive
emissions from haul roads?
Fugitive emissions include emissions from
processes directly related to your operations. Only the vehicles
hauling material need to be included in your calculation of
haul road emissions. You do not need to include security vehicles
or other light duty vehicles.
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What are the definitions of the different
types of particulate matter?
Particulate matter (PM) is all finely divided solid or liquid material, other than uncombined water, emitted to the ambient air, inclusive of all particle sizes capable of being airborne. PM10 is the portion of PM with an aerodynamic diameter less than or equal to 10 micrometers. PM2.5 is the portion of PM that has an aerodynamic diameter less than or equal to 2.5 micrometers and is most health offensive. Condensable PM is material that is vapor phase at stack conditions, but which condenses and/or reacts upon cooling and dilution in the ambient air to form solid or liquid PM immediately after discharge from the stack. All condensable PM is assumed to be in the PM2.5 size fraction.
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Do I need to report condensable PM emissions?
Yes you must report condensable PM (PM-CON) where emission factors or other emissions estimation methods are available.
AP-42 and WebFIRE are good sources of emission factors for condensable particulate matter.
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Do I need to report filterable PM emissions?
Yes you must report filterable PM10 (PM10-FIL) and filterable PM2.5 (PM2.5-FIL).
AP-42 and WebFIRE are good sources of emission factors for filterable particulate matter.
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Do I need to report primary PM emissions?
Primary PM, defined as the sum of condensable and filterable PM will no longer be reported.
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Which PM emission factor should I use?
The appropriate PM emission factor to use
will vary depending on what information is available for your
particular process. Our current guidance is as follows:
If no PM10 emission factor is available, use the total
particulate emission factor to calculate PM10 emissions.
(See K.A.R. 28-19-202(b)(1)(B).) If no information regarding PM2.5 is available, you
are not required to calculate a separate PM2.5 emissions
value. If no information regarding condensable PM (PM-CON) is available, you are not required to calculate a PM-CON emissions value.
Examples of possible PM emissions calculation
scenarios are below. If you need additional assistance with
PM emission factors, please contact us.
Example 1. For an uncontrolled industrial boiler firing distillate oil, Table 1.3-6 in AP-42 lists the following PM-filterable emission factors: PM10 -- 1 lb/1,000 gal fuel; PM2.5 -- 0.25 lb/1,000 gal fuel. For an uncontrolled industrial boiler firing distillate oil , Table 1.3-2 in AP-42 lists the following PM-CON emission factor: 1.3 lb/1000 gal fuel.
In this case, the proper emission factors are:
PM-CON - 1.3 lb./1000 gal fuel PM10-FIL - 1 lb/1,000 gal fuel PM2.5-FIL - 0.25 lb/1,000 gal fuel.
Example 2. For an uncontrolled natural gas fired boiler, Table 1.4-2 in AP-42 lists the following PM emission factors: PM-CON - 5.7 lb/106 scf fuel; PM-filterable -- 1.9 lb/106 scf fuel. A footnote states that all PM is assumed to be less than 1.0 micrometer in diameter, and, therefore, these factors can be used to calculate PM10 or PM2.5.
In this case, the proper emission factors are:
PM-CON - 5.7 lb/106 scf fuel PM10-FIL - 1.9 lb/106 scf fuel PM2.5-FIL - 1.9 lb/106 scf fuel
Example 3. For an uncontrolled preheated
kiln in a cement manufacturing process, Table 11.6-2 in AP-42
lists a filterable TSP emission factor of 250 lb/ton clinker
produced. There is no information on PM10 or PM2.5 emissions
or condensable particulate matter emissions. In this case, the
filterable TSP emission factor would be used to calculate PM10 and no PM2.5
emissions would be calculated.
In this case, the proper emission factors are:
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Who must pay emissions fees?
As specified in K.A.R. 28-19-202, facilities that emit 1 ton per year or more of NOx, PM10, SO2, VOC or HAPs must pay emissions fees.
For fees, PM10 emissions are defined the sum of filterable PM10 (PM10-FIL) and condensable PM (PM-CON).
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Do I round up to the nearest ton in paying fees?
Yes. You do need to round up to the nearest ton in paying fees. For example, if your facility emitted .5 tons of SO2 in the previous calendar year, you would round up to 1 ton and multiply by $37.00 per ton to determine your fees.
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How can I unprotect a Class II form posted
on the web in a Excel format?
Open the form you wish to unprotect.
Select - Tools, Protection, Unprotect Workbook
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If my facility doesn't operate all four quarters,
why do the seasonal throughput percentages have to sum to 100% (on
worksheet 1)?
The sum of the seasonal throughput percentages
represents the total amount of time you operated during the
calendar year, not the percentage of your capacity that you
operated. The sum of the percentages should always equal 100%.
For example, if you burned 90 million cubic feet of natural
gas from June-August, 10 million cubic feet of natural gas from
September- November and no natural gas during the other quarters,
you would enter 0% for December-February, 0% for March-May,
90% for June-August and 10% for September-November.
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My Class II facility maintains records on
actual emissions. Can I submit our records in lieu of the Class
II inventory form?
If your Class II facility maintains records
of actual emissions, we encourage you to submit the information,
but it is not required. Send us the inventory form with
the report of your actual emissions attached. You don't
have to fill out the worksheets in the inventory form, but we
do ask that you send them back to us marked with "see attachment".
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Why are the months listed for Seasonal Operating
Percentages Dec-Feb, Mar-May, Jun-Aug, and Sep-Nov instead of the
typical quarterly segments?
December-February is to be December, January,
and February of the same calendar year, which are not
consecutive months. The four quarters are operating
seasons and should equal 100%
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Is there a fee associated with my Class II Inventory?
No. There is no fee for Class II's, unless the Class II emission thresholds have been exceeded.
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Can my forms be faxed or emailed?
Yes. Since no signature is required on the Class II Inventory forms the forms can be faxed or emailed.
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