Emissions Inventory

Frequently Asked Questions


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:

  • PM-CON - blank

  • PM10-FIL - 250 lb/ton of clinker

  • PM2.5-FIL - blank

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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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