Answers to Mixtures Worksheet by jnb91437

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									                                                                                                                                          AERA-05
MINNESOTA POLLUTION CONTROL AGENCY                                                                                     DISPERSION FACTOR ANALYSIS
AIR QUALITY
520 LAFAYETTE ROAD                                                                                                      AIR EMISSIONS RISK ANALYSIS
ST. PAUL, MN 55155-4194                                                                                                   Air Quality #9.05 February 2006

AERA-05:          EMISSIONS
Air Emissions Risk Analysis
Air Quality #9.05 February 2006

 Instructions
 1. Please answer questions in the "Faciltiy Questions" worksheet and in the "Emissions Unit Questions" worksheet. Questions may be answered
 in the excel worksheet. If additional room in needed or attachments are necessary, please note where information can be found in your cover
 letter as well as in the appropriate "Questions" worksheet. Questions from the "Emissions Unit Questions" worksheet will need to be duplicated
 and answered for each emission unit. The "Facility Questions" worksheet only needs to be filled in once - for the overall facility.

 2. The "MPCA Questions" worksheet will be filled out by MPCA staff.

 3. Calculations for emissions are to be filled out in the "Emission Unit [EU00X]" tab(s) of this workbook. A new worksheet will need to be copied
 and inserted into the workbook for each emission unit at the facility.

 To add "Emission Unit [EU00X]" tabs for additional emission units:
 - Click on the "Emission Unit [EU00X]" tab.
 - Click on the "Edit" button on the top of the screen.
 - Click on "Move or Copy Sheet"
 - Make sure the "Copy Sheet" box is checked at the bottom of the box that pops up.
 - Keep sheet in same workbook (first scroll-down box)
 - Select where you would like to place the new "Emission Unit [EU00X]" in the second box.
 - Click on tab for new worksheet and RENAME to reflect the emission unit.
 - Each "Emission Unit [EU00X]" tab should be renamed to reflect the emission unit's name.

 4. Emission rates from columns j and k of the "Emission Unit [EU00X]" will be inserted into the RASS "Emissions" worksheet. Emissions for each
 emission unit (columns j and k) will be inserted into the RASS and correspond with a stack. The "stack identifier" in row 10 of the RASS would be
 the name of the emission unit.

 For information on calculating emission factors, see "Emission Guidance" worksheet or go to the AERA web at
 http://www.pca.state.mn.us/air/aera.html




aq9-05                                                                                                                                           AERA-05
Instructions                                                                                                                                          15
                                                        AERA-05
MINNESOTA POLLUTION CONTROL AGENCY   DISPERSION FACTOR ANALYSIS
AIR QUALITY
520 LAFAYETTE ROAD                   AIR EMISSIONS RISK ANALYSIS
ST. PAUL, MN 55155-4194                Air Quality #9.05 February 2006




aq9-05                                                      AERA-05
Instructions                                                     15
AERA-05:         EMISSIONS
Air Emissions Risk Analysis
Air Quality #9.05 February 2006



 In February of 2006 the MPCA approved emission estimating guidance for use in the AERA.

 The Emissions Estimating Guidance for Use in an AERA provides general guidance for preparing emission estimates for input into the risk
 analysis screening spreadsheet (RASS) of an Air Emissions Risk Analysis (AERA), and is to be viewed as a supplement to the MPCA’s AERA
 Guidance. It is the goal of the MPCA that emission estimates used in an AERA should be the most accurate estimate of emissions over the
 appropriate timeframe with a reasonable certainty that chemical emission rates are not underestimated, irrespective of the data source from
 which they are derived.

 The Guidance for Estimating PM2.5 Emissions for AERAs amends the MPCA’s AERA Guidance Version 1.0 dated March 2004 related to
 estimating PM2.5 emissions and predicting ambient air impacts. Specifically, section 2.6.1 “Criteria Pollutants” and section 3.4.8 “PM2.5” are
 revised and described in this guidance.

 The Guidance documents can be found on the AERA webpage at http://www.pca.state.mn.us/air/aera-emissions.html

 For additional information, please contact Anne Jackson at 651-296-7949.




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Emissions Guidance                                                                                                                                AERA-05
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MINNESOTA POLLUTION CONTROL AGENCY                                                                                                                                                                                                                EMISSIONS
AIR QUALITY
520 LAFAYETTE ROAD                                                                                                                                                                                                 AIR EMISSIONS RISK ANALYSIS
ST. PAUL, MN 55155-4194                                                                                                                                                                                              Air Quality #9.05 February 2006
Emissions Unit Emissions Rate Calculation Worksheet
   Feb-06
                Facility Name:
                Emission Unit No.                                RASS SV ID                                                                                       Date:
                Description:
                Maximum hourly
                throughput/capacity                              mmbtu/hr                           Assumptions used in developing annual throughput (text):
                Maximum annual
                throughput/capacity
       a                       b                       c                   d               e               f               g                h             i               j            k              l             m               n               p
                                                                                                                                                                     Stack Controlled
                                                                                        Uncontrolled Emissions                                                          Emissions                 Fugitive Emissions
                                               Un-               Un-
                                               controlled        controlled
                                               Factor            Factor                             Lb/hour                                                       Lb/hour                         Lb/hour                                       HAP?
CAS or                                         (acute)           (chronic)                          Emission Tons per                   Capture     Control       Emission Tons per               Emission Tons per           Factor            (yes or
MPCA #          Pollutant                      [3][4][6]         [3][6]            Units            Rate     Year                       Eff.        Eff. [1]      Rate     Year                   Rate     year               Source [2]        no) [7]
                Criteria Pollutants
                Particulate Matter                                                                               0                  0                                         0               0            0              0
                PM-10                                                                                            0                  0                                         0               0            0              0
                PM 2.5 [8]                                                                                       0                  0                                         0               0            0              0
                Sulfur Dioxide                                                                                   0                  0                                         0               0            0              0
                Nitrogen Oxides                                                                                  0                  0                                         0               0            0              0
                Carbon Monoxide                                                                                  0                  0                                         0               0            0              0
                Volatile Organic Comp.                                                                           0                  0                                         0               0            0              0
                Lead                                                                                             0                  0                                         0               0            0              0


                Air Toxics
                                                                                                        0.00E+00          0.00E+00                                   0.00E+00       0.00E+00        0.00E+00     0.00E+00
                                                                                                        0.00E+00          0.00E+00                                   0.00E+00       0.00E+00        0.00E+00     0.00E+00
                                                                                                        0.00E+00          0.00E+00                                   0.00E+00       0.00E+00        0.00E+00     0.00E+00
                                                                                                        0.00E+00          0.00E+00                                   0.00E+00       0.00E+00        0.00E+00     0.00E+00




                                                                                                                                 Click Here To                    lb/hour         tons/year
                                                                                                                                 Add New Row       Total Hap         0.00E+00       0.00E+00


MPCA Notes:
[1] Only use a control efficiency if it affects the emission rate given by the factor. For instance, it is not appropriate to use a control efficiency when using an emission limit as the factor. Document derivation of control efficiency.
[2] If using an AP42 or FIRE factor, provide the table number that the factor is taken from. If using a permit limit, state such.
   If using an alternative source for an emissions factor append supporting information.
   If using a data set to estimate emissions (e.g., stack test results) see Emissions Estimating Guidance. (February '06). Submit copies of the test's summary pages that contain the data and derivation of emissions factor.
[3] Typically the acute and chronic factors will be the same factor, because emission factor references provide only a single value.
[4] When using stack test data, the acute value is either the highest measured value or the 95% UCL, whichever is greater. See February '06 emissions guidance for providing documentation supporting a 95% UCL.
[5] Units of throughput should match units of the emission factor used.
[6] If the factor is in lb/hour, leave the emission factor cells blank, and use the lb/hour and tons per year columns instead.
[7] Identify if the chemical is a Clean Air Act Hazardous air pollutant.
[8] See February 2006 guidance describing how to estimate PM2.5 emissions



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Emission Unit Worksheet                                                                                                                                                                                                                                       8
AERA-05:          EMISSIONS
Air Emissions Risk Analysis
Air Quality #9.05 February 2006

                                                  Total Facility Level Information

** Reminder: Please remember to accurately fill in RASS SV ID (Cell 4E) in each header block of the "Emission Unit [EU00X]." The cell
should contain the SV ID number in the RASS that contains the emission rates corresonding to the information in this form. Also note:
columns j and k of the worksheet should appear in the RASS.

Facility Name:
Facility ID:
SIC Code:
Date:


 Provide answers below and reference attachments here and in cover letter.
 1. Describe the process used to identify emission factors (e.g. databases consulted, literature reviewed, internet searches, industry
 databases, personal interviews with industry experts, etc.).


 2. Describe any guiding principals or assumptions used throughout the emissions process. (e.g., treatment of non-detects in all data
 sets).

 3. Summarize the how much the project will increase (or decrease) emissions? (include information on risk drivers and mercury)

 4. Review the applicability of control standards and requirements as they relate to toxics controls. Specifically, what NESHAP applies,
 if any? Was feasible and reasonable control used?

 5. Were insignificant activities included? If included, describe assessment. (AERA Guide Section 2.3.2)

 6. If future projected actual emissions are used, provide business case description to support future case, three years of TRI
 information for existing facilities, and propose production-based permit limits.

 7. Determination of Technical and Economic Feasibility. If risk estimates are above risk criteria, a demonstration of technical and
 economic feasibility for control must be prepared. (AERA Guide Section 3.9)



aq9-05                                                                                                                                   AERA-05
Facility Emission Questions                                                                                                                    9
 8. Describe qualitatively how close the emission estimates are to what the facility will actually emit? What are the factors that impact
 this? (e.g., operating conditions, hours of operation, assessing individual chemicals, groups and mixtures)
 Some of the factors influencing the degree of conservativeness of the emissions estimates are summarized in the following example bullets.
 • The calculations assumed the combustion units would be operating at 100% availability rather than the actual historical availability of 90%
 availability. As such, this may overestimate the emissions by about 10%.
 • For the emission factors based on stack testing, the results are conservative in that maximum operating conditions and 8760 hours of annual
 operation were factored in.
 • The performance tests are run at maximum operating conditions.
 • The waste combustor annual emissions are based on 8760 hours of operation.
 • In this analysis, the consistency or variability of the dioxin/furan congener profile, and the associated stability of the 2,3,7,8-TCDD to total
 dioxins and furans mass ratio, has not been assessed. Minimal data has been reviewed to understand how reproducible the dioxin/furan
 congener profile would be over time and under varying operating conditions. If higher concentrations of the more toxic congeners were emitted,
 the risks could be higher than estimated. (The unlikely upper bound on this would be roughly 30 times higher risk and the unlikely lower bound
 would be zero risk).




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Facility Emission Questions                                                                                                                            10
AERA-05:          EMISSIONS
Air Emissions Risk Analysis
Air Quality #9.05 February 2006


                                            Emission Unit [EU00X] Questions
** Must duplicate these questions for each emission unit.
MPCA suggests that you label the emission unit in the grey box and answer questions. Copy and paste questions below the box below, label for
appropriate emission unit, and answer questions.

Facility Name:
Facility ID:
SIC Code:
Date:

 Provide answers below and reference attachments here and in cover letter.
 1. Describe the process used to identify sources of emissions factor data for this unit. Why did you choose the sources you chose
 (column n)?

 2. Was there conflicting information between different sources? Were some potential sources of emissions information considered and
 rejected?

 3. Provide the table number for AP-42 or FIRE factors (column n). Describe:
    - whether AP-42 factor is modified to account for it being an arithmetic average.
    - what mitigating factors support AP-42 being an upper bound estimate, if assumed.

 4. Describe source of emission factors for factors from sources other than AP-42, FIRE, or stack tests. Provide table number and/or
 page number as found in reference. Describe:
   - the number of tests used to generate emission factor.
   - the similarity of the emission unit, operating capacity and control equipment to those relied upon to generate the factor.
   - if an emissions factor within the reference being used is being excluded, provide rationale.
   - if using a mass balance, provide calculations and attach.

 5. If using stack test data to derive emissions rate, provide:
   - copies of tests' summary page(s)
   - list data points that were excluded with rationale. Describe how "outliers" were determined
   - ProUCL printout or other sheet describing calculation of 95% UCL

aq9-05                                                                                                                                         AERA-05
Facility Emission Unit Questions                                                                                                                    11
  - ProUCL printout or other sheet describing calculation of 95% UCL
  - description of how non-detects in dataset are managed. If chemical identified as "not detected" is not expected to be present,
 explain.

 6. What is the emission unit's operating capacity used in the calculations? (e.g., rows 6 and 7 in the worksheet)

 7. How do the assumptions used in the emission unit's operations compare with expected operating conditions? (actual hours of
 operation, percent utilization)

 8. Was a reasonable level of effort made to identify all COPI, i.e., was readily available information considered?

 9. Is there a difference in methods for how emissions are done? What is the difference before and after the modification?

 10. Review the applicability of control standards and requirements as they relate to toxics controls. Specifically, what NESHAP applies,
 if any? Was feasible and reasonable control used?

 11. If there is an emission limit for a given pollutant, did you use it in the worksheet? If permit limit, identify in sheet as "permit limit"
 and cite rule.

 12. Document capture and control efficiency assumed in columns h and i.




                                            Emission Unit [EU00X] Questions




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Facility Emission Unit Questions                                                                                                                       12
d




    aq9-05                             AERA-05
    Facility Emission Unit Questions        13
applies,




           aq9-05                             AERA-05
           Facility Emission Unit Questions        14
AERA-05:          EMISSIONS
Air Emissions Risk Analysis
Air Quality #9.05 February 2006


                                                   MPCA Engineer Questions
Facility Name:
Facility ID:
Date Received:
Date Completed:
Engineer:



 1. How were emission calculations confirmed? (including emission rates, conflicting information between different sources, and
 complete list of chemicals)

 2. Describe qualitatively how close the emission estimates are to what the facility will actually emit? What are the factors that impact
 this? (e.g., operating conditions, hours of operation, assessing individual chemicals, groups and mixtures)
 Some of the factors influencing the degree of conservativeness of the emissions estimates are summarized in the following example bullets.
 • The calculations assumed the combustion units would be operating at 100% availability rather than the actual historical availability of 90%
 availability. As such, this may overestimate the emissions by about 10%.
 • For the emission factors based on stack testing, the results are conservative in that maximum operating conditions and 8760 hours of annual
 operation were factored in.
 • The performance tests are run at maximum operating conditions.
 • The waste combustor annual emissions are based on 8760 hours of operation.
 • In this analysis, the consistency or variability of the dioxin/furan congener profile, and the associated stability of the 2,3,7,8-TCDD to total
 dioxins and furans mass ratio, has not been assessed. Minimal data has been reviewed to understand how reproducible the dioxin/furan
 congener profile would be over time and under varying operating conditions. If higher concentrations of the more toxic congeners were emitted,
 the risks could be higher than estimated. (The unlikely upper bound on this would be roughly 30 times higher risk and the unlikely lower bound
 would be zero risk).

 3. Should stack testing be considered? Why or why not?




aq9-05                                                                                                                                                AERA-05
MPCA Emission Questions                                                                                                                                    15

								
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