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Yes. If your facility did not operate in the previous calendar year and you want to keep your operating permit active, you must submit an annual emissions inventory.
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All facilities that are required to apply for a Class I or Class II operating permit must submit an annual emissions inventory. See Kansas Administrative Regulations (K.A.R.) 28-19-517 (Class I inventory and fee requirements) (PDF) and K.A.R. 28-19-546 (Class II inventory requirement) (PDF) for the regulations pertinent to your facility.
See Kansas Administrative Regulation (K.A.R.) 28-19-517(c)(3) (PDF) for more information.
Provided your facility continues to have an active operating permit you must submit an annual emissions inventory. If your facility shut down its operations and you wish to terminate your operating permit, you must notify the Bureau of Air in writing.
Confidential information can be labeled as such within the State and Local Emissions Inventory System (SLEIS) utilizing the CBI checkbox location on the Process tab under Process Emissions.
There are currently no fees associated with inventory from Class II facilities unless the Class II emission thresholds have been exceeded.
Class II facilities will begin paying emission inventory fees for tons of criteria pollutants and hazardous air pollutants emitted beginning with the 2024 reporting year on inventory reports that will be due on April 1, 2025.
See Kansas Administrative Regulation (K.A.R.) 28-19-517(c)(3) (PDF).
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 to August, 10 million cubic feet of natural gas from September to November and no natural gas during the other quarters, you would enter:
December to 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%.
If these types of records are kept at your facility, determine the average hours/day, and days/week based on your operations during the peaking period. If you do not have this information, please provide your best estimate based on your knowledge of your process.
All emissions of criteria pollutants and their precursor pollutants must be reported including carbon monoxide (CO), oxides of nitrogen (NOx), all forms of particulate matter (PM2.5-Filterable, PM10-Filterable, and PM-Condensable), sulfur dioxide (SO2), and volatile organic compounds (VOCs). Emissions of ammonia (NH3) must also be reported.
All emissions of hazardous air pollutants (HAPs), as listed in Kansas Administrative Regulations (K.A.R.) 28-19-201(a) (PDF), greater than 20 pounds (0.01 tons) per year (facility-wide) must be reported.
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:
Note: emissions that are a result of routine activities at the facility, even those that may be listed as Insignificant within an Operating Permit, are not exempt and are expected to be reported for annual emissions inventory purposes.
Yes, fugitive emissions must be reported per Kansas Administrative Regulation (K.A.R.) 28-19-517(a)(2)(B) (PDF).
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.
Please use only the mass of the of metal HAP component. The Chemical Abstracts Service (CAS) numbers for the metal elements can be found in Appendix B (PDF). HAPs that contain metal components and shall be reported include:
VOC include any compound of carbon that participates in atmospheric photochemical reactions, excluding:
The compounds that KDHE has designated as having negligible photochemical reactivity are listed within Kansas Administrative Regulation (K.A.R.) 28-19-201(b) (PDF). Emissions of these compounds do not have to be reported as a VOC, although some of these compounds are hazardous air pollutants (HAPs) and must be reported as HAPs.
Through the Toxic Release Inventory (TRI) program, the Environmental Protection Agency (EPA) has provided guidance on what compounds are included in the glycol ethers category; view the EPA's TRI Guidance Document (PDF), online. Chemicals listed in this document should be reported as glycol ethers.
Kansas Administrative Regulation (K.A.R.) 28-19-210(f)(1) (PDF) 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 along with the facility's other actual emissions for the calendar year using a unique process identifier for malfunctions or upsets.
All forms of Particulate Matter (PM) shall be reported. 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:
All subsets of Particulate Matter (PM) shall be reported when applicable:
The appropriate Particulate Matter (PM) emission factor to use will vary depending on what information is available for your particular process. Our current guidance is as follows:
Please note that KDHE requests only the filterable and condensable components of particulate matter, which is in turn used to calculate the primary component of particulate matter.
The following are examples of possible PM emissions calculation scenarios. If you need additional assistance with PM emission factors, please contact us.
For an uncontrolled industrial boiler firing distillate oil, Table 1.3-6 in AP-42 lists the following PM-filterable emission factors:
For an uncontrolled industrial boiler firing distillate oil, Table 1.3-2 in AP-42 lists the following PM-CON emission factor: 1.3 pounds per 1000 gal fuel.
In this case, the proper emission factors are:
For an uncontrolled natural gas fired boiler, Table 1.4-2 in AP-42 lists the following PM emission factors:
A footnote states that all PM is assumed to be less than 1 micrometer in diameter, and, therefore, these factors can be used to calculate PM-10 or PM-2.5.
For an uncontrolled preheated kiln in a cement manufacturing process, Table 11.6-2 in AP-42 lists a filterable total suspended particles (TSP) emission factor of 250 pounds per ton clinker produced. There is no information on PM-10 or PM-2.5 emissions or condensable particulate matter emissions. In this case, the filterable TSP emission factor would be used to calculate PM-10 and no PM-2.5 emissions would be calculated.
Use the emission factor for VOC.
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 Kansas Administrative Regulation (K.A.R.) 28-19-18b(c)).
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.