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Bureau of Air - Emissions Inventory

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1. 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 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.

2. Who submits the emissions inventory report for a source that changed ownership?

See Kansas Administrative Regulation (K.A.R.) 28-19-517(c)(3) (PDF) for more information.

3. Do I need to submit an emissions inventory if I did not 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 an annual emissions inventory.

4. Do I need to submit an emissions inventory if my facility shut down its operations in the previous calendar year?

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.

5. What if some of the information pertaining to my facility is confidential?

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.

6. Is there a fee associated with my Class II Inventory?

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.

7. Who pays emissions inventory fees for a source that changed ownership?

See Kansas Administrative Regulation (K.A.R.) 28-19-517(c)(3) (PDF).

8. If my facility doesn't operate all four quarters, why do the seasonal throughput percentages have to sum to 100%?

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:

• 0% for December to February
• 0% for March to May
• 90% for June to August
• 10% for September to November

9. Why are the months listed for Seasonal Operating Percentages December to February, March to May, June to August, and September to November instead of the typical quarterly segments?

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%.

10. What should peaking plants enter for start time, hours/day, and days/week?

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.

11. What pollutants must be reported?

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.

12. 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:

• Plant upkeep and maintenance:
  • Painting
  • Welding
  • Plumbing
  • Roof tarring
  • Paving parking lots
  • Clerical activities
  • Maintenance shop activities
  • Cleaning, etc.
• Finishing operations: hand held equipment for any of the following processes for wood or plastic:
  • Buffing
  • Cutting
  • Drilling
  • Grinding
  • Machining
  • Polishing
  • Sawing
  • Turning
• Residential activities: not including fuel burning equipment with a capacity of 500,000 British thermal units (BTU) per hour or greater or incinerators
• Health care activities: activities and equipment directly associated with the diagnosis, care and treatment of patients in medical or veterinary facilities

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.

13. Am I required to report fugitive emissions at my facility?

Yes, fugitive emissions must be reported per Kansas Administrative Regulation (K.A.R.) 28-19-517(a)(2)(B) (PDF).

14. 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.

15. How do I report metals (or metalloids) hazardous air pollutants (HAP) such as chromium?

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:

• Antimony
• Arsenic
• Beryllium
• Cadmium
• Chromium
• Cobalt
• Cyanide
• Lead
• Manganese
• Mercury
• Nickel
• Selenium

Example:

1. A facility emits 100 pounds of strontium chromate
2. The atomic mass for strontium chromate is 204
3. The atomic mass of chromium is 52
4. The amount of chromium is 52 divided by 204 which is 25.5% of the total atomic mass of strontium chromate
5. Multiplying 100 pounds by the 0.255 yields 25.5 pounds of chromium
6. The 25.5 pounds divided by 2,000 pounds per ton is equal to 0.013 tons of chromium with the CAS number 7440473 as the reported pollutant code

16. Which compounds are considered volatile organic compounds (VOC)?

VOC include any compound of carbon that participates in atmospheric photochemical reactions, excluding:

• Ammonium carbonate
• Carbon dioxide
• Carbon monoxide
• Carbonic acid
• Metallic carbides or carbonates

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.

17. What compounds are considered glycol ethers?

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.

18. How should facilities report emissions due to malfunctions or upsets?

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.

19. What types of particulate matter must be reported?

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:

• 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
• PM Condensable 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 PM condensable is assumed to be in the PM2.5 size fraction
  • All PM2.5 is also a part of the PM10 size fraction

All subsets of Particulate Matter (PM) shall be reported when applicable:

• PM10-Filterable (PM10-FIL)
• PM25-Filterable (PM25-FIL)
• PM-Condensable (PM-CON)

20. Which Particulate Matter (PM) emission factor should I use?

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:

• If no PM-10 emission factor is available, use the total particulate emission factors to calculate PM-10 emissions.
• If no information regarding PM-2.5 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.

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.

Example 1

For an uncontrolled industrial boiler firing distillate oil, Table 1.3-6 in AP-42 lists the following PM-filterable emission factors:

• PM-10: 1 pound per 1,000 gallons (gal) fuel
• PM2.5: 0.25 pounds per 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 pounds per 1000 gal fuel.

In this case, the proper emission factors are:

• PM10-FIL: 1 pounds per 1,000 gal fuel
• PM2.5-FIL: 0.25 pounds per 1,000 gal fuel
• PM-CON: 1.3 pounds per 1000 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 pounds per 106 standard cubic feet (scf) fuel
• PM-filterable: pounds per 106 scf fuel

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.

In this case, the proper emission factors are:

• PM10-FIL: 1.9 pounds per 106 scf fuel
• PM2.5-FIL: 1.9 pounds per 106 scf fuel
• PM-CON: 5.7 pounds per 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 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.

In this case, the proper emission factors are:

• PM-10-FIL: 250 pounds per ton of clinker

21. Which emission factor should I use if different factors are listed for volatile organic compounds (VOC), total organic compounds (TOC), and non-methane TOC?

Use the emission factor for VOC.

22. 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 Kansas Administrative Regulation (K.A.R.) 28-19-18b(c)).

23. 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.