First, I want to say that NIF Import files
for point sources do not have an importance to us. We will compile our
own data for point sources and submit to EPA.
To
simplify the RAPIDS3 structure, I think using control groups is an easy
approach. The Overall Capture Efficiency and Overall Capture/Control
Efficiency (combined) should provide us total fugitive emissions and total
stack emissions for the process. We can have characteristics of each
control device under the control device group, but these parameters will not be
used in emission calculation and report. When we use controlled emission
factors, RAPIDS could go to the group and find a match of control device codes.
The only thing we lose is the order of control devices. Anyone feels the
order of control devices is a critical piece?
Chun Yi
Wu, Ph.D., P.E.
Environmental Analysis & Outcomes Division
Minnesota Pollution Control Agency
520 Lafayette Road N.
St. Paul, 55155-4194
Phone: (651)282-5855
Fax: (651)297-7709
E-mail: chun.yi.wu@state.mn.us
-----Original Message-----
From:
owner-airtoxics@great-lakes.net [mailto:owner-airtoxics@great-lakes.net] On Behalf Of Tom Velalis
Sent: Thursday, May 17, 2007 10:06
AM
To: Airtoxics; Mark Young
Cc: Mike Ahern; Safaa ElOraby
Subject: RE: Control Device
Information
We are dealing with three
distinct possibilities/challenges of importing data in RAPIDs:
The NIF import is projected to be
the most popular import mechanism. Beginning with
inventory year 2008, every State is
required to submit NIF files for CAPs and HAPS
every three years to U.S.EPA.
Every State is prepared to meet this
reporting requirement and that also
applies for the Great Lakes States. For the
import of NIF files to
RAPIDs, I suggest doing the minimum processing of records and
make no assumptions on the
data. Having the data represented identically in RAPIDS and NEI,
is the best approach in storing
data and avoid having to deal with transparency issues.
The RAPIDs import files will be an
alternative method of importing data. I anticipate it to be a
less popular format because of the
additional burden in having to prepare RAPIDs files. However,
it is an option for some States who
wish to take the time and prepare control device files with
individual control and capture
efficiencies. Furthermore, States can distinguish fugitive emission
records from Stack records, report
multiple stacks for a process, etc, etc, etc. I personally do not
see
the purpose of doing all the
extra work. Is it for the few States that plan to estimate point
source HAP emissions
in RAPIDs? If that is
the main reason, I do not see how having detailed information will
assist with the
calculation of emissions. Controlled
FIRE factors are pretty much worthless for inventory purposes.
All that is needed for the
calculation of emissions is the activity, an uncontrolled factor and the
Total capture/control efficiency.
Also, when data are
exported to USEPA, the records will have to be processed and
aggregated to meet NIF format.
The manual entry is the
State's last resort of entering data and there is no need to even
discuss it.
Thanks for listening (less is
more).
Tom.
>>> "Mark Young" <ravenhunter@qwest.net> 5/16/2007
5:22 PM >>>
Cong,
Thanks for the feedback. I agree with everything you said, and you raised
a
couple of good points. I'm hoping to be able to handle both
cases--individual control devices and composite control systems. The NIF
format basically models the control system, as a whole. That's okay, and
we
can work with that if the input comes solely from NIF. I also think we
should try to accommodate the individual control devices for users who
aren't using NIF to import data to RAPIDS. I have some ideas on this, but
we still have issues to work out in cases where the sequencing of devices is
not known, etc. We could end up with a Control System record (equivalent
or
similar to NIF) and treat is as a kind of group. Individual control
device
records would then be members of a group, for accounting purposes, mainly.
I've been looking at the proposed EIS format the EPA has been working on,
and it looks similar to the NIF control format, with one major exception.
The control record has only two values--Overall Capture Efficiency and
Overall Capture/Control Efficiency (combined). There is no primary
control
efficiency in the proposed design (so far). That makes things even more
difficult if we try to disaggregate that record into multiple control device
records. It doesn't really seem necessary to disaggregate, though, as
long
as we know enough to compute total capture and control efficiencies for the
system.
Anyway, we'll have to bring this up for discussion with the group.
Thanks again,
Mark
-----Original Message-----
From: Doan, Congtru (ENE) [mailto:Congtru.Doan@ontario.ca]
Sent: Wednesday, May 16, 2007 8:15 AM
To: Mark Young
Subject: RE: Control Device Information
Mark,
If I understand correctly, you will not represent the composite control
device (control system with more than one control devices) in RAPIDS. In my
opinion it is a practical design. There should not be any problem in
grouping control devices of the same pollutant into a single NIF control
equipment record while exporting from RAPIDS to NIF files. However, there
might be problem in importing a NIF control equipment record with more than
two control devices. Do you have enough information in control device record
to populate the control efficiency factors for each control device in
RAPIDS? If there are only two control devices in a system then it is
possible to calculate the secondary control efficiency factor based on
primary control efficiency factor and system control efficiency factor. If
there are more than two control devices then we have to assume that all
other control devices but the primary have same control efficiency factor.
Cong,
-----Original Message-----
From: owner-airtoxics@great-lakes.net
[mailto:owner-airtoxics@great-lakes.net] On Behalf Of Mark Young
Sent: Tuesday, May 15, 2007 5:20 PM
To: Airtoxics
Subject: Control Device Information
Hi All,
During the meeting last week, we had some difficulty understanding the use
of control and capture efficiencies in NIF. Today, Tom gave me some
info that I also just found in the NIF 3 User Guide...
I copied into a Word document. The main point is that the capture
efficiency is for the whole system. I think we'll be modifying the
control
table structure a little bit from the way it is the the current ERD's. I
want to be able to represent individual control devices (not just overall
systems) for each process.
Let me know if you have any comments. Otherwise, we can pick this up in
the next call.
Thanks,
Mark Young
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