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Chun Yi, Do you mean three control devices within a
control equipment record? I believe there is no limit on number of control equipment
records for a process. In other words, one process can have one control equipment
record for Sox, one for NOx, one for VOC, one for PM …… I might be
wrong. I know very little about NIF! Mark, Why is the order of control devices important
to you? Could you provide an example where the order of control device
configuration results different emissions (control emission and fugitive
emission). We did not have enough time in the meeting to verify this! Thanks. Cong, From:
owner-airtoxics@great-lakes.net [mailto:owner-airtoxics@great-lakes.net] On Behalf Of Wu, Chun Yi The new NEI Facility Inventory Data
Collections request us to report up to three control devices. Is it
feasible if we pick up the first member of the control device within the
control group as the primary control device and so on? Chun Yi -----Original Message----- Chun Yi It seems that you are in agreement
in having a control group instead of individual control devices. The NEI
control equipment file lists up to four control sequential device
codes. NEI control equipment file structure does not specify
how the control devices are configured (Parallel or Series) but it does
define the order. This file should be sufficient to calculate controlled
emissions. Tom.
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. -----Original Message----- Mark We are dealing with three
distinct possibilities/challenges of importing data in RAPIDs: 1. NIF Import files and 2. RAPIDS Import files 3. Manual Entry. 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. |