FW: Control Device Information

-----Original Message-----
From: Wu, Chun Yi
Sent: Thursday, May 17, 2007 4:30 PM
To: 'Doan, Congtru (ENE)'
Subject: RE: Control Device Information

Yes. Three control devices within a Control Measures Collection record for one pollutant being controlled in the draft NEI document.

Chun Yi

-----Original Message-----
From: owner-airtoxics@great-lakes.net [mailto:owner-airtoxics@great-lakes.net] On Behalf Of Doan, Congtru (ENE)
Sent: Thursday, May 17, 2007 2:13 PM
To: Airtoxics; Mark Young
Subject: RE: Control Device Information

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
Sent: Thursday, May 17, 2007 2:46 PM
To: Tom Velalis; Airtoxics; Mark Young; Chun Yi Wu
Cc: Safaa ElOraby
Subject: RE: Control Device Information

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-----
From: Tom Velalis [mailto:tom.velalis@epa.state.oh.us]
Sent: Thursday, May 17, 2007 12:50 PM
To: Airtoxics; Mark Young; Chun Yi Wu
Cc: Safaa ElOraby
Subject: RE: Control Device Information

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.

>>> "Wu, Chun Yi" <Chun.Yi.Wu@state.mn.us> 5/17/2007 12:26 PM >>>

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

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.

>>> "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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