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RE: Control Device Information
Mark and GLC members,
there seems to be a lot of discussions lately about control devices.
You may want to examine the proposed new EIS structure that will replace
the current NIF for 2008. I believe that the format will be
changing..... control information will also be mandatory in the new
EIS. Currently data in the CE table in the NIF is not required.
The control measure in current NIF is linked to the process ID and
pollutant. You can have up to 4 control devices for each process ID.
We are doing a lot of clean-up of control measures code table as part of
EIS.
Let me know if you would like more information....
I will be in Chicago at RO V for a mercury workshop July 16 - 18 if you
would like to meet with me.
anne
"Mark Young"
<ravenhunter@qwe
st.net> To
Sent by: "'Airtoxics'"
owner-airtoxics@ <airtoxics@great-lakes.net>
great-lakes.net cc
Subject
05/17/2007 04:02 RE: Control Device Information
PM
Cong,
Some users may be using NIF just to import data into RAPIDS and store it
there--including precalculated emissions. However, imagine using NIF
formats to import everything EXCEPT emissions into RAPIDS. In that
case, we would need enough information to calculate.
With the CE format (NIF control systems), there's enough information to
calculate emissions, as is. Theoretically, at least. That's what you
and Tom are both saying. I agree. We don't need the efficiency details
of individual devices, just the system as a whole. So, in using the NIF
approach, everything should work okay--IF the necessary efficiency
fields are actually filled in.
In the case of moving data from older versions of RAPIDS, we may have
other issues where we need to know the efficiency data for each control
device in order to calculate the overall system values. In that case,
the order of equipment is only important if more than one device has a
capture efficiency <100%. In a case like that, we'd need to know which
one captures first.
I am in favor of using the "Control System" approach, myself. It seems
the only way to generalize all the possible cases. Storing information
for individual devices is only a suggestion, and those records would not
be used for any reason other than "accounting", nor would they be
required. The big question is: do we really need or want the ability
to record devices individually?
Mark
From: owner-airtoxics@great-lakes.net
[mailto:owner-airtoxics@great-lakes.net] On Behalf Of Doan, Congtru
(ENE)
Sent: Thursday, May 17, 2007 1:13 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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