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In the previous RAPIDS, we find a match of control devices and ignore the order of them when we use controlled emission factors. I still want to have the same approach. The new NEI document indicates three control devises. In our state, we might have one emission unit associated with more than three control devices (some times goes to 14) for some reason. That is why I want to look at the individual control device codes under the group.
Chun Yi
-----Original Message-----
Chun Yi All that is needed is the code and the order of the control devices for the calculation of emissions using controlled factors. The data elements are present in the NIF3.0 control file but may not be present in the re-engineered format.
I have been working with FIRE emission factors for over a year now and I have little confidence on the FIRE controlled emission factors. Most of the controlled factors are derived from a single test and there is little information available regarding the efficiency of the control device. I even called many State inventory staff regarding this issue and got the same response from all of them. Do you know of any State inventory application that makes use of the Fire controlled factors? I will personally prefer stripping the controlled factors from RAPIDS3.
Tom.
I have a disagreement on “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.”
If we consider use controlled emission factors to calculate emissions in RAPIDS, we will need to have the information of individual control devices (codes) as I suggested in my previous e-mail.
Chun Yi
-----Original Message-----
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) 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. |