RE: Control Device Information

["Jon Dettling" <dettling@glc.org>]

Orlando,

This did get stopped by the listserv due to the attachment. I?ve posted the
original message and the attachments on the Wiki under a page I created for
describing the handling of Control Devices in the new RAPIDS:
http://glos.us/wiki/x/CwAU. When we get this all sorted out, we can update
that page to document the final design plan.

Jon

______________________
Jon Dettling
Great Lakes Commission
734-971-9135
dettling@glc.org
________________________________________
From: Cabrera-Rivera, Orlando - DNR
[mailto:Orlando.CabreraRivera@Wisconsin.gov] 
Sent: Friday, May 18, 2007 4:43 PM
To: dettling@glc.org
Subject: FW: Control Device Information

Hi Jon,
 
I sent this message earlier today, but I think it did not make it to the
list.
 
Thanks,
 
Orlando

________________________________________
From: Cabrera-Rivera, Orlando - DNR
Sent: Fri 5/18/2007 12:37 PM
To: Airtoxics
Subject: RE: Control Device Information
I believe that we can solve the problem with the controlled emission
factors by creating the capability to select the factor, and not by limiting
the EF table.  Regarding the calculation using control efficiencies and the
NIF export of control parameter, here are three documents that may help
provide information from the RAPIDS (or AEMS) perspective. These are
documents contain the Code used in our EI system emissions calculator, and
for the AEMS to NEI export. I know that we are supposed to be thinking out
of the RAPIDS box when redesigning the system, but perhaps these documents
can help.
 
Orlando
 
 
 
 

________________________________________
From: owner-airtoxics@great-lakes.net
[mailto:owner-airtoxics@great-lakes.net] On Behalf Of Wu, Chun Yi
Sent: Friday, May 18, 2007 10:23 AM
To: Tom Velalis; Airtoxics; Mark Young; Chun Yi Wu
Subject: RE: Control Device Information
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-----
From: owner-airtoxics@great-lakes.net
[mailto:owner-airtoxics@great-lakes.net] On Behalf Of Tom Velalis
Sent: Friday, May 18, 2007 8:24 AM
To: Airtoxics; Mark Young; Chun Yi Wu
Subject: RE: Control Device Information
 
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.
 


>>> "Wu, Chun Yi" <Chun.Yi.Wu@state.mn.us> 5/17/2007 5:45 PM >>>
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-----
From: owner-airtoxics@great-lakes.net
[mailto:owner-airtoxics@great-lakes.net] On Behalf Of Mark Young
Sent: Thursday, May 17, 2007 3:02 PM
To: 'Airtoxics'
Subject: RE: Control Device Information
 
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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