Comment Details
| Comment Author: | Natasha Meskal |
| Organization: | Ecotek |
| Comment Date: | Thursday, 04 June 2009 |
| Comments: |
Attachment 3: General Stationary Combustion: General Comment for stationary combustion fuel units: We would suggest the following standardized units for fuels: Gaseous: mmscf (or standard metric), Liquid: 1000 gallons (or standard metric), Solid: tons (or standard metric), and Energy: MMBTU (or standard metric). If Rule allows both versions, standard units used in US and standard metric units, future reporting tool could easily and simply convert from one to the other to allow: Each user group to use units they are comfortable with (it would inherently increase data accuracy) For data analysis – user would choose view in American or metric units and tool would take care of conversion, Since tool is converting one to the other – conversions used (and number of decimal places for constants) would be consistent and would not affect data quality. There are few reasons we are suggesting specific American System units: Most of the local Districts collects the fuel usage data in the proposed units – consequently I believe that big number of the facilities that will be subject to the reporting already have tracking systems set up to track their usage mentioned units. If industry (or some of the local governments) consider the consolidated reporting of criteria, toxics and GHG emissions reporting (which I hope will become general movement with WCI and EPA as well in the future – I would be happy to provide a list of numerous advantages to that approach if requested) – it will allow for easier data transfer and minimize chances for conversion/data entry errors. And the main reason for suggesting these particular standardized units is the fact that EPA FIRE (most commonly used compilation of default emission factors on national level) tends to offer default emission factors either in proposed units or in lbs/heating value. Recently lot of work/improvements was done on FIRE. It already contains some GHG default emission factors, that I would hope, will soon be greatly expanded. Particular improvement/effort to collect updated or new emission factors is reflected in new web application, recently added, that accepts source test data directly from facility/local government for EPA review and potential incorporation in FIRE. Thank you for your consideration. Please do not hesitate to call me at 714-596-8836 x 304 if I could provide any additional help. Sincerely, Natasha Meskal Ecotek |