United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-454/R-94-033
September 1994
Air
vvEPA
PM-10 EMISSION INVENTORY
REQUIREMENTS
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EPA-454/R-94-033
PM-10 EMISSION INVENTORY
REQUIREMENTS
Office Of Air Quality Planning And Standards
Office Of Air And Radiation
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
September 1994
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This report has been reviewed by the Office Of Air Quality Planning And Standards, U. S.
Environmental Protection Agency, and has been approved for publication. Any mention of trade
names or commercial products is not intended to constitute endorsement or recommendation for use.
EPA-454/R-94-033
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CONTENTS
Pacre
LIST OF TABLES iv
ACRONYMS v
1.0 OVERVIEW OF DOCUMENT . , 1
1.1 Purpose 1
1.2 How to Use This Document . 1
2.0 DEFINITIONS AND REGULATORY REQUIREMENTS 2
2.1 Definitions of PM-10 2
2.1.1 Primary PM-10 2
2.1.2 Condensible PM-10 2
2.1.3 Secondary PM-10 (PM-10 Precursors) . 2
2.2 Summary of Regulatory Retirements 3
2.2.1 Nonattainment Designations 3
2.2.2 Classification 3
2.2.3 Nonattainment Area Boundaries . . : 3
2.2.4 SIP Requirement Submittal Timelines 4
2.2.5 Attainment Demonstration 4
3.0 EMISSION INVENTORY 7
3.1 Summary of Inventory Types 7
3.2 Temporal Resolution of Inventory 9
3.3 Inventory Preparation Plan (IPP) 9
3.3.1 IPP Point Source Requirements 10
3.3.2 IPP Area and Mobile Source Requirements 10
3.3.3 Other IPP Requirements , 11
3.4 Base Year Inventory 11
3.4.1 AIRS Compatible Reporting 12
3.4.2 Geographic Coverage 13
3.4.3 Applicable Source Categories • . . . 13
3.4.3.1 Point Sources .' 13
3.4.3.2 Area and Mobile Sources 14
3.4.4 Rule Effectiveness 15
3.5 Updating Inventories 15
3.6 Adjustment of Base Year Inventory (Backcasting) 15
3.7 RFP Projection Inventories 16
3.8 Modeling Inventories 16
3.8.1 For Multi-source Areas 16
3.8.2 Background Sources 18
4.0 DOCUMENTATION/DATA MANAGEMENT AND REPORTING OF THE INVENTORY ... 19
4.1 Documentation 19
4.2 Data Management and Reporting 22
5.0 REFERENCES • 23
APPENDIX A INVENTORY PREPARATION PLAN (IPP) REVIEW CHECKLIST 25
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LIST OF TABLES
Number ' Page
2.1 Moderate Nonattainment Area Due Dates 5
2.2 Serious Nonattainment Area Due Dates 6
3 .1 Basic Outline of an Inventory Preparation Plan 12
3.2 Model Emission Input Data for Point Sources 17
4.1 Outline for EPA Recommended Format/Contents for PM-10 Emission
Inventory Reports 20
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ACRONYMS
AFS AIRS Facility Subsystem
AIRS Aerometric Information Retrieval System
AMS AIRS Area and Mobile Source Subsystem
BACM Best Available Control Measure
BACT Best Available Control Technology
CAA Clean Air Act as amended in 1990
CHIEF Clearinghouse for Inventories and Emissions Factors
EPA U.S. Environmental Protection Agency
FIRE Factor Information Retrieval System
FTA fail to attain
FTD fail to demonstrate
Hr hour
IPP inventory preparation plan
MMBtu million British thermal units
NAAQS National Ambient Air Quality Standard
PM-10 particulate matter that measure less than or equal to
10 micrometers in aerodynamic mass median diameter
QA quality assurance
QC . quality control
RACM Reasonably Available Control Measure
RACT Reasonably Available Control Technology
RE rule effectiveness
RFP reasonable further progress
SCRAM Support Center for Regulatory Air Models
SIP State implementation plan
TTN Technology Transfer Network
VMT vehicle miles traveled
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SECTION 1.0
OVERVIKW OF DOCUMENT
1.1 Purpose
This document describes the .emission inventory requirements that are
contained, either explicitly or implicitly, in the Clean Air Act as amended in
1990 (CAA) for those areas that are required to submit a State Implementation
Plan (SIP) for demonstrating attainment of the National Ambient Air Quality
Standard (NAAQS) for PM-10. The guidance in this document pertains to PM-10
moderate nonattainment areas and to areas that have been reclassified as
serious nonattainment areas. The purposes of the document are to (1) identify
the types of inventories required; (2) briefly review the regulatory
requirements pertaining to submission of these inventories; (3) describe the
objectives, components, and ultimate uses of the inventories; and (4) define
documentation and reporting requirements for the inventories.
1.2 How -bo Use This Document:
This document is intended to be a guide for State and local agencies to
refer to for the requirements as prescribed by the CAA for submitting their
emission inventories; it is not a procedures document covering the methods for
compilation or reporting of emission inventories. The U.S. Environmental
Protection Agency (EPA) will issue further guidance pertaining to procedures
for preparing, compiling, and reporting emission inventories. It is
recommended that State and local agencies consult the references listed in the
Section 5.0 of this document for additional information.
This section provides an overview of the document organization and
contents. The key points and format of the material presented in the
remaining sections of this document are as follows.
Section 2.0 contains definitions and discussions of PM-10 categories and
presents a brief overview of the regulatory requirements and milestones for
PM-10 emission inventories under the CAA. State personnel should reference
the General Preamble for specific language on the regulatory requirements and
should consult the appropriate Regional Office of EPA to identify any guidance
issued subsequent to the General Preamble.
The specific details of inventory development and compilation
requirements are the focus of Section 3.0. In this section, requirements for
Inventory Preparation Plans (IPPs) are described. The major discussion in
this section focuses on the components of the base year inventory, while brief
discussion is also included regarding other types of inventories — modeling,
and periodic [i.e., reasonable further progress (RFP) and maintenance plan]
inventories. Presentation of the base year inventory includes an overview of
the applicable source categories to be included — point, area, and mobile
sources. In addition, requirements regarding the temporal resolution of the
inventory and adjustments to the base year inventory are also presented in
Section 3.0.
Section 4.0 discusses documentation/data management and reporting
requirements for SIP inventories prepared in response to the CAA. Section 5.0
provides the references for this document. Appendix A provides a checklist
for IPPs.
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SECTION 2.O
DEFINITIONS AND REGULATORY REQUIREMENTS
This section of this document summarizes information in the General
Preamble dealing with the regulatory requirements for designations and
classifications, nonattainment area boundaries, and SIP submittal timelines.
State personnel should reference the General Preamble for specific language on
the regulatory, requirements and should consult the appropriate Regional Office
of EPA to identify any guidance issued subsequent to the General Preamble.
2.1 Definitions of PM-10
PM-10 is defined as particulate matter that measures less than or equal
to 10 micrometers in aerodynamic mass median diameter. PM-10 may be directly
emitted into the atmosphere from a source or it may be formed in the
atmosphere as a result of condensation or chemical reactions of other
pollutants.
3.1.1 Primary PM-1O
Primary particulate matter is broadly defined as particles that enter
the atmosphere as a direct emission from a stack or an open source. It is not
formed due to a chemical reaction that occurs once the matter has been
emitted. The focus of emission inventories for PM-10 nonattainment areas
should be on primary PM-10 emissions. However, in some areas secondary and
condensible PM-10 account for a significant portion of PM-10 in the atmosphere
and, therefore, these would need to be included in the emission inventory.
3.1.2 Condensible PM-10
Condensible particulate matter (or condensed particulate matter, as it
is synonymously described) can be broadly defined as material that is not
particulate matter at stack conditions but which condenses and/or reacts (upon
cooling and dilution in the ambient air) to form particulate matter
immediately after discharge from the stack. Condensible particle matter forms
in a few seconds in the stack exhaust due primarily to immediate cooling and
air dilution. Condensible particulate matter is of potential importance
because it usually is quite fine and thus falls primarily within the PM-10
fraction. As a consequence, condensible particulate matter should always be
included in the emission inventory.
2.1.3 Secondary PM-1O (PM-1O Precursors)
Secondary particulate matter can be broadly defined as particles that
form through chemical reactions in the ambient air well after dilution and
condensation have occurred (i.e., usually at some distance downwind from the
emission point). An example of this phenomenon is the formation of sulfate
Particles in a plume from the oxidation of sulfur dioxide by one of several
atmospheric transformation mechanisms. Generally, secondary particulate
matter can be distinguished from condensible particulate matter by the time
and/or distance downwind from the stack required for formation. Precursor
emissions contributing to secondary particulate matter should not be included
in the PM-10 inventory except where EPA and the State determines that the
sources of PM-10 precursors contribute significantly to PM-10 levels which
exceed the PM-10 NAAQS in the area. This determination will be based upon air
quality analysis in which States assess the contribution of precursors.
If precursors contribute significantly to nonattainment. States will
need to consider both the source-receptor relationship and the significance of
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?eaSI?~~ Cont"but:Lons to overall nonattainment. In making a determination
regarding significance, EPA will rely in part on the technical information
contained in the State's submittal which could include .filter analyses an
assessment of the relative contribution of precursors to overall
^^mf^"11"511*1' Snd the Date's Reasonable Available Control Technologies
(RACT)/Reasonably Available Control Measures (RACM) strategy States are
encouraged to submit additional material for consideration, since all findings
will be made on a case-by-case basis. nnaings
2.2
Summary of Regulatory Requirements
State personnel should refer to the General Preamble for the
Implementation of Title I of the CAA of 1990 for specific language on the
re^ui^ementf for moderate nonattainment areas according to the CAA
secndr PM 0 addresses ^sues concerning condsible and
ProSS?^ Z'f StatSS ^ould contact the Sulfur Dioxide/Particulate Matter
Programs Branch for case-by-case determinations .
submifc a SIP which will demonstrate attainment
-f n rSa des£9nated nonattainment and classified as
™S?™°r«- * nr^ ^ CAA' Wlthin 18 m°nths after beinS designated
nonattainment for PM-10. The Sulfur Dioxide/Particulate Matter Programs
?retSl^?^Pa^ a Staff W°rk product as a supplement for the General
1993a) Whlch addresses serious nonattainment area requirements (U.S. EPA
3. 2.1 Wonattairunsnt naaJ.gnatJ.oas
m,S
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to the boundaries. A defensible^rationale must be submitted to EPA to justify
an area's designation and boundaries. The Boundaries designated by the
Governor of a State will be subject to final approval by EPA.
3.3.4 SXF Rayulx-ement; SutimlfcfcaJ T±mol±naB
Tables 2.1 and 2.2 present the schedule and due dates for SIPs for
moderate and serious areas, respectively. The moderate area SIPs containing a
New Source Review permit program revision, attainment demonstration, and RACM
are due 18 months.after being designated nonattainment. For serious areas, a
SIP containing Best Available Control Measures (BACM) is due 18 months after
reclassification. Implementation of either RACM or BACM (dependent upon the
area's designation) is to be completed within 4 years after designation.1
2.3.5 Attainment Demonstration
Section 189(a)(1)(B) provides that States with moderate PM-10
nonattainment areas must submit a demonstration (including air quality
modeling) showing either attainment by the applicable attainment date or that
attainment by the applicable date is impracticable. The attainment
demonstration projects how the area will come into attainment (or will fail to
attain) with the NAAQS based on air quality modeling with forecasted
emissions. The SIP must contain the emissions forecasts used in the air
quality modeling attainment demonstration. In general, attainment
demonstrations for these areas will be reviewed in accordance with the general
guidance addressing PM-10 [PM-10 SIP Development Guideline, (U.S. EPA, 1987);
PM-10 Moderate Area SIP Guidance: Final Staff Work Product (U.S. EPA, I99la) ,-
and PM-10 Serious Area SIP Guidance: Final Staff Work Product (U.S. EPA,
1993a)] and any future applicable EPA guidance or regulations. For current
compilation of available policy and guidance for the PM-10 program, the reader
should refer to PM-10 Guideline Document and Appendix (U.S. EPA,, I993b).
RACM and BACM refer to control measures for both point and area sources
in moderate and serious PM-10 nonattainment areas, respectively. RACT
and best available control technologies (BACT) refer to control measures
for only point sources in moderate and serious PM-10 nonattainment areas,
respectively. See the General Preamble for further discussion of this
terminology.
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Table 2.1 Moderate Nonattainmont Area Due Dates
Event
Months following
designation
Designation as nonattainment Q
Classification (moderate by operation of law) 0
Inventory Preparation Plan (IPP) 3
Draft Inventory 12
SIP due containing: lg
a) New Source Review permit program
b) attainment demonstration that includes
1) air quality modeling
2) base year actual emissions inventory
3) modeling inventory (projected
allowables at attainment [i.e., at 72
months])
4) inventory showing projected allowables
at 48 months when RACM/RACT is
implemented
c) RACM/RACT implementation program
d) Quantitative milestones (RFP)
e) PM-10 precursors assessment
Decision by EPA whether to reclassify area as serious for 36
FTD attainment (18 months from submission)
Implementation of control strategies, including RACM/RACT 43
RFP Milestone due date 54
Determination by EPA that State's RFP milestone is met 57
SIP revision due for failure to report RFP milestone or 63
determination by EPA that milestone was not met
Attainment (as expeditiously as possible but no later ' 72
than)
Redesignation to serious if in violation of NAAQS after 72-78
attainment date
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Table 2.2 Serious Nonattainment Area Due Dates
Event Months following-
__ reclassification
Reclassification 0
Inventory Preparation Plan (IPP) 3
Draft Inventory (The base year for FTA will be the actual 12
emissions for the year the area should have attained; for
FTD areas the base year inventory will become the modeling
emission inventory projected to the attainment year)
RFP Milestone due date *
Determination by EPA that State's RFP demonstration is **
adequate
BACM SIP due containing: 18
a) BACM/BACT implementation program (schedule
for implementation)
b) PM-10 precursors assessment
c) base year inventory
SIP revision due for failure to report RFP milestone or ***
determination by EPA that milestone was not met
Full SIP containing BACM SIP information and: 48
a) attainment demonstration with air quality
modeling
b) additional BACM/BACT requirements
Implementation of BACM/BACT 48
RFP Milestone is due t
Determination by EPA that State's RFP milestone is met ft
SIP revision due for failure to report RFP milestone or ttt
determination by EPA that milestone was not met
RFP Milestone is due -j-
Determination by EPA that State's RFP milestone is met ft
SIP revision due for failure to report RFP milestone or ttt
determination by EPA that milestone was not met
Attainment (as expeditiously as possible but no later 120
than)
* 54 months after designation as a moderate nonattainment area for areas
that FTD; 90 months after designation as a moderate nonattainment area
for areas that FTA
** 3 months following *
*** 6 months following **
t 3 years following previous RFP milestone due date
tt 3 months following t
ttt 6 months following tt
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SKCTION 3.0
EMISSION INVENTORY
3.1 Summary of Inventory Types
For PM-10 nonattainment areas, there are three (3) basic kinds of
inventories that States may need to develop under the CAA. These include base
year inventories, periodic inventories, and modeling inventories. The
information presented below represents EPA's view of accurate, complete, and
approvable inventory submittals.
The base year inventory is the primary inventory from which all other
inventories are derived. All inventories shall be consistent with data
provided in the base year inventory. Section 172 (c) (3) of the CAA requires
States to ensure that this inventory is comprehensive, accurate, and current
for all actual emissions of PM-10. The base year inventory must include
emissions from all point, area, and mobile sources.
For moderate nonattainment areas, the SIP base year emission inventory
must be based on actual emissions. For moderate and serious nonattainment
areas, the base year for emission inventories must be consistent with the
3 years of data which were necessary to designate the area as nonattainment.
The base year inventory is the inventory of actual emissions for the chosen
base year. The base year inventory should reflect the last year of the
3 years used to determine nonattainment.
Should a moderate nonattainment area "fail to demonstrate" (FTD)
attainment, then the area will be reclassified as serious. This will require
submission of a serious area base year emission inventory which is due
18 months following reclassification (see Table 2.2). The serious area base
year emission inventory also serves as the BACM SIP emission inventory.
Moderate areas that FTD attainment and have been reclassified can use the
moderate area attainment demonstration emission inventory (see modeling
inventories below) as a starting point for their serious area base year/BACM
emission inventory, but it must include any changes (such as shutdowns or
emission factor changes) that have occurred since the moderate area SIP was
submitted. This means that the year that would have been the attainment year
under the moderate area provisions becomes the base year for the serious area
SIP inventory. It also assumes that the moderate area SIP regulations (i.e.,
RACM) will be implemented, however, should the area be redesignated as
serious,_ BACM requirements will need to be implemented. BACM implementation
may require additional control measures or technologies on processes already
controlled under the RACM implementation. All of the above information
pertaining to serious areas assumes that the moderate area SIP emission
inventory was adequate and that if it was not, it was returned to the State as
part of the completeness and SIP review process that is part of the moderate
area requirements.
Should an area classified as serious "fail to attain" (FTA), then those
areas must reinventory the actual emissions at the time they should have
attained. Such an inventory would be due 18 months after determining that the
area FTA.
Modeling inventories may be used as a tool for a number of purposes
including model performance evaluations, projection to future years,
evaluation of the impact of rulemaking, evaluation of control measures and
technology, receptor modeling reconciliation, and determination of design
concentrations. One of the major roles for modeling inventories will be for
use in the attainment demonstration. Modeling inventories can be based upon
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either allowable or actual emissions, depending on the purpose of the
modeling. For instance, modeling inventories should be based on the actual
daily emissions for model performance evaluation. For control measure
evaluations and the attainment demonstration, the modeling emission inventory
consists of allowable emissions for the base year and projected allowables for
the attainment year. Modeling inventories also have additional data
requirements (e.g., stack parameters). The Guideline on Air Quality Models
(Revised) should be consulted to determine the additional data needed (U S
EPA, 1986).
For moderate areas, an attainment demonstration emission inventory that
provides a projection of allowable emissions to the year following full
implementation of the moderate area SIP is required. The year of record for
this inventory would be the seventh year following designation as a moderate
nonattainment area.
For serious areas, the attainment demonstration emission inventory
provides a projection of allowable emissions for the year following
implementation of the serious area SIP. ' This inventory is due with the
serious area attainment demonstration SIP (see Table 2.2)
The CAA states that the emission inventories may be periodically updated
as deemed necessary by the Administrator. A periodic inventory may be the
consequence of RFP requirements, a maintenance plan for an attainment area, or
for other reasons deemed necessary by EPA. The PM-10 program will not
arbitrarily require inventories every 3 years. It will rely on "event"
oriented periodic emission inventories and, therefore, will be decided on a
case-by-case basis. Guidance from EPA for States related to requirements and
events that will trigger development of a PM-10 emission inventory is
forthcoming. Questions related to this topic should be addressed to the
Office of Air Quality Planning and Standards, Air Quality Management Division,
Sulfur Dioxide/Particulate Hatter Programs Branch.
As a result of the RFP requirement, a detailed compliance schedule or
inventory (RFP projection inventory) may be required. If an RFP projection
inventory were to be used by the States for demonstrating that the emission
reductions will be achieved, the following applies.
For moderate nonattainment areas, the RFP projection inventory
(i.e., RFP milestone) will be due 3 years after the SIP inventory
submittal (see Table 2.1). The RFP projection inventory is to be based
on allowable emissions. It should be based on the base year inventory
but should incorporate any significant changes including rule
effectiveness (RE) and RACM implementation.
It should be noted that only one RFP milestone will be required
for^moderate nonattainment areas assuming that they are in attainment on
their required attainment date. The reason for this can be ascertained
by referring to Table 2.1. The RFP milestone is due 54 months following
designation as a moderate nonattainment area. The next RFP
demonstration would be due 3 years later (i.e., 90 months following
designation), however, attainment is scheduled for 72 months. Should
the moderate area fail to reach attainment at the scheduled time and be
reclassified as a serious nonattainment area, then the RFP schedule
.continues from the original moderate area schedule. Thus, an RFP
projection inventory for a serious nonattainment area could be required
at the same time as the BACM SIP inventory is due if the area is
reclassified as serious 72 months after being designated as a moderate
nonattainment area.
Another circumstance which would trigger a periodic inventory would be
™, f* *rSa becomes.eliSTible for redesignation. Maintenance plan emission
inventories are required once an area has reached attainment and desires to be
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redesignated to and continue as an attainment area. An unclassified area
requesting redesignation to attainment iraist also submit a maintenance plan
emission inventory.
The maintenance plan emission inventory should include an
attainment inventory as well as a maintenance inventory. The attainment
inventory should include actual emissions at the time of attainment or
at the time of the request for redesignation as attainment. The
maintenance inventory should present projections of allowable emissions
for the ninth year following reclassification to attainment. Another
periodic inventory may be required within the 9-year time frame for
failure to maintain or for a SIP call. States should refer to the
redesignation policy for additional requirements for redesignations.
3.2 Temporal Resolution of Inventory
States will have to model short-term (daily) and long-term (annual) air
quality for PM-10 to assure that both standards will be protected, even if air
quality measurements show exceedances for only one time period.
Some areas may experience seasonal emissions increases which largely
cause their nonattainment problem. If the problem involves only one season
(e.g., summer wind blown dust), then a seasonal inventory should be prepared
in addition to an annual inventory. In dual season situations (e.g., summer
wind blown dust and winter wood burning) , an emission inventory should be done
for each season separately, and the results combined for the analysis of the
annual standard. The reporting convention for seasonal emissions must be
consistent for point, area, mobile, and natural sources.
3.3 Inventory Preparation Plan (IPP)
For base year inventories, the EPA requires States to prepare a brief
IPP that_specifies how they intend to develop, document, and submit their
inventories. The plans provide States the opportunity to notify the EPA how
they plan to compile the required inventories and to allow the EPA to provide
important feedback to prevent the use of approaches that are not consistent
with the^ EPA requirements. With the use of IPPs, the EPA can help guide the
preparation of required inventories and ensure that emission estimates are of
high quality and are consistent with the PM-10 emission inventory
requirements. States shall submit IPPs to the EPA Regional Offices and the
EPA headquarters according to the schedule shown in Table 2.1.
In addition to technical data, the IPPs should contain a schedule
showing when the State plans to submit the draft and final inventory to the
EPA. If the State plans to submit an inventory in component pieces (e.g.,
point source component, area source component, etc.), the IPP must clearly
make this distinction and indicate a draft and final submittal date for each
component. The final submittal dates shall be consistent with the PM-10
emission inventory requirements. A complete draft inventory is required to be
submitted to the EPA Regional Offices and the EPA headquarters within
12 months after the date that an area is designated nonattainment. The IPP
shall also explicitly detail the year chosen as the base year for the
inventory, and explain the basis for the selection. Further details on the
base year inventory are found in Section 3.4.
In addition to the IPP submittal to the EPA Regional Office, the State
shall also submit a copy of the IPP and any correspondence relating to the IPP
to the EPA headquarters. The copy should be addressed to: Chief, Inventory
Guidance and Evaluation Section, Emission Inventory Branch (MD-14), Technical
Support Division, U.S. EPA, Research Triangle Park, NC 27711.
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States must prepare an IPP for each nonattairunent area for which a base
year inventory is required by the CAA, to the extent that different approaches
will be used. If a. State has multiple nonattaintnent areas but plans to use
the same overall approach for each, the State may submit a single IPP that
details that approach and the areas to which it will apply. In detailing the
approach utilized for developing the inventory for the area(s) , the IPP must
clearly delineate that the IPP was prepared for the purposes of a PM-10 SIP,
must define the nonattainment area(s) addressed by the inventory and the
nonattainment classification of the areas. In addition, the IPP should
identify the persons responsible for the inventory, the contents and
organization of the report, submission schedules, any modifications to the
approach used for multiple area submittals, the source categories inventoried,
and a summary of the emissions documentation information for each major
inventory component (i.e., point, area, and mobile sources).
States must be aware that the EPA considers submittal of an IPP crucial
to an approvable SIP inventory. By approving an IPP, the EPA will accept the
intended approach for inventory compilation. The EPA's approval of an IPP
does not, however, signify that the EPA unconditionally accepts all of the
information to be contained in the actual inventory. That inventory will be
reviewed separately and on its own merits regardless of how well the IPP was
assembled.
3.3.3. IPP Point Source Re
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the PARTS emissions model was not utilize;! or was not available prior to the
inventory submittal deadline, the basis f*br the alternative estimation
methods, any key modeling assumptions, and the vehicle classes covered must be
discussed in the IPP.
The PARTS model does not address emissions for nonroad mobile sources
(e.g., construction, farm, industrial, and lawn and garden equipment;
motorcycles; and snowmobiles). Methodologies for estimating emissions from
these sources are documented in Nonroad Engine and Vehicle Emission Study —
Report (U.S. EPA, 1991b).
3.3.3 Other IFF Ra
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Table 3.1 Basic Outline o£ an Inventory Preparation Plan
Introduction
• 'Define the boundaries of the nonattainment area.
• Describe the basis for the inventory (i.e., previous efforts that
are viable and related); indicate the starting point.
• Define how the plan is structured and what it contains.
Specify who is responsible for the inventory and who is actually
compiling it (air agency, consultants, etc.).
Point Source Approach
How will sources be identified and located?
What categories will be addressed and why?
What categories will be excluded and why?
Define the use of existing data sources.
Identify data collection methods to be used.
Provide the basis for activity level data and emission estimates
Provide the basis for control efficiencies.
Discuss the application of RE.;
Indicate the basis for RE levels.
Area and Mobile Sources Approach
• What categories will be addressed and why?
• What categories will be excluded and why?
• What estimation methods will be used (e.g. AP-42, Emission
Inventory Procedures Document, site specific surveys, etc.)?
• What methods will be used for collecting activity/commodity level
data?
• Provide specification of the mobile source emissions model used.1
• Discuss application of RE.
Provide basis for RE levels.
Documentation Approach
• Describe written presentation and documentation.
Describe computerized compilations and documentation.
• Describe the data required to be submitted to EPA (as defined by
the EPA Regional Office) and the computerized format that will be
used to submit the data.
QA Plan
Describe the QA program.
How_will the QA program affect and benefit the inventory.
Verify adherence to previously issued QA guidance (U S EPA
1988b). . '
0 ^ni;ssions factors for mobile sources should be obtained by running the
R1OCL6 J. •
3.4.1 AIRS CoxnpatiijJe
( The official repository for all emission inventory data will be
designated by the EPA Regional Office. One of the options that may be
»T«9nat!}d ^ the Regi°nal Offices is to have the official data record in
T^roo* £ " option is selected, all SIP data must be loaded directly into
AIRS or submitted in an AIRS compatible format.
= Emission Inventory Branch (inventory requirements) and National Air Data
Branch (data system enhancements, schedules, and availability) can provide
coordination with State and local agencies during the inventory preparation
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process for both batch transactions to the AIRS Repository and on-line
interactive submittal of APS and Area and Mobile Source Subsystem (AMS) SIP
inventory data. As the PM-10 program defines data-system needs (now and in
-,fU^Ure> system will be enhanced to meet these needs. Therefore it
would be appropriate for State and local agencies to coordinate with EPA
regarding availability of new and scheduled enhancements to AIRS during the
preparation of IPPs and prior to actual inventory data entry.
3.4.3 Geographic Cove.
>ragre
The geographic boundaries of the inventory area shall be determined by
the _ area officially designated nonattainment . At a minimum, this area shall
be included in the emission inventory. However, the attainment demonstration
developed as part of the SIP inventory process must include air quality
modeling. As a consequence, sources contributing significant fractions to the
ambient concentrations must also be included. This may necessitate the
inclusion of sources outside the boundary of the nonattainment area in the
emission inventory. The nonattainment area coupled with any other areas
containing sources that need to be included in the attainment demonstration
modeling effort are considered the modeling domain. Guidance on the
oriUPS=7y?rMa5e7an%0t^er^°del:Lng criteria c«n be found in the Guideline
on Air Quality Models (Revised) (u.s EPA, 1986). Current code for EPA
approved air quality models are available through the EPA's Office of Air
SUa , T ~lanning and Sfcandar<3s SCRAM (Support Center for Regulatory Air
Models) Bulletin Board System and the related programs can be downloaded to a
personal computer diskette. Information is also included with regard to
upgrades to various models.
«- . ,The, ex1pent of the sources to be included in the emission inventory
outside the immediate nonattainment area must be determined by the State The
decision is based on the types of sources in upwind areas and on their '
potential impact inside the nonattainment area. However, documentation of
rationale used in determining which sources to include or exclude must be
provided as part of the emission inventory submittal. In addition, a brief
discussion of this rationale should be included in the IPP. Coordination
staf^wieff^^^i^en^^y•PreParati0n Staff ^'^ a^ quality modeling
staff will facilitate efficient inventory preparation and submittal.
3.4.3 Applicable Source Catesrord.es
Base year emission inventories are required to include all types of
™°bile sources. The particulate matter emission
±f SOUrCe ^egories ^ould be included
n tne i™ egores ou e nclu
and £o42 Vent°ry- F?r ?olnt sources, a list of source classification codes
and corresponding emission factors can be obtained from the program, FIRE
forCInveSf^rati0S *e*ri?val System) , by accessing the CHIEF (Clearinghouse
r Fsr s^^"*"™-^-^ ^^^^"^-"^sis
the TTN training manual by accessing the AIRS Bulletin Board System on
3.4.3.1 PojCnt Sources
SOUr°e? a« physical emission points or processes usually within a
pollutanfc emissions. PM-10 point sources generally refer
r stacks for which individual records are collected
size ,, ?lassifi<=ati°n affects the facility emissions
all sta??o included in the base year inventory. For moderate areas,
all stationary sources which emit directly, or have the potential to emit
(i.e., allowable emissions), 100 tons per year or more of PM-10 must be-
13
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included in the inventory. These sources are referred to as "major stationary
sources" in Section 302(j) of the CAA.
For serious areas, all stationary sources or groups of stationary
sources located within a contiguous area and under common control that emit or
have the potential to emit at least 70 tons per year of PM-10 must be
included. (Section 189 (b) (3) )
The EPA also believes that the States ' inventory may need to go beyond
those sources having a tons per year limit to include other sources in the
area that are reasonable to control.
3.4.3.3 Aram axuSL Mobile Sources
Area sources are generally defined as an aggregation of all sources not
defined as point sources in a specific geographic area. Area sources include
fugitive dust sources; mobile sources; and stationary sources that are too
small, difficult, or numerous to account for individually as point sources.
Area sources also include residential wood combustion sources, and prescribed,
silvicultural and agricultural burning sources .
^ EPA issued technical information guidance documents on BACMs for
fugitive dust; residential wood combus£ion; and prescribed, silvicultural and
agricultural burning sources (U.S. EPA, 1988, 1989a, and 1992, respectively) .
Fugitive dust is particulate matter suspended in the air either by mechanical
disturbance of the surface material or by wind action blowing across the
surface. Mechanical disturbance includes resuspension of particles from
vehicles traveling over roadways, parking lots, and other open areas. Wind
action includes dust blown off disturbed open areas . Process fugitive
emissions should be included in the point source inventory. Residential wood
combustion includes wood smoke from residential wood stoves and fireplaces.
Residential wood combustion is a significant source of PM-10 particularly in
nonattainment areas in the western United States. Prescribed burning
generally describes burning on lands that are being managed. This includes
both planned ignition and prescribed natural fire, however, it does not
include forest and wildfires. If a State excludes any of the emission sources
addressed in the three documents from its emission inventory, it must provide
documentation on why the source ( s ) were excluded .
The EPA has developed the Parts model for estimating PM-10 emissions
from mobile sources. The model can be used to estimate total particulate
matter emissions as well as particulate matter fractions ranging from 1.0 to
10 micrometers. For gasoline engines, total exhaust particulate matter
includes direct sulfate (exhausted as sulfuric acid) and lead emissions. For
diesel engines, total exhaust particulate matter also includes emissions for
soluble organic fraction and the remaining carbon portion. Each of these
emission components can also be estimated individually. The Parts model can
also be used to estimate the following:
Particulate matter from brake and tire wear,
• Gaseous sulfur dioxide exhaust emissions,
Indirect sulfate emissions formed later in the atmosphere
associated with sulfur dioxide exhaust emissions,
Fugitive dust emissions from paved and unpaved roads, and
• Idle-speed exhaust emissions.
The Parts model and user's manual may be obtained from EPA's Bulletin
Board System for the Office of Mobile Sources on the TTN.
14
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3.4.4 Rula E££ectz±vanaBa
Rule effectiveness, currently not required, may be required by EPA at a
later date. The feasibility of and guidance on using RE are being studied by
EPA at this time. Until guidance is issued by EPA, RE may be considered by
the State at its option. Should the State exercise this option, RE should be
applied to all sources that are affected by a regulation and for which
emissions are determined by means of emission factors and control efficiency
estimates. No RE factor is needed in cases where no control is applied or
there is no applicable regulation.
Past inventories have assumed that regulatory programs would be
implemented with full effectiveness, achieving all of the required or intended
emission reductions and maintaining that level over time. However, experience
has shown regulatory programs to be less than 100 percent effective for most
source categories in most areas of the country. The concept of applying RE in
a SIP emission inventory has evolved from this observation. In short, RE
reflects the actual ability of a regulatory program to reduce emissions from
all sources at all times that are subject to a specific regulation.
Several factors should be taken into account when estimating the
effectiveness of a regulatory program. These include: (1) the nature of the
regulation (e.g., whether any ambiguities or deficiencies exist, whether test
methods and/or recordkeeping requirements are prescribed) ,- (2) the nature of
the compliance procedures (e.g., taking into account the long-term performance
capabilities of the control); (3) the performance of the source in maintaining
compliance over time (e.g., training programs, maintenance schedule,
recordkeeping practices); and (4) the performance of the implementing agency
in assuring compliance (e.g., training programs, inspection schedules, follow-
up procedures).
For base year PM-10 inventories under the CAA, the EPA will allow the
use of reasonable default values provided the values are -justified bv the
State. Justification may include a RE study performed according to the March
24, 1988 National Protocol. The RE factor shall be applied along with the
estimated control efficiency in the calculation of emissions from a source.
An example of the application is as follows:
Uncontrolled emissions =
Estimated control efficiency =
RE =
Emissions after control =
50 Ibs/day
90%
75%
50 [1 - (0.90)(0.75)]
50 (1 - (0.68]
= 16.25 Ibs/day
Thus, the application of RE results in a total emission reduction of
68 percent.
3.5
Updating1 Inventories
Updating of prior year inventories to the base year inventory will, in
general, not be acceptable. A new inventory for the appropriate base year
should be prepared. A State that believes that a special situation exists in
which. EPA should allow an existing inventory to he updated should apply to the
appropriate Regional Office for a written exception.
3.6
Adjustment of Base Year Inventory (Backcasting)
The EPA recognizes that adjustment of the base year inventory, or
backcasting, may be necessary. Backcasting is the recalculation of a previous
inventory due to changes in the parameters used to calculate the emissions
initially. Situations where backcasting may be invoked include changes in
emission factors, changes in calculational methods, or insufficient data for
15
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the base year that may be more complete in a. previous year. States may make
adjustments to ba.ua year inventories only with tha approval of the EPA.
3.7 RP"P Projection Inventories
The RFP inventory should "track" all sources that are subject to
regulations for the nonattainment area, whether or not they are actually in
the area. The inventory must be able to answer the question: "Is the State
achieving the agreed emission reductions specified in the SIP at any
particular time?" The basis for the reductions required will be the
attainment demonstration. Since there are no specific level of reductions
required under the CAA for PM-10 as there are for volatile organic compounds
the level of reductions required will be determined by the RACM requirements
and what is necessary to demonstrate attainment of the PM-10 NAAQS by the
appropriate attainment date.
RFP projection inventories are to be projections of allowable emissions.
In addition, the RFP projection inventory should include the effects of
control strategy implementation (such as RACM or BACM) . Emission reductions
determined from the RFP projection inventories are to be based upon the base
year inventory which uses actual emissions. It is important to remember that
attainment will be based upon a target level of emissions (i.e., an amount of
emissions required to meet attainment) and that backcasting may necessitate an
adjustment of the target level of emissions. Some air planning agencies may
toe used to thinking in terms of the emissions reduction required relative to a
current control strategy projection, rather than a target level of emissions.
_ Projections of attainment year emissions would be used to calculate the
required emissions reductions expressed on such a basis, by simply taking the
difference between the attainment year projection inventory (without controls
applied) and the attainment year target level of emissions. However, States
that choose this approach should be aware that the attainment year target
level is dependent only on the base year inventory, whereas the calculation of
an emission reduction required relative to the current control strategy
projection depends on the accuracy of the attainment year projection, which in
turn depends on the estimate of future growth in activities. The assessment
of whether an area has met the emission reduction requirement will be based on
whether the area is at or below the target level of emissions and not whether
the area has achieved a certain actual emission reduction relative to having
maintained the current control strategy.
3.8 Modeling' Inventories
Modeling inventories may require inclusion of additional sources outside
the nonattainment area, as defined by the modeling domain. For this reason
.
domain should be defined as early as possible so that emission
data for point, area, mobile, and natural sources can be gathered for the
entire modeling domain as part of the base year inventory preparation process.
3.8,1 For Mai ti — soturera
•^oa*^ Accordin9- to the Guideline on Air Quality Models (Revised) (U.S. EPA,
1986) , all sources expected to contribute significantly to the ambient
concentrations in the nonattainment area or near the critical receptor for
16
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Tabl* 3.2 Model Emission Input: Data for Point: Sources *
Emission Limit
(#/MMBtu)**
Operating Level
(MMBtu/Hr)** '
Operating Factor
(e.g. Hr/Yr, Hr/day)
For Stationary Point Source(s) Subject to SIP Emission Limit(s) Evaluation for Compliance with
Ambient Standards (Including Areawide Demonstrations)
Averaging time
Annual & quarterly
Short-term
Maximum allowable
emission limit or
federally
enforceable permit
limit.
Maximum allowable
emission limit or
federally
enforceable permit
limit.
Actual or design
capacity (whichever
is greater), or
federally
enforceable permit
condition.
Actual or design
capacity (whichever
is greater) , or
federally
enforceable permit
condition.» * « *
Actual operating
factor averaged over
most recent
2 years.***
Continuous
operation, i.e., all
hours of each time
period under
consideration (for
all hours of the
meteorological data
base).*****
For Nearby Background
Source(s)
Same input requirements as for stationary point source(s) above.
For Other Background
Source(s)
If modeled (see Section 9.2.3), input data requirements are defined
below.
Averaging time Annual &
quarterly
Maximum allowable
emission limit or
federally
enforceable permit
limit.
Annual level when
actually operating,
averaged over the
most recent
2 years.***
Actual operating
factor averaged over
most recent 2
years.* * *
Short-term
Maximum allowable
emission limit or
federally
enforceable permit
limit.
Annual level when
actually operating,
averaged over the
most recent
2 years.***
Continuous
operation, i.e., all
hours of each time
period under
consideration (for
all hours of the
meteorological data
base).*****
The model input data requirements shown on this table apply to stationary source control
strategies for STATE IMPLEMENTATION PLANS. For purposes of emissions trading, new
source review, or prevention of significant deterioration, other model input criteria
may apply. Refer to the policy and guidance for these programs to establish the input
data.
Terminology applicable to fuel burning sources; analogous terminology, e.g.,
#/throughput may be used for other types of sources.
Unless it is determined that this period is not representative.
Operating levels such as 50 percent and 75 percent of capacity should also be modeled to
determine the load causing the highest concentration.
If operation does not occur for all hours of the time period of consideration (e.g.,
3 or 24 hours) and the source operation is constrained by a federally enforceable permit
condition, an appropriate adjustment to the modeled emission rate may be made (e.g., if
operation is only 8:00 a.m. to 4:00 p.m. each day, only these hours will be modeled with
emissions from the source. Modeled emissions should not be averaged across nonoperatinq-
time periods). .
17
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emission limit(s) should be explicitly modeled. For evaluation for compliance
with the short term and annual ambient standards, the nearby sources should be
modeled using the emission input data shown in Table 3.2. The number of such
sources is expected to be small except in unusual situations. The nearby
source inventory should be determined in consultation with the reviewing
authority. It is envisioned that the nearby sources and the sources under
consideration will be evaluated together using an appropriate model [typically
selected from Appendix A of the Guideline on Air Quality Models (Revised)
(U.S. EPA, 1986)].
The impact of the nearby sources should be examined at locations where
interactions from several sources (plus natural background) can occur
Significant locations include: (1) the critical receptor(s) identified as
exceeding the NAAQS; (2) areas having a large number of significant sources in
a small area; (3) areas close to major sources; and (4) areas with peculiar
topography and/or meteorology that may result in enhanced impacts from several
sources. These locations may be identified through trial and error analyses
or by using screening model approaches.
3.8.2 Background Sources
Other sources not expected to contribute significantly to the ambient
concentration may include minor sources and distant major sources That
portion of the background attributable to these sources should be determined
by application of a model using Table 3.2 or by the following procedure.
If there are no ambient PM-10 monitoring stations in the vicinity
of the source, a "regional site" may be used to determine the
background. A "regional site" is one that is not influenced by major
sources.
Alternatively, air quality data collected in the vicinity of the
source can be used to determine the background concentration. The
average annual background concentration can be calculated by excluding
those values when the source impacts the monitoring site.
Line sources commonly included in emission inventories are
roadways and streets along which there are well-defined movements of
motor vehicles, but they may be lines of stacks such as in aluminum
refineries. Area and volume sources are often collections of a
multitude of minor sources with individually small emissions that are
impractical to consider as separate point or line sources. Large area
sources are typically treated as a grid network of square areas, with
pollutant emissions distributed uniformly within each grid square.
After determining emissions for background sources, they may be entered
into the data system. For example, if AIRS is the data system and the source
is large_enough to be tracked as a facility, data for the source could be
entered in AFS._ To enter data in AMS, the activity or emission values must be
summed, or partitioned, to fit the geographic units used. For example,
highway data are not entered in AMS as "line sources." Highway data for the
appropriate vehicle-type and road-type categories are entered for the County
(if the County as a whole is the geographic unit being tracked)
18
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SECTION 4.0
DOCUMENTATION/DATA MANAGEMENT AND REPORTING OF THE INVENTORY
4.1 Documentation
. Base year emission inventory information under the CAA shall be provided.
to EPA in written format. The written presentation must contain documentation
sufficient for the Agency to reproduce the emission estimates that are
submitted in the inventory. Written documentation requirements are summarized
in this section.
Under the CAA, EPA is requiring that States prepare written inventory
documentation reports according to a more standardized set of guidelines.
Although the organization of the inventory report is somewhat flexible.
Table 4.1 presents EPA's recommended outline for this report. Inventory
reports that are not prepared according to the outline will be harder for EPA
to review and are more likely to be deemed unacceptable by the Agency. The
EPA's primary interest is that all inventories address the crucial elements
inherent in a good inventory and provide summary data and documentation that
allow the quality of the inventory effort to be effectively judged.
Inventories not meeting the minimum data reporting and documentation standards
established in this discussion shall be deemed unacceptable and returned to
the States for modification before any further technical quality review will
be performed.
The introduction to an inventory report shall contain a description of
the nonattainment area that has been inventoried, a listing of the
counties/areas covered, a map of the area, an identification of who prepared
the inventory and the respective contacts for major inventory components, a
description of major inventory problems or deficiencies, and a discussion of
how'the remainder of the report is organized. After the introduction, the
report must contain a thorough summary of the emissions data by source type
(point, area, mobile, and natural) and geographic area. At a minimum, the
report must include summary emissions tables by source type, summary emissions
tables by county/area, and graphics illustrating the contribution to areawide
emissions by source type. If PM-10 precursor emissions are reported, they
should be presented in separate tables from primary and condensible PM-10
emissions. States are required to report emissions data on an annual basis.
Separate discussions must be presented to describe inventory development
procedures and results for point, area, mobile, and natural sources. In
addition to the specific parameters germane to these source types, each source
type discussion needs to explain how emissions were temporally allocated to a
daily basis and how RE was incorporated into each emission estimate.
The point source discussion shall include a description of how the list
of sources to be inventoried was identified. The report must also state if
any source categories were not considered in the inventory and why. The
discussion shall address the issue of completeness of source coverage. Data
collection methods and tools shall be thoroughly explained and documented.
All information surveys that may have been conducted must be discussed and the
results provided (probably in an appendix). All sources inventoried shall be
listed according to their source category type (e.g., refinery, plant, etc.).
The methodology by which activity levels and emissions were determined for
each plant or source category (when applicable) shall be succinctly but
explicitly explained. Large volumes of detailed data shall be put into
appendices but clearly linked to the text discussion in terms of how they were
19
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Table 4.1 Outline for EPA Recommended Format/Contents for PM-10 Emission
Inventory Reports
I. Cover and Title Page
A. Title (geographic area, type of inventories, pollutants, base year)
B. Responsible agency [e.g., NC Dept of Health and Natural Resource]
C. Report date (completed/distributed)
D. Preparer (if different from responsible agency - e.g., contractor)
II. Table of Contents
A . Cont ent s
B . Tables
C . Figures
III . Introduction
A. Reason for report being prepared, purpose
[For example. In response to letter from _ to _ , dated _
requesting preparation of a SIP for demonstration of attainment of
PM-10 NAAQS in (geographic area) , beginning with an emission inventory
•for the base year. Base year emission inventory serves as the basis
for emissions modeling and projections for future years.]
B. Geographic area covered, base year, type of inventory (PM-10)
pollutants included (PM-10, others)
C. Brief discussion of contents of report
[Note: Include a paragraph or less describing each major report
section. For example. Section 2 summarized stationary point, area and
mobile source emissions by county. Section 3 describes stationary
point source emissions and includes a discussion of methods used to
gather data, calculate annual and/or seasonal emissions, and presents
a summary of emissions by plant. Detailed point source emissions data
are presented in Appendix F. Section 4 discusses ...]
D. Discussion of automated data systems used (AFS/AMS, State system)
E. Major problems, deficiencies, portions of inventory not included
F. List of primary guidance documents and references used (EPA guidance
documents , AP-42 , etc . )
G. List of contacts for each distinct portion of the inventory
IV. Summary
A. Emissions (annual and/or seasonal) of each pollutant by major category
(point, area, and mobile sources) in both tabular and graphical form;
brief discussion in footnote, etc. to clarify what each includes.
B' no^, exampi
-------
Table 4.1 Outline for EPA Recommended Format/Contents for PM-10 Emission
Inventory Reports (Continued)
V. Documentation of Emissions Methods/Data/Estimates
A. Point Source Emissions
I' discussions of procedures and methodologies including sample
calculations
2- example surveys/questionnaires
3 • list of plants by primary product and total emissions
4 • summary data for each plant by source classification code
with details in an appendix
5. point source emissions summary
B. Area Source Emissions
1- discussions of procedures and methodologies including sample
calculations
2- list of and emissions by source category
3• calculations and discussion for each source category
4. area source emissions summary
C. Mobile Source Emissions
1- discussion of procedures and methodologies including sample
calculations
2- list of vehicle classes and emissions
3• discussion of how VMT estimates were derived
4- discussion of key assumptions involved in the use of the
PARTS model (or the latest available version)
5- calculations and discussion for each vehicle class
6 • mobile source emissions summary
VI. Quality Assurance/Quality Control (QA/QC)
A. QA/QA plan - discussion of QA/QC methodologies used
B. Results from the application of the QA plan
C. QA procedures can also be discussed in individual source category
sections
VII. Appendices
A. Lengthy data, calculations, documentation of methodologies/models
Notes: Annual and/or seasonal emissions shall be presented in the summary and
sections describing emissions.
All pages in the report (including appendices) shall be numbered
Sources of information shall be referenced throughout. Include
complete list(s) of references within body of report (preferably at end
of each section).
Margins of report shall be adequate so that copying of report will not
lose text, page numbers, or other important information.
21
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used to determine emissions. Summary tables and graphics shall be prepared to
address just point source emissions.
For area and mobile sources, the report must state if any source
categories were not considered in the inventory and why. All of the source
?So^°^e! C0v1!red shall be listed and the method used to determine emissions
identified. If an EPA method was used, but a different emission factor was
used, this must be noted. For all approaches used (EPA or otherwise) , the
derivation of activity/commodity level data shall be thoroughly discussed As
needed, supporting data can be put into appendices but the appendices shall be
fully explained and clearly linked back to the text discussion and emission
estimates. Like point sources, emission summaries shall be developed for area
and _ mobile sources. The summaries must reflect emissions by county and for the
entire nonattainment area.
As an aid to States in the preparation and checking of their inventories
prior to submittal to EPA, the Agency has been preparing a set of quality
review guidelines. These guidelines will contain what is essentially a
checklist of items that an inventory must contain or address in order for the
inventory to be considered acceptable for review by EPA. The guidelines will
address whether inventories meet developed specifications for completeness
consistency (both internal and with national trends) , reasonableness of
emission values, and emissions documentation.
States are _ required to design and implement a QA program to enhance the
ine£;£ion«oX?X^tyr^d ^^^ °f the P1*-10 SIP emission inventories prepared
in response to the CAA. The inventory report shall have a separate section
that describes the implementation of the State's QA plan and the results
«St?VS^ y *v,QA Pro?ram- For a11 source category types, the QA discussion
shall address the completeness of the inventory (e.g., are all of the EPA-
recommended area source categories accounted for) , reasonableness of the
emission estimates (e.g., are estimates for a category consistent with some
other related parameter for the area), and relative accuracy of the data (e g
?£ i ? indlZidual c«»ty emission figures total to the sums given for " '
the whole area) . The QA discussion must show the range of quality review that
SouldlXl^i-3?* h°? ^ nriSW benefitted the inventory. This QA discussion
should reflect the planned QA program that was approved as a part of the IPP
The QA section should discuss how the QA plan was actually implemented, what '
^Si0",0* ?{! QA program did and did not work, the results of any internal or
external audits that were performed, and a general QA of the inventory data.
4.2 Data Management and Reporting
Emission inventory information for base year and periodic (if recruired)
inventories under the CAA shall be provided to EPA in electronic formal The
level of detail required to be reported to EPA is currently being determined
e Sje of fue EPA
aion of
2SSSSL 5 S% °? t^SpeClfiC level °f detail re<3uired for the electronic
reporting of data to EPA. If a State elects to use the EPA' s AIRS, the level
°Lde^ai1 reined for AIRS submittals would be sufficient for EPA data
reporting in coordination with EPA Regional Office requirements The
requirements and instructions for data coding, updating, editing, storage and
£^leVe4 af6 sPecified in the AIRS User's Guide manuals. The AIRS User^s
Guide manuals, along with several other reference documents for using AFS and
AMS, are available on the AIRS Bulletin Board System on the TTN The AFS Dafa
System Helpline (1-800-367-1044) is available tS hand?! technical syltJm
questions, software malfunctions, and problems with the system The AMS also
has a user's Help Line (1-800-333-7909) for assistance in^lfaspects^f usfng
AMS. For more information, contact the EPA Regional Office. using
22
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SECTION 5.O
REFERENCES
U.S. EPA, 1986: U.S. Environmental Protection Agency, Guideline On Air Quality
Models (Revised), EPA 450/2-78-027R, and its supplements, July 1986.
(Codified in Appendix W of 40 CFR 51.)
U.S. EPA, 1987: U.S. Environmental Protection Agency, PM-10 SIP Development
Guideline, EPA 450/2-86-001, June 1987 and Supplement June 1988.
U.S. EPA, 1988a: Control of Open Fugitive Dust Sources, EPA-450/3-88-008,
September 1988.
U.S. EPA, 1988b: U.S. Environmental Protection Agency, Guidance for
Preparation of Quality Assurance Plans for Ozone/Carbon Monoxide SIP
Emission Inventories, EPA 450/4-88-023, December 1988.
U.S. EPA, 1989a: U.S. Environmental Protection Agency, Guidance Document
ror Residential Wood Combustion Control Measures, EPA 450-2-89-015
September 1989. '
U.S. EPA, 1989b: U.S. Environmental Protection Agency, Example Emissions
Inventory Documentation for Post-1987 Ozone State Implementation
Plans (SIPS), EPA-450/4-89-018, October 1989.
U.S. EPA, 1990: U.S. Environmental Protection Agency, Guideline on Air
Quality Models (Revised), memorandum from Joseph Tikvart and Robert
Bauman, July 5, 1990.
U.S. EPA, 1991a: U.S. Environmental Protection Agency, PM-10 Moderate Area
SIP Guidance: Final Staff Work Product, memorandum from John
Calcagni, April 2, 1991.
U.S. EPA 1991b: U.S. Environmental Protection Agency, Nonroad Engine and
Vehicle Emission Study — Report, EPA-21A-2001, November 1991.
U.S. EPA, 1992: U.S. Environmental Protection Agency, Background
Information Document for Prescribed Burning Best Available Control
Measures, EPA 450/2-92-003, September 1992.
U.S. EPA, 1993a: U.S. Environmental Protection Agency, PM-10 Serious Area
SIP Guidance: Final Staff Work Product, memorandum from Joseph W
Paisie, September 24, 1993.
U.S. EPA, 1993b: U.S. Environmental Protection Agency, PM-10 Guideline
Document and Appendix, EPA 452/R-93-008, April 1993.
23
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24
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APPENDIX A
INVENTORY PREPARATION PLAN (IPP) REVIEW CHECKLIST
The purpose of this checklist is to provide a decision tool for
determining if an IPP meets EPA's minimum requirements. The Questions marked
with an asterisk (*) are considered crucial to an acceptable IPP, but are not
required. Those questions not so marked are considered desirable items.
1.0
APPROACH
*1.1 Does the IPP indicate whether it was prepared for the purposes of a PM-10
SIP inventory?
Yes
No
Comments
"1.2
Does the IPP define the nonattainment area(s) that the inventory will
address, and indicate the nonattainment classification for the area(s)?
Yes
No
Comments
1.3 Are the groups/persons responsible for the inventory and the
groups/persons compiling the inventory specified?
Yes
No
Comments
1.4
Does the IPP contain a suitable outline for content and organization
review of the planned inventory report?
Yes
No
Comments
25
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Does the IPP contain schedules of submission dates for draft and final
inventories or inventory components if the State plans to submit the
inventory in component pieces?
Yes
No
Comments
*1.6 If the IPP covers multiple nonattainment areas, are differences in the
approach for the nonattainment areas clearly defined?
Yes
No
Comments
1.7 Does the IPP address which source categories of PM-10, regardless of size
will be inventoried? '
Yes
No
Comments
*1.8 Are stationary point, stationary area, on-road mobile, and nonroad mobile
where applicable, addressed?
Yes
No
Comments
*1.9 Does the IPP summarize the basis for the inventory and the source(s) of
basic emissions documentation information for each principal inventory
component (point, area, on-road mobile, etc.)?
Yes
No
Comments
26
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2.0 POINT SOURCES
*2.1 Does the IPP define how all pertinent emission sources will be identified
and located?
Yes
No
Comments
2.2 Does the IPP describe how point source activity levels and associated
parameters will be developed and discuss how these data will be used to
calculate emission estimates?
Yes
No
Comments
*2.3 Does the IPP discuss how and when statewide point source reporting to the
EPA will be conducted and how it will be coordinated with reporting for
nonattainment area sources?
Yes
No
Comments
*2.4 Does the IPP indicate whether rule effectiveness (RE) was applied and
discuss the basis for its application if it was included in the emission
calculations ?
Yes
2 . 5 Does the
Yes
No
-
Comments
IPP discuss what emission control efficiencies will be based on
No
Comments
27
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3.O STATIONARY AREA AND NONROAD MOBILE SOURCES
*3.1 Does the IPP explicitly state which source categories will be addressed?
Yes
No
Comments
*3.2 Does the IPP explicitly state which source categories from EPA's emission
inventory requirements will not be addressed and provide justification?
Yes
No
Comments
*3.3 For source categories included, does the IPP indicate or reference the
approach used to calculate emissions?
Yes
No
Comments
*3.4 If there are alternate EPA methods for a category, does the IPP clearly
indicate the method the State intends to use?
Yes
No
Comments
*3.5 Are the major assumptions stated for approaches that differ from EPA's
guidance?
Yes
*3.6 Does the
Yes
No
Comments
IPP define the source of activity level data?
No
Comments
28
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"3.7 If RE was applied, does the IPP discuss the basis for the application
of RE?
IYes
No
Comments
*3 . 8 Does the IPP discuss what emission control efficiencies will be based on'
IYes
No
Comments
4.0 ON-ROAD MOBIIiE SOURCES
*4.1 Does the IPP provide a clear indication of how the State intends to
develop a VMT estimate?
!Yes
No
Comments
*4.2 Does the IPP indicate that PARTS will be used to develop mobile source
emission factors?
Yes
No
Comments
*4.3 If PARTS will not be used, does the IPP discuss the alternate emissions
estimation methods?
IYes
No
Comments
*4.4 Are the key assumptions for the PARTS model identified (i.e., vehicle
speed) ?
IYes
No
Comments
4.5 Does the IPP specify the vehicle classes that will be covered?
29
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Yes
No
Comments
5 . O MODKLING
*5.1 Is the modeling inventory and the modeling approach for the attainment
demonstration discussed in the IPP?
5.2 Is
Yes
No
Comments
the modeling area defined?
Yes
No
Comments
-
5.3 Does the IPP indicate when initial modeling inventory data will be
submitted?
Yes
No
Comments
5.4 Does the IPP discuss early coordination between inventory and modeling
personnel in inventory planning?
Yes
No
Comments
5.5 Does the IPP discuss how the temporal and spatial resolution will be
determined for model inputs?
30
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6 . O
DOCUMENTATION
,l?arly describe how the Stafce
the inventory to EPA?
to present, document,
Comments
6.2 Does the IPP discuss how emission estimates will be summarized for each
nonattainment area?
"6.3 Was the Regional Office contacted to establish the specific level of
Sp^L^f** f°r fc^ ?le=tronic Deporting of data to EPA, and does the
to EPA* computerized methods for compiling and submitting the data
7.0 QUALITY ASST3RANCE (QA) FLAN
*7.1 Does the IPP contain a QA plan for the inventory?
31
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*7.2 Does the QA plan describe the overall QA program that the State intends to
use during Compilation of the inventory?
Yes
No
Comments
S.O QA POLICY STATEMENT
*8.1 Does the QA plan contain a Policy Statement with a formal declaration of
management's commitment to the development and implementation of the QA
program?
IYes
No
Comments
*8.2 Does the Policy Statement indicate that there is a commitment to develop a
Quality emission inventory, including the allocation of resources for the
QA program?
Yes
No
Comments
*8.3 Is the Policy Statement signed by the QA Coordinator and Agency
Administrator?
IYes
No
Comments
9.0
SUMMARY
9.1 Does the QA plan's summary include an overview, of the major components of
inventory development?
Yes
No
Comments
'
32
-------
*9.2 Does the summary include a description of the flow of the inventory data
through the Agency or refer to such a flow chart elsewhere in the IPP?
Yes
No
Comments
*9.3 Does the summary indicate the critical points at which QA is applied
during the development of the inventory?
Yes
No
Comments
9.4 Are the data QC techniques given in the summary, including an indication
of the frequency that they will be applied?
Yes
No
Comments
9.5 Does the summary contain the objectives for emission inventory
development?
Yes
No
Comments
9.6 Does the summary discuss the constraints relative to the development of
the emission inventory (i.e., given personnel, time, resources, data
processing capabilities)?
Yes
No
Comments
"9.7 Does the summary include an organizational chart showing the technical as
well as QA personnel?
Yes
No
Comments
33
-------
*9.8 Does the organizational chart show the QA coordinator reporting to upper
management not directly involved in the development of the inventory?
Yes
No
Comments
*9.9 Does the summary provide the names and telephone numbers of the QA
coordinator and directors?
Yes
No
Comments
10.0 TECHNICAL CONSIDERATIONS PLANNING
10.1 Does the QA plan contain a schedule of QA activities?
IYes
No
Comments
10.2 Are the responsibilities of the QA Coordinator given?
IYes
No
Comments
10.3 Is the personnel training program explained in the QA plan?
IYes
No
Comments
10.4 Are the checkpoints for problem detection given in the QA plan?
Yes
No
Comments
34
-------
*10.5 Does the QA plan show that the QA/QC program includes assessing data
completeness and standard range checking?
Yes
No
Comments
*10.6 Does the QA plan give the critical data elements relative to assessing the
completeness of the source data? -assessing cne
Yes
No
Comments
11.0 TECHNICAL CONSIDERATIONS DATA COLLECTION AND ANALYSIS
*11.1 Does the QA plan explain data collection procedures and QA/QC procedures
used to insure quality data were collected?
Yes
No
Comments
11.2 Does the QA plan indicate what QA/QC procedures will be implemented to
account for all sources?
Yes
No
Comments
*11.3 Does the QA plan describe QA/QC procedures that will prevent double
counting of sources?
Yes
No
Comments
35
-------
*11.4 Does the QA plan explain how the quality and accuracy of the calculations
will be evaluated for:
- Consistency in methodology?
IYes
No
Comments
- Review of engineering judgement?
Yes
No
Comments
- Accuracy of units and unit conversions?
IYes
No
Comments
- Transposition of figures?
Yes
1
No
Comments
Misinterpretations of the use of emissions factors?
Yes
No
Comments
*11.5 Does the^QA plan explain how the completeness, reasonableness,
reliability, and consistency in the use of equations for specific methods
will be evaluated?
Yes
No
Comments
36
-------
11.6 Does the QA plan indicate that the person responsible for evaluating the
e Calculations is not directly involved in the inventory
12.0 TECHNICAL CONSIDERATIONS DATA HANDLING
*12.1 Does the QA plan explain the data management procedures (i.e , coding
tracking, securing, storing on disks)?
*12.2 Does the QA plan include procedures which explain how data will be
corrected and these corrections tracked?
*12.3 Are data documentation procedures given (i.e., use of notebooks
computers, work sheets)?
13 .0 QA REPORTING
inventor
indic?te how applicable data checks (e.g., consistency,
reasonableness< and proofing) will be reported in the
37
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14.0 QA AUDITS
*14.1 Does the QA plan contain a statement that the Agency is willing to be
audited by EPA?
IYes
No
Comments
14.2 Does the QA plan indicate that the QA program includes routine assessments
of the effectiveness of the inventory development procedures (i.e. ,
internal audits) ?
IYes
No
Comments
14.3 Does the QA plan indicate the frequency of internal audits?
IYes
No
Comments
14.4 Are the objectives of the audits given?
IYes
No
Comments
-
14.5 Does the audit procedure include documentation of the findings and
periodic reports to management?
IYes
No
Comments
38
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
i. REPORT NO.
EPA-454/R-94-033
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
PM-10 Emission Inventory Requirements Final Report
5. REPORT DATE
September 1994
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Randy Strait
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
E. H. Pechan & Associates, Inc.
3500 Westgate Drive, Suite 103
Durham, NC 27707
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D2-0159, WA 13
12. SPONSORING AGENCY NAME AND ADDRESS
Emission Inventory Branch (MD-14)
Sulfur Dioxide/Particulate Matter Programs Branch (MD-15)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
EPA Contacts: Robin Dunkins, SDPMPB (MD-15) and Bill Kuykendal, EIB (MD-14)
16. ABSTRACT
This document describes the emission inventory requirements that are contained, either explicitly or
implicitly, in the Clean Air Act as amended in 1990 (CAA) for those areas that are required to submit a
State Implementation Plan (SIP) for demonstrating attainment of the National Ambient Air Quality
Standard (NAAQS) for PM-10. The guidance in this document pertains to PM-10 moderate
nonattainment areas and to areas that have been reclassified as serious nonattainment areas. The
purposes of the document are to (1) identify the types of inventories required; (2) briefly review the
regulatory requirements pertaining to submission of these inventories; (3) describe the objectives,
components, and ultimate uses of the inventories; and (4) define documentation and reporting
requirements for the inventories.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Emissions
Particulate
Emission Inventories
PM-10
Guidance
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
45
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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