EPA-450/4-88-019 EMISSION INVENTORY REQUIREMENTS FOR PosT-1987 OZONE STATE IMPLEMENTATION PLANS BY DAVID C. MISENHEIMER TECHNICAL SUPPORT DIVISION OFFICE OF AIR QUALITY PLANNING AND STANDARDS U. S. ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711 DECEMBER 1988 ------- TABLE OF CONTENTS Chapter Page Table of Contents iii List of Tables iv Preface v 1.0 Overview of Document 1 1.2 Purpose 1 1.2 Summary of Document Contents 1 2.0 Introduction 2 3.0 Emission Inventory Requirements 3 3.1 Geographic Area To Be Inventoried 3 3.2 Pollutants To Be Inventoried 4 3.3 Rule Effectiveness And Penetration 5 3.4 Base Year Emission Inventory 7 3.5 Projected Attainment Year Emission Inventory 9 3.6 Point Sources 10 3.7 Area Sources 11 3.8 Mobile Sources 12 3.9 Fuel Volatility 12 3.10 Quality Assurance 12 4.0 Reasonable Further Progress Reporting Requirements 14 5.0 Format For Submission Of Inventory Data 16 5.1 Summary Format 16 5.2 Point Source Listing 16 6.0 Documentation Of The Inventory 27 7.0 Schedule For Submission Of Inventory Items 29 7.1 Initial Inventory Submittal 29 7.2 Final Inventory Submittal 29 8.0 References 31 Appendix A Appendix B iii ------- LIST OF TABLES Number page Table 1-A 17 Table 1-B 21 Table 1-C 23 Table 2 25 IV ------- PREFACE This document describes emission inventory requirements related to the preparation and submission of ozone (03) State Implementation Plans (SIPs) for those areas required to revise their plan after December 31, 1987. Included in this document are a number of improvements and additions to the emission inventory requirements that applied to the 1982 O3 SIPs. The focus of this report is requirements for base year emission inventories. Although not required until submittal of the SIP, brief discussions of projected emission inventories and reasonable further progress (RFP) tracking are also included for those agencies that choose to begin preparation of this information. More information concerning projected emission inventories and RFP tracking will be issued later in 1989. Major changes incorporated in this document are summarized briefly below: 0 Emissions of volatile organic compounds (VOC), nitrogen oxides (NOX) and carbon monoxide (CO) shall be inventoried for all counties (or county equivalents) within the metropolitan statistical area (MSA) or consolidated metropolitan statistical area (CMSA), if one exists, in which a nonattainment determination was made. The inventory shall also include emissions from sources in adjacent nonattainment counties and emissions from major stationary sources outside of, but within 25 miles of, the MSA/CMSA boundary. Only sources within the county in which the determination was made were included in previous inventories. The inventory area has been expanded because major sources of 03 precursors located in areas surrounding the nonattainment area may contribute significantly to the O3 formation problem in the affected area. 0 Emissions of VOC, NOX and CO shall be summarized on a countywide or equivalent (parish, township, etc.) basis aggregated by source category for both point sources and area sources. The CO emissions information was not required in previous O3 SIP emission inventories. However, recent evidence from smog chamber studies indicates that CO plays a small, but significant role in ozone production. Reductions in CO, due to automotive and other emission control programs, will reduce O3 levels and will reduce the amount of VOC control necessary to attain the National Ambient Air Quality Standard (NAAQS). 0 In addition to the source category emissions summaries, emissions information shall be compiled and reported for each individual point source within the MSA/CMSA that emits at least 10 tons per year (tpy) VOC and for each individual point source outside, but within 25 miles of, the MSA/CMSA that emits at least 100 tpy VOC. For sources of VOC that emit from 10 to 25 tpy, emissions estimates may be determined by a survey of a ------- representative statistical sample (e.g., 10 percent) of sources within each source category in the MSA/CMSA and extrapolation of the collected data to the remaining sources. Detailed process and emissions data shall be reported for all sources that emit at least 25 tpy VOC. Previous inventories required VOC emissions data for each point source emitting at least 100 tpy. 0 A listing of plant names and emission estimates shall be compiled and reported for each individual point source within the MSA/CMSA that emits at least 100 tpy of NO, or CO and for each source outside, but within 25 miles of, the MSA/CMSA that emits at least 100 tpy of NO, or CO. 0 For areas that anticipate NOX emission reductions as part of their demonstration of attainment for 03, a detailed listing of NOX process and emissions data shall be reported for each individual point source that emits at least 100 tpy. 0 States shall assess rules existing before December 31, 1987, and rules resulting from post-1987 SIP revisions, and shall apply a rule effectiveness factor to emissions covered by these rules to estimate actual reductions that will be achieved. This is because, in the past, reductions from many national and local control measures have not been fully realized. vi ------- 1.0 OVERVIEW OF DOCUMENT 1.1 PURPOSE This document describes emission inventory requirements for the preparation of post-1987 O3 SIPs for those areas that are required to revise their plan for attainment of the NAAQS for 03. 1.2 SUMMARY OF DOCUMENT CONTENTS As noted above, this section presents the purpose of this report and also provides an overview of the contents of the document. It briefly outlines the key points and format of the material presented in the remaining sections of this report. Section 2 of this document introduces the emission inventory and its role in the post-1987 O3 SIP revisions. Some background on the O3 SIP revisions is also provided. Section 3 details the specific requirements of the emission inventory. Inventory requirements are discussed with regards to topics such as geographic area of inventory, pollutants, base year inventory, projected attainment year inventory, point sources, area sources, mobile sources, and quality assurance. Section 4 summarizes the SIP reporting requirements portion of the RFP program. The RFP program primarily tracks whether emission reductions expected as a result of SIP regulations are being achieved. The information and format required for reporting under RFP are briefly described. Section 5 provides a recommended format for submitting emission inventory data, Section 6 focuses on documentation requirements of the inventory, and Section 7 describes the schedule for submitting the inventories and documentation. ------- 2.0 INTRODUCTION Many areas did not attain the NAAQS for O3 by December 31, 1987, and corresponding States are now required to revise their SIPs. Revised SIPs shall include updated emission estimates for the MSA or CMSA in which a nonattainment determination was made. Base year and projected attainment year emission inventories for VOC, NOX and CO shall be included in the attainment demonstration of these SIP revisions. The Clean Air Act (CAA) prescribes that current, comprehen- sive and accurate emissions data shall be submitted to EPA for each attainment demonstration area. This document prescribes EPA's policies regarding the emissions data base to be submitted to EPA for post-1987 03 SIP revisions or redesignation requests. The EPA views compliance with these emission inventory data base requirements as an important component of post-1987 O3 SIP submittals. ------- 3.0 EMISSION INVENTORY REQUIREMENTS Revised SIPs shall include base year and projected year emission inventories representative of a typical weekday during the peak O3 season (generally May through September). The inven- tories shall be presented in two formats: 1) a summary of emissions of reactive VOC, NOX and CO from stationary (point and area) sources and mobile sources by source category on a county- wide (or equivalent) basis; and 2) a more detailed list of stationary point source emissions and process information by facility process. Emission estimates shall be determined to the extent possible, using source specific information in conjunction with method- ologies described in inventory guideline references. One such reference, Procedures For The Preparation Of Emission Inventories For Volatile Organic Compounds - Volume I.1 is recommended for use in inventorying VOC, NOX and CO emissions from stationary sources. Another reference, Procedures For Emission Inventory Preparation,. Volumes I-Vf* was developed as general guidance to those engaged in inventorying criteria pollutants. Volume IV of this series contains information for inventorying VOC, NOX and CO from mobile sources. More specifically, States shall be guided by the requirements described below. 3.1 GEOGRAPHIC AREA TO BE INVENTORIED The planning, or demonstration, area is generally the MSA, or CMSA, if one exists, in which nonattainment of the O3 NAAQS was determined. MSAs and CMSAs in the United States are identified in Reference 3. Previous SIP inventories were required only for the counties in which the nonattainment determinations were made. The demonstration area has been expanded to all counties within the MSA/CMSA, because emissions from stationary sources and transportation systems (and associated vehicles) throughout the MSA/CMSA may contribute to the O3 nonattainment problem. There are several instances in which an area larger than the MSA/CMSA should be used for the inventory. If monitoring sites that record exceedances of the O, NAAQS are located in counties adjacent to, but not within, an MSA/CMSA, sources within such counties should be included in the inventory. In cases where a previous Part D SIP has used a planning area larger than the MSA or CMSA, the area comprising the MSA/CMSA and the previous planning area should be used. In most cases under Part D, the Section 107 designated nonattainment areas coincide with the planning areas. However, some Section 107 areas in the northeast were larger, encompassing as much as the entire state. In such cases, the larger of the previous planning area or the MSA (not ------- the Section 107 area) should be used for the inventory. In cases where the present nonattainment area previously was classified as rural and thus, has no "previous planning area," the largest of the Section 107 area, the MSA, or the county in which the MSA is located should be used for the inventory. For isolated rural nonattainment areas (those not adjacent to a MSA/CMSA), the inventory area shall be the county in which the violation was determined. In addition, major stationary sources that emit VOC, NO,, or CO at a level of at least 250 kg/day or 100 tons per year (tpy) located outside, but within 25 miles of, the MSA/CMSA boundary shall be included in the inventory. This is because these sources may contribute to exceedances of the NAAQS within the MSA/CMSA. Major emission sources within 25 miles of non-MSA/CMSA demonstration areas, such as those discussed above, shall be included in the inventory. In some cases, a major source may be located in one SIP call area and within 25 miles of another area receiving a SIP call. To avoid double counting, the source should be included only in the emission inventory of the MSA/CMSA in which it is located. Emission inventory summaries (as described in Section 5) shall be reported for each county within the MSA/CMSA, except in those areas where information is commonly available at the parish, city, or township (e.g., the Northeast). In such cases, emission summaries may be compiled and maintained on this non-county basis. 3.2 POLLUTANTS TO BE INVENTORIED The inventory shall contain a summary of emission estimates of VOC, NO, and CO from point, area and mobile sources. Inventories of CO were not required in previous O3 SIPs. However, recent evidence from smog chamber studies indicates that CO plays a small, but significant role in ozone production. Reductions in CO, due to automotive and other emission control programs, will reduce O3 levels and the required amount of VOC control necessary to attain the NAAQS. The emission inventory shall also contain a more detailed listing of VOC emissions data for point sources. For areas where NOX reductions are anticipated to supplement VOC strategy in demonstrating attainment, the inventory shall also contain a detailed listing of NOX emissions data for point sources. Emission inventories for VOC should be consistent with the Agency's reactivity policy discussed in the Federal Register.4iS Nonreactive VOC compounds should be excluded from the inventory for purposes of O3 SIPs, since controls on emissions of nonreactive compounds will neither contribute to the attainment ------- and maintenance of the NAAQS for 03I nor be credited toward achievement of that standard. These compounds include: methane ethane methylene chloride methyl chloroform trichlorotrifluoroethane (CFC-113) trichlorofluoromethane (CFC-11) dichlorodifluoromethane (CFC-12) chlorodifluoromethane (CFC-22) trifluoromethane (rC-23) dichlorotetrafluoroethane (CFC-114) chloropentafluoroethane (CFC-115) Perchloroethylene has been proposed as a nonreactive VOC. However, until a decision on the status is complete, perchloroethylene should not be considered nonreactive and should be included in the inventory. States are encouraged to use source specific test or mass balance data to estimate the magnitude of emissions for each major source. Emission factors should be used where source specific data are not available. Emission factors for VOC, NOX and CO are contained within Compilation Of Air Pollutant Emission Factorsf AP-42.''7 Emission factors for some source categories have not yet been published in AP-42 but are available elsewhere. For example, under the National Acid Precipitation Assessment Program (NAPAP), EPA developed VOC and NOX emission factors for approximately 1000 source classification categories (SCCs) where factors were previously absent.' New VOC emission estimation procedures are available for hazardous waste Treatment, Storage and Disposal Facilities (TSDF), industrial waste water treatment facilities, Publicly Owned (waste water) Treatment Works (POTW), and municipal landfills.1 3.3 RULE EFFECTIVENESS (RE) AND PENETRATION 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 in most source categories in most areas of the country. The concept of applying RE in the SIP emission inventory has evolved from this observation. In short, RE reflects the ability of a regulatory program to achieve all the emission reductions that could be achieved by full compliance with the applicable regulations at all sources at all times. ------- 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). In the proposed post-1987 ozone/CO policy, it was stated that a factor of 80 percent should be used to estimate RE in the base year inventories. The final policy will allow use of the 80 percent default value, but will also give States the option to derive local category-specific RE factors within some tightly prescribed guidelines as EPA deems appropriate. Whichever option is exercised to estimate RE, the results of a local source-by- source evaluation performed for a particular source category according to the protocol published by the stationary Source Compliance Division will override estimated factors. In the SIP inventory, the RE determined for the source category shall be applied to all sources in the category (both point and area sources) with the following exceptions: (1) sources not subject to the regulation, (2) sources achieving compliance by means of an irreversible process change that completely eliminates solvent use, and (3) sources for which emissions are directly determined by calculating solvent use over some time period and assuming all solvent was emitted from the source during that time period. The RE factor shall be applied to the estimated control efficiency in the calculation of emissions from a source. An example of the application is given below. Uncontrolled emissions = 50 Ibs/day Estimated control efficiency = 90% Rule effectiveness = 80% Emissions after control = 50 [1 - (0.90)(0.80)] = 50 [1 - (0.72)] =14 Ibs/day Thus, the application of RE results in a total emission reduction of 72 percent. ------- In addition to RE, another important regulatory consideration is the extent to which a regulation may cover emissions from an area source category. When estimating emissions using area source methodologies for source categories where a rule or regulation applies, agencies shall incorporate an estimate of the amount of rule penetration by means of the following formula: Rule Uncontrolled emissions Penetration = covered by the regulation x 100 percent Total uncontrolled emissions Once uncontrolled emissions and rule penetration are determined, RE should be applied as discussed above. An example of how to incorporate both penetration and RE in the same source category follows. Uncontrolled emissions = 100,000 tpy Control efficiency required by the regulation = 95 percent Rule penetration = 60 percent Rule effectiveness =80 percent Emissions from the category = (100,000)[1 - (0.60)(0.95)(0.80)] = 54,400 tpy Further discussions of the use of rule effectiveness and rule penetration are included in Reference 1. 3.4 BASE YEAR EMISSION INVENTORY The following discussion concerns the requirements for base year emission inventories to be used in conjunction with the EKKA model. Use of the EKMA model meets the minimum O3 modeling requirements for development of a post-1987 O3 SIP. The base year inventory shall be representative of actual emission levels for the period of air quality data used in the modeling. Baseline inventories shall be prepared for a 1987 or 1988 base year. Base year emissions must reflect actual conditions. defined as the estimated typical emission rate multiplied times the average hourly production or throughput rate times hours of operation per day. The inventory shall take into account the impact of already implemented SIP regulations in base year emission levels. Base year inventories must also reflect appropriate effectiveness levels, as described above. ------- Base year VOC, NOX and CO emissions should be calculated using assumptions that reflect conditions that exist on a typical weekday during the months that encompass the peak O3 season (generally May through September). This is accomplished in two ways. First, for source categories whose operating rates vary seasonally, typical weekday emissions should be determined using average O3 season operating data obtained from the source. For some point sources, production (throughput) may increase or decrease during the peak O3 period. Highway vehicle traffic, gasoline handling and space heating are examples of source categories whose activities generally vary from season to season (gasoline throughput typically increases during summer months). Secondly, certain emission factors for some source categories vary as a function of temperature and/or humidity. Most importantly, the emission factors for gasoline-powered vehicles and petroleum product storage and handling operations are a function of temperature. NOX emissions from light-duty vehicles are a function of absolute humidity. In compiling the emission inventory for post-1987 O3 SIPs, temperature and humidity assumptions shall be consistent throughout the inventory, to the extent possible. The average temperature and humidity during the 10 highest ozone days during the design value period (normally three years) shall be used in estimating emissions from mobile and stationary sources, where applicable. Generally, highway vehicle travel estimates are determined for an average annual weekday by the responsible Metropolitan Planning Organization (MPO) or State Department of Transportation. To develop an inventory of emissions for a typical O3 season weekday, travel estimates for the O3 season can be used if available, or a seasonal factor can be applied to average annual estimates to adjust for increases (or decreases, in some cases) in travel occurring during the O3 season. Generally, such an adjustment factor can be derived from local traffic counting programs. Guidance for preparation of mobile source emission inventories is contained in Reference 9. Emission estimates for point and area sources are freguently maintained on an annual basis in State and local inventories. For area sources, if seasonal activity levels are not available, the inventorying agency will have to apply seasonal and weekday adjustments to annual area source activity levels, based on local knowledge of the operating patterns of each source. If local operating data are unavailable to make such adjustments, the data presented in Reference 1 may be used for this purpose. Because local practices may vary, the use of local data, when available, is strongly encouraged. 8 ------- The requirements described above concern preparation of base year emission inventories to be used in conjunction with the EKMA model. Use of the EKMA model meets the minimum 03 modeling requirements for development of a post-1987 O3 SIP. However, use of the Urban Airshed model, while not required, is encouraged. If the Urban Airshed model is to be used by the agency compiling the base year emissions inventory, an hourly gridded emissions inventory would be necessary.10 3.5 PROJECTED ATTAINMENT YEAR EMISSION INVENTORY An inventory of estimated VOC, NOX and CO emissions shall be developed for the year the O3 standard is projected to be attained. If attainment is projected to occur more than 3 years from the base year, emissions must be projected for each 3-year period prior to attainment. The first interim projection must be for 5 years (rather than 3 years) after the base year. Interim emission reduction projections would then be made for each 3-year period starting from the initial 5-year projection and extending to the attainment date. Two types of emission estimates are required for the projection inventories and are described below: (a) projected baseline emissions, and (b) projected "new or revised SIP strategy" emissions. (a) The projected baseline emission estimates shall be based on allowable emissions and shall reflect the increases or decreases in emissions due to growth since the base year and enforceable emission rates resulting from regulations with compliance deadlines of December 31, 1987, or before (i.e., previous SIPs). Projected baseline emissions should not reflect reductions resulting from additional regulations required for attainment in post-1987 03 SIPs. The projected baseline inventory should reflect changes in emissions due to unique, irregularly occurring events or conditions which affected the base year inventory. For example, the projected inventory should not reflect temporary reductions in emissions that occurred in the base year resulting from strikes, recession-influenced production cutbacks or other unusual factors (such as major equipment malfunctions or variances). (b) The projected, "new or revised SIP strategy" emission estimates shall account for the changes included in the baseline projection and the impact of additional stationary source regulatory controls to be adopted as part of the post-1987 03 SIPs. The "revised SIP strategy" emission estimates shall be based on allowable emissions, which are the product of an enforceable emission rate (e.g., pounds of VOC per gallon of solids applied), the operating capacity (e.g., gallons of solids applied per hour), and the actual operating schedule (hours per ------- day) for a typical or average peak 03 season weekday in the projected year. Projected emissions must then be adjusted for effectiveness of regulatory controls for applicable sources (see Section 3.3). The projected interim and attainment year inventories should be developed with procedures for projecting emissions contained within References 1 and 2. 3.6 POINT SOURCES At a minimum, stationary sources (facilities) that emit equal to or greater than 10 tons per year VOC, on an actuals basis, shall be considered as point sources. Previous SIP inventories defined the cutoff for VOC point sources as sources with the "potential to emit" 100 tons per year. Stationary sources that emi*: equal to or greater than 100 tons per year NOX or CO, on an actuals basis, shall also be considered point sources. Point source emission cutoff levels less than 10 tons per year for VOC, and less than 100 tons per year for NOX and CO, are encouraged, especially for sources for which States will be defining Reasonably Available Control Technology (RACT), and/or other control regulations. Detailed process and emissions data shall be collected and reported for each VOC point source that emits equal to or greater than 25 tons per year, at a minimum, as discussed in Section 5. States are encouraged to collect such data for VOC sources that emit equal to or greater than 10 tpy. A summary listing of plant names, locations and total plant emissions (tons/day) is required for sources of NO, and CO that emit at least 100 tons per year. Detailed process and emissions data for each NO. point source that emits equal to or greater than 100 tons per year is required for areas that anticipate NO. reductions as part of their O3 control strategy. For VOC point sources expected to emit between 10 and 25 tpy, a survey of a statistical sample of sources in each source category can be used to estimate emissions in the MSA/CMSA. For each source category inventoried using this method, the sample survey must identify the location, activity (e.g., production, throughput, or number of employees), and emissions for a statistical sample (e.g., 10 percent) of the 10 to 25 tpy sources in the attainment demonstration area. The location and activity level of the remaining 10 to 25 tpy sources can be identified using information from business survey statistics, trade associations, Chambers of Commerce, etc. Emissions for each source shall then be estimated by extrapolating the data collected in the sample survey (e.g., emissions-per-production, per-throughput or per-employee) to the remaining sources. These statistical estimates for the 10 to 25 tpy sources can riot be used as a baseline for new source review or emissions trading policies. This method is described further in Reference 1. 10 ------- 3.7 AREA SOURCES Area sources include those emissions from stationary and non-highway sources that are too small and/or too numerous to be included in the point source inventory, but which can contribute collectively to O3 formation. As such, it is possible for area source emissions to be reported for many of the same source categories as point sources. All service stations and commercial dry cleaners may be considered as area sources in the VOC inventory because the bulk of these facilities emit less than 10 tons per year. In a number of previous SIP submittals, emissions from many small sources have been inadvertently left out of inventories because of a lack of available procedures or lack of emphasis on this portion of *^he inventory. Existing methodologies can be used to estimate emissions from the various area source categories. Detailed procedures are discussed in Reference 1. However, some of these techniques are briefly described herein for emphasis. Large sources are inventoried by use of questionnaires, plant visits, permit data, etc. In many instances, emissions information for smaller sources (i.e., less than 10 tons per year of VOC, and less than 100 tons per year of NOX or CO) is developed via the same methods, since there may be no other alternatives available to accurately inventory sources in some source categories. For this reason, use of point source methods is recommended, even for determining emissions for source categories below the cutoff levels mentioned above. In such cases, States are encouraged to maintain and report individual point source records for each of the smaller source emissions. Emissions from certain area source categories, especially those associated with solvent use, may be estimated on a per capita basis. This procedure may be necessary when the availability of other area source estimating methodologies is limited. Population estimates used in making such emission estimates should be documented. Specific information on per capita factors to be used is contained in Reference 1. Another area source procedure essentially uses nationally derived emissions-per-employee factors to calculate emissions from sources in an area based on areawide employment data. The procedure is best utilized for those source categories where (a) total employment in the source category is known for the area, and (b) where there are numerous sources whose emissions are typically less than the cutoffs mentioned above for point sources, but whose collective emissions represent a significant total. 11 ------- 3.8 MOBILE SOURCES The mobile source emission inventory must include a detailed account of highway vehicle emissions in the demonstration area (MSA/CMSA). Emissions from local traffic, as well as emissions from traffic on major highways, must be included. Particular care should be taken to obtain accurate information of vehicle miles traveled (VMT) and vehicle speed.9 As described below, fuel volatility must also be accurately described for proper calculation of highway vehicle emission estimates. MOBILE4 shall be used in all non-California areas for estimating emissions from mobile sources.11 3.9 FUEL VOLATILITY Gasoline marketing, storage, transportation, and usage account for a significant portion of the VOC inventory. The amount of VOC that is evaporated from fuel sources depends upon the volatility of the fuel, which is characterized by its Reid Vapor Pressure (RVP). The inventory should account for vapor pressure variations by area of the country and time of year. Fuel volatility, in terms of RVP, is one of several inputs required for estimating motor vehicle emissions with MOBILE4. Specific guidance on determining local RVP, as well as other inputs to MOBILE4 for the inventory area is provided in the User's Guide to MOBILE4.9 The RVP used in the base year inventory shall be used in all projected inventories, unless national volatility control is regulated or local volatility control is a strategy option. 3.10 QUALITY ASSURANCE (QA) A QA program shall be implemented to enhance the overall guality of the emission inventory. One of the key elements of this program shall be the development of a quality assurance plan by the agency preparing the inventory. This plan shall include a discussion of the steps that will be taken by the agency to ensure the quality and reliability of the inventory, as described in Reference 13. For example, efforts should be undertaken to ensure that all VOC, NO, and CO point sources are included in the inventory. Comparisons of source listings with independent listings prepared by others (e.g., trade associations, etc.) or with listings derived by the States, based on guidance contained in References 1 and 2, is recommended. In some areas, extensive inventory efforts have been undertaken, such as those in the NAPAP, and should be cross-referenced with SIP emission inventories, and/or compared with State and locally maintained data bases from earlier years. Where discrepancies exist between inventories for an area, resolution of the discrepancies should be documented for current SIP base year emission inventories. 12 ------- Quality checks should be designed into the SIP emission inventory program and be documented in the inventory submittal. Quality checks should include some sampling of calculated data to be recalculated by independent methods (i.e., different data systems or personnel). It is advisable that checks also include some comparisons of process data and emissions with expected ranges to ensure they are reasonable and consistent. Further discussions of quality checks are contained in References 1, 2 and 12. The emission inventory should be reviewed by the agency preparing the inventory for completeness and satisfaction of EPA requirements prior to submittal. The EPA will use the checklist in Appendix B for an initial review of the SIP emission inventories. State and local agencies should also use this checklist for a "pre-submitta!" completeness review. A complete base year emissions inventory shall be submitted by mid-November 1989, approximately one (1) year from the completion of the Workshops For Development Of 03/CO SIP Emission Inventory, to allow EPA to review both the inventory and the quality assurance plan and to identify needed improvements and/or adjustments. [Refer to Section 7 for more information on the schedule for submitting the inventory.] The final SIP emission inventory package, to be submitted with the SIP approximately two (2) years after EPA issues the post-1987 03/CO Policy, shall include the final base year and projected inventories along with supporting documentation. This package also should be reviewed for completeness and satisfaction of requirements (before submittal). 13 ------- 4.0 REASONABLE FURTHER PROGRESS REPORTING REQUIREMENTS To track and verify whether emission reductions that are expected to occur as a result of SIP regulations are being achieved, States shall submit information as required in the RFP program." The three (3) principal requirements of the RFP program are: 1) the initial listing in the SIP of sources to be tracked, along with their projected emissions; 2) an annual RFP status report and updating for permanent changes in emissions for a subset of key emission sources and source categories within nonattainment areas, based on criteria described in Reference 13; and 3) a periodic (3-year) update of the entire inventory. As part of the initial RFP reporting requirements, the States shall include in the SIP a section that: (a) Identifies the total VOC emission reduction expected to occur for all sources as a result of compliance with SIP regulations. (b) Lists a subset of point sources (based on criteria described in Reference 13) to be tracked, the area and mobile source categories affected by SIP regulations, base year actual emissions, SIP regulation(s) affecting each source/source cate- gory, year of expected compliance with specific regulation(s), and projected allowable emissions when source/source category comes into compliance. Projected allowable emissions are calculated estimates for planning purposes that result from the applications of enforce- able SIP emission limits (e.g., Ib/gal), assumptions of further production, and adjustments for control effectiveness. There- fore, these should not be interpreted as enforceable emission limits. However, significant exceedances above these projections in the aggregate may indicate need for corrective action. (c) Tabulates the information described in (b) above to illustrate the annual reductions expected to occur as a result of compliance by source/source category from base year to expected attainment year (includes increases in emissions due to anticipated growth). (d) Presents, in a graphical fashion, the anticipated total emission reduction or total emissions for the subset of sources/source categories to be tracked on a year-to year basis from base year to year of expected attainment. (The emission reduction or total emissions target for the year of attainment shall be based on projected allowable emissions). Following the initial listing of RFP information in the SIP, tracking of RFP must continue through annual reports and periodic 14 ------- (3-year) updates of the emission inventory. Specific requirements for RFP tracking are contained in Reference 13. 15 ------- 5.0 FORMAT FOR SUBMISSION OF INVENTORY DATA The SIP emission inventory shall be reported as follows: 5.1 SUMMARY FORMAT (a) In order to facilitate strategy evaluation, area-to-area consistency, the demonstration area emission inventory should be summarized on a countywide (or equivalent) basis, in the reporting format illustrated in Table 1. other summary formats equivalent to those shown in Table 1 are acceptable, if approved by the EPA Regional Office, and if the alternative formats contain emission estimates in terms of average daily emissions for the ozone season by source category. Emissions should be summarized for source categories that relate to the various RACT control measures, such as those source categories listed in Table 1. The inventory shall include individual tables summarizing seasonally adjusted emissions of VOC, NOX and CO for each county (or equivalent). Each summary table submitted with the base year inventory shall include emissions from stationary point sources, stationary area sources and mobile sources, summarized by source category or vehicle type. Projected emissions summaries shall be submitted with the final SIP emissions inventory. 5.2 INDIVIDUAL POINT SOURCE LISTING In order to facilitate strategy evaluation, emissions for each VOC source inventoried as a point source (i.e., generally those that emit at least 10 TPY) shall be reported in a format similar to that illustrated in Table 2. However, if the alternative method described in Section 3.6 is used to inventory VOC point sources that emit between 10 and 25 tpy, then the data requirements are limited to a listing of each plant name, location, activity (rate of production or throughput, or number of employees) emissions estimate, emission factor, and source category. For sources of NO, and CO that emit at least 100 tpy, a listing of plant names, locations and total plant emissions (tons per day) is required. If point source NOX emission reductions are used to demonstrate attainment for O3, Table 2 must also be submitted for NOX point sources that emit at least 100 tpy. Alternative (including computer produced) formats containing equivalent information are acceptable, if agreed to by the EPA Regional Office. Actual emis-sions shall be included for the base year and allowable emissions projected for the attainment year. Appendix A identifies major point source categories and principal procedures/operations within the categories that should be reported in Table 2. 16 ------- TABLE 1-A Suaaary Table Of VOC missions (Tons Per Day)1 For (County or Equivalent) Storage. Transportation And Marketing Of VOC Oil and Gas Production Natural Gas and Gasoline Processing Other Petroleia Processing Gasoline and Crude Oil Storage4 All (except floating roof) Floating Roof Volatile Organic Liquid Storage VOL - Transfer Ship and Barge Other Barge and Tanker Cleaning Bulk Gasoline Teminals5 Gasoline Bulk Plants' Service Station Loading (Stage I) Service Station Unloading (Stage II) Gasoline Tank Trucks Others (specify) Industrial Processes Petroleua Refineries Vacua Systeis Fugitive Other Lube Oil Manufacture Applicable Regulation3 Base Year (specify year) Point Area Base Line Projection3 (specify year) Point Area ' Revised SIP Strategy Projection3 (specify year) Point Area Typical peak ozone season weekday. List approbations at end of table with brief explanation, (i.e., I-XU = Group I CTG, State Reg XX.X; IHY..Y - Group II CTG, State Reg. TC.Y; etc.). Required with final SIP subaittal. Soae areas aay require projections for aultiple yews. Includes all storage facilities except those at service stations and bulk plants. Eaissions froa loading tank trucks and rail cars. Eiissions froa storage and transfer operations. 17 ------- TABLE 1-A Sunary Table Of VOC Enissions (Tons Per Day)1 For (County or Equivalent) Organic Chenical Manufacture Polyethylene Propylene Polystyrene Others (specify) soon Fugitive Air Oxidation Others (specify) Inorganic Cbeaical Manufacture Fernentation Processes Vegetable Oil Processing Phanaceutical Manufacture Plastic Products Manufacture Robber Tire Manufacture SBR Rubber Manufacture Textile Polyaers and Resin Manufacture Synthetic Fiber Manufacture Iron and Steel Manufacture Coke Ovens Others (specify) Industrial Surface Coating Large Appliances Magnet Hire Autos and Light Trucks Cans Metal Coils Paper Fabric Metal and Hood Furniture Miscellaneous Metal Products Flatuood Products Plastic Products (continued on next page) Applicable Regulation2 Base Year (specify year) Point Area i Base Line Projection3 (specify year) Point Area Revised SIP Strategy Projection3 fspecify year) point Area i 1 Typical peak ozone season weekday. 2 List appreviations at end of table with brief explanation, (i.e., I-XX.X = Group I CTG, State Reg XX.X; II-YY.Y = Group II CTG, State Reg. YY.Y; etc.). 3 Required with final SIP subaittal. Sone areas nay require projections for nultiple years. 18 ------- TABLE 1-A Sunary Table Of VOC Mssions (Tons Per Day)1 For (County or Equivalent) Large Ships Large Aircraft Others (specify) Kon-indurtrial Surface Coating Architectural Coatings Auto Refinishing Others (specify) Other Solvent Use Degreasing Dry Cleaning Perchloroethylene Petroleun Other Graphic Arts Adhesives Cutback Asphalt Solvent Extraction Processes Consuaer/Conercial Solvent Use Others (specify) Haste Disposal Municipal Haste Coabustion Landfills TSDFs poms rws Industrial Boiler Co-firing Others (specify) Applicable Regulation2 Base Year (specify year) Point Arei_ Base Line Projection3 f specify year! Point Area Revised SIP Strategy Projection3 (sDecify yearl Point Area 1 Typical peak ozone season weekday. 2 List appreviations at end of table with brief explanation, (i.e., I-XX.X = Group I CTG, State Reg XU; IHY.I = Group IICTG, State Reg. YY.Y; etc.). 3 Reguired with final SIP subaittal. Soae areas nay require projections for aultiple years. 19 ------- TABLE 1-A Sumary Table Of VOC Enissions (Tons Per Day)1 For (County or Equivalent) Other Miscellaneous Sources Fuel Coobustion Forest, Agricultural, and Other Open Burning Pesticide Applications Stationary Internal Coabustion Engines Mobile Sources Highway Vehicles Applicable Regulation2 Light Duty Gasoline Vehicles (LDGV) Light Duty Diesel Vehicles (LDDV) Light Duty Gasoline Trucks Type 1 (<6000 Ibs) (LDGTl) Type 2 (6000-8500 Ibs) (LDGT2) Light Duty Diesel Powered Trucks (LDDT) Heavy Duty Gasoline Trucks (HDGV) Heavy Duty Diesel Trucks (HDDV) Motorcycles (MC) Non-highway Vehicles Rail Aircraft Vessels Other •Mobile Sources Total: Stationary Sources Total: Grand Total For All Sources: Base Year (specify year) Point Area Base Line Projection3 (specify year) Point Area Revised SIP Strategy Projection3 f specify year) Point Area 1 Typical peak ozone season weekday. 3 List appreviations at end of table with brief explanation, (i.e., I-XX.X = Group I CTG, State Reg XX.X; II-YY.Y = Group II CTG, State Reg. YY.Y; etc.). 3 Required with final SIP subiittal. Sone areas nay require projections for nultiple years. 20 ------- TABLE 1-B Sumary Table Of HO, Emissions (Tons Per Day)1 For (County or Equivalent) External Fuel Coabustion Utility Boilers Industrial Boilers Conercial, institutional, Residential Other External Fuel Coabustion Stationary Internal Coibustion Reciprocating Engines Gas Turbines Other Coibustion Waste Disposal Open Burning Other Industrial Processes Cheiical Manufacturing Adipic Acid Nitric Acid Other Iron and Steel Mineral Products Ceient Glass Other Petroleua Mining Other Mobile Sources Highway Vehicles Light Duty Gasoline Vehicles (LDGV) Light Duty Diesel Vehicles (LOT) Light Duty Gasoline Trucks Type 1 (<6000 Ibs) (LDGT1) Type 2 (6000-8500 Ibs) (LDGT2) Light Duty Diesel Povered Truclcs (LDDT) Heavy Duty Gasoline Trucks (HDGV) Heavy Duty Diesel Trucks (SDDV) fctorcycles (MC) Base Year (specify vearl Point Area Base Line Projection2 (specify year) Point Area RtV^BGU SIP strategy Projection2 (specify yearl Point Area 1 Typical peak ozone season weekday. 2 Required with final SIP subnittal. Soae areas nay require projections for nultiple years. 21 ------- TABLE 1-B Suaaary Table Of HO, Enissions (Tons Per Day)1 For (County or Equivalent) 1 Non-highway Vehicles Rail Aircraft Vessels Other Mobile Sources Total: Stationary Sources: >250a Effective Stack Height: Subtotal Other Stationary Sources: Subtotal Grand Total For All Sources: Base Year (specify year) Point Area Base Line Projection2 (specify year) Point Area Revised SIP Strategy Projection2 (specify year) Point Area .1. -I. -I. 1 Typical peak ozone season weekday. 2 Required with final SIP subaittal. Sone areas nay require projections for nultiple years. 22 ------- TABLE 1-C SuMary Table Of CO Eaissions (Tons Per Day)1 For (County or Equivalent) External Fuel Coabustion Utility Boilers Industrial Boilers Conercial, Institutional, Residential Other External Fuel Conbustion Stationary Internal Coabustion Reciprocating Engines Gas Turbines Other Conbust *.i Waste Disposal Other Industrial Processes Chenical Manufacturing Iron and Steel Mineral Products Petroleun Refining Other Habile Sources Highway Vehicles Light Duty Gasoline Vehicles (LDGV) Light Duty Diesel Vehicles (LDDV) Light Duty Gasoline Trucks Type 1 (<6000 Ibs) (LDGT1) Type 2 (6000-8500 Ibs) (LDGT2) Light Duty Diesel Powered Trucks (LDDT) Heavy Duty Gasoline Trucks (HDGV) Heavy Duty Diesel Trucks (HDDV) Motorcycles (K) Son-highway Vehicles Rail Aircraft Vessels Other Base Year Point Area Base Line Projection2 (specify year) Point Area Revised SIP Strategy Projection2 (specify year) Point Area 1 Typical peak ozone season weekday. 2 Required with final SIP subnittal. Soae areas say require projections for mltiple years. 23 ------- TABLE 1-C Sunary Table Of CO Enissions (Tons Per Day)1 For (County or Equivalent) Mobile Sources Total: Stationary Sources: Grand Total For All Sources: Base Year Point Area Base Line Projection2 (specify year) Point Area Revised SIP Strategy Projection2 (specify year) Point Area Typical peak ozone season weekday. 2 Required with final SIP subaittal. Soie areas nay require projections for lultiple years. 24 ------- Table 2. Emissions Information for Individual Processes Within a Point Source Facility1 Plant Intonation Pollutant (VOC, me): Plant Kane: Base Year (1987 or 1988): NEDS ID (State, County, Plant): Street Address, City, State: Projected Attainnent Year: Model Area (County, Tovnsnip, or Grid Code): SlCCode(s):2 Total Banked Hussions (tons/yr): Base Year Point Intonation NEDS Point Process ID Description Operating Schedule3 CTG Applicable Emission Compliance Category (hr/dy) (dy/vk) (rt/yr) Regulation Liiitation Year (I,II,III) Base Year Sequent Intonation Etission NEDS Process Control Eaission Factor Rule 0, Season Banked Point Process Rate Control Efficiency Estiiation (Ib/process Effectiveness Eiissions Missions ID SCC* Rate Units5 (/day)6 Equipient7 (*) fethod* rate unit) (t) (Its/day) (tons/yr) 25 ------- Table 2. Emissions Information for Individual Processes Within a Point Source Facility (cont.)1 Projection Year Intonation Projection Year Projected Projected Baseline Rule SIP Strategy Point Control Efficiency Growth Eaissions10 Applic. Eiission Coipliance Effectiveness Eaissions11 ID SCC Equipment (I) Factor (Ite/day) Regulation Liiitation Year (I) (Us/day) Kotes: 1. The foriat presented in this table is reconended for inventorying point sources that eut voc. This fonat is also reconended for facilities cutting BOX in areas where NOx eiission reductions are anticipated as part of the attairaent strategy. Other fonats with equivalent infonation nay be substituted. I. Standard Industrial Classification code(s) describing plant operations. 3. Indicate hours per day and days per week for typical ozone season operating schedule. 4. Source Classification Code (SCC). See Reference 8. 5. Operating rate units (eg., thousand gallons burned) associated with SCC or other eiission factor. 6. Actual process or operating rate for typical ozone season weekday in units listed in previous coluin, This lay be oiitted for sources where emissions are asi dependent on process rate. 7. Indicate appropriate control equipient code(s). See Reference l, page 5-9 for listing of AEROS control equipient codes. 8. Method used to estiiate eiissions. 0 = not applicable; 1 = stack test; 2 = aaterial balance; 3 = calculated using SCC eiission factor; 4 = guess; 5 = calculated using non-SCC eiission factor; 6 = new construction, not yet operational; 7 = facility closed, operations ceased. 9. Factor used to estiiate increase in eiissions due to growth since base year. 10. Based on allowable eiissions and reflecting increases or decreases in eiissions due to growth since the base year and enforceable eiission rates resulting froi regulations with coipliance deadlines prior to 1/1/88. Should not reflect reductions resulting froi post-87 SIP strategy. 11. Based on allowables eiissions and reflecting changes in projected baseline eiissions due to post-87 SIP strategy. 26 ------- 6.0 DOCUMENTATION OF THE INVENTORY Inventory documentation shall include a narrative report describing the procedures, data and assumptions used in compiling the base year and projected attainment year inventories. Documentation of the base year inventory shall be submitted with the inventory (i.e., within twelve (12) months of receipt of the guidance). Similarly, documentation for the projected emissions shall accompany the projected inventory due with the SIP. [See Section 7 for a discussion of the schedule for submitting emission inventory information.] Items to be included in the documentation are listed below: A. The geographic areas included in the inventory. B. The population of the area, as well as the source of the population data used in making emission estimates and projections. C. Data, assumptions and procedures used in determining or projecting emissions. Techniques used to estimate area source emissions. Activity base (e.g., employment, gas usage) and projection levels should be documented. Use and basis of emission factors, other than those in AP-42, for stationary sources should be provided. Procedures and data used for exclusion of nonreactive VOC and for seasonally adjusting the inventory totals should likewise be documented. D. Procedures and results of the emission inventory QA program, including data "reasonableness" ranges and QA objectives. E. Information shall be reported that describes the basis for highway vehicle emissions estimates, as listed below. In cases where default parameters from MOBILE4 are used, this should be stated. I. Description of procedures and models used to estimate base year and future year transportation parameters. 2. Description of the travel data base and any subsequent updates. When possible, estimates of the degree of accuracy and other statistical parameters should be included. 3. Description of traffic counting programs. Estimates of the degree of accuracy of VMT estimates based on traffic counts should be included. 4. Description of methods used to estimate vehicle speeds. Special speed studies should be documented. 27 ------- 5. Description of methods for estimating truck travel parameters (VMT, speed, etc.). 6. Description of methods for estimating traffic parameters (VMT, speed, etc.) for local (off-network) traffic. 7. Description of methods used to estimate VMT in the hot and cold start modes. 8. Description of method used to estimate trips per day and miles per trip in calculating evaporative emissions. 9. Description of how local fuel volatility (i.e., RVP) was determined. 10. Description of methods used to calculate emissions, including a description of how data were aggregated and emission factors applied. 11. Description of how other emission parameters (such as vehicle age distribution, average annual miles driven by model year) were obtained. 28 ------- 7.0 SCHEDULE FOR SUBMISSION OF INVENTORY ITEMS 7.1 INITIAL INVENTORY SUBMITTAL 1. A complete base year emissions inventory (e.g., 1987) for VOC, NO, and CO, including data elements described in Sections 3 and 5 and documentation described in Section 6, shall be submitted to the EPA Regional Office no later than twelve (12) months after receipt of the emission inventory guidance. EPA will return comments on the initial inventory submittals, as agreed upon with the Regional Office, generally within three (3) months of receipt of the inventories. EPA will not provide "preapproval" of the inventory, but rather EPA's review is intended as part of the QA process to identify any deficiencies or needed improvements/adjustments before the final inventory is submitted. EPA's review of the inventory should not delay development of the SIP. 2. A quality assurance plan describing the steps taken by the agency preparing the inventory to assure the completeness and reliability of the emissions inventory. 7.2 FINAL INVENTORY SUBMITTAL 1. Final base year emission inventories including both detailed point source data and summarizes by source category and county (as discussed above), shall be submitted to the EPA Regional Office with the SIP. These inventories shall reflect EPA comments to the initial inventory submittals. 2. Projected baseline inventories and "new or revised SIP strategy" attainment year inventories of reactive VOC, NO, and CO, summarized by source category (see Section 5, Table 1), shall be submitted to the EPA Regional Office with the SIP. The emissions summarized should represent totals for each county (or equivalent ) within the designated nonattainment area. 3. For point sources that emit VOC equal to or greater than 10 tpy, a final listing of process information and VOC emission estimates for each source (see Section 5, Table 2) shall be submitted to the EPA Regional Office with the SIP. A final listing of plant names, locations and emission estimates shall be submitted for sources that emit NOX or CO equal to or greater than 100 tpy. For areas where point source NOX emission reductions are used to demonstrate attainment for O3, a listing of process information and NOX emission estimates (see Section 5, Table 2) for point sources within the nonattainment area that emit NOX equal to or greater than 100 tpy shall be submitted with the SIP. This listing shall be for the base year and for the projected baseline and "revised SIP strategy" emission estimates. 29 ------- 4. A report that documents the procedures and assumptions in compiling all inventories discussed above shall be submitted to the EPA Regional Office with the SIP. [Refer to Section 6 for a discussion of documentation requirements.] 5. A subset of point sources to be tracked under RFP reporting requirements. Also, tabulation and graphical representation of emission reductions or total emissions expected for point source subset on a year-to-year basis from base year to expected attainment year. 30 ------- 8.0 REFERENCES 1. Procedures For The Preparation Of Emission Inventories For Precursors Of Ozone. Volume If EPA-450/4-88-021, U. S. Environmental Protection Agency, Research Triangle Park, NC, December 1988. 2. Procedures For Emission Inventory Preparation. Volumes I-V. EPA-450/4-81-026, a-e, U. S. Environmental Protection Agency, Research Triangle Park, NC, September 1981. 3. Statistical Abstracts Of The United States. 1988. U. S. Department of Commerce, Appendix II. 4. Federal Register. Volume 42, No. 131, July 8, 1977, page 35314. 5. Federal Register, Volume 45, No. 142, July 22, 1980, page 48941. 6. Compilation Of Air Pollutant Emission Factors. Volume I - Stationary Point And Area Sources. Fourth Edition and subsequent Supplements, AP-42, U. S. Environmental Protection Agency, Research Triangle Park, NC, September 1985. 7. Compilation Of Air Pollutant Emission Factors. Volume II - Mobile Sources, Fourth Edition, AP-42, U. S. Environmental Protection Agency, Ann Arbor, MI, September 1985. 8. Criteria Pollutant Emission Factors For The 1985 NAPAP Inventory, EPA-600/7-87-015, U. S. Environmental Protection Agency, Research Triangle Park, NC, May 1987. 9. Procedures For Emission Inventory Preparationf Volume IV; Mobile Sources (Section 4, Emissions from Highway Vehicles, is being revised for distribution in February 1989), EPA- 450/4-81-026d, U. S. Environmental Protection Agency, Research Triangle Park, NC, December 1988. 10. Procedures For The Preparation Of Emission Inventories For Volatile Organic Compounds. Volume lit Emission Inventory Requirements For Photochemical Air Quality Simulation Models, EPA-450/4-79-018, U. S. Environmental Protection Agency, Research Triangle Park, NC, September 1979. 11. User/s Guide To MOBILE4 (Mobile Source Emissions Model - Currently Under Development, Available February 1989), U. S. Environmental Protection Agency, Ann Arbor, MI. 31 ------- 12. Guidance For The Preparation Of Quality Assurance Plans For Ozone/Carbon Monoxide SIP Emission Inventories. EPA-450/4- 88-023, U. S. Environmental Protection Agency, Research Triangle Park, NC, December 1988. 13. "Revised Guidance For Tracking Reasonable Further Progress (RFP) In Ozone Control Programs," Monitoring and Data Analysis Division, U. S. Environmental Protection Agency, Research Triangle Park, NC, September 1986. 32 ------- APPENDIX A Individual Point Source Summary (Source Category List For Completing Table 2) ------- APPENDIX A INDIVIDUAL POINT SOURCE SUMMARY Storage. Transportation And Marketing Of Petroleum Products and Volatile Organic Liquids (VOLI Oil And Gas Production Storage Fugitives Other Process Units (specify) Natural Gas And Gasoline Processing Storage Fugitives Other Process Units (specify) Oil Processing Storage Fugitives Other Process Units (specify) Tank Farms (specify material stored) Fixed Roof Tanks External Floating Roof Tanks Primary Seals Secondary Seals Internal Floating Roof Tanks Bulk Gasoline And VOL Terminals Leaks From Valves, Flanges Meters, Pumps Vapor Collection Losses Vapor Control Unit Losses Filling Losses From Uncontrolled Loading Racks Tank Truck Vapor Leaks From Loading Of Gasoline Non-tank Farm Storage Gasoline Bulk Plants Gasoline Bulk Storage Loading And Unloading Racks (Controlled And Uncontrolled) Tank Truck Vapor Leaks From Loading And Unloading Of Gasoline Leaks From Valves, Flanges, Meters, Pumps Barge And Tanker Transfer Gasoline Loading/Barge Crude Oil Ballasting/Tanker Barge And Tanker Cleaning A-l ------- Industrial Processes Petroleum Refineries Process Drains And Wastewater Separators Vacuum Producing Systems Process Unit Turnarounds Fugitive Leaks From Seals, Valves, Flanges Pressure Relief Devices, Drains Other Process Emissions Such As Heaters, Boilers Cat Cracker Regenerators (specify) Lube Oil Manufacture Pharmaceutical Manufacture Process Units Such As Vacuum Dryers, Reactors, Distillation Units, Filters, Extractors, Centrifuges, Crystallizers Major Production Equipment Such As Exhaust Systems And Air Dryers Storage And Transfer Other Process Units (specify) Rubber Tire Manufacture Undertread And Sidewall Cementing Bead Dipping Bead Swabbing Tire Building Tread End Cementing Green Tire Spraying Tire Curing Solvent Mixing Solvent Storage Other Process Units (specify) Styrene Butadiene Rubber Manufacture Slowdown Tanks Steam Stripper Prestorage Tanks Other Process Units (specify) Vegetable Oil Oil Extraction And Desolventization Mean Preparation Oil Refining Fugitive Leaks Solvent Storage Other Process Units (specify) A-2 ------- Organic Chemical Manufacture (specify major chemicals) Fugitive Leaks From Seals, Valves, Flanges, Pressure Relief Devices, Drains Air Oxidation Units Waste Water Separators Storage And Transfer Other Process Units (specify) Polymer And Resin Manufacture Catalyst Preparation Reactor Vents Separation of Reactants, Solvents And Diluents From Product Raw Material Storage Solvent Storage Other Process Units (specify) Plastic Products Manufacture Mold Release Solvent Consumption Adhesives Consumption Other Process Units (specify) Inorganic Chemical Manufacture Fugitive Leaks From Seals, Valves, Flanges, Pressure Relief Devices, Drains Storage And Transfer Other Process Units (specify) Fermentation Processes Fermentation Tank Venting Aging/Wine or Whiskey Other Process Units (specify) Iron And Steel Manufacture Coke Production Coke Pushing Coke Oven Doors Coke Byproduct Plant Coke Charging Coal Preheater Topside Leaks Quenching Battery Stacks Sintering Electric Arc Furnaces Other Process Units (specify) A-3 ------- Synthetic Fiber Manufacture Dope Preparation Filtration Fiber Extrusion - Solvent Recovery Takeup Stretching, Washing, Drying, Crimping, Finishing Fiber Storage - Residual Solvent Evaporation Equipment Cleanup Solvent Storage Other Process Units (specify) Industrial Surface Coating Large Appliances Cleaning And Pretreatment Prime Spray, Flow, Or Dip Coating Operations Topcoat Spray Coating Mixing Coating And Solvent storage Equipment Cleanup Other Process Emissions (specify) Magnet Wire Cleaning And Pretreatment Coating Application And Curing Coating Mixing Coating And Solvent Storage Equipment Cleanup Other Process Emissions (specify) Automobiles And Light Duty Trucks Cleaning And Pretreatment Prime Application, Electrodeposition, Dip Or Spray Prime Surfacing Operations Topcoat Operation Repair Topcoat Application Area Coating Mixing Coating And Solvent Storage Equipment Cleanup Other Process Emissions (specify) Cans Cleaning And Pretreatment Two Piece And Exterior Base Coating Interior Spray Coating Sheet Basecoating (Interior) Sheet Basecoating (Exterior) Side Seam Spray Coating End Sealing Compound Litography Over Varnish Coating Mixing Coating And Solvent Storage A-4 ------- Cans (continued) Equipment Cleanup Other Process Emissions (specify) Paper Coating Operations Coating Mixing Coating And Solvent Storage Equipment Cleanup Other Process Emissions (specify) Coil Coating Prime Coating Finish Coating Solvent Mixing Solvent Storage Equipment Cleanup Other Process Emissions (specify) Fabric Coating Operations Coating Mixing Coating And Solvent Storage Equipment Cleanup Other Process Emissions (specify) Metal And Wood Furniture Cleaning And Pretreatment Coating Operations Coating Mixing Coating And Solvent Mixing Equipment Cleanup Other Process Emissions (specify) Flatwood Products Filter Sealer Basecoat Topcoat Inks Coating Mixing Coating And Solvent Storage Equipment Cleanup Other Process Emissions (specify) Plastic Products Cleaning And Pretreatment Coating Operations, Flow, Dip, Spray Coating Mixing Coating And Solvent Storage Equipment Cleanup Other Process Emissions (specify) A-5 ------- Large Ships Cleaning And Pretreatment Prime Coat Operation Topcoat Operation Coating Mixing Coating And Solvent Storage Equipment Cleanup Other Process Emissions (specify) Large Aircraft Cleaning And Pretreatment Prime Coat Operation Topcoat Operation Coating And Solvent Storage Equipment Cleanup Other Process Emissions (specify) Miscellaneous Metal Parts And Products Cleaning And Pretreatment Coating Operations, Flow, Dip, Spray Coating Mixing Coating And Solvent Storage Equipment Cleanup Other Process Emissions (specify) Other Solvent Use Dry Cleaning Perchloroethylene Petroleum Other Degreasing Open Top Vapor Degreasing Conveyorized Degreasing - Vapor Conveyorized Degreasing - Cold Cleaning Solvent Extraction Processes Adhesives Adhesive Application Solvent Mixing Solvent Storage Other Process Emissions (specify) Grahic Arts Letter Press Rotogravure Offset Lithography Ink Mixing Solvent Storage A-6 ------- Waste Disposal Municipal Waste Combustion RDF Mass Burn Co-fired Other Landfills TSDFs Lagoons Tanks Mixing Aeration Landfills Other POTWs Tanks Lagoons Aeration Mixing Digestion Other ITWs Tanks Lagoons Aeration Mixing Digestion Other Industrial Boilers Co-firing (specify major substances and co-firing fuels, such as oil, gas, coal, etc.) A-7 ------- APPENDIX B EPA Checklist For Reviewing Post-1987 Ozone SIP Emission Inventories ------- REVIEW OF POST 1987 03 SIP EMISSION INVENTORIES Developed By: Monitoring and Reports Branch Technical Support Division Office Of Air Quality Planning And Standards AREA: RECEIPT DATES: BY: BY: (name, Organization) BY: (name, Organization) BY: (name, Organi zation) REVIEW COMPLETION DATES*: BY: (name, Organization) BY: BY: BY: REGION CONTACTS: STATE CONTACTS: *Attach copies of review correspondence, B-l ------- Enclosed is a checklist developed by the Monitoring and Reports Branch (MRS) of the Technical Support Division (TSD), Office of Air Quality Planning and Standards (OAQPS), to evaluate the basic adequacy of the Post 1987 O, State Implementation Plan (SIP) emission inventories. The primary objective in using this checklist is to review each inventory for national consistency. A secondary objective is to assist the Regional Offices in their evaluation of the technical soundness of each data base. OAQPS will focus its reviews on the draft emission inventories to be submitted before SIPs are included. As such emphasis will necessarily be placed on the base year inventories due at that time. Upon completion of this review process, OAQPS will send a copy of the completed checklist to the designated Regional Office ozone SIP emission inventory contact. Please direct any correspondence regarding this checklist to E. L. Martinez, Chief, Criteria Emissions Section, Mail Drop 14, or call him at FTS 629-5575. B-2 ------- CHECKLIST OF '87 O, SIP INVENTORIES Note: "Post '87 requirements" refers to Emission Inventory Requirements For Post '87 Ozone State Implementation Plans. 1. VOC/NOX/CO Summary Tables a. Does the subroittal contain completed VOC/NOX/CO summary tables, per Table 1 in Post '87 Requirements, for: i. the base year inventory (draft inventory)? Yes No ii. the base line projection year inventory (final inventory)? Jlj Yes Hi No Comment? b. If the suggested format is not followed, is a format used that contains equivalent information? HI Yes Jlj No Comment? c. In the VOC/NO./CO summary tables, is the attainment year specified? |~| Yes j~| No Year? 19 Comment? B-3 ------- d. In the VOC/NOyco summary tables, is the point/area source distinction made? Hi Yes \~\ No Comment? e. In the VOC/NOX/CO summary tables, have the emissions been seasonally adjusted? Yes |_! No Comment? f. Have the suggested RACT source category distinctions been maintained? HI Yes HI No Comment? Are emissions reported as reactive VOC? Ill Yes II! No Comment? h. Is the geographical area specified? Hi Yes Hi No Comment? B-4 ------- 2. Point Source Listing a. Does the submittal contain a point source listing, per Table 2 in Post '87 Reguirements, for the base year? Yes | _}' No Comment? b. Are the principal operations specified with corresponding emission totals? ill Yes j-j No Comment? 3. Documentation - General Considerations a. Is there documentation accompanying the summary tables and point source listing? ill Yes Hi No Comment? b. Does the documentation specify who did the inventory? IIJ Yes Jlj No Comment? E-5 ------- c. Does the documentation define the area covered by the inventory? JlJ Yes JlJ No Comment? d. Does the documentation tell how nonreactive VOC were excluded from the emission totals? HI Yes HI No Comment? e. Does the documentation describe how the seasonal and weekday adjustments were made? Ill Yes JlJ No Comment? 4. Specific Documentation - Point Sources a. Are point source cutoff levels defined? HI Yes Jlj No What are they? Do they exceed 25 kg/day (10 TPY) for VOC or 250 kg/day (100 TPY) for NOX or CO? {II Yes HI No Comment? B-6 ------- b. Has the inventory been scaled up in some manner to account for points emitting less than the cutoff level(s)? Hi Yes Jl| No Comment? Do all major point source categories appear to be included? Hi Yes Hi No Have all voc and NOX emission source categories in NAPAP inventory been addressed in SIP inventory? !l! Yes Jl! No Comment? d. Have material balance techniques been used to estimate VOC emissions from solvent-using facilities? HI Yes HI No Have source test results been used to identify emissions? |lj Yes |lj No Typical age range if source test data: Comment? e. Are summer conditions of higher temperatures (and appropriate Vapor Pressures for gaoline) reflected in the VOC emission estimates made for petroleum product marketing and storage operations? ~ Yes |I j No B-7 ------- Do other volatile organic chemical storage calculations use appropriate temperature and throughput assumptions? IIj Yes j~| No Comment? f. Are the latest (through Fourth Edition, Supplement A) AP-42 emission factors used for calculating voc emission estimates for petroleum product marketing and storage operations? ili Yes ilj No Have "gapfilling" emission factors from NAPAP been used? Jlj Yes |~j No Comment? Is the SIP emission inventory produced from a computer data base? Yes !""! No If so, what emission inventory system is used? (e.g., SAM/EIS/P&R) . Are example emission calculations shown for several major point source categories? Yes } _', No Comment? B-8 ------- 5. Specific Documentation - Area Sources a. Are all of the major area sources listed in Table 4.1-1 of Procedures For The Preparation Of Emission Inventories For Volatile Organic Compounds, Volume I, (Third Edition) included in the inventory? Hi Yes (I! No Comment? When certain facilities within one of the source categories listed in Table 4.1-1 are covered as point sources, have the associated emissions been subtracted from those emissions estimated for the corresponding area source category? !lj Yes Jl! No Comment? c. Have the per capita factors from Procedures For The Preparation Of Emission Inventories .or Volatile Organic Compounds, Volume I, (Third Edition) been used to compute emissions? \~\ Yes Jlj No If not, have techniques been used that appear to be technically sound, and are these alternate methods documented? II! Yes Jlj No Comment? B-9 ------- d. Has local activity levels information been used? Yes }~j No Comment? e. Does gasoline usage fall in the range of 400 to 800 gallons per capita per year? j_j Yes !~j No Are emissions included from underground tank breathing and trucks in transit? Yes j No Comment? f. Have the technical points in Attachment I of the check list (regarding per capita factors) been considered? j~j Yes {~j No Comment? 6. Specific Documentation - Highway Vehicles Is the following information reported? a. Description of procedures and models used to estimate base year and future year transportation parameters. j~j Yes }~| No Comment? B-10 ------- b. Description of the travel data base and any subsequent updates. When possible, estimates of the degree of accuracy and other statistical parameters should be included. Yes [_! No Comment? c. Description of traffic counting programs. Estimates of the degree of accuracy of VMT estimates based on traffic counts should be included. II! Yes Jlj No Comment? d. Description of methods used to estimate vehicle speeds. Special speed studies should be documented. Sll Yes {Ij No Comment? e. Description of methods for estimating traffic parameters (VMT, speed, etc.) for local (off -network) traffic. Yes j No Comment? B-ll ------- f. Description of methods used to estimate vehicle hot and cold start soak emissions. Yes Jj No Comment? Description of methods used to calculate emissions, including a description of how data were aggregated and emission factors applied. l~~l v«»- l~' j | 160 j j Comment? h. Description of how other emission parameters (such as vehicle age distribution, average annual miles driven by model year) were obtained. Jlj Yes jlj No Comment? 7. Specific Documentation - Projections a. Does the inventory submittal specify how growth is incorporated into the baseline projection inventory? HI Yes |lj No Comment? B-12 ------- b. Are the population projections used in the SIP inventory consistent with those projections used in water quality planning and design of wastewater treatment facilities? Jl| Yes Jl| No Comment? Are reasonable surrogates used for "growing" activity levels and emissions, such as those indicators shown in Procedures For The Preparation Of Emission Inventories For Volatile Organic Compoundsr Volume I, (Third Edition)? Jlj Yes \~\ No Comment? d. Does the baseline projection take into account "on-the-books" control measures, specifically those in earlier SIPS (1979, 1982)? j~j Yes j~| No Comment? e. Are specific examples shown of how projections were made for specific source categories? HI Yes HI No Comment? B-13 ------- f. Are projections for very large VOC emitters generally considered on a plant-by-plant basis rather than in aggregate? ill Yes Hi No Comment? 8. Specific Documentation - Quality Assurance a. Has a quality assurance effort been made? Yes HI No Comment? b. Were the RACT or other industrial directories compared with the point source file to determine the possibility of missing sources? j~| Yes j~| No Comment? c. Were emissions data and point source listings compared with other emissions inventories (i.e., 1985 NAPAP)? HI Yes Hi No Comment? B-14 ------- d. If the emission inventory was developed from a computer data base (mainframe, mini, micro, or PC), are the emission factor files used in calculations referenced (i.e., AP-42, source specific test, other)? j~| Yes j~j No Are nonhighway area source inventory equations used in the file documented or referenced? |~j Yes j~{ No Comment? e. Are any data reasonableness checks made on emissions (i.e., comparison with national or regional averages)? j~{ Yes j~j No Comment? f. Do the base year travel and emission estimates fall within the ranges presented in Guidelines For Review Of Highway Emission Inventories For 1982 SIPs (EPA-400/12-80-002)? |~! Yes |~| No Comment? B-15 ------- Attachment I Points Regarding Use Of Per Capita Factors National per capita factors are available in Volume I to estimate (or crosscheck) reactive VOC emissions from the following area source categories. ° Small cold cleaning (degreasing) - 3 Ib/capita-yr Note; Open top vapor and conveyerized cleaners are not covered by this factor. 0 Dry cleaning -1.2 Ib/capita-yr (commercial plants) 0.3 Ib/capita-yr (coin-op plants) 1.5 Ib/capita-yr (total) Note; Industrial plants are not covered by these factors. 0 Architectural surface coating - 4.6 Ib/capita-yr Note; This includes thinning and cleanup solvent. 0 Automobile refinishing - 1.9 Ib/capita-yr Note; Where employment information for SICs 7531 and 7535 is available, EPA recommends applying a factor of 2.6 ton/employee-yr to employment rather than applying a per capita factor. 0 Graphic arts (printing) - 0.8 Ib/capita-yr Note; This per capita factor covers < 100 ton per year solvent users, and assumes > 100 TPY sources are covered as point sources. 0 Miscellaneous consumer/commercial solvent - 6.3 Ib/capita-yr Note; This factor is not a catchall to compensate for missing industrial solvent use not covered in the point source inventory. B-16 ------- TECHNICAL REPORT DATA (Please read Instructions on the reverse before completing) 1. REPORT NO. EPA-&SOM-88-Q19 3. RECIPIENT'S ACCESSION NO. 4. TITLE AND SUBTITLE Emission Inventory Requirements For Post-1987 Ozone State Implementation Plans 5. REPORT DATE 1 QSfi 6. PERFORMING ORGANIZATION CODE 7. AUTHOR(S) David C. Misenheimer 8. PERFORMING ORGANIZATION REPORT NO. 3. PERFORMING ORGANIZATION NAME AND ADDRESS Criteria Emissions Section Monitoring And Reports Branch Technical Support Division Office Of Air Quality Planning And Standards 10. PROGRAM ELEMENT NO. 11. CONTRACT/GRANT NO. 12. SPONSORING AGENCY NAME AND ADDRESS Research Triangle, NC 27711 13. TYPE OF REPORT AND PERIOD COVERED 14. SPONSORING AGENCY CODE 15. SUPPLEMENTARY NOTES 16. ABSTRACT This document describes the final emission inventory requirements related to preparation and submission of post-1987 ozone State Implementation Plans (SIPs) for those States required to revise their plans after December 31, 1987. Addressed in the document are emission inventory requirements relating to geographic area of coverage, point source cutoff size specifications, sources to be included, pollutants of interest, data reporting formats, documentation requinements, quality of data base, years to be addressed, and schedule for inventory submission. 17. KEY WORDS AND DOCUMENT ANALYSIS DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS C. COS AT I Field/Group 18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (ThisReport) 21. NO. OF PAGES 68 20. SECURITY CLASS (Thispage) 22. PRICE EPA Fo»m 2220-1 (R«». 4-77) PREVIOUS EDITION is OBSOLETE ------- |