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
------- |