United States
          Environmental Protection
          Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/4-88-023
DECEMBER 1988
          Air
vvEPA
        GUIDANCE FOR THE
     PREPARATION OF QUALITY
  ASSURANCE PLANS FOR O3/CO
    SIP EMISSION INVENTORIES

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                             EPA-450/4-88-023
       GUIDANCE  FOR THE
   PREPARATION  OF QUALITY
ASSURANCE PLANS FOR O3/CO
  SIP EMISSION INVENTORIES
                    BY

               SHARON L. KERSTETER
                REBECCA BATTYE
              ALLIANCE TECHNOLOGIES
              CHAPEL HILL, NC 27514
             EPA CONTRACT NO. 68-02-4396
         EPA PROJECT OFFICER: WILLIAM B. KUYKENDAL
        OFFICE OF AIR QUALITY PLANNING AND STANDARDS
          U. S. ENVIRONMENTAL PROTECTION AGENCY
           RESEARCH TRIANGLE PARK, NC 27711
                 DECEMBER 1988   U.S. Environmental Protection Agency
                           Region 5, Library (5PL-16)
                           230 S. Dearborn Street, Room 1670 _,
                           Chicago, IL  60604

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This report has been reviewed by the Office Of Air Quality Planning And Standards, U. S. Environmental Protection
Agency, and has been approved for publication as received from the contractor.  Approval does not signify that the
contents necessarily reflect the views and policies of the Agency, neither does mention of trade names or commercial
products constitute endorsement or recommendation for use.
                                           EPA-450/4-88-023

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                               TABLE OF CONTENTS
Section                                                             Page

1.0  INTRODUCTION	    1-1

     1.1  Purpose and Overview of Document	    1-1
     1.2  Definition of Quality Assurance	    1-1
     1.3  Quality Assurance Coordinator	    1-3

2.0  QUALITY ASSURANCE POLICY STATEMENT	    2-1

     2.1  Policy Statement	    2-1

3.0  SUMMARY	    3-1

     3.1  Program Summary	    3-1

4.0  TECHNICAL CONSIDERATIONS	    4-1

     4.1  Introduction	    4-1
     4.2  Planning	    4-1
          4.2.1  Resource Allocation for Quality Assurance	    4-1
          4.2.2  Prioritizing Sources and Data Elements	    4-3
          4.2.3  Personnel Training	    4-5
          4.2.4  Schedule and Project Planning	    4-5
          4.2.5  Data Sources	    4-6
          4.2.6  Data Checking Procedures	    4-6
     4.3  Data Collection and Analysis	    4-6
          4.3.1  Identification of Emissions Sources	    4-6
          4.3.2  Collection Procedures	    4-7
          4.3.3  Data Quality	    4-8
          4.3.4  Emission Estimation Methods	    4-8
          4.3.5  Calculations	    4-10
          4.3.6  Validation Procedures	    4-11
     4.4  Data Handling	    4-13
          4.4.1  Data Coding and Recording	    4-13
          4.4.2  Data Tracking	    4-13
          4.4.3  Correcting Data	    4-14
          4.4.4  Missing Data	    4-15
          4.4.5  Review of Estimates	    4-15
     4.5  Data Reporting	    4-16

5.0  SYSTEM AUDITS	    5-1

     5.1  Introduction	    5-1
     5.2  Internal Audits	    5-1
     5.3  External Audits	    5-1

6.0  REFERENCES	    6-1
                                      111

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APPENDIX A	   A-l
                                      IV

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                                    FIGURES


Number                                                              Page

1.1-1     Outline of example quality assurance (QA) plan	   1-2

3.1-1     Example emission inventory (El) organization chart	   3-2

4.1-1     Principles of the QA program	   4-2

4.2-1     Ozone SIP emission inventory point source information..   4-4

 A-l      Emissions information for individual processes within a
          point source facility	   A-17

 A-2      Summary tables for VOC, N03, and CO emissions	   A-19

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                                    TABLES







Number                                                              Page




 A-l      Individual Source Summary	.	   A-l




 A-2      Area Sources of Emissions	   A-13
                                      VI

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                               1.0  INTRODUCTION

1.1  PURPOSE AND OVERVIEW OF DOCUMENT

     As part of the State Implementation Plan (SIP) process, each State
involved in developing a SIP shall submit a quality assurance (QA) plan to the
EPA Regional office for review and approval.  The submittal and approval of a
QA plan is new to the SIP inventory process and is designed to ensure emission
inventories of higher quality than previous emission inventory submittals.  The
purpose of this document is to provide guidance to State and local agencies in
the development of a QA plan for their inventories.
     Section 1 of this document presents the purpose of the document and a
brief introduction to quality assurance.  Sections 2 through 5 examine the
elements included in a QA plan.  Section 2 describes the inventorying agency's
QA policy statement, including the purpose and the scope of the program.
Section 3 discusses the organization of the inventory as a whole.  Included in
this Section are general discussions of control techniques and audit
procedures.  In Section 4, the technical aspects of the inventory and the
associated QA procedures are presented.  The bulk of the discussion in this
report is found in Section 4.  Section 5 covers system audits, including audit
responsibility and schedules and procedures.
       Figure 1.1-1 gives an outline of an example QA plan.  The structure of
each section reflects the basic elements which should be considered and/or
included in the State QA plan.  While State agencies are not required to follow
this format, the elements outlined in the following -sections should be covered
in the State QA plan.

1.2  DEFINITION OF QUALITY ASSURANCE

     The purpose of quality assurance is to ensure the development of a
complete, accurate and consistent data base.  The quality assurance of an
inventory is the system of procedures which operates to ensure that the
inventory and accompanying data meet a specified level of quality.  Planning
and implementing such procedures ensure and document data quality.  A quality
                                      1-1

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*  1.0  Quality Assurance Policy Statement
        1.1  Purpose of the program
        1.2  Scope

   2.0  Summary
     *  2.1  Organization chart
     *  2.2  Emission inventory tasks and assignments or responsibility
        2.3  Information flow
        2.4  Summary of control techniques and relation to information flow
        2.5  Audit procedures
        2.6  Inventory objectives and constraints

   3.0  Technical
        3.1  Task planning
          *  3.1.1  Resource allocation
             3.1.2  Prioritizing sources and data elements
          *  3.1.3  Personnel training
          *  3.1.4  Schedule and project planning
             3.1.5  Data sources
             3.1.6  Data checking procedures
        3.2  Data collection and analysis
          *  3.2.1  Identification of emissions sources
          *  3.2.2  Collection procedures
          *  3.2.3  Data quality
          *  3.2.4  Emission estimation methods
          *  3.2.5  Calculations
          *  3.2.6  Validation procedures
        3.3  Data handling
             3.3.1  Data coding and recording
                    3.3.1.1  Recording and coding forms
                    3.3.1.2  Rules for data coding
                    3.3.1.3  Data editing procedures
          *  3.3.2  Data tracking
          *  3.3.3  Correcting data
          *' 3.3.4  Missing data
             3.3.5  Review of estimates
        3.4  Data reporting
             3.4.1  Reporting formats

   4.0  System Audits
     *  4.1  Audit responsibility and schedules
        4.2  Procedures
             4.2.1  Elements
             4.2.2  Schedule
             4.2.3  Audit report


* Required to be submitted.  Other elements are recommended but not  required.

         Figure 1.1-1.  Outline of example quality assurance (QA) plan.,
                                      1-2

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assured SIP inventory should produce a more accurate inventory and lead to
better assessment of control strategies and the impact of emissions on air
quality.  In fact, a well-designed QA program promotes user/agency confidence
in the data, provides a better assessment of emission inputs to air quality
models and should lower program costs for subsequent data base maintenance.
     An agency's QA plan should be designed to address such issues as:

          o  are all source categories covered in the inventory?
          o  have the best available data been used within the
             constraints of the inventory?
          o  are calculated values reasonable?
          o  have calculations been checked?
          o  does the inventory meet the stated objectives and
             requirements?
          o  how was the inventory produced?

These objectives and requirements can include the coverage, detail and format
of the inventory as well as its end uses and its ability to be analyzed and
updated.

1.3  QUALITY ASSURANCE COORDINATOR

     Before a new emissions inventory effort is begun, the agency should
appoint an individual to act as QA coordinator who will be responsible for all
the QA activities and who will serve as the liaison for communication and
contact.  A State may wish to assign one person to cover the entire emissions
inventory, or to assign one person for each major section (i.e., point sources,
area sources and mobile sources).  The coordinator does not necessarily have to
work on QA full-time and should preferably not be an individual engaged in the
actual inventory work.
     The appointment of a QA coordinator will help ensure implementation of the
quality assurance techniques.  The QA coordinator can audit the emissions
inventory process to ensure that errors in all phases of the inventory
preparation are detected and corrected.  The coordinator should also serve as
the focal point for addressing significant QA problems and corrective actions
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and should have a good understanding of the sources of the data used in the
inventory.
                                       1-4

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                    2.0  QUALITY ASSURANCE POLICY STATEMENT

2.1  POLICY STATEMENT

     The policy statement is the formal declaration of agency commitment for
developing and maintaining a quality assurance program.  The policy statement
defines quality assurance as related to agency activities, explains the need
for the program and provides the basis for committing resources to the
program.
     An example of a typical QA policy statement is given below.  While the
agency is not required to use this example statement, it should consider the
items mentioned in this statement in preparing its own.

EXAMPLE.       The objective of this emission inventory for 1988 is to compile
          an accurate and comprehensive inventory of emissions and facility
          data from point, area, and mobile sources for the base year.  The
          inventory will be developed for volatile organic compounds (VOC),
          oxides of nitrogen (NOX), and carbon monoxide (CO).
               To ensure that the inventory is of the highest quality, this
          agency will implement certain quality assurance procedures at various
          points in the inventory process.  Resources, including trained QA
          personnel, have been/will be allocated for this purpose.  This agency
          will follow the procedures outlined in Guidance for the Preparation
          of Quality Assurance Plans for O^/CO SIP Emission Inventories.  The
          details of this QA program are discussed in the following sections.
                                                      QA Coordinator
                                                    Agency Administrator
                                      2-1

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                                  3.0   SUMMARY

3.1  PROGRAM SUMMARY

     The quality assurance program summary is an executive summary of the
technical procedures.  It provides an overview of the major components of the
program without explaining the details of daily operating procedures.  The
summary explains the flow of emission inventory data through the agency, shows
graphically the interaction among functional groups, and flags the points in
the inventory procedures where quality assurance and quality control techniques
are applied.  It lists the control techniques and the frequency of their
application.
     The agency may also wish to include a discussion of the inventory
objectives and constraints in its summary.  While the major objectives for
performing a SIP inventory have been outlined by EPA in Emission Inventory
Requirements for Post-1987 Ozone State Implementation Plans  and Emission
Inventory Requirements for Post-1987 Carbon Monoxide State Implementation
      2
Plans,  other inventory objectives may vary from agency to agency depending,
for example, upon the choice of the photochemical model to be used.  Inventory
constraints may include personnel, time, resources,  data processing
capabilities, and others.  Agency understanding of inventory objectives and
constraints can aid in the decision of how resources will be allocated.
     Figure 3.1-1 shows an example QA organization chart.  The agency should
specify the names and telephone numbers (if known) of the directors and
coordinator on its organization chart.
                                     3-1

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  Point Source




   El  Director
                       State Air Pollution




                            Director
                       Emission Inventory




                            Director
Area Source




 El Director
                                   QA




                               Coordinator
Mobile Source




 El Director
Figure 3-1.  Example Emission Inventory (El) Organization Chart,
                            3-2

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                         4.0  TECHNICAL CONSIDERATIONS

4.1  INTRODUCTION

     The QA plan includes the operating details of each of the four major
emission inventory task categories (i.e., task planning, data collection,
technical procedures and calculations, and data recording, processing, and
reporting).  The plan must include step-by-step procedures for and details of
checking procedures.  The following discussions focus on the QA principles
shown in Figure 4.1-1.

4.2  PLANNING

     The agency should identify the procedures and principles it will use in
the planning section of the QA plan.  The detailed' descriptions of the
procedures, or how the agency intends to implement the planned procedures,
should be discussed under their appropriate headings; the planning section
outlines the QA elements to be employed.  The agency should explain that
certain procedures such as appointing a QA coordinator, prioritizing sources
for inclusion in the inventory, preparing checklists of sources to be
evaluated, determining data collection activities, identifying the critical
data elements, and implementing data checking programs, will be performed and
should give a schedule of these activities.  Some QA items to be included in
the planning are shown in Figure 4.1-1.  These items are discussed below.

4.2.1  Resource Allocation for Quality Assurance

     The agency should acknowledge allocation of resources for the QA of the
emission inventory and designation of or plans to designate a QA coordinator.
The name and telephone number of the QA coordinator should be provided (if
known) and the duties and responsibilities of the QA coordinator should be
identified.  Designation of a QA coordinator and his/her responsibilities early
in the emission inventory process will aid in standard and consistent
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Planning:

     -  Allocate resources for optimal QA.
     -  Prepare a checklist of sources of be evaluated.
     -  Account for significant VOC sources.
     -  Identify critical data elements and impacts on results and
        utility of the inventory.
     -  Review questionnaire design.
     -  Schedule routine checking of calculations and data entry.
     -  Prepare data checking programs incorporating standard range
        and missing data checks.
     -  Maintain a separate QA staff with experience in data collection
        and analysis.
     -  Plan audit procedures.

Data Collection and Analysis:

     -  Crosscheck identification of all major sources to ensure inclusion.
     -  Check questionnaire design based on response.
*    -  Check data collected.
     -  Check emission estimation methods and consistency of application.
*    -  Check calculated results.
     -  Initiate verification procedures.

Data Handling;

   .  -  Track data flow.
     -  Handle corrected data.
     -  Check data after conversion to inventory format.
*    -  Check individual data entries for missing emissions, SIC codes,
        implausible operating data, etc.
     -  Assign agency estimates for missing data on a consistent and
        documented basis.
*    -  Review tabulated data for quality and identification of outliers.

Data Reporting;

     -  Check aggregation of emissions.
     -  Check disaggregation of emissions.
     -  Compare results with other inventories.
* Logical checkpoints.


                  Figure 4.1-1.  Principles of the QA program.
                                      4-2

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application of the QA procedures and establishment of effective lines of
communication.

4.2.2  Prioritizing Sources and Data Elements

     In order to focus the QA effort, the agency should prioritize the source
categories and data elements for the inventory and should report the procedures
used in these prioritization processes.  Some brief examples are given below.
     Source categories can be prioritized based on their importance in the
inventory.  For example, they can be prioritized so that the agency's resources
are spent first on the source categories that the agency considers most
important and/or the sources that are most important for meeting the inventory
objectives.  The sources can be prioritized by checking previous SIP
inventories to identify the largest emitting area or point source categories,
checking other types of inventories to identify the largest emitting area or
point source categories, and/or determining the categories which are most^
important to the end users of the inventory.  Within this process, the agency
should also include consideration of how well the source category has been
characterized.  Once sources are prioritized, the agency must determine the
most appropriate procedures or methods for data collection and emission
estimation for each source category.
     Data elements for source categories can also be prioritized since certain
data are essential to the inventory.  The data priorities for the point source
inventory can be found in the guidance documents Emission Inventory
Requirements for Post-1987 Ozone State Implementation Plans  and Emission
Inventory Requirements for Post-1987 Carbon Monoxide State Implementation
     2
Plans ; those required are shown in Figure 4.2-1.  These may be used as
resources and checklists for prioritizing point sources and their data
elements.
     Much of the agency's resources for the mobile source inventory will be
spent developing the data inputs for the MOBILE model.  Some specific
parameters required as input to the MOBILE model include:  region for which
factors are to be calculated; calendar year; vehicle speed; ambient
temperature; percentage of total VMT accumulated by noncatalyst vehicles
                                      4-3

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      Data Elements
                            Data Elements (continued)
I.  PLANT IKFORMATION
                          III.  SEGMENT INFORMATION
    *
    *
    *
    *
    *
    *
    *
    *
    *
 NEDS  State ID
 NEDS  County ID
 NEDS  Plant ID
 NEDS  Pollutant
 Model Area (County,
  Township, or Grid Cell)
 Number of Employees
 Base Year of Inventory
 UTM Zone
 UTM Coordinates (km)
  X:
  Y:
 Plant Name
 Street Address
 City
 State
 Zip Code
 Plant Contact
 Plant SIC Code(s)
 Principal Product
Projected Attainment Year
Total Plant Banked Emissions
Year Emissions Banked
II.  POINT INFORMATION

   *   NEDS Point ID
   *   Point Description
       % Annual Throughput
         Dec—Feb
         Mar-May
         June-Aug
         Sept-Nov
       Normal Operation Schedule
   *     hrs/day
   *     days/wk
   *     wk,s/yr
         daily start/end times
   *   Regulation in Place?  (Y/N)
   *   Emission Limitation
   *   Compliance Year
          'Category (I,I
*   sec
*   SCC Description
*   Process Rate Units

  A.  BASE YEAR INFORMATION
      Actual Annual Process Rate
      Seasonal Adjustment Factor
      03 Season Daily Process  Rate
      Maximum Hourly Design Rate
      Control Equipment
        primary
        secondary
      Control Efficiency (£)
      Emission Estimation Method
      Emission Factor Units
      Emission Factor (uncontrolled
        emissions)
      Annual Base Year Emissions
        (tons/yr)
      Rule  Effectiveness  (2)
      03 Season Daily Emissions
        (Ibs/day)
      Banked Emissions (tons/yr)
      Comment
*
*
*
*
*
*
                                       *
                                       *
                                  B.   PROJECTED YEAR INFORMATION

                                      Projected Baseline Information
                                        Compliance Year
                                        Control Equipment
                                         primary
                                         secondary
                                        Control Efficiency  (2)
                                        Growth Factor
                                        Baseline Daily Emissions
                                          (Ibs/day)
                                      Projected Control Strategy Info
                                        Regulation in Place? (Y/N)
                                        Emission Limitation
                                        Compliance Year
                                        Control Equipment
                                          primary
                                          secondary
                                        Control Efficiency  (2)
                                        Rule Effectiveness  (Z)
                                        SIP Strategy Daily Emissions
                                         '(Ibs/day)
      Required for base  year  ozone  or  CO  SIP  emission inventory.
    Figure 4.2-1.   Ozone  SIP emission  inventory point  source  information.
                                         4-4

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 operating in the cold-start mode; percentage of the total VMT accumulated by
 catalyst-equipped vehicles operating in the hot-start mode; and percentage of
 total VMT accumulated by catalyst-equipped vehicles operating in the cold-
 start mode.  The agency has the choice of specifying local data or using
 default values in the model for parameters such as:  distribution of VMT by
 vehicle type; vehicle model year and accumulated mileage distributions;
 baseline emission rates; factors to correct emissions for air conditioner use,
 extra loading, trailer towing and humidity; and RVP of fuel, I/M parameters,
 and anti-tampering, if needed.  These lists can be used to prioritize mobile
 source data elements.

 4.2.3  Personnel Training

      In this section, the agency should describe the training to be provided
 for personnel involved in producing the inventory.  It may also want to
. identify the areas in which personnel are to be.trained, who will lead the
 training, who will be trained, and how the agency has arrived at these
 decisions.  Training of the inventory personnel will help to ensure consistency
 in the collection of data and estimation of emissions, reduce confusion in
 performing inventory functions, and allow the inventory to proceed at a quicker
 pace.

 4.2.4  Schedule and Project Planning

      The planning portion of the QA plan should also indicate the types of QA
 procedures that will be implemented and identify when these procedures will be
 implemented.  Checkpoints for optimal problem detection should be located and
 provisions for timely correction of problems should be identified.  (The actual
 correction processes will operate during the data collection and analysis and
 data handling procedures.)  The agency's QA plan should identify or flag these
 checkpoints.  To do this, the agency may provide a chart, such as that shown in
 Figure 4.1-1, showing the principles of the QA program, and denoting logical
 checkpoints with an asterisk.
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4.2.5  Data Sources

     An important element in planning is the identification of data sources.
The agency should outline how it will determine the data sources it will use.
To determine the reliability of the data and data sources, the agency should:
(1) judge the professional capabilities and biases (if any) of the agencies or
facilities supplying the data; (2) assess the collection techniques used to
compile the data; (3) assess the purpose for which the data have been compiled;
and (4) know and understand any limitations placed on the data by the
originating agency.  The agency's QA plan should also discuss how it will
perform these assessments and how it will treat the results.

4.2.6  Data Checking Procedures

     In the planning section, the agency should acknowledge that there is a
need for preparing data checking procedures for elements such as standard range
checks and missing data checks.  It should identify where and how these checks
will be implemented.

4.3  DATA COLLECTION AND ANALYSIS

     In the agency's QA plan, it should identify not only the data collection
procedures that it will use but also the quality control (QC) procedures that
it will employ to verify the data collection.  The following sections contain
discussions of the items to be considered in data collection.

4.3.1  Identification of Emissions Sources

     To ensure that all sources of emissions have been included in the
inventory, the agency must identify and implement procedures to account for the
sources.  These procedures, also known as completeness checks, assure that all
emission points within a source, and all major sources within the study region,
are included in the inventory.  Completeness checks may differ depending on the
major source category, i.e., point source, area source and mobile source. The
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agency should indicate how sources within these categories were identified and
verified.  The agency may use tables such as Table A-l in Appendix A for point
sources and Table A-2 in Appendix A for area sources to ensure that all
sources are inventoried.
     Sources of information on individual point sources to be surveyed for the
inventory include:  existing emission inventories; other air pollution control
agency files or government agency files; EPA/CTG source listings; local
information sources, such as local industrial directories, telephone
directories, and manufacturers and suppliers; and national publications, such
as trade and professional society publications and business references.  The
agency should describe the procedures it will use to crosscheck the
identification of the major sources.

4.3.2  Collection Procedures

     Data collection procedures can vary depending not only on the major source
category involved (point, area, mobile), but also on the individual source
categories within each of the above, the level of detail involved, and the
estimation methods to be used.  The choice of one particular collection method
over another may be dependent on the agency's time and resource constraints.
To ensure an emission inventory of the highest possible quality given the
agency's constraints, the agency should identify the critical data elements of
the collection procedures and assess their impacts on the results and utility
of the inventory and how easily these data can be obtained.
     The agency's QA plan should discuss:  (1) the collection procedures that
will be used; and (2) how the agency will provide quality control (QC) for
these data collection procedures.  Aspects of the first part of the discussion
have been outlined briefly above and in greater detail in Procedures for the
                                                            3
Preparation of Emission Inventories for Precursors of Ozone.   Examples of the
second part of the discussion are given below.
     To provide QC to the questionnaire approach to data collection, the agency
may decide to use industry-specific questionnaires and specially trained
personnel to handle those particular sources.  If the agency uses plant
inspections, it may provide special training, coding forms, and checklists to
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its inspectors.  It may also prepare the plant for its inspection by providing
the plant manager with questionnaires for certain information prior to the
inspection.  These measures are examples of the type of QC procedures that the
agency can use in their QA plan.

A.3.3  Data Quality

     To ensure that the emission inventory is of the highest possible quality,
the agency's QA plan should include procedures for evaluating the reliability
and quality of the data and should explain how these procedures will be
implemented.  Some actions that might ensure data reliability and quality are:
(1) check the date of the data to make sure that it corresponds with the
year(s) being inventoried; (2) check the data sources against other published
data; (3) assess the professional capabilities and biases (if any) of the
agencies supplying the data; (4) assess the purpose for which the data have
been compiled; and (5) assess the collection techniques used to compile the
data.  The agency may refer to Procedures for the Preparation of Emission
                                   3
Inventories for Precursors of Ozone  for further discussion of this topic.
     As an example, the agency may have greater confidence in data that have
been compiled for similar reasons as those for the current inventory, and
therefore, may decide that these data should be given preference over other
data.  The agency may also have greater confidence in data that are based on
actual activity levels rather than data based on assumptions.  The agency may
then decide to discard data based on assumptions in favor of those based on
activity surveys.

4.3.4 Emission Estimation Methods

     As with data collection procedures, emission estimation methods can vary
depending on the source category.  Within each major source category there are
several estimation methods that can be used, as well as emission factors that
can be employed.  In its QA plan, the agency should identify the procedures it
will employ to ensure that the method or methods used and the emission factors
used are the best ones for the inventory considering the constraints and
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objectives of the inventory.  The agency should also include a discussion on
how it plans to implement quality control procedures in the use of the emission
estimation methods.
     In estimating emissions from area sources (except highway mobile sources),
the agency can use any of the following methods:  (1) treating area sources as
point sources; (2) using local surveys to determine activity data; (3)
apportioning national or State totals to the area under consideration; (4)
using per capita emission factors; or (5) using emissions-per-employee factors.
(The available highway mobile source methods are described in Chapter 4, Volume
4 of Procedures for Emission Inventory Preparation. )  Determination of the
method or methods to use for estimating emissions from an area source category
will depend on the constraints of the inventory and the agency.  The agency
should identify the constraints to each method, including time and funds
available to the inventory and availability of data and of experienced
personnel.  If the agency's resources are limited, it may choose to use per
capita emission factors or emissions-per-employee factors, both of which can be
found in Procedures for the Preparation of Emission Inventories for Precursors
of Ozone.  If per capita factors are used, the agency may employ strict
procedures and forms that provide spaces for each of the data elements (the
emission factor, the population and the unit conversion factor, if necessary)
required for the per capita estimation method.
     If the agency has the resources to perform a detailed inventory, it may
choose to treat area sources as point sources or perform local surveys to
determine activity data.  The QA of these estimation methods may include
detailed investigation of the data sources, and again, strict procedures for
using the data sources.
     The agency may use emission factors from sources such as Compilation of
Air Pollutant Emission Factors (AP-42)  or may decide to use local emission
factors for point, area, and nonhighway mobile sources.  The choice can depend
on the availability o^ data and resources to compute local emission factors.
(Agencies must use MOBILE4 for emission factors for highway mobile sources.)
The agency must identify the procedures it will use to ensure that the emission
factors it will employ are sound and that the deployment of those procedures
are consistent (i.e., how will the agency QA and QC the emission factors it
                                     4-9

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will use).  If, for example, the agency users local emission factors, the
agency may compare the factors with published ones from AP-42  for
reasonableness or may compare the results from using the emission factors with
known emission published elsewhere.  If its local factors fall outside of a
certain percentage of the national factors from AP-A2,  the local factors will
be submitted to EPA with supporting documentation for approval.

4.3.5  Calculations

     As mentioned earlier, the agency's QA plan should discuss training for all
personnel involved in developing the inventory.  This includes providing
information on the types of calculations to be used for each estimation method
(per capita, production, throughput, etc.) and the format and equations to be
used.
   In the QA plan, the agency should identify how it will ensure the following:
(1) that the equations used within each method or procedure are the same; (2)
that all assumptions and engineering judgments used in the calculations are
documented and reviewed; (3) that units and unit conversions are checked; (4)
that calculations are reviewed for possible transposition of digits, entering
of incorrect numbers in calculators or computers, or misinterpretation of
either the emission factors or the instructions for their use; and (5) that
forms for recording calculations are consistent (for example, for all vehicle
classes in the mobile source inventory).  The QA plan should identify who will
perform this duty.  The agency might decide that this individual should be
independent of the inventory process.
     One way to ensure quality for this part of the inventory is to spot check
calculations.  A certain percent, for example five percent, of all calculations
should be recalculated and checked for errors.  In actuality, the frequency of
these checks will depend on staff experience, size of the staff, size of the
inventory, etc.* Another way to ensure the quality of the calculations is to
record all assumptions and engineering judgments used in the calculations in a
project notebook.  The notebooks should contain all of the calculations used to
develop the inventory and should contain the references for the data sources.
If the data are calculated using computers, a hard copy of the source code for
                                      4-10

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all calculations and all input files should also be maintained in the project
notebook (and described in the QA plan).
     The use of a computerized system for calculations, such as EPA's SIP Air
Emissions Inventory Management System (the SAM System) can be advantageous to
the agency in its QA process.  This and other PC programs can be generated to
assist in inventory submittal tracking, edit checking, and data and calculation
review.

4.3.6  Validation Procedures

     Data validation includes quality checks such as those for completeness and
internal data consistency.  Quality checks should be designed into the
inventory and should be documented in the inventory submittal.  The data checks
are divided into manual checks and computerized or mechanized checks.  In the
QA plan, the agency should discuss the specific validation steps that it will
undertake.
     Completeness includes checks to ensure that all emission sources have been
represented in the inventory.  Some of these checks can be performed manually
while others can be performed by computers.  Manual checks may include
comparing the agency's list of area sources with the area source categories
shown in Table A-2.  Point sources can be checked against those categories
shown in Table A-l or can be compared with previous inventories (i.e., the
1985 NAPAP inventory) and independent listings by source category (local
business directories) to ensure that all of the major sources in the MSA/CMSA
are included.
     Checks for data consistency should be implemented by the agency.  To
ensure consistency in the inventory, the agency must address issues such as:
(1) is the same geographic area used for all major source categories as well  as
individual categories; (2) are only reactive VOC counted in the inventory;
(3) has double-counting of some general source categories been taken into
consideration; and (4) has the use of emission factors, units of measurement,
populations of vehicles, year(s) of data and information, and apportioning and
distribution techniques been consistent.  The agency's plan for implementing
these checks should be included in the QA plan.
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     The agency should use methods described in Procedures for the Preparation
of Emission Inventories for Precursors of Ozone  to ensure that only reactive
VOC are reported in the inventory.  (For most categories,  AP-42  includes
emission factors for methane and nonmethane VOC.)  Section 2.2.11 of Procedures
for the Preparation of Emission Inventories for Precursors of Ozone  lists
those compounds considered to be nonreactive hydrocarbons.
     To ensure that double-counting does not occur in the  inventory, the agency
should identify those industries, for example, dry cleaning,  included in its
point source inventory that emit less than 100 tons per year  VOC and subtract
those emissions from the area source emission estimates where appropriate.
     Data used in the inventory and estimates calculated in the inventory
should be checked for reasonableness.  Reasonableness checks  can be employed on
several levels.  Individual data elements and emission estimates can be checked
to make sure that the values fall within reasonable or acceptable ranges.  Much
of this effort can be done by computerized checks.  In addition, the computer
can check for internal consistency.  Rudimentary edit checks  will be built into
the SAM System and will be provided to the agencies for their use.  (These edit
checks will initially consist mainly of range checks, etc.)
     The EPA report Guidelines for Review of Highway Source Emission
Inventories for 1982 SIPs  provides both information on reasonable data ranges
and worksheets useful in reviewing the mobile source inventory for reliability.
(The range checks in this document are only good for the travel data; any range
checks in this document for temperature or emissions are out  of date.)  Source
category emissions can be cross-referenced with other emission inventories.
VMT data can be checked against data found in Highway Statistics  (for data at
the State level only).
     The inventory should also be checked to ensure that it meets its stated
objectives and requirements.  Appendix B of the EPA document  entitled Emission
Inventory Requirements for Post-1987 Ozone State Implementation Plans  includes
a checklist of information to be reported by the State which  will be used by
EPA when reviewing the SIPs.  The agency's QA plan should  explain how it plans
to verify the information that is to be reported by the State.
     Once the data are in the inventory format, individual data elements can be
checked for incomplete or" missing data, implausible data,  etc.  Examples of
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these procedures include checking for correspondence of units listed and SCC
listed, checking control equipment codes against the process (SCC) to ensure
that there is a proper fit and checking operating schedule ranges.

4.4  DATA HANDLING

     Data handling includes all the aspects of following the data through the
inventory.  These aspects include:  coding and recording the data; data
tracking; correcting data and handling corrected data; checking data after they
have been converted to the inventory format; dealing with missing data; and
reviewing the estimates.

4.4.1  Data Coding and Recording

     To ensure an inventory of high quality and to decrease confusion, data
should be coded and recorded in a consistent manner.  In its QA plan, the
agency should discuss how the data are going to be coded and recorded
consistently and how it plans to verify these procedures.  To accomplish the
consistent coding and recording, the agency can develop specific formats and
coding forms for inventory personnel to use.  Spot checking of coding forms for
missing or incomplete data may be employed here.  Once the data are in the
specified format, the agency should have procedures to ensure that this
recorded information is complete.  Elements found in the discussion under data
validation can be useful in this.

4.4.2  Data Tracking

     During the development of the inventory, the sources of the data and
equations should be tracked.  The agency should discuss the procedures it will
use to track the data throughout the inventory and how it will verify that the
data are being tracked.
     One method the agency may use to track data is to have all personnel
working on the inventory keep notebooks, using a consistent format for
recording emission estimates, calculations and associated individual data for
                                     4-13

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all emission sources.  Calculations performed for the inventory,  as well as
other pertinent notes and references, can be recorded in the notebooks.
Notebooks can be checked at specified intervals for QC of the tracking process.
     If the agency uses spreadsheets, data tracking may involve maintaining
diskettes.  The data should be backed-up.  Regardless of the method of data
tracking, the agency should have procedures for identifying the location of the
raw data, the calculations, and the references.
     The data tracking effort should encompass the tracking of the original
data as well as corrections and additions to the data.  The QA of the raw data
is expected to uncover errors in the data.  As these data are corrected or
found to be missing, the agency should have procedures in place to keep track
of the source of the new data, the day the new data were put into the inventory
and the person responsible for the change.  One method for tracking data is the
QA notebook; a separate notebook may be kept to follow the corrected data or
audit trail.  A discussion of the audit trail procedure should be included in
the QA plan.  It should include a discussion of the location and contents of
the notebook and procedures for ensuring that corrected data are entered in the
notebook.  The audit trail could be a computer program that checks old values
against new values and records the necessary data surrounding the change in a
separate file.

4.4.3  Correcting Data

     As has been mentioned earlier, the agency should have specific procedures
for correcting data and for handling the corrected data.  The QA plan should
outline these procedures and how it will ensure that the procedures are being
carried out.  For example, information regarding the data items that have been
corrected may be recorded in an audit trail notebook.  Periodic checking of
project notebooks against the audit trail notebook may help ensure that the
procedure is being implemented.
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4.4.4  Missing Data

     As part of its QA plan, the agency should have procedures in place for
dealing with missing data elements.  The agency should identify how it will
discover if data are missing and how it will assign estimates for missing data
on a consistent and documented basis.
     Missing data elements in the coded and recorded data can be identified
through internal data checks using the computer.  These checks can be
implemented at periodic intervals, and the audit trail notebook can be used for
recording both the identification of the problem and the documentation of the
resolution.  The audit trail notebook can be the resource material for assuring
that estimates are assigned on a consistent and documented basis.
                         »

4.4.5  Review of Estimates

     The emission estimates should be reviewed for quality and identification
of outliers.  The agency should discuss how it plans to estimate the quality
of the inventory in the QA plan and how it will reexamine values that are
outliers.  It may assign values of confidence (for example, low, medium, high)
to data sources, estimation methods, and emission factors, and may decide to
assign confidence levels to portions of the inventory.
     The agency may wish to choose certain data quality indicators for its
inventory.  The selection and use of data quality indicators may have great
significance to modeling, strategy development, and other activities which
will use the inventory data.  For agencies with sufficient resources, the
results of the validity and edit checks can be summarized for data users
outside the inventory work group, and data quality indicators may go beyond
this to include representativeness, bias, and error bounds or confidence
intervals.
     It should be noted that simply because the estimate is an outlier, i.e.,
it does not fall within the expected range, it is not necessarily in error.  If
the agency is confident in the data elements used to calculate the estimate,
the estimate need not be changed.  Outlier estimates may be recalculated and
the elements and procedures involved in the calculations may be reviewed.  If
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the agency has confidence in the data or does not have the resources to use
another estimation method, the outlier estimate may remain as it is.

4.5  DATA REPORTING

     Data reporting formats have been proposed for the post-1987 ozone SIP
emission inventories and are shown in Figures A-l and A-2 in Appendix A.
Consistency in adhering to these formats will facilitate QA of the data.  The
agency should include a discussion in its QA plan regarding the reporting
format it will use and how it plans to use QA and QC procedures to ensure that
the data will be in the required format.
                                       4-16

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                               5.0   SYSTEM AUDITS

5.1  INTRODUCTION

     In general, this segment of a QA plan outlines the procedures for agency
management and/or EPA to follow in reviewing the effectiveness of the program.
System audits can be both internal (agency audits) and external (EPA audits).

5.2  INTERNAL AUDITS

     An internal audit, while not required,  is a process that the agency may
choose to do.  In an internal audit, a periodic and complete review of the QA
system is performed to maintain the inventory.  The auditor examines QA
procedures and their effectiveness, assesses technical and personnel resources,
and takes steps to tune the QA process accordingly.  The documentation of the
audit specifies the records and procedures that will be reviewed and the
frequency of review.  It provides guidelines for management report format that
can be used to compare audit results over time.  The system audit is important
because it can flag procedures that are not  cost-effective, or, on the other
hand, it can indicate the need for more procedures to improve data quality.  By
employing self-auditing procedures, the agency can determine errors at an early
stage and minimize costs to correct them.

5.2  EXTERNAL AUDITS

     The agency's QA plan provides a basis for EPA's external audit of the SIP
inventories.  For the purposes of the SIP inventories, an audit of the
agency's QA plan will be performed by EPA.   The agency need only acknowledge
that its QA plan may be audited by EPA (EPA may conduct an on-site audit) and
that it may be called upon to update its program.   Provisions for this external
                                                                            A
audit should be included in the agency's QA plan.
                                     5-1

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                                6.0  REFERENCES
1.  Emission Inventory Requirements for Post-1987 Ozone State Implementation
    Plans, EPA-450/4-88-019, U.S. Environmental Protection Agency, Research
    Triangle Park, NC, December 1988.

2.  Emission Inventory Requirements for Post-1987 Carbon Monoxide State
    Implementation Plans. EPA-450/4-88-020, U.S. Environmental Protection
    Agency, Research Triangle Park, NC, December 1988.

3.  Procedures for the Preparation of Emission Inventories for Precursors of
    Ozone, EPA-450/4-88-021, U.S. Environmental Protection Agency, Research
    Triangle Park, NC, December 1988.

4.  Procedures for Emission Inventory Preparation, Volume IV;  Mobile Source,
    EPA-450/4-81-026d, U.S. Environmental Pro'tection Agency, Research Triangle
    Park, NC, September 1981. (Revisions currently underway.)

5.  Compilation of Air Pollutant Emission Factors, Fourth Edition and
    Supplements, AP-42, U.S. Environmental Protection Agency, Research
    Triangle Park, NC, September 1985.

6.  Guidelines for Review of Highway Source Emission Inventories for 1982 SIPs,
    EPA-400/12-80-002, U.S. Environmental Protection Agency, Washington, DC,
    December 1980.

7.  Highway Statistics, U.S. Department of Transportation, Federal Highway
    Administration, Washington, DC.  Annual publication.
                                     6-1

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APPENDIX A

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                 TABLE A-l.  INDIVIDUAL SOURCE SUMMARY3
STORAGE, TRANSPORTATION AND MARKETING OF PETROLEUM PRODUCTS AND
  VOLATILE ORGANIC LIQUIDS

 1.  Oil and Gas Production
       Detailed emissions from well head to load-out, including process
         sources, storage, fugitive and handling

 2.  Petroleum Product and Crude Oil Storage
       Fixed Roof Tanks
       External Floating Roof Tanks
         Primary Seals
         Secondary Seals
       Internal Floating Roof Tanks
       Leaks from Valves, Flanges Meters,  Pumps

 3.  Bulk Terminals
       Fixed Roof Tanks
       External Floating Roof Tanks
         Primary Seals
         Secondary Seals
       Internal Floating Roof Tanks
       Leaks from Valves, Flanges Meters,  Pumps
       Vapor Collection Losses
       Filling Losses from Uncontrolled Loading Racks
       Tank Truck Vapor Leaks from Loading of Gasoline
       Non-Tank Farm Storage

 4.  Bulk Plants
       Fixed Roof Tanks
       External Floating Roof Tanks
         Primary Seals
         Secondary Seals
       Internal Floating Roof Tanks
       Loading and Unloading Racks
       Tank Truck Vapor Leaks
       Leaks from Valves, Flanges Meters,  Pumps

 5.  Volatile Organic Liquid Storage and Transfer
       Fixed Roof Tanks
       External Floating Roof Tanks
         Primary Seals
         Secondary Seals
       Internal Floating Roof Tanks
       Loading and Unloading Racks
       Tank Truck Vapor Leaks
       Leaks from Valves, Flanges Meters,  Pumps
                                 A-l

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           TABLE A-l.  INDIVIDUAL SOURCE SUMMARY (Continued)


STORAGE, TRANSPORTATION AND MARKETING OF PETROLEUM PRODUCTS AND
  VOLATILE ORGANIC LIQUIDS (Continued)

 6.  Vessels
       Petroleum Products and VOL Loading - Barge
       Petroleum Products and VOL Loading - Tanker
       Crude Oil Ballasting - Tanker

 7.  Barge, Tanker, Tank Truck and Rail Car Cleaning

 8.  Barges, Tankers, Tank Trucks and Rail Cars in Transit

 9.  Service Station Loading (Stage I)

10.  Service Station Loading (Stage II)

11.  Formulation and Packing VOL for Market

12.  Local Storage (airports, industries that use fuels, solvents and
       reactants in their operation).

INDUSTRIAL PROCESSES

 1.  Petroleum Refineries
       Process Drains ans Wastewater Separators
       Vacuum Producing Systems
       Process Unit Turnarounds
       Fugitive Leaks from Seals, Valves, Flanges, Pressure Relief
         Devices and Drains
       Petroleum Coking
       Cooling Towers
       Secondary Losses (Wastewater - Solid Waste)
       Other Process Emissions such as Heaters, Boilers, Catalytic
         Cracker Regenerators (specify)

 2.  Natural Gas and Petroleum Product Processing

 3.  Lube Oil Manufacture

 4.  Organic Chemical Manufacture
       Fugitive Leaks from Seals, Valves, Flanges, Pressure Relief
         Devices and Drains
       Air Oxidation Units
       Storage and Transfer
       Wastewater Separators
       Handling
       Secondary Losses (Wastewater - Solid Waste)
       Other Process Units (specify)
                                 A-2

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           TABLE A-l.  INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL PROCESSES (Continued)

 5.  Inorganic Chemical Manufacture
       Fugitive Leaks from Seals, Valves, Flanges, Pressure Relief
         Devices and Drains
       Storage and Transfer
       Clean Up
       Secondary Losses (Wastewater - Solid Waste)
       Other Process Units (specify)

 6.  Iron & Steel Production
       Sintering
       Electric Arc Furnaces
       Other Process Units (specify)
       Secondary Losses (Wastewater - Solid Waste)

 7.  Coke Production
       Coke Pushing
       Coke Oven Doors
       Coke Charging
       Coke Preheater
       Topside Leaks
       Quenching
       Battery Stacks
       Secondary Losses (Wastewater - Solid Waste)

 8.  Coke By-Product Plants
       Collection Leaks
       Primary Cooler
       Ammonia Stills
       Light Oil Scrubbers
       Tar Precipitators
       BTX Stills
       Tar Decanters
       Secondary Losses (Wastewater - Solid Waste)
       Other Unit Operations (specify)

 9.  Synthetic Fiber Manufacture
       Dope Preparation
       Filtration-
       Fiber Extrusion - Solvent Recovery
       Takeup Stretching,  Washing,  Drying,  Crimping,  Finishing
       Fiber Storage - Residual Solvent  Evaporation
       Equipment Leakage
       Solvent Storage
       Secondary Losses (Wastewater - Solid Waste)
       Other Process Units (specify)
                                 A-3

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           TABLE A-1.  INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL PROCESSES (Continued)

10.  Polymers and Resins Manufacture
       Catalyst Preparation
       Reactor Vents
       Separation of Reactants, Solvents, Diluents from Product
       Raw Material Storage
       Solvent Storage
       Handling
       Equipment Leakage
       Secondary Losses (Wastewater — Solid Waste)
       Other Process Units (specify)

11.  Plastic Products Manufacture
       Mold Release
       Solvent Consumption
       Adhesive Consumption
       Adhesives Preparation
       Fiber Storage - Residual Solvent Evaporation
       Secondary Losses (Wastewater - Solid Waste)
       Other Process Units (specify)

12.  Fermentation Processes
       Fermentation Tank Venting
       Aging (Wine or Whiskey)
       Drying/Conditioning Used Grain
       Bottling
       Clean Up
       Secondary Losses (Wastewater - Solid Waste)
       Other Process Units (specify)

13.  Vegitable Oil Processing
       Oil Extraction and Desolventation
       Meal Preparation
       Oil Refining
       Fugitive Leaks
       Solvent Storage
       Secondary Losses (Wastewater - Solid Waste)
       Other Process Units (specify)

14.  Pharmaceutical Manufacturing
       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
       Fugitive Leaks
       Packaging
       Secondary Losses (Wastewater - Solid Waste)
       Other Process Units (specify)
                                 A-4

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           TABLE A-l.  INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL PROCESSES (Continued)

15.  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
       Retreaders
       Secondary Losses (Waatewater - Solid Waste)
       Other Process Units (specify)

16.  SBR Rubber Manufacture
       Slowdown Tanks
       Steam Stripper
       Prestorage Tanks
       Secondary Losses (Wastewater - Solid Waste)
       Other Process Units (specify)

17.  Ammonia Production
       Desulfurization Unit Generation
     .  Primary Reformer, Heater Fuel Combustion
       Carbon Dioxide Regenerator
       Condensate Steam Stripper

18.  Carbon Black Manufacture
       Main Process Vent
       Flare
       CO Boiler
       Solid Waste Generator

19.  Phthalic Anhydride Production
       Oxidation of o-Xylene
         Main Process Stream
         Pretreatment
         Distillation
       Oxidation''of Naphthalene
         Main Process Stream
         Pretreatment
         Distillation
                                 A-5

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           TABLE A-l.  INDIVIDUAL SOURCE SUMMARY (Continued)


INDUSTRIAL PROCESSES (Continued)

20.  Terephthalic Acid Production
       Reactor Vent
       Crystallization, Separation, Drying
       Distillation and Recovery
       Product Transfer

21.  Maleic Anhydride Production
       Storage
       Fugitive Leaks
       Other Process Units (specify)

22.  Pulp and Paper Mills

23.  Primary and Secondary Metals Production

24.  Plywood, Particle Board, Pulp Board, Chip or Flake Wood Board
                                                  4
25.  Charcoal Production

26.  Carbon Electrode and Graphite Production

27.  Paint, Varnish and Other Coatings Production

28.  Adhesives Production

29.  Printing Ink Manufacture

30.  Scrap Metals Clean Up

31.  Adipic Acid Proction

32.  Coffee Roasting

33.  Grain Elevators (fumigation)

34.  Meat Smokehouses

35.  Asphalt Roofing Manufacture

36.  Bakeries

37.  Fabric, Thread and Fiber Dying and Finishing

38.  Glass Fiber Manufacture

39.  Glass Manufacture
                                 A-6

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           TABLE A-1.  INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL PROCESSES (Continued)

40.  Soaps, Detergents and Cleaning Agents Manufacturing, Formulation
       and Packaging

41.  Food and Animal Feedstuff Processing and Preparation

42.  Bricks and Related Clays

INDUSTRIAL SURFACE COATING

 1.  Large Appliances
       Cleaning and Pretreatment
       Prime Spray, Flow or Dip Coating Operations
       Topcoat Spray
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

 2.  Magnet Wire
       Cleaning and Pretreatment
       Coating Applications and Curing
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

 3.  Autos and Light Trucks
       Cleaning and Pretreatment
       Prime Application, Electrodeposition, Dip or Spray
       Prime Surface Operations
       Topcoat Operation
       Repair Topcoat Application Area
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

 4.  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
       Lithography
       Overvarnish
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
                                 A-7

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           TABLE A-l.  INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL SURFACE COATING (Continued)

 5.  Metal Coils
       Prime Coating
       Finish Coating
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

 6.  Paper/Fabric
       Coating Operations
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

 7.  Wood Furniture
       Coating Operations
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

 8.  Metal Furniture
       Cleaning and Pretreatment
       Coating Operations
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

 9.  Miscellaneous Metal Parts and Products
       Cleaning and Pretreatment
       Coating Operations, Flow, Dip, Spray
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

10.  Flatwood Products
       Filler
       Sealer
       Basecoat
       Topcoat
       Inks
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

                                 A-8

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           TABLE A-l.  INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL SURFACE COATING (Continued)

11.  Plastic Products
       Cleaning and Pretreatment
       Coating Operations, Flow, Dip, Spray
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

12.  Large Ships
       Cleaning and Pretreatment
       Prime Coat Operation
       Top Coat Operation
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

13.  Large Aircraft
       Cleaning and Pretreatment
       Prime Coat Operation
       Top Coat Operation
       Coating Mixing
       Coating and Solvent Storage
       Equipment Clean Up
       Other Process Units (specify)

NONINDUSTRIAL SURFACE COATING

 1.  Architectural Coatings

 2.  Auto Refinishing

OTHER SOLVENT USE

 1.  Degreasing
       Cold cleaning
       Vapor Degreasing
       Conveyorized Degreasing

 2.  Dry Cleaning
       Perchloroethylene
       Petroleum Solvents
                                 A-9

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           TABLE A-l.  INDIVIDUAL SOURCE SUMMARY (Continued)
OTHER SOLVENT USE (Continued)

 3.  Graphic Arts
       Letterpress
       Rotogravure
       Offset Lithography
       Ink Mixing
       Solvent Storage
       Flexography
       Equipment Clean Up

 A.  Adhesives
       Adhesive Application
       Solvent Mixing
       Solvent Storage
       Packaging
       Equipment Clean Up
       Other Process Units (specify)

 5.  Solvent Extraction Processes

 6.  Cutback Asphalt

 7.  Consumer/Commercial Solvent Use
       Paints, Primers, Varnishes
       Hair Sprays
       All Purpose Cleaners
       Insect Sprays
       Car Polishes and Waxes
       Room Deodorants and Disinfectants
       Window and Glass Cleaners
       Caulking and Sealing Compounds
       Moth Control Products
       Herbicides, Fungicides
       Carburetor and Choke Cleaners
       Auto Antifreeze
       Personal Deodorants
       Brake Cleaners
       Adhesives (Consumer)
       Engine Starting Fluids
       Lubricants and Silicones
       Engine Degreasers
       Metal Cleaners and Polishes
       Rug and Upholstery Cleaners

 8.  Asphalt Roofing Kettles

 9.  Pesticide Application
                                A-10

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           TABLE A-l.  INDIVIDUAL SOURCE SUMMARY (Continued)


EXTERNAL COMBUSTION SOURCES

 1.  Industrial Fuel Combustion

 2.  Coal Cleaning
       Fluidized Bed
       Flash
       Multilouvered

 3.  Electrical Generation

 4.  Commercial/Institutional Fuel Combustion

 5.  Residential Fuel Combustion

 6.  Resource Recovery Facilities

 7.  Solid Waste Disposal
       On-Site Incineration
       Open Burning
       Prescribed Burning
       Structural Fires
       Wildfires

 8.  Recycle/Recovery (Primary Metals)
       Auto Body Incineration
       Drum Cleaning

 9.  Sewage Sludge Incinerators

STATIONARY INTERNAL COMBUSTION

 1.  Reciprocation Engines

 2.  Gas Turbines

WASTE DISPOSAL

 1.  Publicly Owned Treatment Works

 2.  Industrial Wastewater Treatment

 3.  Municipal Landfills
                                A-ll

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           TABLE A-l.  INDIVIDUAL SOURCE SUMMARY (Continued)
WASTE DISPOSAL (Continued)

 4.  Hazardous Waste Treatment, Storage and Disposal Facilities
       Landills
       Landfarms
       Surface Impoundments
       Storage
       Incinerators
       Leaking Undergroud Storage Tanks
       Wastepiles

MOBILE SOURCES

 1.  Highway Vehicles
       Light Duty Autos
       Light Duty Trucks
       Heavy Duty Autos
       Heavy Duty Gasoline Trucks
       Heavy Duty Diesel Trucks
       Motorcycles

 2.  NonHighway Vehicles
       Railroad Locomotives
       Aircraft
         Military
         Civil
         Commercial
       Vessels
       Motorboats
       Off-Highway Motorcycles
       Construction Equipment
       Industrial Equipment
       Farm Equipment
       Lawn and Garden Equipment
       Snowmobiles
       Orchard Heaters
a               . ,.
 Pollutants in each source category are shown in Table A-2.
                                A-l 2

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              TABLE A-2.   VOC, CO AND NO* EMISSION SOURCES
                                                            POLLUTANTS
                  SOURCES OF EMISSIONS
                                                          VOC  CO
Storage, Transportation, and Marketing of Petroleum
  Products and Volatile Organic Liquids

   Oil and Gas Production                                  X
   Petroleum Product and Crude Oil Storage                 X
   Bulk Terminals                                          X
   Bulk Plants                                             X
   Volatile Organic Liquid Storage and Transfer            X
   Vessels                                                 X
   Barge, Tanker, Tank Truck and Rail Car Cleaning         X
   Barges, Tankers, Tank Trucks and Rait Cars in Transit   X
   Service Station Loading (Stage I)         '              X
   Service Station Loading (Stage II)                      X
   Formulation and Packing VOL for Market                  X
   Local Storage (airports, industries that use fuels,     X
     solvents and reactants in their operation).

Industrial Processes
Petroleum Refineries
Natural Gas and Petroleum Product Processing
Lube Oil Manufacture
Organic Chemical Manufacture
Inorganic Chemical Manufacture
Iron & Steel Production
Coke Production
Coke By-Product Plants
Synthetic Fiber Manufacture
Polymers and Resins Manufacture
Plastic Products Manufacture
Fermentation Processes
Vegitable Oil Processing
Pharmaceutical Manufacturing
Rubber Tire Manufacture
SBR Rubber Manufacture
Ammonia Production
Carbon Black Manufacture
Phthalic Anhydride Production
Terephthalic Acid Production
Maleic Anhydride Production
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X









X



X
X
X
X
X
X
X
X









X



                                   A-13

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          TABLE A-2.   VOC, CO AND NOX EMISSION SOURCES (Continued)
                                                            POLLUTANTS
                  SOURCES OF EMISSIONS	
                                                          VOC  CO
Industrial Processes (Continued)

   Pulp and Paper Mills                                    XX    X
   Primary and Secondary Metals Production                 XXX
   Plywood, Particle Board, Pulp Board, Chip or Flake      X
     Wood Board
   Charcoal Production                                     XXX
   Carbon Electrode and Graphite Production                X
   Paint, Varnish and Other Coatings Production            X
   Adhesives Production                                    X
   Printing Ink Manufacture                                X
   Scrap Metals Clean Up                                   X
   Adipic Acid Proction                                    X         X
   Coffee Roasting                                  ,       X         X
   Grain Elevators (fumigation)                            X
   Meat Smokehouses                                        XXX
   Asphalt Roofing Manufacture                             XXX
   Bakeries                                                X
   Fabric, Thread and Fiber Dying and Finishing            X
   Glass Fiber Manufacture   •                              X
   Glass Manufacture                                       XXX
   Soaps, Detergents and Cleaning Agents.Manufacturing,    X
     Formulation and Packaging
   Food and Animal Feedstuff Processing and Preparation    X
   Bricks and Related Clays                                     X    X

Industrial Surface Coating
                                                           X
   Large Appliances                                        X
   Magnet Wire                                             X
   Autos and Light Trucks                                  X
   Cans                                                    X
   Metal Coils                                             X
   Paper/Fabric                                            X
   Wood Furniture                                          X
   Metal Furniture.                                        X
   Miscellaneous J%tal Parts and Products                  X
   Flatwood Products                                       X
   Plastic Products                                        X
   Large Ships                                             X
   Large Aircraft                                          X

-------
          TABLE A-2.   VOC,  CO AND NO* EMISSION SOURCES  (Continued)
                                                            POLLUTANTS
                  SOURCES OF EMISSIONS
                                                          VOC  CO
Nonindustrial Surface Coating

   Architectural Coatings                                  X
   Auto Refinishing                                        X

Other Solvent Use

   Degreasing3                                             X
   Dry Cleaning                                            X
   Graphic Arts                              .              X
   Adhesives                                               X
   Solvent Extraction Processes                            X
   Cutback Asphalt                                         X
   Consumer/Commercial Solvent Use                         X
   Asphalt Roofing Kettles                                 XXX
   Pesticide Application                                   X

External Combustion Sources3

   Industrial Fuel Combustion                              XXX
   Coal Cleaning                                           X         X
   Electrical Generation   .                                XXX
   Commercial/Institutional Fuel Combustion                XXX
   Residential Fuel Combustion                             XXX
   Resource Recovery Facilities                            XXX
   Solid Waste Disposal                                    XXX
   Recycle/Recovery (Primary Metals)           .            XXX
   Sewage Sludge Incinerators                              XXX

Stationary Internal Combustion3

   Reciprocating Engines                                   XXX
   Gas Turbines                                            XXX

Waste Disposal . ,

   Publicly Owned Treatment Works                          X
   Industrial Wastewater Treatment                         X
   Municipal Landfills                                     X
   Hazardous Waste Treatment, Storage and Disposal         X
     Facilities
                               A-15

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         TABLE A-2.   VOC, CO AND NO* EMISSION SOURCES (Continued)
                                                            POLLUTANTS
                  SOURCES OF EMISSIONS                   	
                                                          VOC  CO
Mobile Sources

   Highway Vehicles                                        XXX
   Nonhighway Vehicles                                     XXX

a
 Emissions from these sources may occur from source categories
 identified elsewhere in Table 2.2-1.  For example, carbon monoxide and
 oxides of nitrogen are emitted from industrial boilers at organic and
 inorganic manufacturing facilities.  Likewise, carbon monoxide and
 oxides of nitrogen are emitted from reciprocating engines at oil and
 gas production facilities, and volatile organic compounds are emitted
 from many industries involved in degreasing operations.  An effort
 should be made to avoid double counting from these sources.
                                A-16

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Plant Information
                                            Figure  A-l.
Pollutant  (VDC, NOx):
                                     Plant  Name:
Base Year (1987 OP 1988):
NEDS ID (State, County,  Plant):  "      Street Address, City, State:
                                                                            Projected Attainment Year:
Model Area  (County,  Township,
  or Grid Code):
                                     SIC Code(s):2
Total  Banked Emissions (tons/yr):
Base Year  Point Information

NEDS
Point            Process
 ID            Description
                                       Operating Schedule3                                              CTG
                                     	 Applicable       Emission       Compliance  Category
                                     (hr/dy)  (dyM) (wk/yr) Regulation      Limitation         Year    (I,II,III)
Base Year Segment Information
                                                                    Emission
                             Process           Control    Emission    Factor       Rule      03 Season  Banked
                   Process     Rate11   Control  Efficiency Estimation (Ib/pracess Effectiveness Emissions Emissions
 ID      SCC      Rate Units* (/day)   Equipment'   (7.)       Method'"  rate unit)       (7.)      (Ibs/day) (tons/yr)
NEDS
                      Emissions  Information  for Individual  Processes Within  A
                      Point  Source  Facility
                                             i
                                               A-l 7

-------
                                     Figure A-l.    (cont.)


Projection Year In-fonnation
Projection Year  	                      Projected                                              Projected
                           Control          Baseline .                                  Rule      SIP Strategy
Point         t     Control  Efficiency Growth Emissions Applicable  Emission  Compliance Effectiveness Emissions11
 ID      SCC''   .Equipment'   (7.)      Factor'(Ibs/day) Regulation Limitation    Year         (7.)   •    tlbs/day)
Projection Year  	                      Projected                                              Projected
                           Control         Baseline  ,                                   Rule      SIP Strategy
Point         •    Control  Efficiency Growth Emissions' Applicable  Emission  Compliance Effectiveness Emissions11
 ID      SCC4    Equipment7    (7.)     Factor'(Ibs/day) Regulation Limitation    Year         (7.)       (Ibs/day)
Projection  Year  	           _           Projected                                              Projected
                            Control         Baseline  .               '                    Rule      SIP Strategy
Point             Control ^Efficiency Growth Emissions Applicable  Emission   Compliance Effectiveness Emissions11
  ID      SCC     Equipment7   (7.1     Factor'(Ibs/day) Regulation Limitation    Year         (7.)       (Ibs/day)
                       Emissions  Information  for Individual  Processes  Within A
                       Point  Source  Facility  (cont)

                                              A-l 8

-------
                                            Figure A-2.

                   Summary Table Of VOC Emissions For
                                                      (.County or Equivalent)
                                        (tons per day)
I
1
!
Storage, Transportation
And Marketing Of VOC
Oil and Gas Production
Natural Gas and Gasoline
Processing
Other Petroleum Processing
Gasoline and Crude Oil Storage-^
All (except floating roof)
Floating Roof
Volatile Organic Liquid Storage
VOL - Transfer
Ship and Barge
Other
Barge and Tanker Cleaning
Bulk Gasoline Terminals4
Gasoline Bulk Plants5
Service Station Loading
(Stage I)
Service Station Unloading
(Stage II)
Gasoline Tank Trucks
Others (specify)
Industrial Processes
Petroleum Refineries
Vacuum Systems
Fugitive
Other
Lube Oil Manufacture
Appl icable
Regulation^




























Base Year
(specify year)
Point Area






















*

































Base Line
Projection
(sjsecify ^ear)
Point Area
























































Revised SIP
Strategy
Projection
(specify year)
Point Area
























































4
5
Typical ozone season weekday
List appreviations at end of table with brief explanation,
•  (i.e., I = Group I CTGs - State Reg XX.X;
  II = Group II CTGs - State Reg. YY.Y, etc.)
Includes all storage facilities except those at service
  stations and bulk plants
Emissions from loading tank trucks and rail cars
Emissions from storage and transfer operations
                                              A-19

-------
                                    Figure  A-2.   (cont)

               Summary Table  Of  VOC  Emissions  ^or
                                                    (County or  Equivalent)

                                        (tons  per day)

Organic Chemical Manufacture
Polyethylene
Propylene
Styrene
Others (specify)
SOCMI
Fugitive
Air Oxidation
Others (specify)
Inorganic Chemical Manufacture
Fermentation Processes
Vegetable Oil Processing
Pharmaceutical Manufacture
Plastic Products Manufacture
Rubber Tire Manufacture
SBR Rubber Manufacture
Textile Polymers and Resin
Manufacture
Synthetic Fiber Manufacture
Iron and Steel Manufacture
Coke Ovens
Others (specify)
Industrial Surface Coating
Large Appl iances
Magnet Wi re
Autos and Light Trucks
Cans
Metal Coils
Paper
Fabric
Metal and Wood Furniture
Miscellaneous Metal Products
Flatwood Products
Plastic Products
(continued on next page)
Applicable
Regulation^



































Base Year
(specify year)
Point Area










































B



























Base Line
Projection
(specify year)
Point Area






































































Revised SIP
Strategy
Projection
(soecify year)
Point Area

































































.




Typical ozone season weekday
List appreviations at end of table with brief explanation,
 (i.e., I = Group I CTGs - State Reg XX.X;
 II = Group II CTGs - State Reg. YY.Y,  etc.).

                                             A-20

-------
                                    Figure A-2.  (cont)

              Summary Table Of VOC Emissions For
                                                  (County or Equivalent)

                                       (tons per day)

Large Ships
Large Ai rcraft
Others (specify)
Non-industrial Surface Coating
Architectural Coatings
Auto Refinishing
Others (specify)
Other Solvent Use
Degreasing
Dry Cleaning
Perchloroethylene -
Petroleum
Other
Graphic Arts
Adhesi ves
Cutback Asphalt
Solvent Extraction Processes
Consumer/Commercial Solvent Use
Others (specify)
Waste DisDOsal
Municipal Waste
Combustion
Landfills
TSDFs
POTWs
ITWs
Industrial Boiler Co-firing
Others (specify)
Applicable
Regulation2




























Base Year
(specify^ year)
Point Area
























































Base Line
Projection
(specify year)
Point Area
























































Revised SIP
Strategy
Projection
(specify year)
Point Area
























































Typical ozone season weekday
List appreviations at end of table with brief explanation,
 (i.e., I = Group I CTGs - State Reg XX.X;
 II = Group II CTGs - State Reg. YY.Y, etc.).
                                          A-21

-------
                                   Figure A-2.  (cont)


           Summary Table Of VOC Emissions  For
                                                 (County or Equivalent)

                                    (tons  per day)

Other Miscellaneous Sources
Fuel Combustion
Forest, Agricultural, and
Other Open Burning
Pesticide Applications
Stationary Internal Combustion
Engines
Mobile Sources
Highway Vehicles
Light Duty Autos
Light Duty Trucks
Heavy Duty Gasoline Trucks
Heavy Duty Diesel Trucks
Other Highway Vehicles
Non-highway Vehicles
Rail
Ai rcraft
Vessels
Other
Mobile Sources Total:
Stationary Sources Total:
Grand Total For All Sources:
Applicable
Regulation^






















Base Year
(specify year)
Point Area











































1
Base Line
Projection
(specify year)
Point Area












































Revised SIP
Strategy
Projection
(specify year)
Point Area












































Typical ozone season  weekday
List appreviations  at end of table with brief explanation,
 (i.e., I = Group I  CTGs  - State Reg XX.X;
 II = Group II CTGs  - State Reg. YY.Y,  etc.).
                                          A-22

-------
                                     Figure A-2.   (cent)




      Summary Table For Oxides Of Nitrogen Emissions For




                                         (tons per day)
(County or tquivalent)
External Fuel Combustion
Utility Boilers
Industrial Boilers
Commercial, Institutional, Residential
Other External Fuel Combustion
Stationary Internal Combustion
Reciprocating Engines
Gas Turbines
Other Combustion
Waste Disposal
Open Burning
Other
Industrial Processes
Chemical Manufacturing
Adipic Acid
Nitric Acid
Other
Iron and Steel
Mineral Products
Cement
Glass
Other
Petroleum Refining
Other
Mobile Sources
Highway Vehicles
Light Duty Autos
Light Duty Trucks
Heavy Duty Gasoline Trucks
Heavy Duty Diesel Trucks
Other Highway Vehicles
Base Year
Point Area
*

Base Line
Projection
Point Area


Revised
SIP Strategy
Projection
Point Area


Typical ozone season weekday
                                           A-23

-------
                                       Figure  A-2.   (cont)




         Summary Table For Oxides Of Nitrogen Emissions For




                                           (tons per day)
(County or Equivalent)

Non-highway Vehicles
Rail
Ai rcraft
Vessels
Other
Mobile Sources Total:
Stationary Sources:
>250m Effective Stack Height: Subtotal
Other Stationary Sources: Subtotal
Grand Total For All Sources:
Base Year
Point Area









*










Base Line
Projection
Point Area




















Revised
SIP Strategy
Projection
Point Area




















*  Typical ozone season weekday
                                             A-24

-------
                                    Figure A-2.  (cont)




         Summary Table For Carbon Monoxide Emissions For




                                         (tons per day)
(County  or  Equivalent)
External Fuel Combustion
Utility Boilers
Industrial Boilers
Commercial, Institutional, Residential
Other External Fuel Combustion
Stationary Internal Combustion
Reciprocating Engines
Gas Turbines
Other Combustion
Waste Disposal
Other
Industrial Processes
Chemical Manufacturing
Iron and Steel
Mineral Products
Petroleum Refining
Other
Mobile Sources
Highway Vehicles
Light Duty Autos
Light Duty Trucks
Heavy Duty Gasoline Trucks
Heavy Duty Diesel Trucks
Other Highway Vehicles
Non-highway Vehicles
Rail
Ai rcraft
Vessels
Other
Base Year
Point Area


Base Line
Projection
Point Area


Revised
SIP Strategy
Projection
Point Area
•

Typical ozone season weekday
                                           A-25

-------
                                   Figure A-2.  (cont)




        Summary Table For Carb.on Monoxide Emissions For




                                        (tons per day)'
(County or Equivalent

Mobile Sources Total :
Stationary Sources:
>250m Effective'Stack Height: Subtotal
Other Stationary Sources: Subtotal
Grand Total For All Sources:
Base Year
Point Area










Base Line
Projection
Point Area










Revised
SIP Strategy
Projection
Point Area










"ypical  ozone season weekday
                                         A-26

-------
r
                                    TECHNICAL REPORT DATA
                             fPleasc read Instructions on the reverse before completing)
 1. REPORT NO.

  EPA-450/4-88-023
                               2.
4. TITLE AND SUBTITLE
  Guidance For The Preparation Of Quality Assurance
  Plans  For 03/CO SIP Emission Inventories
                                                             3. RtCIPIENT'S ACCESSION NO
                                                             5. REPORT DATE
               December  1988
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
  Sharon  Kersteter
  Rebecca Battye
             8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Alliance Technologies Corporation
  500  Eastowne Drive
  Chapel  Hill, NC 27514
                                                             10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.

                68-.Q2-4396
                Work Assignment 3
 12. SPONSORING AGENCY NAME AND ADDRESS
  U.S,  Environmental Protection Agency
  Office  of Air and Radiation
  Office  of Air Quality Planning and Standards
  Research  Triangle Park,  NC  27711
             13. TYPE OF REPORT AND PERIOD COVERED

                Fi na 1	
             14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
  EPA  Project Officer:  William B. Kuykendal
 16. ABSTRACT
 • w* r*&t# i riMW *
 This document presents guidance for the preparation of quality  assurance (QA)  plans
 by State and local air pollution control agencies required  under the post 1987 ozone
 and carbon  monoxide State  Implementation Plans.   The guidance discusses both  required
 and recommended components  for these QA plans.   Major topics that are covered  are as
 follows:  QA policy statement, QA and the project organization,  planning, data
 collection  and analysis, data  handling, data  reporting, and QA  auditing.
17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                           c.  COSATI Field/Group
 Quality Assurance
 Ozone
 Carbon Monoxide
 Emission Inventories
 State Implementation  Plans
 18. DISTRIBUTION STATEMENT

 Release Unlimited
19. SECURITY CLASS (This Report)
  Not  classified
21. NO. OF PAGES
     62
                                                20. SECURITY CLASS (This page)

                                                 Not classified	
                                                                           22. PRICE
 EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE

-------