United States Office of Air Quality EPA-450/4-81-
Environmental Protection Planning and Standards September 1981
Agency Research Triangle Park NC 27711
Air ~
Procedures for Emission
Inventory Preparation
Volume II: Point Sources
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NOTICE
The Procedures for Emission Inventory Preparation consists of these
five volumes.
Volume I - Emission Inventory Fundamentals
Volume II - Point Sources
Volume III - Area Sources
Volume IV - Mobile Sources
Volume V - Bibliography
They are intended to present emission inventory procedures and
techniques applicable in State and local air programs, and for con-
tractors and other selected users. The object is to provide the best
available and "state of the art" information. For some areas, however,
the available source information and data either may allow more precise
procedures and more accurate estimation of emissions or may not be amen-
able to the use of these procedures. Therefore, the user is asked to
share his knowledge and experience by providing comments, successfully
applied alternative methods or other emission inventory information
useful to other users of these volu'neo. Please forward comments to the
U.S. Environmental Protection Agency, Air Management Technology Branch,
(MD-14), Research Triangle Park, NC 27711. Such responses will provide
guidance for revisions and supplements to these volumes.
Other U.S. EPA emission inventory procedures publications:
Procedures for the Preparation of Emission Inventories for
Volatile Organic Compounds, Volume I, Second Edition,
EPA-450/2-77-028, U.S. Environmental Protection Agency,
Research Triangle Park, NC, September 1980.
Procedures for the Preparation of Emission Inventories of
Volatile Organic Compounds, Volume II: 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.
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EPA-450/4-81-026b
Procedures for Emission Inventory Preparation
Volume II: Point Sources
by
Monitoring and Data Analysis Division
Office of Air Quality Planning and Standards
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
September 1981
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This document is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers. Copies are
available free of charge to Federal employees, current EPA contractors
and grantees, and nonprofit organizations - in limited quantities - from
the Library Services Office (MD-35), U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina 27711; or, for a fee, from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
Virginia 22161.
This report was furnished to the Environmental Protection Agency by GCA
Corporation, Bedford, Massachusetts 01730, in fulfillment of Contract
No. 68-02-3087. The contents of this report are reproduced herein as
received from GCA Corporation. The opinions, findings and conclusions
expressed are those of the author and not necessarily those of the
Environmental Protection Agency.
Publication No. EPA-450/4-81-026b
ii
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TABLE OF CONTENTS
Section Page
List of Figures v
List of Tables v
1.0 INTRODUCTION 1-1
1.1 Preparing the Emission Inventory 1-3
1.2 Quality Assurance 1-5
1.3 Documentation 1-7
1.4 Emission Inventory Manpower Requirements 1-7
1.5 Organization of Volume 1-8
2.0 DATA COLLECTION 2-1
2.1 Identification of Point Sources 2-2
2.2 Data Requirements 2-5
2.3 Data Collection 2-11
2.3.1 Questionnaire 2-11
2.3.2 Plant Inspections 2-14
2.3.3 Other Data Procurement Methods 2-15
3.0 DATA ANALYSIS AND ESTIMATION OF EMISSIONS 3-1
3.1 Data Analysis and Validation 3-1
3.1-1 Locating and Correcting Errors and
Inconsistencies in Data 3-1
3.1.2 Engineering Assessment of Data 3-2
3.2 Estimation of Emissions 3-8
3.2.1 Source Test Data 3-8
3.2.2 Material Balances 3-8
3.2.3 Emission Factors 3-9
3.2.3.1 Available Emission Factors 3-10
3.2.3.2 Development of Emission Factors 3~10
3.2.4 Calculation of Emissions Using Emission Factors . . 3—11
3.2.4.1 Activity Data 3-12
3.2.4.2 Control Device Efficiency 3-13
3.3 Temporal Adjustment of the Annual Inventory 3-14
3.4 Emission Projections 3-14
3.4.1 Major Point Source Projections ..... 3-16
3.4.2 Aggregate Point Source Projections 3-17
3.4.3 Projection Documentation and Review 3-17
4.0 PRESENTATION AND DOCUMENTATION OF THE INVENTORY 4-1
4.1 Presentation of the Inventory 4-1
4.2 Documentation of the Inventory 4-3
111
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Section Page
5.0 INV
5.1
5.2
DRYING MAJOR POINT SOURCE CATEGORIES
5.1.1 External Combustion Sources
5.1.3 Solid Waste Incineration and Open Burning . . .
5.2.1 Special Problems
5.2.2 Special Techniques
5.2.5 Metallurgical Industry
- GENERAL INSTRUCTIONS TO THE APER FORM
- SUPPLEMENTAL INSTRUCTIONS TO THE APER FORM
- EXAMPLE AIR POLLUTANT EMISSIONS REPORT
- GRAIN ELEVATOR QUESTIONNAIRE
. . 5-1
. . 5-2
. . 5-4
. . 5-5
. . 5-6
. . 5-6
. . 5-12
. . 5-18
. . 5-19
. . 5-20
. . 5-20
. . 5-21
. . 5-24
. . 5-24
. . 5-25
. . A-l
. . B-l
. . C-l
. . D-l
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LIST OF FIGURES
Figure paSe
2-1 Monthly Fuel Use Pattern 2-7
3-1 Example Point Source Load Sheet - Plant Record
Transactions 3-2
3-2 Example Point Source Load Sheet - Point Record
Transactions • 3-3
3-3 Example Point Source Load Sheet - SCC Record
Transactions 3-4
4-1 Tabular Reporting Format for 1982 State Implementation
Plan 4-2
LIST OF TABLES
Table Page
2-1 Standard Industrial Classifications (SICs) Associated
With VOC Emissions; Emission-Per-Employee Ranges 2-3
3-1 Examples of Parameter Check Values 3-7
5-1 Contribution of Major Point Source Categories to
Nationwide Emission Totals 5-3
5-2 NEDS Source Classification Codes for Incinerators 5-7
5-3 Industries, Emissions and Controls 5-8
5-4 Major Sources of Fugitive Particulate Emissions ...... 5-13
5-5 Steel Mill Source Priority Ranking for Particulate
Emissions 5-22
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1.0 INTRODUCTION
This volume is the second of a tnultivolume series designed to assist
state and local air pollution agencies in preparing emission inventories of
air pollutants. The emission inventory procedures presented in this volume
are specific to point sources. Volume I presents a review of the fundamentals
of preparing an emission inventory of point, area and mobile sources; Volumes
III and IV pertain specifically to inventorying area and mobile source
emissions, respectively: and Volume V is a bibliography of pertinent emission
inventory literature.^~^
An inventory of point source emissions should provide a comprehensive,
accurate and current accounting of air pollutants released to the atmosphere
by specific stationary facilities/plants/activities. Emissions from
stationary sources not Included jn the point source inventory must be
accounted for in the inventory of area sources. Emissions from point and area
sources, together with those from mobile sources, comprise the total inventory
of emissions and provide the foundation for agency actions aimed at
maintaining or improving ambient air quality.
Under ideal circumstances all stationary sources would be considered
point sources. However, in practice, only sources that emit more than
specified levels of certain pollutants are considered point sources. At a
minimum, these levels are determined by State Implementation Plan (SIP)
requirements for reporting point source emissions specified in the Clean Air
Act and its Amendments under the published provisions of Title 40 of the Code
of Federal Regulations Part 51 (40 CFR 51), ^ Subpart 51.321. In general,
the Clean Air Act Amendments of 1977 require the development of emission
inventories (especially for nonattainment areas) which are far more detailed
and comprehensive than previously specified or currently available in many
control agencies throughout the country.° State agencies are required to
report point source emissions data annually to the EPA through their
respective regional office for certain sources. Point sources subject to the
annual emissions reporting requirements are:
Any facility that actually emits a total of 90.7 metric tons (100 tons)
per year or more of particulate matter, sulfur oxides, hydrocarbons, or
nitrogen oxides.
Any facility that actually emits a total of 907 metric tons (1000 tons)
per year or more of carbon monoxide.
Any facility that actually emits a total of 4.5 metric tons (5 tons) per
year or more of lead or lead compounds measured as elemental lead.
In addition, reporting of annual emissions from individual emission points
within a facility is required for those points for which:
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Actual emissions of particulate matter, sulfur oxides, hydrocarbons and
nitrogen oxides equal or exceed 22.7 metric tons (25 tons) per year.
Actual emissions of carbon monoxide equal or exceed 227 metric tons (250
tons) per year,
Actual emissions of lead, or lead compounds measured as elemental lead,
equal or exceed 4.5 metric tons (5 tons) per year.
The provisions of 40 CFR 51 require that particulate matter, sulfur
oxides, carbon monoxide, nitrogen oxides, and hydrocarbon emission data be
submitted in the format of the NEDS point source coding forms.' Emission
data for lead or lead compounds measured as elemental lead must be submitted
in the format of the Hazardous and Trace Emissions System (HATREMS) point
source coding forms.
State agencies are required to submit emission data in the annual report
for any point source for which one or more of the following conditions occurs:
A source achieves compliance at any time within the reporting period with
any regulation of an applicable plan.
A new or modified source receives approval to construct during the
reporting period or begins operating during the reporting period.
A source ceases operations during the reporting period.
A source's emissions have changed more than 5 percent from the most
recently submitted emission data.
Concerning the last requirement, if it is determined that emissions from any
point source have not changed more than 5 percent from the most recently
submitted emission data, the state shall only update the year of record of the
previously reported emission data.
Many state agencies have taken action to reduce the emission levels
required for point source classification to levels well below those required
by 40 CFR 51. The reduction in point source emission cutoff level is usually
instituted by the agency to assess emissions and alternative control
strategies for specific source categories/pollutants of principal interest to
the agency. This focusing of point source inventorying efforts allows the
agency to collect and assess detailed data on categories which meet definite
criteria; e.g., they are known emitters of pollutants of concern in the
jurisdiction, they consist of an identifiable and manageable number of
individual sources, and they are efficiently controlled by existing
technology. Gasoline marketing and dry cleaning are two source categories
which generally meet the above criteria, and some agencies have elected to
include all sources in these categories in the point source file even though
emissions from individual sources are far less than 100 tons per year.
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The accuracy and utility of the emission inventory will increase as a
greater fraction of total emissions is included in the point source data
file. Data in the point source file are more reliable and extensive than the
data maintained in the area source file and can be readily expanded through
contact with the source to include data that meet special needs of the agency;
e.g., temporal emission patterns and species identification data-
1.1 PREPARING THE EMISSION INVENTORY
Five basic steps are included in the preparation of an emission
inventory. The first step is planning. Prior to the initiation of data
collection activities, the agency must carefully define the objectives of the
inventory and develop the organization, program and schedule for preparing the
inventory. All proposed procedures and data sources should be documented at
the outset and subjected to review by all potential users of the final
inventory, including the management and technical staff of the agency.
At the end of the planning period the agency will have defined the
program for preparing the inventory. The following items," which are
discussed in more detail in Volume I, will have been addressed and fully
resolved and documented:
The end use(s) of the inventory are established.
Source categories have been defined which are compatible with available
source and emission information, and are of sufficient detail to
facilitate control strategy projections.
The role of existing inventory data has been determined and any
previously omitted data and sources have been identified.
The geographic area has been identified. Typically, this area will
consist of the agency's entire jurisdiction.
Decisions have been made on whether to temporally adjust emissions and to
what level; e.g., seasonally or daily.
The point source cutoff has been defined. Sources smaller than the
cutoff limit will be treated as area sources.
The point source data collection methods have been determined.
Procedures for identifying nonreactive emissions have been selected.
The agency has decided on how emissions will be projected, and the
projection period, including end year and intermediate years, has been
designated.
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An inventory data handling system has been selected and coding forms are
available.
The agency's future use of dispersion models has been considered and
appropriate plans have been made to obtain all data required by the
models«
Quality assurance procedures have been selected.
Written documentation of all procedures has been completed.
Manpower and budget allocations have been made and organization has been
established by assigning authority and responsibilities, including those
for quality assurance.
The second basic step is data gathering. A major distinction involves
which sources should be considered point sources in the inventory and which
should be considered area sources. Data collection procedures for these two
source types are fundamentally different. Individual plant contacts, in
general, are used to collect point source data, whereas collective information
is generally used to estimate area source activity. Much more detailed data
are collected and maintained on point sources.
Only sources that emit more than some specified cutoff level of pollutant
are considered point sources. Depending on the needs of the agency, this
cutoff level will vary. An emission cutoff level appreciably lower than the
required level of 100 tons/year is recommended to include source categories
which are identifiable, controllable and collectively significant. A recent
study in several urban areas identified many VOC sources emitting less than 25
tons per year.^ Moreover, many of these sources were in categories for
which no reliable area source inventory procedures currently exist. Because
of this, some agencies have opted to define cutoff levels at or below 5 tons
per year in order to directly cover a large percentage of VOC and other
emissions in a point source inventory, rather than rely heavily on estimates
of collective emissions from area source categories.
Several methods for collecting data for point sources of emissions are
presented in Chapter 2 of this volume. However, the inventorying agency must
decide which procedures to use in its inventory effort. Point source data
gathering methods include mail surveys, plant inspections, use of agency
permit and compliance files, and source listings. The agency should determine
in the planning phase which methods will be used in data collection. This
determination will allow time to obtain necessary reference and support
materials and help define the time and manpower requirements of the individual
data collection tasks.
Special procedures may be required to obtain information not normally
obtained when compiling an emission inventory. This information may be
temporal data or relate to pollutant characterization; e.g., fraction of
inhalable particulate or VOC compound identification. Even though the data
1-4
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are not required for the basic inventory, the agency may deem it expedient to
collect this information at the time plant contacts and surveys are made as
part of a routine inventory update. If the agency anticipates the need for
special data, it is more efficient to collect the data at the same time the
other source and emission data are collected for the basic inventory.
The third basic step in the inventory compilation effort involves the
analysis of data collected and the developing of emission estimates for each
source. Source test data, material balances, and emission factors are all
used to make these estimates. Estimates of projected emissions must also be
made as part of this step. Experienced personnel with a high level of
competence in process and environmental engineering and familiar with the
industrial activity in the jurisdiction will be needed to assess the
reliability of the collected data- Although quality assurance error checks
can alleviate many of the sources of error, engineering judgment must be
exercised to establish the validity of source, process, and emission
information.
The fourth step is reducing and filing all collected data. The collected
data and source information should be reduced to a predesigned uniform source
file record format and entered into the file. The source file system can be
either a computerized or a manual file system. Computerized systems can be
programmed to perform some of the data analysis, error checks and calculation
functions comprising the third step above. The agency, before developing its
own computerized system, should consider the use of systems developed by the
U.S. Environmental Protection Agency to compile, analyze and present point
source emission inventory data. The National Emissions Data System (NEDS)^
and the Emission Inventory System/Point Sources (EIS/PS)^ are two such
systems that are available to state agencies. The EIS/PS is a system which- is
compatible with NEDS and satisfies EPA reporting requirements. EPA will
provide assistance and training to the agency and its personnel in installing
and operating the system.
The fifth step is reporting. Basically, reporting involves presenting
the inventory data in a format that serves the agency in the development and
implementation of control programs or other regulatory efforts. Depending on
the capabilities of the Inventory data handling system, many kinds of reports
can be developed that will be useful in numerous agency activities.
1.2 QUALITY ASSURANCE
Quality assurance procedures are needed to prepare an emission inventory
of known accuracy, which can be used with some specified level of confidence
to assess the impact of control strategies on emissions and air quality.
Also, lower overall program costs may be realized because inventory update and
revision activities will not be as extensive as when conducted without a
quality assurance program and can be effectively focused on those areas of the
inventory requiring the most attention.
1-5
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Principles of quality assurance can be applied in planning, data
collection, calculation of emissions, and reporting of the emission
inventory. Quality assurance requires anticipating the measures needed in
each of the inventory functions. To promote effective quality assurance, the
inventory planner should consider the steps listed below prior to initiating
inventory tasks.•*•"
1. Planning
- Plan to allocate resources for maximum quality assurance.
- Plan to account for all significant emission sources.
Prepare a checklist of sources to be evaluated.
- Use staff experienced in data collection and analysis.
- Plan for routine checking of calculations.
- Plan for checking data file entries.
Prepare data checking programs (when using a computer for data
handling).
~ Maintain a separate quality assurance staff.
2. Data collection and analysis
- Use redundant identification of major sources (quality
assurance staff should prepare an independent source list).
- Check questionnaire design.
Check data collected.
Check emission estimation methods.
- Check calculated results.
- Verify adherence to quality assurance procedures.
3. Data handling and analysis
Check data file entries.
Check individual data entries (missing emissions, SIC codes,
addresses, etc.)
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Assign agency estimates for missing data.
- Check for data correctness.
Review tabulated data for quality.
4. Data reporting
Check pollutant emissions from individual categories and their
totals against other estimates or estimates for other areas..
Volume 1^ contains an extensive discussion of Quality Assurance which
will acquaint the user with the concepts and principles of quality assurance.
Additional information on emission inventory quality assurance can be found in
References 10 through 12 or can be obtained through an EPA Regional Office.
The most effective instruments of quality assurance are the standard operating
procedures developed and documented by the agency, as these steps determine
methods to be used throughout the inventory effort.
1.3 DOCUMENTATION
Documentation is an integral part of an emission inventory. Review of
the written documentation of an inventory's data sources and procedures by the
agency's quality assurance and technical personnel will help to uncover, if
they exist, errors in assumptions, calculations or methods. Remedial actions
to correct detected errors will lead to the development of a reliable and
technically defensible data base which is essential for enforcement actions,
source impact assessments, and development of emission control strategies.
While documentation requirements may evolve during the data collection,
calculation, and reporting steps of the emission inventory, these requirements
should be anticipated during the planning phase. Planning the level of
documentation required will (1) ensure that important supporting information
is properly developed and maintained, (2) allow extraneous information to be
identified and disposed of, thereby reducing the paperwork burden, (3) help
determine data storage requirements, and (4) aid in identifying aspects of the
inventory on which to concentrate quality assurance efforts.
1.4 EMISSION INVENTORY MANPOWER REQUIREMENTS
To ensure that sufficient resources have been allocated to achieve good
results with an inventory effort, cost and manpower requirements should be
evaluated in the planning stage of the project. Technical manpower and budget
allocations required will be a function of the number and type of sources to
be inventoried and the desired data base detail. These inputs, in turn, will
be affected by the inventory end use and by the data handling capabilities of
the agency. Administrative and secretarial support will be a function of the
technical manpower and budget allocations determined by all of these
factors.13,14
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Manpower and budget requirements will vary for each Inventory effort.
When an agency has conducted inventories regularly, its past experience can be
used to estimate requirements. A detailed discussion of manpower requirements
is provided in Volume I of this series.-'- A computer model is also available
from EPA which estimates technical and administrative costs associated with
emission inventories. Information can be obtained through EPA Regional
Offices or from the Control Programs Operations Branch, Control Programs
Development Division, MD-15, U.S. Environmental Protection Agency, Research
Triangle Park, NC 27711.
1.5 ORGANIZATION OF VOLUME
The following three chapters of this document present the "how to" for
the collection, analysis and presentation of data contained in the point
source emission inventory. Emphasis is given to methods that produce annual
emission estimates. However, attention is devoted to preparing an annual
inventory of emissions that can be adjusted to seasonal or daily temporal
levels. Problems encountered in inventorying major source categories and
solutions to them are provided in the final chapter. The appendices contain
copies of questionnaires and associated process and emission information that
have been developed by EPA for the purpose of preparing a point source
inventory.
References for Chapter 1.0
1. Procedures for Emission Inventory Preparation, Volume I; Emission
Inventory Fundamentals, EPA-450/4-81-026a, U.S. Environmental Protection
Agency, Research Triangle Park, NC, September 1981.
2. Procedures for Emission Inventory Preparation, Volume^ III; AreaSources,
EPA-A50/4-81-026c, U.S. Environmental Protection Agency, Research
Triangle Park, NC, September 1981.
3. Procedures for Emission Inventory Preparation, Volume IV: Mobile
Sources, EPA-450/4-81-026d, U.S. Environmental Protection Agency,
Research Triangle Park, NC, September 1981.
4. Procedures for Emission Inventory Preparation, Volume V; Bibliography,
EPA-450/4-81-026e, U.S. Environmental Protection Agency, Research
Triangle Park, NC, September 1981.
5. Code of Federal Regulations (CFR), Title 40. Part 51.
6. Procedures for the Preparation of Emission Inventories for Volatile
Organic Compounds, Volume I: Second Edition, EPA-450/2-77-028, U.S.
Environmental Protection Agency, Research Triangle Park, NC, September
1980.
7. AEROS Manual Series, Volume II, AEROS User's Manual, EPA-450/2-76-029,
U.S. Environmental Protection Agency, Research Triangle Park, NC,
February 1976.
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8. Shah, M. C., and F. C. Sherman, "A Methodology for Estimating VOC
Emissions from Industrial Sources," presented at the 71st Annual Meeting,
American Institute of Chemical Engineers, Miami Beach, FL, November 1978.
9. The Emission Inventory System/Point Source User's Guide,
EPA-450/4-80-010, U.S. Environmental Protection Agency, Research Triangle
Park, NC, May 1980.
10. Bradley, R., J. Stredler, and H. Taback, "Improving Emission Inventory
Quality—A QA/QC Approach," presented at the 73rd Annual Meeting of the
Air Pollution Control Association, Montreal, Canada, June 22-27, 1980.
11. Development of an Emission Inventory Quality Assurance Program,
EPA-450/4-79-006, U.S. Environmental Protection Agency, Research Triangle
Park, NC, December 1978.
12. Goklany, I. M., "Emission Inventory Errors for Point Sources and Quality
Assurance Aspects," Journal of the Air Pollution Control Association,
30(4): 362-5, April 1980"!
13. Southerland, J. II., "Emission Inventories: A Perspective," presented at
the 71st Annual Meeting of the Air Pollution Control Association,
Houston, TX, June 25-30, 1978.
14. Donaldson, T., and M. Senew, "Estimating the Cost of State Emission
Inventory Activities," presented at the 73rd Annual Meeting of the Air
Pollution Control Association, Montreal, Canada, June 22-27', 1980.
1-9
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2.0 DATA COLLECTION
During the planning stages the agency will have made decisions which have
an important bearing on the number of stationary sources to be included in the
point source inventory, with the principal determinant being the emission
level selected to distinguish point from area sources. The distribution of
both source categories and pollutants within the point source inventory will
also change as the point source emission level is lowered for all pollutants.
Further changes in these distributions will occur if the agency elects to
include all facilities of a source category (e.g., dry cleaning or asphalt
concrete batch plants) regardless of the size of the facility, in the point
source inventory.
At a minimum, the point source cutoff level will be that as defined in 40
CFR 51. However, to increase the accuracy and utility of the overall
inventory, lower emission levels could be selected by the agency to increase
the number of emission sources, and thus the fraction of the emission
estimates maintained in the point source file. Accuracy will be increased
because the inclusion of a source in the point source inventory requires some
form of direct plant contact to obtain and validate the data maintained in the
point source file. In addition, the far greater amount of data maintained in
the point source file will allow the agency to appraise more accurately and
confidently the contribution of sources to ambient air quality and the
effectiveness of proposed control strategies.
The agency, in addition to reducing the point source emission level for
all sources, may elect to include within the point source inventory all
sources comprising a source category, regardless of the size of individual
sources. Gasoline marketing and dry cleaning are two examples of source
categories that are significant emitters of VOC but whose individual sources
generally emit appreciably less than 25 tons per year. The agency should
consider maintaining these and other source categories in the point source
file, particularly those for which Control Techniques Guidelines (CTGs) have
been developed (see Reference 1 for a listing of VOC source categories for
which CTGs have been published) and provide for the reporting of data from
these sources.
In the case of a pollutant specific inventory (e.g., lead or a hazardous
organic species) the agency should identify all source categories known to
emit the specific pollutant, using EPA publications and the technical
literature as resources. If feasible, all sources of a specific hazardous
pollutant should be included in the point source inventory file.
In addition to defining the emission cutoff limit and any specific source
categories or pollutants to be included in the inventory, the agency planners
should estimate the number of sources to be contacted and identify the data
requirements and methods of data collection. These considerations play a
major role in determining the resources necessary to achieve the objectives of
the inventory.
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2.1 IDENTIFICATION OF POINT SOURCES
A necessary step in preparing the emission inventory is to develop a list
of the facilities to be surveyed. The list will identify each facility or
plant by name, address, size, and standard industrial classification (SIC)
code.* If possible, the name and telephone number of the individual at the
facility who will be responsible for dealing with the agency should also be
identified to facilitate further correspondence and telephone contact. The
decision to include a facility on the point source mailing list will depend
upon the agency's criteria for estimating potential emissions. If the process
responsible for emissions is known, a determinant, such as number of
employees, which correlates with emissions from the process can be used to
estimate emissions. Parameters other than employment such as sales can be
used to estimate emissions, however, employment is generally the most readily
available parameter. Correlative relationships between employment and
emissions are only rough guidelines, as is indicated by the range of values
exhibited within the several VOC sources shown in Table 2-1.
The type and number of facilities comprising the mailing list will
determine the design and selection of questionnaires and will give the agency
an indication of how many and what kinds of sources will be included in the
point source inventory. In this regard, the point source list can be used to
help the agency determine if the resources allocated for the compilation
effort will be sufficient. Frequently, more sources are identified than were
believed to exist during the initial planning stages.
There are numerous information sources which are useful for the
identification of point source candidates. Information sources which are
available include the following:^
Existing Inventories—An existing point source inventory is the best
source of Information, particularly if it has been frequently updated and
well documented. A list prepared from the existing inventory will
require updating by (a) deleting any point source that has discontinued
operation, (b) making appropriate changes for any source that has changed
status, and (c) adding new point sources.
Other air pollution control agency files—Compliance, enforcement, permit
application, or other air pollution control agency files may provide
valuable information on the location and types of sources that exist in
the jurisdiction. These files can also be utilized later to cross-check
information supplied on questionnaires.
*Because the SIC code assigned to a facility denotes the principal economic
activity of the firm, the code may not correspond to the activity contributing
to emissions. If possible, an appropriate source classification code (SCC),
which identifies an emission producing process operation, should be assigned
to the facility to ensure meaningful communication between the facility and
agency.
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TABLE 2-1. STANDARD INDUSTRIAL CLASSIFICATIONS (SICs) ASSOCIATED
WITH VOC EMISSIONS; EMISSION-PER-EMPLOYEE RANGES
General 2-Digit
SIC Categories
20 Food
21 Tobacco
22 Textiles
23 Apparel
24 Lumber & wood
25 Furniture &
fixtures
26 Paper
27 Printing
28 Chemicals
29 Petroleum
30 Rubber, Plastic
31 Leather
32 Stone, clay, etc
33 Primary metal
34 Fab. metal
35 Machinery
36 Elect. Machinery
37 Transpt. equip.
38 Instruments
39 Misc. Mfg.
5171 Bulk terminals
7216 Dry cleaning
Specific 4-l)iglt
SIC Categories
Alcoholic beverages
(2085)
Not surveyed
Coating (2295),
Non-wovens (2297),
Dyeing (2231)
Not surveyed
Finished product (2435),
(2492)
SIC: (2511), (2514),
(2521), (2522), (J542)
Bags, box (2643),
(2651), (2653),
Coated papers
(2641)
Newspaper publishing
(2711), Coram.
printing (2751),
(2754)
Organic chemical mfg.
(2821), (2823), 2861),
Chemical coating (2851).
Specialty chemical (2842),
Carbon black (2895)
All companies
Footwear (3021), Plastics
(3041), (3069)
Mfg. shoes (3149), Bags
(3161), Personal goods
(3172), Leather
refinishlng (3111)
Class products (3221)
Treating (3398), Tubing
(3357)
Screws (3451-2), Metal
stampings (3469), Plating
(3471), Tool mfg. (3423),
(3429)
Industrial machines
Devices (3643), Semlcond.
(3674)
Boats (3732), Truck bodies
(3711, 13, 14, 15)
Optical frames (3832)
Precision instruments
.Jewelry (3914-15), Toys
(3944), Writing instr.
(3951,53)
Al 1 surveyed
All surveyed
Kmission-Per-Employee
Ranges (tons/employee/yr)
0.075
0.536-0.89
0.024-0.07
0.OR-0.24
1.0-1.2'j
0.08-0.5
0.32-0.357
0.11-2.12
0.16-0.256
0.13
0.03-0.092
0.10-0.267
0.19-0.281
0.03-0.048
0.04-0.07
0.11-0.855
0.04-0.199
0.07-0.59
Source: Reference 1, Table 3.1-].
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Files of other government agencies—Files maintained by various Federal
and State government agencies frequently aid in the preparation of the
mailing list. These files may include state industrial directories
wherein companies are listed alphabetically by SIC and county. Agencies
to be contacted include labor, tax, commerce and trade agencies. The
information available from these agencies will vary from state to state.
Contact the appropriate personnel within these agencies to become
familiar with the available and useful data.
EPA/CTG source listings—EPA's Division of Stationary Source Enforcement
has developed point source listings for several source categories for
which Control Techniques Guidance documents have been published (see
Reference 1 for a discussion of these categories). The listings provide
company name, address and, in some cases, a phone number for each
source. These listings are available through EPA Regional offices upon
request by air pollution control agencies. Because additional documents
for other source categories are in preparation, the agency should also
contact the EPA regional office to obtain source listings for these
additional categories if available.
Local information sources—The following local information sources can be
consulted, where available:
Local industrial directories—State and local industrial, commercial
and trade organizations may provide a list of sources which operate
in the inventory area.
- Chamber of Commerce and Regional Planning Commissions—State and
local chambers of commerce and regional planning commissions are
knowledgeable about industrial activity, may publish industrial
directories and should be able to provide industrial growth
estimates.
Yellow Pages—The local telephone directory will have names,
addresses and phone numbers of many industrial/commercial sources.
Caution is advised in that phone directory areas often do not
correspond to county or community boundaries.
Manufacturers and suppliers—Contact firms that make or supply
equipment and materials used in major industrial applications. For
example, a supplier of organic solvents may be able to provide
information concerning the existence and location of sources or at
least an estimate of the amount and types of solvents used by
industry within the jurisdiction.
National publications—The following national publications can be used,
when available:
- Dun and Bradstreet, Million Dollar Directory^—Companies with
sales over $1,000,000 a year are compiled by SIC and county.
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Dun and Bradstreet, Middle Market Directory^—Companies with sales
between $50,000 and $1,000,000 a year are compiled by SIC and county.
- Dun and Bradstreet—Industrial Directory.
National Business Lists^—Companies are listed by SIC and county
with information on financial strength and number of employees.
Trade and professional society publications"''—Names and
addresses of members are listed along with their type of business.
Other publications^"!! contain detailed information that may also
be useful in estimating emissions.
When compiling the final point source list, special attention should be
given to the Standard Industrial Classification (SIC) code associated with
each source. SIC codes were devised by the U.S. Office of Management and
Budget to classify establishments acording to the type of economic activity in
which they are engaged.*-*• Employment information should also be obtained to
assist in estimating establishment and industry size and in estimating
emissions. The Commerce Department reports the number of establishments and
employment in states and counties by SIC. ^ Employment information by
facility is generally available from state agencies and industrial directories.
2.2 DATA REQUIREMENTS
The types and quantity of data required in an emission inventory of point
sources depend upon the ultimate use of the inventory and the accuracy
required. The data requirements defined below are those necessary for
developing a comprehensive emission inventory that can be used for
mathematical dispersion modeling.-^ Included are all data requirements for
point source inventories specified in Appendix D of 40 CFR 51.1-*
a. DEFINITION, GENERAL INFORMATION, AND IDENTIFICATION. The
information required is as follows:
1. Geographic code identification number—using standardized
state, county and AQCR identification code numbers for
compatibility with other data systems.
2. Source number—this is a sequential identification number
within each county; a source is a plant or facility.
3. Point number—this is a sequential number within each source
(plant or facility) used to denote individual stacks, vents, or
emitting points.
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4. Year of record—this indicates the date of source operations
data collection or update.
5. Facility name and facility address.
6. Name, address, and telephone number of person at facility to
contact about plant process, emissions and air pollution
control.
7. Ownership of facility—to facilitate sorting of data on the
basis of private, government, or public utility ownership.
8. Confidentiality—an indicator to call attention to the
possibility of the presence of confidential data.
9. Source Classification Code (SCC)—to identify the basic process
or industry activity (this applies to process units which
contribute to emissions from emission points within the
facility).
10. Source Identification Code (SIC)—a code number assigned to a
specific facility. It may or may not accurately reflect the
major processes (SCC) at the plant or facility which are
responsible for emissions.
b. FUEL COMBUSTION DATA. The required fuel combustion data include:
1. Combustion rate—fuel consumed per hour, this amount must be
related to the source classification code to facilitate
calculation of emissions using emission factors.
2. Sulfur content, in percent.
3. Ash content, in percent.
4. Heat content, in millions of Btu (or kilocalories) per SCC rate
unit.
These data are applicable primarily to boilers where external
combustion of oil, coal, wood, or gas as fuels takes place, or to
internal combustion sources burning gas or oil. The combustion (or
process) rate may vary according to season (Figure 2-1). Although
the total consumption for the entire year is of most interest, it
may be necessary to obtain daily or hourly consumption data on a
seasonal or monthly basis to more accurately assess emissions.
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FUEL
USE
SPACE
HEATING
PROCESSING
J I
M
A
J J
MONTH
A
0
N
D
Figure 2-1. Monthly fuel use pattern.
Information on the combustion of fuels must be tied together by
means of an identifier, SCC, to clearly indicate exactly which fuel
is used in what combustion process. This permits the calculation of
emissions by the appropriate emission factor and the application of
the proper control equipment efficiency. The use of the SCC
identifier also enables summary statistics reports to be prepared
providing groupings by control equipment, type of combustion unit,
size, etc.
The stationary point source fuels commonly in use include anthracite
and bituminous coal, lignite, residual and distillate oil, natural
and process gas, coke, bagasse, liquefied petroleum gas, and wood,
all of which are burned in external combustion boilers. Natural gas
and oil are normally used in internal combustion sources.
For fossil fuels, the sulfur and ash contents must be specified in
order to determine sulfur oxide and particulate emissions. Annual
actual fuel charging rate, maximum hourly design rate, and heat
content of the fuel must be available for calculation of emissions.
Further classification of the sources is required in order to
summarize emissions. The standard categories of electric/steam
generation, industrial processing, and commercial/institutional are
typically used for external combustion boilers.
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c. SOLID WASTE COMBUSTION DATA. Solid waste material is usually
incinerated in large municipally operated facilities, commercial
buildings (hotels, apartments, etc.), and institutional and
industrial facilities. The data required for those sources are:
1. Combustion rate—material quantity per hour, as required by the
source classification code.
2. Estimated heat content, if estimation is possible.
d. PROCESS LOSS DATA. This particular source category covers the
largest and most complex group of sources. The basic item of data
is the throughput in units as required by the appropriate SCC.
e. EVAPORATIVE LOSS DATA. The major point sources of evaporative
emissions are fuel storage tanks. The capacity of the storage tank,
expressed in the units required by the SCC, is necessary for
emission calculation. Other data (e.g., vapor pressure of material
stored, type of tank, size and condition) are also necessary for
accurate calculation of emissions. Fugitive emissions may be
important in certain petroleum or organic chemical plants and must
be considered by the agency.
f. MISCELLANEOUS EMISSION DATA. Information usually is grouped as
follows:
1. Percent of annual throughput diurnally and by season—
production, consumption, throughput, etc., representing the
operation of the source, proportioned among the three 8-hour
shifts per day and the four 3-month calendar year quarters.
2. Percent of total fuel used for space heating—this amount of
fuel will be assumed to produce emissions only in the heating
season.
g. EMISSION ESTIMATES. Estimates of emissions from an individual point
source (in tons/year) can be made by the following methods:
1. Stack test results or other emission measurements.
2. Material balance using expertise and engineering knowledge of
the process.
3. Emission factors.
4. Rough estimates.
The above methods are listed in order of preferred approach. The
method of estimation must be specified in order to compare agency
calculated emissions using given emission factors and control
equipment efficiencies to other emission estimating methods.
2-8
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h. MODELING INFORMATION. Modeling information is required for
individual point sources in order to provide input for computer
analysis. The items required, in addition to those previously
discussed, are:
1. Coordinates of emitting point—using a standard reference
system. UTM coordinates are the most commonly used.
2. Stack height—the vertical distance between the point of
emission and ground level.
3. Altitude of stack base—above sea level.
4. Stack diameter—the inside diameter of a circular gas exit
(equivalent cross-sectional area) at the point of emission.
5. Stack exit gas temperature—the temperature of the exhaust
stream under normal operating conditions .
6. Stack exhaust flow rate—the maximum design exhaust gas volume,
or measured flow rate.
7. Plume rise—predicted by an analytical expression which
considers stack characteristics, meteorological conditions, and
the physical and chemical nature of the effluent.
i. CONTROL EQUIPMENT. The equipment controlling each individual air
pollutant at the emission point and its relative efficiency in
controlling each pollutant are required. In many cases there will
be a primary and a secondary item of equipment, and their relative
positions in the flow may affect the overall control efficiency.
In cases where the efficiency range of the device is unknown, an
estimate must be made. Equipment that normally is a part of the
source will usually be considered in the emission factor. It may be
anticipated that the majority of changes in the emission inventory
will be in control equipment parameters. Control efficiencies must
be examined closely because of the high sensitivity of emissions to
estimated control efficiency, particularly at high efficiency levels.
j. COMPLIANCE DATA. The required items about each emitting point are
as follows:
1. Allowable emissions—maximum emissions, in tons per year, of
each pollutant that the source is legally permitted to
discharge into the atmosphere under the most stringent of the
following conditions:
2-9
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i. Existing local/state/provincial/national regulations.
ii. Imminent legislation which will legally require the source
to comply with a specific emission limitation.
2. Source compliance status.
i. In compliance
ii. Not in compliance, on compliance schedule
iii. Not in compliance, not on compliance schedule
iv. Compliance schedule
Date of schedule preparation
Equipment order date
Equipment installation date
Equipment operation date
3. Applicable control regulations.
4. Emergency control action program—certain sources are required
to prepare a program for immediate reduction of emissions
whenever air pollution in the area reaches prescribed
conditions; this item should indicate if a program is required
and, if so, whether the program has been submitted and approved.
k. LAND USE DATA. Several items used primarily in land use planning
operations are normally included with source inventory data. These
are:
1. Normal number of operating hours per day.
2. Normal operating days ^er week.
3. Normal operating weeks per year.
4. Number of employees at facility.
5. Land area of facility.
1. DATA CONFIDENTIALITY. Many sources which submit data request that
all or part be kept confidential, by the control agency. Legal
advice may be required in such cases to assure that the data are, in
fact, legally confidential. Those items actually found to be
confidential must then be protected from release, and must clearly
be identified in the data system, with restrictions on their use
clearly documented. Quantities and kinds of emissions are not held
confidential.
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2.3 DATA COLLECTION
There are several methods available for the collection of point source
emission data. Typical methods include mail and telephone surveys, plant
inspections and use of agency permit and compliance files. The agency must
determine which methods to employ to provide an accurate and comprehensive
data base. Often it is necessary to use a combination of these data
procurement methods to acquire the desired data base in an efficient manner.
The data collection method(s) to be employed should be determined in the
planning stage of the emission inventory effort. During the planning stage,
inventory personnel can review the existing inventory, permit and compliance
files, and source listings to evaluate their usefulness as data sources. If,
after examining the files, it is evident that the required information is
incomplete and/or outdated it will be necessary to conduct a point source
survey to collect the required data.
The inventorying agency has several options available. If only a few
industries are involved, if a small amount of information is needed from each
one, and if written verification is not necessary, a telephone survey may
suffice. In addition, plant inspections by agency personnel may be applicable
when there are only a few industries and/or a small geographic area involved.
These survey techniques which provide direct communication with each point
source can be inexpensive and quite effective in procuring required data.
In many instances, however, especially if there are numerous industries,
a great deal of Information needed, or a large geographical area to be
inventoried, the mail survey is the most practical method for conducting an
emission Inventory. The primary purpose of the mail survey is to obtain
source and emission data by means of a questionnaire mailed to each facility
identified as a potential point source.
Activity level employment data for each facility can be used by the
agency to identify those facilities within the source categories which are
potential point sources and therefore should receive a questionnaire.
Correlative relationships between employment and emissions should be used with
caution as shown by the ranges of emissions-per-employee values given in
Table 2-1 for several VOC source categories.
2.3.1 QUESTIONNAIRE
One of the most effective means of collecting information for emission
inventories directly from point sources is the questionnaire. However, before
proceeding with a questionnaire survey, the agency should be sure that the
information desired Is not already available within the agency. For example,
air pollution control agencies are empowered to require permits to operate
(and annual updates) which can contain source and emission data of the detail
required by the inventory, including plot plans and process flow diagrams. If
this information is available in the permit file, data update and/or
2-11
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verification procedures, rather than the questionnaire survey, can be
instituted with a considerable reduction in effort to both industry and agency
personnel.
The first step in conducting a questionnaire survey is to develop a
mailing list of point sources to be surveyed. Subsection 2.1 of this chapter
describes methods for identifying point sources- The types of data required
to conduct an atmospheric dispersion modeling program are described in detail
in Subsection 2.2 (Data Requirements). To obtain the information called for
in Subsection 2.2, a questionnaire is sent to each facility identified as a
potential point source.
The questionnaire can be prepared as either an industry-specific
questionnaire for each source category or a general questionnaire that can be
completed by all source categories.-*-^ Generally, if the mailing list is
long or if the agency is unfamiliar with many of the sources on the list, the
use of a general questionnaire may be advisable. Oftentimes in practice, a
general questionnaire is merely a collection of process-specific
questionnaires sent out as one questionnaire. Appendix C is an example of a
general emission inventory questionnaire which can be mailed to any industrial
facility.-*-' This form is EPA's questionnaire for point source reporting.
Appendix A contains the general instructions for completing the questionnaire
while Appendix B contains supplemental instructions which are
industry-specific. Although the questionnaire is general in nature, these
supplemental instructions provide industry-related examples for certain items
on the questionnaire. Descriptions of major activities and process/operating
units, feed materials and products which are typical for a specific industry
category are identified to help the source owner complete the questionnaire.
In addition, the units in which data should be reported are specified along
with any special notes applicable to an industry grouping. The facility must
provide a plot plan and process flow diagram suitably labeled to identify
pertinent emission information contained in the questionnaire.
Industry-specific questionnaires are advantageous for certain sources.
Appendix D is an example of a source specific questionnaire sent to operators
of grain elevators. Such questionnaires will generally be shorter, because
questions not applicable to the particular industry need not be included. In
addition, industry-specific terminology can be used to simplify response and
reduce confusion. For these reasons, inventory accuracy is increased when
industry-specific questionnaires are used. However, this approach has
disadvantages. One disadvantage is that the design of many industry-specific
questionnaires requires significant resources and skill. Second, all the
returned questionnaires cannot be processed in the same way because of the
variations in format that will exist from questionnaire to questionnaire.
Third, inappropriate industry-specific questionnaires may be inadvertently
sent to some sources because of lack of knowledge of the emission producing
operations at these sources; e.g., questionnaires provided to the facility on
the basis of SIC code may not be applicable to the facility in question. This
is not uncommon, particularly when the facility is owned by a large
multiproduct corporation involved in integrated production of several
industrial products.
2-12
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The actual mailing of the questionnaires can be performed in two
ways.-*- The first method is by registered mail, which documents for the
agency the date of receipt of this questionnaire by the company. The rate of
response will probably be somewhat greater than if the questionnaires are sent
by first class mail. However, the increase in response may not justify the
added expense of sending every potential source a registered letter. As a
compromise, registered mail may be used only to contact major sources.
The second method is to send the questionnaires by conventional first
class mail. The questionnaire is best addressed to a known responsible plant
contact or, if unknown, to the attention of the plant manager. This directs
the questionnaires to the proper supervisory personnel and reduces the chances
of the material being lost or discarded. It is recommended that a stamped,
agency addressed envelope be included with each questionnaire to facilitate
return of the questionnaire to the agency.
The legal authority empowering the agency to gather the questionnaire
data and requiring the facility to respond should be stipulated on either the
transmittal letter or on the face of the questionnaire as shown on page C-3 of
Appendix C of this volume. While the appropriate regulations and penalties
must be cited, the agency should encourage cooperation by announcing its
intent to provide all possible assistance to a facility. Agency personnel who
are familiar with the industry and inventorying procedures should be
identified in the cover letter as individuals who will, if requested by the
facility, provide assistance in preparing the questionnaire.
A simple computer program can be helpful in the mailing of questionnaires
and the handling of returned questionnaires. The program should be designed
to produce a number of duplicate mailing labels for each source sent a
questionnaire. These labels, can be attached to the questionnaire and to the
stamped return envelope to facilitate the identification of the questionnaires
as they are returned. Additional mailing labels may be used for other
administrative purposes or to recontact those sources whose responses are
inadequate. An example label is shown below:
(SIC Code) 0000 (ID Code)
INDIVIDUAL'S NAME (or PLANT MANAGER)
TITLE
COMPANY NAME
STREET
CITY, STATE, ZIP CODE
The SIC code (or the more definitive 8 digit SCC if known) can be used
internally by the agency to assign the returned questionnaire to the proper
agency personnel for review. The ID number is used to keep records of all
correspondence with a company. If the study area is large, a county
identification number may also be included on the mailing label.
2-13
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It is important to develop a tracking system to determine the status of
the mail survey and to update information as indicated. Such a tracking
system should tell the agency: (1) which companies have been sent
questionnaires; (2) the dates the questionnaires are mailed and returned;
(3) if the correct name, address, and SIC or SCC information was used for each
facility; (4) if recontacting is necessary based on a review of the submitted
data; and (5) the status of the followup contact effort. Tracking can be
accomplished manually through the use of worksheets designed for the purpose
or through the use of a simple computer program.
Upon receipt of the completed questionnaires, the agency can begin
analyzing the data. An initial classification of facilities based on a
preliminary screening of the data should be made. Each facility should be
assigned to one of the following five categories:
P - Point source
A - Area source
N - No emissions (nonsource)
OOB - Out of business
R - Recontact for clarification or additional information
Classifying the facilities in this manner will help to ensure the timely
completion of the mail survey, as well as assist in estimating the amount of
resources that will be subsequently needed in the inventory effort.
The questionnaire recipient should be notified, at the time the
questionnaire is sent, that it may be necessary to recontact the source to
clarify returned information. For this reason the questionnaire should
request that the facility identify a contact who can respond to questions
pertaining to the inventory effort. Sources may have to be recontacted by the
agency for two basic reasons: the source may not have returned the
questionnaire at all, or the response provided may be Inadequate to meet the
agency's needs. If the source has received the questionnaire but has not
returned it as requested, it can be recontacted with a formal letter citing
the appropriate statutes requiring completion of the questionnaire. When the
number of sources to be recontacted is small, the information can be obtained
through telephone contacts or plant visits. If the source refuses to complete
the questionnaire, legal action can be taken to force a response.
2.3.2 PLANT INSPECTIONS
Plant inspections are a direct means of obtaining information or to
verify data that were submitted in the questionnaire. The major advantage of
the plant inspection Is that it may provide more thorough and accurate
information about a facility than would a questionnaire alone. In addition,
errors resulting from misinterpretation of the questionnaire or the agency's
misinterpretation of the response are avoided. In cases where a process is
unique and/or complex, the only realistic way for the agency to gain an
adequate understanding of the emitting points and variables affecting
emissions is to personally observe the plant equipment and to review the
2-14
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operations and process schematics with the appropriate plant personnel.
Before visiting a plant, the agency should notify the plant manager or contact
via formal letter of the upcoming visit and identify, to the extent possible,
the specific information to be acquired at that time. This will allow the
plant manager and staff to assemble the data needed by the agency prior to the
visit.
The data that are gathered during a plant inspection are basically the
same as those solicited in a questionnaire. Generally, more data may be
obtained than would normally be requested on the questionnaire, such as plant
flow diagrams, logs of various process variables and control device
characteristics. Any source test data supplied by a plant should be reviewed
before they are used in the inventory to make sure that acceptable sampling
and analytical procedures were employed and that the test conditions were
representative of the time period covered by the inventory.
Standard plant inspection forms should be developed to help the agency
conduct the formal plant visit. Such forms will assist the inspector in
performing a thorough inspection by specifying the information to be
obtained. After the inspection, the appropriate recorded information should
be checked and inserted if valid into the inventory data base. The inspection
form should be placed with the facility file and maintained there for possible
review by agency personnel.
2.3.3 OTHER DATA PROCUREMENT METHODS
As noted, the use of air pollution agency data such as permit and
compliance file data will identify sources and the nature of their
operations. The permit file is also a potential source of emission data
because all sources can be required to report emissions and other necessary
emission inventory data at the time of application. In addition, the facility
can be required to submit plot plans and process schematics of the plant
suitably labeled to identify pertinent emission information, such as stacks,
processes, etc. Regular (annual) source emission updates, suitable for
entering into the inventory, can be made a mandatory requirement of the permit
process.
References for Chapter 2.0
1. Procedures for the Preparation of Emission Inventories for Volatile
Organic Compounds, Volume I, Second Edition, EPA-450/2-77-028, U.S.
Environmental Protection Agency, Research Triangle Park, NC, September
1980.
2. Million Dollar Directory, Dun and Bradstreet, Inc., New York, NY.
3. Middle Market Directory, Dun and Bradstreet, Inc., New York, NY.
4. Industrial Directory, Dun and Bradstreet, Inc., New York, NY.
5- National Business Lists, Inc., 162 N. Franklin St., Chicago, IL.
2-15
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6. Colgate, C. , Jr., ed. , National Trade and Professional Associations of
the United States and Canada and Labor Unions, Fifteenth Edition,
Columbia Books, Inc., Washington, DC, 1980.
7. Yanos, N. , and D. Akey , eds., Encyclopedia of Associations, Volumes 1-3,
Fourteenth Edit ion, Oale Research Company, Detroit, MI, 1980.
8. "Steam Electric Plant Aj r and Water Quality Control Data for the Year
Ended December 31, 19 ," Federal Power Commission Form 67, Annual.
9. Post's Pulp and Paper Directory, Miller Freeman Publications, Inc., 500
Howard Street, San Francisco, CA.
-*-0* Qj-j^and Ga_s__J°H?-EaA> Petroleum Publishing Co., 1021 S. Sheridan Road,
Tulsa, OK. Weekly publication.
11. Chemical and Engineering News, American ChemiraJ Society, Washington, DC,
Weekly publication.
12. Standard Industrial Classification Manual, Office of Management and
Bud gefT^Wa^hington , DC, 1972.
•^" County Business Patterns, Bureau of the Census, U.S. Department of
Commerce, Washington, D.C., Annual publication.
14. Harotnerle, J. R. , Emission Inventory, Chapter 17 of Mr Pollution, A. C.
Steen, Editor., Academic Press, New York, 1977.
15. Code of Federal Regulations (CFR) , Title 40, Part 51.
^ ^ " Development of Questionnaires for Various Emi s s :ion Inventory Uses,
EPA-450/3-78-122, U.S. Environmental Protection Agency, Research Triangle
Park, NC, June 1979.
17. EPA Form OMB No. 158-R0075.
2-16
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3.0 DATA ANALYSIS AND ESTIMATION OF EMISSIONS
Following planning and data collection, it will be necessary for the
agency to analyze and assess the validity of the data received and, in most
cases, to calculate emissions from the submitted source data. The validated
source and emission data must be converted to a standard file format record
and placed in the point source emission inventory file (computerized or
manual). Sample log sheets for plant record, point record, and SCC record
transactions for the EIS/PS-1- master file are shown in Figures 3-1, 3-2 and
3-3, respectively.
3.1 DATA ANALYSIS AND VALIDATION
Data analysis to assess the adequacy of the collected data is an
essential element of the emission inventory, and procedures for data
validation should be embodied in a formal program using standard operating
procedures for data collection, data analysis and correction, and data quality
assessment. A high degree of process engineering skills and familiarity with
emission inventorying procedures on the part of the emission inventory staff
will be required to effectively assess the adequacy of the collected data.
However, to assess the status of the overall reliability of the emission
inventory data file, a quality assurance organization, as discussed in Volume
I of this series,^ should be structured and given responsibility for the
monitoring of the inventory data file. Working with the engineering staff,
they should establish error checks and develop means for instituting
corrective action as required.
3.1.1 LOCATING AND CORRECTING ERRORS AND INCONSISTENCIES IN DATA
Finding and correcting errors and inconsistencies in the source and
emission data are necessary to ensure that data are complete, accurate and
suitable for use by the agency in the development and assessment of control
strategies. Potential sources of error found in most emission inventories are
identified in Volume I, ^chapter 2 of this series. Some typical edit
procedures to correct for data errors are cross checking of values to assure
compatability; comparison of collected data with predetermined maximum and
minimum source and emission data, such as those identified in Reference 3 and
others as used by NEDS;* and comparison of grid coordinates with geographical
boundry lines. The following types of error can be found in most emission
inventories.^
*Maximum and minimum values for source classification codes are available
from NEDS (National Air Data Branch, U.S. Environmental Protection Agency,
Research Triangle Park, NC, 27711); the agency should review these values and
if possible, modify them to increase the stringency of the boundary condition
limitations set by NEDS.
3-1
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3-3
-------
EMISSIONS INVENTORY SYSTEM/POINT SOURCE (EIS/PS) BY
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-------
Missing facilities or sources—Permit and inventory systems out of phase;
errors in estimating potential emissions; lost paperwork; problems with
computer file updates.
Duplicate facilities or sources—Name changes through corporate
acquisitions; use of multiple data sources with different source
numbering schemes.
Missing operating or technical data—Ambiguous data request forms;
intentional deletion by facility staff; inadequate followup procedures;
no preliminary indication of inventory size; or overall inadequate
project control.
Erroneous technical data—Misinterpretation of data request instructions;
assumed units, faulty conversions, etc.; intentional misrepresentation by
the facility; poor handwriting and transcription.
Improper facility location data—Recording coordinates of facility
headquarters instead of the operating facility; inability of technicians
to read maps; failure to observe inventory area boundaries.
Inconsistent area source categories or point source sizes—Failure to
designate inventory cutoffs.
Inaccurate or outdated data—Mixed use of primary and secondary data
without a policy for standardizing data.
Errors in calculations—Transposition of digits; decimal errors; entering
wrong numbers on a calculator; misinterpreting emission factor
applications.
Errors in emission estimates—Imprecise emission factors; applying the
wrong emission factor; errors in throughput estimates; improper
interpretation of combined sources; errors in unit conversions; faulty
assumptions about control device efficiency; failure to exclude
nonreactive emissions.
Reported emissions wrong by orders of magnitude—Recording the wrong
identification code for subsequent computer emission calculations;
ignoring implied decimals on computer coding sheets; transposition
errors; data coding field adjustment errors.
To correct the above errors the agency should use a staff experienced in
data collection and analysis to check data file entries or to institute
computerized edit programs. The Quality Assurance staff together with the
Engineering Staff should develop procedures (manual or computerized) to detect
and correct errors or identify data requiring plant verification.
3-5
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3.1.2 ENGINEERING ASSESSMENT OF DATA
Engineering analyses include quick reviews by technical personnel to
detect any numbers which are obviously much too high or low—possibly
indicating a decimal placement error—and to identify unreasonable responses
such as "no emissions," "100 percent control efficiency," etc. Engineering
assessments will also include more detailed review of data to reveal errors
not readily discernible by quick-scans. A summary of some specific
engineering assessment techniques available to the agency follows:
Emission estimate calculations using emission factors or material
balances will provide a check on the reliability of questionnaire
responses. Although emission factors are only average, values, emission
rates reported by the source should be in the same range as the emisson
estimate based on emission factors. If a significant difference appears,
this will signal a need for data verification-
Process parameters should fall within acceptable limits, for example,
excess air for a combustion process should not be less than 5 percent, 10
percent and 25 percent for gas, oil and coal, respectively. Based on
these values, if the actual volume flow is calculated to be 190, 195 and
220 scfm/million Btu or less for gas, oil and coal, respectively, then
information provided for the volume flow and/or heat input are
incorrect. The upper limit of excess air for combustion processes is
about 100 percent, equivalent to about 350 scfm/million Btu of heat
input- Excess air or stack flow values exceeding these limits should be
considered questionable.
Stack temperature should also fall within certain limits. Maximum
temperatures which can be expected for coal, oil and natural gas-fired
boilers are presented in Table 3-1. A stack temperature below 100°F
indicates that a combustion process is probably riot involved. If the
stack temperature is below 250°F and a scrubber is not being used, then
the temperature specified may be too low. If the stack temperature is
above 250°F and a scrubber is being used, then the temperature may be too
high.3
Fuel usage data can be checked by dividing the annual fuel consumption by
the number of hours of operation per year- If this ratio exceeds the
design maximum firing rate, an error is indicated. If the ratio is less
than 0.15 times the maximum continuous rate, then equipment utilization
is either very low or else incorrect data have been specified. In either
case, a low value should be checked for possible errors.
Different gas cleaning devices have characteristic ranges of efficiency
when used in conjunction with various combustion sources and industrial
processes. An efficiency range can be developed using emission factors
in AP-42,-" RAPS" and emission factors from state agencies. Emission
data obtained in the survey can be checked against this range to identify
possible inaccuracies.
3-6
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TABLE 3-1. EXAMPLES OF PARAMETER CHECK VALUES
Parameter for which
check is needed
Actual volume flows
Stack temperature
Actual velocity
Actual velocity
Stack height
Stack height
Operating time
hours/day
days /week
weeks/year
Source
Boiler-coal
Boiler-oil
Boiler-gas
Boiler-coal <250 mmBtu/hr
Boiler-oil <250 mmBtu/hr
Boiler-oil >250 mmBtu/hr
Boiler-gas <250 mmBtu/hr
(all stacks)
(boilers)
Check value
<220 scfm/106
<195 scfm/106
£190 scfm/106
>320°
>500°
>350°
^600°
< 1,000 fpm
>6,000 fpm
>1,000 ft
<40 ft
>24
>7
>52
Btu/hr
Btu/hr
Btu/hr
Control efficiency
>0 for no controls
3-7
-------
Check values are also available for validating information for both
production and emission rates. For most operations, emission rates are
proportional to the production rate; i.e., an increase in the production rate
will normally result in a proportional increase of emissions. As a result,
the ratio of normal to maximum production rate should approximate the ratio of
normal to maximum emission rates. Where these proportions differ, an
investigation should be made to determine if there is an error in the emission
calculation.
A computer program can he used to check data against a set of limits and
identify potentially erroneous data. Once identified, recalculations and
followup contacts can be used to verify or correct potentially erroneous
data. As noted, maximum and minimum parameter values are available from NEDS
for the purpose of flagging questionable data.
While engineering techniques and calculation are available to assess and
validate much of the data, some inaccuracies inherent to the inventory system
are impossible to identify without periodic updates including scheduled plant
inspections. Deterioration of control equipment, inadequate hooding systems
resulting in excessive fugitive emissions, abnormal operations and process
upsets, and variations in raw materials represent some of many potential
sources of inaccuracy in the inventory which must be checked by discussions
with facility personnel and by plant visits.
3.2 ESTIMATION OF EMISSIONS
There are three basic methods for determining emissions from point
sources: source test data, material balances and emission factors. The three
methods are discussed below.
3.2.1 SOURCE TEST DATA
If source test data are available at the agency or from the source, this
method of estimating emissions is usually the most accurate method. Source
test data should be used if the data were obtained under conditions which are
representative of or relatable to operating conditions normally encountered at
the source using test conditions of known accuracy and precision. If facility
operation and test methods employed during the source test cannot be
adequately characterized, the source test data should not be used.
3.2.2 MATERIAL BALANCES
Material balances are commonly used for estimating emissions from many
source categories, primarily VOC sources. In its simplest form, the material
balance assumes that all VOC entering the process is emitted. However, as
noted in Reference 4, situations often exist where the above assumption does
not apply. VOC may be retained in the product, destroyed in the process, or
physically removed for reprocessing or disposal. In other cases; e.g., bulk
3-E
-------
storage of petroleum products, the amount of solvent lost by evaporation is
small compared to the capacity or throughput of the source and cannot be
accurately determined by a material balance.
3.2.3 EMISSION FACTORS
Stack test results or other emission measurements are not always
available for each point source in the inventory. Similarly, source-specific
process information, necessary to perform a material balance, may be
deficient. In such cases, the agency must rely on emission factors to
estimate emissions. The emissions from a process are estimated by multiplying
the emission factor by the activity of the process (SCC unit). The SCC unit
is a process parameter, usually production rate, which can be correlated with
emissions. Emission factors are most valid when applied to a large number of
individual sources especially over extended periods of time. Emission factors
are developed from source tests, material balance studies, and engineering
estimates.
Emission factors are most accurate when the relationship between process
data and emissions is direct and relatively uncomplicated." If, for
example, the sulfur content of eastern bituminous coal used as fuel in a large
industrial boiler is known, the use of the emission factor (38 S Ibs of sulfur
oxide per ton of coal, where S is the sulfur content of the coal in
percent)-" to estimate sulfur dioxide is accurate for most uses of the
inventory. The sulfur in bituminous coal is converted virtually completely
(95 percent) to S02 and conversion of S02 to particulate sulfate and 803
(normally 1 to 3 percent) prior to emission is not considered significant from
the standpoint of the accuracy of the inventory of sulfur dioxide emissions.
An entirely different situation exists, however, in the case of estimating the
emissions of the oxides of nitrogen from an industrial boiler. The emission
factor for nitrogen oxides, as given in AP-42,-* varies with both the type
and size of the combustion unit, from 6 to 55 Ib of NOX per ton of coal.
This is because the factors affecting NOX production include flame and
furnace temperature, residence time of the combustion gases in the conbusion
zone, rate of cooling, amount of excess air, as well as the amount of
nitrogenous compounds in the fuel. Thus, the emission factor of 18, which is
applicable to a pulverized coal boiler burning 100 tons per hour, is an
average value. Actual emission values for specific boilers may differ
significantly from the quantities estimated using the average factor.
The agency conducting the inventory should be aware of the accuracy of
the emission factors being employed so that gross emission estimate errors can
be avoided. If an emission factor for a specific source or a source category
will not provide a reasonably accurate emission estimate, it is always better
to rely on actual stack test data. Conversely, if an emission factor will
provide accurate emission estimates, stack testing may represent an
ineffective use of valuable time and resources.
3-9
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3.2.3.1 Available Emission Factors^
EPA report No. AP-42,5 "Compilation of Air Pollutant Emission Factors,"
is a compilation of emission data for use by individuals and groups
responsible for conducting air pollution emission inventories. Emission
factors provided in this document cover most of the common emission source
categories: fuel combustion by stationary sources; combustion of solid
wastes; evaporation of fuels, solvents, and other volatile substances; various
industrial processes; and miscellaneous sources. When source-test data are
unavailable, these factors can be used to estimate the quantities of air
pollutants (particulates, CO, 862, NOX, and hydrocarbons) being emitted
from a source or source category. Qualitative estimates of the quality of the
emission factors are provided for each tabular listing of emission factors.
When an emission factor is not available in AP-42 for a specific source,
it is often possible to acquire emission data from various technical
publications. Numerous EPA reports are available which present the results of
engineering investigations concerning air emissions from a number of different
processes. EPA New Source Performance Standards documents and Control
Techniques Guidelines documents, and other EPA reports discussed in more
detail in Chapter 5 are potential sources of Information from which emission
factors can be developed. Fugitive emission factors for a number of
industrial operations are presented in Reference 7. That report and similar
engineering reports are assigned to the Environmental Protection Technology
Series which are available through the National Technical Information Service,
Springfield, Virginia 22161. It is important to note that AP-42 is regularly
updated to reflect the information available in the EPA reports mentioned
above. The most recent update of AP-42 should be used by the agency to ensure
that the best available emission factors are employed.
3.2.3.2 Development of Emission Factors
Emission factors have been developed and compiled in EPA report AP-42-*
for most major sources of air pollution. However, it is not unusual for a
given geographical area to contain point sources for which no emission factors
exist. In such instances it will be necessary to develop an emission factor
through source testing, material balance or engineering estimates.
Source testing is the preferred method of developing an emission factor
because it generally provides the most accurate results. Agency personnel who
are familiar with the source operation should be present during the testing to
monitor the process. The emission factor developed from the source test data
will provide accurate emission estimates only if the process was operating at
normal (average) operating conditions during the test. However, upset
conditions of appreciable magnitude or frequency are occurrences that can
invalidate estimates of emissions from many sources regardless of the accuracy
of the emission factor developed during periods of normal operation. The
agency should attempt to identify facilities/processes/equipment prone to
significant deviation from normal emission patterns. Mandatory reporting of
such occurrences by the plant or their detection through agency surveillance
3-10
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are means of identifying emission upsets. Excess emissions resulting from
process or control device inadequacies or malfunctions can have a significant
effect on emissions and must be considered by the agency in estimating
emissions from the sources.
Often it is not possible to conduct source testing to develop an emission
factor. If this is the case, agency personnel may have to develop emission
factors based on material balances or general engineering judgments. A
knowledge of the exact quantities of materials entering and exiting a process
will aid the agency in developing an emission factor, provided material
balance information is available at all emission points.
Developing emission factors without source test and material balance data
will require application of sound engineering judgment usually based on
analogy with similar processes. Plant visits to observe the process and
evaluate emissions may be helpful in developing emission factors; e.g., the
opacity of stack emissions may provide a rough estimate of mass particulate
emissions.
3.2.4 CALCULATION OF EMISSIONS USING EMISSION FACTORS
In order to calculate emissions from emission factors, various inputs to
the estimation algorithm are required. These inputs are:->
1. Activity information from the source inventory,
2. Emission factors to translate activity information into
"uncontrolled" emission estimates, and
3. Control device efficiency information to provide the basis for
estimation of emissions to the atmosphere after passage through the
control device(s).
The basic emission estimation algorithm is:
E - R x EF x (1 -
where E = emission estimate for source (at the process level) ,
R = activity level (such as throughput),
EF = emission factor (such as Ib emitted/throughput), and
C = control device efficiency (in percent).
The accuracy of the emission estimate is equally dependent upon the relative
accuracy of each of these individual components. Errors introduced into any
one of these components will affect the final emission estimate.
3-11
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3.2.4.1 Activity Data
Activity data are generally reported as fuel consumption rate (in tons,
10^ gal, 1CH or 10^ cu ft per hour) or process weight (in Ib, ton, gal
or bbl per hour) for fuel burning equipment and industrial processes,
respectively. The optimum activity data are hourly values, although in
some cases only shift, daily, weekly or even monthly data are available. If
hourly values are not known, the hourly average value can be calculated from
the operating pattern; e.g., 5 days per week, 8 hours per day, closed for
holidays and a 2-week vacation period.
In many instances, conversion factors must be applied to convert reported
consumption or production values to units that correspond to the SCC emission
unit; e.g., gallons to pounds, barrels to gallons, cubic meters to cubic feet,
etc. Most conversions will be straightforward; others may require
recontacting the facility to insure that the correct conversion factors are
applied; for example, to convert production rate from the number of panels of
plywood to the SCC units of tons processed. Problems associated with the
conversion of activity data to SCC units can be minimized by clearly
specifying the required units on the questionnaire submitted to the facility.
In any case, conversions should be made prior to data entry into the file.
Combustion activity is often reported as power output (megawatt hours/hr)
or steam production (Ib/hr). These activity data must be converted to the
equivalent fuel consumption (Btu/hr) using the following conversion factors:
1 MW = 3.413 x 106 Btu/hr
1 Ib steam/hr (300 psi, saturated) = 1202 Btu/hr.
Fuel consumption over the desired time interval is then converted to the
desired SCC activity units (tons burned for coal), using the heating value of
the fuel. A correction factor representing the fractional efficiency of the
fuel burning equipment is applied for Conversion of heat input to power output
(electrical) or steam production (thermal).
Typical sample calculations for mass emissions in Ib/hr are shown below
for fuel activity data and process activity data.
Example 1: Calculation of Particulate Emissions Using Fuel Activity
Data for SCC 1-01-002-02 (coal-fired utility boiler).
Given the following pertinent data:
Firing Rate (R) 30 ton/hr
Average Ash Content (A) ....... 7.5 percent
Emission Factor (EF) 13A Ib/ton
Collector Efficiency (C) 95 percent
3-12
-------
Emissions are calculated using:
C
E = R x EF x (1 - •—
part. 10U
where E = mass emission of particulates (Ib/hr) .
part .
In this case:
E = 30 x 13(7.5) x (1 - •—) = 146.3 Ib/hr.
Example 2 ; Calculation of Particulate Emissions Using Process Activity
Data for SCC 3-04-003-03 (electric induction furnace).
Given the following pertinent data:
Process Weight Rate (R) ....... 30 ton/hr
Emission Factor (EF) ......... 1.5 Ib/ton
Collector Efficiency (C) ....... 95 percent
Emissions are calculated using:
E = R x EF x (1 -
part. 100'
where E = mass emission of particulates (Ib/hr)
In this case :
EPart. =3°X l'5* (1 -!§§> =^.75 Ib/hr.
3.2.4.2 Control Device Efficiency
Control device efficiency is the third element of the linear emission
algorithm. Control device efficiency may be determined for specific equipment
by source tests to measure concentrations before and after the control
device. However, because of possible variation in control device operation
with process, control device malfunction and deterioration over time, etc.,
the measurement is subject to the potential limitations of all source tests.
When test data are not available for a specific control device,
literature values may be used for estimating control efficiency. EPA
publication AP-42^ supplies control device efficiencies for control devices
which are commonly encountered in industrial applications. These control
efficiency estimates, in reality, may not be precisely applicable to specific
3-13
-------
control devices. In addition, a control device may be improperly sized for
effective control of the process under consideration. Therefore, the estimate
should be tempered with knowledge of the process and engineering judgment.
A third method of obtaining a control device collection efficiency is to
employ the manufacturer's design specification or guaranteed performance
specification subject to field verification. However, the design collection
efficiency reported by manufacturers is the efficiency obtainable under
optimum conditions which may not represent actual conditions. Some assessment
of design efficiency may be required to adjust for these source conditions.
It may also be necessary to modify the control device efficiency estimate
based on considerations such as "downtime." If the devices are shut down
periodically for maintenance, upset, etc., then the emissions released in
1 hour may far exceed those released in the "controlled" mode over many hours
of operation. Failure to account for excess emissions resulting from
"downtime" could be a large source of error in the inventory. It should be
noted, however, that, in general, regulations and permitting conditions
preclude the operation of the emitting processes by the source when the
control equipment is inoperative.
3.3 TEMPORAL ADJUSTMENT OF THE ANNUAL INVENTORY
Most emission inventories have traditionally estimated annual emissions.
However, emissions from many source categories are subject to large seasonal
and/or hourly variations. Some source categories exhibit pronounced temporal
dependence due to changes in activity levels or to physical changes resulting
from climatic conditions. For example, a public school or university will
consume most of its fuel during the winter heating season. Diurnal patterns
of activity will also be apparent. Consequently, it will be necessary to
obtain hourly consumption data on a seasonal or monthly basis to determine
these fuel use patterns. The questionnaire should request sufficient activity
level information so that the desired variations can be determined.
Accounting for temporal physical changes, such as changes in the vapor
pressure of VOC with temperatures, is not as easily addressed as temporal
activity level changes and will require a greater level of effort. Reference
4 should be consulted for a detailed discussion of methods for temporal
adjustment of the annual inventory for VOC sources.
3.4 EMISSION PROJECTIONS
Emission inventory projections are needed by an agency to determine if a
given area will achieve or exceed ambient standards in future years. There
are two basic types of projections, baseline and control strategy, defined as
follows:
Baseline Projections—Estimates of future year emissions that take into
account (1) expected growth in an area and (2) air pollution control
regulations currently in effect at the time the projection is made.
3-14
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Baseline projections also take into account the effect of adopted
regulations which will become effective at some date prior to the
projection year.
Control Strategy Projections—Estimates of future year emissions that
take into account the effect of modified or additional control
regulations on baseline projections.
Baseline projection inventories of annual emissions for the particular
years of interest will probably not be available from past inventory efforts,
and projection inventories that do exist may not reflect all of the growth and
control scenarios that the agency may wish to evaluate. Hence, the agency
will have to devote resources to the development of projection year
inventories. The following general considerations should be kept in mind from
the outset of inventory planning:^
1. To a large extent, projection inventories will be based on forecasts
of industrial growth, population, land use, and transportation. The
air pollution agency is generally not equipped and should not
attempt to make these forecasts but, rather, should rely on the
local Metropolitan Planning Organization (MPO), Regional Planning
Commission (RFC), or other planning agencies to supply them. This
course has two major advantages. First, it would be extremely
costly for the air pollution agency to duplicate the forecasts made
by other planning agencies. Second, the air pollution agency needs
to base its emission projections on the same forecasts as other
governmental planning agencies. This consistency is necessary to
foster the credibility of any proposed control programs based on
emission projections.
2. The control strategies under consideration may influence the type of
data collected as well as the structure of the inventory itself. As
an example, if the agency wants to test the effect of applying
Stage I controls on tank trucks unloading only to service stations
above a particular size, it may be desirable to treat these
particular stations as point sources rather than including them in a
general service station area source category.
3. It is important that all emissions projected for future years be
determined using the same methods and procedures that were used to
determine base year emissions. Use of the same techniques assures
consistency between base year and projection year emission estimates
and avoids possible errors resulting from changes in methods and
procedures.
4. Projection inventories will always be open to question because of
their somewhat speculative nature. Internal and external review of
emission inventory projections, including extensive research and
documentation of assumptions, methods, and procedures, will improve
their technical quality and enhance credibility.
3-15
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3.4.1 MAJOR POINT SOURCE PROJECTIONS
The most direct approach for projecting emissions from major point
sources is to obtain information on each facility. This type of projection
information would ideally be determined by contacting plant management, but it
could be solicited on questionnaires. Generally, questionnaires would not be
sent out solely to obtain projection information, but this additional
information may be elicited on questionnaires used in periodic updates of the
baseline inventory. Permit applications submitted to various Federal, state,
and local agencies should also be screened for information on expected
expansion or new construction. In addition, the local metropolitan planning
organization and other planning bodies must be contacted for any information
they may have on projected industrial expansion and for comment on the
reasonableness of any plans submitted by industrial facilities.
Once this type of projected plant growth information is obtained, the
agency needs to determine what regulations will apply in order to estimate
controlled emissions. In the baseline projections, existing applicable
regulations are evaluated. For instance, a fossil fuel power plant now under
construction and expected to start operation in 2 years would be subject to
Federal New Source Performance Standards (NSPS) for particulate, S02 and
NOx- Hence, unless plant personnel indicated that more stringent controls
will be applied, the resulting emissions could reasonably be assumed to be
equal to the standard. Similarly, the effects of any other future regulations
which would impact the source would have to be evaluated.
As an example of making point source projections for specific sources,^
consider a facility employing a large open top vapor degreasing operation that
emitted 100 tons of solvent per year in 1977, based on an annual production of
10,000 units of a particular metal part. Assume that no control measures are
planned to reduce solvent losses from the process. The plant projects that 5
percent more metal parts will be produced per year until 1982 using the
existing operation, and that, in 1987, a replacement facility will be brought
on line at another location within tl»>: plant to produce 20,000 parts per
year. The source is located in an ozone attainment area where RACT is not
required on VOC sources. To estimate VOC emissions from this source for a
1982 projection inventory, one could assume that, since no additional controls
are expected, the current emission level can be multiplied by the cumulative
growth rate in metal parts production (i.e., 5 years at 5 percent/year =
[1.05]5 = 1.28, or 128 percent) to estimate 1982 VOC emissions. (Emissions
are assumed proportional to production.) Thus, emissions for 1982 can be
estimated at 128 percent of 100, or 128 tons per year, and the point source
record for this projection year should be adjusted to take this growth into
account.
Continuing this example, suppose a control strategy projection is desired
for 1987 to evaluate the effect of RACT as an alternate control strategy. In
this case, both growth and controls must be considered. As a first
approximation, if a similar open top vapor degreasing operation is used in the
new facility, one can assume that, since 1987 production will be twice 1977
3-16
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production, uncontrolled emissions from the replacement plant will be twice
those of 1977, or 200 tons per year. Since the new plant will be subject to
RACT in this control scenario, VOC emissions will be reduced 45 to 60 percent
from the uncontrolled case.8 Hence, projected emissions in 1987 would be
only 80 to 110 tons per year, depending on which RACT measures were
instituted. Note that, since the replacement facility commences operation in
1987, it should be included in the 1987 projection inventory as a new point
source, and the old source deleted from the inventory.
3.4.2 AGGREGATE POINT SOURCE PROJECTIONS
In many instances, projection information will not be available from the
management of individual facilities. In addition, some source categories,
such as small industrial boilers, will be too small and too numerous to
justify the solicitation of projection information. In these situations,
emission growth trends of sources for which projection information have been
obtained can be applied to similar sources which were unable to provide
projection information.
Surrogate indicators of growth rate can also be used; e.g., employment
projections for industrial manufacturing categories.^ Regardless of what
surrogate indicators are used for making projections, the basic calculation is
the same for a source category. The ratio of the value of the surrogate
indicator in the projection year to its value in the base year Is multiplied
by the base year activity level to determine the projection year activity
level. Because the projection years of interest to the air pollution control
agency may not be the years for which growth projections have been made by
other planning agencies, interpolation of projection year data may be
required. The planning agency responsible for the projection should be
contacted to determine whether straight line or other interpolation methods
should be employed.
3.4.3 PROJECTION DOCUMENTATION AND REVIEW
Because the projection inventories are so important in control strategy
development, they should be carefully reviewed for errors by experienced
personnel. The projection review is most readily accomplished if all
assumptions, procedures and data sources used are carefully documented. This
documentation and review process will help assure that all the projections are
(1) consistent with other projections being made In the area; (2) objective
and not biased toward any particular policy; (3) open, with all assumptions
and estimates clearly stated for review; and (4) defensible because of
thorough documentation and review.
The key aspects of projections that will invite criticism are: (1) the
viability of indicators used for projecting activity level growth; (2) how,
when and where this growth will occur; and (3) what emissions will be
associated with this growth. When planning, compiling and reviewing the point
source projection inventory, the agency should focus particular attention on
these issues.
3-17
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References for Chapter 3.0
1. The Emissions Inventory System/Point Source User's Guide, EPA-450/
4-80-010, U.S. Environmental Protection Agency, Research Triangle Park,
NC, May 1980.
2. Procedures for Emission Inventory Preparation - Volume I; Emission
Inventory Fundamentals, EPA-450/4-81-026a, U.S. Environmental Protection
Agency, Research Triangle Park, NC, September 1980.
3. Goklany, I. M., "Emission Inventory Errors for Point Sources and Some
Quality Assurance Aspects," Journal of the Air Pollution Control
Association, ,30(4) : 362-5, April 1980.
4. Procedures for the Preparation of Emission Inventories for Volatile
Organic Compounds, Volume I, Second Edition, EPA-450/2-88-028, U.S.
Environmental Protection Agency, Research Triangle Park, NC, September
1980.
5. Compilation of Air Pollutant Emission Factors, Third Edition and
Supplements, AP-42, U.S. Environmental Protection Agency, Research
Triangle Park, NC, October 1980.
6. Regional Air Pollution Study; Point Source Methodology and Emission
Inventory, EPA-600/4-78-042, U.S. Environmental Protection Agency,
Research Triangle Park, NC, July 1978.
7. Assessment of Fugitive Particulate Emission Factors for Industrial
Processes, EPA-450/3-78-107, U.S. Environmental Protection Agency,
Research Triangle Park, NC, September 1978.
8. Control of Volatile Organic Emissions from Solvent Metal Cleaning,
EPA-450/2-77-022, U.S. Environmental Protection Agency, Research Triangle
Park, NC, November 1977.
9. "Regional Economic Activity in the U.S.," 1972 PEERS Projections, Bureau
of Economic Affairs, U.S. Department of Commerce, and. Economic Research
Services, U.S. Department of Agriculture, 1974.
3-18
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4.0 PRESENTATION AND DOCUMENTATION OF THE INVENTORY
4.1 PRESENTATION OF THE INVENTORY
The final phase of an emission inventory activity is to present the data
which have been collected, compiled and analyzed. The data can be presented
in a variety of forms, from unorganized raw data listings to aggregated
summary reports. Generally, the form in which the data will be presented is
determined by (1) how the data can be most efficiently summarized, and, more
importantly, (2) the purpose of the inventory.1
The purpose of the emission inventory is the primary consideration when
adopting a reporting format. An inventory developed only for research
purposes can be presented in many forms ranging from a raw data listing, which
basically presents all data compiled in the inventory in the form of computer
printouts of sources and emissions, to summary reports.
A summary report includes information that has been aggregated and
organized in some manner during the reporting process. For instance, a
summary report of total VOC emissions from all dry cleaners in an area would
involve a totaling of emission data stored in certain file records. In many
instances, some analysis of the data; e.g., evaluation of alternative
controls, might also be performed in the process of preparing a summary
report. ^
Many inventory reports, such as those required for State Implementation
Plan (SIP) submissions, and certain other control strategy inventory reports,
must meet formatting requirements set forth in local, state and EPA
regulations. The reporting format required In the 1982 State Implementation
Plan submittals for VOCs is shown in Figure 4-1. Because the agency must be
able to determine and compare the impact of employing various control
strategies, such as RACT, a common format is considered desirable to promote
reporting consistency. The format presented in Figure 4.1 required for
reporting VOC emissions in 1982 SIPs,^ is an example of one level of
reporting. This format allows the agency to identify all major source
categories of volatile organic compound emissions and to determine the
reductions that may occur in an area if various control strategies are
employed.
In addition to required reporting formats, a variety of tables and
graphic displays can be employed to present inventory data. Charts, tables
and graphs can be formatted to depict emission breakdowns by industries,
geographical areas, or source size. Emission trends and the effects of
control programs can also be tabulated or graphed. Several examples of tables
and graphs are presented in Volume I of this series. Tabular reports are the
most common kind of report, as they can be readily generated from computerized
inventory systems such as the EIS/PS.4 Certain types of graphic displays
4-1
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are difficult to produce using a computer and require time and manpower to
develop manually. Most of the NEDS and EIS raw data and summary reports
available to the public are of the tabular variety. The various NEDS
reporting programs are described in detail in Reference 5. The EIS reports
are compatible with NEDS and satisfy EPA reporting requirements.
4.2 DOCUMENTATION OF THE INVENTORY
Documentation of the emission inventory is necessary for all inventory
uses. Documentation entails keeping a record of all methods, assumptions,
example calculations, references and results employed in the compilation
effort. The goals of documentation are to provide in written form an
explanation to both the agency and outside users as to (1) how the inventory
was compiled and (2) its reliability. Proper documentation of the inventory
will help an agency when future inventories are conducted. Therefore,
compiling and maintaining documentation in support of data is recommended in
all emission inventories.
The following kinds of documentation of point source procedures will
achieve inventory goals.^
A. Background information should be presented on reasons for compiling
the inventory, its future uses, how it evolved, and the significance
of changes from emissions of previous years.
B. The geographic area covered by the inventory should be specified.
This may be a county, air basin, AQCR, etc. A map of the area
should be included.
C. Population, employment and economic data used in projections should
be presented. This includes data used in calculating emissions with
per capita emissions and eraissions-per-employee factors (see Item G).
D. The time interval represented by the emission inventory should be
specified (e.g., annual, seasonal, hourly, etc.).
E. Record any proposed or promulgated control strategy programs that
will affect the baseline inventory. In control strategy
inventories, include graphs and tables to illustrate progress toward
air quality goals.
F. Baseline emission estimates should be summarized by source category
in tabular format.
1. Source categories for which the emissions are negligible should
be listed as "Neg".
2. Source categories for which there are no emissions in the study
area should be listed as "0".
4-3
-------
A narrative should also be presented for each category of the
inventory. Much of the information contained in the narrative
should also be in the agency's procedure manuals which it should
prepare and follow. The narrative should contain at least the
following:
1. Procedures used to collect/analyze the data—All procedures for
data collection and analysis should be fully described. A
concise point source/area source definition should also be
included•
2' Sources of the data—A complete description of the types of
sources assessed in the course of compiling the inventory
should be presented. These sources would include, for example,
permit files, inspection reports, source test data, actual
company inquiries, other agencies, etc. A statement should be
included assessing the completeness of the data collected.
3. Copies of questionnaires—Samples of questionnaires mailed to
various source categories for the collection of data should be
included as part of the inventory documentation.
4. Questionnaire s t a t is11cs—Statistics regarding the
questionnaires should be presented. This information should
include:
a. The number of questionnaires sent
b. The number for which response was received
5. Emission factor citation—Emission factors used for the
calculation of emissions should be clearly identified. Factors
from sources other t_T: ,* AP-42 may be used but a rationale for
the use of these other factors should be provided. Source test
data are preferred over emission factors.
6, Method of calculation—Sample calculations for each type of
computation should he presented, to allow for an independent
verification of the computations. (Some emission factors are
frequently misused.) Techniques for excluding nonreactive VOC
from a VOC inventory should be described.
7. Assumptions—Any assumptions made in any part of the procedures
should be clearly stated.
8. Items not included—Any sources of emissions which are not
included in the inventory should be itemized in the narrative.
A statement as to why these sources were excluded should be
presented. A possible reason for exclusion could be, for
example, that the emissions from these sources are known to be
negligible.
-------
9. Quality assurance procedures—All procedures and the results of
their application to inventory activities plus an estimate ( f
the reliability of the data base for major categories and the
overall inventory should be presented.
10. References—A list of references should be included as a final
section of the narrative.
A technically sound inventory, if well documented, can be useful for several
years with only annual updating. Proper documentation will allow the agency
to update the inventory in a prompt and efficient manner and to readily
institute procedural changes reflecting advances in methods and procedures for
inventory preparation.
References for Chapter 4.0
1. Procedures for Emission Inventory Preparation - Volume I: Emission
Inventory Fundamentals, EPA-450/4~81-026a, U.S. Environmental Protection
Agency, Research Triangle Park, NC, September 1981.
2. Procedures for the Preparation of Emission Inventories for Volatile
Organic Compounds, Volume I, Second Edition, EPA-450/2-77-028, U.S.
Environmental Protection Agency, Research Triangle Park, NC, September
1980.
3. Emission Inventory Requirements for 1982 Ozone State Implementation
Plans, EPA-450/4-80-016, U.S. Environmental Protection Agency, Research
Triangle Park, NC, September 1980.
4. The Emission Inventory System/Point Source User's Guide,
EPA-450/4-80-010, U.S. Environmental Protection Agency, Research Triangle
Park, NC, May 1980.
5. AEROS Manual Series, Volume III: Summary and Retrieval, Second Edition,
EPA-450/2-76-009a, U.S. Environmental Protection Agency, Research
Triangle Park, NC, July 1977.
4-5
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5.0 INVENTORYING MAJOR POINT SOURCE CATEGORIES
The preparation of an emission inventory of point sources involves direct
contact with the source to collect the necessary process and emission
information. Although data collection procedures are straightforward, the
assessment of the adequacy of the collected data with regard to completeness
and accuracy requires a high level of technical competence because of the
large number of source categories or processes maintained in the point source
file and the possible variability of source and emission data within
categories. Assessment is particularly demanding when the data are from
sources which are large and complex, difficult to control, or sources of
fugitive emissions.
The agency should maintain and update a library of recent technical
publications that assess emissions from source categories within the agency's
jurisdiction. Over the past few years several source assessment programs and
measurement programs designed to assist EPA and states in the development of
standards (e.g., NSPS, NESHAP and RACT for VOC sources) have been conducted.
Several relevant studies are included in the bibliography Volume V, of this
emission inventory preparation series. Although the results of many of these
studies will eventually be embodied in AP-42-'- the agency should contact EPA
representatives to obtain the most recent and pertinent technical reports as
they become available. Information contained in these reports, and in data
files such as NEDS^ and the Environmental Assessment Data System (EADS),-*
will provide guidance to the agency in identifying emission points associated
with specific facilities and activities. The EADS data can also be used in
many cases to assess the effect of process and control device operating
variables on emissions from specific source categories.
Some agencies have developed and maintained source manuals for use by
agency personnel responsible for the assessment of inventory data from
significant source categories. These manuals typically provide a process
description, identify emission pointpj characterize control device types and
performance, define boundary values for process and control device parameters
and emission rates, and otherwise provide guidance to agency personnel in
their assessment of the data that, if deemed adequate, will be entered into
the emission inventory file.
Although an indepth technical description of major source categories and
their emissions is not provided in this volume, following discussions will
identify some specific problem areas, and possible solutions to them, which
are encountered in inventorying emissions from major source categories. These
major categories are:
Combustion (including incineration),
Chemical manufacturing,
Food and agriculture,
5-1
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Metallurgical industries,
Mineral products,
Wood products,
Petroleum industry, and
Evaporation loss sources.
The contribution of major source categories to nationwide emissions is
summarized in Table 5-1. The data in this table were taken from the 1977
National Emissions Data Report^ and represent nationwide totals. Mobile
source and combined mobile source and area source totals are also provided in
the table to illustrate the relative contributions of each source. Agency
files should contain similar summary tables for both the state and its
subdivisions. These tables can be used as an indication of the importance of
source categories within the agency jurisdiction.
5.1 COMBUSTION SOURCES
Combustion sources include external combustion boilers and internal
combustion turbines and reciprocating engines. Uncontrolled emissions will
generally exceed 100 tons/yr of any one criteria pollutant for the following
combustion systems if operated 8,000 hr/yr.
Coal-fired boilers - 4 x 106 Btu/hr
Residual oil-fired boilers - 13 x 106 Btu/hr
Distillate oil-fired boilers - 70 x 106 Btu/hr
Natural gas-fired boilers - 110 x 106 Btu/hr
Internal combustion - 10 x 10" Btu/hr
The above point source (100 tons/yr) cutoff sizes are approximate values
only. Actual valuers will depend on many factors including fuel
characteristics; furnace type, size and age, and load and other operating
characteristics. Pollutants of interest from external combustion sources,
listed in order of decreasing actual nationwide mass emission rate, are SOX,
particulate and NOX from coal combustion; SOX, NOX and particulate frori
residual oil combustion; SOX and NOX from distillate oil combustion; and
NOjj from natural gas combustion.^ Internal combustion turbines and
engines are major sources of NOX and also can emit appreciable quantities of
hydrocarbons and carbon monoxide. Emission factors for internal combustion
sources are not as reliable as emission factors for external combustion
sources."
5-2
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The preponderance of air emissions from combustion sources are stack
emissions. However, fugitive emissions from coal and ash storage piles and
drift from cooling towers are other possible sources of emissions which should
be considered by the agency in compiling the combustion source inventory.
Particulate control devices are used on all utility boilers and most
industrial boilers burning coal. Overall, only about 10 percent of
particulate emissions from oil-fired utility combustion sources are
controlled; and no controls are used for natural gas combustion sources.
Control measures for SOX and NOX emissions from utility boilers have not
yet been instituted to any significant extent. However, control measures for
these pollutants will be forthcoming due to passage of New Source Performance
Standards (NSPS) for utility boilers.
The application of control measures for smaller industrial boilers
(nominally 10 - 250 x 106 Btu/hr heat input) is far less than that for
utility boilers. Overall particulate control efficiencies range from 20 to 50
percent for coal-fired units with efficiency increasing with boiler size. The
control devices used are generally mechanical cyclones with efficiencies in
the 50 to 90 percent range, in contrast to the high efficiency (>99 percent)
electrostatic precipitators used in the utility sector."
5.1.1 EXTERNAL COMBUSTION SOURCES
The emission factors used for large utility boilers are considered
adequate for all furnace types (e.g., pulverized units, cyclones and stokers),
pollutants, and fuels (with the possible exception of wood-fired boilers) •
The principal factor affecting the accuracy of particulate emission estimates
is the control device efficiency. The sensitivity of emissions to control
device efficiency estimates is most pronounced at high efficiencies. An order
of magnitude underestimate of emissions can occur, for example, if a control
unit with a design efficiency of 99.5 percent is actually operated at an
average efficiency of 95 percent. For this reason, the agency should, when
possible, use stack test data to de- ermine actual emissions. The use of stack
test data, however, provides no assurance that conditions at the time of test
were representative of normal plant operation. Records of equipment
maintenance and malfunctions and continuous monitoring data should be examined
by agency personnel to provide some measure of equipment performance over a
long-term basis.
Emissions of SQ^ from combustion sources can be accurately estimated
for bituminous and anthracite coals, fuel oil and natural gas by assuming that
95 percent of fuel sulfur is emitted as SC^. Approximately 98 percent of
the SOX is emitted as S02, the remainder being 803. For coals of high
alkali ash content, such as lignite and some western subbituminous coals, the
of coal sulfur emitted as SOX is appreciably less, of the order of 50
percent. 3 The remaining sulfur is bound in the ash. Stack test data will
be needed to determine SOX emissions from coals containing high alkali ash.
5-4
-------
Emissions of NO^ from combustion sources are a function of fuel
nitrogen content and furnace operating parameters such as temperature and
excess air. The AP-421 emission factors for utility boilers show the
average effect of fuel and furnace type on NC^ emissions. These factors
accurately depict NOx emissions from most efficiently operated utility
boilers.
Hydrocarbon and carbon monoxide emissions from well-operated combustion
sources are normally not significant. Recent evidence does indicate, however,
that inefficiently operated coal- and wood-fired sources can emit potentially
significant quantitites of polycyclic organic matter (POM)."
Emission factors for smaller nonutility boilers are not as reliable as
those for utility boilers due to a smaller emission data base and greater
variability in operating parameters for the nonutility boilers. Small boilers
tend to be less well maintained and are often subject to frequent startup and
shutdowns and low load operational cycles. Generally, particulate and NOX
emissions decrease and hydrocarbon and carbon monoxide emissions increase with
decreasing load. However, particulate emissions can increase drastically at
load conditions which are well below the normal design load.
In compiling the inventory of external combustion sources, furnace design
and fuel type must be clearly distinguished because of the impact of these
factors on emissions. Units burning more than one fuel should receive further
attention to determine if the fuels are burned separately or dual-fired. Such
information can be useful in assessing temporal emission variations and in
conducting research programs; e.g., studies of acid rain and SC>2 emissions.
5.1.2 INTERNAL COMBUSTION SOURCES
Emissions from internal combustion sources are a function of unit design,
load and fuel. NC^ emissions are significant due to the high temperatures
of combustion, and increase with load Emission factors for CO and HC are
appreciably higher than those for external combustion. In the absence of
stack test data, the agency must rely on existing emission factor data from
AP-42 or data from other EPA test programs.6
Electric utility turbines are typically used to generate peak or standby
power and generally operate 5 hours per day or less. They may be out of
service for days or weeks at a time. Because of variability in operating
schedules the maintaining of a permanent record of data on temporal patterns
is not of immediate use to the agency. However, the temporal pattern of
emissions should be noted and considered by the agency in assessing the data
needs of research programs aimed, for example, at studying ozone formation.
Unit design (i.e., gas turbines burning gas or oil and reciprocating engines
burning gas, oil or any combination thereof) should be clearly distinguished
in the inventory.
5-5
-------
5.1.3 SOLID WASTE INCINERATION AND OPEN BURNING
Although several solid waste incineration classification systems have
been developed, the most frequently used is that provided by NEDS^ (see
Table 5-2). This system describes three major incinerator categories by owner
(commercial/institutional, governmental, and industrial). The commercial/
institutional category includes hospitals, shopping centers, restaurants,
etc. The governmental category covers the incineration of wastes such as
sewage sludge and municipal waste. Most municipal waste and sludge
incinerators will be point sources. Industrial incinerators are the most
diverse, ranging from small units burning general plant trash to large
suspension-fired boilers burning over 500 tons of shredded plant trash,
product waste and sludge per week. The NEDS system does not include
agricultural and mineral waste incineration as separate categories.
Agricultural incineration is probably a significant source of emissions in
some states and an agricultural/point source incineration category may be
merited in those locations.
AP-42''- provides emission factors for the incineration of municipal,
industrial and commercial wastes for several types of incinerators. The
emission factors given are average values based on typical waste
characteristics.
All questionnaires used to collect point source data from industry should
request an accounting of the amount and type of waste burned. Emission
factors are not available in AP-42 for agricultural waste and must be obtained
from the literature or estimated from existing emission factors for the
incineration of other wastes or the open burning of agricultural wastes.
Variations in waste will not only directly affect the nature of emissions but
will indirectly affect emissions due to the possible effects of waste on
incinerator and control device performance. The use of stack test emissions
data Is preferable to the use of emission factors for calculating emissions.
However, if stack data are used, the facility and test organization should be
contacted to determine the representativeness of incineration operation during
the test period. Engineering judgment will be required to assess the
importance of the large number of variables involved in determining
representative operation and performance.
5.2 INDUSTRIAL SOURCES
The exceedingly large number of industrial processes to be inventoried is
indicated by the industrial source list compiled from AP-42-'- and shown in
Table 5-3. This list: is not all inclusive of the nationwide industrial base.
Although it is not possible to comprehensively discuss the special problems of
each of these processes, this section describes some of the more widespread
problems that are encountered when inventorying industrial emissions and
identifies some techniques for developing inventory information. In addition,
specific problems and inventory techniques that are applicable to the major
categories of chemical manufacturing, food processing and agriculture,
metallurgical processes, mineral products, wood products, the petroleum
industry and evaporation loss sources are discussed in somewhat more detail.
5-6
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5-7
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TABLE 5-3. INDUSTRIES, EMISSIONS AND CONTROLS
Product/process
Types of emissions expected
Types of controls used
CHEMICAL PROCESS INDUSTRY
Adipic acid
Synthetic ammonia
Carbon black
Charcoal
Chlor-alkali
Explosives
Hydrochloric acid
Hydrofluoric acid
Nitric acid
Paint and varnish
Phosphoric acid
Phthalic anhydride
Plastics
Printing ink
Soap and detergents
Sodium carbonate
Sulfuric acid
Sulfur recovery
Synthetic fibers
Synthetic rubber
Terephthalic acid
Lead alkyl
FOOD AND AGRICULTURE INDUSTRY
Alfalfa dehydration
Coffee roasting
Cotton ginning
Feed and grain, mills and
elevators
Fermentation
Fish processing
Co, VOC, NOX, particulates
CO, CO2, NHf, NOX, SOX,
organics
CO, NOX, SOX, organics, par-
lates, trace elements
CO, C02, VOC, NO . organics,
A
CO, CO?, Hi, Hg
Acid mist, NOX SOX,
particulates
HC1
S02 hydrofluoric acid,
Florosilic acid particulates
NOX
VOC
Fluorine, particulates
CO, SOX, particulates
Monomers, solvents
COj, organics, particulates
Organics, particulates
NH3, particulates
SOX, acid mist
S02> H2S, COS, CS2
CS2, H2S, VOC, oil vapor and
mist
Monomers, particulates
NOX
Alkyl lead vapor, particulate
lead oxide
Particulates
NOX, organics, particulates
Particulates
Particulates
H2S, organics
H2S, organics, particulates
Incineration, thermal reduction
scrubbers, carbon aabsorbers,
flaring
Process modification
Gas filter, flare, incineration,
scrubber
Afterburner
Alkaline scrubber, chlorine
recovery, process modification
Acid recovery, fume recovery,
ESD scrubber
Absorption scrubbet
Additives, bag filter, covers,
scrubber
Catalytic combustor
Adsorbers, afterburners, condensers
Condenser, cooling pond, demister,
ESP scrubber
Scrubber, incineration
Adsorption, condensers, floating
roof tanks
Afterburners, condensers, scrubbers
Cyclone, scrubber
Ammonia recovery
Process modification, scrubber
Process modification
Adsorption
Fabric filter
Incineration, scrubber
Cyclone, fabric filter
Afterburner
Cyclone, filter, screen, unifilter
Cyclone, fabric filter
Process modification
Afterburner, cyclone, scrubber
(continued)
5-8
-------
Products/process
TABLE 5-3 (continued)
Types of emissions expected
Types of controls used
Meat smokehouses
Ammonium nitrate fertilizer
Phosphate fertilizer
Starch manufacture
Sugar cane processing
Bread baking
Urea
Beef cattle feedlots
Defoliation and harvesting
of cotton
Harvesting of grain
METALLURGICAL INDUSTRY
Primary aluminum production
Organics, particulates
NHs, NOX, particulates
NHs, SOX, ammonium chloride,
fluoride, hydrogen fluoride,
silicon tetrafluorlde
Particulates
Particulates
Organics
NHa, particulates
Ammonia, malodorous gasses,
particulates
Arsenic acid, DEF, paraquat
particulates, sodium chlorate
Particulates
VOC, SO}, alumina, fluorides,
hydrogen fluoride, organics,
particulates
Metallurgical coke manufacture CO, VOC, HzS, NO , carbon
disulfide, particulates
Primary copper smelting
Ferroalloy production
Iron and steel production
Primary lead smelting
Zinc smelting
Secondary aluminum operations
Secondary copper smelting and
alloying
Grey iron foundries
Secondary lead smelting
Secondary magnesium smelting
Steel foundries
SOz, particulates
CO, particulates
CO, fluorides, particulates
(mainly iron oxide, manganese,
aluminum, silicon)
SOa , particulatos
SOj, particulates
Fine particulates, chlorine
Particulates
CO, particulates
50^, particulates
NOX, SOX, particulate MgO
VOC, NOX, SOX, particulates
Afterburner, ESP, scrubber
Mist eliminator, scrubber, wet
cyclone
Scrubber
Scrubber
None
Condenser, scrubber
Housekeeping
Process modification
Process modification
Alumina adsorption, centrifugal
collectors, ESP, multiple cyclones,
scrubbers
Process modification
Cyclone, ESP, Fabric filter,
scrubber
Flare or combustion (of CO), par-
ticulate control device
Cyclone, ESP, fabric filter, flar-
ing or combustion (of CO)
Centrifugal collector, ESP, fabric
filter, tubular cooler, sulfuric
acid plant, sulfur recovery, DMA
adsorption process, ammonia
adsorption
Conversion of S02 to sulfuric acid,
ESP, fabric filter
ESP, fabric filter
ESP, fabric filter, scrubber
ESP, fabric filter, scrubber
Gas settling/cooling chamber
cyclone, demister, fabric filter,
scrubber
ESP, fabric filter, scrubber
(continued)
5_c
-------
Products/process
TABLE 5-3 (continued)
Types of emissions expected
Types of controls used
Secondary zinc processing
Storage battery production
Lead oxide and pigment
production
Miscellaneous lead products
Leadbearing ore crushing and
grinding
MINERAL PRODUCTS INDUSTRY
Asphaltic concrete
Asphalt roofing
Bricks and related clay
products
Calcium carbide
Castable refractories
Portland cement
Ceramic clay
Clay and fly ash sinterings
Coal cleaning
Concrete patching
Glass fiber
Frit
Glass
Gypsum
Lime
Mineral wool
Perlite
Phosphate rock processing
Sand and gravel
Stone quarrying and processing
CO, NOX, particulates
Lead, particulates
Lead, particulates
HC, particulate lead
Lead, particulates
Particulates
Organics, particulates
NOX, SOX, fluorides,
part iculates
CO, S0x, acetylene, particulates
Fluorides, particulates
Fabric filter, scrubber
Cyclone, fabric filter, settling
chamber
ESP, fabric filter, rotoclone,
scrubber, process modification
Cyclones, fabric filter, process
modification, housekeeping
Cyclone, fabric filter, scrubber,
spray tower
Afterburner, ESP, filter, scrubber
Cyclone, ESP, fabric filter,
scrubber
Scrubber
Cyclone, ESP,
scrubber
fabric filter,
NOX, SOX, particulates
NOX, acid gases, fluoride,
particulates
Particulates
NOX SOX, organics, particulates
Particulates
CO, VOC, NOX, SOX, particulates
Particulates
CO, NOX, SOX, orpanics,
particulates
Particulates
CO, NOX, SOX, particulates
SOX, fluorides, particulates
Particulates
SOX) fluoride, particulates
Particulates
Particulates
ESP, fabric filter, multicyclones
Cyclone, ESP, fabric filter,
scrubber, settling chamber
Cyclone, fabric filter, scrubber
Cyclone, scrubber, water spray
Enclosure
Afterburner, ESP, fabric filter,
incinerator, scrubber, wet handling
Fabric filter, scrubber
ESP, fabric filter, scrubber
Cyclone, ESP, fabric filter
Cyclone, multiple cyclone, fabric
filter, settling chamber
Afterburner, scrubber
Fabric filter
ESP, fabric filter, scrubber,
process modification
Water spray
Cyclone, fabric filter
(continued)
5-10
-------
TABLE 5-3 (continued)
Products/process
Types of emission expected
Types of controls used
Coal conversion
Taconite ore processing
PETROLEUM INDUSTRY
Petroleum refining
Natural gas processing
WOOD PRODUCTS INDUSTRY
Chemical wood pulping
Pulpboard
Plywood veneer and layout
operations
Woodworking waste collection
operations
EVAPORATION LOSS SOURCES
Dry cleaning
Surface coating
Storage of petroleum liquids
Transportation and marketing
of petroleum liquids
Cutback asphalt, emulsified
asphalt, and asphalt cement
Solvent degreasing
Waste solvent recovery
Tank and drum cleaning
Source: EPA Publication AP-42
Hazardous organics, metal
carbonyls, trace elements,
toxic gases (CO, H2S, HC-N,
COS, CS2>, particulates
Particulates
CO, VOC, NH3, NOX, SO,
aldehydes, cyanides,
particulates
SOX
CO, H2S, SOX, NOX, dimethyl
disulfide, methyl mercaptan,
particulates, dimethyl sulfide
Particulates
Organics, particulates
Particulates
Volatile organic compounds
Volatile organic compounds
Volatile organ it compounds
Volatile organic, (.(impounds
Volatile organic compounds
Volatile organic compounds
Volatile organic compounds,
particulates
Volatile organic chemicals
Afterburner, ESP, fabric filter,
incineration, scrubber, water
spray, housekeeping maintenance,
process modification
Centrifugal collector, cyclone,
multiple cyclone, rotoclone, ESP,
fabric filter
Cyclone, ESP, incineration,
scrubber, vapor recovery system,
process modification, housekeeping
maintenance
Flaring, incineration, process
modification
Absorption, ESP, mist eliminator,
multiclone, scrubber, process
Not available
Condenser, cyclone
Cyclone, fabric filter
Carbon adsorber, incineration
Carbon adsorber, afterburner
Pressure tank, variable vapor
space tank, fixed or floating roof
Carbon adsorber, condenser
Carbon adsorber, condenser cover
Floating roof tank, scrubber,
condenser, incineration
Flare, absorption
5-11
-------
5.2.1 SPECIAL PROBLEMS
Special problems in developing point source emission inventories include
estimating fugitive emissions; accounting for factors influencing emissions
such as process variability, equipment malfunctions and upset conditions; and
estimating emissions from processes which do not have emission factors.
Fugitive emissions from stockpiles, material handling and transfer, process
leaks, hoods and roof monitors may represent a substantial portion of actual
emissions from many facilities. A list of 19 industrial processes, their
major sources of fugitive particulate emissions, and estimates of annual
uncontrolled emissions and the percentage of the fugitive contribution to
total uncontrolled emissions are shown in Table 5-4.' The emission
estimates, largely based on process data for various years in 1970, are not
supported by extensive test data.^ They should be used by the agency only
to identify sources and provide a rough measure of their potential
contribution to emissions from the industrial processes shown.
Variations in emissions due to normal process variability or abnormal
conditions of operation can result in greatly increased emissions which can be
difficult to quantify. For example, the efficiency of many control devices,
such as electrostatic precipitator, cyclonic collectors, condensers, sorption
columns and incinerators can be altered appreciably as a result of changes in
process, including feedstock changes, which result in flow variations, changes
in particle resistivity or other modifications of pollutant and waste streams
characteristics, etc. The effect of such changes on efficiency are not always
subject to rigorous analysis.
Equipment malfunctions or process upsets can also result in increased
emissions and are a recurring problem at some facilities, either because of
old or poorly maintained equipment or because of the inherent nature of the
process. Such excess emissions are difficult to quantify and require a search
of plant records to determine the frequency and duration of excess emissions
and the application of sound engineering judgment to estimate their
magnitude. The seriousness of the excess emissions problem has resulted in
regulatory actions in many states which require facilities to report all
incidents of excess emissions to the regulatory agency. However, there can be
no guarantee that all incidents are reported.
The agency is likely to identify facilities and processes for which no
emission factors have been developed. In inventorying such sources, the
agency will request and probably obtain a estimate of the type and quantity of
emissions from each operation. To validate this estimate, the agency must
obtain from the facility a description of the test procedures used. If the
test procedures are not valid or if no estimate is provided, the agency can
perform a source test or else require the source to perform a test using
accepted procedures. If testing is not possible, emission data obtained from
the current literature for processes which are similar to the one in question
can be used by experienced agency process technologists and engineers to
estimate emissions.
5-12
-------
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5.2.2 SPECIAL TECHNIQUES
There are several approaches that are useful to the agency in developing
solutions to difficult inventorying problems. These include:
1. Review of special studies by the EPA and others,
2. Review of a rapidly growing base of stack test data,
3. Mass balance calculations, and
4. More effective use of questionnaires.
Consultation with industrial and control system experts may also provide, or
suggest solutions, to particularly difficult Inventorying problems. These
people can be identified by directly contacting authors or EPA offices that
have produced reports on related topics.
EPA is involved in a great number of special studies in support of new
control technology, regulatory development, etc. The following programs* are
sources of industry-specific emission data:
1. New Source Performance Studies (NSPS) conducted prior to the
promulgation of NSPS.
2. Control Techniques Guideline (CTG) studies in support of Reasonably
Available Control Technology (RACT) for volatile organic compounds.
3. Source Assessment and other EPA studies aimed at relating process
parameters to emissions for specific industrial processes.
4. Proceedings of conferences sponsored by EPA, the Air Pollution
Control Association (APCA), and other ecological organizations.
Stack test data from similar processes at other locations may be
available from EPA or other state agencies and used to estimate emission for
sources within the agency's jurisdiction. Care should be exercised to ensure
that the effects of all process differences between the two locations have
been taken into account prior to using the stack test data to estimate
emissions. The Environmental Assessment Data System (EADS),^ developed by
EPA's Industrial Environmental Research Lab, Research Triangle Park, NC,
27711, is a rapidly growing data base which contains detailed field
*Further information concerning these data sources can be obtained from the
Office of Air Quality Planning and Standards and the Office of Research and
Development, U.S. Environmental Protection Agency, Research Triangle Park,
NC, 27711. EPA Regional Offices, also should be able to provide assistance
to the agency in obtaining pertinent efficiencies.
5-18
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measurement information. The EADS representative at IERL/RTP should be
contacted to obtain stack test data from specific industrial categories.
In some cases it is possible to use the material balance to calculate
mass emissions to the atmosphere. Mass balance calculations, however, are
susceptible to error in those instances where a minor error in the calculation
of a large mass (the input or product components) will have a major impact on
the small value (loss) being calculated; e.g., storage tanks losses.
Questionnaires of either an industry-specific or "catch all" type are
regularly used to collect much of the information needed from industrial point
sources (see Subsection 2.3.1). Source specific questionnaires should be used
to collect data from small operations such as grain elevators, small printing
plants, asphalt batch plants, etc., involving in most cases a singular
process. These questionnaires are easy to design by the agency and they
should be easy for the facility to fill out. For large, complex industrial
facilities the general questionnaire is best. A questionnaire should be
accompanied by a set of supplementary instructions in which examples of
typical process/operating units, feed materials, products and major activities
are listed. Appendix B provides a list of examples used by the EPA (EPA Form
3520-4A, 9-78).° These examples can be used as a guide for industry
personnel filling out the form.
5.2.3 CHEMICAL PROCESS INDUSTRY
The chemical process industry consists of a wide variety of facilities
producing a multitude of products. Individual facilities may produce several
products, operate several interconnected unit operations and have numerous
emission points.
A tabulation of some of the major activities, process/operating units,
feed materials used and types of products produced by the chemical process
industry is provided in Appendix B on page B-7. Although not a complete list,
this table does identify some raw materials, processes and products of the
industry. Typical emissions, along with usual control systems, used in 22
segments of the industry are presented in Table 5-3. The majority of
emissions from the chemical process industry are gas phase emissions and are
often controlled by incineration, adsorption and absorption. Combinations of
control equipment are sometimes used where several types of pollutants must be
removed from the waste gas stream or where a high collection efficiency is
needed. Pollution control in this industry is often economically
advantageous, as many constitutents of the emissions can be recovered and
recycled into the process.1
Special problems in the chemical process industry are often related to
the complexity of the processes and the manner in which emission streams are
treated. Fugitive VOC emissions from synthetic organic chemical manufacturing
are also a problem.^ A great deal of time and effort will be required to
identify all emission points and estimate total emission rates from a complex
process with several individual operations. In many operations several
5-19
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processes may be ducted to a single stack, making it difficult to assign
emission rates to each specific process. The agency questionnaire should
request that this information be provided in sufficient detail to accurately
explain the relationships among the various processes.
Emission factors for the 22 segments of the chemical process industry
listed in Table 5-3 are provided in AP-42. Because the emission factors for
some of these processes are based on limited data or were estimated using
material balances derived for similar processes, the reliability of emission
estimates based on the use of these factors is generally low. However, the
mass balance technique may be more amenable to chemical process sources than
other sources, because some manufacturers routinely calculate losses with a
high degree of accuracy.
5.2.4 FOOD AND AGRICULTURE INDUSTRY
Examples of some of the processes, operating units, products and feed
materials used in the food and agriculture industry are listed in Appendix B,
page B-16. Several steps are often involved in transforming the raw materials
into consumer products, many of which create emissions- For most segments of
this industry the primary concern is with particulate emissions. Cyclones,
baghouse filters and scrubbers are therefore the principal devices used to
control emissions.
If stack test data are unavailable, emissions must be estimated, usually
by comparison with a similar process. Comparison with operations for which
emission factors are available may lead to inaccurate estimates, however. For
example, particulate emissions from a grain elevator storing wheat will vary
with the type of wheat stored and duration of storage. As a result, emission
factors may not be accurate when applied to specific facilities or
localities. When AP-42 emission factors are unavailable or of high
uncertainty, the agency should attempt to locate more reliable data as
described in Subsection 5.2.2.
5.2.5 METALLURGICAL INDUSTRY
Examples of processes, operating units, feed materials and products of
the metallurgical industry are given in Appendix B, page B-14. The majority
of air pollutants result from various furnace operations. Table 5-3 lists the
types of emissions expected and pollution controls used in 18 segments of the
metallurgical industry. Effluent pollutants consist primarily of submicron
dusts and fumes resulting from the vaporization and condensation of charge
materials. Impurities present in the charge such as grease and oil can lead
to increased emissions of both particulate and organics. Combustion products
will also be present in the gas stream when a fuel-burning furnace is used.
Fluoride is emitted from primary aluminum and steel production processes in
both particulate and gaseous form, thereby creating a difxicult control
problem."
5-20
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Pollution control equipment used with furnaces must be capable of
operating at elevated temperatures and providing reasonable control efficiency
for submicron particulates. Control devices meeting these requirements
include ESPs, scrubbers, and baghouse filters using glass fiber fabrics or
some other high temparaturic fabric.1°
There are several potential sources of fugitive emissions in the
metallurgical industry. Process sources such as furnaces and open sources
such as storage piles and raw materials handling operations can result in
significant particulate emission. A ranking of emission points within steel
mills is shown in Table 5-5. While it is recognized that fugitive emissions
may constitute a large percentage of the total particulate emissions, very few
studies have provided quantitative emission data. Emission factors developed
for process sources of fugitives are often estimates rather than measured
values. As a result, the reliability of emission estimates based on these
factors is low. Emission factors for open sources are particularly lacking
with appreciably more sampling and analysis data being necessary to establish
such factors.H In the absence of specific stack test or emission factor
data, the agency should review the technical literature. EPA has conducted
and is presently conducting several studies of emissions from the
metallurgical industry. References 11, 12, and 13 are examples of studies
which will be of value to the agency in assessing emissions from the various
sources of fugitive emissions.
5.2.6 MINERAL PRODUCTS INDUSTRY
The mineral products industry consists of a broad range of processes used
to produce numerous nonmetallic products. A description of many of the
process and operating units used, feed materials used, and products produced
are presented in Appendix B, page B-13, while Table 5-3 lists the types of
emissions which can be expected and typical controls used in 21 segments of
the industry.
Most emissions in the mineral product industry are particulates resulting
from quarrying; material storage; and transfer, drying, crushing, screening,
conveying, and packaging operations. Since emissions are produced primarily
by mechanical wear, they are in most cases identical chemically to the parent
material.1
Control systems for drilling, transport, crushing, screening and
packaging operations typically include hood capture ducted to a fabric filter
or cyclone. Wet suppression is used whenever possible, particularly during
quarrying where it is often the only method of control used. Emission factors
for the 21 industry segments listed in Table 5-3 have been established and are
presented in AP-42-1 The accuracy of these factors may be affected by the
rate at which material is processed, the method of transfer, the moisture
content of raw material, and the degree of enclosure of transfer points,
processes, and storage areas. In addition, excess emissions are often caused
by overloading process equipment such as kilns, dryers, and furnaces which
resulting in higher gas velocities through pollution control equipment and a
high frequency of breakdown or malfunction.
5-21
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TABLE 5-5. STEEL MILL SOURCE PRIORITY RANKING FOR PARTICULATE EMISSIONS
Model
plant
Ib/hr
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
Coke quenching
Blast furnace casthouae
BOF stack
Material stockpiles
Roadway travel
Coke combustion stack
BOF charge and tap
Coke pushing
Sinter, misc. fugitives
Sinter windbox
EAF charge, tap, slag
Coal preparation
Open hearth stack
Coke door leaks
EAF stack
Sinter discharge end
Blast furnace top
Ore screening
Teeming
BOF misc. fugitives
Coke topside leaks
(continued)
5-22
283
156
143
120
118
110
97
62
64
60
54
52
50
49
46
42
26
25
18
15
14
Industry
total
tons/yra
38,000
25,000
22,000
18,000
18,000
18,000
16,000
9,800
9,600
9,000
8,400
8,200
8,000
7,800
7,300
6,300
4,100
3,600
4,100
2,400
2,300
-------
TABLE 5-5 (continued)
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
Coal charging
Reheat furnaces
Blast furnace combustion
Open hearth roof monitor
Open area
Machine scarfing
BOF hot metal transfer
Open hearth misc. fugitives
Soaking pits
EAF misc. fugitives
Open hearth hot metal
transfer
Model
plant
Ib/hr
14
13
12
12
8
5
4
4
3
4
4
Industry
total
tons/yr
2,000
2,200
2,000
2,000
1,200
740
720
700
630
600
210
aTons per year—multiply by 0.9078 to obtain metric
tons/yr (1000 kg).
BOF—Basic Oxygen Furnace
EAF—Electric Arc Furnace
Source: Development of Inhalable Particulate Emission
Factors for Ferrous Metallurgical Sources,
Program Overview Paper, Peer Review for
Metallurgical Process Branch, IERL,
U.S. EPA, February 19, 1981.
5-23
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5.2.7 WOOD PRODUCTS INDUSTRY
Operations that make up the wood products industry include timber
harvesting and transportation, saw mills and planing mills, veneer and plywood
mills, hardboard and insulation board mills, particle board mills, pulp and
paper mills and whole wood products. Four segments of the industry which can
cause significant emissions are listed in Table 5-3. A description of the
major process/operating units, feed materials, and products produced by the
industry are presented in Appendix B, pages B-9 and B-17.
Pulping is accomplished by one of three processes: Kraft pulping, acid
sulfite pulping, and neutral sulfite pulping, each producing different amounts
and types of emissions. Emissions consist mainly of particulates and various
sulfur compounds with scrubbers being the most common control device used.
Emission factors are presented in AP-42-* for the Kraft and acid sulfite
processes. Emission factors for the neutral sulfite process are not
provided. Several EPA studies, which report pulp and paper mill emission
data, are available to the agency. The proceedings of annual Technical
Association of the Pulp and Paper Industry (TAPPI) conferences also provide
emission data.
Emissions generated from plywood, veneer and layout, and woodworking
waste collection operations consist mainly of particulates. A simple cyclone
is generally considered an adequate control method due to the relatively large
particle size (generally greater than 10 ym), while baghouse filters can be
used to capture essentially all of the emissions. Emission factors for
fugitive sources of particulates from plywood, veneer and layout operations
and for cyclone-controlled woodworking operations are provided in AP-42.
Organic compounds are also emitted from veneer drying operations, the
condensable fraction of which can be recovered by condensation. Emission
factors are dependent upon the type of wood used and are so presented in
AP-42.!
5.2.8 PETROLEUM INDUSTRY
The petroleum industry consists of crude oil and natural gas production,
petroleum refining and natural gas processing. Major activities, processes
and operating units typical of the petroleum industry are presented in
Appendix B, page B-4. Table 5-3 lists emissions which can be expected and
typical controls used by the industry.
Air contaminants emitted from crude oil and natural gas production
consist chiefly of light saturated hydrocarbons. Hydrogen sulfide gas may
also be emitted in some production areas. The principal emission sources are
process equipment (well drilling and pumping) and storage vessels. Internal
combustion engines, mostly natural gas-fired compressors, are also a source of
emissions. Acceptable control methods for drilling and pumping operations
include smokeless flares and general maintenance procedures. AP-42 does not
contain emission factors for drilling and pumping.
5-24
-------
In refining, petroleum crude oil is converted into more than 2500
products. Major potential refining emissions include hydrocarbons, sulfur
oxides, carbon monoxide, nitrogen oxides, particulate matter, aldehydes and
ammonia. Major emission sources include vacuum distillation, catalytic
cracking, thermal cracking, utility boilers, heaters, compressor engines,
blowdown and sulfur recovery systems- In addition, fugitive emissions
consisting mainly of hydrocarbons and sulfur compounds are emitted from
wastewater systems, cooling towers, pipeline fittings, relief valves, pump and
compressor seals, asphalt blowing, sweetening, storage and transfer
operations. •"-
Emissions are largely dependent upon production capacity, the type of
crude oil processed, type and complexity of the processing employed, air
pollution control measures in use, and the degree to which maintenance and
good housekeeping practices are used. Emission factors for many, but not all,
petroleum refinery operations are provided in AP-42.1 Emission factors are
also provided for many uncontrolled sources of fugitive hydrocarbon
emissions. The agency should obtain additional fugutive emission data from
recent or current EPA studies as discussed in Subsection 5.2.2.
Natural gas is often processed to remove contaminants. Field separators
are used to remove hydrocarbon condensate and water at the well. Hydrogen
sulfide must be removed in a gas sweetening plant if the concentration is
greater than 0.25 grains/100 standard cubic feet. In approximately 95 percent
of the plants in the U.S., hydrogen sulfide is removed by absorption in an
amine solution. Emission factor for amine process gas sweetening plants, using
smokeless flares or incinerator controls are provided in AP-42.-^
5.2.9 EVAPORATION LOSS SOURCES
Evaporation loss sources of concern are those producing volatile organic
compound (VOC) emissions. A list of eight major sources of VOC emissions
along with typical pollution controls used is shown in Table 5-3 Emission
sources include organic solvents emitted from dry cleaning, surface coating
and degreasing operations in addition to volatile organics emitted from
petroleum products. A description of the processes from which organic
solvents may be emitted, the feed materials commonly used, and the products
produced are given in Appendix B, page B-8.
Carbon adsorption, condensation and incineration are the primary methods
of controlling VOC emissions from many operations emitting solvents. Control
efficiency for carbon adsorption systems properly designed and maintained are
in excess of 90 percent. However, poor maintenance and improper operation of
equipment may result in excess emissions. In addition, leaky pipes, flanges
and pumps can also be significant sources of fugitive emissions.^-^ Solvent
recovery by both carbon adsorption and condensation may have economic benefits
depending on the type and amount of solvent used. Emission factors for
controls and uncontrolled dry cleaning operations are provided in AP-42^-
along with emission factors for surface coating operations.
5-25
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Methods used to control emissions from petroleum storage include using
fixed roofs, floating roofs, variable vapor space tanks, and pressure tanks-
Emissions are generated through fixed roof breathing and working losses,
floating roof standing storage losses, floating roof withdrawal losses,
variable vapor space filling losses, and pressure tank losses. Loading
operations, potentially a major source of emissions, are effectively
controlled by carbon adsorption and condensation with efficiencies in excess
of 90 percent. Emission factors for storage facilities are provided in AP-42.
For many sources of VOC emission, the best method of estimating emissions
from solvent evaporation is the mass balance. In this case, it is assumed
that all of the solvent used in a process evaporates into the atmosphere.
Therefore, the only information needed to calculate emissions is the amount of
solvent purchased over the time interval of concern, with emissions being
equal to the quantity of solvent purchased less any solvent returned to
reprocessors."
References for Chapter 5.0
1. Compilation of Air Pollution Emission Factors, 3rd Edition and
Supplements, AP-42, U.S. Environmental Protection Agency, Research
Triangle Park, NC, October 1980.
2. AEROS Manual Series, Volume II; AEROS User's Manual, EPA-450/2-76-029,
U.S. Environmental Protection Agency, Research Triangle Park, NC,
December 1976.
3. Environmental Assessment Data Systems; Systems Overview Manual,
EPA-600/8-80-005. U.S. Environmental Protection Agency, Research
Triangle Park, NC, January 1980.
4. 1977 National Emissions Report, EPA-450/1-80-Q05, U.S. Environmental
Protection Agency, Research Triangle Park, NC, March 1980.
5. Preliminary Emissions Assessment of Conventional Combustion Systems,
Volume II, EPA-600/2-76-046b, U.S. Environmental Protection Agency,
Research Triangle Park, NC, March 1976.
6. Emissions Assessment of Conventional Combustion Systems, Volumes I
through V and Summary Report, EPA Contract No. 68-02-2197, U.S.
Environmental Protection Agency, Research Triangle Park, NC, April 1981.
7. Assessment of Fugitive Particulate Emission Factors for Industrial
^Processes, EPA-450/3-78-107, U.S. Environmental Protection Agency,
Research Triangle Park, NC, September 1978.
8. EPA Form 3520-4 (9-78): OMB No. 158- R0075.
5-26
-------
9. Guideline Series—Control of Volatile Organic Fugitive Emissions from
Synthetic Organic Chemical, Polymer, and Resin Manufacturing Equipment:,
Freliminay Draft, prepared for Emissions Standards and Engineering
Division, Office of Air Quality Planning and Standards, U.S.
Environmental Protection Agency, Contract No. 68-02-3168, January 1981.
10. Danielson, J. A. Mr Pollution Engineering Manual. Air Pollution
Control District: County of Los Angeles. EPA Publication AP-40. May
1973.
11. Fugitive Emissions From Integrated Iron and Steel Plants,
EPA-600/2-78-050, U.S. Environmental Protection Agency, Research Triangle
Park, NC, March 1978.
12. Particulate Emission Factors Applicable to the Iron and Steel Industry,
EPA-450/4-79-028, U.S. Environmental Protection Agency, Research Triangle
Park, NC, August 1979.
13. Operation and Maintenance of Particulate Control Devices on Selected
Steel and Ferroalloy Processes, EPA-600/2-78-037, U.S. Environmental
Protection Agency, Cincinnati, OH, March 1978.
14. Guide for Lowest Achievable Emission Rates from 18 Major Stationary
Sources of Particulate, Nitrogen Oxides, Sulfur Dioxide, or Volatile
Organic Compounds, EPA-450/3-79-024, U.S. Environmental Protection
Agency, Cincinnati, OH, April 1979.
15. Procedures for the Preparation of Emission Inventories for Volatile
Organic Compounds, Volume I, Second Edition, EPA-450/4-79-028, U.S.
Environmental Protection Agency, Research Triangle Park, NC, September
1980.
5-27
-------
APPENDIX A
GENERAL INSTRUCTIONS TO THE APER FORM
£PA Form 3520-4 A (9-78)
A-l
-------
LNVIRONMIiNTAL PRO'l ECTION AGENCY
AIR POLLUTANT EMISSIONS REPORT
1. BACKGROUND
Hie An Pollutant I misMons Kepoif (API R) loun is a comprehensive veliiclo for oblainr'g
operational and emissions il.il.i from a wide variety o) nulustnal and commercial souicos. Trie APF.R
has been organized into sepaiatc sections as follows.
Section
I
II
III
IV
Fit Ic Purpose
GhM-RAl. 1NI-ORMA1 ION Basic source identification data.
MAJOR ACTIVITY IHROUGHPUTS Operating capacity of major activities.
FACILITY INK RRI I ATIONSIIIPS Inter connection of process/operating
units, air cleaning equipment, and
stacks and vents at the facility.
PROCFSS/OPI RATING DAI A
P.iit 1 Cieneial Information
Unit description and operation data.
Pait 2 Input/Output Information. Feed material and product throughput data.
Part .? Fuel Usage llorination Fuel usage ol combustion units.
(•.MISSIONS DAI A
VI
VII
VIII
IX
AIKCLI AMN(, lOUIPMFN'i
STACKS AND VLNTS
STORAG1 IANK DATA
Quantity ol emissions into the atmostpliere
of each pollutant from each source.
Specifications foi all air cleaning
equipment units.
( haraetcrisucs of all pollutant
emission points.
Chaiacteristics and specifications of
all otganic liquid storage facilities.
SOIVFN'I US'\(.i INFORMATION Solu-nt identification, recovery and
disposal data.
The questionnaire requests data to be supplied lor ma]or activities (Section II) and for process/
operating units (Sections 111 and IV). A major activity is an independent procedure that transforms
raw material inputs into finished pioducts. In industnes such as petroleum refining and chemical
production, major jc'ivities may relate to the output of the intermediate products.
Process/updating units consist of one 01 more pieces of equipment which convert initial or
intermediate inputs into intermediate or final outputs, 01 aie involved with materials handling or
storage operations Lach proccss/opeiatniL; unit has the potential to be a source of air pollution
emissions.
EPA Form 3520-4 A (9-78)
A-2
-------
I. BACKGROUND (Cont'd)
The APER instructions have been arranged in two segments. The first segment provides detailed
guidelines for completing the entire questionnaire. These instructions have been prepared to assist
you in completing the form by explaining the data requested in each item. The second segment deals
with the characteristics of specific industrial and non-industrial categories by providing examples of
process/operating units, input materials and output products, and units of measure. These
supplemental instructions are designed to assist you in completing the APER in those situations
unique to a particular industry or category. They can also provide aid in helping you to differentiate
between major activities and process/operating units.
II. COMPLETING THE FORM
If no pollutants are emitted at your facility, then only Section I of the form need be completed.
If any of the pollutants listed in the cover letter are emitted, then the entire questionnaire must be
filled out. In either case, the individual responsible for completing the APER must sign it.
Each respondent reporting on pollutant emissions should complete all sections of the form for
which he has information. Every effort should be made to determine the required data and guessing
should be avoided.
Section VIII, STORAGE TANK DATA must be completed for any facility in which organic
liquids are stored. Additionally, Section IX, SOLVENT USAGE INFORMATION, must be filled out
if the facility uses solvent or it employs a feed material containing solvent.
If all data for a given section of the APER cannot be listed on each sheet, use additional copies
of the required section. The number of sheets used should be indicated in the upper right-hand corner
where "PAGE OF " is shown. This designation refers to the pages of a given section and not
the entire APER. Therefore, if you had four major activities in Section II, the forms should contain
PAGE 1 OF 4 through PAGE 4 OF 4. If additional copies are not available from EPA, please use
copies of the original form.
In certain instances, it may not be possible to enter all the relevant information for a given item
in the space provided. In these situations, it is acceptable to use the same space on the next line for
the additional data. However, be careful to list each new identification number or code on an empty
line to avoid confusion.
It is important to distinguish between data values which are zero, and those that are unknown
or blank. Accordingly, if an item has a ^ero value, be certain to clearly write "0" in the appropriate
space. If the data item does not apply to your situation, indicate this by entering "N/A" for not
applicable. A blank response should bo used when the information requested is unknown.
In the upper left part of each page, list the date this page of the APER is submitted. Pages two
through eleven ask that the facility name be shown in the upper right-hand corner. This information
should not be overlooked.
On pages two through eleven, usually in the first column on each sheet, you are requested to
supply an identification number or code for each process/operating unit, air cleaning device and stack
or vent. Please use your own internal code for identifying these units, if such an ID exists. Otherwise,
make specific assignments of numbers or codes and ensure that the same number of code is used
throughout the APLR to refer to the item to which it was originally assigned.
EF V Form 3520-4 A (9-78)
A-3
-------
II. COMPLETING THE FORM (Cont'd)
In many instances the APER requests that data elements be provided in specific units of
measure. Please adhere to these specifications wherever possible. If the required information is not
available in the requested units of measure, other units may be used. However, these units should be
clearly identified on the form. In other instances, specific units have not been indicated, and you are
urged to use the most appropriate measure. In either case, the size of specific industry measures such
as petroleum barrels and cotton bales must be clearly defined in standard units (Ibs, gals, etc.) to
prevent any misunderstandings. These measures can be defined in the space available at the bottom of
the form in Sections IV through IX.
III. GENERAL INSTRUCTIONS
The detailed general instructions for completing the APER are as follows:
SECTION I. GENERAL INFORMATION
1. Facility Name - Provide full legal name under which business is being conducted.
2. Facility Address - Complete address or exact location at which business is being conducted. Do
not use post office box numbers.
3. County - County in which facility is located.
4. Mailing Address -- Complete address to which all mail for this facility is sent. Post office boxes
may be used. Be sure to include the correct zip code.
5. Facility Contact - Name of responsible facility manager who can be contacted for additional
data concerning operations at the facility.
6. Position - Title or position of the Facility Contact.
7. Telephone Number - Telephone number of the Facility Contact. Be certain to include the area
code.
8. Parent Company Name - If organization operating the facility is a subsidiary or division of
another firm, give full legal name of parent company.
9. Parent Company Mailing Address - Complete mailing address of main office of parent
company.
10. Parent Company Contact - Name of individual in the parent company responsible for
operation of the subsidiary or division.
11. Position — Title or position of parent company contact.
12. Telephone Number -- Telephone number of parent company contact. Be sure to include area
code.
13. Calendar Year of Record - Calendar year for which data is being provided. All data should be
representative of operations that occurred during the most recent calendar year.
EPA Form 3520-4A (9-78)
-------
III. GENERAL INSTRUCTIONS (Cont'd)
14. Land Area in Acres - Size of lot at which facility is located.
15. Elevation Above Mean Sea Level Mean elevation above mean sea level of lot at which facility
is located.
16. Number of Employees Approximate number of employees at location specified in (2) above
at end of calendar year of record.
17. Principal SIC Code List the principal SIC code describing the operations at this facility, If
known.
18. Principal Products List principal piuducts produced or services performed at this facility.
19. Construction Start Date -• Month, day and year that a contract was signed to undertake and
complete a continuous program of construction or modification of the entire plant or facility;
or the month, day and year the initial work actually began if no contract was signed.
20. Operation Start Date - Month, day and year the plant or facility began operations.
21. Sketches Provide sketches or diagrams depicting each of !hc following Hems for which check
marks were placed in the associated boxes.
a) Plant or facility location Show nearest cross streets, roads or landmarks and indicate
the north direction.
b) Plant layout - Denote the location of all structures, buildings and major activity work
areas. Indicate the north direction. Locate each source of pollution separated by 50 yards
or more and show its internal identification code.
c) Process flow for entire facility - Illustrate the material flow relationships among the
major activities using a simple block diagram, not to exceed one page,
d) Process flow for each major activity Illustrate the material flow relationships among the
process/operating units, air cleaning equipment, and stacks and vents. Be certain to
identify all items by the proper internal identification codes.
If a facility is small, it may be possible to combine figures 2 la and 21b into one diagram.
If a facility has only one major activity, the process flow sketches defined in 21c and 21d may
be combined into one diagram.
22. Signature - Signoff of responder to the questionnaire.
a) Complete this item only if the other sections of this questionnaire do not apply due to a
lack of emissions of the designated pollutants. List these pollutants and sign and give your
title where indicated.
EPA Form 3520-4 A (9-78)
A-5
-------
III. GENERAL INSTRUCTIONS (Cont'd)
b) Complete this item only if other sections of this questionnaire must be completed. List the
pollutants that apply to your facility, sign the form and give your title where requested.
SECTION II. MAJOR ACTIVITY
The page containing Sections II and III provides information for one major activity only. Use
separate pages for each major activity.
1. Description of Major Activity Describe in a few words, the activity being performed at the
facility. This explanation should relate to the products made or the services performed.
2. Construction Start Date Month, day and year that a contract was signed to undertake and
complete a continuous program of construction or modification of the major activity facility;
or the month, day and year the initial work actually began if no contract was signed.
3. Operation Start Date - Month, day and year that activity operations began.
4.* Major Activity Product — List major products resulting from this major activity or the materials
being processed.
5.* Maximun: Operating Capacity -- Indicate the maximum amount of each product that the
facility can produce or the amount of material that can be processed.
a) Annual Rate ol annual production during calendar year of record; include units of
measure.
b) Hourly Rate of hourly production during calendar year of record; include units of
measure.
SECTION III. FACILITY INTERRELATIONSHIPS
The Facility Interrelationships Section should be utilized to indicate how process/operating
units, air cleaning equipment and stacks and vents are interconnected. On each line, space has been
provided to list by identification code, one process/operating unit (Item 1), two units of air cleaning
equipment (Items 2a and b) and three stacks and vents (Items 3a, b and c). There is no need to
describe these units in this section. Descriptions are requested in later segments of the APER. At this
point you are only being asked to indicate how your units are related to each other. If more space is
required for additional air cleaning devices or stacks and vents handling the emissions from a given
process/operating unit, the next line should be used. Figure 1 indicates how this form should be
completed, and the following describes its interpretation:
a) Process/operating unit PP01 is serviced by control devices CC01 and CC02, and causes
emissions via stacks and vents SS01, SS02, and VV01.
* Items 4 and 5 appear un I'Oth halves <>l die tunti lo jlluw tor I lie listing of six major activity products.
EPA Form 352U-4A (V-78)
A-6
-------
SECTION HI. FACILITY INTERRELATIONSHIPS (Cont'cl)
b) Process/operating unit PP02 is serviced by control devices CC03, CC04 and CC05, and by
stacks and vents SS03 and VV02.
c) Process/operating unit PP03 is also controlled by device CC04 as well as device CC06, and
emissions exit through stack SS03.
Table 1 provides a general listing of process/operating units and air cleaning equipment. For
examples of specific units dial relate to given industries, see the supplemental instructions for that
industry.
SECTION IV. PROCESS/OPERATING DATA
Section IV requests information concerning each process/operating unit at the facility including
those units that arc on standby. Data are requested concerning the general characteristics of the unit,
its inputs and outputs, and all the fuels it burns. The same identification codes that were listed in
Section 111.1 should be included here.
Part 1. General Information
Part 1 of the Process/Operating Data Section lequests geneial information for all
process/operating units.
EPA Form 3520-4A (9-78)
A-7
-------
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A-8
-------
Table 1. EXAMPLES OF PROCESS/OPERATING UNITS AND AIR CLEANING EQUIPMENT
PR OC ESS/OPE RATING UNITS
Procurement Handling
Surface Mine
Quarry, Excavation
Harvester
Solids Storage Method
Conveyor, Hopper
Elevator
Pipeline
Process Units
Crusher, Grinder, Mill
Saw, Clnppei, Sander
Blender, Miser
Separator
Meltei, Smelter
Diyer, Calcmer
Smoker, Rendeiei, Cooker
Pneumatics j Converter, Refiner
Combustion Units
Boilei
Incineratoi*
Heater, Burnei
Engines
Evaporative Units
Storage Tanks
Mixing Tanks
Miscellaneous Open
Tanks
Solvent Operations
1'iactio/iator, O.xidizer
Polymeu^ei
Reactor
Jrnpregnalor, Soaker
Surface C'oater
Lvaporatoi, Condenser
Furnace
AIR CLEANING EQUIPMENT
Particulars
Baghouse
Cyclone Separator
Spray Chamber
Wet Scrubber
Dry Electrostatic Pre-
cipitator (ESP)
Wet ESP
Settling Chamber
Filter
Venturi Scrubber
Impingement Separator
Vapors
Absorber
Adsorber
Afterburner
Condenser
Scrubber
Vapor Balance Transfer
System
""Include incinerator only il it uses an indirect heat exchanger. Direct flame units are to be shown
under Air Cleaning Equipment in Section VI.
EPA Form 3520-4A (9-78)
A-9
-------
SECTION IV. PROCESS/OPERATING DATA (Cont'd)
1. Internal ID Code of Process/Operating Unit - List the internal identification (ID) codes of all
process/operating units at the facility. Include units used in the transfer of raw materials and
for space heating.
2. Description of Process/Operating Unit - Provide a brief description of each process/operating
unit at the facility. Sample descriptions are listed in Table 1. For examples that are
representative of your specific industry, please see the supplemental instructions.
3. SCC (Source Classification Code) Enter the most appropriate SCC for your facility, //// is
known.The complete SCC list is published by EPA in AP-42, "Compilation of Air Pollution
Emission Factors."
4. Operational Dates Provide the appropriate dates only if they fall after August 17, 1971,
unless they are specially requested in the cover letter to this form.
a) Construction Began: Indicate the month, day and year that a contract was signed to
undertake and complete a continuous program of construction or modification to the
process/operating unit; or the month, day and year that work actually began if no
contract was signed.
b) In-Service: List the month, day and year the process/operating unit began operations.
5. Operating Schedule
a) Hours/Day: Give the normal operating hours per day.
b) Days/Week: Provide the normal operating days per week.
c) Weeks/yeai Enter the actual number of weeks ol operation during the calendar year of
record.
d) Hours/Year: Provide the actual number of hours of operation during the calendar year of
record.
6. Process Seasonal lliroughput ('7<) Enter the annual throughput percentage for each of the
seasonal quarters, as shown These quarters are based on seasons of the year and are' not
calendar quaitcrs. "IXxvmbcr" in Item 6a refers to the year prior to the "Calendar Year of
Record" listed in Section 1, Item 13.
a) December February (Winter)
b) March Mav (Spring)
c) June August (Summer)
d) September- November (Fall)
Part 2. Input I Out put Information
Part 2 of the Process/Operating Data requests feed and product throughput data for all units
except those having to do exclusively with fuel usage. Units used for the cleaning of fuels are to be
included in this section.
1. Internal ID Code ot Process/Operating Unit Enter the internal identification code of each
process/operating unit listed in Part 1 (omit combustion units specifically used for process or
space heating, boileis. etc.)
EPA Form 3520-4A (9-78)
A-10
-------
SECTION IV. PROCESS/OPERATING DATA(Cont'd)
Complete Items 7 and 8 placing no nioie than one input and one output on each line. Feed
materials and products should be shown on the same line, or on consecutive lines below the line
containing the ID code to winch they apply. Each new ID code should be shown on the first available
line after all feed materials and products have been listed for the previous unit. Specify the units that
are common for the industry and if abbreviations are used, define them in the space provided at the
bottom of the page.
7. Process/Operating Unit Inputs •- List each feed material and its throughput on a separate line.
a) Teed Materials: List all feed materials used by the process/operating nnit but omit fuels
that arc not specifically feed materials for products or processes. Fuels that are feed
materials should be included with other feed materials under process/operating unit
inputs.
b) Annual Rate. Give the quantities of feed materials actually used for this
process/operating unit during the calendar year of record. Specify the units that are
common for the industry.
c) Daily Process Rale' I isi (he designated feed rates using identical units for each category
and specify the units used.
Normal daily feed rate undei normal use of the year of record.
Maximum maximum daily feed rate attained during the calendar year of record
Note: The daily Piocess Rate must be completed only if the feed material is a solvent or
contains solvent. I-'or all other feed matciials, this item may be omitted.
d) llouily Process Rale: Lisl the designated hourly feed rates using identical units for each
category and specify the units used.
Design hourly feed ule as specified by the manufacturer
Normal - houily feed rate under normal use for the year of record
Maximum maximum hourly feed rate attained during the calendar year of record
e) Reid Vapor Pressure (KVP) Lntcr the RVP or the true vapor pressure of the stored
material in psia at IOO°F. II not readily available enter the vapor pressure in psia and
specify corresponding temperature (e.g., 3.5 ("' 70°F). This item is not to be used in
relation to storage of solid materials, and should only be completed for feed materials
containing organic liquid.
8. Process/Operating Unit Outputs
a) Products: List all products of the specified process/operating unit. Use one line for each
product.
b) Annual Rate: Enter actual quantity produced by the process/operating unit during the
calendar year of record under amount and specify the appropriate units.
c) Hourly Process Rate: Enter the designated hourly production rates using identical units
of measure loi each category and specify units.
Design - product late as specified by the manufacturer
Normal -- normal production rate for the calendar ye.ir of record
Maximum maximum production rate during calendar year of record
EPA Form 3520-4 A (9-78)
A-ll
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SECTION IV. PROCESS/OPERATING DATA (Cont'd)
Part 3. Fuel Usage Information
Part 3 requests information concerning fuel usage of combustion units.
1 . Internal ID Code of Process/Operating Unit - bnter the internal ID code of combustion units from
Section III.l or Section IV, Part 1 .1 . Use one line for each fuel type burned in the unit.
9. Size of Combustion Unit - Enter the maximum rated capacity for the combustion unit in
millions (10 ) BTU/hour. If the maximum rated capacity is only known in boiler horsepower,
brake horsepower or pounds of steam per hour, convert to BTU/hour as follows:
• Multiply the boiler horsepower by 33.5 x 10
• Multiply the brake horsepower by 25.5 x 10
• Multiply the pounds of steam per hour by the heat content of the steam in BTUs/!b and
divide by the boiler efficiency. If either the heat content of the steam or the boiler
efficiency are known, specify the quantities that are known by placing a letter after the
value of the item as follows:
For pounds of steam per hour, use "S," e.g., .1 - S, in 10 Ibs steam per hour;
For heat content of the steam, use "II," e.g., 1 1 50-H in BTU/lb; and
For boiler efficiency, use "B," e.g., 60% - B.
Note: This item is not. applicable lor direct heat transfer units.
10. Fuel
a) Type: Spccity the type of fuel burned in the combustion unit. If more than one fuel is
burned, list each fuel on a separate line on the form and provide all the data requested. If
solvent is added to the fuel, be certain to include the solvent in this item. Typical
examples of fuels include:
anthracite coal, bituminous coal, I.^nite
coke
LJJC. butane, propane
natural gas
process gas
wood, bark, sludge
fuel oil and number (e.g., fuel oil #2)
gasoline
Foi items b, c, d and e, if any of these values are unknown, obtain the necessary data from your
fuel supplier.
b) Heat Content. Enter the heat content of the fuel in BTU per fuel unit, where the fuel
unit is specified in Item 1 1 B, Amount of Fuel Used -- Hourly. (Average value for calendar
year of recoid )
c) Percent Sulfur Provide the average percent of sulfur by weight in the fuel used during the
calendar year of record; and indicate the highest percentage of sulfur by weight in the
fuel used lor the year.
d) Percent l^ad' ("urnish the average percent of lead by weight in the fuel used during the
calendar year ot record, and indicate the (ughesi percentage of lead by weight in the fuel
Xised for the year.
EPA Form 3520-4 A (9-78) A- 12
-------
SECTION IV. PROCESS/OPERATING DATA (Cont'd)
e) • Percent Ash: Enter the average percent ash by weight in the fuel used during the calendar
year of record.
11. Amount o) Fuel Used
a) Animal' Provide the amount of fuel using during the year and specify the units of
measure. Recommended units include tons for solid fuels, thousand (10 ) gallons for
liquid fuels, and thousand (10 ) cubic feet for gaseous fuels.
b) Hourly Kate: Enter the liouily fuel consumption rate using identical units for the three
designated entries.
Design - consumption rate as designed
Normal nonnal consumption rate
Maximum maximum utc ol fuel use during the year
Specify the units used. Recommended units include pounds for solid fuels, gallons for liquid
fuels and cubic feet for gaseous (uels.
12. Normal Percent h'xccss Air Used Enter the normal percentage of air in the combustion unit in
excess of that required lor complete combustion of the fuel. Use the space at the bottom of the
form to define any unit abbreviations used.
13. Pud Seasonal 'throughput ("',) I ntei the annual percent of luel burned during each quarter
of the year on a seasonal basis "December" in ITEM 13a refers to the year prior to the
"CALENDAR YLAR 01 RLCORD" listed in SECTION 1, HEM 13.
a) December-February (Wmier)
b) March-May (Spring)
c) June-August (Summer)
d) September-November (i'aJI)
SECTION V. EMISSIONS DATA
This section identifies sources of emissions to the atmosphere and describes the pollutants and
the quantities of their respective emissions. No stack test should be expressly conducted in order to
complete this section <>/ (he form, and guessing is not a valid emission estimation method.
1. Internal ID Code oj Lstimatioti Point List all the ID codes of units for which emission
estimates are available Those should include piocess/operatmg units, air cleaning devices and
stacks and vents.
2. Location <>j /.'mission I'slinwiion 1'uint Identity (he location at which the emission estimate
is being made Provide inhumation foi all emission points for which data is available. Possible
responses for this item include
EPA Form 3520-4A (9-78)
A-13
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SECTION V. EMISSIONS DATA (Cont'd)
1- Stack
2- Vent
3- Fugitive
4- Immediately after the process/operating unit (prior to combination with other units)
5— Immediately after the control device
Enter either the indicated number or the appropriate term.
3. Pollutant For the unit identified in Section V.I and Section V.2 above, list each pollutant for
which emission estimates are available on a separate line. For hydrocarbons, specify the
chemical name such as methane, butane, benzene, if known, and enter each on a separate line.
4. Estimation Method Specify the method used to make the emission estimate for each
pollutant. Possible responses include:
1- Stack Test
2- Material Balance
3- EPA Emission Factor
4- Other Emission Factor (Specify)
5 - Other (Specify)
Enter either the indicated number 01 the appropriate term.
5. Emissions Enter the quantity of emissions attributed to the measurement point. For
process/operating units this quantity refers to the level of emissions in the absence of controls;
for air cleaning devices the quantity refers to the level of emissions after the control procedure
has been completed; and lor stacks and vents, the measurement is considered to be at a point
just prior to the emissions entering the auiospherc.
a) Annual: Lnter the total emissions in tons ol the pollutant for the calendar year of record.
b) Hourly: Lnter the normal and maximum emission rates in pounds per hour for each
pollutant for the ycai.
6. Source Test Data Complete this item only if the box in the heading contains a check mark
and a physical test was performed at the emissions estimation point indicated in item 2.
a) Date of Last Test: Enter date when the last emissions test was conducted.
b) Method Used: Describe the analytical procedure used to obtain the results. These
methods may be denoted by an acronym and a number such ar,: EPA Method #5. If any
other test method was used, specify all pertinent data.
c) Percent Operating Capacity: Enter the percent of design product-throughput at the time of
the test
Supply copies of records for all source tests performed in the last (3) years. No source tests
should be conducted specifically lor this rcpoit
EPA F«m 3520-4 A (9-78)
A-14
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SECTION VI. AIR CLEANING EQUIPMLNT
Information concerning eacli item of air cleaning equipment whose internal ID code should
have been listed in Section III.2 is requested in this section.
1. Internal ID Code of Control Equipment - Enter ID code of each item of control equipment.
2. Air Cleaning Equipment
a) Type: Specify type of control equipment such as:
• single cyclone
• mechanical, centiifugal separator
• spray chamber, vcnlun scrubber
• baghouse
• electrostatic precipitators (single or two-stage)
• afterburners
• condensers
• absorbers, adsorbers,, scrubbers
• direct flame incinerators
b) Normal lire/Week: Enter the hours of operation of the equipment during a normal
operating week.
c) Normal 1 Irs/Day I'.ntei the hours of operation of the equipment on a normal operating
day.
5. Pollutant Removed - I ist the specific pollutants removed including the chemical names for all
hydrocarbons where available. If more than one pollutant is affected use an additional line for
each pollutant. The following pollutant abbreviations may be used.
SOV = Oxides of Sulfur
X
NO = Oxides ot Nitrogen
PART = Participates
CO = Carbon Monoxide
THC = Total Ilydiocjibons
Other (Specify)
6. % Collection Efficiency Entei the efficiency ol pollutant collection 111 percent by weight.
a) Design I nk-i design efficiency of the unit foi the pollutant.
b) ActuaJ: Enter the actual efficiency attained during the year of record.
7. Inlet Gas Temperature (°F) Enter the normal temperature of the gas entering the air cleaning
device in °F.
8. Inlet Cos l-'low Rate Entci the normal volumetric flow of the gas entering the air cleaning
device in actual cubic leel per minute (aefm).
EPA Form 3520-4A (9-78)
A-15
-------
SECTION VI. AIR CLEANING EQUIPMENT (Cont'd)
9. Hlel Gas Pressure - Enter the normal pressure of the gas at the inlet to the air cleaner in
p. a.ids per square inch absolute.
10. Pressure Drop - Enter the pressure drop through the air cleaning device.
a) Design: Provide the design pressure drop in pounds per square inch (psi).
b) Actual: Enter the average actual pressure drop in psi.
SECTION VII. STACK AND VENT DATA
Section VII requests information concerning the points of emission to the atmosphere.
1. Internal ID Codes of Stack or Vent -- Enter ID codes of stacks and vents as shown in
Section III.3. No stack or vent should be listed more than one time.
2. Inside Configuration at Top of Stack
a) Shape: Give the shape of the cross-sectional flow path of the gas at the exit of the stack
or vent (round, square, rectangular, elliptical, irregular, etc.).
b) Cross-Section Area: Enter in square feet the cross-sectional flow area at the exit point of
the stack or vent.
3. Height of Top Above Grade - Enter the height of the stack/vent opening as measured in feet in
relation to ground level.
Note: Hems 4, 5, 6 and 7 should reflect conditions at the exit point from each stack or vent.
4. Exit Gas Temperature ~ Specify the temperature of the exhaust gases in °F.
5. Exit Gas Flow Rate - Provide the volumetric flow rate of the exhaust gases at the exit gas
temperature given in VII.4.
a) Normal: Enter the normal gas flow rate in actual cubic feet per minute (acfm).
b) Maximum: Enter the maximum gas flow rate in acfm.
6. Normal Exit Gas Velocity Enter the exhaust gas velocity in feet/second. This can be
calculated as follows:
Normal Exit Gas Flow Rate in acfm (Item 5a)
Cross-Sectional Area of Stack Mouth in ft (Item 2b) x 60
= Normal Exit Gas Velocity in ft/sec.
EPA Form 3520-*A (9-78)
A-16
-------
SECTION VII. STACK AND VENT DATA (Cont'd)
7. Exit Gas Components Lntcr information concerning the exhaust gas as listed:
a) Heat Content: Enter the heat content of the exhaust gas in BTU per standard cubic feet
(14,7 psia and 68°E).
b) %CO2 Content- hnter the percent of carbon dioxide in the exhaust gas by volume.
c) % Oxygen Content' l-nter the percent of oxygen in the exhaust gas by volume.
d) % Moisture Content: Enter the percent of water vapor in the exhaust gas by volume.
8. Number of Sampling i'orts Specify the number of sampling ports in the stack or vent.
SECTION VIII. STORAGE fANK DATA
This section identifies storage facilities for pet/oleum based products and describes their
characteristics, associated control equipment, the product being stored and the resulting emissions.
1. Internal ID Code for Storage Tank Unit List the internal ID code tor all storage facilities used
to hold organic liquid products such as fuels and solvents.
2. Operational Dates
a) Construction Began: Indicate the month, day and year that a contract was signed to
undertake and complete a continuous program of construction or modification to the
storage tank unit; or the month, day and year that work actually began if no contract was
signed.
b) In-Servicc. List the month, day and year that the storage tank unit began operations.
3. Tank Measurements
a) Capacity: Specify the capacity of the tank in units of thousands of barrels (10 bbls).
Enter 100 for a tank with a capacity of 100,000 bauels.
b) Throughput: Indicate the annual throughput of the tank in thousands of barrels per year
(10 bbls/yi) foi the specified year. Enter 2,000 for a tank with a throughput of
2,000,000 barrels pei year.
c) Diameter. Provide the diameter of the tank in feet.
d) Height. Enter the height of the tank in feet.
e) Vapor Space Height. Indicate the vapor space height in feet. The vapor space height is
that distance between the normal 01 average level of the liquid product being stored and
EPA Form 3520-4A (9-78)
A-17
-------
SECTION VI11. STORAGE TANK DATA (Cont'd)
the fixed roof of the tank. An adjustment is required for cone-shaped roofs. First,
calculate the distance between the normal or average level of the liquid and the base of
the cone. Second, determine the height of the cone section alone and divide this amount
by three. Finally, add these two values together to yield the vapor space height.
4. Control Equipment - Provide the information requested pertaining to the control equipment
connected to the indicated storage tank unit.
a) Internal ID Number: Supply the internal ID code numbers for the control equipment
units connected to this storage tank.
b) Brand Name and Model Number: Enter the brand name and model number of all control
equipment units.
c) Type: Specify the type of control equipment used by entering the number associated
with each item as follows:
1- Absoiption
2— Refrigeration
3 - Variable Vapor Space
4 Fixed With (ias Blanket
5- Incineration
6- Other (Specily)
d) Percent Control Efficiency: Enter the efficiency of total hydrocarbon collection in
percent by weight.
Design Supply the design efficiency of the unit.
Actual Indicate the actual efficiency attained during the Calendar Year of Record.
e) Vent Identify whether the control equipment unit is vented to the atmosphere or an
incinerator as follows:
ATM atmosphere
INC muneratoi
5. Tank Ouiractcristics Several charactciistic* lor each storage tank unit liave been requested on
the form. For churactciistics a, b, c, d, o, I and i. several alternatives have been provided. Please
fill in the appropriate spaces on the form with the characters or numbers representing the most
representative choice available. If unothei i espouse is more desirable, enter it or an abbreviation
in the space pmvidi'd When the lattei is used, define the abbieviation in the space at the
bottom of the page.
a) Location
ABV above ground
UND undergound
EPA Form 3520-4 A (9-78)
A-18
-------
SECTION VIII. STORAGE TANK DATA (Cont'd)
b) Fill Method:
SUB - submerged
SPL splash
BLD bottom loading
c) Roof Type:
1 - fixed
2- floating pan
3 floating pontoon
4 floating double deck
5 variable vapor space
6 pressurized
d) Seal Type:
S single
D double
e) Seal Condition:
T tight
L loose
f) Shell Construction:
RIV riveted
WELD welded
GUN gunite
EPOX epoxy coated rivets
g) Roof Color: Supply the color of the tank roof.
h) Shell Color: I-urnish the color of the tank excluding the roof area.
i) Paint Condition:
G good
P - poor
6. Product Stored - Identify the common name of the product stored in the tank. If unknown, use
the chemical name.
EPA Form 3520-4A (9-78)
A-19
-------
SECTION VIII. STORAGE TANK DATA (Cont'd)
7. Product Characteristics -
a) Density: Supply the density of the product vapors when converted from liquid to vapors
in pounds per gallon (Ibs/gal).
b) Vapor Molecular Weight: Provide the molecvilar weight of the product vapors in pounds
per mole (Ibs/mole).
c) Reid Vapor Pressure (RVP): Enter the RVP or true vapor pressure of the stored material
in psia at 100°F. If not readily available, enter the vapor pressure in psia and specify the
corresponding temperature (e.g., 3.5 fe1 70°F). This item is not to be used in relation to
storage of solid materials.
d) Storage Temperature: Indicate the temperature at which the product is stored.
Normal normal or average storage tempciatuie of the produ< t
Maximum - maximum storage temperature of the product
8. Tank Emissions (if known)
a) Amount: Provide the estimated tank emissions in Ibs/hour from the storage tank unit.
Normal - Indicate the normal or average hourly emissions.
Maximum List the maximum emission rate observed dunng the Calendai Year of
Record in Ibs/hour.
b) Estimation Method. Denote the method used to determine the emissions by entering one
of the following choices or the associated number in the appropriate space.
1 - Source Test
2— Material Balance
3-- EPA Emission Factor
4 Other Emission Factor (Specify)
5-- Other (Specify)
SECTION IX. SOLVENT USAGE INFORMATION
If solvents, or substances that contain solvents, arc used as feed nutenals by a process/operating
unit, then this page of the form must be completed to identify theii use.
This section of the form has been designed in two semi-independent parts. The first part
requests information pertaining to tho solvent composition ot feed materials, while the second part
asks the usei to indicate the amount of solvent recovered and disposed. Each part can be completed
independently.
1. Feed Material List all Iced material* that cithci contain solvent or are solvent.
EPA Form 3520-4 A (9-78)
A-20
-------
SECTION IX. SOLVENT USAGE 1NEORMATION (Cont'd)
2. Heat Used -- Indicate by eitlier "Yes" or "No" whether or not this feed material comes into
contact with a flame, or is baked, heat cured or heat polymerized.
3. Common Name of Solvent List the common name of all solvents in the feed material
identified above in I.
4. Oiemical Composition oj Solvent Loi each solvent listed, provide the chemical composition.
5. Solvent as Percent of Feed Material
a) By Volume: Specify, by volume, the listed solvent as a percentage of the indicated feed
material.
b) By Weight: Specify, by weight, the listed solvent as a percentage of the indicated feed
material.
1. Feed Material Repeat the feed materials mentioned in the left most column on this page. The
same feed material need not be included on the same line.
6. Internal ID Code of Process/Operating Unit Using Listed Feed Material as Input - List the
internal ID codes of all piocess/operating units using the indicated feed material as input. If
there are many process/operating units using a particular feed material, list the ID code of each
unit.
Note: For /tons 7, 8, and 9, if mo/e than one recovery or disposal method applies, feel free to
use more than one line.
7. Solvent Recovered
a) Amount: Provide the average amount of total solvent recovered. Recovered solvent
includes that amount that is recycled.
• By volume in gallons per day (gal/day)
• By weight in pounds per day (Ibs/day)
b) Method. Indicate the method used to recover the solvent. Enter either the number or an
abbreviated term trout the following alternatives.
1 - Absorption
2 Adsorpotion
3 Condensation
4 - Distillation
5- Recycling (amount of solvent automatically returned to the system)
6 Other (Specify)
8. Disposal of Solvent
a) Amount: Provide (he average amount of total recovered solvent disposed of in gallons per
day (gal/day).
EPAForm 3520-4 A (9-78)
A-21
-------
SECTION IX. SOLVLNT USAGE INFORMATION (Cont'd)
b) Method: Denote the method used to dispose of the solvent, Enter either the number or
an abbreviated term from the following alternatives:
1 - On Site Dumping
2-- Evaporation
3— Incineration
4 Off Site Removal
5- Container Storage
6-- Discharge into a Sanitary System
7 Other (Specify)
9. Disposal of I'ccd Material
a) Amount: Provide the average amount of the indicated feed material containing solvent
disposed of in gallons per day (gal/day).
b) Method: Denote the method used to dispose of the solvent. Enter either the number or
an abbreviated teim from tlic following alternatives:
I ~ On Site Dumping
2- Evaporation
3- Incineration
4- Off Site Removal
5- Container Storage
6- Discharge into a Sanitary System
7- Other (Specify)
SOLVENT MANUFACTURER OR SUPPLIER
On a separate sheet of paper, list the name and address of the manufacturer or supplier of each
solvent used. This list should be submitted witli this section of the APER.
EPA Form 3520-4 A (9-78)
A-22
-------
APPENDIX B
SUPPLEMENTAL INSTRUCTIONS TO THE APER FORM
EPA Form 3520-4A (9-78)
B-l
-------
INDUSTRY GROUPINGS FOR APER SPECIFIC INSTRUCTIONS
1. CHEMICAL PRODUCTS/PROCESSES
Industrial Chemicals
Plastic Materials and Synthetics
Drugs
Soap, Clcancis, "1 oilet Goods
Paints, Varnishes and Allied Products
Gum Mid Wood Chemicals
Agricultural Chemicals (Feitih/ers, Acids)
Miscellaneous Chemicals (Explosives, Charcoal, etc.)
2. FOOD AND AGRICULTURAL PRODUCTS/PROCESSES
Dairy
Meat Handling
Fish Processing
Grain and Fermentation (Grain elevators)
Sugai
Tobacco
Agricultural and Open Burning
Roasting
Cotton Ginning
Miscellaneous
METAL INDUSTRY
Sled Production
Smelters
Non-Ferrous Metals
Aluminum
Coke
Metal reprocessing
Electroplating
4. MINERAL PRODUCTS
Glass, Fnt, Fibciglass
Clay and Refractories
Mining
Concrete, Gypsum
Asbestos, Asphalt
Misc. Non-Metals
5. LUMBER AND WOOD PRODUCTS
Sawmills, Planing Mills
Lumber Products (Plywood, Furniture)
Wood Preserving
Miscellaneous
EPA F«m 3520-4 A (9-78)
B-2
-------
6. PAPER PROCESSING
Pulp Mills, Paper Mills
Pulpboards
Paper Manufacturing
7. MISCELLANEOUS SOFT GOODS MANUFACTURING
Textile Mill
Apparel
Leathergoods
Rubber and Plastic Products
Converted Paper Products
8. PRIMARY EVAPORATIVE SOURCE
Drycleanmg, Degreasing
Petroleum Products Handling
Printing and Publishing
Painting, Surface Coating
Miscellaneous
9. HARDWARE FABRICATION/MANUFACTURING
Fabricated Metal Products
Machinery
Electrical Equipment and Supplies
Transportation Equipment
Instruments and Related Products
Ordinance and Accessories
10. PETROLEUM REFINING/NATURAL GAS PROCESSING
11. COMBUSTION SOURCES
Power Plants
Hospitals
1 2. SOLID WASTt DISPOSAL
Incinerators
Dumps
Automotive
Sewage Sludge
EPA Form 3520-4A (9-78)
B-3
-------
PETROLEUM REFINING/NATURAL CAS PROCESSING/OIL & SOLVENT RE-REFINING
(Supplemental Instructions)
These supplemental instructions provide industry related examples for certain items of the Air
Pollutant Lmissions Kepoit (APLR). Although not intended to be all inclusive of the industry
covered, the examples arc directed towards industries related to yours and should be helpful in the
completion of the APFR.
TYPICAL DESCRIPTIONS OF MAJOR ACTIVITIES (Section II, Item 1)
• crud',1 oil distillation (atmospheric & vacuum)
• deasphaJting
• alkyldlion
• isomcrization
• thermal cracking
• coking processes (delayed & fluid)
• catalytic cracking (fluid bed & moving bed)
• asphalt production
• sulfur recovery
• sulfunc acid manufacture
• acid gas treating (MI.A and DL'A absorbents)
• hydrotreatmg (hydrodesulfun/ation)
• reforming
• hydrocracking
• hydrogen pioduction
• sweetening (merox)
• light ends recovery (LPG)
• waste water treating
• clay filtering
• blowdown recovery
• storage tank farms
• marketing activities
• cooling towers
• steam generation
TYPICAL DESCRIPTIONS OF PROCESS/OPERATING UNITS (Section IV, Part 1, Item 2)
• reactor vessels (distillation columns)
• regenerator vessels (catalyst & clay regeneration, TCC kilns)
• surge hoppers (use tor TCC's)
• process heaters (include CO boilers)
• incinerators.
• pumps
• compressors
• flares (only associated with "blowdown recovery")
• loading equipment (only associated with "marketing activities")
• process diams(only associated with "waste water treating")
• oil-water separators (only associated with "waste water treating")
• sour water strippers (only associated with "waste water treating")
* sludge disposal equipment (only associated with "waste water treating")
• vacuum jets
• hydrocarbon storage tajiks (only associated with "storage tank farms")
• cmulsiflers (only associated with "asphalt production")
• oxidizers (only associated with "asphalt production")
• solid matenal storage (use for coke piles, catalyst & clay storage)
• solid material conveycis
EPA Form 3520-4A (9.78)
B-4
-------
SPECIAL NOTLS
• "Crude Oil Distillation" (Major Activity)
I) Section II, Item 4 In Majoi Activity Products, do not include atmospherically
distilled (radio/is which arc fed (o vacuum distillation columns.
2) Section IV List each distillation column as a process/operating unit. All feed mate-
rials and products should be listed for each column in Part 2.
• "Fluid Catalytic Cracking" (Major Activity)
1) Section IV, Part 1 List reactor and regenerator vessels as separate process/operat-
ing units.
2) Section IV, Part 2 Feed material for the reactor should reflect fresh oil feed while
teed material lor the regenerator should be rccirculated catalyst.
3) Section VI Cyclones which are contained within the regenerator vessel should be
listed as "internal" or "process" cyclones. Lxternal control devices should be listed
separately.
• "Marketing Activities" (Major Activity)
I ) Section IV For each loading apparatus, show the Reid Vapor Pressure of the
loaded maten.il in Pait I, Item 5C.
2) Section VI F'oi each loading apparatus, show the loading technique (submerged
(ill, hotiom loading, splash loading) 'Type ol Air Cleaning Equipment", Item 2b.
• "Sul/Uf Recovery" (Ma|oi Activity)
1) Section II, Item 4 The maior activity product (or this category should be the total
product sullm doiii the Claus and tail gas clean up units.
2) Section III Tail gas clean up systems should be treated as air cleaning equipment
lor the purposes of this lonn, and their relationslup 'o the Claus process equipment
should be shown m tlm section.
3) Suction IV, Parl 1 Ail piocess/opeiatmg units in the sulfur recovery system should
be listed, starting with the acid gas burner and including the Claus catalytic reac-
tors, numerators, and any associated process combustion units.
4) Section V I mission data need only be provided for the final emission point of the
.system (i.e., the tail gas incinerator or the tail gas clean up unit vent) and associated
process healers
5) Section VI Data related to a tail gas clean up system should be shown in this
.sei (ion.
EPA Form 3520-4A (9-78)
B-5
-------
"Pumps and Compressors" 'Process/Operating Unit;:)
I) Section IV For each pump and compressor, show the Reid Vapor Pressure of the
material handled in Part 1, Item 7e.
2) Section VI For each pump or compressor, show the type of seal used under "Type
of Air Cleaning Equipment," Item 2a.
"Oil-Waier Separators" (Process/Operating Unas)
]) Section IV- For each oil-water separator, show the Reid Vapor Pressure of the
waste water stream in Part 1, Item 7e.
2) Section VI For each oil-water separator, show the type o! cover used under "Type
of Air Cleaning Equipment," Item 2a.
"Flaies" (Process/Operating Units)
I) Section IV For emergency flares, show waste gas feed rates in Item 7. (No data
need be shown foi outpuls in Item 8.) Also, include pilot flame fuels in Items 10
and 11 of Section IV. For continuously operated Hares, show the waste gas feed
rates in Items 10 and 11. The total sulfur content of the feed to the flare should be
shown in Item lOc for both emergency and continuous flares.
EPA Form 3520-4A (9-78)
B-6
-------
CHEMICAL PRODUCTS/PROCESSES
(Supplemental Instructions)
These supplemental instructions provide industry related examples for certain items of the Air
Pollutant Emissions Report (APER). Although not intended to be all inclusive of the industry
covered, the examples are directed towards industries related to yours arid should be -helpful in the
completion of the APER.
DESCRIPTION OF MAJOR ACTIVITIES (Section II, Hem 1)
alkylation • hydrolysis
animation • hydrogenation
cracking • dehydrogenation
dehydration • nitration
esterification • oxidation
halogenation • polymerization
DESCRIPTION OF PROCESS/OPERATING UNIT (Section IV, Item 2)
Examples of inputs are:
• conveyor, hopper etc. (raw feed handling)
• weigher, mixer, grinder, dryer (physical processes)
• open kettle, tank, pot (open reaction vessels)
• conveners, regenerators, partial oxidi/.ers (reactors)
• incinerator, pyrolizri, cooker, kiln, cooler
• separator (specify)
• electrolytic cells
• packager, specify other product handlers
• storage tanks, bins, piles
FEED MATERIALS (Section IV, Item 7)
Feed materials can include:
• hydrogen, chlorine, carbon dioxide
• sulfuric, nitric, fatty acids
• wood waste, hydrocaibom, coke
• phenol, formaldehyde, vinyl chloride, styrene
• brine, ores
• miscclJaiu'ou:) chemicab (specify)
• fin-Is (specify) which arc .SOUKTS ol products
PRODUCTS (Section (V, Item 8)
Product examples include
• end product chemicals (specify)
• polymers, resins, synthetics (specify)
• paints, varnish, ink, pigment, dye
• drugs, soaps, detergents
• acids, feitili/crs, pesticides (specify)
UNITS
Enter units normally used for the feed or products and specify. Recommended units are pounds
and tons (2000 Ibs) for solids, 1000 gallons for liquids and 103 or I06 standard cubic feed(SCF) for
gases. Any non-standard units used (i.e. bancls) must be defined in space at bottom of page 4 in
pounds or gallons.
EPA Form 3520-4A (9-78)
B-7
-------
MISCELLANEOUS EVAPORATIVE SOURCES
(Supplemental Instructions)
These supplemental instructions provide industry related examples for certain items of the Air
Pollutant Emissions Report (APER). Although not intended to be all inclusive of the industry
covered, the examples are directed towards industries related to yours and should be helpfiil in the
completion of the APER.
For operations involving organic liquid storage or solvent usage, Sections VIII and IX of the
APER should also be completed.
DESCRIPTION OF PROCESS/OPERATING UNIT (Section IV, Item 2)
Entries may include:
solvent dip, rinse, dry (may be separate or combined)
blender, mixer
dcgreascr, cleaner, passivator
spray bath, flowcoatcr, dip tank, electroplater (surface coat)
baking, curing, drying units
liquid handling, transfer
masking area
waste disposal
FEED MATERIALS (Section IV, Item 7)
a. Typical feed materials include:
peiehloretliylene, toluene, acetone etc. (solvents/thmners)
dyes, pigments, resins
paint, varnish, rubber, metal salts etc. (surface coatings)
acids, bases (specify etchants)
chemical composition of solutions used
b. Rates
Specify actual quantity expended for milling, etching, cleaning solutions.
PRODUCTS (Section IV, Item 8)
a. Typical products are:
• cleaned fabrics
• milled, coated products
• paint, varnish, inks etc.
b. Rates
Output lates for large finished products need not be entered i.e., autos, large appliances,
furniture)
UNITS
Generally use tons (2000 pounds) for all inputs and outputs including solvents. For liquid
transfers use 1000 gal units.
EPA Form 3520-4 A (9-78)
B-8
-------
LUMBER AND WOOD PRODUCTS
(Supplemental Instructions)
These supplemental instructions provide industry related examples for certain items of the Air
Pollutant Emissions Report (APliR). Although not intended to be all inclusive of the industry
covered, the examples arc directed towards industries related to yours and should be helpful in the
completion of the A1TK.
DESCR1PTJON OF PROCESS/OPERATING UNIT (Section IV, Item 2)
• enter woodworking if seveial types of woodworking arc being done at one area. If specific
procedures are being carried out at specified areas enter actual units: saws, planers,
sunder, chipper, etc.
pneumatic conveyor
open storage
retort for wood treatment
veneer assembler and pi ess
dryei (veneer, lumber, etc.)
surface co.ilmg (spiay booth, lollei coatci, etc.)
mixing lank, sloiage Kink (jipecily liquid)
waste burner, waste handling
FEED MATE RIALS (Sec lion IV, Item?)
Typical teed matcruK includi
• logs, lumber, veneer
• specify type of wood (pine, walnut, etc.)
• specify preservative, lesin.s used (cieosote)
• specify surface coaling used
• adhesivcs
PRODUCTS (Section IV, Item X)
Typical ptodiuls include
• luinbei (type), plywood, veneers
• boxes, crates
• office furniture
• pules, pilings
UNITS
Units standard for the industry may be used to indicate feed and product throughputs. Please
specify units used and define m pounds or tons in space provided at bottom of page 4. Recommended
units arc pounds 01 Ions (.7000 pounds) foi inosl inputs and gallons for liquid fuels.
EPA Form 3520-4A (9-76)
B-9
-------
MISCELLANEOUS SOFT GOODS/PRODUCTS
(Supplemental Instruct ions)
Those supplemental instructions provide industry related examples for certain items of the Air
Pollutant Emissions Report (APFR). Although not intended to be all inclusive of the industry
covered, the examples are directed towards industries relaled to yours and should be helpful in the
completion of the APtR.
DESCRIPTION OF PROCESS/OPERATING UNIT (Section IV, Item 2)
Only general examples of 'process/operating units aie given for this group of non-specific prod-
uct oriented industries. Since many of the units are used differently at the different types of facilities
represented, please he specific in providing your descriptions.
• hide/skin cleaning, compounding, fiber spinning units
• preservation, bating, tanning units
• chemical treatment of various types (specify)
• heating, curing, drying units
• coaling, molding, extruding units
• dyeing, printing, finishing units
• milling, buffing units
• storing, handling of liquids and solids
• waste disposal
FEED MATERIALS (Section IV, Item 7)
Some examples of feed materials are:
• hides, skins, vinyl/plastics, pulp stock, fibers, base polymers, etc. (specify type)
• tire cuicuss, fabnc cord
• chemicals used for treatment (specify)
• solvents, resins, adhesives
• dyes, pigments, lacquers
• curing agents, antitoxidants, etc.
PRODUCT (Section IV, Item 8)
Actual products and byproducts should be included
• leather, leather goods (types)
• artificial leather, coat fabrics
• gelatin, ^lue
• apparel, ^porting goods, synthetic fibers and films
• finished paper products (cups, wallpaper, disposable fabrics, metallized paper)
• tires
• foams, coatings, sealant, insulation
• laminates, misc. hard plastic products
UNITS
Generally use tons (2000 pounds) processed or tons product. For solvent throughputs 1000
gallons unit is recommended. Units common to the industry may be used. If these units are not in
pounds, tons, gallons or cubic feet, please enter conversions to these basic units at bottom of page 4.
EPA Form 3520-4 A (9-78)
B-10
-------
POWER PLANTS
(Supplemental Instructions)
These supplemental instructions provide industry related examples for certain items of the Air
Pollutant Emissions Report (APER). Although not intended to be all inclusive of the industry
covered, the examples are directed towards industries related to yours and should be helpful in the
completion of the APER.
DESCRIPTION OF PROCESS/OPERATING UNIT (Section IV, Item 2)
Examples of entries include:
gas turbine, engine (specify type)
tangential fired water tube boiler, etc.
nuclear reactor (type)
storage tank, storage devices lor solids
coal handling (specify)
other sources of pollutant generation
fly ash, waste hadnling and disposal (specify)
SECTION IV, PART 3
1. PROCESS/OPERATING UNIT - Knter (hose combustion units which are used for the
generation of powei. All non-combustion units should be enteied.
7. INPUTS - (For power generating equipment only) Hnter fuel in item 7a. Use one line
for each fuel burned and omit 7b and 7c since these items will be covered in Part 3 for
fuels.
8. OUTPUTS (For power generating equipment only) - [inter powei as product and
output rate in megawatts or kilowatts. Specify units.
UNITS
For Feed and Products other than power, define all special units used (barrels, etc.) in pounds,
tons (2000 pounds), gallons or cubic feet and give conversions at bottom of page 4.
EPA Form 3520-4 A (9-78)
B-H
-------
SOLID WASTE DISPOSAL/RECLAMATION
(Supplemental Instructions)
These supplemental instructions provide industry related examples for certain items of the Air
Pollutant Emissions Report (APER). Although not intended to be ah1 inclusive of the industry
covered, the examples are directed towards industries related to yours and should be helpful in the
completion of the APER.
DESCRIPTION OF PROCESS/OPERATING UNIT (Section IV, Item 2)
Enter a brief and specific description of the incineration/combustion unit used for solid waste
disposal. Also include waste handling methods which may potentially give rise to emissions.
multiple chambci incinerator, single chamber incinerator
pathological, trench, sludge, conical incinerator
wood w;iste boiler (specify with or without flyash reinjection)
reclamation incinerator (specify type)
open burning (wood, refuse)
municip;il incinerator
SEASONAL THROUGHPUT(%)(Section IV, Item 6)
Enter in percent, for each season, the annual throughput of waste processed by the specified
disposal/reclamation method.
FEED MATERIALS (Section IV, Item 7a)
Do not enter waste used strictly as fuel for process or space heating. Inputs will be requested in
Section IV, Part 3 Fuel Usage.
Enter description, and mix of waste handled:
industrial waste (specify)
refuse, garbage, rubbish, trash
auto parts, electrical equipment, wires
pathological samples, animals
sewage, sludge
PRODUCTS (Section IV, Item 8)
Products of wasle handling can include:
• unburncd salvage (drums, metals, wires)
• soil conditioners
• it no useful product specify none
UNITS
Specify units where indicated. For most waste and waste products use pounds or tons (2000
pounds).
FUEL USAGE INFORMATION (Section IV, Part 3)
If a waste material is used strictly as fuel (i.e. wood chips), complete this section for the waste
material and process/operating unit. Also, complete for auxiliary fuels.
EPA Form 3520-4A (9-78)
B-12
-------
MINERAL PRODUCTS
(Supplemental Instructions)
These supplemental instructions provide industry related examples for certain items of the Air
Pollutant Emissions Report (APliR). Although not intended to be all inclusive of the industry
covered, the examples are directed towards industiies related to yours and should be helpful in the
completion of the APER.
DESCRIPTION OF PROCESS/OPERATING UNIT (Section IV, Item 2)
Examples include:
surface mine, quariy, excavator (collection)
conveyor, hopper (handling)
crusher, grinder, blonder, si/c (physical process)
dryer, s/nclter, caJcincr, mdier, kiln, oven
furnaces (revejberatory, induction, rotary)
blow chamber, cooler
storage tanks, bins, piles, silo
sprayer, saturation tanks
packager, pcllctizer, fiber former
FEED MATERIALS (Section IV, Item 7)
Feed materials examples arc:
stone, gravel, clay
coal, coke, lignite, shale
alumina, magnesia, silica, /Jrcoma
lime, basic mixed oies, minerals
borosilicutc, cement, gypsum
matenals in storage
PRODUCTS (Section IV, Item 8)
Products may include:
• asphalt, aspliall roofing
• calcium carbide, cement, ceramics, clay
* gbss, fiberglass, mineral wool, frit
• gypsum, lime, perlite, brick
• cleaned coal
• magnesium carbonate, calcium borate, etc.
UNITS
Units common to the industry may be used to indicated feed and product throughputs (i.e.
cubic yard of connate, barrels of cement). Please specify units used and define in space at bottom of
page 4 (i.e. cement luirel = 376 Ib).
Use pounds or tons (2000 pounds) whenever possible. Also, gallons for liquids and 1000 cubic
feet for gases can be used.
EPA Form 3520-4 A (9-78)
B-13
-------
METALLURGICAL INDUSTRY
(Supplemental Instructions)
These supplemental instructions provide industry related examples for certain items of the Air
Pollutant Emissions Report (APER). Although not intended to be all inclusive of the industry
covered, the examples are directed towards industries related to yours and should be helpful in the
completion of the APER.
DESCRIPTION OF PROCESS/OPERATING UNIT (Section IV, Item 2)
Examples include:
A. Non ferrous
• Copper
- Roaster (multi-hearth, fluid bed)
- Rcverberatory furnace
Converter
- Refinery furnace
• Lead
-iSinter plant (updraft, downdraft)
- Blast furnace
- Dross kettles
- Refinery kettles
- Retorts
-Kilns
• Zinc
—iRoaster plant
- Sinter plant
- Retorts
• Aluminum
— Baking furnace
— Reduction cell (horizontal sodeberg/vertical sodeberg)
- Sweating furnaces
— Crucible
- Reverberatory furnaces
B. Ferrous
Sinter plant
Coke oven (type)
Blast furnaces
Open hearth furnaces
Electric arc furnaces
Basic oxygen furnaces
Scarfing
Rolling mills
Finishing and coating
Cupula
Soaking pits
EPA Form 3520-4A (9-78)
B-14
-------
C. General
• Muteiial handling
• Mixing
• Crushing
• Si/ing
• Ikdding
FEED MATE RIALS (Sec lion IV, Item 7)
Typical feed materials include
• ore, suap, salvage, piecipitates, slag
• ferroalloys, coke, pig iion, m.ilte, calcines
• minerals (specify)
• coppei, /me, (in, lead, etc.
• llu\ (specify)
• sand
• malciials in storage
PRODUCTS (Section IV, Item 8)
Typical products include'
• aluminum, magnesium, coppei, etc.
• coke
• brass, hron/e, steel
• galvani/cd, tin plate
• pig iron, cast iron, metal ingots, blister copper
• steel (sheet, plate, strip, bar, rod, tube, pipe, structural)
• other specified metal products
UNITS
Units used should be specified. Use pounds or tons (2000 Ibs) whenever possible. Additionally,
1000 gallons can be used for liquids and 10 ' or 10 standard cubic feet for gases. Other units, if used,
should be converted to pounds, tons, gallons or cubic feet. Show conversions at bottom of page.
EPA Form 3520-4 A (9-78)
B-15
-------
FOOD AND AGRICULTURAL PRODUCTS/PROCESSES
(Supplemental Instructions)
These supplemental instructions provide industry related examples for certain items of the Air
Pollutant Emissions Report (APER). Although not intended to be all inclusive of the industry
covered, the examples arc directed towards industries related to yours and should be helpful in the
completion of the AI'LR.
DESCRIPTION OF PROCESS/OPERATING UNIT (Section IV, Item 2)
Examples include:
open held burning (specify crop, weeds, etc.)
orchard heater
conveyors, giam elevators, hoppers, bins, piles
separator, cotton gin, crusher, grinder, mill, blender
roaster, smoker, renderer, stoncr
coolei, dryer
incineration, compost, land fill (waste disposal)
packager, loader
storage tanks, silos
FEED MATERIAL (Section IV, Item 7)
Feed material examples are:
farm grown products (specify)
cotton, grain (specify), coffee beans, sugar cane, tobacco leaves, alfalfa
fish, meat, poultry (specify)
materials in storage
waste material
PRODUCTS (Section IV, Item 8)
Typical products may be:
canned, preserved products (specify)
sugar, cotton, cereal, grain oil, coffee, Hour, starch
meal, feed, tobacco
canned fish, fish oil, type of moat
lard, tallow
beer, whiskey, wine
UNITS
Units standard to the industry may be used to indicate feed and product throughput (i.e. bale
of cotton, barrels of whiskey). Please specify units used and define in space at bottom of page 4 (i.e.
bale = 500 Ibs, barrel = 50 gal). Recommended units are pounds or tons (2000 pounds) for solids and
gallons for liquid.
EPA Form 3520-4A (9-78)
B-16
-------
WOODPULP PROCESSING
(Supplemental Instructions)
These supplemental instructions provide industry related examples loi certain items of the An
Pollutant Emissions Report (APHR). Although not intended to be all inclusive of the industry
covered, the examples are directed towards industiies lelated to yours and should be helpiul in the
completion of the APliR.
DESCRIPTION OF MAJOR ACTIVITY (Section II, Item !)
Conversion of wood to pulp (II moie than one process exists at a plant, each would be a majoi
activity. Specify pr! enlnes mcliule
• recoveiy funuce, inne kiln
• smelt dissolving tank
• cooker/digesler/lilow lank
• evapoiatoi, diver
• pulp retinei, beatei, fi:nsliei
• cutlet, sander
FEED MATERIALS (Section IV. Item 7)
Typical feed m;jlenals include
• wood chips, cotton lan^, textile waste, papei stock
• sodium sails (specify)
• slaked lime
• sulfurous acid
• resins, colois, si/in^'
• specify solvents used lot ticalinciH, lie inLing, etc.
PRODUCTS (Section IV, Hem X)
Typical products include
• pulp
• papei bo.ird, pulpbo.ud. pai liclehoaul
• pa pei
UNITS
You may enlei units nomially used m the indiisli) loi quantities ol leed and products and
define at bottom of page 4 in' pounds 01 tons. Use pounds, tons (2000 pounds) 01 gallons when
possible. Also, supply the lollowing conversion factors to convert piocess mateiials utilized at \our
facility into equivalent tons ol unbleached .111 -diy kialt pulp.
equivalent tons unbleached aii-dtv krali pulp "•
^ J I I ,,'JS COVFRNMEIITPRINTINi; OFFICE 1978- '? - ,-,
jioiinds icbuined lime
jxidiids thy solids in sj>enl hcjuor
EPA Form 3520-4A (9-78)
B-17
-------
APPENDIX C
EXAMPLE AIR POLLUTANT EMISSIONS REPORT
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APPENDIX D
GRAIN ELEVATOR QUESTIONNAIRE
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before eomph ting)
1 REPORT NO
EPA-450/4~81-026b
4. TITLF ANDSUBTITLE
Procedures for Emission Inventory Preparation
Volume II: Point Sources
7 AUTHOR(S)
Monitoring and Data Analysis Division
Office of Air Quality Planning and J>
6 PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U. S. Environmental Protection Agency
Research Triangle Park, N. C. 27711
12 SPONSORING AGENCY NAME AND ADDRESS
3 RECIPIENT'S ACCESSION NO.
5 REPORT DATE
S epjtemb er_l 9 81_
1O. PROGRAM ELEMENT NO,
11. CONTRACT/GRANT NO
13. 1 YPE OF- REPORT AND PERIOD COVERED
14. SPONSORING AGtNCY CODE
15 SUPPLEMENTARY NOTES
EPA Project Officer: A. A. MacQueen
16 ABSTRACT
Procedures are described for compiling the complete comprehensive emission
inventory of the criteria pollutants and pollutant sources. These procedures
described are for use in the air quality management programs of state and local
air pollution control agencies.
Basic emission inventory elements—planning, data collection, emission esti-
mates, inventory file formatting, reporting and maintenance—are described.
Prescribed methods are presented; optional methods are provided. The procedures
are presented in five (5) volumes:
Volume I, Emission Inventory Fundamentals
Volume II, Point Sources
Volume III, Area Sources
Volume IV, Mobile Sources
Volume V, Bibliography
DESCRIPl ORS
KEY WORDS AND DOCUMENT ANALYSIS
b IDENTIFIERS/OPEN ENDfcD TERMS
Emission Inventory
Inventory
Source Inventory
Emissions Source
Emissions Files Formatting
Questionnaire
Air Quality Management
Point Sources
c. COSATl I'icld/Group
18 DISTR'BUTION STATEMENT
19 Sf CURU Y CLASS {/'/in Kepvrt)
20 SECURITY CLASS (fins'pa^e]
21 NO OF PAGES
J.39
22 PRfCE
EPA Form 2220 — 1 (Rev, 4—77) PREVIOUS EDITION is OBSOLETL
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