United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/4-8B-004
March 1868
Air
<>EPA
QUALITY ASSURANCE PROGRAM
FOR POST-1987
OZONE AND CARBON MONOXIDE
STATE IMPLEMENTATION PLAN
EMISSION INVENTORIES
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EPA-450/4-89-004
QUALITY ASSURANCE PROGRAM
FOR POST-1987
OZONE AND CARBON MONOXIDE
STATE IMPLEMENTATION PLAN
EMISSION INVENTORIES
PREPARED BY
PETER R. WESTLIN
U. S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF AIR AND RADIATION
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
RESEARCH TRIANGLE PARK, NC 27711
MARCH 1989
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This report has been reviewed by the Office Of Air Quality Planning And Standards, U. S. Environmental
Protection Agency, and has been approved for publication. Any mention of trade names or commercial
products is not intended to constitute endorsement or recommendation for use.
EPA^50/4-89-004
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TABLE OF CONTENTS
Section page
I. Project Background
A. Background and Purpose 2
B. QA/QC Basics 3
C. General Responsibilities 4
II. Emission Inventory QA/QC Program Overview
A. Program Purposes 7
B. Program Objectives 7
C. Program Organization 10
III. Description of Tasks
A. Identification of QA/QC Elements 10
B. Developing Check Lists 11
C. Developing QA/QC Screening Mechanisms 12
D. Developing Audit Procedures 14
IV. QA/QC Report
A. Periodic Report 17
B. Reporting Responsibilities 17
V. References 19
Appendix A - Draft Check List For Reviewing
Post-1987 Ozone SIP Emission
Inventory Activities
Appendix B - Draft List Of Point Source Categories
For Inclusion In Post-1987 Ozone SIP
Emission Inventories
Appendix C - Transferring Inventory Data to EPA Data Base
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I. Project Background
A. Background and Purpose
On June 6, 1988, EPA proposed to designate as nonattaimnent
under the Clean Air Act those areas throughout the nation that
had not attained the National Ambient Air Quality Standards
(NAAQS) for ozone (O3) or carbon monoxide (CO). Letters from EPA
Regional Administrators to State Governors giving notice of SIP
calls were issued during May and June, 1988. In these letters,
EPA asked States to proceed with the following activities in
preparation for developing the State Implementation Plans (SIPs):
1) correct any outstanding deviations, deficiencies, or
inconsistencies in existing State volatile organic carbon (VOC)
regulations; and 2) prepare base year emission inventories for
precursors of O3 and CO. The base year (either 1987 or 1988)
emission inventories are due for submittal to EPA for review in
the fall of 1989.
These inventories will be important as a baseline for
strategy planning, demonstration of adequate attainment strategy,
inspection and enforcement activity, and tracking of emission
reduction progress. The proposed post-1987 03 and CO
nonattainment policy incorporates the following initiatives to
ensure the accuracy and completeness of these inventories:
geographic extension of nonattainment areas, reducing the point
source emission cut off limit, adding new area source categories,
accounting for vehicle running losses, and estimating the actual
effectiveness of regulatory programs. In addition, the post-1987
inventories will be based on actual emissions rather than
allowable emissions as have been used in the past. EPA
envisions that the quality of these base year emission
inventories will be consistent high in terms of emissions
estimates, complete documentation, and complete source coverage.
The purpose of this document is to outline the program for
implementing the quality assurance and quality control (QA/QC)
requirements and the QA/QC tools for the States and local
agencies and EPA to apply in preparing and reviewing these O3/CO
SIP emission inventories to ensure that the inventories meet
minimum QA/QC requirements. This document describes
responsibilities for efforts necessary to ensure minimum
acceptable levels of data quality applying the information,
documentation, and resources available at this time or expected
to be available in time for use in developing and reviewing these
emission inventories.
The objectives of the quality assurance program are:
1. Identify the QA/QC elements that may be applied to the
emission inventory development and develop check lists
for review.
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2. Develop and distribute manual and computer-aided tools
for implementing the QA/QC elements.
3. Develop procedures for selecting auditing sites and for
conducting emission inventory preparation audits.
4. Assess the quality of the submitted inventories.
These objectives are discussed in detail with specific tasks and
responsibilities in Section II. B. of this document.
B. QA/QC Basics
A number of terms associated with the preparation and review
of the emission inventories are listed below with definitions
explaining the applicability to this program:
Quality assurance - External activities by a second
party to evaluate data quality. These emission inventories
will be prepared primarily by the applicable State and local
agencies. EPA through the Regional Offices and OAQPS/OMS
will provide the bulk of the QA activity consisting of on-
site audits and verification of reasonableness and
completeness through the emission inventory review.
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Quality control - Internal activities by the performing
organization to ensure data quality. The State and local
agencies will incorporate QC activities into the data
collection, assimilation, calculation, and reporting for the
emission inventories. EPA has provided guidance on the
types of QC checks and reviews that should be included in
the emission inventory development programs.
QA/QC Plan - A written document detailing the specific
QA/QC activities associated with the preparation of the
emission inventory. These activities include designating a
QA officer and organization, inventory review steps,
corrective action, and documentation activities.
Audits - A targeted and in-depth review of a subset of
emission inventory development. The purpose of the audit is
to evaluate the effectiveness of the QA/QC program and the
quality of the inventory during preparation or after
submittal of the base year inventory.
The elements of EPA's QA/QC program for emission inventory
review and verification can be identified as follows:
Check lists for emission inventory review in published
guidance documents - The purpose of these check lists is to
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ensure a level of national consistency in the inventories.
For example, the guidance document, Emission Inventory
Requirements for Post-1987 Ozone State Implementation Plans.
includes check lists of data collection and documentation
activities required for the part of the inventory covering
stationary point and area sources. Appendix A contains a
copy of the activities check list from the "Requirements"
document. The emphasis of the check list reviews will be
primarily summary and the checks will be applied manually.
Computer-aided emission inventory review - The purpose
of computer-aided review procedures is to provide a
mechanism for flagging suspicious inventory data at the time
of data collection and at each stage of the review process.
For example, OAQPS has developed a PC-based data handling
system that incorporates the O3/CO SIP emission inventory
requirements in a manner that allows the State/local
agencies, Regional Offices, and EPA headquarters reviewers
to ensure the presence of required data elements.
QA/QC audits - The audits performed by EPA at the
inventory preparation sites will be limited in number and
will generally be targeted at high priority elements of the
inventory. For example, the audit may focus on a
determination of activity levels, selection of emission
factors, and a review of the questionnaires. Auditors will
include representatives from Regional Office, EPA
headquarters (OAQPS/OMS), and contractors, where
appropriate.
C. General Responsibilities
State and local agencies - The State and local agencies are
responsible for preparing the emission inventories. In this
capacity, the State and local agencies must maintain awareness of
the EPA QA/QC requirements and the specific elements that will be
reviewed in the emission inventory submittals. The EPA guidance
specifies that each agency responsible for preparing an emission
inventory shall prepare a QA/QC plan. The document, Guidance for
the Preparation of Quality Assurance Plans for O,/CO SIP Emission
Inventories, provides detailed descriptions of the elements of an
adequate and appropriate QA plan.
The guidance provided by EPA to the State and local agencies
recommends that the QA/QC plan designate one person in the agency
to be responsible for ensuring the implementation of the QA/QC
plan during the inventory preparation. This QA/QC person should
be independent of the inventory preparation program; that is, the
QA/QC person should not be directly involved on the data
collection, calculation, and documentation activities. The
designated QA/QC person need not be assigned full time to the
emission inventory effort. For example, a person from the solid
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waste management group in the State or local agency may serve to
oversee implementation of the QA/QC plan by reviewing activities
reports, the check list completions, and the format of the
submittal.
The State or local agency should be aware of the resources
necessary to implement the QA/QC procedures in preparing the
inventories. Many of the data collection, calculation, and
documentation activities associated with inventory preparation
involve QA/QC procedures as a normal part of completing the
tasks. These activities include completion of standardized data
forms, use of computer-aided data reduction procedures,
identification of the data collector or reporter, and
documentation of data sources and procedures. Such activities
should be described in the QA/QC plan but may not affect the
resource allocations for the inventory directly as QA/QC
activities.
More typical QA/QC activities that will dictate allocation
of specific resources include preparation of check lists for
ensuring complete source coverage, checking data input accuracy,
and verifying that minimum reporting requirements are met. Also
included among QA/QC activities will be completion of these check
lists and corrective action when deficiencies are identified.
EPA recommends that 10 to 20 percent of the total resources for
emission inventory be allotted to QA/QC activities separate from
standard data collection and reduction procedures.
Regional Offices - The EPA Regional Offices have primary
responsibility for contact with the State and local agencies
during the preparation and review of the emission inventories.
The Regional Offices should identify a QA/QC contact for the
emission inventory activities and the QA/QC contact shall
interact with the State and local agencies in resolving QA/QC
questions and issues. The QA/QC contacts may have additional
responsibilities in the emission inventory preparation and review
area. The QA/QC contacts shall provide EPA OAQPS with periodic
reports of QA/QC activities, problems, and solutions during the
inventory preparation period.
The Regional Offices will be responsible for reviewing the
submitted inventories, comparing the inventories with the
requirements, and resolving the errors that are found. The
Regional Offices shall apply the inventory check lists for
inventory completeness and accuracy provided by OAQPS. The
inventories submitted to OAQPS should be thoroughly checked by
both the State or local agency preparing the inventories and the
applicable Regional Office.
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OAOPS - The EPA headquarters office, OAQPS, is responsible
for defining the SIP policy and associated schedules. The
proposed post-1987 policy and the 1988 SIP calls serve to fulfill
this responsibility until the final policy is promulgated.
OAQPS is also responsible for defining the current emission
inventory requirements and providing details explaining the
policy to the Regional Offices and the State and local agencies.
OAQPS has or will issue several documents describing the post-
1987 emission inventory requirements including:
Emission Inventory Requirements for Post-1987 Ozone State
Implementation Plans (September 1988)
Emission Inventory Requirements for Post-1987 Carbon
Monoxide State Implementation Plans (EPA-450/4-88-020,
December 1988)
Rule Effectiveness Policy Guideline (to be issued in April
1989)
OAQPS is responsible for providing guidance materials on the
procedures that should be applied in preparing the inventories.
These documents incorporate many data checks and data
requirements that form the bases for the QA/QC procedures to be
used in reviewing the emission inventory submittals. Some of the
documents that OAQPS has prepared and distributed to the State
and local agencies include:
Procedures for the Preparation of Emission Inventories for
Precursors of Ozone (EPA-450/4-88-021, December 1988)
Procedures for Emission Inventory Preparation. Volume IV:
Mobile Sources (EPA-450/4-81-026d(revised), December 1988.
Updated Chapter 4 on Highway Sources is being distributed in
April 1989)
One of the tools developed by EPA for use by the State and
local agencies and the Regional Offices in preparing and
reviewing the emission inventories is a personal computer based
data handling program. The SIP Air Emission Inventory Management
(SAM) System provides a useful tool for emission inventory data
storage, calculation, and reporting. SAM provides easy-to-use
mechanisms for identifying and applying emission factors and
source identification codes. EPA strongly encourages the use of
SAM in preparing and checking the emission inventories.
OAQPS is responsible for establishing QA/QC requirements for
the emission inventories and for preparing an overall QA/QC plan
for reviewing the inventory submittals. The purpose of this
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document is to provide these details. Some of the specific OAQPS
activities addressed in the QA Project Plan include establishing
minimum QA/QC requirements, developing procedures for reviewing
emission inventories following Regional Office review, and
interpreting regulations.
II. Emission Inventory QA/QC Program Overview
A. Program Purposes
The purposes of the national program are reduction of errors
and maximization of consistency in the emission inventories on a
national basis. Both of these purposes serve to further the
correct application of the control strategies for reducing
emissions leading to reduction of ambient 03 and CO
concentrations. Analyses of base year inventories, applications
of dispersion models, and development of emission projections
depend on accurate and complete inventories. While EPA desires a
high level of national data consistency, the Agency recognizes
that absolute consistency among the emission inventories is
probably not an achievable goal given the absence of prescriptive
data collection procedures and reporting format in the guidance
and the variety of reporting systems used by the States. The
objectives described in this section are intended to define the
level of QA/QC effort needed to ensure reasonable levels of
inventory accuracy, completeness, and consistency.
B. Program Objectives
The objectives of the program are:
1. Identify the QA/QC elements that may be applied to
the emission inventory development and develop
check lists for review.
Specific objectives include OAQPS efforts to expand the data
elements check lists incorporated into the guidance already
available. This expansion would entail developing more detailed
criteria for stationary point source data, additional stationary
area source data criteria, and criteria for checking mobile
source input data.
These check list objectives represent what should be
accomplished. Limited resources in OAQPS may place constraints
on development of additional data review elements and of
completeness and reasonable range check lists. However, the
completion of the basic checklists by the State and local
agencies preparing the inventories and EPA review activities
remain minimum objectives for this program.
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A complete review of the emission inventories should include
a check of the accuracy or reasonableness of the emission
estimations. One objective of this project is the development of
reasonable ranges for emission estimations and emission factors.
OAQPS can provide the means for developing a check list
incorporating ranges of emissions expected from source categories
using population or activity factors as a basis for emission
levels. These reasonably expected emission ranges may then be
used to compare with the emission estimations reported in the
inventories. Reported values outside the expected ranges will be
flagged for additional review and correction as necessary.
A second important part of the review process is a check of
the compl-eteness of the source coverage in the inventory. Again,
OAQPS would be responsible for developing complete lists of all
the source categories that potentially could be included in the
inventory in order to compare with the reported inventory and
identify deficiencies in source coverage. The source category
completeness lists would be based on results of previous
inventories, sources identified in the published emission factor
documents (e.g., AP-42), and published industrial documents. The
source category completeness list developed by OAQPS will address
sources on a national basis and should be supplemented by the
State or local agency to include sources of particular local
interest. Appendix B includes a draft list of point source
categories expected to be included in the Oj/CO inventories.
2. Develop and distribute manual and computer-aided tools
for implementing the QA/QC elements.
Application of check lists incorporating the important data
elements at the point of inventory preparation, i.e., the State
and local agencies, provides the most effective means for
checking the inventories. The check lists should be applied by
the Regional Offices and OAQPS in the review process. The
objective then is to incorporate the completeness check lists and
the reasonable ranges, if available, into the SAM PC system and
distribute SAM to the State and local agencies to use in
inventory preparation.
Completion of these first two objectives represents a fully
funded effort. A limited effort could be undertaken to include
use of the currently available information for check list
development and inventory review by the Regional Offices (both
manual and with SAM).
3. Develop procedures for selecting auditing sites and for
conducting emission inventory preparation audits.
The independent audit of an emission inventory is the third
means for checking and assuring completeness and accuracy. The
effort to develop and implement an audit program will be a
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combined Regional Office and OAQPS responsibility. One objective
will be for OAQPS to develop completeness and accuracy checking
procedures that may be applied during the audit. These
procedures may be based on the check lists developed for
inventory preparation. A second objective will be to develop
procedures for reviewing the application of the QA/QC plans
developed by the State or local agency for preparing the
inventory.
OAQPS should be responsible for developing selection
criteria for conducting the audits. These criteria may be based
on capabilities and past performance of the preparing agency,
the size of the emission inventory, the application of SAM, and
other factors.
4. Assess the quality of the submitted inventories.
The checking of emission estimations and the review of the
inventories by the Regional Offices should be completed using the
check lists and SAM prepared by OAQPS. These reviews should be
performed regardless of the format of the submitted inventories.
Not all of the inventories will be submitted on SAM and manual
reviews may be required for those inventories that are not on
SAM. OAQPS should provide to the Regional Offices the check
lists in manual form for these reviews. The Regional Offices are
then responsible for resolving questions about the submitted
inventories resulting from the completeness and reasonable range
checks and preparing a report of the review results. OAQPS are
responsible for reviewing the inventories following Regional
Office review using similar check lists and review procedures.
The Regional Office are primarily responsible for conducting
the audits. OAQPS may also participate in not only the site
visit and in reviewing the audit results. The audits could be
combined with other visits to the State and local agencies and
should be considered both before and following the base year
inventory submittal. The Regional Offices will prepare reports
of the audit results to submit to OAQPS.
OAQPS will review the collection of submitted inventories
and the results of reviews and audits in order to assess the
overall quality of the inventory data. OAQPS will prepare a
report of the data quality assessment including an estimation of
the accuracy and precision of the resulting emissions data.
The completion of objectives 3 and 4 as described represents
a complete effort by EPA in developing and conducting an
inventory audit and review program. A limited effort would
include a review of the QA/QC plans as submitted for the
inventory preparation, review of submitted inventories by the
Regional Offices, resolution of discrepancies, and a limited
number of site visits by the Regional Offices.
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C. Program Organization
OAQPS will be responsible for overall project management and
preparation of the program results and recommendations. The
technical staff will be divided into two function areas. The
substantive tasks, including development and distribution of
QA/QC guidance, check lists, and SAM will be headed by the
Criteria Emission Section, MRB, TSD. Review tasks will involve
persons in the Regional Offices, QMS, AQMD, and TSD (MRB and
NADB).
III. Description of Tasks
A. Identification of QA/QC Elements
The identification of the QA/QC elements that may be applied
in emission inventory development and review has been done to a
large extent for stationary sources in the several documents
identified earlier. The "Requirements" document, for example,
includes a check list specifying the minimum data requirements
and activities that must be completed in preparing and
documenting the emission inventory. These include:
Plant information -
NEDS identification
Pollutant
Base year of inventory
Plant name, address
SIC code
Principal product
Point information -
NEDS point identification
Point description
Operating schedule
Regulation emission limit
Segment information -
SCC
Process rate, units
Control equipment
Control efficiency
Rule effectiveness
Emission estimation method
03 and/or CO season daily emissions (Ibs/day)
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Small point source summary data (option for 10-25 tons per year
(tpy) sources) -
Plant name, address
Activity level (throughput or number of employees)
Plant emissions (Ibs/day)
Area source data -
Source category
Activity level (throughput, number of employees, population)
Emission factor (e.g., tons VOC/throughput)
Source category emission (tons/day)
The minimum documentation requirements are also specified in
the "Requirements" document. The areas covered include the data
example format for detailed point sources and summary formats for
small point, area, and mobile sources. Examples of required
documentation content and format are also displayed. Other
guidance documents include some expected data range tables,
tables of accepted emission factor values, example data format
and calculation procedures, and additional example reporting
forms.
Development effort will be necessary for portions of the
emission inventories for which QA/QC data elements are not well
defined or do not exist. Such development work will require the
cooperation of persons in the areas responsible for the emission
inventory requirements and procedures. These include persons in
the Air Quality Management Division, the Technical Support
Division, and the Office of Mobile Sources.
B. Developing Check Lists
The QA/QC elements must then be incorporated into mechanisms
for checking and correcting the inventories, i.e., data screening
tools. As mentioned above, the guidance documents for stationary
source emission inventory preparation include a data collection
activity check list, a list of affected sources, and a list of
pollutants covered in the inventory. Also included are tables
describing:
- Parameters for identifying sources between 10 and 25 tpy
- Errors and error sources in the emission inventory process
- Expected ranges of percent control efficiency for various
control devices
- Growth indicators for area sources
- Summaries of control techniques guidelines for stationary
sources
Similar check lists should be developed for other portions
of the inventory, particularly for the mobile sources emissions.
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Development of reasonable emission range check lists for
point and area source categories will require collection and
analysis of emission and source activity data. Such data will be
available from emission inventories prepared for earlier SIP
calls or other inventory depositories (e.g., National Emissions
Data System). The task is not trivial considering the lack of
detail incorporated in existing inventories and the large number
of sources not covered in earlier inventories that are to be
covered in the post-1987 03 and CO SIP inventories.
Reasonable range check lists for emission and activity
factors will be more easily developed using the existing emission
factor publications and existing inventories. For example, the
existing published emission factors with percent ranges applied
may be used in flagging values in the submitted inventories
calculated with emission factors outside the expected range.
Such emission factor reasonable range check lists may be
developed for area source categories as well as for point
sources; although, the area source emission factor data are not
required in the reported inventory.
Development of these activity and reasonable range check
lists will require the cooperation of persons in the areas
responsible for the emission inventory requirements and
procedures. These include persons in the Air Quality Management
and Technical Support Divisions of OAQPS, and the Test and
Evaluation Branch of OMS. Coordination responsibility lies with
the Monitoring and Reports Branch of TSD.
C. Developing QA/QC Screening Mechanisms
Both the inventory preparer and the reviewer could make use
of data screening tools that would check inventory completeness
and reasonableness. A third objective in this program will be to
develop means for data screening using the QA/QC elements and
check lists identified in the earlier tasks. The SAM PC system
provides a ready mechanism for incorporating the QA/QC elements
into the inventory development process at the point of
preparation and would also be useful in the review process. The
SAM PC system will be modified to incorporate many of the QA/QC
checks that will be included among the QA/QC elements. One item
in this task will be to revise the SAM PC system to incorporate
the applicable QA/QC elements developed during the first phases
of this project.
In the hands of the inventory preparer, the SAM PC system
provides the means to conduct critical QA/QC data checks at the
point of origin. Checks at preparation provide the most
efficient means for correction and editing as the inventory
preparer has the most intimate knowledge of the data. The SAM PC
system built-in QA/QC checks will provide the reviewer with a
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system built-in QA/QC checks will provide the reviewer with a
speedy data checking tool allowing identification of potential
problem areas and prompting the reviewer to contact the inventory
preparing agency in order to resolve the differences.
Not all of the emission inventories will be prepared using
the SAM PC system. Another mechanism for conducting QA/QC checks
will be necessary. A second item under this task will be to
develop a manual procedure incorporating the same QA/QC elements
as applied in the SAM PC system. The manual data review
procedure incorporating the activity check list should be applied
by both the State or local agency responsible for the inventory
and the appropriate Regional Office. The limitations of the
manual review of the emission inventory are the great amount of
time and effort required to review the entire inventory and loss
of direct contact with the data and the inventory preparer.
Coordination of the screening procedures development and
distribution will be a OAQPS responsibility. Most of these
activities will be directed toward incorporating the screening
mechanisms into the SAM PC system. Development of similar
screening mechanisms for mobile sources shall be coordinated
through QMS.
Application of the check lists and the other screening tools
will be the responsibility of all parties involved. The activity
check lists are useful to State and local agency persons
preparing the inventories and will be an important QA/QC tool.
The State should incorporate the use of the check lists and the
screening tools, especially SAM, in the planning for the
inventory preparation to apply during data collection. The use
of the check lists during review of the inventories prior to
submittal to the Regional Office is also an important function of
the QA/QC program in the State or local agency.
The activities check lists are somewhat less useful as
review tools once the inventories are submitted because the
emission inventory reviewer will be faced with checking the
results of the inventory activities rather than overseeing the
completion of the activities. The reasonable emission range
check lists would be useful to both the inventory preparer and
the reviewer.
The Regional Offices are responsible for the primary EPA
review function once the inventories are submitted. The first
task is review and comment on the QA/QC plan submitted by the
State prior to inventory preparation. In some cases, this task
may include prompting the State or local agency to prepare the
QA/QC plan or assisting the preparation through direct contact
with the agency. As already mentioned, the review of the
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inventory submittals using the check lists or SAM will be an
important Regional Office function. Both of these tasks include
resolution of any questions or errors with the State or local
agency.
The Regional Office should maintain contact with the
inventory preparation agency during the review process for quick
response to address questions and issues resulting from the
review. The Regional Office should provide final response with
recommendations on the inventory within 60 to 120 days of
receipt, unless the review requires especially laborious effort.
The basic OAQPS functions will include coordination of the
inventory review with the Regional Offices and resolution of
procedural or policy problems. The OAQPS review tasks begin when
the Regional Office has completed the primary review. While
application of the activity and reasonable range check lists will
be limited relative to that performed by the State or local
agencies or the Regional Offices, OAQPS will have available all
the inventories for comparison purposes. One area of comparison
will be the levels of emissions reported for the source
categories. For example, a range of reported values for each
category may be used to identify particularly high or low values
for purposes of additional review.
D. Developing Audit Procedures
There are two stages during the inventory development
process during which on site audits may be applied. The first is
during the inventory preparation period at which time the
auditing organization (i.e., Regional Office) can review the
procedures as applied by the State or local agency. The purpose
of this procedural audit is to assure that prescribed inventory
elements are being considered and incorporated into the inventory
development program. An audit will involve a visit by Regional
Office reviewers to the State or local agency responsible for the
inventory. Some assistance from OAQPS and QMS reviewers may be
considered appropriate. The auditors will review the emission
inventory quality assurance plan prepared by the State or local
agency with a view towards checking the inventory preparation
activities against the proposed QA plan.
The inventory preparation audit could coincide with another
planned visit to the State or local agency in order to
consolidate travel and conserve resources. A visit to every
State or local agency is desirable during this period, but the
Regional Office may be able to keep track of inventory
preparation progress through other means (e.g., frequent
telephone conferences) in order to conserve travel resources.
The second phase of the program during which audit visits
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inventory to the Regional Office. The purpose of a postsubmittal
audit is similar to that of the presubmittal audit, that is, to
assure that the inventory requirements have been addressed in the
inventory submittal. The postsubmittal audit may be most
appropriately applied for a State or local agency preparing the
inventory not easily checked with the QA/QC tools provided by
OAQPS (e.g., without using the SAM PC system).
The audit visit will include interviews with persons
responsible for collecting the inventory data, assimilating the
source and emissions information, calculating the emissions, and
preparing the inventory report. The purpose of the interviews
will be to establish that the agency is following or has followed
the procedures outlined- in the QA plan and the specified
requirements in preparing the inventory. At a minimum the audit
will include procedures to address the following:
1. Comparison of the emission inventory components to the
specified requirements.
2. Completeness of the inventory in terms of the source
categories addressed.
3. Adequacy of the base year selection.
4. General quality of the inventory as determined by
comparison to the QA/QC check list.
5. Necessary disaggregation of the inventory summary by
source category to allow for evaluating the emission
estimations.
6. Adequacy of supporting documentation including
calculations or other emission determinations.
A more complete audit of the inventory inputs is not within
the scope of this project. Such an audit would include a repeat
of all or part of the emission inventory including surveying the
sources, collecting source and emission data, assimilating the
data, calculating the emission rates, and comparing the results
with the submitted inventory.
Not all agencies submitting emission inventories will be
subjected to the on site audit. EPA must prepare a scheme for
selecting which agencies and submitted inventories will be
audited. The criteria for selecting the audit sites, in order of
most likely to least likely to be audited, include:
1. State or local agencies submitting inventories in hard
copy or on computer tape in formats not compatible with
the SAM PC system.
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Emission inventories submitted in hard copy only or on
computer tapes not in readily reviewable formats present a
particular problem to the Regional Office and headquarters
reviewers. The reviewers can not apply the QA/QC check list
easily nor can the inventory be input to the AIRS data base
without a complicated "bridge" computer program specifically
developed for each inventory. The Regional Office and
headquarters reviewers must then conduct the inventory
completeness and requirements checks manually. Such
detailed, manual reviews would be facilitated by direct
contact with the inventory preparers during an on site
audit.
2. State or local agencies submitting inventories in
formats compatible with the SAM PC system.
Some States have indicated that their inventories are to be
prepared using a computer-based program the output of which
can be edited to be compatible with the SAM PC system
format. Inventories submitted in such formats can be
reviewed in the Regional Office or at headquarters in much
the same manner as for inventories submitted in the SAM PC
system format. One difference will be that the PC computer
check list incorporated into the SAM PC system may not be
applicable for such inventories because of format
differences. Instead, the manual check list with the QA/QC
elements incorporated into the SAM PC system must be
applied. Such manual checks are more easily completed in
cooperation with the inventory preparers.
3. State or local agencies using the SAM PC system in
preparing the inventory.
The SAM PC system incorporates many of the completeness
checks that would be reviewed during a postsubmittal audit.
In addition, the SAM PC system is designed to be compatible
with NEDS and AIRS data input formats. While use of the SAM
PC system would not guarantee that the submitted inventory
addresses all of the post-1987 O3/CO SIP requirements (e.g.,
completeness of source coverage), such inventories will be
more easily reviewed in the Regional Office or at
headquarters than inventories submitted in other formats.
Responsibility for primary contact with the State or local
agency will belong to the Regional Office. In preparation for a
presubmittal audit, the Regional Office should obtain and review
the State or local agency's QA/QC plan and identify the persons
primarily responsible for the inventory preparation. The on site
visit should focus on discussions with the inventory preparers
16
-------
about the procedures being applied and corrections needed as
identified in the QA/QC plan review.
In preparation for the postsubmittal on site visit, the
Regional Office will prepare a summary of the inventory review
results. This review should include review of the QA/QC plan,
completed inventory activity and reasonable range check lists,
accounts of problems encountered during the inventory development
and accompanying resolutions, and administrative information
regarding the contacts at the State or local agency.
The Regional Office will be responsible for conducting the
audit visit focusing on the elements established for the
interview. Problems arising from the audit visit should be
resolved as soon as possible, preferably on site. The Regional
Office will prepare an audit summary report describing the
results of the site visit and conclusions about the quality of
the inventory.
OAQPS will provide guidance for audit review procedures, as
needed, based on identification of the review elements. OAQPS
will work with Regional Offices to prepare audit selection
criteria and assist in selecting audit sites. OAQPS will assist
in the conduct of the audit visit including active participation
when possible, resolution of technical and policy issues, and
evaluation of the quality of the inventory as a result of the
audit.
IV. QA/QC Report
A. Periodic Report
A periodic assessment of the QA/QC activities with regards
to the emission inventories is necessary in order to identify
areas for additional attention. These assessments of the
emission inventory QA/QC activities will address the completeness
of the inventory results for both the percentage of responses to
the SIP calls and the degree of source category coverage. Also
addressed in the periodic assessment reports will be the quality
of the inventory submittals and in particular the results of the
inventory reviews and audits. Significant problems and
corrective actions shall be described in the reports.
B. Reporting Responsibilities
The Regional Offices will be responsible for providing
monthly progress updates covering the areas listed and for
submitting the monthly reports to MRB. These updates need not be
in writing but may be in the form of telephone conferences
between the Regional Office and OAQPS beginning with the first
17
-------
submittals of the emission inventories. Regional Offices will be
responsible for initiating the telephone conferences.
Regional Offices should notify MRS immediately of the
occurrence of critical problems or changes in the inventory
program. Such occurrences would include change in staff
responsibilities within the Regional Office, failure of a State
or local agency to respond to directives on corrective actions,
or inability of the State or local agency to gather critical
inventory information or data. The Regional Office should be
monitoring inventory preparation activities prior to submittal.
OAQPS will prepare monthly report summaries of Regional
Office activities and inventory quality for distribution to TSD,
AQMD, OMS, and the Regional Offices. Review of the submitted
reports and responses to noted trouble areas will be major
responsibilities within OAQPS. OAQPS will also be responsible
for a final summary report to be prepared at completion of the
emission inventory activities, i.e., when SIP submittals have
been completed and approved. The final report will summarize the
progress of the inventory development QA/QC program and the final
products and an evaluation of the overall quality of the
inventories.
18
-------
V. References
A. Emission Inventory Requirements for Post-1987 Ozone
State Implementation Plans. EPA-450/4-88-019, U.S.
Environmental Protection Agency, Research Triangle
Park, NC, December 1988.
B. Emission Inventory Requirements for Post-1987 Carbon
Monoxide State Implementation Plans, EPA-450/4-88-020,
U.S. Environmental Protection Agency, Research Triangle
Park, NC, December 1988.
C. Procedures for the Preparation of Emission Inventories
for Precursors of Ozone. EPA-450/4-88-021, U.S.
Environmental Protection Agency, Research Triangle
Park, NC, December 1988.
D. Procedures for Emission Inventory Preparation,, Volume
IV; Mobile Source. EPA-450/4-81-026d, U.S.
Environmental Protection Agency, Research Triangle
Park, NC, September 1981. (Revisions currently
underway.)
E. Compilation of Air Pollutant Emission Factors, Fourth
Edition and Supplements, AP-42, U.S. Environmental
Protection Agency, Research Triangle Park, NC,
September 1985.
F. Guidelines for Review of Highway Source Emission
Inventories for 1982 SIPs. EPA-400/12-80-002, U.S.
Environmental Protection Agency, Washington, DC,
December 1980.
G. Highway Statistics. U.S. Department of Transportation,
Federal Highway Administration, Washington, DC. Annual
publication.
19
-------
APPENDIX A
Draft Check List For Reviewing Post-1987
Ozone SIP Emission Inventory Activities
-------
CHECKLIST OF '87 O, SIP INVENTORIES
Note: "Post '87 requirements" refers to Emission Inventory
Requirements For Post '87 Ozone State Implementation
Plans.
1. VOC/NOX/CO Summary Tables
a. Does the submittal contain completed VOC/NO^CO summary
tables, per Table 1 in Post '87 Requirements, for:
i. the base year inventory (draft inventory)?
i_| Yes |_| No
ii. the base line projection year inventory (final
inventory)?
Ill Yes HI No
Comment?
b. If the suggested format is not followed, is a format
used that contains equivalent information?
Jlj Yes !I| No
Comment?
c. In the VOC/NOX/CO summary tables, is the attainment
year specified?
}~| Yes |~| No Year? 19
Comment?
-------
d. In the VOC/NO,,/CO summary tables, is the point/area
source distinction made?
II! Yes j~j No
Comment?
e. In the VOC/NOX/CO summary tables, have the emissions
been seasonally adjusted?
HI Yes |~j No
Comment?
f. Have the suggested RACT source category distinctions
been maintained?
Ill Yes |lj No
Comment?
Are emissions reported as reactive VOC?
HI Yes |~| No
Comment?
h. Is the geographical area specified?
HI Yes HI No
Comment?
-------
2. Point Source Listing
a. Does the submittal contain a point source listing, per
Table 2 in Post '87 Requirements, for the base year?
j~| Yes |~j No
Comment?
b. Are the principal operations specified with
corresponding emission totals?
ill Yes ill No
Comment?
3. Documentation - General Considerations
a. Is there documentation accompanying the summary tables
and point source listing?
Yes j_| No
Comment?
b. Does the documentation specify who did the inventory?
\~\ Yes Jl| No
Comment?
-------
c. Does the documentation define the area covered by the
inventory?
j_j Yes j_j No
Comment?
d. Does the documentation tell how nonreactive VOC were
excluded from the emission totals?
II! Yes HI No
Comment?
e. Does the documentation describe how the seasonal and
weekday adjustments were made?
Jlj Yes HI No
Comment?
4. Specific Documentation - Point Sources
a. Are point source cutoff levels defined?
ill Yes j~| No
What are they? _ Do they exceed 25 kg/day
(10 TPY) for VOC or 250 kg/day (100 TPY) for NO, or CO?
I I V<=><: I I
Comment?
-------
b. Has the inventory been scaled up in some manner to
account for points emitting less than the cutoff
level(s)?
j~| Yes !lj No
Comment?
c. Do all major point source categories appear to be
included?
j~| Yes j~j No
Have all VOC and NOX emission source categories in
NAPAP inventory been addressed in SIP inventory?
ill Yes Hi No
Comment?
d. Have material balance techniques been used to estimate
VOC emissions from solvent-using facilities?
J Yes ~ No
Have source test results been used to identify
emissions?
HI Yes j-j No
Typical age range if source test data:
Comment?
e. Are summer conditions of higher temperatures (and
appropriate Vapor Pressures for gaoline) reflected in
the VOC emission estimates made for petroleum product
marketing and storage operations?
Hi Yes j~| No
-------
Do other volatile organic chemical storage calculations
use appropriate temperature and throughput assumptions?
Ill Yes |I! No
Comment?
f. Are the latest (through Fourth Edition, Supplement B:)
AP-42 emission factors used for calculating VOC
emission estimates for petroleum product marketing and
storage operations?
Jlj Yes Jl! No
Have "gapfilling" emission factors from NAPAP been
used?
HI Yes Hi No
Comment?
Is the SIP emission inventory produced from a computer
data base?
Hi Yes Hi No
If so, what emission inventory system is used? (e.g.,
SAM/EIS/P&R) . Are example emission
calculations shown for several major point source
categories?
II! Yes jll No
Comment?
-------
5. Specific Documentation - Area Sources
a. Are all of the major area sources listed in Table
4.1-1 of Procedures For The Preparation Of Emission
Inventories For Volatile Organic Compounds. Volume I,
(Third Edition) included in the inventory?
Hi Yes Hi No
Comment?
When certain facilities within one of the source
categories listed in Table 4.1-1 are covered as point
sources, have the associated emissions been subtracted
from those emissions estimated for the corresponding
area source category?
II VOG II Mo
,_( xes ,_| NO
Comment?
c. Have the per capita factors from Procedures For The
Preparation Of Emission Inventories For Volatile
Organic Compounds. Volume I, (Third Edition) been used
to compute emissions?
II! Yes HI No
If not, have techniques been used that appear to be
technically sound, and are these alternate methods
documented?
\~\ Yes HI No
Comment?
-------
d. Has local activity levels information been used?
j~J Yes j~| No
Comment?
Does gasoline usage fall in the range of 400 to 800
gallons per capita per year?
j_j Yes Jlj No
Are emissions included from underground tank breathing
and trucks in transit?
HI Yes ilj No
Comment?
f. Have the technical points in Attachment I of the check
list (regarding per capita factors) been considered?
HI Yes Jlj No
Comment?
6. Specific Documentation - Highway Vehicles
Is the following information reported?
a. Description of procedures and models used to estimate
base year and future year transportation parameters.
J~| Yes |Ij No
Comment?
-------
b. Description of the travel data base and any subsequent
updates. When possible, estimates of the degree of
accuracy and other statistical parameters should be
included.
Jli Yes \~\ No
Comment?
c. Description of traffic counting programs. Estimates of
the degree of accuracy of VMT estimates based on
traffic counts should be included.
ili Yes Jlj No
Comment?
d. Description of methods used to estimate vehicle speeds.
Special speed studies should be documented.
Yes i No
Comment?
e. Description of methods for estimating traffic
parameters (VMT, speed, etc.) for local (off -network)
traffic.
Yes J! No
Comment?
-------
f. Description of methods used to estimate vehicle hot and
cold start soak emissions.
Hi Yes \~\ No
Comment?
Description of methods used to calculate emissions,
including a description of how data were aggregated and
emission factors applied.
ill Yes Jl| No
Comment?
h. Description of how other emission parameters (such as
vehicle age distribution, average annual miles driven
by model year) were obtained.
\~\ Yes Hi No .
Comment?
7. Specific Documentation - Projections
a. Does the inventory submittal specify how growth is
incorporated into the baseline projection inventory?
Hi Yes j"j No
Comment?
-------
b. Are the population projections used in the SIP
inventory consistent with those projections used in
water quality planning and design of wastewater
treatment facilities?
HI Yes |I| No
Comment?
Are reasonable surrogates used for "growing" activity
levels and emissions, such as those indicators shown in
Procedures For The Preparation Of Emission Inventories
For Volatile Organic Compounds, Volume I, (Third
Edition)?
HI Yes |I| No
Comment?
d. Does the baseline projection take into account
"on-the-books" control measures, specifically those in
earlier SIPS (1979, 1982)?
HI Yes }~J No
Comment?
e. Are specific examples shown of how projections were
made for specific source categories?
Hi Yes HI No
Comment?
-------
f. Are projections for very large .VOC emitters generally
considered on a plant-by-plant basis rather than in
aggregate?
|~j Yes |~j No
Comment?
8. Specific Documentation - Quality Assurance
a. Has a quality assurance effort been made?
Hi Yes Jlj No
Comment?
b. Were the RACT or other industrial directories compared
with the point source file to determine the possibility
of missing sources?
j~j Yes Jlj No
Comment?
c. Were emissions data and point source listings compared
with other emissions inventories (i.e., 1985 NAPAP)?
Hi Yes j~j No
Comment?
-------
d. If the emission inventory was developed from a computer
data base (mainframe, mini, micro, or PC), are the
emission factor files used in calculations referenced
(i.e., AP-42, source specific test, other)?
Hi Yes Hi No
Are nonhighway area source inventory equations used
in the file documented or referenced?
Hi Yes Hi No
Comment?
e. Are any data reasonableness checks made on emissions
(i.e., comparison with national or regional averages)?
Jli Yes Jl! No
Comment?
f. Do the base year travel and emission estimates fall
within the ranges presented in Guidelines For Review Of
Highway Emission Inventories For 1982 SIPs
(EPA-400/12-80-002)?
j~! Yes Hi No
Comment?
-------
APPENDIX B
Draft List Of Point Source Categories
For Inclusion In Post-1987
Ozone SIP Emission Inventories
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY^
STORAGE, TRANSPORTATION AND MARKETING OF PETROLEUM PRODUCTS AND
VOLATILE ORGANIC LIQUIDS
1. Oil and Gas Production
Detailed emissions from well head to load-out, including process
sources, storage, fugitive and handling
2. Petroleum Product and Crude Oil Storage
Fixed Roof Tanks
External Floating Roof Tanks
Primary Seals
Secondary Seals
Internal Floating Roof Tanks
Leaks from Valves, Flanges Meters, Pumps
3. Bulk Terminals
Fixed Roof Tanks
External Floating Roof Tanks
Primary Seals
Secondary Seals
Internal Floating Roof Tanks
Leaks from Valves, Flanges Meters, Pumps
Vapor Collection Losses
Filling Losses from Uncontrolled Loading Racks
Tank Truck Vapor Leaks from Loading of Gasoline
Non-Tank Farm Storage
A. Bulk Plants
Fixed Roof Tanks
External Floating Roof Tanks
Primary Seals
Secondary Seals
Internal Floating Roof Tanks
Loading and Unloading Racks
Tank Truck Vapor Leaks
Leaks from Valves, Flanges Meters, Pumps
5. Volatile Organic Liquid Storage and Transfer
Fixed Roof Tanks
External Floating Roof Tanks
Primary Seals
Secondary Seals
Internal Floating Roof Tanks
Loading and Unloading Racks
Tank Truck Vapor Leaks
Leaks from Valves, Flanges Meters, Pumps
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
STORAGE, TRANSPORTATION AND MARKETING OF PETROLEUM PRODUCTS AND
VOLATILE ORGANIC LIQUIDS (Continued)
6. Vessels
Petroleum Products and VOL Loading - Barge
Petroleum Products and VOL Loading - Tanker
Crude Oil Ballasting - Tanker
7. Barge, Tanker, Tank Truck and Rail Car Cleaning.
8. Barges, Tankers, Tank Trucks and Rail Cars in Transit
9. Service Station Loading (Stage I)
10. Service Station Loading (Stage II)
11. Formulation and Packing VOL for Market
12. Local Storage (airports, industries that use fuels, solvents and
reactants in their operation).
INDUSTRIAL PROCESSES
1. Petroleum Refineries
Process Drains ans Wastewater Separators
Vacuum Producing Systems
Process Unit Turnarounds
Fugitive Leaks from Seals, Valves, Flanges, Pressure Relief
Devices and Drains
Petroleum Coking
Cooling Towers
Secondary Losses (Wastewater - Solid Waste)
Other Process Emissions such as Heaters, Boilers, Catalytic
Cracker Regenerators (specify) ,
2. Natural Gas and Petroleum Product Processing
3. Lube Oil Manufacture
4. Organic Chemical Manufacture
Fugitive Leaks from Seals, Valves, Flanges, Pressure Relief
Devices and Drains
Air Oxidation Units
Storage and Transfer
Wastewater Separators
Handling
Secondary Losses (Wastewater - Solid Waste)
Other Process Units (specify)
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL PROCESSES (Continued)
5. Inorganic Chemical Manufacture
Fugitive Leaks from Seals, Valves, Flanges, Pressure Relief
Devices and Drains
Storage and Transfer
Clean Up
Secondary Losses (Wastewater - Solid Waste)
Other Process Units (specify)
6. Iron & Steel Production
Sintering
Electric Arc Furnaces
Other Process Units (specify)
Secondary Losses (Wastewater - Solid Waste)
7. Coke Production
Coke Pushing
Coke Oven Doors
Coke Charging
Coke Preheater
Topside Leaks
Quenching
Battery Stacks
Secondary Losses (Wastewater - Solid Waste)
8. Coke By-Product Plants
Collection Leaks
Primary Cooler
Ammonia Stills
Light Oil Scrubbers
Tar Precipitators
BTX Stills
Tar Decanters
Secondary Losses (Wastewater - Solid Waste)
Other Unit Operations (specify)
9. Synthetic Fiber Manufacture
Dope Preparation
Filtration
Fiber Extrusion - Solvent Recovery
Takeup Stretching, Washing, Drying, Crimping, Finishing
Fiber Storage - Residual Solvent Evaporation
Equipment Leakage
Solvent Storage
Secondary Losses (Wastewater - Solid Waste)
Other Process Units (specify)
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL PROCESSES (Continued)
10. Polymers and Resins Manufacture
Catalyst Preparation
Reactor Vents
Separation of Reactants, Solvents, Diluents from Product
Raw Material Storage
Solvent Storage
Handling
Equipment Leakage
Secondary Losses (Wastewater - Solid Waste)
Other Process Units (specify)
11. Plastic Products Manufacture
Mold Release
Solvent Consumption
Adhesive Consumption
Adhesives Preparation
Fiber Storage - Residual Solvent Evaporation
Secondary Losses (Wastewater - Solid Waste)
Other Process Units (specify)
12. Fermentation Processes
Fermentation Tank Venting
Aging (Wine or Whiskey)
Drying/Conditioning Used Grain
Bottling
Clean Up
Secondary Losses (Wastewater - Solid Waste)
Other Process Units (specify)
13. Vegetable Oil Processing
Oil Extraction and Desolventation
Meal Preparation
Oil Refining
Fugitive Leaks
Solvent Storage
Secondary Losses (Wastewater - Solid Waste)
Other Process Units (specify)
14. Pharmaceutical Manufacturing
Process Units such as Vacuum Dryers, Reactors, Distillation
Units, Filters, Extractors, Centrifuges, Crystalliaers
Major Production Equipment such as Exhaust Systems and Air Dryers
Storage and Transfer
Fugitive Leaks
Packaging
Secondary Losses (Wastewater - Solid Waste)
Other Process Units (specify)
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL PROCESSES (Continued)
15. Rubber Tire Manufacture
Undertread and Sidewall Cementing
Bead Dipping
Bead Swabbing
Tire Building
Tread End Cementing
Green Tire Spraying
Tire Curing
Solvent Mixing
Solvent Storage
Retreaders
Secondary Losses (Wastewater - Solid Waste)
Other Process Units (specify)
16. SBR Rubber Manufacture
Slowdown Tanks
Steam Stripper
Prestorage Tanks
Secondary Losses (Wastewater - Solid Waste)
Other Process Units (specify)
17. Ammonia Production
Desulfurization Unit Generation
Primary Reformer, Heater Fuel Combustion
Carbon Dioxide Regenerator
Condensate Steam Stripper
18. Carbon Black Manufacture
Main Process Vent
Flare
CO Boiler
Solid Waste Generator
19. Phthalic Anhydride Production
Oxidation of o-Xylene
Main Process Stream
Pretreatment
Distillation
Oxidation of Naphthalene
Main Process Stream
Pretreatment
Distillation
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL PROCESSES (Continued)
20. Terephthalic Acid Production
Reactor Vent
Crystallization, Separation, Drying
Distillation and Recovery
Product Transfer
21. Maleic Anhydride Production
Storage
Fugitive Leaks
Other Process Units (specify)
22. Pulp and Paper Mills v
23. Primary and Secondary Metals Production
24. Plywood, Particle Board, Pulp Board, Chip or Flake Wood Board
A
25. Charcoal Production
26. Carbon Electrode and Graphite Production
27. Paint, Varnish and Other Coatings Production
28. Adhesives Production
29. Printing Ink Manufacture
30. Scrap Metals Clean Up
31. Adipic Acid Proction
32. Coffee Roasting
33. Grain Elevators (fumigation)
34. Meat Smokehouses
35. Asphalt Roofing Manufacture
36. Bakeries
37. Fabric, Thread and Fiber Dying and Finishing
38. Glass Fiber Manufacture
39. Glass Manufacture
B-
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL PROCESSES (Continued)
40. Soaps, Detergents and Cleaning Agents Manufacturing, Formulation
and Packaging
41. Food and Animal Feedstuff Processing and Preparation
42. Bricks and Related Clays
INDUSTRIAL SURFACE COATING
1. Large Appliances
Cleaning and Pretreatment
Prime Spray, Flow or Dip Coating Operations
Topcoat Spray
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
2. Magnet Wire
Cleaning and Pretreatment
Coating Applications and Curing
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
3. Autos and Light Trucks
Cleaning and Pretreatment
Prime Application, Electrodeposition, Dip or Spray
Prime Surface Operations
Topcoat Operation
Repair Topcoat Application Area
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
4. Cans
Cleaning and Pretreatment
Two Piece and Exterior Base Coating
Interior Spray Coating
Sheet Basecoating (Interior)
Sheet Basecoating (Exterior)
Side Seam Spray Coating
End Sealing Compound
Lithography
Overvarnish
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL SURFACE COATING (Continued)
5. Metal Coils
Prime Coating
Finish Coating
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
6. Paper/Fabric
Coating Operations
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
7. Wood Furniture
Coating Operations
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
8. Metal Furniture
Cleaning and Pretreatment
Coating Operations
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
9. Miscellaneous Metal Parts and Products
Cleaning and Pretreatment
Coating Operations, Flow, Dip, Spray
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
10. Flatwood Products
Filler
Sealer
Basecoat
Topcoat
Inks
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
INDUSTRIAL SURFACE COATING (Continued)
11. Plastic Products
Cleaning and Pretreatment
Coating Operations, Flow, Dip, Spray
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
12. Large Ships
Cleaning and Pretreatment
Prime Coat Operation
Top Coat Operation
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process. Units (specify)
13. Large Aircraft
Cleaning and Pretreatment
Prime Coat Operation
Top Coat Operation
Coating Mixing
Coating and Solvent Storage
Equipment Clean Up
Other Process Units (specify)
NONINDUSTRIAL SURFACE COATING
1. Architectural Coatings
2. Auto Refinishing
OTHER SOLVENT USE
1. Degreasing
Cold cleaning
Vapor Degreasing
Conveyorized Degreasing
2. Dry Cleaning
Perchloroethylene
Petroleum Solvents
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
OTHER SOLVENT USE (Continued)
3. Graphic Arts
Letterpress
Rotogravure
Offset Lithography
Ink Mixing
Solvent Storage
Flexography
Equipment Clean Up
A. Adhesives
Adhesive Application
Solvent Mixing'
Solvent Storage
Packaging
Equipment Clean Up
Other Process Units (specify)
5. Solvent Extraction Processes
6. Cutback Asphalt
7. Consumer/Commercial Solvent Use
Paints, Primers, Varnishes
Hair Sprays
All Purpose Cleaners
Insect Sprays
Car Polishes and Waxes
Room Deodorants and Disinfectants
Window and Class Cleaners
Caulking and Sealing Compounds
Moth Control Products
Herbicides, Fungicides
Carburetor and Choke Cleaners
Auto Antifreeze
Personal Deodorants
Brake Cleaners
Adhesives (Consumer)
Engine Starting Fluids
Lubricants and Silicones
Engine Degreasers
Metal Cleaners and Polishes
Rug and Upholstery Cleaners
8. Asphalt Roofing Kettles
9. Pesticide Application
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
EXTERNAL COMBUSTION SOURCES
1. Industrial Fuel Combustion
2. Coal Cleaning
Fluidized Bed
Flash
Multilouvered
3. Electrical Generation
4. Commercial/Institutional Fuel Combustion
5. Residential Fuel Combustion v
6. Resource Recovery Facilities
7. Solid Waste Disposal
On-Site Incineration
Open Burning
Prescribed Burning
Structural Fires
Wildfires
8. Recycle/Recovery (Primary Metals)
Auto Body Incineration
Drum Cleaning
9. Sewage Sludge Incinerators
STATIONARY INTERNAL COMBUSTION
1. Reciprocation Engines
2. Gas Turbines
WASTE DISPOSAL
1. Publicly Owned Treatment Works
2. Industrial Wastewater Treatment
3. Municipal Landfills
-------
TABLE B-l. INDIVIDUAL SOURCE SUMMARY (Continued)
WASTE DISPOSAL (Continued)
4. Hazardous Waste Treatment, Storage and Disposal Facilities
Landills
Landfarms
Surface Impoundments
Storage
Incinerators
Leaking Undergroud Storage Tanks
Wastepiles
MOBILE SOURCES
1. Highway Vehicles
Light Duty Autos
Light Duty Trucks
Heavy Duty Autos
Heavy Duty Gasoline Trucks
Heavy Duty Diesel Trucks
Motorcycles
2. NonHighway Vehicles
Railroad Locomotives
Aircraft
Military
Civil
Commercial
Vessels
Motorboats
Off-Highway Motorcycles
Construction Equipment
Industrial Equipment
Farm Equipment
Lawn and Garden Equipment
Snowmobiles
Orchard Heaters
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APPENDIX C
Transferring Inventory Data to EPA Data Base
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Transferring Inventory Data to EPA Data Base
One objective not mentioned in the scope of this program but
important in the management of the inventories is to provide
means to transfer the emission inventory data to the Aerometric
Information Retrieval System (AIRS) so that the data may be
available for additional evaluations. Specifically, OAQPS
planners intend to use the inventory data for comparing
inventories from different localities, analyzing consistency of
control strategies, track reasonable further progress, model
attainment projections, evaluate emission trading and bubble
policies, and evaluate alternative growth factors on a national
basis. These types of evaluations are possible only if the
inventory data are available from a retrievable computer data
storage program. The AIRS program is intended to meet these
needs and provide access to inventory and other aerometric
information to State and local agencies, as well.
The first item in the task to transfer the inventory data to
AIRS is to establish the level of detail from the inventories
that must be recorded. The issues that must be addressed include
recording of category summary results versus individual source
emission data, storing annual emission averages versus peak ozone
season weekday or hourly data, and storing summary emission rates
versus category data for stationary area and mobile sources. The
criteria used to establish the level of detail to be recorded for
each section or category of the inventory may depend on the final
post-1987 O3/CO SIP policy and the potential for applying
emission control regulations.
The level of detail specified for data storage and retrieval
capabilities defines part of the task to transfer the inventory
data to AIRS. The second item in this task is to establish
mechanisms for transferring the inventory data from the
submittals to AIRS. Several means for transferring the inventory
data are available. These include:
1. Emission inventories submitted on the SAM PC system can
be transferred to AIRS after assuring that inventory
data elements are common to both systems and data
formats are compatible.
Incorporation of the capability in the SAM PC system to
transfer the inventory data to AIRS will require knowledge
of the AIRS data format for all source categories. Such
information is available for some categories (e.g., large
point sources), but AIRS capabilities to assimilate the
emission data for area and mobile sources are under
development and scheduled for completion in the summer of
1992. The SAM PC system will likely act as data storage for
much of the post-1987 O3/CO SIP emission inventory until
AIRS is completed and the data transfer format can be
defined. Once the transfer details are known, incorporation
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of the transfer language into the SAM PC system should
proceed quickly providing the most expeditious means for
handling the emission inventory transfer to a common data
base.
2. Emission inventories submitted in formats compatible
with the SAM PC system can be transferred to SAM and
then to AIRS once the AIRS data base is completed.
Alternatively, the emission inventory submittals may be
transferred directly to AIRS after assuring the
inventory data elements and formats are common to both.
As noted above, several State agencies have indicated
intention to submit PC compiled emission inventories in
formats compatible with the formats in the SAM PC system.
The technical problems associated with transferring
inventories submitted .in this fashion are similar to those
described for the SAM PC system above. Transferring the
data directly from the submittal to AIRS is preferable to
using the SAM PC system as a conduit because the opportunity
for data transfer errors would be reduced.
3. Emission inventories submitted in hard copy or on
computer format not compatible with the SAM PC system
must be transferred to AIRS via a computer bridge
program.
The post-1987 O3/CO SIP requirements do not include that
submittals be in a common format. The result will be that
some State and local agencies will submit emission
inventories in formats not compatible with the data base
system EPA plans to use for storing the emission inventory
data. The means to transfer data from incompatible formats
to AIRS must be tailored to each of such submittals. The
headquarters organization responsible for developing the
computer bridge programs must be determined in order that
the responsible
group can begin work with the State and local agencies in
designing appropriate programs.
The capability for States or local agencies responsible for
the inventories to enter the data directly to AIRS would be the
preferred approach. Having access to the AIRS directly would aid
the States by providing a common useable format for submittal and
retrieval. OAQPS reviewers would find that direct submittal
provides for fewer data transfer errors in the emission
inventories. In order to meet the needs for inventory review,
AIRS would have to be modified to include the QA/QC checks
incorporated in the SAM PC system and other inventory
requirements checks as discussed above.
OAQPS will be responsible for providing the means to
transfer the emission inventory data to AIRS. Mechanisms for
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accomplishing this goal include modification of the SAM PC system
to allow direct transfer to AIRS, preparing PC procedures for
transferring inventories on PC programs compatible with SAM to
SAM and then to AIRS, and developing individual computer programs
for transferring other inventories not on SAM or compatible
systems to AIRS. OAQPS will work with State and local agencies
to coordinate computer programming needs.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/4-89-004
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
5. REPORT DATE
Quality Assurance Program For Post-1987 Ozone
And Carbon Monoxide State Implementation Plan
Emission Inventories
IQfiQ
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
Peter R. Westlin
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency (MD-14)
Research Triangle Park, NC 27711
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document is to outline the program for implementing the quality
assurance and quality control (QA/QC) requirements and the QA/QC tools '
for the "State and local agencies and EPA to apply in preparing and
reviewing O3/CO SIP emission inventories to ensure that, the inventories 1
meet minimum QA/QC requirements. The document describes responsibilitie
of State and local agencies, Regional Offices, and EPA headquarters in
efforts to ensure minimum acceptable levels of data quality.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Quality Assurance
State Implementation Plans
Ozone
Carbon Monoxide
Emissions Inventory
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (TltisReport)
20. SECURITY CLASS (Tliispage)
21. NO. OF PAGES
&Q-
22. PRICE
EPA Form 2220-1 (R»v. 4-77) PREVIOUS EDITION is OBSOLETE
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